Nova Ljubljanska Banka Annual Report 2024

FY2024 Annual Report · Nova Ljubljanska Banka

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NLB Group Annual Report 2024

NLB Group
Annual Report 2024
2
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Report format
The Annual Report in PDF format represents its unofficial version. The Annual Report
in European Single Electronic Format (ESEF) is pursuant to Commission Delegated
Regulation (EU) 2019/815 and paragraph one of Article 134 of the Market in Financial
Instruments Act (ZTFI-1) and represents its official version published on SEOnet.
Forward-looking statements
The expectations, forecasts and statements regarding future developments that are
contained in this report are based on assumptions and are contingent on a number of
factors that will come into play in the future. Consequently, the actual situation may turn
out to be different.
Contents
OVERVIEW. . . . . . . . . . . . . . . . . . . . . . . . 3
NLB Group at a Glance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Statement by the Management Board of NLB. . . . . . . . . . 5
Statement by the Chairman
of the Supervisory Board of NLB. . . . . . . . . . . . . . . . . . . . . . . 8
This is where our community thrives.. . . . . . . . . . . . . . . . . . 10
Key Highlights. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Key Events. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Shareholder Structure and Market Performance
of NLB’s Shares and GDRs. . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Macroeconomic Environment. . . . . . . . . . . . . . . . . . . . . . . . . 23
Regulatory Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
BUSINESS REPORT . . . . . . . . . . . . . . . 31
Strategy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Funding Strategy, MREL Compliance, and Capital. . . . . 34
Risk Factors and Outlook. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
Overview of Financial Performance. . . . . . . . . . . . . . . . . . . 44
Segment Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
NLB Group Key Members. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
Risk Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
IT and Cyber Security. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109
Human Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113
Corporate Governance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115
Compliance and Integrity. . . . . . . . . . . . . . . . . . . . . . . . . . . 125
Internal Audit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128
Corporate Governance Statements. . . . . . . . . . . . . . . . . 129
Disclosure on Shares and Shareholders of NLB. . . . . 154
Events after the End of the 2024 Financial Year. . . . . 156
Reconciliation of Financial Statements
in Business and Financial Part of the Report . . . . . . . . 157
Alternative Performance Indicators. . . . . . . . . . . . . . . . . 159
NLB Group Chart. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166
Organisational Structure of NLB. . . . . . . . . . . . . . . . . . . . 167
Sustainability Statement. . . . . . . . . . . . . . . . . . . . . . . . . . . . 168
FINANCIAL REPORT . . . . . . . . . . . . . 369
NLB Group Directory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 555
Definitions and Glossary of Selected Terms . . . . . . . . . 558

NLB Group
Annual Report 2024
3
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
With an in-depth understanding
of customer’s needs and business
environment, NLB Group charts
a path that ensures not only its
long-term development, but also
the development of wider economic
environment in our home region,
South-Eastern Europe. We invite you
to explore the key achievements,
financial performance, and strategic
objectives of NLB Group in 2024.
OVERVIEW

NLB Group
Annual Report 2024
4
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group at a Glance
Investment grade rating from
Moody’s (A3 long-term deposit rating
with positive outlook; as of 7 January
2025, solicited rating) and from
Standard & Poor’s (long-term credit
rating at BBB with a stable outlook).
Strategic focus 2030
Sustainable banking
Total assets
EUR
3,411
million
EUR
1,245
million
more than
2. 9
million

8,322
EUR
28,035
million
A3
2024
A3
2023
Total capital
Total operating income
Number of active clients
Employees
Ratings
16. 0
2023
10. 5
2024
Vision
7
banks with
409
branches
5
leasing companies
3
asset management
companies
The Group will look after the financial needs of its clients and improve the quality of life
in its home region – South-Eastern Europe.
º In May 2024, the NLB Group
launched its NEW GROUP
STRATEGY 2030, which will ensure
the long-term development of
NLB Group and the broader
economic environment in
Southeastern Europe.
º Strategy 2030 foresees THE
DOUBLING OF NLB GROUP’S
BALANCE SHEET, REVENUES,
AND PROFIT BY 2030.
• Sustainability is integral to the new Group Strategy
and embedded in business processes.
• NLB Group is committed to the Paris Agreement with
a net-zero strategy to reduce emissions in lending,
investments, and operations.
• ESG Risk Rating: 10.5 (low risk), ranking us in the top 5th
percentile of global banks and earning Top Regional &
Top Industry badges.
Note: Number of active clients in NLB Group banking members. Core financial members include seven banks with 409 branches, five leasing companies and three asset management companies.

NLB Group
Annual Report 2024
5
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement by the Management Board of NLB
Esteemed Stakeholders,
By now, you know us well. You
know that our deepest commitment
extends to continuously providing our
customers with meaningful services
and; between maintaining stability
and fostering growth in the markets
of our operations, as well as driving
shareholder value and advancing
their interests. You also know that
we constantly strive to exceed
expectations and that we do not
shy away from seizing opportunities
that lie beyond not yet discovered
horizons. This was also the case for
NLB Group in 2024.
In the preceding year, we clearly and confidently
demonstrated our ambition that reaches beyond the
known by introducing NLB Group’s new business
strategy for the following five-year period – a
strategy designed to devote our Group and its talents
to growth and development in a rapidly changing
financial environment.
The strategy called "New Horizons" that was presented
during the second NLB Investor Day in May stipulates
that the Group’s ambition remains to create sustainable
growth to support individuals and businesses alike. It
foresees the doubling of the NLB Group’s balance sheet
(to more than EUR 50 billion assets), recurring revenues
of more than EUR 2 billion, and a profit of more than
EUR 1 billion by 2030, combining organic growth with
selected M&As in the targeted markets in South-Eastern
Europe (SEE) – our home region.
The strategy focuses on growth across three
pillars: Retail, Corporate and Investment Banking,
and Payments, along with operating platform
enhancement initiatives that enable their delivery. One
of the most prominent ones includes transitioning to a
fully digital business model, which includes leveraging
advanced technologies such as artificial intelligence,
cloud services, and data analytics.
We believe that with a thorough understanding of the
business environment and a prudent consideration of
the risks, the new business strategy paves a path that
will continue to justify the trust of our shareholders –
who will receive strong dividend payments – while at the
same time fosters long-term development of the Group
and, indirectly, also the wider economic environment
and society in our home region.
Hedvika Usenik
Member
Andrej Lasič
Member
Archibald Kremser
Member

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
However, the development of such an ambitious
business strategy has been supported by the strong
business results and milestones we have achieved in
recent years, including 2024. Global economic activity
held up well in the first half of the year but moderated
later; moreover, in the European Union especially
gave way to an evolving interest rate environment,
as well as structural changes such as digitalisation,
decarbonisation, and demographic shifts. Economic
growth, interest rate cuts, and the gradual disinflation
trends contributed to healthy credit activity and
demand for banking services in all client segments,
product lines, and geographies, which positively
impacted NLB Group’s operations. All of this activity
enabled the Group to reach EUR 515 million of net
income after tax, further strengthening market shares
across SEE geographies, with all banking members
reporting solid net earnings and contributing 58.1% to
the Group’s after-tax result.
The Group’s robust performance in 2024 generated
substantial value for our shareholders, as NLB
honoured its commitment by increasing its dividend
payment from the previous year’s distribution by 100%,
resulting in a combined EUR 220 million pay-out in two
tranches. The amount represents a 40% pay-out ratio
of the previous year’s profit after tax. Furthermore, the
Bank’s outlook for 2025 continues to surpass even this
percentage, while at the same time will strive to maintain
the capacity for organic and/or M&A-driven growth.
The June General Meeting that confirmed the first
dividend pay-out also confirmed rotations in the NLB’s
Supervisory Board, as the mandates of three members
expired in 2024. The General Meeting re-appointed
Primož Karpe (later also confirmed as Chairman for the
third time in a row) and appointed two new members,
namely Natalia Olegovna Ansell and Luka Vesnaver.
Also, in 2024, the NLB Workers’ Council appointed
Sergeja Kočar for another term as an employee
representative in the Supervisory Board.
When it comes to expansion through mergers and
acquisitions, NLB Group in 2024 marked another
milestone in its development and the services and
solutions it offers to its clients in the markets of SEE.
The Group successfully completed the transaction and
became the sole shareholder of SLS HOLDCO, Ljubljana
the parent company of Summit Leasing Slovenija,
Ljubljana and its Croatian subsidiary Mobil Leasing,
Zagreb, together forming SLS Group. This transaction
not only enabled NLB to become the leading provider
of leasing services on the Slovenian market, but
also marks NLB’s re-entry into the market of one of
Slovenia’s most important business partners, Croatia,
after three decades.
The Group also strengthened its position in its home
region by expanding its asset management into the
North Macedonian market by NLB Skladi, Ljubljana
acquiring Generali Investments, Skopje, later rebranded
to NLB Fondovi, Skopje. Furthermore, to consolidate
ownership of the asset management companies
within the NLB Group under the umbrella of NLB
Skladi, Ljubljana the ownership of the Serbian asset
management company KomBank Invest, Beograd was
also transferred and renamed to NLB Fondovi, Beograd.
In line with its new strategy of pursuing selected
M&As in the targeted markets, NLB also launched
an all-cash voluntary public takeover offer aimed at
acquiring control over Addiko Bank AG for all issued
and outstanding Addiko Bank AG shares. As at 16 August
2024, the offer had not achieved sufficient acceptance
declarations to reach the required acceptance threshold
of at least 75% of the issued shares, and so it was not
extended. NLB nevertheless remains committed to further
business development and delivering its new business
strategy, including possible other takeover opportunities.
Yet, in 2024, NLB was active not only on regional
financial but also on international capital markets,
successfully issuing EUR 300 million in 10NC5
subordinated Tier 2 notes in January to strengthen its
capital position, and EUR 500 million in 6NC5 senior
preferred notes in May for MREL purposes. The capital
position remains rock solid and well above regulatory
requirements, representing a firm foundation for further
value accretive growth at a maintained and attractive
dividend payout.
NLB’s successful capital markets activity was also
reflected in an ever more positive recognition of the
Bank and stronger confidence among professional
stakeholders and rating agencies. In June, therefore,
S&P affirmed NLB’s long-term credit rating BBB with
Peter Andreas Burkhardt
Member
Antonio Argir
Member
Blaž Brodnjak
Chief Executive Officer

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
a stable outlook, reflecting its expectation that NLB
will maintain solid financial performance over the next
12–24 months, while prudently expanding across its core
markets in Slovenia and SEE and integrating newly
acquired banks and non-banks. Later, in September,
Moody‘s indicated a low credit risk and strong financial
health. To top off these recognitions, the Ljubljana Stock
Exchange, which traditionally recognises excellence
among listed companies in various categories, has in
2024 once again awarded NLB the title of Prime Market
Stock of the Year.
In November, NLB Group also received a new,
significantly improved ESG Risk Rating of 10.5 by
Morningstar Sustainalytics, reflecting a low risk of
material financial impacts from ESG factors. The rating
places NLB Group in the top 5th percentile of all banks
assessed by the rating company.
We are proud that our sustainability performance
has been acknowledged once again, as we recognise
sustainable practices as key drivers of our long-
term business success. The Group’s commitment to
sustainability extends across all its markets in SEE
and three pillars: sustainable operations, sustainable
finance, and contribution to society. As a systemically
important financial institution in the region, NLB Group
has set the goal to actively contribute to the sustainable
transformation of the economy and society towards a
greener, fairer, and more inclusive future. Therefore, the
Group has integrated a sustainability perspective and
ESG factors into its new business strategy and daily
operations. Guided by the strategy, UN Principles for
Responsible Banking, the Net Zero Banking Alliance,
the Paris Agreement goals, and the United Nations’
Sustainable Development Goals, NLB Group actively
manages its sustainability-related impacts, and
financially material risks and opportunities. These stem
from climate change, human capital, corporate culture
and governance, digitalisation, broader societal issues,
and other important sustainability-related topics.
We are aware, however, that financial institutions also
hold an important social function. Therefore, through
corporate social responsibility activities, NLB Group
also actively contributes to wider socio-economic
development and an improved quality of life in our
home region. This involves supporting communities
with donations and initiatives such as NLB Youth
Sports, promoting financial literacy, endorsing
sports and culture, aiding affected communities
when natural disasters hit, such as during October’s
devastating floods in Bosnia in Herzegovina, and
ensuring responsible relations with employees. The
latter was once again recognised in 2024 by the Top
Employers Institute, which awarded NLB the prestigious
Top Employer certificate for the 9th consecutive year.
Additionally, the bank was once again, for the 13th
consecutive year, awarded as a Family-Friendly
Company with special recognition for promoting the
culture of a family-friendly company in Slovenia.
All these achievements, strategically structured plans
and ambitions keep us firmly positioned for further
growth and development. Consequentially – and
perhaps even more importantly – they also ensure our
stability in supporting all the markets, societies and
communities where we operate. More specifically, our
dedication to South-Eastern Europe, our home region,
goes beyond simply providing financial solutions and
services. We are committed to fostering a thriving
community where individuals and businesses identify
new opportunities and explore new horizons. We know
that here we are a part of something bigger.
Yours truly,
Mangement Board of NLB

NLB Group
Annual Report 2024
8
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement by the Chairman
of the Supervisory Board of NLB
1 McKinsey & Co: "The Global Banking Annual Review 2024: Attaining Escape Velocity," October 2024.
To Our Shareholders,
the period of 2008–2020 has
marked an extended decade during
which the average banking sector
players globally (but even more
so applicable for the European
market) did not show much, if any,
value creation. But then there has
been last 3 to 4 years, when banks
in general returned more capital to
their shareholders than any other
sector of the economy. The later
happened both in terms of dividend
yield and stock performance, with
underlying profitability exceeding the
cost of equity by very solid margin
for the best performing peers.
These were the outcomes which a
neutral observer would quickly pin
only to the rising rates, net interest
margin expansion, and long overdue
economic post-pandemic resurgence
of the economies. But is that really
a case? The fact is that banking
valuations and still prevailing
valuation gap to other industries
highlight both, different regulatory
playground and the need for a
banking business model to evolve.
As the rates are now cut and the forward-looking yield
curve flattens, the natural questions arise: Who will be
the winners within the banking sector of the future?
What’s the right strategy to create shareholder value
going forward and what has changed compared
to period prior to outperformance? In seeking the
answers, we could dwell deep into the cost of equity
consideration, and even deeper into the underlying
structure of the balance and off-balance sheet trends
of the banks, based on which we could easily make a
strong case that best performing banks of today look
nothing like they did 10 years ago (and your NLB Group
should qualify in this bucket, as it falls into very top
decile of all the banks in the world who were able to
move up five or more deciles in their return on tangible
equity over 2013–2023 period1). Four operational
metrics, along with avoiding risk, largely explain
most of the outperformance of total shareholder
return: revenue growth and its decomposition;
better net interest margin management from lower
cost deposit-gathering strategies or more efficient
distribution and credit risk management; growing
fee income (from expansion in wealth management,
and other fee-heavy businesses) and of course cost
efficiency, driven also by digitalisation.
While all these four elements are already core pillars
of NLB Group’s 2030 Strategy, your Supervisory Board
is of the opinion that when it comes to the future, the
rules of the game will predominantly evolve around
two softer, yet crucial elements, and that’s learning and
persistence. In other words:
• Lazy bankers will lose to average ones
• Average ones will lose to focused ones
• Focused ones will lose to (positively) obsessed ones
• And the champions will obsess and focus over
fundamentals, not trophies.
Primož Karpe
Chairman

NLB Group
Annual Report 2024
9
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Excellence comes from perfecting the basics – and
when talking about the basics, I’m referring to the bank
operating model: to end-to-end process optimisation
and subsequent digitalisation allowing scalability, to
understanding the technology and investing into it to
transform, to understanding the data and use it to serve
the clients better and with more tailor-made solutions.
Furthermore, to applying AI where it brings clear
optimisation of costs and better understanding of the
risks, as well as an increase of competitive advantage
for the professionally curious ones. But all of that must
materialise in bolder go-to-market steps and moves
and even more focus on talent and culture, all with the
purpose to serve the clients the way they will feel they
are getting more than just "value for money" when using
the services of the bank.
Least but not last, we are aware we need to understand
"disruption" and "transition" of the future banking model
equally well as those who sit behind the driving wheels
of the largest digitally native banks of the today’s world.
By saying that, we should relentlessly study:
• The ways the people do digital today and the ways the
2 PYMNTS Intelligence: "How the World Does Digital;" 2024.
people will do digital tomorrow (in all aspects of life:
from how they "have fun," how "they communicate," to
how they pursue "be well" initiatives). Having said that,
these three categories respectively engage people in the
digital world more than does digital banking, with the
latter nevertheless being on the extremely high 4th place
of all the digital activities the people engage in today2.
• The giants of the banking future, so one day we’ll also
be able to stand on their shoulders.
NLB Group has adopted the 2030 Strategy with the
clear mindset of transformation. You must agree it
does not lack ambition. You also probably agree it is
focused to unlock even more shareholder value, backed
by higher dividend payout ratios and/or inorganic
equity value creation. As the rate curve changes and
net interest margin naturally shrinks, the strategy
assumes to compensate that in volume growth, it
assumes to compensate that in expansion into new
markets (both organically and inorganically), it predicts
tapping into the untapped revenue pools that exist
already today, and it should concretely materialise
into 16 new customer proposition offerings across the
corporate, retail, and payments business verticals. On
top of all that, the Strategy does not shy away from
continued deep awareness of the whole scope of ESG
responsibilities, as fully outlined in the Sustainability
Statement of this Annual Report.
But to back our promise of the future, we need to invest,
transformation-wise in both technology and talent. We
need to invest into leadership and sustainability, we need
to invest into knowledge and into persistence. Because
by doing things with the right mindset and alongside
the right direction, the future will eventually yield
results through our valuation re-rating, in the erasing
of perceived discounts vs. i.e. US banks, insurers, pure
asset managers and other financial business models,
embedding finance and financial decisions into every
pore of today’s trade, investment, and funding ecosystem.
This way we should enable ourselves to continue giving
back to all our key constituencies to whom we remain
committed to: To our shareholders, to our employees, to
our wider society and of course, to our clients.
Yours truly,
Supervisory Board of NLB

This is where our community
thrives.
(i)
Market share as at 30 September 2024.
(ii) Market share of leasing portfolio. Change in
methodology in NLB Lease&Go, leasing, Ljubljana
and Summit Leasing Slovenija, Ljubljana: as of 31
December 2024, the leasing portfolio in banks is no
longer included in the calculation.
(iii) Data in local financial statements. Result after tax for
full-year 2024.
(iv) On 7 August 2024, Generali Investments, Skopje was
renamed NLB Fondovi, Skopje.
(v) On 10 October 2024, KomBank Invest, Beograd was
renamed NLB Fondovi, Beograd.
For further information on NLB Group subsidiaries,
please refer to the chapter NLB Group Key Members.
NLB Skladi, Ljubljana
Assets under
management
3,048. 6
(in EUR milliions)
Market share
of AUM
40. 7%
in mutual funds
Result
after tax
12. 1
(in EUR millions)
NLB Lease&Go, leasing, Ljubljana
Result
after tax
3. 3
(in EUR millions)
Total assets
349. 0
(in EUR millions)
Market share
by total assets
11. 3%(ii)
NLB, Ljubljana
Market share
by total assets
31. 3%
Active clients
728,350
Result
after tax
478. 2
(in EUR millions)
Total assets
16,975. 1
(in EUR millions)
Summit Leasing Slovenija, Ljubljana
Result
after tax
0. 0(iii)
(in EUR millions)
Total assets
926. 2(iii)
(in EUR millions)
Market share
by total assets
27. 9%(ii)
NLB Banka, Podgorica
Market share
by total assets
14. 3%
Active clients
96,093
Result
after tax
27. 7
(in EUR millions)
Total assets
1,034. 5
(in EUR millions)
Mobil Leasing, Zagreb
Result
after tax
1. 7(iii)
(in EUR millions)
Total assets
126. 4(iii)
(in EUR millions)
NLB Banka, Sarajevo
Market share
by total assets
6. 0%(i)
Active clients
132,887
Result
after tax
14. 4
(in EUR millions)
Total assets
1,005. 1
(in EUR millions)
NLB Banka, Banja Luka
Market share
by total assets
20. 9%
Active clients
210,580
Result
after tax
29. 5
(in EUR millions)
Total assets
1,172. 1
(in EUR millions)
NLB Fondovi, Beograd(v)
Assets under
management
58. 0
(in EUR milliions)
Market share
of AUM
3. 5%
in mutual funds
Result
after tax
-0. 4
(in EUR millions)
NLB Lease&Go Leasing Beograd
Result
after tax
0. 2
(in EUR millions)
Total assets
125. 6
(in EUR millions)
Market share
by total assets
7. 9%
NLB Komercijalna Banka, Beograd
Market share
by total assets
9. 8%
Active clients
1,062,590
Result
after tax
140. 5
(in EUR millions)
Total assets
5,553. 5
(in EUR millions)
NLB Fondovi, Skopje(iv)
Assets under
management
66. 4
(in EUR milliions)
Market share
of AUM
18. 8%
in mutual funds
NLB Lease&Go Skopje
Result
after tax
-0. 7
(in EUR millions)
Total assets
23. 1
(in EUR millions)
Market share
by total assets
n. a.
NLB Banka, Skopje
Market share
by total assets
15. 9%
Active clients
471,007
Result
after tax
67. 8
(in EUR millions)
Total assets
2,158. 8
(in EUR millions)
NLB Banka, Prishtina
Market share
by total assets
17. 0%
Active clients
242,986
Result
after tax
37. 0
(in EUR millions)
Total assets
1,426. 9
(in EUR millions)
NLB Group
Active clients
2,944,493
Result
after tax
514. 6
(in EUR millions)
Total assets
28,035. 4
(in EUR millions)
Market share
by total assets
3. 2%(ii)
Result
after tax
0. 1(iii)
(in EUR millions)

We connect
with societies
and their
people like no
other bank in
the region.
The NLB Group is the
only financial institution
headquartered and
focused on the SEE
region. This is our home.
We know the languages,
customs and people,
and we share a common
history.

NLB Group
Annual Report 2024
12
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Non-performing loans (NPLs)
(in EUR millions)
Gross loans to customers
(in EUR millions)
Robust normalised performance over five years,
fuelled by strong loan demand and revenue
growth, along with stable asset quality
Profit a. t.
(in EUR millions)
204
2018
194
2019
270
2020
236
2021
447
2022
515
2024
Net interest income
(in EUR millions)
2018
313
2019
318
2020
300
2021
409
2022
505
2023
833
31 Dec
2018
7,627
31 Dec
2019
7,938
31 Dec
2021
10,903
31 Dec
2024
16,721
31 Dec
2018
622
31 Dec
2019
375
31 Dec
2020
475
31 Dec
2021
367
31 Dec
2022
328
31 Dec
2023
301
31 Dec
2020
10,033
1,877
KB
31 Dec
2022
13,397
954
N
Banka
Key Highlights
173
NGW(i)
N Banka
138
NGW(i)
KB
551
2023
52
DT(ii)
2024
934
14,064
31 Dec
2023
970
SLS
Group
31 Dec
2024
330
(i) NGW = negative goodwill = gains from bargain purchase
(ii) DT = deferred tax: increase of deferred tax assets and first recognition of deferred tax liability for withholding tax on dividends

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Annual Report 2024
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Strategy
Risk Factors & Outlook
Performance Overview
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NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
(EBA definition)
14 bps
Capital
Asset
quality
EUR
1,672. 5
million
EUR
220
million
18. 73%
37. 47%
1. 1%
MREL
TCR
Dividend pay-out in 2024
MREL ratio
MREL funding (stock)
cost of risk
NPE ratio
vs. 15.50% requirement (incl. P2G)
representing a 100% increase over the previous
year’s distribution
vs. 35.04% requirement
New MREL funding in 2024: EUR 800 million
Governance
Social
Environmental
EUR
439
million
of new sustainable financing, supporting
the green transformation of our clients

54%
increase of employee engagement
(+28 p.p. vs baseline year 2015)

10. 5
(low risk)
by Sustainalytics ESG Risk rating
(improved by 5.5 points)

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Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Key performance indicators
Table 1: Key financial indicators for NLB Group and NLB
NLB Group
NLB
2024
2023
2022
2024
2023
2022
Income statement data (in EUR millions)
Net interest income
934
833
505
432
373
177
Net non-interest income
311
260
294
378
266
189
Net non-interest income (BoS)
354
300
503
389
277
199
Net revenue
1,683
1,454
1,181
1,069
830
461
Total costs
-602
-502
-460
-312
-238
-208
Operating costs (BoS)
-642
-541
-496
-323
-249
-218
Result before impairments and provisions(i)
643
591
338
498
401
158
Impairments and provisions
-37
-14
-29
14
78
6
Gains less losses from capital investments in
subsidiaries, associates, and joint ventures
3
1
1
-
-
-
Result before tax
608
578
483
512
479
164
Result of non-controlling interests
16
13
11
-
-
-
Result after tax
515
551
447
478
514
160
Financial position statement data (in EUR millions)
Total assets
28,035
25,942
24,160
16,975
16,015
13,939
Gross loans to customers
16,721
14,064
13,397
8,816
7,277
6,157
Impairments and valuations of loans to customers
-358
-329
-324
-158
-121
-95
Net loans to customers
16,364
13,735
13,073
8,657
7,156
6,062
Financial assets
6,324
4,804
4,877
4,548
3,016
2,961
Deposits from customers
22,206
20,733
20,028
12,294
11,882
10,984
Equity
3,226
2,883
2,366
2,526
2,249
1,603
Non-controlling interests
72
65
57
-
-
-
Total off-balance sheet items
7,336
6,301
5,449
6,108
5,291
4,046
Key financial indicators
a) Capital adequacy
Total capital ratio
18.7%
20.3%
19.2%
24.4%
25.2%
25.6%
Tier 1 ratio
15.8%
16.9%
15.7%
19.6%
19.7%
19.1%
CET 1 ratio
15.3%
16.4%
15.1%
18.8%
18.8%
18.1%
Total RWA (in EUR millions)
18,216
15,337
14,653
11,153
9,207
7,833
RWA / Total assets
65.0%
59.1%
60.6%
65.7%
57.5%
56.2%
b) Asset quality
NPL coverage ratio 1 (coverage of gross non-
performing loans with impairments for all loans)
108.7%
110.0%
98.9%
107.2%
87.9%
86.1%
NPL coverage ratio 2 (coverage of gross
non-performing loans with impairments
for non-performing loans)
62.7%
64.6%
57.1%
70.4%
61.2%
58.1%
NPL coverage ratio (EBA definition)(ii)
63.5%
65.6%
58.1%
70.6%
61.4%
58.2%
NPL coverage ratio (EBA definition) (BoS)(iii)
63.5%
65.6%
58.1%
70.6%
61.4%
58.2%
NPL volume (in EUR millions)
330
301
328
148
138
111
NPL ratio (internal def.; NPL/ Total loans)
1.6%
1.5%
1.8%
1.4%
1.2%
1.1%
Net NPL ratio (internal def.; net
NPL / Total net loans)
0.6%
0.5%
0.8%
0.4%
0.5%
0.5%
NPL ratio (EBA definition)(ii)
2.0%
2.1%
2.4%
1.6%
1.9%
1.7%
NPL ratio (EBA definition) (BoS)(iii)
1.6%
1.5%
1.8%
1.4%
1.2%
1.1%
NPE ratio (EBA definition)
1.1%
1.1%
1.3%
0.8%
0.9%
0.9%
NPE ratio (EBA definition) (BoS)(iv)
1.1%
1.1%
1.3%
0.8%
0.9%
0.9%
Received collaterals / NPL
55.9%
58.1%
61.0%
48.5%
58.7%
58.4%

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Annual Report 2024
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Overview
MB Statement
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Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
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Financial
Report
NLB Group
NLB
2024
2023
2022
2024
2023
2022
NPL Collateral received / NPL (EBA definition)
67.0%
45.6%
54.7%
61.3%
67.1%
75.6%
Credit impairments and provisions / RWA
0.1%
-0.1%
0.1%
0.3%
0.0%
0.2%
c) Profitability
Net interest margin (BoS)(v)
3.5%
3.4%
2.2%
2.6%
2.5%
1.3%
Financial intermediation margin (BoS)
4.8%
4.6%
4.4%
5.0%
4.4%
2.9%
Operational business margin(vi)
5.0%
4.8%
3.6%
3.8%
3.7%
2.5%
ROE b.t.
19.1%
21.6%
20.6%
21.2%
26.0%
10.5%
ROA b.t.
2.3%
2.3%
2.1%
3.1%
3.3%
1.2%
ROE a.t.
16.5%
21.0%
19.9%
19.8%
27.9%
10.2%
ROA a.t.
1.9%
2.2%
1.9%
2.9%
3.5%
1.2%
d) Business costs
Operating costs / Average total assets (BoS)
2.4%
2.2%
2.2%
2.0%
1.7%
1.7%
CIR(vii)
45.7%
45.9%
57.6%
34.5%
37.3%
56.8%
Total costs / RWA
3.3%
3.3%
3.1%
2.8%
2.6%
2.7%
Total costs / Total assets
2.1%
1.9%
1.9%
1.8%
1.5%
1.5%
e) Liquidity
Liquidity assets / Short-term financial
liabilities to non-banking sector
43.7%
51.9%
48.5%
54.7%
66.5%
61.8%
Liquidity assets / Average total assets
34.5%
41.0%
40.7%
40.0%
51.5%
49.8%
Liquidity Coverage Ratio (LCR)
197.2%
245.7%
220.3%
235.6%
299.7%
276.5%
Net stable funding ratio (NSFR)
167.6%
187.3%
183.0%
155.1%
175.0%
177.6%
f) Leverage ratio
Leverage ratio
9.9%
9.6%
9.1%
12.4%
10.9%
10.3%
g) Other
Market share in terms of total assets
-
-
-
31.3%
30.2%
27.6%
LTD
73.7%
66.2%
65.3%
70.4%
60.2%
55.2%
Total revenues / RWA
6.8%
7.1%
5.4%
7.3%
6.9%
4.7%
Key indicators per share
Shareholders(viii)
-
-
-
4,649
3,457
3,025
Shares
-
-
-
20,000,000
20,000,000
20,000,000
The corresponding value of one share (in EUR)
-
-
-
10
10
10
Book value (in EUR)
157.1
139.9
114.1
122.1
108.3
75.9
Branches
Number of branches
409
418
440
69
68
71
Employees
Number of employees
8,322
7,982
8,228
2,523
2,554
2,418
NLB Rating
NLB Outlook
2024
2023
2022
2024
2023
2022
International credit ratings
S&P
BBB
BBB
BBB
Stable
Stable
Stable
Moody's
A3
A3
Baa1
Positive
Stable
Stable
(i) The result before impairments and provisions of NLB Group for the year 2022 does not include negative goodwill.
(ii) Loans and advances without loans and advances classified as held for sale, cash balances at central banks, and other demand deposits.
(iii) Loans and advances, including cash balances at CBs and other demand deposits.
(iv) The carrying amount of debt instruments measured at fair value through other comprehensive income (FVOCI) is increased by value adjustments due to impairments.
(v) Calculated on the basis of average total assets.
(vi) Calculated as Net income from operational business (NII - Tier 2 expenses + Net fee and commission income + Recurring net income from financial operations)/Average total assets.
(vii) Tax on the balance sheet excluded from a calculation from 2024 on.
(viii) As per the share register of Central Securities Clearing Corporation (KDD). The shares are listed on the Ljubljana Stock Exchange. The Bank of New York (the "GDR Depositary") represented in the share register of KDD as a single
holder is not the beneficial owner of shares. It holds shares in its capacity as the depositary for the GDR holders. The GDRs representing shares are issued against the deposit of shares and are listed on the London Stock Exchange.
Therefore, the number in the share register of KDD does not represent all final beneficial owners of the Bank shares. The rights under the deposited shares can be exercised by the GDR holders only through the GDR Depositary, and
individual GDR holders do not have any direct right to either attend the general meeting of Bank’s shareholders or to exercise any voting rights under the deposited shares.
Further details on the definition of certain indicators in this table are available in the chapter Alternative Performance Indicators.

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Annual Report 2024
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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Key Events
1
2
3
4
5
6
7
8
9
10
11
12
Issuance of
Tier 2 Notes
Top Employer
certificate
Apple Pay
available to
NLB customers
NLB Skladi,
Ljubljana as
Best Asset
Management
Company
New NLB Group
Strategy 2030
Issuance of senior
preferred notes
Acquisition
of Generali
Investments,
Skopje
First tranche
dividend payment
New NLB
Supervisory Board
appointments
New NLB website
Acquisition of
Summit Leasing
and entering the
Croatian market
Re-election of the
Chairman of NLB
Supervisory Board
Sponsorship of
NLB Ljubljana
Marathon
NLB Group
donations for flood
relief in Bosnia
and Herzegovina
KomBank Invest,
Beograd renamed
NLB Fondovi,
Beograd
Regulatory
approvals to
acquire Summit
Leasing
Generali
Investments,
Skopje rebranded
to NLB Fondovi,
Skopje
NLB awarded
Prime Market
Stock of the Year
Second tranche
dividend payment
Improved ESG risk
rating
New NLB Group
website
10. 5
LOW RISK
2024
EUR
110
million
EUR
110
million

NLB Group
Annual Report 2024
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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
January
· Issuance of Tier 2 Notes: The Bank issued 10NC5
subordinated Tier 2 notes in the amount of EUR 300
million (ISIN: XS2750306511). In parallel, the Bank
conducted a liability management exercise (LME)
repurchasing EUR 219.6 million of its two outstanding
Tier 2 notes with approaching call dates.
· Top Employer certificate: The Top Employers Institute
awarded the Bank the prestigious Top Employer
certificate for the 9th consecutive year.
February
· Apple Pay: Apple Pay became available to NLB
customers in Slovenia.
March
· Notifications of major holdings change: The
shareholding of Schroders plc in the Bank changed
from 5.12% to 4.98%.
April
· NLB Skladi, Ljubljana declared the Best Asset
Management Company over a three- and ten-year
period: The financial magazine Moje Finance awarded
NLB Skladi, Ljubljana the Best Asset Management
Company over a three- and ten-year period in the
category Naj Skladi 2023.
· Apple Pay: Apple Pay became available to NLB
customers in Montenegro.
May
· Early redemption of notes: The Bank executed an
early redemption of subordinated Tier 2 notes in the
aggregate nominal amount of EUR 45 million (ISIN:
SI0022103855).
· New NLB Group Strategy 2030: The NLB Group
revealed its new Group Strategy until 2030 at NLB
Investor Day in Ljubljana on 9 May 2024.
· Announcement of NLB’s intention of Addiko Bank
AG public takeover offer: On 15 May, NLB announced
its intention to launch an all-cash voluntary public
takeover offer aimed at acquiring control over Addiko
Bank AG for all issued and outstanding Addiko shares
for a consideration of EUR 20.00 per Addiko Bank AG
share on a cum dividend basis.
3 The company was removed from the court register on 1 July 2024.
4 The company was removed from the court register on 1 July 2024.
· Issuance of senior preferred notes: NLB issued senior
preferred notes in the aggregate amount of EUR 500
million for MREL purposes (ISIN: XS2825558328).
· Acquisition of Generali Investments, Skopje by NLB
Skladi, Ljubljana: NLB Skladi, Ljubljana has expanded
into the North Macedonian market by acquiring
Generali Investments, Skopje. The acquisition was
completed after receiving all relevant approvals.
· Award from the Slovenian Marketing Association:
NLB received the leading award from the Slovenian
Marketing Association for Excellence in NLB Brand
Management.
June
· Addiko Bank AG public takeover offer: On 7 June
2024, NLB published a voluntary public takeover offer
to acquire control of Addiko Bank AG and publicly
presented the offer at a webcast held on 10 June 2024.
· Dividend payment: The Bank paid the dividends
(the first tranche) of EUR 110 million or EUR 5.5 gross
per share.
· Appointment of three members of the Supervisory
Board: The NLB General Meeting re-appointed Primož
Karpe and two new members Natalia Olegovna Ansell
and Luka Vesnaver.
· New NLB website: NLB successfully renovated its
website (nlb.si).
· Google Pay: Google Pay became available to NLB
customers in Kosovo.
· Garmin Pay: Garmin Pay became available to NLB
customers in Slovenia.
· The merger of NLB Leasing, Ljubljana – in liquidation
with NLB Lease&Go, leasing, Ljubljana: NLB Leasing,
Ljubljana – in liquidation ceased to exist3, its assets
and liabilities were transferred to NLB Lease&Go,
leasing, Ljubljana.
· The merger of PRIVATINVEST, Ljubljana with NLB Real
Estate, Ljubljana: Company PRIVATINVEST, Ljubljana
ceased to exist4, and its assets and liabilities were
transferred to NLB Real Estate, Ljubljana.
July
· Re-election of the Chairman of NLB Supervisory Board:
The members of the NLB Supervisory Board re-elected
Primož Karpe as their Chairman for the third time.
· Improved Addiko Bank AG public takeover offer: NLB
announced the improved offer price for the voluntary
public takeover offer aimed at acquiring control over
Addiko Bank AG by increasing the Share Offer Price
from EUR 20.00 to EUR 22.00 per Addiko share on a
cum dividend basis. Following the announcement of
the improvement of voluntary public takeover, the Bank
published the addendum to the Offering Memorandum
and revised Presentation on 22 July 2024.
· Early redemption of notes: The Bank executed the
early redemption of NLB senior preferred notes in the
aggregate nominal amount of EUR 300 million (ISIN:
XS2498964209).
· NLB as general sponsor of NLB Ljubljana Marathon:
NLB has taken on the role of general sponsor of the
largest running event in SEE, now known as the NLB
Ljubljana Marathon.
August
· Regulatory approvals to acquire SLS HOLDCO,
Ljubljana: NLB obtained all required regulatory and
supervisory approvals from the Croatian Financial
Services Supervisory Agency (HANFA), the Slovenian
Competition Protection Agency (AVK), and the ECB
in relation to the completion of the transaction
contemplated in the Sale and Purchase Agreement
to acquire a 100% shareholding in SLS HOLDCO,
Ljubljana, the parent company of Summit Leasing
Slovenija, Ljubljana and its Croatian subsidiary Mobil
Leasing, Zagreb.
· Results of Addiko Bank AG public takeover offer: The
public takeover offer aimed to acquire control over
Addiko Bank AG did not obtain sufficient acceptance
declarations.
· NLB Fondovi, Skopje: Asset management company
Generali Investments, Skopje, was rebranded on
7 August 2024 to NLB Fondovi, Skopje.
September
· Completion of the acquisition of the SLS Group and
entering the Croatian market: After obtaining all
regulatory approvals in August, NLB completed the
transaction on 11 September 2024 and became the sole
shareholder of SLS HOLDCO, Ljubljana, the parent
company of Summit Leasing Slovenija, Ljubljana and

NLB Group
Annual Report 2024
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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
its Croatian subsidiary Mobil Leasing, Zagreb, together
forming the SLS Group.
· Completion of the acquisition of KomBank Invest,
Beograd by NLB Skladi, Ljubljana: After obtaining
regulatory approval, NLB Skladi, Ljubljana successfully
completed the transaction on 19 September 2024 and
with this, the NLB Group consolidates the ownership of
the asset management companies under the umbrella
of NLB Skladi, Ljubljana.
· Beginning of a mandate of a Supervisory Board
member: On 30 September 2024, Luka Vesnaver took
up his office as a member of the Supervisory Board
of NLB, following the ECB's decision not to object
to his appointment to the function, to which he was
appointed at the 42nd General Meeting of NLB on
17 June 2024.
October
· NLB Group donation to eliminate the consequences
of the devastating floods in Bosnia and Herzegovina:
NLB Group donated EUR 1 million to help eliminate the
consequences of the disastrous floods in Bosnia and
Herzegovina that occurred in October. The donation
was directed to humanitarian organisations – the
Red Cross Society of Bosnia and Herzegovina and
Pomozi.ba, to ensure that the aid reaches those most
in need.
· NLB Fondovi, Beograd: KomBank Invest, Beograd was
renamed NLB Fondovi, Beograd.
November
· Beginning of a mandate of a Supervisory Board
member: On 8 November 2024, Natalia Olegovna
Ansell took up her office as a member of the
Supervisory Board of NLB, following the ECB's decision
not to object to her appointment to the function, to
which she was appointed at the 42nd General Meeting
of NLB on 17 June 2024.
· Prime Market Stock of the Year: Ljubljana Stock
Exchange awarded NLB for Prime Market Stock of
the Year.
· Garmin Pay: Garmin Pay became available to NLB
customers in Montenegro, North Macedonia, Bosnia
and Herzegovina and Kosovo.
· Early redemption of Tier 2 notes: The Bank executed
an early redemption of subordinated Tier 2 notes in the
aggregate nominal amount of EUR 9.9 million (ISIN:
XS2080776607).
December
· NLB MUZA: The Bankarium Museum has been
renamed to NLB MUZA.
· New NLB Group website: NLB Group successfully
renovated its website (nlbgroup.com).
· Dividend payment: The Bank paid the dividends
(the second tranche) of EUR 110 million or EUR 5.5 gross
per share.
· Improvement of ESG risk rating: NLB received an
ESG risk rating of 10.5, reflecting a low risk of material
financial impacts from ESG factors, placing NLB in the
top 5th percentile of all banks assessed by Morningstar
Sustainalytics.
· Google Pay: After migrating its card issuing to a new
service provider in December, NLB Komercijalna
Banka, Beograd introduced Google Pay to its
customers.
· Notifications of major holdings change: Brandes
Investment Partners, L.P. has increased its shareholding
in the Bank above 5%, reaching 5.03%.

In a dynamic banking
world, we seize
opportunities. Our
new business strategy
foresees doubling the
NLB Group’s balance
sheet (to more than
EUR 50 billion assets),
recurring revenues
of more than EUR
2 billion and profit
of more than EUR
1 billion by 2030.
We lead with vision and
grow with purpose.

NLB Group
Annual Report 2024
20
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Shareholder Structure and Market Performance
of NLB’s Shares and GDRs
Shareholder structure of NLB
The Bank’s shares are listed on the Prime Market
sub-segment of the Ljubljana Stock Exchange (ISIN
SI0021117344, Ljubljana Stock Exchange trading symbol:
NLBR), and the GDRs representing shares are listed on
the Main Market of the London Stock Exchange (ISIN:
US66980N2036 and US66980N1046, London Stock
Exchange GDR trading symbol: NLB and 55VX). Five
GDRs represent one NLB share.
Table 2: NLB’s main shareholders as at 31 December 2024(i)
Shareholder
Number of
shares
Percentage
of shares
Bank of New York on behalf
of the GDR holders(ii), (iii)
9,659,425
48.30
of which EBRD
/
>5 and <10
of which Brandes
Investment Partners, L.P.(iv)
/
>5 and <10
Republic of Slovenia (RoS)
5,000,001
25.00
Other shareholders
5,340,574
26.70
Total
20,000,000
100.00
(i) This information is sourced from the NLB’s shareholders’ book that
is accessible at the web services of CSD (Central Security Depository,
Slovenian: KDD - Centralna klirinško depotna družba) and available to
CSD members. The information on major holdings is based on self-
declarations by individual holders pursuant to the applicable provisions
of Slovenian legislation, which require that the holders of shares in a
listed company notify the company whenever their direct and/or indirect
holdings pass the set thresholds of 5%, 10%, 15%, 20%, 25%, 1/3, 50%, or
75%. The table lists all self-declared major holders whose notifications
have been received. In reliance on this obligation vested with the holders
of major holdings, the Bank postulates that no other entities nor any
natural person hold directly and/or indirectly ten or more percent of the
Bank’s shares.
(ii) The Bank of New York holds shares in its capacity as the depositary
(the GDR Depositary) for the GDR holders and is not the beneficial owner
of such shares. The GDR holders have the right to convert their GDRs
into shares. The rights under the deposited shares can be exercised by
the GDR holders only through the GDR Depositary, and individual GDR
holders do not have any direct right to either attend the shareholders’
meeting or exercise any voting rights under the deposited shares.
(iii) The information on GDR ownership is based on self-declarations by
individual GDR holders as required pursuant to the applicable provisions
of Slovenian law.
(iv) The information on GDR ownership is based on self-declarations
made by Brandes Investment Partners, L.P. on 5 December 2024.
25%
+ 1 share
Republic of Slovenia
26. 70%
Other shareholders
48. 30%
Shares in GDR format
GDR holders with shares >5% and <10%:
• EBRD
• Brandes Investment Partners, L.P.

NLB Group
Annual Report 2024
21
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Market performance
of NLB’s shares and
GDRs
The EURO STOXX 600 Index saw a steady rise in Q1,
supported by robust performances in the technology
and healthcare sectors, while in Q2, there was some
volatility due to geopolitical tensions and fluctuating
commodity prices. The index experienced a slight
dip in July and August due to market corrections,
but rebounded in September as investor confidence
returned. In Q4, the index closed the year with a gain of
approximately 8.9% YoY, reflecting the overall positive
market sentiment and strong performances in the
industrial and consumer goods sectors. The EURO
STOXX Banks Index had an impressive year in 2024.
In the first two quarters, the index benefitted from
high capital ratios, more substantial earnings, and
expectations of consolidation in the banking industry.
The H1 saw significant gains as banks reported better-
than-expected quarterly results. The momentum
continued in H2, with the index climbing 21.4% over
the year, marking its best performance since 2021. The
banking sector was buoyed by still high interest rates
and cost-cutting measures, which improved profitability.
The SBITOP Index grew throughout the year for the most
part, driven by positive market sentiment and strong
performances from key blue-chip companies. The index
experienced only two meaningful falls, both in mid-July
to the first part of August, as the beginning of the third
quarter brought some volatility, which was influenced by
broader market corrections and economic uncertainties.
A steady recovery ensued, supported by improved
corporate earnings and investor confidence. In 2024, the
index gained approximately 33.4% YoY.
Throughout 2024, the NLB stock experienced various
fluctuations, reflecting broader market trends and
company-specific developments. The stock started
the year at around EUR 84.8 and steadily increased,
reaching EUR 110 by the end of March. This increase was
likely driven by positive market sentiment and strong
quarterly earnings. During Q2, the stock continued its
upward trend, peaking at EUR 126.5 in June. The period
saw consistent growth, indicating investor confidence
and favourable market conditions. In Q3, the stock
experienced some volatility, while the highest price
of the year, EUR 136, was recorded at the end of July.
However, the stock saw a slight decline towards the
end of the quarter, closing at EUR 120 in September. It
showed resilience and recovery in Q4, closing the year
at EUR 127.5, reflecting a positive end to the year despite
some mid-quarter volatility, gaining more than 50% in
value during the year compared to YoY.
Figure 1: NLB share price movements on the Ljubljana Stock Exchange and NLB GDR price movement on
the London Stock Exchange (in EUR)
Source: Ljubljana Stock Exchange, Bloomberg.
GDR
Shares (NLBR)
GDR (NLB)
Shares
30.00
29.00
28.00
27.00
26.00
25.00
24.00
23.00
22.00
21.00
20.00
19.00
18.00
17.00
16.00
140.00
135.00
130.00
125.00
120.00
115.00
110.00
105.00
100.00
95.00
90.00
85.00
80.00
Jan 2024
Feb 2024
Mar 2024
Apr 2024
May 2024
Jun 2024
Jul 2024
Aug 2024
Sep 2024
Oct 2024
Nov 2024
Dec 2024
Share
price
growth
in 2024 above
50%
and more than
63% total return
(including dividends)
Ljubljana Stock Exchange
awarded NLB as
"Prime
Market Stock
of the Year"

NLB Group
Annual Report 2024
22
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB shares and GDRs
Table 3: NLB share information
Share information
31 Dec 2024
Total number of shares issued
20,000,000
Highest closing price (in 2024)
EUR 136.0
Lowest closing price (in 2024)
EUR 84.8
Closing price as at 30 December 2024(i)
EUR 127.5
NLB Group book value per share
EUR 157.1
NLB Group earnings per share (EPS)
EUR 25.7
Price/NLB Group book value (P/B)
0.81
Dividend per share (for the previous business year)
EUR 11.00
Market capitalisation(i)
EUR 2,550,000,000
(i) No market on 31 December 2024.
Indices
The Bank’s shares are included in several indices: the
SBITOP index, SBITOP TR index, and ADRIA prime index
of the Ljubljana Stock Exchange, FTSE Frontier Index,
MSCI Frontier, and MSCI Slovenia, S&P Eastern Europe
BMI, S&P Emerging Frontier Super Composite BMI, S&P
Extended Frontier 150, S&P Frontier BMI, S&P Frontier
Ex-GCC BMI, S&P Slovenia BMI, as well as the STOXX
All Europe Total Market, STOXX Balkan Total Market,
STOXX Balkan Total Market ex-Greece & Turkey, STOXX
EU Enlarged Total Market, STOXX Eastern Europe 300,
STOXX Eastern Europe 300 Banks, STOXX Eastern
Europe Large 100, STOXX Eastern Europe Total Market,
STOXX Eastern Europe Total Market Small, STOXX
Global Total Market, and STOXX Slovenia Total Market,
among others.
The Investor
Relations function
The Bank participated in various forms of engagement,
such as investor meetings, calls, conferences, and
roadshows to meet the requirements of the Bank’s
ownership. Transparent communication with investors
and analysts allowed for a dialogue on strategic
developments, as well as on the financial performance
of the Group. The Bank promoted greater awareness
and understanding of operating businesses,
developments, and events, which influence the
performance of the Bank's share price. The performance
of the Bank is covered by analysts from Deutsche Bank,
Wood & Company, Citi, InterCapital, Raiffeisen Bank
International, Erste, Ipopema, Capital AM, PKO BP, and
Ilirika BPH.
Throughout 2024, the Bank participated in more than
18 conferences, roadshows, and organised a very
successful Investor Day in Ljubljana. Representatives
from the Bank met 170+ investors on 360+ investor
interactions. Those meetings covered various topics,
including governance (including remuneration),
sustainability, digitalisation, strategy, and finance.
In 2024, the Bank obtained its second credit coverage
from Raiffeisen Bank International, expanding analysts’
coverage beyond equity research and helping the Bank
with capital markets activities.
In addition, in December 2024, the Ljubljana Stock
Exchange awarded Bank shares (ticker "NLBR") the
"Prime Market Stock of the Year" accolade.
IR presentations, financial reports, and important
information are available on the Bank’s website in line
with IR’s Financial Calendar.
Expanded
analyst
coverage
of NLB by Erste, Ipopema,
and Capital AM on the
equity side and Raiffeisen
Bank International on the
fixed income side
More
than EUR
EUR 1. 2
million
in combined average
regular trading volume
per day (excluding
block trades)

NLB Group
Annual Report 2024
23
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Macroeconomic Environment
The hope was that the euro area economy’s growth would gain traction in 2024, but it stagnated instead. Household
consumption was the main driver of growth. The hardship of its industrial sector never got a break in 2024, while
wage growth remained elevated, helping to reaccelerate inflation in the final quarter.
The global and
European economies
The U.S. dollar hit a two-year high versus the EUR
and posted an annual gain against almost all major
currencies, as the prospect that the FED would hold
interest rates higher than peers led the U.S. currency to
dominate rivals. The USD has received a boost by rising
growth concerns elsewhere against the background of
geopolitical risk. The EUR registered an approximate
6.2% yearly decline against the USD. Geopolitical
tensions, demand fluctuations, and economic indicators
shaped oil prices in 2024. Chinese demand growth was
underwhelming, leading to periods of price depression.
At the same time, conflicts in the Middle East, particularly
between Israel and Hamas, and the broader regional
instability caused temporary spikes in oil prices due to
fears of supply disruptions. Strong global oil production
growth and slower demand growth exerted downward
pressure on prices.
In 2024, the U.S. economy experienced growth, driven
primarily by consumer spending, which remained
robust throughout the year, supported by a strong
labour market and increased household incomes.
Business investments increased significantly, particularly
in technology and infrastructure. Fiscal policies and
government spending also contributed positively,
although concerns about the fiscal deficit remain.
The U.S. saw a continued decline in inflation rates
that enabled the FED to cut interest rates, which was
accommodated by supply chain improvements (reduced
bottlenecks) and the stabilisation of energy prices.
Inflation re-accelerated towards the 3% YoY mark in
Q4, partly driven by the low base effects from last year,
particularly in energy and an increase in food prices.
In 2024, China’s economic growth was driven by strong
exports, high-tech investments, and stimulus measures
that boosted economic activity, especially in Q4. Despite
these positive factors, China faced challenges such as
weak domestic demand and demographic issues. The
manufacturing sector significantly contributed to a
sizeable growth in industrial output. China’s economic
performance in 2024 provided stability and confidence
to the global economy, reinforcing its role as a key driver
of global growth.
However, the euro area economy was hoping for a
rebound in 2024 that never materialised, with growth
lingering below the 1% YoY mark in the first three
quarters, but reaccelerated above that mark in Q4 to
reach an average of 0.9% YoY in 2024, while inflation
reaccelerated in Q4. Household consumption, aided by
increasing government consumption, posed as the main
driver of growth, even if it seemed a little pent-up by the
not-too-optimistic consumer sentiment, which caused
the retail trade to swing between mild contraction and
soft growth in 2024. Therefore, the savings rate jumped
by more than one p.p. during the first three quarters
compared to YoY. Returning to GDP components, the
gross fixed capital formation was in contraction in all four
quarters, boding poorly for future growth. Exports started
the year in contraction, but broke into positive territory
in remaining quarters, while imports contracted in H1
and returned to growth in H2. Industrial production spent
most of the year in contraction, as the euro area industry
has been rapidly losing its competitiveness on the global
market, leading to stagnation. While households saved
more than in 2023, their investment rate diminished
slightly, and their gross disposable income slowed down
notably in Q2 and Q3 in QoQ terms. In 2024, the Middle
East oil exports to Europe were down more than 20%
YoY due to disruption in the Red Sea shipping lane. The
gas transit deal between Russia and Ukraine expired on
the last day of 2024, affecting Europe’s energy prices.
The euro area economy is in danger of plunging even
deeper into crisis, and the room for the ECB manoeuvres
is diminishing rapidly. The economic engine is in danger
of further stalling, the inflation trend is on a negative
trajectory, and governments are wrestling with high
deficits. Germany's recessionary economy hangs like a
weight on the euro area.
Inflation in the euro area receded towards its 2% YoY
goal, even dropping below the mandated target in
September. However, inflation reaccelerated from then
on, to the highest level in five months in December
which mainly reflected higher service costs. Services
appeared to be very sticky throughout the year, while
food prices growth was slowing down for most of the H2
(but started to growth in December again). Core inflation
was slower in coming down under the 3% YoY mark and
stabilised at around 2.7% YoY in the last quarter. On
average, prices grew by 2.4% YoY in 2024. Inflation in
the euro area accelerated in November and December
2024, supporting the European Central Bank’s gradual
approach to reducing interest rates. The increase was
primarily driven by energy costs, which climbed for
the first time since July, as a large part of the increase
comes from fuel price base effects. The boost was not
surprising to the ECB, which has repeatedly warned that
the path back to its 2% target will be bumpy, and that
it only expects to hit that milestone toward year’s-end
sustainably. The ECB cut key interest rates four times
1. 6%
economic growth
in Slovenia in 2024

NLB Group
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Strategy
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Performance Overview
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Risk Management
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Financial
Report
(each by 25 bps), bringing the deposit facility rate to
3%, which is still seen as restricting economic activity
at a time when the currency bloc failed to mount an
economic recovery. However, concern about inflation
in the services sector remains. The rate has been stuck
at about 4% for over a year due to rising wages. The
stickiness of services inflation means that the ECB will
likely keep cutting interest rates only slowly as the
economic outlook remains poor. The ECB’s indicator
for wage growth was nearing the 5% YoY growth mark
in Q1 of 2024, and slowed by more than one p.p. in Q2.
However, it accelerated by more than two p.p. in Q3.
One of the primary drivers was the need to compensate
for the high inflation rates experienced in previous
years. The tight labour market gave workers and unions
more negotiating leverage, leading to higher wage
settlements. Also, as businesses (slowly) recovered and
profitability improved, there was more room for wage
increases. Some governments implemented policies
to support wage growth, such as increasing minimum
wages or encouraging sectoral agreements. The ECB is
worried about the inability of the euro area economy to
gain momentum while geopolitical risks remain elevated.
Should Donald Trump enact tariffs, this would pressure
international trade, which might cause China to (as was
the case with steel) offer its products at lower prices, thus
exporting its deflation to Europe.
In 2024, the FED worked to back its narrative of achieving
an economic "soft landing" – avoiding a recession while
guiding inflation towards the mandated goal in times of
heightened geopolitical uncertainties and an elevated
political risk due to presidential elections. The FED took
significant steps to address economic challenges, mainly
focusing on inflation and the labour market as it cut key
interest rates three times yearly. It initiated its first rate
cut in over four years in September 2024, reducing the
federal funds rate by 0.5 p.p. This move was aimed at
providing relief to borrowers and addressing a slowing
labour market, while the second rate cut of 0.25 p.p.
followed in November 2024, continuing the FED’s efforts
to support economic stability. The final rate cut of the
year by another 0.25 p.p. arrived in December 2024
and brought the target range down to a range from
4.25% - 4.50%. Additionally, the CB was deflating its
balance sheet, reducing its long-term treasury and
MBS securities. These actions in combination were part
of the FED’s strategy to balance its dual mandate of
maximum employment and price stability. Despite this,
the FED signalled a slower pace of rate reductions in
2025, reflecting ongoing concerns about inflation and
economic growth.
The economy in the
Group’s region
A widely expected rebound in growth of the euro
area economy never materialised, having a subdued
Slovenia as the only country in NLB Group’s region to
experience similar trends of development. At the same
time, other countries were growing faster, with stronger
(in comparison) household consumption being aided
by government consumption, both being in most cases
the driving factors of growth. It was a good year for
the region, attracting foreign and domestic investment.
However, it was a weak year for industrial sectors and
exporters due to the weak rebound of the euro area
economy as the most important regional trading partner.
While Slovenia’s exports performed reasonably well only
in Q3 2024, they grew throughout the year in Serbia and
in H1 in Kosovo but mostly contracted in other countries.
Industrial production swung between soft growth and
contraction during the year in most countries. At the
beginning of the year, prices grew above the 5% YoY
mark in Serbia. The downward trend in prices persisted
in H1 thanks to slower growth in food prices and the
contracting prices of energy – but prices reaccelerated
in Q4 in most cases (predominantly due to food prices).
Montenegro, Bosnia and Herzegovina, and Serbia
exhibited the highest YoY growth rates in retail trade,
hinting at more vital household consumption. At the
same time, the economic sentiment at the end of the year
surpassed its level from the year’s opening, with retail and
services confidence indicators improving the most among
the sub-indicators. The unemployment rates in the region
were subsiding throughout 2024, reaching historically low
levels in most countries. Slovenia was the only country to
register a deterioration (+1 p.p. from Q2 to Q3) as the rate
rebounded to 4.4% in Q3 from its historical minimum. In
Q4, it rose further to 5.0%, bringing the average rate for
2024 to 4.1%. In historical context, this is a tight labour
market, but the first cracks started to appear in the
second half of the year.
In Slovenia, FDI flows slowed marginally YoY, reflecting
the uncertainty regarding the relatively stagnant
growth and calls for additional taxation. Despite
the softer industrial momentum, the manufacturing
sector attracted the most investments. In Bosnia and
Herzegovina, the YoY change was even more minor,
predominantly due to a slowdown in Q2. In North
Macedonia, conversely, the FDI inflows sped up YoY,
especially so in Q3, reflecting a favourable investment
climate and growing investor confidence in the country’s
economic prospects. Similarly, in Serbia, FDI flows sped
up compared to YoY, reflecting Serbia’s strategic focus
on diversifying its economy and enhancing its industrial
base, as investments were focused on mining and
construction, followed by IT and communications and
the processing industry. In Kosovo, the FDI flows posted
a marginal uptick compared to YoY, with real estate and
leasing activities being the most significant beneficiaries.
The 2024 was a year of
stagnant growth and
tight labour markets

NLB Group
Annual Report 2024
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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
A macroeconomic
snapshot of NLB Group’s
region
The 2024 was a positive year for the region, driven by
household and government consumption, while the
stagnant euro area acted as a drag.
In Serbia, GDP growth in 2024 remained amongst the
highest in the SEE region, albeit losing steam throughout
the year, more than one p.p. from Q2 to Q3. This
resembled the movement in household consumption
which was very solid but grew at a slightly slower pace
in Q3. It was, nonetheless, the main driving force of
the economy, along with gross fixed capital formation,
which grew throughout the year and even started
approaching a double-digit annual growth in Q3,
confirming the good work done in attracting investment.
Government consumption also slowed its pace in Q3
(-2 p.p. QoQ). Growth changed little in Q4 (from Q3),
bringing the rate for 2024 to 3.9% YoY. Exports picked
up from Q1, while imports accelerated notably in Q3,
well into double-digit growth. Inflation gradually came
down from January until June. However, it rose again
in July and stayed above the 4% mark for the rest of
the year, following similar dynamics exhibited by food
prices. Housing and electricity prices were slowing
down for the whole year. Industrial production started
the year strong, but fluctuated following the euro area’s
slow growth and expectations of a rebound that never
materialised. Retail trade confirmed strong private
consumption, but its growth slowed in Q3.
The economy in Bosnia and Herzegovina held a steady
pace in 2024, propped by household and government
consumption. There was a notable jump in the annual
growth of gross capital formation in Q1, and the rate was
close to double digits in Q2 and Q3. Exports contracted
in H1, while imports were slow to gain pace. The
inflation rate hovered above the 2% YoY growth mark
until July. Then, it slowed to under the 1% mark, only to
accelerate again in November and December due to
food prices accelerating again (above levels exhibited
at the beginning and mid-year). Industrial production
was mainly in contraction (compared YoY) in 2024,
while retail trade confirmed the resilient household
consumption, growing vigorously in H1 but slowing
down in H2.
The economy steadily gained pace in 2024 in North
Macedonia thanks to strong governmental consumption,
which grew throughout the year, exceeding the 13%
YoY mark in Q3, while household consumption grew
at a much softer pace during the year. Gross capital
formation started the year strong, but stumbled in Q2
and in Q4. Exports contracted in the first three quarters
of the year as did imports, only to a lesser degree. In
Q4, growth accelerated further to bring the average
for 2024 to 2.7% YoY. Inflation lingered in the 2.2%–4.3%
YoY range, reaccelerating in H2 following the dynamics
in food prices. Industrial production contracted in all
quarters, following the disappointing growth of the euro
area, while retail trade started the year slow but picked
up in H2.
The Slovenian economy grew at a stagnant pace of 1.6%
YoY in 2024, primarily relying on household (averaging
to 1.6% YoY in 2024) and state consumption; the latter
picked up notably in Q2 and subsided in Q3 and Q4
averaging to 8.5% YoY in 2024. While the gross capital
formation accelerated from Q1 to Q2, it plummeted into
a deep contraction in Q3 and improved slightly in Q4,
contracting by 2.4% YoY in 2024. Exports were stagnant
at best in H1 but picked up the pace in Q3 and Q4, while
imports grew throughout the year. Inflation subsided
below the 2% mark in June, slowing down to a halt in
October and back to the 2% mark at year’s end, as food
prices reaccelerated again (and prices of energy broke
back into growth from contraction). Industrial production
mainly contracted in YoY terms in 2024, following a very
soft demand from abroad, while retail trade switched
between contraction and smooth growth which resulted
in a 0.6% YoY contraction in 2024, hinting at not-too-
confident domestic consumers.
The economy in Montenegro exhibited solid YoY
growth propped by household consumption, but with a
fading momentum as government expenditure slowed
throughout the year. Gross fixed capital formation
YoY growth was among the region’s highest, while
exports contracted throughout the year. Imports
contracted in Q1 but turned to growth in the following
two quarters. Inflation sped up from January to March,
but began slowing down from June to October when it
reaccelerated again. Industrial production contracted
notably in Q2, to a much milder degree in Q3 and swung
into expansion again in the last quarter of the year,
finishing the year strong. Retail trade confirmed strong
household consumption, growing throughout the year
and finishing the year strong. The economy finished the
Q4 in similar pace to the previous two quarters, bringing
the average for 2024 to 3.2% YoY.
The GDP grew at a solid pace in Kosovo, led by the
substantial household consumption that, however,
started losing momentum through the year along
with robust governmental consumption. Gross capital
formation grew at a solid pace throughout the year,
while net exports contracted. It started the year strong,
but slowed into contraction in Q3. Inflation was already
under control in January, but picked up slightly in H1
to slow down fast from August onwards. Industrial
production mostly grew at a solid pace amid an
occasional contraction, while retail trade grew strongly
in Q1, contracted in Q2, and remained slow in Q3.
2. 9%
economic growth
in the Group’s region
in 2024

NLB Group
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
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Financial
Report
The banking system in the Group’s region
2024 was a stellar year for regional banking sectors, as
profits remained high and the countercyclical capital
buffers helped the banking system’s resilience, while
promoting financial stability.
Table 4: Movement of key banking systems indicators(i) in the NLB Group region in 2024
Corporate loans
Household loans
Corporate deposits
Household deposits
Net interest margin
NPL
CAR
in EUR
millions
∆ % YoY
in EUR
millions
∆ % YoY
in EUR
millions
∆ % YoY
in EUR
millions
∆ % YoY
2023, in %
2024, in %
in %
∆ p.p. YoY
in %
∆ p.p. YoY
Slovenia
9,762
-2.1
13,311
6.0
10,910
-0.3
27,309
3.0
3.0
3.1
1.5
0.1
19.7(i)
-0.7
Serbia
15,988
7.9
13,814
10.4
18,433
15.1
21,840
13.4
4.0
4.1
2.5
-0.7
21.9(i)
-0.3
N. Macedonia
3,940
13.9
4,057
8.8
2,866
9.2
6,454
13.8
3.5
3.6
2.7
0.1
18.9(i)
0.8
BiH
5,445
9.0
6,585
9.2
4,143
14.6
9,025
9.9
3.3
3.0(i)
3.5(i)
-0.5
19.5(i)
0.2
Kosovo
3,475
15.8
2,325
22.6
2,299
13.9
4,623
13.9
3.2
2.5
1.9
-0.1
16.2
2.5
Montenegro
1,678
14.9
2,028
17.0
2,142
-2.7
2,981
9.2
4.7
3.7
4.0(i)
-1.0
19.8(i)
-0.9
(i) Data as of Q3 2024.
Source: Statistical offices, CBs, NLB.
Note: Net interest margin calculated on interest-bearing assets. Residential loans and deposits for Montenegro.
Slovenia was the only country where NFC loans
contracted, while in two countries of the region, they
grew at double-digit rates, and while in two more, they
clocked in right under that milestone. The decrease in
corporate loans suggests potential challenges in the
corporate sector, possibly due to economic uncertainties
and strict lending criteria. Household loans grew
strongly (the least in Slovenia) in the NLB Group’s region,
with double-digit growth rates in three countries, while
one finished the year right under that mark. The healthy
household loan and deposit growth indicated consumer
confidence and economic stability.
In Slovenia, the variable interest rates for new corporate
loans persisted above the 5% mark. From there,
they started diminishing towards year-end to 4,3%
in December. In contrast, interest rates for consumer
loans went down only marginally, opening the year
with 6.7% and stood at 6.4% in December, while real
estate loans followed similar but a touch more intense
dynamics, declining to 3.1% in December from 3.9% in
January. In Serbia, a similar dynamic ensued in all three
categories as during the year, corporate loan rates
subsided by 0.8 p.p., consumer loans by 1.8 p.p., and
real estate loans by almost 0.4 p.p. In North Macedonia,
the corporate loan rates declined by 0.6 p.p. during the
Figure 2: ROE ratio in the euro area and NLB Group region
Source: ECB, National CBs.
Note: Return on average equity (ROAE) used for Bosnia and Herzegovina. Data for the euro area, Bosnia and Herzegovina and Montenegro are for Q3 2024.

Slovenia

Euro area

Serbia

Montenegro

Kosovo

N. Macedonia

BiH
9.3%
10.2%
20.6%
18.9%
18.0%
20.2%
16.1%
17.6%
16.7%
17.9%
19.7%
19.9%
19.3%
22.1%
2023
2024

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year, while real estate loan interest rates decreased
by 0.3 p.p. in the same comparison. However, rates
for consumer loans went up by 0.15 p.p. from the
start of the year. The situation differed in Bosnia and
Herzegovina, where all rates went up during 2024,
corporate by 0.3 p.p., real estate loans by 0.2 p.p.,
and 1.4 p.p. in consumer loans. In Kosovo, the rates for
corporate loans decreased by 0.35 p.p., and by 0.75 p.p.
in consumer loans, while in real estate, they fluctuated
but stayed roughly the same. In Montenegro, corporate
loan rates have decreased by 1.1. p.p., in consumer loans
by approximately 1.0 p.p., and 0.6 p.p. in real estate
loan rates during the course of the year.
The decrease in NPLs in most countries indicates
better asset quality and effective risk management.
Historically high capital adequacy, with stable and solid
liquidity and good credit portfolio quality, means that
the banking system can support economic growth –
particularly investment. Due to ECB lowering rates,
subsequent decreases in net interest margin and ROE
were anticipated but never really materialised, as both
categories improved in 2024 in most countries of the
NLB Group’s region. There were fewer challenges (than
anticipated) in maintaining profitability; hence, 2024
was a year to remember for banks. LTD ratios grew
throughout the region, implying banks tried to maximise
their profits by using their deposit base to generate
higher income, albeit increasing credit risk and reducing
liquidity at the same time.
Figure 3: Loans to non-financial corporations and household loans (% GDP) in the euro area and the NLB Group region in 2024
Source: National CBs, National Statistical Offices.
Note: Data from Q3 2024 for Bosnia and Herzegovina and Kosovo, Residential loans for Montenegro.
Figure 4: LTD ratio in the euro area and NLB Group region

Slovenia

Euro area

Serbia

Montenegro

Kosovo

N. Macedonia

BiH
Loans to non-financial corporations, % GDP
Household loans, % GDP
34.3%
45.8%
14.9%
19.8%
18.1%
16.7%
24.6%
26.1%
20.5%
24.7%
31.6%
21.6%
20.2%
26.0%

Slovenia

Euro area

Serbia

Montenegro

Kosovo

N. Macedonia

BiH
2023
2024
Source: ECB, National CBs, NLB.
.
94.3%
92.9%
60.1%
60.4%
74.3%
73.0%
81.6%
81.5%
75.1%
76.2%
80.2%
84.0%
62.2%
68.9%

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Regulatory Environment
The Group consistently monitors regulatory developments to maintain full compliance and adapt to new standards.
By leveraging technology, strengthening internal controls, and fostering a culture of responsibility, the Bank
reinforces its position as a reliable and forward-looking financial institution committed to meeting the challenges
of an evolving regulatory environment and ensuring full compliance with the existing and new requirements.
Disclosure of the most relevant changes in legislation and regulation that influence the Group is presented herein.
Regulatory
environment in
Slovenia
In 2024, significant regulatory developments at both
the EU and Slovenian levels influenced the banking
sector, prompting the Bank to adapt its operations
and strengthen its compliance framework. These
changes reflect the dynamic nature of the regulatory
landscape and the Bank’s commitment to maintaining
the highest standards of compliance, governance, and
risk management.
Finalisation of Basel III (CRR III/CRD VI)
The adoption of the revised Capital Requirements
Regulation (CRR III) and Capital Requirements
Directive (CRD VI) marked a significant milestone in the
implementation of the final elements of Basel III within
the EU. Effective as at January 2025, these regulations
introduce enhancements to credit risk, market risk,
operational risk, and capital adequacy frameworks.
The Bank has proactively assessed the impact of these
changes, updated its risk management systems, and
initiated measures to ensure a smooth transition to the
new requirements.
Instant Payments Regulation
In 2024, a new EU regulation on instant payments
denominated in euro was adopted, making instant
payments the standard across the EU. This framework
aims to enhance affordability, security, and accessibility
for all users. The changes will come into effect gradually,
with staggered deadlines throughout 2025. The Bank
is implementing the necessary measures and activities
to ensure full compliance with these deadlines, aligning
its payment systems and processes to meet regulatory
expectations while enhancing the customer experience.
Digital Operational Resilience Act (DORA)
In December 2022, the Digital Operational Resilience
Act (DORA) Regulation was published in the EU’s Official
Journal alongside the revised directive on the security
of network and information systems (NIS2 Directive).
In 2024, significant progress was made in the DORA
regulatory framework by adopting Regulatory Technical
Standards (RTS) and Implementing Technical Standards
(ITS). These standards outline detailed requirements
for ICT risk management, major incident reporting,
testing of operational resilience, and oversight of third-
party ICT service providers, further clarifying DORA’s
implementation ahead of its application in January 2025.
The Bank has taken significant steps to align with
DORA’s provisions, prioritising enhancements to its ICT
risk management framework, refining incident reporting
processes, and strengthening governance over third-
party ICT service providers. These efforts ensure that
the Bank is well-prepared to meet the regulation’s
requirements and can maintain the high standards of
digital operational resilience.
ESG regulations
Sustainability remained a key priority in 2024, as several
regulatory advancements shaped the ESG landscape:
• The Corporate Sustainability Due Diligence Directive
(CSDDD) introduced requirements for identifying,
mitigating, and addressing environmental and social
risks in the value chain.
• The regulation on ESG Ratings established standards
for transparency and reliability in ESG rating activities,
enhancing comparability for stakeholders.
• Amendments to the Companies Act (ZGD-1M)
incorporated EU sustainability reporting requirements
under the CSRD, mandating companies to disclose
sustainability information using the European
Sustainability Reporting Standards (ESRS).
In line with these developments, the Group is publishing
its sustainability statement, fully aligned with the CSRD
framework, reflecting its commitment to transparency,
accountability, and sustainable growth. Regular
internal policies and process updates ensure the Group
remains aligned with evolving ESG standards and
regulatory expectations.
Anti-Money Laundering Directive VI (AMLD VI)
In 2024, the EU adopted the sixth Anti-Money
Laundering Directive (AMLD VI), further harmonising
measures to combat money laundering and terrorist
financing across member states. This directive
introduces stricter penalties for non-compliance,
enhanced cross-border cooperation, and additional
180 NLB /
107 NLB Group
number of changes
in the regulatory
environments with
material effects,
published in 2024

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requirements for beneficial ownership transparency and
risk-based due diligence.
Payment Services, Electronic Money Issuing Services,
and the Payment Systems Act
In 2024, Slovenia adopted amendments to Payment
Services, Electronic Money Issuing Services, and the
Payment Systems Act (ZPlaSSIED-B) to align with
evolving EU regulations. The updated act focuses
on enhanced transparency, user protection, and
operational security in payment systems. The Bank
is analysing these amendments and will adapt its
operations to ensure full compliance with the new
requirements, further reinforcing its commitment to
providing secure and transparent payment services.
Regulatory
environment in the
Group’s region
The regulatory environment in the rest of the region
where the Group operates was dominated by actions to
ensure the stable functioning of financial systems.
In Serbia, the Law on Amendments and Supplements to
the Law on Payments Services, implementing the PSD2,
was adopted in July 2024, with an application date set
for May 2025. This law aims to enhance competition
and transparency in providing payment services,
primarily by introducing a payment initiation service
and account information service. It also strengthens
customer protection and security while executing
payment transactions and regulates the actions of
payment service providers in case of suspected fraud
and abuse. The obligations regarding strong customer
authentication and communication standards between
payment service providers, payers and payees,
introduced by this law, are further detailed in the
Decision on Technical Standards for Strong Customer
Authentication and Common Secure Open Standards
of Communication, which shall be applicable as at
1 January 2026. Additionally, the new Decision on
Minimum Information System Management Standards
for Financial Institutions has been adopted, with an
application date as at 1 January 2026. This decision
provides detailed regulations on managing ICT system
risk – ICT incidents and their reporting and overall
information security.
Drafts of the Law on Amendments and Supplements
to the Law on Banks, and the Law on the Protection
of Financial Service Consumers were also published.
Novelties of the Law on Banks mainly focus on the
internal control system, competencies, and organisation
of the Bank’s bodies, corporate governance, risk
management and supervision authorities of the
National Bank of Serbia (NBS). One of the main
novelties is mystery shopping in the area of financial
services, along with the possibility of audio recording
of employees without their explicit consent during the
supervision of the Bank.
Additionally, the Law on Amendments and Supplements
to the Law on the Prevention of Money Laundering and
Financing of Terrorism, and the Law on Amendments
and Supplements to the Law on Freezing of Assets
with the Aim of Preventing Terrorism and Proliferation
of Weapons of Mass Destruction were adopted in
November 2024. The most significant amendments
relate to the definition of a beneficial owner, the
obligation to assess the risk of financing the proliferation
of weapons of mass destruction while conducting
various actions, the requirement for a payee’s payment
service provider to reject payment transfers if it has not
collected and verified the payer’s data, restrictions on
cash transactions, new obligations for banks to retain
and provide certain data to the competent authorities
upon request, and more.
In 2024, North Macedonia continued the process of
harmonising its legislation with the Law on Payment
Services and Payment Systems, along with related by-
laws. Several new by-laws were adopted or amended in
various areas related to this law and are in the process
of implementation in the bank or already implemented.
Two new laws were adopted: the Law on Prospectus
and Transparency Obligations of Issuers of Securities,
which largely aligns with the European regulations (such
as Directive 2004/109/EC of the European Parliament,
and of the Council of 15 December 2004 on the
harmonisation of transparency requirements in relation
to information about issuers whose securities are
admitted to trading on a regulated market), and the Law
on Financial Instruments, largely aligned with Directive
2014/65/EU on markets in financial instruments and
Regulation (EU) No. 600/2014 on markets in financial
instruments – MiFID II, as well as other EU directives.
These laws were adopted with a delayed application
period of 18 months from their entry into force. Also,
many new by-laws related to these laws were adopted
throughout the year.
The National Bank of the Republic of North Macedonia
adopted several significant acts, including: the Decision
on Amending and Supplementing the Decision on
the Methodology for Credit Risk Management; the
Decision on Amending and Supplementing the
Decision on the Methodology for Determining Capital
Adequacy; the Decision on Mandatory Reserve; the
Decision on Amending the Decision on Determining the
Requirements for Enhanced Authentication and General,
Secure and Open Communication Standards; and the
Guidelines for Consumers with Disabilities in the Banking
Sector from the NBRNM. Additionally, a new Rulebook
on the security of personal data processing with a
prolonged application was adopted.
In the Federation of Bosnia and Herzegovina, the most
important regulatory decision in 2024 was the adoption
and implementation of the new AML/CFT Law. This
regulation harmonises local legislation with elements of
the 5th and 6th AML/CFT Directives, while incorporating
certain local specifics such as the special risk assessment
of clients, additional indicators of suspicious transactions,
specific methods for determining and recording
the beneficial owner, and more. In the same year,
implementing acts related to this law were also adopted.
The implementation of the Financial Regulator’s
Guidelines related to ESG continued throughout 2024.
In August 2024, the regulator published a draft of a
new Decision for Managing the Information Systems in
Banks. The draft proposes a clearer and more robust
framework for managing information systems in banks,
as well as detailed requirements for the supervision of
information systems by the regulator. Banks provided
comments on the draft, but the Decision has not yet
been adopted.
Following the catastrophic floods in one part of Bosnia
and Herzegovina, the regulator adopted "Specialist

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supervisory expectations regarding the treatment of
banks and ensuring business continuity in emergency
situations". The aim of these expectations is to ensure
adequate business continuity plans (BCP) placed in
banks for unforeseen events.
In November 2024, the regulator introduced a set
of decisions related to the reporting on persons in a
special relationship with the bank and maintaining
mandatory reserves. The mentioned regulation is in the
implementation, or has already been implemented by
the bank.
To preserve the stability of the banking sector in the
Republic of Srpska, several decisions on temporary
measures have been made, among which the most
important are a Decision on Temporary Measures
for the Approval of Reliefs to Private Individuals for
Settlement of Credit Obligations, and a Decision on
Temporary Measures for the Approval of Reliefs to
Legal Entities for Settlement of Credit Obligations.
These measures aim to grant relief to bank clients by
reprogramming or restructuring loans.
Moreover, the National Assembly of the Republic of
Srpska has adopted the Law on Amendments to the
Family Law (the amendments exclude "cash" from the
property of minors that parents could dispose of with
the prior consent of the guardianship authority), and the
Law on Amendments to the Law on Foreign Exchange
Operations. The latter includes: (i) allowing foreign
exchange payments and disbursements of cash foreign
currency to be made, not only between accounts of the
same person, but also to the foreign exchange account
of a close family member with the same or different
bank; and (ii) the institute of syndicated loans, defining
the procedure for payments and collections on behalf of
participation in syndicated loans.
At the national level, the Parliamentary Assembly
of Bosnia and Herzegovina has passed the Law on
Preventing Money Laundering and Terrorist Financing,
which introduces several updates, such as new terms
like "virtual currency," "provider of services related to
virtual currencies," "electronic money," and alignment
of the definition of politically exposed persons (PEP)
with EU regulations. The law also provides enhanced
identification and monitoring measures for clients
from high-risk countries, provisions on cash payment
restrictions, and new reporting obligations to the
Financial Intelligence Unit. The manner of cooperation
between supervisory authorities is additionally
regulated, and penalty provisions are defined more
clearly and strictly.
In late November 2024, the Kosovo Assembly adopted a
package of laws, including the updated Law on Banking
and the Law on Payment Services. This legislative
package will be effective in 2025.
Through the Banking Association, the bank actively
participated and contributed to the amendment of
these laws which impact banking processes. Following
the enactment of the Payment and Services Law, within
the SEPA (Single Euro Payment Area) project, which
drives payment system upgrades in alignment with
EU requirements, the Central Bank adopted several
regulations which will come into force in 2025, 10 days
after the law becomes effective.
In addition to SEPA-related regulations, the Central Bank
of Kosovo has introduced several other regulations. The
bank’s main activities concerned the implementation
of the requirements from the Regulation on Register
of Banking Accounts, the Regulation on Directors
and Senior Managers of Banks, the Regulation on
Country and Transfer Risk Management Principles, the
Regulation for the Prevention of Money Laundering and
Financing of Terrorism, the Regulation on Information
That Should Accompany Fund Transfers, Guidance on
Policies and Procedures for the Effective Management
of the Risk of AML/FT; QR code Standard, and more. It is
also worth mentioning the ongoing efforts and activities
by the bank and the banking sector to implement
electronic/digital signatures.
In 2024, the main activities in Montenegro focused
on implementing the Law on Prevention of Money
Laundering and Terrorism Financing and relevant
bylaws. The most important novelties introduced
by the law include: the obligation for an authorised
person to possess a license for the prevention of
money laundering and terrorism financing; supervision
over the Register of Beneficial Owners, as well as
enabling the public to access the Register of Beneficial
Owners (a certain data set); preventing clients from
using falsified personal documents by prescribing the
possibility for the obligee of the Law to use the Central
Population Register; introduction of electronic and
video-electronic identification of the client; strengthening
of the supervision over the obligee of the law (direct and
indirect supervision); establishment of the Register of
Politically Exposed Persons, and the Register of Accounts
and Safety Boxes to which the financial intelligence
unit will have access; the obligation to appoint a
member of the governing body – responsible for the
implementation of the law; additional data needed
when transferring funds; verification of PEP status for life
insurance beneficiaries; exceptions to the confidentiality
principle in relation to correspondent banks in the event
of customer identification and verification; the amount of
penalties in case of non-compliance with the provisions
of the law up to EUR 1 million.
To integrate the Montenegrin financial system into the
European Economic and Market Area, the Montenegrin
Central Bank (MCB) adopted the Decision on the
Requirements for Credit Transfers and Direct Debits in
Euro within the SEPA, which requires certain adjustments
to banks’ operations. With the assistance from NLB, the
bank is working on implementing these SEPA-related
requirements.
An important amendment has also been made to the
Decision on the Remuneration in Credit Institutions.
By amending the Decision, the postponement applies
only to employees whose variable remuneration on an
annual basis exceeds the sum of EUR 30 thousand and
30% of fixed income on an annual basis. There is no
deferral of remuneration for employees whose variable
remuneration is equal to or below the stated thresholds.

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Collaboration, dedication,
and a shared vision drive business
success. The Business Report
provides a detailed analysis
of the NLB Group’s financial
and operational performance,
highlighting strategies,
sustainability performance,
achievements, and challenges,
while addressing compliance,
risk management, and
key business updates.
BUSINESS
REPORT

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Strategy*
NLB Group introduced its new Group Strategy 2030 in May 2024. The new strategy equally balances revenue
generation based on best practices (housing financing, bancassurance, consumer finance, trade finance, transition
finance, and payments) and the transformation of NLB into the leading operating platform in the region through
rigorous simplification and digitalisation, while maintaining its prudent risk practices.
The Group has continued implementing its medium-term
strategy, protecting and strengthening its market position
in its home region, actively participating in market growth
and consolidation, and promoting the ESG agenda.
In May 2024, the Group introduced its new Group
Strategy 2030, key performance indicators, and
expected future development. With the new Group
Strategy 2030, the Group responds to the changing
banking environment and upcoming challenges and
addresses new opportunities. The Group’s ambition
remains to create sustainable growth to support
individuals, businesses, and society. Overall, the new
strategy foresees the doubling of the NLB Group balance
sheet to more than EUR 50 billion in assets, recurring
revenues of more than EUR 2 billion, and a profit of more
than EUR 1 billion by 2030 (combining organic growth
with selected M&A) across the SEE region.
The Group focuses on the following four areas:
prioritising customers’ needs, delivering on its
shareholders’ expectations, ensuring stability,
nurturing talent, and fostering culture. Firstly, the Group
continuously focuses on enhancing the external and
internal customers’ user experience across all channels
by providing best-in-class support, products, and
solutions. It also focuses on providing all mass banking
services and their seamless experience through digital
platforms, using advanced technology to deliver
fast, secure, and convenient solutions. Secondly, the
Group is committed to delivering excellent returns to its
shareholders, aiming to increase the pay-out ratio to
50–60% of the previous years’ profit after tax throughout
the period. The Group is also committed to ensuring
stability by being a trustworthy partner and a systemic
provider of client-relevant universal financial services
across all SEE target markets, supporting the economy,
the community, and sustainability, as well as promoting
culture and sports. Additionally, the Group focuses on
developing future employees by uplifting, enhancing, and
renewing their skills.
The Strategy 2030
foresees doubling NLB
Group’s balance sheet,
revenues, and profit
by 2030
Figure 5: NLB Group's Strategy 2030 key focus
Delivering on our
shareholders expectations:
NLB Group aims to increase the dividend pay-out
ratio to 50-60% throughout the period.
Ensuring stability:
By prudent risk management and strategic
investments, we are safeguarding the financial
welfare of the Group and broader economy,
supporting Southeast Europe’s development.
Nurturing talent
and fostering culture:
By uplifting, enhancing, and renewing their skills,
we are developing employees of the future, ready
to thrive in the face of tomorrow’s challenges.
Prioritising customer’s needs:
We will focus on enhancing our customers’
user experience across all channels, providing
best in class support, products and solutions in
mortgages, bancassurance, consumer finance
and sustainable financing, and increase digital
penetration in our home region.
Ambitious growth
across the SEE region:
NLB Group aims to double its balance
sheet, revenues, and profit by 2030.
EUR
>50
billion
in total
assets
EUR
>2
billion
of recurring
revenues
EUR
>1
billion
profit
* Incorporation by reference: The reference is made to this chapter from the
Sustainability Statement chapter SBM-1 Strategy, business model, and value chain.

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Retail banking
segment*
In the retail banking segment, the strategic goal by 2030
is to be the leading bank in SEE, to increase the number
of customers to over 3 million and achieve more than
80% digital penetration. The Group’s strategy is built
on three lines of attack: better monetising its existing
client base, doubling down on attractive sub-segments,
and scaling its product verticals around key customer
needs. At the same time, the Group will consciously
include additional success markers, digitise its franchise,
and move to a customer-centric delivery model with
mobile as the core channel. The Group will move to
an advisory-driven branch model, offering a market-
leading customer experience on par with international
best practices. The Group aims to positively contribute
to the societies it serves, with a solid commitment to
developing the market for investments and financial
protection/insurance across the region.
Corporate and
investment banking
segment*
The Group aims to become the strategic banking
partner for corporations across the SEE region, making
it the leading local corporate and investment banking
bank and achieving profitable growth across markets,
while keeping close control of risk (with CoR lower than
50 bps). The Group’s strategy is based on three lines
of attack: being consistently better in its existing core,
becoming the transition finance leader in the region
while driving SME and trade finance, and remaining
stewards of prudent risk management. To enable the
strategy, the Group will innovate its operating model
end-to-end by digitising and streamlining processes,
especially in onboarding and underwriting. At the same
time, the Group remains deeply committed to the region;
accordingly, the Group Corporate and Investment
Banking will position itself as the leader in transition
finance in SEE by 2030 – leveraging NLB’s balance sheet
and providing attractive investment opportunities to
outside investors.
Payments*
The Group’s ambition in the field of payments is
to support NLB’s growth path towards becoming
the leading bank in SEE with best practices across
customer and operating models, introducing digital
payment solutions, and driving the cash transition in
the markets in which the Group operates. The Group’s
strategic goal in the field of payments is that by 2030,
the share of mobile active users will exceed 80%. The
Group’s strategy builds on the solid basis of the existing
payments strategy through three lines of attack: driving
the regional cash transition, focusing on merchant
acquiring, and developing new propositions. Payments
will also positively contribute to the societies the Group
serves – by actively driving the markets’ cash transition.
The Group will help the societies prosper, increase
financial inclusion, and combat the shadow economy.
Further information on the Group Strategy 2030 is
available on the NLB website.
* Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter SBM-1 Strategy, business model, and value chain.

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Funding Strategy,
MREL Compliance, and Capital
Fostering strong client relationships is vital for maintaining a stable and growing deposit base. At the same time,
wholesale funding focuses on meeting MREL requirements and optimising capital, which leads to increased average
funding costs. Nonetheless, the overall funding costs remains low thanks to a reliable deposit base and the stability
of sight deposit pricing, which remains unaffected by market fluctuations.
Deposit strategy
Deposits from customers represent the primary funding
source for the NLB Group, and each bank within the
Group has established processes that enable prudent
strategic deposit management aligned with business
targets and regulatory requirements. Regularly
monitoring deposits and their structure enables timely
reactions whenever necessary due to business or
regulatory-related reasons. Following the disruptive
2020–2023 period, when NLB Group still maintained
a healthy liquidity profile, year 2024 brought inflation
stabilisation and a general decrease in interest rates.
NLB Group’s liquidity profile remained robust, with a
slightly increased LTD ratio still cruising below 75%
through 2024, thus representing a strong structural
liquidity position that enables the realisation of
investment opportunities as set in the adopted NLB
Group Strategy.
A strong market position, proactive client relationships,
and a sound franchise name are crucial for maintaining
a stable deposit base. The Group’s fund pricing adheres
to international standards, and effective deposit pricing
plays a key role in prudent risk management and
strategic decision-making. In 2024, the significance of
agile deposit pricing and active client engagement was
further emphasised in competitive markets. All Group
banks defended their market positions, aligning with
strategic objectives. By initiating the interest rates cutting
cycle in 2024, the ECB also induced trend reversal
on deposit markets, prompting NLB Group banks to
gradually stabilise deposit interest rates to align with
interest rates dynamics on the asset side in terms of
business profitability.
NLB Group retail deposits represent a majority in the
structure and are the most stable funding source, with
around 80% insured by the Deposit Guarantee Scheme.
Despite persistently competitive circumstances in
deposit markets, Group retail deposits recorded strong
single-digit growth in 2024. Sight deposits maintained
structural dominance as they represented 82% of the
Group’s total retail deposits, signalling a stable deposit
structure supporting planned business performance.
Corporate sector deposits represent around 30% of the
NLB Group deposit base. Despite increased price levels,
combined with uncertainties related to the economic
outlook in recent years, the Group’s corporate deposit
base became stronger, grew at a notable pace, and
remained structurally stable also in 2024 as well.
The overall cost of funding remains low thanks to a
reliable deposit base and the stability of sight deposits.
Figure 6: Average cost of funding (quarterly data)
Q1 2024
Q2 2024
Q3 2024
Q4 2024
6.13%
0.98%
0.53%
5.96%
1.04%
0.55%
6.10%
1.04%
0.55%
5.78%
1.01%
0.56%
Total average cost of funding
Average interest rate for deposits from customers
Average cost of wholesale funding

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Wholesale funding
and MREL
Wholesale funding activities in the Group aim to achieve
diversification, improve structural liquidity and capital
position, and fulfil regulatory requirements, especially
compliance with the MREL requirements.
The Bank was active on international capital markets
in 2024, issuing 10NC5 subordinated Tier 2 notes in
January to improve the capital position and 6NC5 senior
preferred notes in May for MREL purposes.
The Preferred Resolution Strategy (PRS) for the NLB Group
is based on the Multiple Point of Entry (MPE) strategy.
Bail-in at the level of NLB is the primary resolution tool to
be applied during the stabilisation phase.
Within the NLB Group, seven resolution groups are
designated. The resolution group in the Banking Union
is headed by NLB, and the remaining six resolution
groups are headed by the banking subsidiaries
located in non-EU countries (Bosnia and Herzegovina,
Montenegro, and Serbia, while Kosovo and North
Macedonia have not yet implemented MREL legislation).
Figure 7: Resolution groups within NLB Group
NLB d. d.
&
NLB Lease&Go, leasing, SLS Group, NLB Skladi, Other
SLO
SRB
NLB
Komercijalna Banka,
Beograd
MNE
NLB Banka,
Podgorica
BIH
NLB Banka,
Banja Luka
BIH
NLB Banka,
Sarajevo
RKS
NLB Banka,
Prishtina
MKD
NLB Banka,
Skopje
The NLB Resolution Group consists of NLB as the only
banking member and other non-banking members, the
latter representing 13% in TREA. The entities and their
contribution to TREA of the NLB Resolution Group are
presented in the table below.
Table 5: Contribution to NLB Resolution Group’s TREA
in EUR millions
Entity
31 Dec 2024
NLB d.d.
8,782
SLS Group
830
NLB Lease&Go, leasing, Ljubljana
279
NLB Lease&Go Leasing Beograd
96
NLB Skladi, Ljubljana
66
Other
63
TREA total:
10,115
NLB has to ensure a linear build-up of its own funds
and eligible liabilities towards the MREL requirement
applicable as of 1 January 2024, which amounts to:
• 30.66% of TREA + applicable CBR (4.38% on
31 December 2024),
• 10.69% of LRE.
On 31 December 2024, the MREL ratio amounted to
37.47% TREA and 21.43% LRE, which was well above the
required level.
SEE banking members in Bosnia and Herzegovina,
Serbia, and Montenegro are subject to local
MREL requirements.
Figure 8: Evolution of MREL eligible funding (in EUR millions),
MREL requirement and realised MREL ratio
31 Dec 2022
31 Dec 2023
31 Dec 2024
2,733
1,057
2,358
964
2,041
489
36.31%
40.24%
37.47%
35.04%
31.91%
28.69%
Realised MREL ratio
CET1+T1+T2
MREL requirement (including CBR)
MREL deposits and senior funding
Resolution group
MREL legislation not implemented yet

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Capital and capital adequacy
Pillar 1
Pillar 2
TSCR
Combined Buffer
P2G
OCR+P2G
1.00%
2.53%
1.90%
11.07%
4.38%
2.00%
0.53%
2.53%
1.50%
0.40%
1.90%
4.50%
1.19%
5.69%
8.00%
2.12%
10.12%
OCR+P2G
15.50%
OCR
14.50%
T2
CET1
AT1
Capital requirements
The NLB ensures ongoing compliance with capital
adequacy requirements set out by the applicable
regulatory framework. These requirements are defined
by the Supervisory Review and Evaluation Process
(SREP) and are complemented by capital buffers to
mitigate risks and enhance financial stability.
At the end of 2024, the Bank’s Overall Capital
Requirement (OCR) on a consolidated basis was 14.50%,
which is slightly lower (by 0.01%) than at the end of 2023.
However, the reduction in the SREP requirement by
0.28% was offset by an increase in the Countercyclical
buffer by 0.26%. The OCR comprises:
Total SREP Capital Requirement (TSCR): 10.12%, which
includes:
• 8.00% Pillar 1 requirements and
• 2.12% Pillar 2 requirements (P2R).
Combined Buffer Requirement (CBR): 4.38%,
consisting of:
• 2.50% Capital Conservation Buffer,
• 1.25% O-SII Buffer,
• 0.52% Countercyclical Buffer (CCYB)5 and
• 0.11% Systemic Risk Buffer6.
In addition to the mandatory capital requirements, the
regulator has recommended a Pillar 2 Guidance (P2G)
at 1.0% of Common Equity Tier 1 (CET1), which the Group
maintains as a safeguard against severe economic
stress scenarios.
5 The Bank of Slovenia has increased the countercyclical capital buffer for exposures in Slovenia from 0% to 0.5%. The Bank had to meet the required buffer from 31 December 2023 onwards. The level of the countercyclical capital buffer
for the NLB Group is also affected by the CCYB buffers of the Group members.
6 Starting from 1 January 2023, the Bank of Slovenia has made it mandatory for banks to maintain a systemic risk buffer for sectoral exposures. The required rates are 1.0% for all retail exposures to natural persons secured by residential
real estate and 0.5% for all other exposures to natural persons.
Key developments during the year
• Effective from 1 January 2024, NLB has lower capital
requirements. On 1 December 2023, NLB received a
new SREP decision on a consolidated basis for 2024.
As per the decision, the Pillar 2 Requirement was
reduced by 0.28 p.p. to 2.12%, reflecting an improved
overall SREP assessment. At the end of 2024, the Pillar 2
requirement remains unchanged.
• The countercyclical capital buffer for the NLB Group
was 0.52% (or 26 p.p. increase YoY), also affected by
the CCYB buffers of the Group members (NLB, NLB
Banka, Skopje, and NLB Banka, Prishtina in 2024).
Future changes in buffer rates
Effective 1 January 2025, changes to capital buffer rates
in Slovenia will be implemented.
• The CCYB rate for exposures in Slovenia will increase
from 0.5% to 1.0%.
• The sectoral systemic risk buffer for retail exposures to
natural persons secured by residential real estate will
be reduced from 1.0% to 0.5%.
In addition, the CCYB for the Group is expected to be
higher due to the introduced CCYB in the Group members
(NLB Banka, Skopje, and NLB Banka, Podgorica).
Figure 9: NLB Group capital requirements as at 31 December 2024

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Capital adequacy
Table 6: Capital realisation YoY and surplus over the regulatory requirement of the NLB Group as of 31 December 2024
in EUR millions
31 Dec 2024
31 Dec 2023
Change YoY
Surplus over
OCR+P2G
31 Dec 2024
Common Equity Tier 1 capital
2,786
2,510
276
769
Tier 1 capital
2,872
2,598
275
510
Total capital
3,411
3,109
302
588
Total risk exposure amount (RWA)
18,216
15,337
2,879
Common Equity Tier 1 Ratio
15.29%
16.36%
-1.07 p.p.
4.22 p.p.
Tier 1 Ratio
15.77%
16.94%
-1.17 p.p.
2.80 p.p.
Total Capital Ratio
18.73%
20.27%
-1.55 p.p.
3.23 p.p.
As at 31 December 2024, the Group’s TCR stood at 18.7%
(or 1.5 p.p. decrease YoY), and the CET1 ratio stood at
15.3% (or 1.1 p.p. decrease YoY), which is well above
requirements. The lower total capital adequacy derives
from higher RWA (EUR 2,878.9 million YoY), although
capital increased by EUR 302.1 million YoY. The Group
increased its capital by partially including 2024 profit
(EUR 257.0 million) and revaluation adjustments (EUR
56.5 million).
Figure 10: NLB Group capital (in EUR millions), realised total
capital ratios and regulatory thresholds

Figure 11: NLB Group CET1 (in EUR millions), realised CET1 ratio
and regulatory requirement

Figure 12: Capital (in EUR millions) and capital ratios of NLB
Group – evolution YoY

31 Dec 2022
31 Dec 2023
31 Dec 2024
2,872
539
2,598
511
2,296
511
3,411
3,109
2,806
15.50%
15.51%
15.10%
19.15%
20.27%
18.73%
TCR realised
OCR + P2G requirement
Tier 1
Tier 2
31 Dec 2022
31 Dec 2023
31 Dec 2024
2,786
2,510
2,208
11.07%
10.96%
10.46%
15.07%
16.36%
15.29%
CET1 ratio realised
CET1 (OCR + P2G) requirement
CET1
31 Dec
2023
Result
OCI +
other
SLS Group
impact
RWA
impact
31 Dec
2024
20.3%
1.4%
3,109
3,411
0.3%
-0.8%
Capital
-2.5%
18.7%

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Dividend payout
The total cumulative payout in the year amounted to
EUR 220.0 million. The dividend payout was structured
into two tranches. The first instalment of EUR 110.0
million was paid in June 2024, followed by a second
instalment of the same amount, EUR 110.0 million, in
December 2024.
Total risk exposure
dynamic
In 2024 (YoY), the RWA of the Group for credit risk
increased by EUR 2,340.3 million due to lending activity
in the corporate and retail segments, of which the
acquisition of the SLS Group companies contributed
to a higher RWA by EUR +698.0 million. RWA for high-
risk exposures increased due to new project financing
loans and withdrawal of previously approved project
finance loans. Furthermore, higher RWA for liquidity
assets resulted from EUR-denominated placements
with central banks and liquidity surpluses placed at
commercial banks.
Starting from 1 January 2025, the calculation of RWA
for credit risk is based on CRR3 regulation. NLB Group
is using the Standardised approach; therefore, no
materially significant changes in the calculated volumes
are expected. Nevertheless, the cumulative result of
the new regulation will lead to the increase in RWA,
primarily due to increased credit conversion factor
(CCF) for unused credit lines and the introduction of an
FX lending multiplier for lending to private individuals
in non-domestic currency. Partially, the increases will
be compensated by more favourable risk weights for
residential real-estate collateral.
The increase in RWAs for market risks and Credit Value
Adjustments (CVA) by EUR 59.8 million YoY was driven by
a higher RWA for FX risk of EUR 58.6 million (mainly the
result of more open positions in domestic currencies of
non-euro subsidiary banks), and slightly higher RWA for
CVA risk of EUR 2.4 million (calculating exposure value
for derivative transactions subject to CRR risk based on
OEM method).
31 Dec 2021
31 Dec 2022
31 Dec 2023
31 Dec 2024
10,205
1,244
12,667
59%
61%
Figure 13: RWA structure (in EUR millions)
59%
65%
RWA /
Total
Assets
14,653
15,337
18,216
1,218
1,410
1,445
1,707
1,462
2,186
1,522
11,798
12,168
14,508
Credit risk
Market risk incl. CVA
Operational risk
CAGR: 12.9%
YoY: 18.8%
The increase in the RWA for operational risks (EUR 478.9
million YoY) derived from the higher net interest and
net fee and commission income, mainly from the NLB,
NLB Komercijalna Banka, Beograd and Summit Leasing
Slovenija, resulting in a higher three-year average of
relevant income. There were no significant deviations
from previous years in the other components used in
the calculations.
Further information on capital and capital adequacy is
available in the Financial Report of this Annual Report
and in Pillar 3 Disclosures.

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Risk Factors and Outlook
Risk factors
Risk factors affecting the business outlook are (among
others):
• The economy’s sensitivity to a potential slowdown in
the euro area or globally
• Potential liquidity outflows
• Widening credit spreads
• Worsened interest rate outlook/Persistence of
high inflation
• Energy and commodity price volatility
• Increasing unemployment
• Geopolitical uncertainties
• Potential cyber-attacks
• Litigation risks
• Regulatory, other legislative, and tax measures
impacting the banks
The growth of the euro area economy stagnated in
2024, while other countries in NLB Group’s region were
growing faster, with household consumption being the
main driving factor of growth. Wage growth remained
elevated, impacting to reaccelerate inflation. Lending
growth, which was modest in the previous year due
to increasing interest rate trends, peaked in 2024.
Nevertheless, potentially high inflationary pressures,
increased unemployment, lower-than-expected GDP
growth, and geopolitical and other uncertainties
could lead to a slowdown in private consumption and
investment growth.
Credit risk usually increases considerably in times of an
economic slowdown. During 2024, the Group’s credit
portfolio remained high-quality and well-diversified,
with a stable rating structure and lower NPLs level. There
was no large concentration in any selected industry
sector. The latter is particularly important as geopolitical
tensions, the green transition, and other macro
developments could materially impact specific industry
sectors. The Group monitored the macroeconomic and
geopolitical circumstances closely and remained very
prudent in identifying any increase in credit risk at a very
early stage and proactive in NPL management.
Furthermore, unfavourable trends in the German
automotive industry did not severely influence the
Slovenian export-oriented industry. Having that in
mind, the bank downgraded some selected clients in
stage 2 and formed additional impairments, though the
overall cost of risk remained at a relatively low level. The
aforementioned adverse developments could affect the
cost of risk and NPLs. Notwithstanding the established
procedures in the Group’s credit risk management,
there can be no certainty that they will be sufficient to
ensure the Group’s credit portfolio quality or that the
corresponding impairments will remain adequate.
The investment strategy of the Group, referring to the
Group’s bond portfolio kept for liquidity purposes,
adapts to the expected market trends in accordance
with the set risk appetite. Investment activity continued
with a balanced approach to finding attractive market
opportunities while pursuing a well-managed credit
spread, interest rate risk, and capital consumption.
Geopolitical uncertainties impacted the volatility in the
financial markets, particularly shifts in credit spreads,
interest rates and foreign exchange rate fluctuations.
The Group closely monitors its prominent bond portfolio
positions, mostly sovereigns, and carefully manages
them by incorporating adequate early warning systems
to limit the potential sensitivity of regulatory capital.
So far, no material movements regarding the Group’s
significant FX positions have been observed. Current
developments, market observations, and potential
mitigations are closely monitored and discussed. While
the Group monitors its liquidity, interest rate, credit
spread, FX position, and corresponding trends, their
impacts on the Group positions, and any significant and
unanticipated movements on the markets or a variety
of factors, such as competitive pressures, consumer
confidence, or other certain factors outside the Group’s
control, could adversely affect the Group’s operations,
capital, and financial condition.
Special attention is paid to the continuous provision of
services to clients, their monitoring, and the prevention
of cyber-attacks and potential fraud events. The Group
has established internal controls and other measures
to facilitate adequate management. However, these
measures may only sometimes entirely prevent possible
adverse effects.
With regard to litigation risk, in recent years, and even
more so in recent periods, the Bank has seen a shift in
case law that is generally more favourable to consumers,
e.g. litigation cases related to loan processing fees and
loan insurance premiums in Serbia and CHF litigations in
Slovenia. In the latter case, we have noticed an increase
in the number of proceedings against the Bank, which
was expected. The current litigations against the Bank
referring to CHF are less material, but the Bank is closely
monitoring developments.
The Group is subject to various regulations and laws
relating to banking, insurance, and financial services.
Respectively, it faces the risk of significant interventions
by several regulatory and enforcement authorities in
each jurisdiction in which it operates, including changes
in the tax treatment of banking business and changes in
the interpretation of legislation.
The SEE region is the Group’s most significant geographic
area of operations outside the RoS, and the economic
conditions in this region are, therefore, crucial to the
Group’s operations and financial condition results. The
Group’s financial condition could be adversely affected
by any regional instability or economic deterioration.
In this regard, the Group closely follows the
macroeconomic indicators relevant to its operations:
• GDP trends and forecasts,
• Economic sentiment,
• Unemployment rate,
• Consumer confidence,
• Construction sentiment,
• Deposit stability and growth of loans in the
banking sector,
• Credit spreads and related future forecasts,
• Interest rate development and related future forecasts,
• FX rates,
• Energy and commodity prices,
• Other relevant market indicators.

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In H1 2024, the Group regularly reviewed the IFRS 9
provisioning by testing the relevant macroeconomic
scenarios to adequately reflect the current circumstances
and their future impacts. The Group established multiple
scenarios (i.e., baseline, optimistic, and severe) for the
Expected Credit Losses (ECL) calculation, aiming to
create a unified projection of the macroeconomic and
financial variables for the Group, aligned with the Bank’s
consolidated view of the future of economic development
in the SEE. The Group formed three possible scenarios
with an associated probability of occurrence for forward-
looking assessment of risk provisioning in the context
of the IFRS 9. These IFRS 9 macroeconomic scenarios
incorporate the forward-looking and probability-
weighted aspects of the ECL impairment calculation.
Both features may change when material changes in the
future development of the economy are recognised and
not embedded in previous forecasts.
The baseline scenario presents a forecasted
macroeconomic view for all the countries of the
Group. This scenario is based on recent official and
professional forecasts, with specific adjustments for
individual countries of the Group. Key characteristics
include decreasing inflation as the energy-related
impact on goods and services prices abates, a slightly
less tight labour market, GDP growth supported by
declining interest rates, and strong private consumption
due to real wage growth, a resilient labour market and
positive expectations, industry and export activity pick-
up, and the limited spillover effects of financial system
issues/major trading partners’ growth slowdown on the
real economy.
The alternative scenarios are based on the plausible
drivers of economic development over the next three
years. The optimistic alternative scenario demonstrates
supply-driven positive developments. Supply chains
adapt swiftly and support an optimistic economic
stance – keeping a lid on inflation pressures. Labour skill
mismatches are addressed through targeted training
programs. Automation and technology adoption create
new job opportunities, offsetting any displacement. In
the short term, financing conditions ease, and business
confidence rebounds. Consumer spending picks up,
contributing to overall growth. The ECB considers both
demand and supply factors when setting interest rates.
In this scenario, the ECB maintains a dovish stance,
easing aggressively until the inflation rebounds towards
the ECB target.
The severe alternative scenario paints a picture of bleak
economic developments, where supply constraints,
geopolitical tensions, technological shifts, and labour
market disruption hinder economic recovery. Moreover,
high public debt diverts funds from productive
investments. Policymakers must navigate these
challenges to ensure stability and sustainable growth.
This adverse scenario results in a prolonged global
recession, with growth falling well below the levels
needed to achieve sustainable development goals in
the mid-term. The ECB carefully considers demand and
supply factors when setting interest rates to prevent
abrupt economic shifts.
The Bank considers these scenarios when calculating
expected credit losses in the context of IFRS 9. On this
basis, the Group revised scenario weights in H1 2024.
The assigned weights were 20%–60%–20% (alternative
scenarios receiving 20% each, and the baseline
scenario 60%).
The Group established a comprehensive internal
stress-testing framework and early warning systems in
various risk areas with built-in risk factors relevant to the
Group’s business model. The stress-testing framework
is integrated into the Risk Appetite, the Internal Capital
Adequacy Assessment Process (ICAAP), the Internal
Liquidity Adequacy Assessment Process (ILAAP), and the
Recovery Plan to determine how severe and unexpected
changes in the business, geopolitical, and macro
environments might affect the Group’s capital adequacy
or liquidity position. The stress-testing framework and
recovery plan indicators support proactive management
of the Group’s overall risk profile in these circumstances,
including capital and liquidity positions from a forward-
looking perspective.
Risk Management actions that the Group might use
are determined by various internal policies and
applied when necessary. Moreover, the selection and
application of mitigation measures follow a three-layer
approach, considering the feasibility analysis of the
measure, its impact on the Group’s business model, and
the strength of the available measure.
Outlook
The indicated Outlook constitutes forward-looking
statements subject to several risk factors and is not
a guarantee of future financial performance. The
NLB Group is pursuing various strategic activities to
enhance its business performance. The interest rate
outlook is uncertain, given the adaptive monetary
policy of the ECB and local central banks to the general
economic sentiment.
GDP growth in the euro area should accelerate in 2025.
Private spending will gain traction on lower inflation, and
fixed investment is set to rebound due to looser financing
conditions. Higher U.S. tariffs pose a downside risk,
along with a sustained weakness in Germany’s industrial
sector. Still, high long-term interest rates could pose a
problem for new investments (especially in industry)
and governmental borrowing. In Slovenia, economic
growth in the coming years will be supported by private
consumption underpinned by high employment, real
income growth, and gradually improving consumer
confidence. Public investment is expected to improve
due to the increased use of EU funds. Export demand
is likely to increase as the economies of Slovenia’s main
trading partners recover. Predominantly negative risks
accompany the growth forecast, while those on the
inflation side are slightly tilted to the upside. The domestic
economic environment remains subject to structural
challenges, which are, among other things, related
to low past investment activity, pressures on export
competitiveness, and an unfavourable demographic
picture. The unemployment rate is forecast to rise
marginally in 2025 and remain low for the remaining
years, suggesting a tight labour market. Economic growth
in the NLB Group’s region is forecast to improve in 2025
compared to 2024. Private and public spending should
accelerate. Moreover, exports are expected to rebound
due to stronger EU demand. Cooling inflation and looser
monetary conditions will boost household spending, while
exports will accelerate on sturdier EU demand. That said,
public spending growth could ease fiscal consolidation
efforts, and looser financing conditions will underpin a
sharper rise in fixed investment. The NLB Group’s region
is growing by 2.9% YoY in 2024, and is expected to grow
by 3.3% in 2025, and 3.4% in 2026. The ECB is seen cutting
rates by about 100 bps by the end of 2025; however, the
FED’s policy stance is a key factor to watch.

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Table 7: Movement of key macroeconomic indicators in the euro area and the NLB Group region
GDP
(real growth in %)
Average inflation
(in %)
Unemployment rate
(in %)
2023
2024
2025
2026
2027
2023
2024
2025
2026
2027
2023
2024
2025
2026
2027
Euro area
0.4
0.9
1.2
1.4
1.5
5.4
2.4
2.2
2.0
2.0
6.5
6.4
6.6
6.5
6.3
Slovenia
2.1
1.6
2.3
2.6
2.6
7.2
2.0
2.5
2.2
2.0
3.7
4.1
4.0
4.0
3.9
Serbia
3.8
3.9
4.2
4.2
4.0
12.1
4.7
3.7
3.2
3.0
9.5
8.6
8.3
8.1
7.9
N. Macedonia
1.0
2.7
3.1
3.2
3.2
9.4
3.5
2.8
2.4
2.2
13.1
12.4
12.1
11.5
11.0
BiH
1.9
2.5
2.7
3.0
3.1
6.1
1.7
2.0
1.9
1.9
13.2
12.7
12.3
11.8
11.7
Kosovo
3.3
4.5
4.0
4.0
3.9
4.9
1.6
2.0
2.1
2.0
11.0
10.5
10.0
9.5
9.2
Montenegro
6.3
3.2
3.4
3.3
3.4
8.6
3.3
3.2
2.6
2.5
13.1
11.5
10.7
10.3
10.0
Note: NLB Forecasts are highlighted in grey.
Source: Statistical offices, Focus Economics.
The financial performance in 2024 provided a solid
base for the Group to deliver on its guidance, with
some key indicators exceeding initial expectations.
Recurring income surpassed the forecasted EUR
1,200 million, reaching EUR 1,246 million, supported by
robust organic loan growth of 12%, which exceeded
the initial "high single-digit" target. The Cost-to-Income
Ratio (CIR) was in line with our guidance at 45.7%,
reflecting the seasonality of year-end bonuses, strategic
investments, and other one-off costs. In contrast, the
cost of risk remained below the forecasted 20 bps,
landing at 14 bps for the year. The RoE a.t. of 16.5% and
normalised RoE of 25.5% further highlight the Bank’s
ability to generate value for shareholders. The Bank
paid the second tranche of dividends, approved at the
43rd General Meeting on 9 December 2024. The total
distribution of EUR 220 million, which amounts to EUR
11 gross per share, represents 40% of the 2023 profit
and underscores the Bank’s commitment to meeting its
established targets.
Looking ahead to 2025, recurring income is expected
to stabilise at around EUR 1,200 million. This forecast
reflects a balanced approach to maintaining profitability
amidst a forecasted lower interest rate environment.
Despite these headwinds, the Group remains committed
to disciplined cost management. The CIR is projected
to transitionally increase in 2025 (expected to be at
approximately 48%), influenced by the integration of SLS
Group, coupled with ongoing strategic investments into
the acceleration of mobile/digital-first transformation,
and in 2030 the targeting of at least 90% of new
production of standard transactions through end-to-
end digital solutions. These efforts aim to enhance
the Group’s operational capacity and position it for
sustained growth in the medium term.
The cost of risk in 2025 is expected to normalise between
30 and 50 bps, reflecting a prudent but proactive
approach to risk management in a dynamic lending
environment. Loan growth is expected to remain robust
at high single-digit levels, driven by the Group’s strategic
focus on core market expansion while preserving sound
asset quality. This sustained growth in lending activity
is supported by relatively higher GDP growth rates and
lower indebtedness across both retail and corporate
segments in the region. The continued momentum
in loan growth is anticipated to enhance revenue
generation while maintaining a well-diversified and
balanced loan portfolio.
For 2026, the Group projects recurring income to exceed
EUR 1,300 million, reflecting the benefits of strategic
initiatives and improved operational efficiencies driving
the CIR below 48%, and realising the benefits from
continued investments in technology and digitalisation
efforts. The cost of risk is expected to remain within the
30–50 bps range, maintaining the Group’s conservative
risk posture. Loan growth is forecasted to sustain its high
single-digit trajectory, accentuating the Bank’s ability
to support economic activity while delivering consistent
financial performance.
Shareholder returns will remain a priority, with dividend
payouts expected at 50% of 2024's profit, presumably
in two trenches in 2025, and reaching 50–60% of the
2025's profit by 2026. The RoE a.t. is projected to stabilise
at approximately 15%, while the normalised RoE should
remain above 20%, underscoring the Group’s strong
capital generation capabilities and resilience in achieving
its strategic objectives outlined in Strategy 2030. The
provided guidance collectively reinforces the Group’s
commitment to delivering sustainable value to investors
and maintaining its leadership position in the market.
Table 8: Market performance and outlook for the period 2025-2026
Last Communicated Outlook
for 2025
Revised Outlook
for 2025
Outlook for 2026
Recurring income
~ EUR 1,200 million
~ EUR 1,200 million
> EUR 1,300 million
CIR
~ 48%
~ 48%
Below 48%
Cost of risk
30-50 bps
30-50 bps
30-50 bps
Loan growth
High single-digit
High single-digit
High single-digit
Dividends
More than 40%
of 2024 profit
50%
of 2024 profit
50-60%
of 2025 profit
ROE a.t.
ROE a.t. normalised(i)
~ 15%
> 20%
~ 15%
> 20%
~ 15%
> 20%
M&A potential
M&A capacity of
up to EUR 4 billion RWA(ii)
M&A capacity of
up to EUR 4 billion RWA(ii)
(i) ROE a.t. normalised = result a.t. divided by the average risk-adjusted capital. An average risk-adjusted capital is calculated as a Tier 1 requirement of
average RWA reduced by minority shareholder capital contribution.
(ii) Assisted with the combination of capital from issuing AT1 notes and a temporary reduction of the dividend payments.

NLB Group
Annual Report 2024
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Overview
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Key Highlights
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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
In May 2024, the Group launched its new Group Strategy
2030, outlining key performance indicators and
expected future development.
Table 9: NLB Group’s Strategy 2030 key financial indicators
Realisation on 31 Dec 2024
Impact ambition 2030
Recurring income
EUR 1,246 million
> EUR 2,000 million
Recurring profit
~ EUR 550 million
> EUR 1,000 million
CIR
45.7%
< 45%
ROE a.t.
16.5%
> 15% (1-2 p.p. upside
from strategic plays)
ROE a.t. normalised
25.5%
> 20%
RTSR(i)
63.44%
> Banking peer group
Payout ratio
40% of 2023 profit
towards 50-60%
P/B
0.8x
> 1
Tier 1 capital ratio
15.8%
~ 15%
CET1 ratio
15.3%
> 13%
Cost of risk
14 bps
30-50 bps
(i) Banking peer group: UniCredit, OTP, RBI (Raiffeisen Bank International), Erste Group, Intesa, Addiko.
Performance measured for the full year 2024.
Further information on the Group Strategy 2030 is available on the NLB website.

NLB is systemically important
and the most reputable
Slovenian bank, managing
70% of the cash, 40% of the
payments, and nearly 40% of
all the assets in the country.
We are more than just a
bank – we are one of the
driving forces behind the
region's economy.

NLB Group
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Key Highlights
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Performance Overview
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Statement
Financial
Report
Overview of
Financial Performance
The financial year concluded with a strong profit after tax result of EUR 514. 6 million, with the profit before
impairments and provisions up a respectable 9% YoY (EUR 51. 2 million). Profit after tax was, however, still down
EUR 36. 1 million or a 7% decline compared to the previous year, which was positively influenced by the booking
of deferred tax, increase of deferred tax assets (EUR 61. 9 million) and first recognition of deferred tax liability for
withholding tax on dividends (EUR 9. 6 million). The year 2024 also showed a moderate, but still positive cost of risk
of 14 bps (2023 still had a negative cost of risk).
The following key drivers influenced the Group’s
performance in the year 2024:
• The Group achieved exceptional YoY organic growth in
gross loans to customers of EUR 1,687.4 million, driven
by healthy demand, with an additional EUR 970.4
million growth deriving from the acquisition of
SLS Group.
• Although interest rates began to decrease in the
second half of the year, the Group successfully grew its
deposit base by EUR 1,473.6 million YoY, with EUR 1,051.7
million from individuals and EUR 445.4 million from
corporates.
• A 12% YoY increase in net interest income was driven by
healthy loan demand, the effects of favourable interest
rates on loans, and higher income from securities.
Despite declining interest rates in the second half of
the year, the annual net interest margin improved
YoY by 0.14 p.p. to 3.64%, mostly due to strategic
M&A activities, which offset the decline from banking
operations.
• Net interest income sensitivity simulated by a 100-bps
immediate parallel downward shift in interest rates,
yields to EUR -70.7 million or -2.47% of T1 capital, driven
mainly by the cash (EUR -17.1 million) and floating rate
loan positions (EUR -63.3 million).
• Net fee and commission income grew by 13% YoY as
it benefitted from strong economic activity, increased
engagement in investment funds and bancassurance,
and renegotiated conditions with the service providers.
• Total costs of the Group in 2024 amounted to EUR
602.2 million. Excluding EUR 33.2 million of the tax on
the balance sheet, the costs grew by EUR 67.2 million,
of which approximately EUR 45 million or 9% was the
result of like-for-like cost increases (i.e., normalising for
tax on the balance sheet introduced in 2024, SLS Group
integration, and some other smaller one-offs).
• The Group closely monitored the macroeconomic
and geopolitical circumstances, remaining very
prudent in identifying any increase in credit risk at a
very early stage and proactive in NPL management.
Furthermore, unfavourable trends in the German
automotive industry did not severely influence the
Slovenian export-oriented industry – considering
that the Bank downgraded certain clients in Stage 2
and formed additional impairments. Nevertheless,
the cost of risk remained at a relatively low level
and confidently within the guidance, with 14 bps. Net
established impairments and provisions for credit risk
in 2024 amounted to EUR 20.6 million. The established
impairments derive from portfolio development, new
financing, and any portfolio deterioration. In contrast,
material repayments of written-off receivables and
changes in models contributed to a lower total impact.
• Other impairments and provisions were net established
in the amount of EUR 16.9 million. The vast majority
were established mainly in the last quarter due to
provisions for legal risk (of which EUR 4.0 million in
NLB and EUR 3.8 million in NLB Komercijalna Banka,
Beograd) and restructuring provisions (mostly in
Slovenia, EUR 2.5 million in NLB and EUR 1.4 million in
Slovenian leasing companies).
• The effective tax rate (calculated as income tax divided
by profit before tax) for the year 2024 for the NLB
Group was 13%, and for NLB, 7%. The effective tax rate
of NLB was significantly influenced by non-taxable
income, which consisted mostly of received dividends
and the release of impairments of equity investments in
subsidiary banks. The overall contribution rate, which
includes income tax and the tax on the balance sheet
for the year 2024 for the NLB Group was 18% and for
NLB 13%.
• A sound financial position was confirmed by a
robust Total Capital Ratio (TCR) of 18.7%, well above
requirements.
• The multi-year declining trend of the non-performing
credit portfolio stock stopped, as the growth of new
NPLs slightly exceeded repayments and recovery
of existing NPLs. Additionally, new NPLs from the
acquired SLS Group were recognised. The combination
of a slight increase in the non-performing credit
portfolio stock and credit growth of a high-quality
portfolio resulted in the decrease of gross NPL ratio
(EBA def.) from 2.1% to 2.0% YoY. The NPE ratio (EBA
def.) remained almost unchanged at the previous year-
end level and stood at 1.1%.
• Unencumbered liquidity reserves portfolio amounted
to EUR 9,287.5 million (33.2% of total assets).
EUR 514. 6
million
of net profit

NLB Group
Annual Report 2024
45
Overview
MB Statement
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
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Statement
Financial
Report
Figure 14: Profit after tax of NLB Group – evolution YoY (in EUR millions)
The Group’s recurring profit before impairments and
provisions grew by EUR 37.2 million or 6% YoY, totalling
EUR 643.5 million. In Q1 2024, the result before
impairments and provisions was negatively affected by
the accrual of a one-time yearly payment of regulatory
costs in NLB (EUR 10.5 million under the Deposit
Guarantee Scheme (DGS)). Conversely, the early
redemption of Tier 2 notes positively affected the result
(EUR 2.7 million). Additionally, in Q4, a EUR 3.9 million
modification loss due to interest rate regulation on
housing loans in NLB Komercijalna Banka, Beograd,
burdened the non-recurring net non-interest income.
2023
Net interest
income
Net fee and
commission
income
Other net
non-interest
income
Total costs
Impairments
and provisions
Share of profit
from investments
in associates and
joint ventures
Income tax
Result of
non-controlling
interests
2024
100.8
35.0
-100.4
-62.8
-3.1
15.7
1.9
514.6
550.7
-23.3
o/w
-33.2 tax
on BS
EUR
1,224. 8
million
of total net operating
income
EUR
642. 6
million
of profit before
impairments and
provisions

NLB Group
Annual Report 2024
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Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
All banks recorded a profit on a standalone basis and
positively contributed to the Group’s result. The largest
contribution again came from NLB, followed by NLB
Komercijalna Banka, Beograd. The YoY decrease in
NLB was mostly attributed to the booking of deferred
tax assets in 2023 and the establishment of provisions
in 2024. The SEE banks contributed 58.1% to the
Group result, with all bank reporting growth. For more
information on bank operations, see the chapter NLB
Group Key Members.
.
Figure 15: Result before impairments and provisions of NLB Group (in EUR millions)
-17.7
-3.4
1.1
-2.0
-7.5
-7.5
-7.5
-14.9
-0.9
3.6
165.8
163.2
171.3
142.3
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
645.4
683.7
179.9
174.2
177.7
151.9
Result before impairments and provisions w/o non-recurring income and regulatory costs
Non-recurring net non-interest income
Regulatory costs
591.4
642.6
+9%
-40.2
-39.1
(i) Merger of NLB and N Banka on 1 Sept ember 2023.
NLB(i)
N Banka(i)
NLB KB,
Beograd
NLB Banka,
Skopje
NLB Banka,
Banja Luka
NLB Banka,
Sarajevo
NLB Banka,
Prishtina
NLB Banka,
Podgorica
2023
2024
12.7
201.0
269.6
-25%
131.7 139.0
+6%
39.7
58.5
+47%
24.3 29.6
+22%
12.5 14.0
+12%
29.5 30.4
+3%
24.5 27.7
+13%
Figure 16: Profit a.t. by company – contribution (in EUR millions)

NLB Group
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Financial
Report
Income statement
Table 10: Income statement of NLB Group
in EUR millions
2024
2023
Change YoY
Q4 2024
Q3 2024
Q2 2024
Q1 2024
Net interest income
934.2
833.3
100.8
12%
240.0
233.7
228.3
232.2
Net fee and commission income
312.9
278.0
35.0
13%
81.0
81.9
78.9
71.1
Dividend income
0.1
0.2
-0.1
-31%
0.0
0.1
0.0
0.0
Net income from financial transactions
24.1
17.3
6.8
39%
2.8
8.5
3.0
9.8
Net other income
-26.5
-35.4
9.0
25%
-3.0
-4.2
-4.3
-15.0
Net non-interest income
310.6
260.0
50.7
19%
80.8
86.2
77.7
65.9
Total net operating income
1,244.8
1,093.3
151.5
14%
320.8
320.0
305.9
298.1
Employee costs
-322.2
-282.2
-40.0
-14%
-95.7
-77.0
-77.3
-72.2
Other general and administrative expenses
-188.6
-170.5
-18.2
-11%
-58.3
-47.8
-43.6
-39.0
Tax on balance sheet
-33.2
0.0
-33.2
0%
-8.6
-8.3
-8.1
-8.1
Depreciation and amortisation
-58.2
-49.2
-9.0
-18%
-15.9
-15.6
-13.6
-13.1
Total costs
-602.2
-501.9
-100.4
-20%
-178.5
-148.7
-142.7
-132.4
Result before impairments and provisions
642.6
591.4
51.2
9%
142.3
171.3
163.2
165.8
Impairments and provisions for credit risk
-20.6
11.8
-32.4
-
-32.9
0.6
16.0
-4.4
Other impairments and provisions
-16.9
-25.9
9.0
35%
-12.4
-3.2
-1.0
-0.3
Impairments and provisions
-37.4
-14.1
-23.3
-166%
-45.3
-2.6
15.1
-4.7
Share of profit from investments in associates and joint ventures
3.0
1.1
1.9
179%
0.7
0.6
0.7
1.0
Result before tax
608.1
578.4
29.7
5%
97.8
169.3
179.0
162.1
Income tax
-77.9
-15.1
-62.8
-
-7.3
-30.1
-21.8
-18.7
Result of non-controlling interests
15.7
12.6
3.1
24%
3.4
3.7
5.2
3.4
Result after tax
514.6
550.7
-36.1
-7%
87.0
135.5
152.0
140.0

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Report
Net interest income
The Group’s net interest income increased by 12% and
reached EUR 934.2 million, accounting for 75% of total
net revenues, consistent with the same period last year.
Without the contribution from SLS Group (EUR 11.0
million), the growth of the net interest income would be
1 p.p. lower.
All the Group banking members reported increased
net interest income, driven by loan volume growth
from healthy demand for loans and higher interest
rates. The growth mainly came from loans to
customers (EUR 140.8 million, with EUR 77.2 million
to individuals and EUR 63.6 million to corporate and
state) and securities (EUR 64.3 million). At the same
time, interest expenses increased due to higher
expenses incurred from MREL-eligible wholesale
funding (EUR 37.7 million) and higher expenses for
customer deposits (EUR 46.8 million).
In the last quarter of the year, the Group successfully
compensated the drop of interest rates with mitigation
measures and important contribution from the acquired
SLS Group loan portfolio (EUR 11.0 million).
Profitability stabilisation is one of the NLB Group’s
priorities. To protect future interest income from a
declining interest rate environment, the Bank hedged
issued securities in the additional amount of EUR 1,070.0
million in 2024. Assuming interest rate dynamics are in line
with market expectations, these hedges should positively
impact the net interest income in the coming years.
Figure 17: Net interest income of NLB Group (in EUR millions)
232.2
228.3
233.7
240.0
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
993.4
1,207.6
292.8
291.9
306.2
316.8
-160.1
-60.6
-63.7
-72.4
-76.8
Interest income
Interest expenses
833.3
934.2
+12%
-273.5

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Financial
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The net interest income sensitivity, simulated by a
100-bps immediate parallel downward shift in interest
rates, yielded a net interest income sensitivity of EUR
-70.7 million or -2.47% of T1 capital, driven mainly by the
cash (EUR -17.1 million) and floating rate loan positions
(EUR -63.3 million). The focus on stabilising the net
interest income includes ongoing increased fixed interest
rate loan stock, active management of the funding mix,
liabilities hedging activities, and increasing duration
and volume of the banking book securities portfolio.
In 2024, NII sensitivity improved by EUR 30.7 million or
145 bps (from -3.92% to -2.47% relative to T1 capital, or
EUR 30.7 million to a level of EUR 70.7 million in case of
-100-bps parallel shift). NLB Group significantly reduced
the NII sensitivity in 2024 by increasing the volume of
fixed interest rate loans (EUR 2,853 million) and new
interest rate hedges (EUR 1,070 million), while reducing
the central bank balances (EUR 2,368 million), and
increasing of investments in high-quality debt securities
(EUR 1,509 million).
Figure 18: NII sensitivity to various rate shocks of NLB Group (in EUR millions)
-70.7
-34.8
29.7
58.2
Scenario
-100 bps
Scenario
-50 bps
Scenario
+50 bps
Scenario
+100 bps
The Group’s annual net interest margin and operational
business margin increased, by 0.14 p.p. YoY to 3.64%,
and by 0.21 p.p. to 4.97%. However, the growth in these
margins was affected by the monetary easing, marked
by four consecutive ECB key interest rate cuts from June
onwards. The decline on a Group level was effectively
mitigated by replacing less profitable central bank
balances with a more lucrative loan portfolio acquired
from the SLS Group. Margins were declining in the last
quarter in NLB and the SEE banks, which is a function of
the declining rates.
The net interest rates are expected to decrease further
as the central bank and Euribor rates decline. Due to
the balance sheet management activities that have
significantly reduced the Group’s net interest income
sensitivity, the pace of the net interest margin decline
should nevertheless be considerably slower than the
pace of the increase during the ECB’s hiking cycle.
Figure 19: Net interest margin (quarterly data, in %)(i)
(i) Calculated based on average interest-bearing assets.
Figure 20: Operational business margin (quarterly data, in %)(i)
(i) Calculated based on average interest-bearing assets.
NLB Group
NLB
SEE banks
NLB Group
NLB
SEE banks
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
4.44%
5.59%
5.84%
5.69%
5.46%
3.73%
4.98%
5.00%
4.97%
4.93%
3.02%
3.94%
3.80%
3.76%
3.69%
2.89%
2.81%
2.75%
3.63%
3.60%
3.61%
4.41%
4.36%
4.22%

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Financial
Report
Net non-interest income
Figure 21: Net non-interest income of NLB Group (in EUR millions)
-8.7
-3.5
-2.0
-14.9
-0.9
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
278.0
312.9
71.1
78.9
81.9
81.0
Net fee and commission income
Recurring other net non-interest income
Non-recurring other net non-interest income
3.6
65.9
2.2
77.7
86.2
1.0
3.3
1.8
80.8
260.0
310.6
+19%
-1.4
-3.1
The overall YoY increase in the net non-interest income
derives from higher net fee and commission income. The
non-recurring net non-interest income was positively
influenced by the early redemption of Tier 2 notes (EUR
2.7 million) in Q1, but negatively affected on the account
of the modification loss recorded for interest rate
regulation on housing loans in NLB Komercijalna Banka,
Beograd in Q4 (EUR 3.9 million in 2024, compared to
EUR 15.3 million in 2023). Regulatory charges, a part of
recurring other net non-interest income, were higher by
EUR 1.1 million YoY due to a higher deposit base, mostly
occurring in Q1 as a result of the accrual of one-off
expenses in Slovenia.
Figure 22: Net fee and commission income of NLB Group (in EUR millions)
Net fee and commission income, a significant
component of the net non-interest income, increased
by 13% YoY. This growth can be attributed to the
positive impact of heightened economic activity and
consumption, resulting in higher fees across banking
members, renegotiated conditions with the service
providers, and increased activities in investment funds
and bancassurance. Notably, NLB Skladi, Ljubljana,
recorded an exceptional sale of investment funds, with
EUR 395.4 million gross inflows in 2024, reflecting over a
50% YoY increase.
The decline in the last quarter derives mainly from a
one-off in NLB Komercijalna Banka, Beograd, due to
an adjustment of receivables related to card operations
(around EUR 2 million) and some minor positive accrued
revenues in the third quarter.
56.6
24.4
81.0
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
207.1
225.2
87.8
50.3
20.8
58.2
20.7
60.0
21.8
70.9
Payment transactions, Basic accounts, Cards and ATM operations
Other
71.1
78.9
81.9
278.0
312.9
+13%

NLB Group
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Report
Total costs
Figure 23: Total costs of NLB Group (in EUR millions)
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Employee costs
Other general and administrative expenses
Tax on balance sheet
Depreciation and amortisation
39.0
72.2
132.4
8.1
13.1
43.6
77.3
142.7
8.1
13.6
47.8
77.0
148.7
8.3
15.6
58.3
95.7
8.6
178.5
15.9
Excl.
53. 0
BS tax
33.2
SLS Group
16.0
Other
3.8
549.2
+20%
188.6
322.2
602.2
282.2
170.5
501.9
+9% normalised
33.2
49.2
58.2
Total costs of the Group in 2024 amounted to EUR 602.2
million. By excluding EUR 33.2 million of the tax on
the balance sheet, the costs grew by EUR 67.2 million,
of which approximately EUR 45 million or 9% is the
result of like-for-like cost increases (i.e., normalising
for the tax on the balance sheet introduced in 2024,
the SLS integration, and some other smaller one-offs).
This elevated cost dynamic is a reflection of the strong
inflationary pressures of 2024 in HR (around EUR 30
million increase, of which EUR 23 million in banks, the
rest across other core businesses) with the remainder
mostly in continued investments into improvement of
branches and IT environment. The considerable HR cost
dynamic in the core banking operations is a function
of effects of repricing and variable compensation (EUR
31 million) more than offsetting effects of headcount
reductions, amounting to around EUR -8 million. It is
clear that this tension will continue to put pressure on
costs in 2025, although measures to address headcount
efficiencies will be substantially increased.
Total costs increased mostly in the fourth quarter, by
EUR 29.8 million, of which the majority (approximately
EUR 24 million) is seasonal (approximately EUR 10
million in regular general and administrative costs
seasonality and EUR 14 million of variable compensation
given very strong financial performance). A smaller part
is related to labour cost inflation (approximately EUR
2 million or 3% QoQ). As SLS Group was acquired in
September, Q4 showed a full cost effect, being EUR 2.3
million higher QoQ.
The Cost-to-Income Ratio (CIR - excluding the tax on the
balance sheet from the calculation) declined by 0.2 p.p.
YoY to 45.7%.
Figure 24: Number of employees
Figure 25: Number of branches

31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
5,121
349
5,202
340
2,554
68
2,523
69
307
597
7,982
417
8,322
409
+340
-8
NLB
SEE banks
Other
NLB
SEE banks

NLB Group
Annual Report 2024
52
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Impairments and provisions
0.6
-0.3
-1.0
2023
2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
11.8
-20.6
-4.4
16.0
-32.9
-25.9
-16.9
-3.2
-12.4
-14.1
-37.4
-4.7
-2.6
-45.3
15.1
Impairments and provisions for credit risk
Other impairments and provisions
-7
14
CoR
(bps)
Figure 26: Impairments and provisions of NLB Group (in EUR millions)
The Group monitored the macroeconomic and
geopolitical circumstances closely, remaining very
prudent in identifying any increase in credit risk at a
very early stage, and proactive in NPL management.
Furthermore, unfavourable trends in the German
automotive industry did not severely influence the
Slovenian export-oriented industry. Still, the Bank
downgraded certain clients in Stage 2 and formed
additional impairments. Nevertheless, the cost of risk
remained at a relatively low level, at 14 bps.
Impairments and provisions for credit risk were
established mainly in Q4 in the amount of EUR 32.9
million. The established impairments derived from
additional provisions of EUR 35.6 million for portfolio
development, mostly in the corporate segment (new
financing, transfer to Stage 2 and Stage 3), repayments
of written-off receivables in the amount of EUR 10.7
million due to a favourable environment for NPL
resolution, and additional impairments and provisions
in the amount of EUR 7.9 million related to the change in
models/risk parameters in NLB.
The Group net established impairments and provisions
for credit risk in the amount of EUR 20.6 million in 2024.
The established impairments derive from portfolio
development, new financing and any portfolio
deterioration. In contrast, material repayments
of written-off receivables and changes in models
contributed to a lower total impact. Further information
is available in the chapter Risk Management.
Other impairments and provisions were net established
in the amount of EUR 16.9 million. The vast majority were
established mainly in the last quarter due to provisions
for legal risk (mainly in NLB and in NLB Komercijalna
Banka, Beograd), and restructuring provisions (mostly
in Slovenia, EUR 2.5 million in NLB and EUR 1.4 million in
Slovenian leasing companies).

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Financial
Report
Income tax
The effective tax rate (calculated as income tax divided
by profit before tax) for the year 2024 for NLB Group was
13%, and for NLB, 7%. The effective tax rate of NLB was
importantly influenced by non-taxable income, which
mainly consisted of received dividends and the release
of impairments of equity investments in subsidiary
banks. In addition, tax losses carry-forward decreased
by 50% of the taxable base. The effective tax rate of
NLB, excluding non-taxable dividends and non-taxable
reversal of equity investments, amounts to 14% at NLB,
and at the Group level 14% (also excluding non-taxable
interest from state securities, according to the local tax
legislations).
In the year 2024, several changes related to taxes
occurred. Based on the Reconstruction, Development,
and Provision of the Financial Resources Act, the tax
rate for corporate income tax in Slovenia was increased
from 19% to 22% for the years 2024 to 2028. Based on
the same law, the tax on balance sheet was introduced
for 2024–2028 in Slovenia. Tax on the balance sheet is
recognised in other general and administrative expenses
and included in the contribution rate. For 2024, the tax
on the balance sheet amounted to EUR 33.2 million.
Based on the OECD Pillar 2 Model Rules and the related
EU Directive, the global minimum top-up-tax was
introduced in the year 2024. NLB Group is liable to pay
the top-up tax for the group members in jurisdictions
where the effective tax rate, calculated by the rules
related to the global minimum top-up tax, is below
15%. NLB, as the parent company, recognised a global
minimum top-up-tax in the amount of EUR 3.9 million
related to subsidiaries in Bosnia and Herzegovina, and
Kosovo, where the statutory corporate income tax rate is
10%. North Macedonia, where a 10% statutory corporate
income tax also applies, introduced a domestic top-up
tax. Therefore, NLB Banka, Skopje recognised a EUR 2.2
million top-up tax.
The overall contribution rate related to profit before tax,
which includes income tax and the tax on the balance
sheet for the year 2024 for the NLB Group was 18% and
for NLB 13%. Until 2028, when tax measures due to the
flood in 2023 are effective, the overall contribution rate
is expected to be slightly less or around 20% on NLB
Group. From 2029, the effective tax/contribution rate
related to profit before tax is expected to be around 14%
for NLB and 18% for NLB Group.
Table 11: Effective tax and contribution rates
in EUR millions
NLB 2024
NLB 2023
NLB Group
2024
NLB Group
2023
Profit before tax
512
479
608
578
Non-taxable income
-266
-236
-44
0
Non-taxable dividends received
-212
-138
0
0
Non-taxable reversal of equity investments
-54
-98
0
0
Non-taxable interest from state debt securities
0
0
-44
-40
Taxable income
246
243
564
538
Adjustments
-138
-145
-260
-232
Utilisation of tax loss carry forward
-123
-115
-126
-117
Other adjustments(i)
-15
-30
-134
-115
Tax base
108
98
304
306
Corporate income tax (at 22%)
24
18
67
58
Withholding tax (mainly dividends) & other
11
8
10
8
Global minimum top-up-tax
4
6
Recognition and increase of DTAs
-6
-62
-7
-62
Non-recognised deferred tax assets on current loss and other
1
0
2
11
Total tax
34
-36
78
15
Effective tax rate related to profit before tax
7%
-7%
13%
3%
Effective tax rate related to taxable income(ii)
14%
11%
14%
12%
Tax on balance sheet
33
33
Donations to state and municipalities
9
9
Contribution (total tax, balance sheet tax and donations)(ii)
67
35
111
75
Overall contribution rate related to profit before tax(ii)
13%
7%
18%
13%
Overall contribution rate related to taxable income(ii)
27%
14%
20%
14%
(i) Effect of different tax rates in other countries is included in other adjustments.
(ii) One-off events related to recognition of DTA's and non-recognised DTA in 2023 are excluded from the calculation of effective tax rate related to taxable
income, contribution, and related rates.

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Statement
Financial
Report
Statement of financial position
Table 12: Statement of financial position of NLB Group
in EUR millions
31 Dec 2024
31 Dec 2023
Change YoY
31 Dec 2024
30 Sep 2024
30 Jun 2024
31 Mar 2024
ASSETS
Cash, cash balances at central banks, and
other demand deposits at banks
4,039.6
6,103.6
-2,064.0
-34%
4,039.6
4,137.9
5,116.3
5,481.1
Loans to banks
458.9
547.6
-88.7
-16%
458.9
433.4
410.7
416.3
Net loans to customers
16,363.6
13,734.6
2,629.0
19%
16,363.6
15,739.3
14,399.3
13,859.9
Gross loans to customers
16,721.4
14,063.6
2,657.8
19%
16,721.4
16,071.4
14,726.7
14,197.1
- Corporate
7,471.2
6,437.8
1,033.4
16%
7,471.2
7,156.6
6,703.6
6,412.8
- Individuals
8,735.0
7,235.3
1,499.7
21%
8,735.0
8,469.1
7,632.5
7,394.8
- State
515.2
390.4
124.8
32%
515.2
445.7
390.6
389.5
Impairments and valuation of loans to customers
-357.8
-329.0
-28.8
-9%
-357.8
-332.0
-327.4
-337.2
Financial assets
6,324.5
4,803.7
1,520.8
32%
6,324.5
6,106.9
5,919.9
5,485.9
- Trading book
19.6
15.8
3.8
24%
19.6
15.8
14.6
15.0
- Non-trading book
6,304.9
4,787.9
1,517.0
32%
6,304.9
6,091.1
5,905.3
5,470.9
Investments in subsidiaries, associates, and joint ventures
14.7
12.5
2.1
17%
14.7
13.9
12.3
13.5
Property and equipment
310.0
278.0
32.0
12%
310.0
300.0
280.9
276.0
Investment property
26.1
31.1
-5.0
-16%
26.1
24.6
25.8
30.0
Intangible assets
100.5
62.1
38.4
62%
100.5
86.9
64.9
60.5
Other assets
397.4
368.7
28.7
8%
397.4
400.5
383.6
402.5
TOTAL ASSETS
28,035.4
25,942.0
2,093.4
8%
28,035.4
27,243.4
26,613.7
26,025.7
LIABILITIES
Deposits from customers
22,206.3
20,732.7
1,473.6
7%
22,206.3
21,373.9
20,693.8
20,471.5
- Corporate
6,304.6
5,859.2
445.4
8%
6,304.6
5,894.0
5,356.8
5,504.3
- Individuals
15,512.0
14,460.3
1,051.7
7%
15,512.0
15,074.3
14,899.9
14,554.6
- State
389.7
413.2
-23.5
-6%
389.7
405.6
437.1
412.6
Deposits from banks and central banks
136.0
95.3
40.7
43%
136.0
139.5
94.3
134.7
Borrowings
225.1
240.1
-15.0
-6%
225.1
210.1
218.8
209.4
Subordinated debt securities
560.1
509.4
50.7
10%
560.1
583.4
558.7
597.3
Other debt securities in issue
1,048.8
828.8
220.0
27%
1,048.8
1,034.8
1,315.3
838.0
Other liabilities
560.9
587.6
-26.7
-5%
560.9
590.9
586.8
674.7
Equity
3,226.0
2,882.9
343.1
12%
3,226.0
3,242.1
3,081.3
3,035.6
Non-controlling interests
72.1
65.1
6.9
11%
72.1
68.7
64.7
64.4
TOTAL LIABILITIES AND EQUITY
28,035.4
25,942.0
2,093.4
8%
28,035.4
27,243.4
26,613.7
26,025.7

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Annual Report 2024
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Statement
Financial
Report
The Group’s balance sheet volume reached EUR
28,035.4 million at the end of the year, reflecting a EUR
2,093.4 million YoY increase. Growth in the customer’s
deposits and additional MREL funding supported the
organic loan book growth, while the liquidity reserves
were used for the acquisition of the SLS Group.
Figure 27: Balance sheet structure of the NLB Group on 31 December 2024 (in EUR millions)

560 Subordinated debt securities
561 Other liabilities
1,049 Other debt securities in issue
361 Deposits from banks and
central banks & Borrowings
Loans to state
3.1%
Loans to
corporate
44.6%
Loans to
individuals
52.3%
16,364
Deposits
from state
1.8%
Deposits
from
individuals
69.9%
Deposits
from
corporate
28.4%
22,206
Liabilities
Deposits
from
customers
22,206
28,035
Assets
Net loans
to customers
16,364
28,035
Cash
equivalents
& placements
with banks
4,499
Financial
assets
6,324
Other assets 849
Total equity
3,298
The LTD ratio (net) increased by 7.4 p.p. YoY to 73.7%
at the Group level. The increase was driven by the
acquisition of SLS Group, which led to a higher growth in
net loans compared to the deposits.
The leverage ratio, which takes into account both
on-balance sheet and off-balance sheet items,
increased by 0.23 p.p. YoY to 9.9% at the Group level. The
increase was driven by higher on-balance exposures to
retail and corporates.
31 Dec 2023
31 Dec 2024
13,735
20,733
16,364
22,206
66.2%
73.7%
LTD
Net loans (in EUR millions)
Deposits (in EUR millions)
Figure 28: NLB Group’s LTD ratio movement

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Assets
(i) T he geographical analysis includes a breakdown of items with respect to the country in which individual NLB Group members are located.
752.5
848.7
6,651.2
4,498.5
13,734.6
16,363.6
4,803.7
6,324.5
Cash equivalents, placements with banks and loans to banks
Net loans to customers
Financial Assets
Other Assets
31 Dec 2023
31 Dec 2024
25,942.0
28,035.4
+8%
Figure 29: Total assets of NLB Group – structure (in EUR millions)
The distribution of total assets between countries was
similar to the previous year, with growth in the SEE
members outpacing the growth in Slovenia. 55.5% of the
total assets related to the Group members were located
in Slovenia and 20.1% in Serbia.
Figure 30: Total assets of NLB Group by country (year-end, in %)(i)
55. 5%
Slovenia
2024
2023
0. 5%
Other
0. 1%
Other
3. 4%
Montenegro
3. 6%
Montenegro
5. 1%
Kosovo
4. 7%
Kosovo
7. 7%
BiH
7. 5%
BiH
7. 7%
N. Macedonia
7. 3%
N. Macedonia
20. 1%
Serbia
19. 6%
Serbia
57. 2%
Slovenia

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Statement
Financial
Report
Growth of lending in 2024 was very strong. In addition
to a EUR 970.4 million YoY increase in gross loans from
the SLS Group, the NLB Group achieved a 12% organic
loan growth, expanding from EUR 14,063.6 million to
EUR 15,751.0 million. Notably, high growth was recorded
in NLB and SEE banks in both segments, individuals and
corporate and state.
NLB recorded a 10% growth in gross loans to individuals,
with stronger growth in the second half of the year. The
new loan production was impressive, with over EUR 500
million in housing and consumer loans approved in 2024,
reflecting a YoY increase of 30% and 38%, respectively.
Corporate and state loans grew by 10%, excluding the
intragroup loan to the newly acquired Summit Leasing
Slovenija, Ljubljana.
In SEE banks, the 16% increase was recorded in loans
to corporate and state, with especially strong growth in
the last quarter in all bank members. The growth of the
individual loans was similar, 15%.
Figure 31: NLB Group gross loans to customers dynamics (in EUR millions)
SEE banks(ii)
NLB Group
NLB(i)
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
8,164.1
570.9
7,586.9
7,235.3
3,608.8
3,523.1
6,828.2
3,667.8
3,245.4
8,735.0
3,965.2
4,056.9
7,986.4
4,850.5
3,751.3
+21%
+13% w/o SLS Group
+10%
+15%
+17%
+11% w/o SLS Group
+32%
+10% w/o intragroup
loan to SLS Group
+16%
Gross loans
to individuals
399.5
Gross loans
to corporate
& state
Gross loans
SLS Group
(i) On a stand-alone basis.
(ii) Sum of data on a stand-alone basis as included in the consolidated financial statements of the NLB Group.

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Report
Following the ECB’s key interest rate cuts, quarterly
interest rates for loans to customers began to decline in
NLB and the SEE banks. However, on NLB Group level,
this decline was partly mitigated due to higher yielding
SLS Group portfolio.

Figure 32: Interest rates for loans to customers (quarterly, in %)
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
5.94%
5.25%
6.61%
5.93%
5.29%
6.52%
5.88%
5.11%
6.45%
5.80%
4.87%
6.33%
SEE banks(ii)
NLB Group
NLB(i)
(i) On a stand-alone basis.
(ii) Sum of data on a stand-alone basis as included in the consolidated financial statements of the NLB Group.

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Financial
Report
Despite significant portfolio growth in all NLB Group
banks in the 2024, and the acquisition of the SLS Group,
the loan portfolio remained well-diversified, and there
was no large concentration in any specific industry or
client segment. Consumer loans and leasing growth
were noticed in the retail portfolio, however housing
loans prevailed. Most of the loan portfolio is in the
euro currency, while the rest in local currencies of the
Group banking members. Looking at the type of interest
rate, almost 66% of the loan portfolio was linked to a
fixed interest rate, and the rest mainly to the Euribor
reference rate.
Figure 33: Loan portfolio(i) by segment, geography, currency, and interest rate type (in EUR millions)
Institutions
409
2%
State(ii)
3,767
18%
Retail
consumer
4,213
20%
Retail
housing
4,522
22%
Corporates
3,138
15%
SME
4,633
22%
EUR 20. 7
billion
by segment(iv)
Other(iii)
919
4%
N. Macedonia
1,705
8%
Montenegro
802
4%
Kosovo
1,208
6%
Serbia
4,624
22%
BiH
1,674
8%
Slovenia
9,751
47%
EUR 20. 7
billion
by geography
Other
1%
BAM
5%
MKD
5%
RSD
10%
EUR
79%
EUR 20. 7
billion
by currency
Floating
34%
Fixed
66%
EUR 20. 7
billion
by interest rate
(i) The loan portfolio also includes account balances, required reserves at CBs, and demand deposits at banks.
(ii) State includes exposures to CBs.
(iii) The largest part represents EU members.
(iv) Segmentation following the company size defined in the Companies Act of an individual country in the region.

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Report
The banking book debt securities portfolio increased
by EUR 1,506 million (book value) YtD, constituting 22.1%
of the Group’s total assets, compared to 18.1% in 2023.
This increase was intentional to manage NII sensitivity
in the declining rate environment. At the end of 2024,
the portfolio’s average duration was 3.6 years (up
from 2.8 years in 2023), with an average yield of 2.49%
in 2024, reflecting an increase of 0.82 p.p. from the
previous year. The ESG portfolio expanded in 2024 and
now represents 10.8% of the entire portfolio. Additional
information is available in the Sustainability Statement
of this Annual Report.
Two business models are implemented, dividing the
portfolio into securities valued at fair value through
other comprehensive income (FVOCI) and securities
valued at amortised cost (AC). In managing NII
sensitivity, the FVOCI portfolio declined by 6.34 p.p.
in 2024, accounting for 39.84% of the total Group
debt securities portfolio at year-end, with an average
duration of 2.1 years. The negative valuation of
the Group’s FVOCI debt securities portfolio during
2024 amounted to EUR 30 million (the net of hedge
accounting effects and related deferred taxes).
The AC portfolio amounted to 60.16% of the total Group
debt securities portfolio at the end of 2024, with an
average duration of 4.6 years. Unrealised losses of
the Group’s AC debt securities portfolio during 2024
amounted to EUR 18 million.
Figure 34: Banking book debt securities portfolio by asset class, geography, currency, rating7, and maturity profile as
at 31 December 2024 (in EUR millions)
7 92% of non-investment grade securities relate to NLB Group’s markets,
i.e. exposures to Bosnia and Herzegovina, North Macedonia, etc.
Information on intangible assets and their contribution
to value creation within the Group is available in the
chapter Strategy, and further in the Financial Report of
this Annual Report.
Government
bonds
4,225
Corporate
bonds
22
Subordinated
debt
59
Covered
bonds
228
Bank senior
unsecured
bonds
699
Multilateral bank
bonds and GGB's
961
by asset class
EUR 6,193
million
Other
32
BAM
118
MKD
204
USD
225
RSD
506
EUR
5,108
by currency
EUR 6,193
million
BBB
17%
BB
6%
B
4%
NR
0%
A
28%
AA
24%
AAA
21%
by rating
EUR 6,193
million
Finland
216
The Netherlands
249
Austria
271
Luxembourg
278
N. Macedonia
323
Germany
370
France
573
Slovenia
928
Other
1,700
Serbia
647
by geography
EUR 6,193
million
Belgium
637
% of total
portfolio
Slovenia
SEE
International
2025
2026-2027
2028-2029
2030+
165
388
698
284
368
1,175
28%
41%
30%
40%
1,251
1,827
148
239
957
1,345
332
248
1,190
1,770
maturity profile

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Report
0.0%
0.0%
0.0%
0.0%
0.1%
Liquidity position
The Group’s liquidity remains strong, with a high level of
unencumbered liquidity reserves in total assets (33.2%)
reflected in the LCR ratio of 197.2%, compared to 245.7%
at the end of 2023. The Group holds a comfortable
liquidity position, with liquidity ratios well above the
risk appetite limit at the Group and individual banking
member levels.
The Group’s unencumbered liquidity reserves consist of
cash, balances at central banks excluding the minimum
reserve requirement, the debt securities portfolio, and
credit claims eligible for CB-secured funding operations.
Among others, these liquidity reserves provide the basis
for future strategic growth.
In 2024, the Group’s unencumbered liquidity reserves
decreased by 9.0% YoY. The decline was primarily due
to a reduction in Cash & CB reserves, mostly resulting
from the acquisition of the SLS Group, with funds being
transferred to the loan portfolio. At the same time,
banking book debt securities increased, while values in
other categories remained stable.
Encumbered liquidity reserves, used for operational
and regulatory purposes, increased by 0.5% YoY to EUR
41.7 million (excluding obligatory reserves) and were
excluded from the liquidity reserves portfolio.
Figure 35: Evolution of NLB Group unencumbered liquidity reserves (in EUR millions)
31 Dec 2023
31 Mar 2024
30 Jun 2024
30 Sep 2024
31 Dec 2024
ECB eligible credit claims
Cash & CB reserves
Trading book debt securities (market value)
Banking book debt securities (market value)
10,207.1
10,329.5
10,182.9
6.6%
48.6%
44.8%
6.1%
38.9%
55.0%
4.1%
29.8%
66.0%
6.5%
42.0%
51.5%
6.5%
31.1%
62.3%
9,529.2
9,287.5

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95.3
Liabilities
20,732.7
240.1
509.4
828.8
587.6
2,948.0
22,206.3
136.0
225.1
560.1
1,048.8
3,298.0
560.9
Deposit from customers
Deposit from banks and central banks
Borrowings
Subordinated liabilities
Other debt securities in issue
Other liabilities
Total equity
31 Dec 2023
31 Dec 2024
25,942.0
28,035.4
+8%
Figure 36: Total liabilities of NLB Group – structure (in EUR millions)
The total liabilities of the Group increased and
amounted to EUR 24,737.3 million, with an additional
EUR 3,298.0 of total equity. The Group’s funding base
was dominated by customer deposits, accounting
for 79%. Sight deposits prevailed; however, due to
increased interest rates and attractive offers on term
deposits – as a response to market conditions – the
share of term deposits continued to grow in the first half
of 2024, reaching 18% by the year-end (compared to 16%
at the end of 2023). The majority of customer deposits
came from individuals, accounting for 70%, the same as
at the end of 2023.

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Deposits from customers increased by 7% YoY. The
largest increase of 15% was recorded in corporate and
state deposits at the SEE banks due to the region’s
improved economic situation, especially in the second
half of the year. The Bank’s corporate and state deposit
base remained stable, supported by an upswing in the
second half of the year.
Moreover, deposits from individuals grew across all
Group member banks. In the SEE banks, deposits
increased by 11%, with steady growth throughout
the year. NLB recorded a 5% growth in deposits
from individuals. The volume of term deposits in NLB
increased by EUR 163.6 million in 2024 as clients shifted
from sight to term deposits starting in Q3 2023. Most of
these term deposits matured in the last quarter of 2024,
and due to declining interest rates, not all were renewed.
Instead, these funds were either allocated to alternative
investments (e.g., mutual funds) or transferred to
savings accounts. Consequently, the share of term and
savings accounts in total deposits from individuals
gradually rose to 51% (or EUR 4,537.5 million) by the
year-end, compared to 48% (or EUR 4,061.9 million) on
31 December 2023. For more information on the average
cost of funding, please refer to the chapter Funding
Strategy, MREL Compliance, and Capital.
702.3
865.9
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
5,276.9
995.6
2,833.0
504.7
5,474.3
1,220.0
2,827.8
500.5
509.1
2,703.7
738.2
Sight deposits Term deposits
6,272.4
6,694.3
+7%
3,337.7
3,328.3
0%
Deposits from
corporate &
state
4,336.1
1,580.4
12,177.7
2,282.6
12,785.8
2,726.2
4,686.3
1,860.3
SEE banks(ii)
14,640.3
15,512.0
+7%
8,543.8
8,965.4
+5%
5,916.5
6,546.6
+11%
NLB Group
Deposits from
individuals
NLB(i)
8,099.5
2,474.2
7,841.6
2,983.3
3,441.9
+15%
Figure 37: NLB Group deposits from customers dynamics (in EUR millions)
(i) On a stand-alone basis.
(ii) Sum of data on a stand-alone basis as included in the consolidated financial statements of the NLB Group.

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The ECB key interest rate cuts were reflected in the
decrease in interest rates on deposits from customers
in the Bank. However, some SEE banks increased the
interest rates on deposits in the last quarter, particularly
in December, to attract additional funding to support the
loan portfolio growth.
Figure 38: Interest rates for deposits from customers (quarterly, in %)
(i) On a stand-alone basis.
(ii) Sum of data on a stand-alone basis as included in the consolidated financial statements of the NLB Group.
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
Q1 2024
Q2 2024
Q3 2024
Q4 2024
0.53%
0.46%
0.63%
0.55%
0.48%
0.66%
0.55%
0.49%
0.65%
0.56%
0.47%
0.68%
SEE banks(ii)
NLB Group
NLB(i)

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Off-balance sheet items
Figure 39: Off-balance sheet items of NLB Group (in EUR millions)
+16%
34.6
41.0
2,832.3
2,663.2
1,631.6
1,805.6
2,140.8
2,487.5
31 Dec 2023
31 Dec 2024
Guarantees
Letters of credit
Loan commitments
Derivatives
6,300.8
7,335.7
The Group’s off-balance sheet items, primarily
consisting of guarantees (25%), loan commitments
(36%), and derivatives (39%), increased to EUR
7,335.7 million by the end of 2024. This growth was
largely driven by increase in derivatives, mainly due
to the hedging of issued NLB securities aimed at NII
stabilisation (EUR 1.070 million in 2024).
The share of guarantees in off-balance sheet items
remained stable, while the share of loan commitments
– mainly divided between loans (56%), overdrafts (17%
retail and 9% corporate), and cards (16%) – declined.

We provide comprehensive
banking and financial
solutions – in one place.
We put our customers first
by providing extensive,
innovative and simple
services – from banking
products to investments,
leasing and insurance.
After nearly 30 years, we
re-entered the Croatian
market, becoming the only
bank offering at least one
form of financing across
all the markets of a former
common country.

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Report
Segment Analysis*
Core Segments*
8 On 10 October 2024, KomBank Invest, Beograd was renamed NLB Fondovi, Beograd.
* The reference is made to this chapter from the Sustainability Statement chapter SBM-1 Strategy, business model, and value chain, the Table 13 excluded.
• Retail Banking in Slovenia covers individuals and micro
companies, asset management (NLB Skladi, Ljubljana),
and part of NLB Lease&Go, leasing, Ljubljana and
Summit Leasing Slovenija, Ljubljana operating
with retail clients; as well as part of the result of the
associated company Bankart.
• Corporate and Investment Banking in Slovenia covers
Key Corporate Clients, SMEs, Cross-Border Corporate
Financing, Investment Banking and Custody, Trade
finance, Restructuring and Workout, and part of NLB
Lease&Go, leasing, Ljubljana and Summit Leasing
Slovenija, Ljubljana operating with corporate clients.
• Financial Markets in Slovenia include treasury
activities and trading with financial instruments
while also presenting the results of asset and liability
management (ALM).
• Strategic Foreign Markets consist of strategic banks in
the Group operating in strategic markets (Serbia, North
Macedonia, Bosnia and Herzegovina, Kosovo, and
Montenegro), as well as the investment companies NLB
Fondovi, Skopje and NLB Fondovi, Beograd8, NLB DigIT,
Beograd, and the leasing companies NLB Lease&Go
Skopje, NLB Lease&Go Leasing Beograd, and Mobil
Leasing, Zagreb.
• Other activities include categories, whose operating
results cannot be allocated to specific segments
(including newly established tax on the balance sheet),
as well as the NLB Cultural Heritage Management
Institute, and also Real Estate entities from 2024 (the
latter were previously in the non-core segment).
Non-Core Segment*
• Non-Core Members include the operations of
non-core NLB Group members, i.e. entities in
liquidation, LHB, NLB Srbija, NLB Crna Gora, and
SLS HOLDCO, Ljubljana.
Table 13: Segments of NLB Group
NLB Group
Core Segments
Non-Core Segment
Retail Banking in
Slovenia
Corporate and
Investment Banking in
Slovenia
Financial Markets in
Slovenia
Strategic Foreign
Markets
Other
Non-Core Members
Profit b.t. (in EUR millions)
608
247
95
-14
338
-54
-4
Contribution to Group’s profit b.t.
100%
41%
16%
-2%
56%
-9%
-1%
Total assets (in EUR millions)
28,035
4,763
3,911
6,391
12,455
487
29
% of total assets
100%
17%
14%
23%
44%
2%
0%
CIR(i)
45.7%
39.2%
42.5%
/
46.1%
/
/
Cost of risk (bps)
14
68
20
/
-17
/
/
(i) Tax on the balance sheet excluded from the NLB Group calculation.
NLB Group’s main indicator of a segment’s efficiency is
net profit before tax. No revenues were generated from
transactions with a single external customer that would
amount to 10% or more of the Group’s revenues.

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Retail Banking
in Slovenia
Figure 40: Contribution to NLB Group
Result b.t.
41%
Net interest income
35%
Net non-interest
income40%
The Bank’s customer-focused approach has been key to its performance, strongly emphasising delivering
innovative products and services tailored to client needs. Digital transformation remains central to the Group’s
strategy and reflects technological innovation. With significant growth in loans and asset management, the Bank
remains committed to delivering excellence and enhancing user experience. The Bank retained its leadership in
bancassurance, leveraging exclusive partnerships with major insurance providers to achieve strong business
volumes. Strategic leasing operations expanded services for individuals and micro-clients, supported by branches’
expert advisory teams. Operational excellence was also marked by the Contact Centre’s 30th anniversary and
branch network, which focuses on high-demand areas and integrating ESG components. These initiatives solidify
the Bank’s market leadership, customer focus, and commitment to innovation and sustainability.
Financial and business performance
Table 14: Performance of the Retail Banking in Slovenia segment
in EUR millions consolidated
2024
2023
Change YoY
Net interest income
325.2
264.7
60.5
23%
Net interest income from Assets(i)
109.8
87.2
22.6
26%
Net interest income from Liabilities(i)
215.4
177.5
38.0
21%
Net non-interest income
123.1
102.3
20.8
20%
o/w Net fee and commission income
130.1
114.1
16.0
14%
Total net operating income
448.3
367.0
81.3
22%
Total costs
-175.9
-153.8
-22.0
-14%
Result before impairments and provisions
272.5
213.2
59.3
28%
Impairments and provisions
-28.1
-32.6
4.5
14%
Share of profit from investments in
associates and joint ventures
3.0
1.1
1.9
179%
Result before tax
247.3
181.7
65.7
36%
31 Dec 2024
31 Dec 2023
Change YoY
Net loans to customers
4,622.0
3,694.2
927.8
25%
Gross loans to customers
4,709.3
3,760.8
948.5
25%
Housing loans
2,678.8
2,483.5
195.4
8%
Interest rate on housing loans(ii)
3.14%
3.07%
0.07 p.p.
Consumer loans
963.5
818.5
145.0
18%
Interest rate on consumer loans(ii)
8.31%
8.14%
0.17 p.p.
Summit Leasing Slovenija
549.1
549.1
-
NLB Lease&Go, leasing, Ljubljana
132.7
98.2
34.5
35%
Other
385.2
360.6
24.6
7%
Deposits from customers
9,849.6
9,357.8
491.7
5%
Interest rate on deposits(ii)
0.49%
0.32%
0.17 p.p.
Non-performing loans (gross)
95.7
77.3
18.4
24%
2024
2023
Change YoY
Cost of risk (in bps)
68
56
12
CIR
39.2%
41.9%
-2.7 p.p.
Net interest margin(ii)
4.71%
4.17%
0.53 p.p.
(i) Net interest income from assets and liabilities using Fund Transfer Pricing (FTP).
(ii) The segment’s net interest margin is calculated as the ratio between annualised net interest income (i) and the sum of average interest-bearing assets
and liabilities divided by 2.

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Net interest income saw a 23% YoY increase, primarily
due to higher volumes (including from the leasing
acquisition) and the relatively high key ECB interest rate,
which positively affected the segment’s income from
clients’ deposits. The average interest rate on deposits
increased by 17 bps YoY. In the last quarter of 2023, the
Bank offered more attractive interest rates for term
deposits and savings accounts for individuals, which
customers perceived positively. Most of these deposits
matured in the last quarter of 2024. Given the decline in
interest rates, not all were renewed. Instead, these funds
were either placed in alternative investments
(e.g., mutual funds) or transferred to savings accounts.
Net fee and commission income increased by 14% YoY,
driven by the significant growth of fees from investment
funds, higher bancassurance client engagement,
repricing of accounts and packages fees, and
renegotiated conditions with the service providers in
card operations.
The segment’s total costs increased by 14% YoY,
primarily due to higher employee costs and the inclusion
of the retail part of Summit Leasing Slovenija, Ljubljana,
in the segment.
Impairments and provisions were net established for
credit risks related to the portfolio development.
The segment’s loan portfolio increased by EUR 948.5
million YoY, with EUR 549.1 million attributed to Summit
Leasing Slovenija, Ljubljana. Additionally, the retail part
of NLB Lease&Go, leasing, Ljubljana, continued its
robust growth, recording a 35% YoY portfolio increase.
Housing and consumer lending recorded strong YoY
growth, increasing 8% and 18%, respectively. As a
result, the segments’ market shares of housing and
consumer loans increased and reached 31.2% and
30.6%, respectively, compared to 30.2% and 29.8% as
at 31 December 2023. In 2024, the Bank relaunched a
successful edition of a housing loan campaign called,
"Your Chance for a Quick Move," in which 100 young
borrowers were rewarded by reimbursing three of their
instalments of up to EUR 1,000. A new mortgage loan
offer was introduced, including a property appraisal
and an energy performance certificate with no approval
fees. This initiative underscores the Bank’s commitment
to sustainability while simplifying the process for an
improved customer experience, which resulted in
boosting up the sales of green lending.
The new loan production was robust, with over EUR 500
million in housing and consumer loans approved
in 2024, reflecting a YoY increase of 30% and 38%,
respectively. Consequently, the market shares of the new
production of housing and consumer loans in 2024 was
also strong, at 36.6% and 33.6%, respectively, compared
to 33.3% and 29.8% in 2023.
The market shares of the segment recorded an increase
in retail lending to 30.4% (compared to 29.5% as at
31 December 2023) and in deposit-taking to 34.3%
(compared to 33.5% as at 31 December 2023). The
market share of short-term deposits remained relatively
low, as clients prefer the very popular savings account
(which is part of sight deposits) over traditional short-
term deposits.
Customer experience is our priority
The Bank’s product and service development is primarily
driven by the requirements and expectations of its clients.
In addition, the Bank tailors its offer to suit specific
segments and devises processes to support its clients’ life
situations. The sales approach and the offer are uniquely
tailored to each segment, serving as the foundation for
the Bank’s initiatives and business models. To enhance
user experience, the Bank is broadening its spectrum of
services to cater to an array of diverse segments. During
the year, the Bank also optimised accounts, and package
offers to provide a clearer offering for customers.
The Bank tracks customer satisfaction using two key
indicators: the Customer Satisfaction Index (CSI) which
measures overall satisfaction, and the transactional
Net Promoter Score (tNPS) which assesses satisfaction
after interaction with the Bank (after obtaining a new
product or service). The tNPS has shown consistent,
31 Dec 2022
31 Dec 2023
31 Dec 2024
30.5%
29.6%
29.8%
30.6%
Housing loans
Consumer loans
31 Dec 2022
31 Dec 2023
31 Dec 2024
36.1%
36.9%
36.8%
Sight deposits
Short-term deposits
Long-term deposits
Figure 41: Market share of net loans to individuals and market share of deposits from individuals
30.2%
31.2%
9.8%
5.8%
6.0%
21.5%
25.1%
27.6%
31. 2% and
30. 6%
market shares in
housing loans and
consumer loans
More than
EUR 1
billion in
new loans

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stable growth over the years and has increased by 6
i.p. YoY, reaching 67. The tNPS also indicates a stable
level of satisfaction (the benchmark for the financial
sector in 2024 is 55 based on the SurveyMonkey global
benchmark), influenced mainly by strong satisfaction
with advisory services.
considered less complex – and by differentiated pricing
with discounted approval costs for loans concluded
through NLB Klik.
Digital engagement, measured by the average number
of logins per active digital user (21 logins), grew rapidly in
2024, moving the Bank towards CE digitally more
advanced banks.
Figure 43: Digital sales(i) and digital penetration(ii)
The Bank aims to optimise its branch network by
closing less profitable offices and opening new ones
in more densely populated areas or locations where it
currently has no presence. After a long period, a new
branch office has been opened, while at the same time
renovations of the existing offices ensure improved
accessibility for people with impairments.
Employees in the Bank’s branch offices assist
clients daily in transitioning to digital and cashless
transactions, enabling faster and more independent
future operations. This allows employees to better utilise
their expertise and to focus on advisory roles for more
complex products, as branches increasingly serve as
31 Dec
2021
31 Dec
2022
31 Dec
2023
30 Jun
2024
31 Dec
2024
49.1%
6.6%
55.8%
7.1%
61.3%
6.3%
63.0%
26.1%
65.3%
29.6%
Sales
Penetration
(i) Share of the volume of digitally sold products in the total volume of
sales for comparable products.
(ii) Share of active digital users in # of clients with an active transactional
account.
Figure 42: Transactional Net Promoter Score(i)
(i) Source: Enterprise Feedback Management tNPS (measuring satisfaction after completion of service or obtaining new product).
The Customer Satisfaction Index indicator in Valicon’s
Client Satisfaction Survey (CSS) measures long-term
client relationships. In 2024, the Bank’s client satisfaction
improved across all dimensions, surpassing the
competition by 4 i.p. The Bank’s advisors remain a key
advantage, both in branches and in the Contact Centre.
Regaining position as
#1 Digital
Bank
The E-laborat study further confirms the highest
satisfaction increase happened in digital channels.
According to their recent independent market evaluation,
the Bank has reclaimed its position as the best-ranking
digital bank among comparable banks in Slovenia.
Available to our clients
The digital bank NLB Klik is an omnichannel solution
which offers a broad range of banking functionalities.
Its usage is primarily driven by its mobile application,
recently recognised as the market’s best mobile bank of
2024. Customers’ digital activity is reflected in growing
digital penetration, total digital sales share, and strong
engagement levels.
The Bank witnessed an increase in digital users of
7% YoY, with active digital penetration of 4 p.p. YoY,
and a significant boost in digital sales of 23.3 p.p. YoY.
Digital sales growth was supported by the launch of
new automated processes for daily banking products
– especially credit card limits and overdrafts, which are
2018
2019
2020
2021
2022
2023
2024
15%
15%
11%
13%
11%
9%
22%
21%
20%
18%
17%
15%
63%
64%
69%
69%
72%
76%
48
50
57
57
62
12%
16%
73%
61
67
Ø 57
Promoters
Neutrals
Detractors
NPS

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hubs for affluent customers. As the first step in improving
the user experience for these clients, the Bank launched
the Premium Plus 24/7 customer service line, providing
round-the-clock assistance. To further value clients’
precious time, an appointment booking option was
introduced that allows them to schedule branch visits or
video calls at their convenience.
The micro segment presents a rather challenging
segment, as it intertwines the characteristics of private
individuals and legal entities. The Bank strongly
emphasises the micro business segment, recognising its
potential for growth and innovation. By providing
dedicated advisory and support, effective processes,
and tailored offers, the Bank aims to empower micro
businesses to navigate challenges, seize opportunities,
and thrive. The Bank’s efforts are committed to
fostering a supportive and dynamic environment for
micro businesses.
In 2024, the Contact Centre (CC) marked a significant
milestone – 30 years of successful operation as the
Bank’s 24/7 customer support hub. During this time,
the CC has proved flexible and responsive to clients’
evolving needs and has become a well-known service
for the Bank’s customers.
With the implementation of the first chatbot on the
Bank’s website, the automation of simple inquiries
continues, enabling highly qualified advisors to focus on
finding the best solutions for more complex needs.
Improving the customer experience at every stage of the
Bank’s service development is an advantage in further
developing the CC as the virtual bank and specialist for
customer care.
In 2024, the CC expanded support for micro businesses
and significantly strengthened fraud prevention.
Communication via video call enabled CC to facilitate
10.9% of key retail product group sales. Furthermore,
good Bank practices are shared and expanded in the
Group’s banks.
With one of the largest ATM networks in the country, the
Bank will also introduce a Cash Deposit System (CDS)
machine to enhance cash service for legal entities, with
pilot use already underway.
Digitalisation of payments redirects clients to non-cash
business, with the convenient Group’s mobile wallet NLB
Pay solution integrating the most used wallets Google
Pay, Apple Pay, and Garmin Pay. The app allows users
to easily confirm their e-commerce purchases and
Flik payments. Further optimisation was achieved by
transferring SMS purchase alerts to push notifications
within the NLB Pay app, making it even more convenient
for clients.
Figure 44: NLB Pay volume of transactions (in EUR thousands)
In acquiring business, the Bank is running cooperation
with selected partners to acquire new merchants,
focusing on micro segment merchants. Another
important solution is the Group’s mobile POS terminal
solution, the NLB Smart POS, which is most suitable for
small businesses, enabling them to provide simple, fast,
and safe services. Several marketing campaigns were
also successfully presented in cooperation with selected
merchants, focusing on pushing the acquiring card
instalments and payments with cards by using NLB Pay.
Added value for our clients
Private banking is a leading banking provider for
this segment in the market and an integral part of the
Bank’s offering. The Bank provides comprehensive
wealth management, combining banking and financial
products, and a full spectrum of advisory services.
Products and services are carefully selected and tailored
to meet the unique needs of clients, which is a base
expanded by 17% YoY. A substantial 30% YoY growth
in assets under management was recorded, which
doubled in just four years, and reflects a successful
approach, new product introductions, and improved
internal processes.
Figure 45: Assets under management and the number of
private banking clients
NLB Skladi, Ljubljana, Slovenia’s largest asset
management company, achieved two milestones in 2024:
surpassing EUR 3 billion in assets under management
and generating EUR 286.1 million in annual net inflows,
which accounted for 55% of all net inflows in the market.
Annual gross inflows in mutual funds reached EUR 395.4
million, compared to EUR 260.9 million in 2023. The
market share of assets under management in mutual
funds reached 40.7%. The total assets under
management grew by 29.1% YoY, reaching EUR 3,047.7
million, with EUR 2,544.8 million from mutual funds and
EUR 502.9 million from the discretionary portfolio. NLB
Skladi, Ljubljana, has introduced a new service, the
management of alternative investment funds. It has also
completed the acquisition of Generali Investments,
Further strengthening
position of Top Retail
banking institution
in Slovenia
Significant progress in
digital
sales
2021
2022
2023
2024
488,565
122,952
58,924
36,218
+297%
31 Dec
2021
31 Dec
2022
31 Dec
2023
31 Dec
2024
1,243
1,711
2,224
1,377
1,800
2,000
2,347
2,756
AuM (in EUR millions)
# of Clients

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Financial
Report
Skopje (which was later rebranded to NLB Fondovi,
Skopje), and transferred the ownership of the Serbian
asset management company KomBank Invest, Beograd
(which was later rebranded to NLB Fondovi, Beograd).
The Bank has been the largest bancassurance provider
on the market for several years. To its long-term
partners, the insurance companies Vita, življenjska
zavarovalnica, Generali Zavarovalnica, and
Zavarovalnica Triglav, Zavarovalnica Sava was added
as a provider of property insurance products. Vita’s
model of exclusive distribution of life insurance products
resulted in excellent overall insurance premium volumes.
Figure 46: Active clients’ penetration of ancillary business
In cooperation with NLB Lease&Go, leasing, Ljubljana,
the Bank expanded its range of financial services to
private individuals and the micro segment. Expert
advice and high-quality financial services are available
within branch offices, where clients can choose the best
leasing solution tailored to their needs and select car
insurance, all provided by licenced advisors.
Leading the market in
Asset management
and Bancassurance
31 Dec
2021
31 Dec
2022
31 Dec
2023
31 Dec
2024
2.5%
10.3%
17.1%
2.7%
10.8%
17.7%
2.3%
11.6%
18.1%
2.4%
12.9%
18.3%
Vita
NLB Skladi
Generali

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Report
Corporate and Investment Banking
in Slovenia
The Bank reaffirmed its position as a leading and systemic player in its home region. It supports corporate clients
with daily banking and tailor-made comprehensive solutions, including trade finance, corporate finance, and cross-
border financing. The Bank also strongly emphasises sustainability in all its operations.
Figure 47: Contribution to NLB Group
Result b.t.
16%
Net interest income
14%
Net non-interest
income15%
Financial and business performance
Table 15: Performance of the Corporate and Investment Banking in Slovenia segment
in EUR millions consolidated
2024
2023
Change YoY
Net interest income
131.7
106.5
25.3
24%
Net interest income from Assets(i)
81.6
62.2
19.4
31%
Net interest income from Liabilities(i)
50.1
44.3
5.8
13%
Net non-interest income
47.1
42.7
4.4
10%
o/w Net fee and commission income
41.1
40.2
0.9
2%
Total net operating income
178.8
149.2
29.6
20%
Total costs
-76.0
-70.2
-5.9
-8%
Result before impairments and provisions
102.8
79.0
23.8
30%
Impairments and provisions
-7.6
7.9
-15.5
-
Result before tax
95.2
86.9
8.3
10%
31 Dec 2024
31 Dec 2023
Change YoY
Net loans to customers
3,871.8
3,360.2
511.6
15%
Gross loans to customers
3,946.4
3,413.2
533.2
16%
Corporate
3,749.1
3,306.7
442.4
13%
Key/SME/Cross Border Corporates
3,250.0
3,049.5
200.4
7%
Interest rate on Key/SME/Cross Border
Corporates loans(ii)
5.07%
4.54%
0.53 p.p.
Investment banking
0.1
0.1
0.0
-15%
Restructuring and Workout
108.2
97.7
10.5
11%
Summit Leasing Slovenija
203.8
203.8
-
NLB Lease&Go, leasing, Ljubljana
187.1
159.4
27.7
17 %
State
196.1
105.6
90.5
86%
Interest rate on State loans(ii)
5.60%
5.95%
-0.35 p.p.
Deposits from customers
2,392.0
2,471.8
-79.8
-3%
Interest rate on deposits(ii)
0.37%
0.28%
0.09 p.p.
Non-performing loans (gross)
79.9
61.8
18.0
29%
2024
2023
Change YoY
Cost of risk (in bps)
20
-36
56
CIR
42.5%
47.1%
-4.5 p.p.
Net interest margin(ii)
4.11%
3.55%
0.56 p.p.
(i) Net interest income from assets and liabilities using FTP.
(ii) The segment’s net interest margin is calculated as the ratio between annualised net interest income (i) and the sum of average interest-bearing assets
and liabilities divided by 2.

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In the Corporate and Investment Banking segment,
the Bank maintains its long-standing tradition and
commitment to sustainable and long-term business
relationships. Serving over 11,000 corporate clients,
it holds a market share of 32.2% in loans and 23.7%
in deposits. The business’s principal revolves around
customer centricity and addressing clients’ actual needs.
The Bank provides extensive and customised financial
solutions to support the broader economy.
Figure 48: Market share in Corporate Banking in Slovenia
Net interest income increased substantially by 24%
YoY, driven primarily by the rise in loan volume and the
relatively high key ECB rate, which positively impacted
the net interest income from clients’ deposits. Deposit
interest rates, being less sensitive to interest rate
volatility, also contributed to higher segment income.
The volume of gross loans grew by EUR 533.2 million
YoY, with nearly half related to the acquired corporate
part of Summit Leasing Slovenija, Ljubljana’s loan
portfolio. The organic growth was mainly recorded in the
Key and Cross-Border segments.
Following a significant decline in deposits during the first
half of the year, a rebound occurred in the second half,
resulting in an overall 3% decrease.
Net fee and commission income increased by 2% YoY,
primarily due to the fees from the RoS bond issue,
brokerage services, and guarantees.
Total costs rose by 8%, mainly driven by higher
employee costs and the inclusion of the corporate part
of Summit Leasing Slovenija, Ljubljana, in the segment.
Impairments and provisions were net established in
the amount of EUR 7.6 million due to changes in risk
parameters and portfolio development.
Comprehensive solution offering
As a key and important systemic player in the financial
market, the Bank raises awareness and supports clients
in the region’s development in ESG and sustainable
finance through proactive advisory services. In this way, it
increases its share in financing the green transformation
of companies in Slovenia and the wider region. The Bank
primarily finances renewable energy sources, electrical
distribution networks, sustainable construction and
building renovations, and sustainable mobility.
Cross-border activities saw substantial development
in 2024. The cross-border outstanding loan portfolio
reached EUR 595.1 million, with an additional approved
and still unutilised loans of EUR 126.8 million. A
significant portion of this financing focused on green
and sustainable projects in the home region, supporting
other key industries such as telecommunications, energy,
and real estate. Outside the home region, activities are
concentrated on Schuldschein loans, granted to large
international investment-grade rated companies that
are mainly in Central and Western Europe. Additionally,
the Bank is exploring options to engage in international
syndication deals in the transition finance universe.
The trade finance business remained stable, with a high
market share of 37.1% for the guarantee business and
a slightly higher share in documentary transactions.
Besides supporting all major infrastructure projects
in Slovenia and the region, the Bank’s guarantee
is recognised as the most requested and accepted
instrument for securing all types of risks in trade,
economy, and construction worldwide, which is reflected
in approximately 10% annual growth in volume and
income. Through all types of letters of credit, which
are also structured to enable financing, the Bank
reduces payment and performance risks for exporters
and importers. A strong focus has been given to all
different versions of receivables and payment financing,
where the Bank is expanding its product range with
interfactoring and thus maximising synergies among the
NLB Group members.
The Bank remains one of the top Slovenian players
in custodian services for Slovenian and international
clients. At the end of the year, the total value of assets
under custody on domestic and foreign markets stood
at EUR 13.1 billion compared to EUR 18.6 billion as of 31
December 2023. This change follows the transfer of a
client portfolio to an account with the Slovenian CSD,
as required by the EU regulation, after several years of
successful cooperation.
In 2024, brokerage services experienced substantial
YoY growth, where the Bank executed client buy and sell
orders of EUR 2.56 billion, reflecting an increase of 107%
compared to the previous year. In dealing with financial
instruments, foreign exchange spot deals amounted to
EUR 1.796 billion, while transactions involving derivatives
reached EUR 256.7 million.
31 Dec 2022
31 Dec 2023
31 Dec 2024
23.8%
25.7%
32.2%
25.3%
23.4%
23.7%
39.0%
38.6%
37.1%
Loans to customers
Deposits from customers
Guarantees and letters of credit
Strong focus on
green
financing
32. 2%
market share in loans to
customers
37.1%
market share in
guarantees and letters
of credit

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The Bank has been actively engaged in financial
advisory sector, which includes M&A and advisory
business, the organisation of syndicated loans, and
bond issuance. It acted as a sole mandated lead
arranger for syndicated loans of EUR 112.6 million, with
NLB participation amounting to EUR 50.8 million.
Additionally, the Bank played a key role in organising
bond issuances, acting as a sole lead manager or joint
lead manager for bonds in the nominal amount of EUR
1.188 billion. NLB was also a joint lead manager and
distributor of the RoS’s first retail bond in the nominal
amount of EUR 258 million.
Intermediary business for NLB Lease&Go, leasing,
Ljubljana remained a focus of the Bank’s commercial
activities, with the goal of providing clients with the best
possible financing solutions for vehicles and equipment.
The acquisition of Summit Leasing Slovenija, Ljubljana,
resulted in the leasing portfolio in this segment
expanding notably in Q3 2024, which strengthened the
focus on leasing activities.
The main focus in acquiring business was on retention
and gaining market share. Several initiatives were
launched to increase usage and onboard new
classic/ NLB Smart POS and E-Comm users. The NLB
Smart POS marketing campaign, offering a two-month
free trial period, successfully ended in December 2024
with merchants adopting a NLB Smart POS. Additionally,
a pilot cooperation with Lab4Pay (Elly POS), particularly
with Billy POS for new merchant onboarding, has been
introduced. An evaluation of this partnership model will be
conducted in January 2025 to determine the next steps.
There were also commercial achievements in 2024,
particularly well-received marketing campaigns
in cooperation with selected partners, focusing on
acquiring card instalments and payments with cards via
NLB Pay.
In 2024, NLB upgraded its card offerings with the
option for digitalisation via Apple Pay and Garmin Pay,
following the introduction of Google Pay in 2023. The
Bank started replacing traditional SMS notifications with
modern push notifications in the NLB Pay mobile wallet.
The Bank was the leading bank in introducing instant
payments in Slovenia and remains the only bank
enabling m-bank users to automatically send out
transactions as instant payments – every day of the year
in Slovenia and the SEPA area.
As the first banking group in the SEE, the Group enables
services arising from the SWIFT Global Payment
Initiative, an international payments service enabling
banks to transfer money faster and more safely
worldwide. At the same time, it enables full tracking of
payment orders and monitoring of related costs.
2021
2022
2023
2024
2021
2022
2023
2024
55
2,535
113
3,244
143
3,492
76
2,865
+8%
27%
e-commerce
POS
Figure 49: Transaction volume in acquiring (in EUR millions)
17%
annual growth in NLB
Lease&Go, leasing,
Ljubljana corporate
portfolio
NLB is the
bank of
choice
for most corporate
clients in Slovenia

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Financial Markets in Slovenia
The segment focused on the Group's operations in international financial markets, including ALM, treasury
functions, correspondent banking, and wholesale funding. Throughout the period, there was a strong focus on
managing liquidity reserves prudently amid the evolving interest rate environment, alongside efforts to stabilise
net interest income (NII). The Bank actively participated in international capital markets, issuing EUR 300 million in
Tier 2 notes and EUR 500 million in senior preferred notes. Correspondent banking played a key role in facilitating
international transactions and supporting the Group's global operations.
2
notes issuances
on international
capital markets
(Tier 2 and SP notes)
The trading and treasury result reached EUR 33 million
(of which net interest income EUR 29.8 million and net
non-interest income EUR 3.2 million), reflecting a YoY
increase of 27.9% (after FTP). This growth was driven
by a larger securities portfolio and more efficient
reinvestment of maturing assets, and focusing on
optimising risk-return metrics.
The Bank successfully issued 10NC5 subordinated Tier
2 notes of EUR 300 million in January to optimise and
strengthen its capital position and 6NC5 senior preferred
notes of EUR 500 million in May. Both issuances also
count towards meeting the MREL requirement.
Financial and business9 performance
Table 16: Performance of the Financial Markets in Slovenia segment
in EUR millions consolidated
2024
2023
Change YoY
Net interest income
-4.1
37.8
-41.8
-
Net interest income w/o ALM(i)
29.8
23.1
6.7
29%
o/w ALM(iii)
-33.9
14.6
-48.5
-
Net non-interest income
3.2
2.7
0.6
21%
Total net operating income
-0.8
40.4
-41.3
-
Total costs
-12.9
-9.9
-3.0
-30%
Result before impairments and provisions
-13.7
30.5
-44.2
-
Impairments and provisions
-0.7
4.8
-5.5
-
Result before tax
-14.4
35.3
-49.7
-
31 Dec 2024
31 Dec 2023
Change YoY
Balances with Central banks
1,772.3
4,153.2
-2,380.9
-57%
Banking book securities
4,499.0
2,981.1
1,517.9
51%
Interest rate(ii)
2.03%
1.17%
0.86 p.p.
Borrowings
51.1
82.8
-31.7
-38%
Interest rate(ii)
2.23%
1.66%
0.57 p.p.
Subordinated liabilities (Tier 2)
560.1
509.4
50.7
10%
Interest rate(ii)
8.33%
6.89%
1.44 p.p.
Other debt securities in issue
1,048.8
828.8
220.0
27%
Interest rate(ii)
6.27%
6.56%
-0.29 p.p.
9 This business overview includes the operations of the Group’s ALM, due to more comprehensive presentation of the operations on the Group level.
(i) Net interest income from assets and liabilities of trading and treasury after using FTP.
(ii) NLB interest rates.
(iii) ALM result in 2023 and 2024 is not comparable due to changed methodology in treatment of costs related to MREL and Tier 2 instruments.
Balances with the central bank decreased by EUR
2,380.9 million YoY, as they were partially transferred to
banking book securities, resulting in a YoY increase of
EUR 1,517.9 million. This transformation was undertaken
to stabilise net interest income in 2024. Additionally
decrease of central bank balances was caused by
acquisition and refinancing of the SLS Group.
57%
government securities in
the banking book debt
securities portfolio

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The Group’s ALM
The Group’s ALM process strategically manages
the Group’s balance sheet concerning the interest
rate, currency, and liquidity risk, considering the
macroeconomic environment and developments in the
financial markets. Monitoring and managing the Group’s
exposure to market risk is decentralised, with uniform
guidelines and limits for each type of risk for individual
Group members.
From the interest rate risk perspective, the surplus
liquidity position of the Group was used for targeted
actions to stabilise net interest income, contributed
to further growth of fixed interest rate loans, mostly
housing loans, and investments in high-quality debt
securities. In terms of funding, the non-banking sector
deposits continued to increase, mainly in the form of
term deposits.
The Group manages its positions and stabilises its
interest margin through pricing policy adjustments,
whereas to manage interest rate risk exposure,
the Group actively adjusts the average duration of
liquidity reserves and keeps outstanding "plain vanilla"
derivatives. Active profitability management has been
supported by a highly disciplined deposit pricing policy,
enabling the response to a highly competitive loan
market all over the Group’s strategic markets.
Liquidity management
The Group’s liquidity management focuses on ensuring
a sufficient level of liquidity reserves to settle all due
liabilities, minimising the cost of maintaining liquidity,
and optimising the structure of liquidity reserves.
The Group has developed a comprehensive liquidity
contingency plan (LCP) to ensure an appropriate level of
liquidity for different situations, including emergencies
and crisis conditions.
For settling due liabilities, the Group uses its liquid
assets, which are comprised of liquidity reserves (see the
subchapter Liquidity position in the chapter Overview of
Financial Performance) and other liquid assets. The
latter includes funds held on accounts with other banks
and money market placements, which are treated as
inflows according to the LCR calculation. Each Group
member manages its liquid assets independently.
Capital, liquidity, and
interest rate risks
management with an
active presence on
capital markets
4. 2 years
the average duration of
the banking book debt
securities portfolio

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Wholesale funding
Wholesale funding activities in the Group aim to achieve
diversification, improve structural liquidity and capital
position, and fulfil regulatory requirements, especially
ensuring compliance with the MREL requirements.
The Bank maintains a regular presence on international
capital markets and has a broad investor base, which
is important for securing favourable funding terms.
In 2024, the Bank was active on international capital
markets by issuing 10NC5 subordinated Tier 2 notes in
January to improve the capital position and 6NC5 senior
preferred notes in May for MREL purposes. In parallel
with the issuance of Tier 2 notes, the Bank conducted
a liability management exercise (LME), repurchasing
EUR 219.6 million of its two outstanding Tier 2 notes with
approaching call dates. In 2024, the Bank also exercised
call options of some of MREL eligible instruments and
Tier 2 instrument.
Additionally, NLB Group banking members from SEE
obtained funding from international financial institutions
in a total of EUR 37 million to support their clients, mostly
with green financing.
Table 17: Overview of outstanding NLB notes as at 31 December 2024(i)
in EUR millions
Type of bond
ISIN code
Issue Date
Maturity
First call date
Interest Rate
Nominal Value
Senior Preferred
XS2825558328
29 May 2024
29 May 2030
29 May 2029
4.500% p.a.
500
Senior Preferred
XS2641055012
27 Jun 2023
27 Jun 2027
27 Jun 2026
7.125% p.a.
500
Total SP:
1,000
Tier 2
XS2750306511
24 Jan 2024
24 Jan 2034
24 Jan 2029
6.875% p.a.
300
Tier 2
XS2413677464
28 Nov 2022
28 Nov 2032
28 Nov 2027
10.750% p.a.
225
Tier 2(i)
XS2113139195
5 Feb 2020
5 Feb 2030
5 Feb 2025
3.400% p.a.
10.5(i)
(issued
amount: 120)
Total Tier 2:
535.5
Additional Tier 1
SI0022104275
23 Sep 2022
Perpetual
between 23
Sep 2027 and
23 Mar 2028
9.721% p.a.
82
Total AT1:
82
Total outstanding:
1,617.5(i)
(i) Further information is available in the chapter Events After the End of the 2024 Financial Year.
Figure 50: Volume of outstanding NLB notes (in EUR millions)
Figure 51: Refinancing needs from matured NLB notes
(in EUR millions)
31 Dec 2024
31 Dec 2025
31 Dec 2026
31 Dec 2027
1,000.0
1,500.0
1,000.0
1,000.0
535.5
82.0
525.0
82.0
525.0
82.0
300.0
0.0
SP
Tier 2
AT1
1,617.5
1,607.0
1,300.0
2,107.0
Note: Including issued SP notes of EUR 500 million (in January 2025).
Maturity envisaged on call date.
31 Dec 2025
31 Dec 2026
31 Dec 2027
500.0
225.0
82.0
10.5
SP
Tier 2
AT1
Note: Maturity envisaged on call date.

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NLB’s banking book debt securities portfolio
Figure 52: Banking book securities portfolio of NLB by asset class and geography as at 31 December 2024 (in EUR millions)
Multilateral
bank bonds
and GGB’s
902
Government
bonds
2,552
Bank
senior
unsecured
bonds
695
Covered
bonds
228
Subordinated
debt
59
Corporate
bonds
12
EUR 4,449
million
Other
1,114
Slovenia
889
Belgium
522
The Netherlands
204
Luxembourg
278
Germany
312
France
476
Austria
199
Spain
186
Finland
173
Slovakia
97
EUR 4,449
million
The purpose of banking book securities is to provide
liquidity, manage interest rate risk and optimise interest
income. In 2024, an ongoing goal was to further diversify
the Bank’s banking book securities portfolio, which
at the end of 2024 amounted to EUR 4,449 million,
constituting 26.2% of the Bank’s total assets. At the year-
end, debt securities measured at FVOCI represented
36.01% of the Bank debt securities portfolio, having a
duration of 2.5 years, while the duration of the portfolio
measured at AC was 5.2 years. The negative valuation
of the FVOCI portfolio at year-end amounted to EUR
16 million (net of hedge accounting effects and related
deferred taxes), and unrealised losses from securities
measured at AC amounted to EUR 39 million.
The average duration of the Bank’s banking book debt
securities was approximately 4.2 years at year-end,
and the average yield on the Bank’s banking book debt
securities portfolio increased by 0.87 p.p. YoY to 2.04%.
Approximately 15% (or EUR 649 million) of the
banking book securities portfolio consists of the ESG
debt securities issued by governments, multilateral
organisations, or financial institutions, of which EUR 368
million were bought in 2024.
Figure 53: Maturity profile of NLB banking book securities as at
31 December 2024
3
2025
2026-2027
2028-2029
2030+
12%
32%
23%
33%
Slovenia
SEE
International
1,149
332
354
135
1,080
284
49
880
138
20
513
1,413
1,038
1,485
24
% of total portfolio

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Strategic Foreign Markets
The market shares (by
total assets) of subsidiary
banks exceeded
10%
in four out of six markets
Figure 54: Contribution to NLB Group
Result b.t.
56%
Net interest income
Net non-interest income
52%
44%
The core financial part of the Group in the Strategic Foreign Markets segment consists of six banks, three leasing
companies, two asset management companies, and one IT services company10. The Group banking subsidiaries are
regional market leaders across various business segments and provide a comprehensive range of financial services
to retail and corporate clients. All Group subsidiary banks have a stable market position, which, measured by total
assets, surpassed 10% in four out of six markets.
In 2024, the SEE region experienced sustained growth and a solid financial outlook. Key drivers contributing to this
positive economic performance include increased foreign direct investment (FDIs), strong export growth, moderate
inflation, and significant improvements in the business climate and economic indicators. These factors contributed
to shifts in the monetary policies of regional central banks, aligned with the ECB’s accommodative approach in
response to evolving economic conditions.
The upgrade of Serbia's sovereign rating signalled greater stability and reduced risk. It could attract more FDIs,
allow lower borrowing costs, and create huge opportunities to boost the local infrastructural projects and stimulate
the regional growth.
The segment achieved excellent results and marked remarkable double-digit growth of gross loans to customers
(17% YoY growth). The banks alone reported a 15% YoY growth, above the local market average, especially in
the retail segment, thereby contributing to the overall economic development of local countries’ households and
supporting green financing.
In line with the self-funding strategy, the Group banks’ customer deposits went up by 12% YoY, adapting to
prevailing market conditions, thus ensuring organic growth and keeping an optimal balance sheet structure.
In 2024, the Group banks accelerated their digital transformation by automating processes and offering various
digital solutions to clients, thus bringing, first in some markets, various solutions further boosting digital sales and
digital penetration, especially in the retail segment.
The Group banks’ ESG and CSR activities were continuously upgraded by supporting the financial literacy of clients,
organising the #FrameOfHelp project for small entrepreneurs, tree planting activities, and many more events, as
stated in the Group Sustainability report.
For their efforts in digital solutions and green financing, several Group banks received distinguished awards for
their contribution to the local countries of operation.
Leasing Operations continued to show solid growth, achieving a market share of 9. 7% in Serbia in new production,
which elevated the company to 6th position in the market. In North Macedonia, the company is the 3rd largest in the
market, with a market share of 20. 1% in new production.
10 More information on NLB DigIT is available in the chapter IT and Cyber Security.

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Financial and business performance
Table 18: Performance of the Strategic Foreign Markets segment
in EUR millions consolidated
2024
2023
Change YoY
Net interest income
483.1
423.2
59.9
14%
Interest income
566.7
472.5
94.2
20%
Interest expense
-83.6
-49.3
-34.3
-70%
Net non-interest income
135.9
118.4
17.5
15%
o/w Net fee and commission income
142.1
124.1
17.9
14%
Total net operating income
619.0
541.6
77.4
14%
Total costs
-285.2
-251.2
-33.9
-14%
Result before impairments and provisions
333.9
290.4
43.5
15%
Impairments and provisions
4.1
1.1
2.9
-
Result before tax
338.0
291.5
46.4
16%
o/w Result of minority shareholders
15.7
12.6
3.1
24%

31 Dec 2024
31 Dec 2023
Change YoY
Net loans to customers
7,847.4
6,648.1
1,199.3
18%
Gross loans to customers
8,027.5
6,839.8
1,187.6
17%
Individuals
4,087.0
3,525.6
561.5
16%
Interest rate on retail loans
6.94%
6.63%
0.31 p.p.
Corporate
3,635.5
3,042.9
592.6
19%
Interest rate on corporate loans
5.81%
5.37%
0.44 p.p.
State
304.9
271.4
33.5
12%
Interest rate on state loans
7.58%
7.13%
0.45 p.p.
Deposits from customers
9,964.3
8,878.3
1,086.0
12%
Interest rate on deposits
0.65%
0.38%
0.27 p.p.
Non-performing loans (gross)
130.6
134.0
-3.3
-2%
2024
2023
Change YoY
Cost of risk (in bps)
-17
-13
-5
CIR
46.1%
46.4%
-0.3 p.p.
Net interest margin
4.35%
4.19%
0.16 p.p.
The volume of the loans increased by 17% YoY. The
most significant increase in gross loans to customers
was achieved by NLB Banka, Prishtina (19% YoY), NLB
Komercijalna Banka, Beograd (17% YoY), NLB Banka,
Banja Luka (15% YoY), and NLB Banka, Podgorica (14%
YoY). High performance in new business production
continued in the corporate and retail segments, as
several products and services were upgraded, including
streamlining and modernising their distribution network
and improving their digital offering by introducing end-
to-end mobile digital retail loans.
In 2024, the leasing companies in strategic foreign
markets achieved remarkable growth, with a total new
leasing financing volume of EUR 184.9 million. Of this
amount, 51% (EUR 94 million) was generated by NLB
Lease&Go Leasing Beograd, 40% (EUR 75.0 million) by
Mobil Leasing, Zagreb, and the remaining 9% (EUR 15.9
million) by NLB Lease&Go Skopje.
The Group banks maintained solid capital and liquidity
positions that are well above regulatory requirements.
Six
subsidiary banks,
three
leasing companies,
two
asset management
companies and
one
IT services company
The overall confidence remained strong, and the total
customer deposit base increased by 12% YoY. The net
interest income increased by EUR 59.9 million YoY due to
higher volumes, of which the highest share was EUR 26.9
million contributed to the segment’s increase by NLB
Komercijalna Banka, Beograd.
The net fee and commission income increased by EUR
17.9 million due to higher volumes of card business and
payments, renegotiation of card terms with service
providers, and increased sales of bancassurance
products. The total net non-interest income of the
segment marked an increase of EUR 17.5 million YoY
as a result of banking members’ operations, which
contributed EUR 14.2 million of growth to the segment.
Total costs increased by EUR 33.9 million YoY due to
higher operating costs resulting from ongoing inflation
and increased employee costs. However, the segment’s
CIR improved to 46.1%.

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Performance Overview
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Statement
Financial
Report
Figure 55: Result after tax of strategic NLB Group banks (in EUR millions)
NLB KB,
Beograd
NLB Banka,
Skopje
NLB Banka,
Banja Luka
NLB Banka,
Sarajevo
NLB Banka,
Prishtina
NLB Banka,
Podgorica
132.3
44.5
24.3
12.8
36.0
26.7
140.5
67.8
29.5
14.4
37.0
27.7
+6%
+52%
+22%
+12%
+3%
+4%
2023
2024
The higher volumes and still high interest rates on the
local markets supported SEE banking members’ results,
thus showing a net interest margin between 3.1% (NLB
Banka, Sarajevo) and 5.1% (NLB Banka, Podgorica).
Retail banking
The banking members realised very high new retail loan
production of 15% YoY. The loan portfolio to individuals
increased in all banking members. New loan production
was still high, significantly outperforming the local
markets, especially in consumer loans. The highest
increase in loans to individuals was achieved by NLB
Banka, Prishtina (29% YoY), followed by other banks
with double-digit growth of the retail loans portfolio,
such as NLB Banka, Banja Luka (17% YoY), NLB Banka,
Podgorica (16% YoY), NLB Komercijalna Banka, Beograd
(15% YoY), NLB Banka Sarajevo (12% YoY) and NLB
Banka, Skopje (10%YoY).
Furthermore, all the banks in the Group increased their
market share in retail lending, with growth achieved
by NLB Banka, Banja Luka (1 p.p. YoY), followed by NLB
Banka, Prishtina (0.9 p.p. YoY), and NLB Komercijalna
Banka, Beograd (0.3 p.p. YoY).
The market shares of housing and consumer loans
showed significant growth. The largest increase was
recorded by NLB Banka, Banja Luka in the housing
segment, which rose by 0.8 p.p YoY, followed by NLB
Komercijalna Banka, Beograd with a 0.2 p.p. increase YoY.
In the consumer segment, the most significant market
share increase was recorded by NLB Banka,
Prishtina (1.2 p.p. YoY), followed by NLB Banka, Banja Luka
(1.0 p.p. YoY), NLB Komercijalna Banka, Beograd (0.6 p.p.
YoY) and NLB Banka, Podgorica (0.4 p.p. YoY). NLB Banka,
Skopje resulted in a market share increase of 0.1 p.p. YoY.
New production in green lending accelerated in 2024
with the offering of various NLB Green Loans through
partners – eco-mortgage loans through business
partners, eco-home appliance loans, electric and hybrid
vehicles, and so forth.
The Group banks retained customer confidence as the
total segment deposits from individuals increased by
11% YoY.
Corporate banking
The banking members achieved double-digit growth
in financing and attracting new corporate clients. The
portfolio to corporate banking clients recorded a 16%
YoY growth, with the highest growth levels achieved
by NLB Komercijalna Banka, Beograd (19% YoY), NLB
Banka, Skopje (19% YoY), and NLB Banka, Banja Luka
(15% YoY).
The banks continued supporting green investments,
particularly in solar power plants and energy efficiency.
The SEE banks attracted corporate deposits by boosting
the segment’s corporate balances by 17% YoY.
Profit before tax
EUR 338. 0
million
16% higher
compared to 2023

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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
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Statement
Financial
Report
Non-Core Members
The Non-Core Members segment includes the operations of non-core Group members. The main objective in the
non-core segment remains a rigorous wind-down of all non-core portfolios and the consequent reduction of
costs. The implementation of the wind-down has been pursued with a variety of measures, including the sales
of portfolios (either packages that include portfolios in a single market or entity, as well as packages combining
portfolios in different markets and/or entities), sales or liquidation of non-core entities, sales of individual assets,
or active collection.
Financial and business performance
Table 19: Performance of the Non-Core Members segment
in EUR millions consolidated
2024
2023
Change YoY
Net interest income
0.9
1.5
-0.6
-40%
Net non-interest income
0.4
-1.7
2.0
-
Total net operating income
1.3
-0.1
1.4
-
Total costs
-7.6
-13.7
6.1
45%
Result before impairments and provisions
-6.3
-13.9
7.6
55%
Impairments and provisions
2.2
3.7
-1.6
-42%
Result before tax
-4.1
-10.1
6.0
59%
31 Dec 2024
31 Dec 2023
Change YoY
Segment assets
28.6
47.1
-18.4
-39%
Net loans to customers
8.5
10.9
-2.5
-23%
Gross loans to customers
24.3
28.6
-4.3
-15%
Investment property and property &
equipment received for repayment of loans
5.5
20.1
-14.6
-73%
Other assets
14.7
16.0
-1.4
-8%
Non-performing loans (gross)
24.3
27.4
-3.2
-12%

The wind-down has remained the main objective of
the non-core segment in all the non-core portfolios.
In line with the divestment strategy, the segment’s
total assets decreased by EUR 18.4 million YoY. The
divestment process has been running with thoughtful
cost management and well-established collection
procedures.
New business has been suspended for all non-core
Group members undergoing wind-down. The decrease
of the cumulative non-core subsidiaries’ portfolio
remains ongoing through different collection measures
and repayments.
EUR 4. 3
million
reduction of gross loans
to customers in 2024
EUR 3. 2
million
reduction of
non-performing loans
(gross) portfolio in 2024

A sporting mentality
is something our
economies need on the
global stage and we
incorporate it daily into
our business operations.
Sports inspire us and bring
us together. That is why the
NLB Group has been proudly
supporting regional sports
for decades.

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Report
NLB Group Key Members
NLB Group banking members
NLB, Ljubljana
NLB as Slovenia’s largest and systematically important
bank, has demonstrated remarkable business
resilience in the dynamic interest rate environment this
year. Bolstered by the successful merger with N Banka
in 2023, the Bank has expanded its footprint, securing
a substantial market share, including in both retail and
corporate lending. In 2024, NLB achieved a record-high
profit before impairments and provisions of EUR 497. 6
million, up 24% YoY, while profit after tax declined by
only 7% compared to the previous year, as the 2023
result benefited from the deferred tax assets booking
and the release of impairments of equity investments.
EUR 478. 2
million
result a.t.
39%
contribution to
NLB Group’s
result a.t.
No. 1
bank in the country
(by total assets)
31. 3%
market share
by total assets
Financial and business performance
Table 20: Key performance indicators of NLB(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
431,880
372,566
16%
Net non-interest income
378,182
265,946
42%
Total costs
-312,458
-237,864
-31%
Impairments and provisions
14,386
78,098
-82%
Result before tax
511,990
478,746
7%
Result after tax
478,161
514,287
-7%
Financial position statement indicators
Total assets
16,975,091
16,014,776
6%
Net loans to customers
8,657,312
7,156,068
21%
Gross loans to customers
8,815,651
7,276,656
21%
Deposits from customers
12,293,708
11,881,563
3%
Equity
2,525,609
2,249,451
12%
Key financial indicators
Total capital ratio
24.4%
25.2%
-0.9 p.p.
Net interest margin
2.9%
2.8%
0.1 p.p.
ROE a.t.
19.8%
27.9%
-8.1 p.p.
ROA a.t.
2.9%
3.5%
-0.6 p.p.
CIR
34.5%
37.3%
-2.8 p.p.
NPL volume
148,119
138,004
7%
NPL ratio (internal def.: NPL/Total loans)
1.4%
1.2%
0.2 p.p.
Market share by total assets
31.3%
30.2%
1.1 p.p.
LTD
70.4%
60.2%
10.2 p.p.
(i) Data on a stand-alone basis as included in the Group’s consolidated financial statements. Merger of NLB and N Banka on 1 September 2023. Tax on the
balance sheet excluded from the calculation of CIR from 2024 on.

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Table 21: Key performance indicators of N Banka(i)
in EUR thousands
2023
Key performance indicators

Net interest income
27,822
Net non-interest income
5,225
Total costs
-16,811
Impairments and provisions
511
Result before tax
16,747
Result after tax
13,389
(i) Data on a stand-alone basis as included in the Group’s consolidated
financial statements. Data for 2023 are for the period January–August, a
merger of NLB and N Banka on 1 September 2023.
Table 22: Capital realisation YoY and surplus over OCR+P2G of NLB
in EUR millions
31 Dec 2024
31 Dec 2023
Change YoY
Surplus over
OCR+P2G
31 Dec 2024
Common Equity Tier 1 capital
2,101.4
1,734.6
366.8
863.3
Tier 1 capital
2,183.4
1,816.6
366.8
733.7
Total capital
2,716.8
2,324.1
392.7
984.9
Total risk exposure amount (RWA)
11,152.7
9,207.5
1,945.2
Common Equity Tier 1 Ratio
18.8%
18.8%
0.0 p.p.
7.7 p.p.
Tier 1 Ratio
19.6%
19.7%
-0.2 p.p.
6.6 p.p.
Total Capital Ratio
24.4%
25.2%
-0.9 p.p.
8.8 p.p.

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NLB Komercijalna
Banka, Beograd
NLB Komercijalna Banka, Beograd, is the second largest
bank within the NLB Group. As of the end of 2024, it
ranked as the fifth-largest bank in the Republic of Serbia
by market share. Throughout 2024, the bank continued
transforming its business model, which is reflected in
all segments of its sales activities. More specifically,
the bank once again outpaced the market in terms of
growth, while at the same time fortified its position as
one of the leading banking institutions in Serbia. Great
emphasis was also placed on the renewal of branches
and the digitalisation of operations to provide digital
solutions for its customers. Over the past year, it has
also devoted much attention to financing green projects.
Through its sponsorships in the previous year, the bank
supported several key areas and thus contributed to
overall progress in its region. The bank was once again
recognised as the Best Employer in Serbia, and for the
first time, it earned the international "Top Employer"
award. Additionally, after migrating card issuing to
a new service provider, the bank introduced Google
Pay, further enhancing its digital banking services.
Moving forward, the bank is committed to maintaining
its position as a top choice for both customers and
employees. Its goal is to remain a fast, simple, and
efficient bank among the best in lending and deposit
services in Serbia, and a leading bank in contributing to
a sustainable future.
Financial and business performance
Table 23: Key performance indicators of NLB Komercijalna Banka, Beograd(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
238,156
211,296
13%
Net non-interest income
53,237
49,686
7%
Total costs
-125,759
-113,634
-11%
Impairments and provisions
-5,694
1,933
-
Result before tax
159,940
149,281
7%
Result after tax
140,482
132,313
6%
Financial position statement indicators
Total assets
5,553,546
5,019,429
11%
Net loans to customers
3,290,707
2,811,599
17%
Gross loans to customers
3,333,958
2,848,543
17%
Deposits from customers
4,510,793
4,004,112
13%
Equity
865,359
827,575
5%
Key financial indicators
Total capital ratio
22.9%
27.1%
-4.2 p.p.
Net interest margin
4.8%
4.7%
0.1 p.p.
ROE a.t.
16.3%
16.9%
-0.5 p.p.
ROA a.t.
2.7%
2.8%
-0.1 p.p.
CIR
43.2%
43.5%
-0.4 p.p.
NPL volume
24,020
22,490
7%
NPL ratio (internal def.: NPL/Total loans)
0.5%
0.6%
0.0 p.p.
Market share by total assets
9.8%
9.9%
-0.1 p.p.
LTD
73.0%
70.2%
2.7 p.p.
(i) Data on a stand-alone basis as included in the Group’s consolidated financial statements.
Retail banking
The retail segment recorded 15% YoY growth in gross
loans over the average market growth, driven mainly
by the increased volume of consumer loans. The bank
continued to grow its market share of retail loans to 12.3%.
Significant double-digit growth in consumer loans
(22% YoY) increased the market share to 11.0%. Despite
a decline in demand in the housing segment, growth
above the market peers was achieved at 9% YoY,
thus boosting the share in the housing segment by
approximately 15 bps to 12.9%.
The deposit base increased by 8% YoY. The interest
margin in the retail segment was still high, but it was
under pressure from competition.
Corporate banking
The corporate segment marked a significant 19% growth
in gross loans in 2024. The bank aimed to build a strong
value proposition for all products and services in the
cross- and upselling programme, which also added
value to customers.
The bank participated in green project financing, thus
confirming its commitment to the green agenda and ESG
targets by supporting the increase of renewable energy
in Serbia. The bank also approved several project
financings for important real estate developments and
sovereign funding for road infrastructure development.
EUR 140. 5
million
result a.t.
27%
contribution to
NLB Group’s
result a.t.
5th
largest
bank in the country
9. 8%
market share
by total assets

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Report
NLB Banka, Skopje
The bank is a leading banking institution in the local
market, and is recognised by the National Bank as
a systemically important bank. In 2024, its success
was reaffirmed and recognised by receiving several
prestigious awards and confirmations in the fields
of banking, ESG, and corporate practices, and
demonstrated humanity and solidarity.
The bank continues to support the country’s
population and economy. The focus remains on
digitalisation and improving digital channels to
increase customer digital penetration, improving
customer experience, and expanding the portfolio of
products and services, particularly in "green" offerings
and socially responsible projects.
As follows, the bank introduced a new online payment
functionality, Pay by Link, as the first and only bank
on the local market which allows the client to pay for
goods and services via the link sent by the merchant.
Additionally, the Bank introduced Garmin Pay, an
innovative and modern solution for contactless
payment with just a smartwatch and NLB Smart POS. It
is a new technological solution for accepting contactless
card payments through which merchants can use their
mobile phones as POS terminals.
Throughout the year, the bank also signed two loan
agreements to support socially responsible, green, and
energy-efficiency investments: one with the French
Development Agency through the Development Bank
of North Macedonia, and the other with the European
Bank for Reconstruction and Development.
Financial and business performance
Table 24: Key performance indicators of NLB Banka, Skopje(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
76,487
65,406
17%
Net non-interest income
25,436
21,198
20%
Total costs
-39,305
-36,416
-8%
Impairments and provisions
15,110
-761
-
Result before tax
77,728
49,427
57%
Result after tax
67,838
44,517
52%
Financial position statement indicators
Total assets
2,158,767
1,902,260
13%
Net loans to customers
1,394,123
1,216,188
15%
Gross loans to customers
1,439,456
1,276,133
13%
Deposits from customers
1,733,845
1,499,509
16%
Equity
322,944
279,987
15%
Key financial indicators
Total capital ratio
17.4%
18.9%
-1.4 p.p.
Net interest margin
4.0%
3.7%
0.3 p.p.
ROE a.t.
22.9%
16.5%
6.5 p.p.
ROA a.t.
3.5%
2.4%
1.0 p.p.
CIR
38.6%
42.0%
-3.5 p.p.
NPL volume
36,214
48,791
-26%
NPL ratio (internal def.: NPL/Total loans)
2.1%
3.1%
-1.0 p.p.
Market share by total assets
15.9%
15.6%
0.3 p.p.
LTD
80.4%
81.1%
-0.7 p.p.
(i) Data on a stand-alone basis as included in the Group’s consolidated financial statements.
Retail banking
Gross loans grew 10% YoY, with the increase in housing
(14%) and consumer loans (9%), surpassing the 2024
market growth. The highest amounts of disbursed loans in
the retail segment led to an increase in the market share
to 22.8%. The bank focuses on the customer journey and
anticipates customers’ needs.
The deposit base increased by 16% YoY. The interest
margin in the retail segment was still relatively high,
but it was under pressure from competition. The key
drivers of income growth were the portfolio increase,
foreign payment operations, account management,
and bancassurance.
Corporate banking
At the end of 2024, the bank held a market share of 12.9%,
driven by an increase in corporate gross loans of 19% YoY.
Considering its strategic orientation, NLB Banka, Skopje
kept supporting investments in renewable sources and
projects aimed at increasing the corporate segment’s
energy efficiency, modernisation, and automation.
The bank grew its portfolio in the segment of long-term
financing of highly creditworthy clients, securing a stable
portfolio and revenue generation. The bank’s total
outstanding balance in project financing was EUR 51.7
million and almost EUR 40 million outstanding loans were
approved for investments in renewable sources, energy-
efficient investments, and green buildings (according to
the EBRD methodology for green buildings).
NLB Banka, Skopje also supported many export-oriented
companies by offering them services and products to
help them adapt to emerging market conditions. In
response to macroeconomic developments, corporate
interest rates were aligned with market conditions
throughout the year.
EUR 67. 8
million
result a.t.
11%
contribution to
NLB Group’s
result a.t.
15. 9%
market share by total assets
3rd
largest bank in the country

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Annual Report 2024
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Financial
Report
NLB Banka,
Banja Luka
In 2024, the bank remained the second largest bank in
the Republic of Srpska market, reaffirming its status as
a leading retail bank with an increased market share
of 23. 0% (increased by 1 p. p. YoY). The predominant
strength of the bank was its market position in the
corporate and retail segments, as well as its solid
deposit base. The bank received several "Golden BAM"
awards for the highest ROE, ROA, and, for the second
year in a row, the award for being the most innovative
bank in the market of Bosnia and Herzegovina, along
with its sister bank NLB Banka, Sarajevo. Further
strengthening its commitment to innovation, the bank
introduced Garmin Pay, expanding its range of digital
payment solutions.
EUR 29. 5
million
result a.t.
6%
contribution to
NLB Group’s
result a.t.
2nd
largest bank in the
Republic of Srpska
20. 9%
market share
by total assets
Financial and business performance
Table 25: Key performance indicators of NLB Banka, Banja Luka(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
38,473
32,475
18%
Net non-interest income
18,512
14,399
29%
Total costs
-23,228
-19,433
-20%
Impairments and provisions
-1,351
-763
-77%
Result before tax
32,406
26,678
21%
Result after tax
29,510
24,269
22%
Financial position statement indicators
Total assets
1,172,113
1,040,630
13%
Net loans to customers
644,579
556,960
16%
Gross loans to customers
664,344
575,960
15%
Deposits from customers
927,972
840,115
10%
Equity
130,314
107,270
21%
Key financial indicators
Total capital ratio
17.8%
15.9%
1.9 p.p.
Net interest margin
3.6%
3.4%
0.3 p.p.
ROE a.t.
24.9%
24.2%
0.7 p.p.
ROA a.t.
2.7%
2.4%
0.3 p.p.
CIR
40.8%
41.5%
-0.7 p.p.
NPL volume
7,445
5,543
34%
NPL ratio (internal def.: NPL/Total loans)
0.8%
0.7%
0.1 p.p.
Market share by total assets
20.9%
20.1%
0.7 p.p.
LTD
69.5%
66.3%
3.2 p.p.
(i) Data on a stand-alone basis as included in the Group’s consolidated financial statements.
Retail banking
Retail banking recorded strong double-digit YoY growth
in gross loans (17%), while deposits grew by 12% YoY.
Consumer loans increased by 20%, and housing loans
increased by 15% YoY. The market share in retail loans
rose by 1.0 p.p. YoY and reached 23.0%, while the market
share in retail deposits was 25.9%. The key drivers of
income growth were interest income and income from
accounts and payments processing.
The focus remained on the retail portfolio growth,
particularly on introducing additional customer services,
especially in digitalisation and bancassurance services.
Corporate banking
Corporate banking recorded YoY growth in gross loans
(15%) by supporting local companies in short- and long-
term projects and financing.
Corporate deposits recorded YoY growth of 15%,
enabling the bank’s organic growth.

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NLB Banka, Sarajevo
In 2024, the bank achieved 10% growth in total assets,
surpassing EUR 1 billion for the first time, as well as
strong profitability and a 12% growth in net profit. The
predominant strength of the bank is seen in housing
and consumer lending, which largely contribute to
the high share of net non-interest income (32% of
net fee and commission income in total net operating
income). Additionally, the bank achieved 12% YoY
growth in net interest income, driven by a substantial
surge in loan volume.
In 2024, the bank actively contributed to the country’s
green financing initiatives and launched new digital
products, including introducing Garmin Pay as the
first bank in Bosnia and Herzegovina. It also gained
significant visibility through various sponsorships and
promotions; among other things, together with NLB
Group, it donated EUR 1 million to flooded areas in
Bosnia and Herzegovina and received "Golden BAM"
for innovations for 2024. Furthermore, the bank’s
President of the Management Board, Lidija Žigić, was
honoured with the prestigious title of "Woman of the
Year 2024" and "Ladies In Ambassador 2025. "
EUR 14. 4
million
result a.t.
3%
contribution to
NLB Group’s
result a.t.
6th
largest bank in the
Federation of Bosnia
and Herzegovina
6. 0%
market share
by total assets
Financial and business performance
Table 26: Key performance indicators of NLB Banka, Sarajevo(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
28,436
25,490
12%
Net non-interest income
13,093
11,203
17%
Total costs
-22,824
-19,877
-15%
Impairments and provisions
-3,304
-2,939
-12%
Result before tax
15,401
13,877
11%
Result after tax
14,384
12,819
12%
Financial position statement indicators
Total assets
1,005,053
917,233
10%
Net loans to customers
633,666
575,560
10%
Gross loans to customers
655,136
597,715
10%
Deposits from customers
831,022
749,708
11%
Equity
107,662
95,980
12%
Key financial indicators
Total capital ratio
16.9%
17.8%
-0.9 p.p.
Net interest margin
3.1%
3.0%
0.1 p.p.
ROE a.t.
14.1%
13.6%
0.5 p.p.
ROA a.t.
1.5%
1.5%
0.1 p.p.
CIR
55.0%
54.2%
0.8 p.p.
NPL volume
14,854
15,732
-6%
NPL ratio (internal def.: NPL/Total loans)
1.7%
2.0%
-0.3 p.p.
Market share by total assets
6.0%(ii)
6.2%
-0.1 p.p.
LTD
76.3%
76.8%
-0.5 p.p.
(i) Data on a standalone basis as included in the consolidated financial statements of the Group.
(ii) Market share as at 30 September 2024.
Retail banking
Retail banking recorded YoY growth in gross loans,
reaching 12%, propelled by the expansion of housing
and consumer loans, which continued to increase
market share. Housing loans experienced a YoY increase
of 26%, while the consumer loans portfolio grew by
9% YoY, attributed to heightened demand, various
campaigns, and increased employee engagement. In
2024, the focus was on retail portfolio growth, client
acquisition, digital transformation, cash transition, and
the introduction of new innovative services to clients.
Retail deposits reached a YoY growth of 13%, which
supported the bank’s organic growth.
Corporate banking
The corporate banking segment achieved YoY growth
in gross loans, reaching 4%, while corporate deposits
had substantial YoY growth of 11%. The focus was on
continuously acquiring new creditworthy clients for loan
growth. A positive trend was observed in the growth
of the new clients and the volume of the guarantees
portfolio. Additionally, the volume of green lending
increased, positioning the bank for greater involvement
in renewable energy financing.

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NLB Banka, Prishtina
In 2024, the bank ranked second in profitability,
increasing its net profit by 3%. It was also the second-
largest bank in Kosovo, increasing its total assets
by 16% YoY. The bank’s predominant strength has
been providing a full spectrum of financial services
to both retail and corporate clients, while also
leading the market in innovations within the local
banking sector. Net interest income grew by 9%
YoY, mainly due to increased lending activities and
optimising investments in securities and the balance
sheet. In 2024, the bank was the first to introduce
an end-to-end mobile solution for retail lending.
Strengthening its commitment to digital innovation,
the bank also introduced Google Pay and Garmin Pay,
expanding its range of contactless payment options.
The bank received several prestigious awards from
the Kosovo Chamber of Commerce awards for
"Employer of the Year 2024" and "Taxpayer of the Year
2024," and from SOS Village for "The Friend of Children
for 2024. " The bank was also recognised by the EBRD
with the "Most Active Local Bank in Using TFP Line"
award for several consecutive years.
EUR 37. 0
million
result a.t.
6%
contribution to
NLB Group’s
result a.t.
2nd
largest bank
in the country
17. 0%
market share
by total assets
Financial and business performance
Table 27: Key performance indicators of NLB Banka, Prishtina(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
51,444
47,165
9%
Net non-interest income
8,164
8,017
2%
Total costs
-17,562
-15,995
-10%
Impairments and provisions
-1,094
776
-
Result before tax
40,952
39,963
2%
Result after tax
37,028
35,968
3%
Financial position statement indicators
Total assets
1,426,862
1,229,757
16%
Net loans to customers
996,781
831,333
20%
Gross loans to customers
1,028,521
866,730
19%
Deposits from customers
1,138,254
1,008,261
13%
Equity
173,827
149,669
16%
Key financial indicators
Total capital ratio
18.1%
15.8%
2.3 p.p.
Net interest margin
4.1%
4.2%
-0.1 p.p.
ROE a.t.
23.8%
27.3%
-3.4 p.p.
ROA a.t.
2.9%
3.2%
-0.3 p.p.
CIR
29.5%
29.0%
0.5 p.p.
NPL volume
17,044
16,234
5%
NPL ratio (internal def.: NPL/Total loans)
1.4%
1.6%
-0.2 p.p.
Market share by total assets
17.0%
16.9%
0.1 p.p.
LTD
87.6%
82.5%
5.1 p.p.
(i) Data on a stand-alone basis as included in the Group’s consolidated financial statements.
Retail banking
In 2024, the bank achieved YoY growth of 29% in gross
loans and 14% in deposits. The growth in retail was
predominately fuelled by heightened loan demand and
a further rise in the general consumption pattern. This,
in turn, has resulted in an inflation-driven increase in
real estate prices. The growth in housing loans reached
23%, and consumer loans showed a significant 40% YoY
increase. Digital penetration as a share of active users in
total increased from 23% to 30% YoY. In 2024, the bank
was the first on the market to introduce an end-to-end
mobile solution for retail lending.
In addition, the bank has signed several partnership
agreements with construction and trade companies
to finance their products and boost the performance
committed by the sales department.
Corporate banking
Corporate banking recorded YoY growth of 12% in gross
loans, mainly driven by the disruption of the normal
supply chain (external factors) and the cross-selling
of products to existing corporate clients who mainly
targeted new retail and SME clients. The optimisation of
the bank’s liquidity structure was highlighted by a 15%
YoY deposits increase. The key drivers of income growth
were working capital loans, credit lines, and overdrafts.
Cooperation on the Group level resulted in financing the
construction of a major locally recognised project that
contributed largely to clean energy production from
renewable sources. Digital penetration as a share of
active users in total increased from 76% to 90% YoY.

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NLB Banka,
Podgorica
In 2024, the bank ranked third among 11 banks in the
market and was identified as a systemically important
bank. The predominant strength of the bank lies
in housing and consumer lending, making it an
important player in the local market.
After being declared the Best Bank in Montenegro
for the third consecutive year and the "Best Bank for
Real Estate" by the respected financial magazine
"Euromoney," NLB Banka Podgorica received further
international recognition at year’s end. The prestigious
financial magazine "The Banker" declared NLB Banka,
Podgorica, the "Bank of the Year" for 2024.
The bank expanded its payment services by
introducing Apple Pay and Garmin Pay. In the last
quarter of 2024, the bank became the first bank in
Montenegro to introduce the new ISO 20022 standard
for cross-border payments. The introduction of
the new standard is a prerequisite for the bank’s
connection to the SEPA Credit Transfer scheme
planned for 2025.
EUR 27. 7
million
result a.t.
5%
contribution to
NLB Group’s
result a.t.
3rd
largest bank
in the country
14. 3%
market share
by total assets
Financial and business performance
Table 28: Key performance indicators of NLB Banka, Podgorica(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
45,987
40,335
14%
Net non-interest income
9,203
8,955
3%
Total costs
-24,069
-20,418
-18%
Impairments and provisions
1,501
3,238
-54%
Result before tax
32,622
32,110
2%
Result after tax
27,714
26,658
4%
Financial position statement indicators
Total assets
1,034,523
971,149
7%
Net loans to customers
669,999
584,526
15%
Gross loans to customers
686,730
603,349
14%
Deposits from customers
846,589
798,018
6%
Equity
119,729
120,390
-1%
Key financial indicators
Total capital ratio
18.6%
19.2%
-0.6 p.p.
Net interest margin
5.1%
4.8%
0.3 p.p.
ROE a.t.
22.1%
22.9%
-0.8 p.p.
ROA a.t.
2.8%
2.9%
-0.1 p.p.
CIR
43.6%
41.4%
2.2 p.p.
NPL volume
17,897
24,140
-26%
NPL ratio (internal def.: NPL/Total loans)
2.1%
3.2%
-1.1 p.p.
Market share by total assets
14.3%
14.4%
-0.1 p.p.
LTD
79.1%
73.2%
5.9 p.p.
(i) Data on a standalone basis as included in the consolidated financial statements of the Group.
Retail banking
The retail segment recorded 16% YoY growth in gross
loans and 7% in deposits. Over half of the retail portfolio
consists of consumer loans, while the remainder is
allocated to housing loans. The growth in gross loans
was recorded by the increase in consumer loan volume
by 20% YoY and housing loans by 13% YoY. Consumer
loan growth was affected by timely organised and well-
executed consumer loan campaigns following increased
pensions at the beginning of 2024 and later tax reform
through the new programme Europa 2. In 2024, the
focus was on retail consumer portfolio growth, with
particular emphasis on introducing additional services
for customers, especially in digitalisation.
Corporate banking
The corporate banking segment recorded YoY growth
in gross loans of 14% and 3% in deposits. The loan
portfolio predominantly consisted of large corporates,
which increased by 22% YoY. By improving the existing
portfolio quality, the new production of EUR 66.7 million
was recorded in all large corporates and SME segments.
In cooperation with the EU, the bank and EBRD signed a
contract worth EUR 3 million to contribute to developing
the SME sector in Montenegro. The funds are provided
within the SME Go Green programme, which the EU
finances through the Western Balkans Investment
Framework (WBIF).

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Leasing operations
Leasing is one of the strategic pillars of the NLB
Group’s operations. Leasing services address customer
needs, which is why NLB Group decided to gradually
expand this activity, first by entering the Slovenian
market with NLB Lease&Go, leasing, Ljubljana in
the spring of 2020, and then by establishing two
new leasing companies in 2022 in North Macedonia
and Serbia, and recently by acquiring SLS HOLDCO,
Ljubljana, the parent company of Summit Leasing
Slovenija, Ljubljana (SLS) and its Croatian subsidiary
Mobil Leasing, Zagreb (MBL) in September 2024. The
leasing services offered by the members of the NLB
Group complement the banks’ lending and enable
individuals and legal entities to choose the option that
best suits their needs, situation, and wishes. Leasing
will become an important part of the Group. The plan
is that through organic growth, it would contribute
more than EUR 2 billion to the total balance sheet of
the NLB Group by 2030.
NLB Lease&Go, leasing,
Ljubljana
NLB Lease&Go, leasing, Ljubljana is one of the
leasing companies in the Slovenian vehicle leasing
market, with EUR 349.0 million in total assets, and
an 11.2% market share11 as at 31 December 2024. NLB
Lease&Go, leasing, Ljubljana offers services for finance
leases and operative leases on movable property,
including financing personal and commercial vehicles,
production and other equipment, vessels, and more.
As at 31 December 2024, the NLB Lease&Go, leasing,
Ljubljana gross credit portfolio contribution to the
Group amounted to EUR 319.8 million. The portfolio’s
structure of EUR 132.7 million (i.e., 41% of the total) refers
to individuals and the rest to corporate.
Table 29: Key performance indicators of NLB Lease&Go, leasing, Ljubljana(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
8,847
6,464
37%
Net non-interest income
1,888
4,424
-57%
Total costs
-8,901
-7,757
-15%
Impairments and provisions
-764
-538
-42%
Result before tax
1,070
2,593
-59%
Result after tax
3,251
1,664
95%
Financial position statement indicators
Total assets
348,958
283,012
23%
Net loans to customers
318,458
256,531
24%
Gross loans to customers
319,776
257,509
24%
Equity
29,551
21,251
39%
Key financial indicators
ROE a.t.
13.4%
8.1%
5.3 p.p.
ROA a.t.
1.0%
0.7%
0.4 p.p.
CIR
82.9%
71.2%
11.7 p.p.
NPL volume
2,371
1,148
107%
NPL ratio (internal def.: NPL/Total loans)
0.7%
0.4%
0.3 p.p.
Market share of leasing portfolio
11.2%
9.7%
1.6 p.p.
(i) Data on a standalone basis as included in the consolidated financial statements of the Group.
11 Market share of leasing portfolio. Change in methodology: as of 31 December 2024, the leasing portfolio in banks is no longer included in the calculation.

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Summit Leasing Slovenija,
Ljubljana
With the signing of the Shares Purchase Agreement
on 30 November 2023 and closing the transaction on
11 September 2024, NLB became the sole shareholder of
SLS HOLDCO, Ljubljana, the parent company of Summit
Leasing Slovenija, Ljubljana (SLS) and its Croatian
subsidiary Mobil Leasing, Zagreb (MBL), together
forming the SLS Group. Completing the transaction is
another step in transforming NLB Group into one of
the regional champions. With this transaction, NLB
re-entered the Croatian market, thus becoming the only
financial institution in the region that offers at least one
form of financing in all markets of the former common
country. In the Croatian market, where Summit Leasing
Slovenija operates through its subsidiary Mobil Leasing,
Zagreb, we plan to gradually strengthen our presence.
Summit Leasing Slovenija, Ljubljana, is an undisputed
leader in the Slovenian vehicle leasing market, with
EUR 926.2 million in total assets, and with a 27.9%
market share12 as at 31 December 2024. The company
is the leading leasing provider for new and used
passenger cars, and a provider of point-of-sale
consumer credit. As at 31 December 2024, the Summit
Leasing Slovenija, Ljubljana gross credit portfolio
contribution to the Group amounted to EUR 867.4 million,
of which EUR 560.6 million (i.e., 65% of the total) relates
to individuals. The vast majority of the remaining part
belongs to corporate. By 31 December 2024, Summit
Leasing Slovenija, Ljubljana had generated a result
before impairments and provisions of EUR 2.3 million.
The merged entity’s pro-forma market share13 as at
31 December 2024 is 39.1% (considering the envisaged
integration with NLB Lease&Go, leasing, Ljubljana),
positioning the NLB Group as the market leader in the
Slovenian leasing market.
12 Market share of leasing portfolio. Change in methodology: as of 31 December 2024, the leasing portfolio in banks is no longer included in the calculation.
13 Market share of leasing portfolio. Change in methodology: as of 31 December 2024, the leasing portfolio in banks is no longer included in the calculation.
Table 30: Key performance indicators of NLB Summit Leasing Slovenija, Ljubljana
in EUR thousands
Sep - Dec 2024(i)
Jan - Dec 2024(ii)
Key performance indicators
Net interest income
9,793
16,245
Net non-interest income
3,086
9,757
Total costs
-8,975
-23,708
Impairments and provisions
-5,223
-2,266
Result before tax
-1,319
28
Result after tax
-1,009
3
Financial position statement indicators
31 Dec 2024(ii)
31 Dec 2024(ii)
Total assets
920,336
926,217
Net loans to customers
845,181
852,721
Gross loans to customers
851,008
867,360
Equity
102,906
108,787
Key financial indicators
CIR
69.7%
91.2%
NPL volume
25,092
NPL ratio (internal def.: NPL/Total loans)
2.9%
Market share of leasing portfolio
27.9%
(i) Data on a standalone basis as included in the consolidated financial statements of the Group. Due to acquisition of NLB Summit Leasing Slovenija,
Ljubljana in September 2024 data for 2024 are for the period September-December 2024.
(ii) Data in local financial statements. Key performance indicators for full-year 2024.
After the takeover of Summit Leasing Slovenija,
Ljubljana, governance activities of the NLB Group
were ensured (new governance rules, along with the
appointment of the Supervisory and Management
Boards changes). The harmonisation of both acquired
entities (SLS and MBL) with NLB Group standards
is ongoing. The merger of the Slovenian leasing
entities (NLB Lease&Go, leasing, Ljubljana and SLS)
is planned for June/July 2025. NLB’s current focus is
on managing a seamless merger process to ensure a
smooth transition, retaining operational efficiency, and
ensuring harmonisation with the NLB Group. The key
focus remains on clients and their needs, employees, the
dealer network, and all related stakeholders.
In 2025, the contribution to profit before tax of the joint
entity is expected to be around EUR 20 million and
grow further to exceed EUR 30 million p.a. by 2027. It
includes a positive impact of EUR 3–5 million p.a. from
cost synergies with an expected full run-rate for 2026
onward. NLB Group’s result in 2025 will be further
strengthened on the consolidated level with EUR 8
million in additional funding synergies. These funding
synergies will further increase with the growth of the
leasing business in the coming years. The planned
integration costs are EUR 8–9 million.
The realisation of cost synergies, funding synergies and
business activation, together with a strict cost agenda,
should bring the CIR of the joint entity to levels below
40% in 2026.

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Asset management
operations
NLB Skladi, Ljubljana
NLB Skladi, Ljubljana, Slovenia’s largest mutual fund
management company, maintains a high market
share of 40. 7% and is the largest asset management
company by total assets under management. The
company delivered strong results in 2024, with net
inflows into the NLB Skladi Umbrella fund amounting
to EUR 286 million and gaining a market share of
55% in net sales on the Slovenian market. The total
assets under management grew by 29% YoY to
EUR 3,048. 6 million, of which EUR 2,544. 8 million
consisted of mutual funds and EUR 503. 8 million in
the discretionary portfolio. In 2024, the company
surpassed an important milestone of EUR 3 billion of
total assets under management.
NLB Skladi, Ljubljana plays a pivotal role in the NLB
Group’s strategic activities, forming a cornerstone of
the Group’s comprehensive business portfolio. The
company offers a wide range of mutual funds and
discretionary portfolio management services and, with
regulatory approval from the Securities Market Agency
(ATVP) in Slovenia on 5 July 2024, has ventured into
managing alternative investment funds. By providing
highly personalised asset management services, NLB
Skladi, Ljubljana, delivers innovative and tailored
investment solutions that align with its clients’ unique
financial objectives.
With over 20 years of experience, NLB Skladi, Ljubljana,
has solidified its leadership position in Slovenia’s asset
management market. As of 31 December 2024, the
company holds an impressive 40.7% market share by
AuM, underscoring its dominance and commitment
to excellence in the sector. In April 2024, NLB Skladi,
Ljubljana, was honoured with eight prestigious awards
at the annual "Moje finance" event, recognising the top-
performing mutual funds. NLB Skladi, Ljubljana, has
been named the "Best Asset Management Company for
the Three-Year Period" and "Best Asset Management
Company for the Ten-Year Period."
Regionally, NLB Skladi, Ljubljana, continues its
growth through strategic acquisitions, further
enhancing its presence in the SEE region. On 23 May
2024, the company entered the North Macedonian
asset management market by acquiring Generali
Investments, Skopje, and in August 2024 renamed it
to NLB Fondovi, Skopje. To consolidate the ownership
of the asset management companies within the NLB
Group under the umbrella of NLB Skladi, Ljubljana,
the ownership of the Serbian asset management
company KomBank Invest, Beograd was transferred
from NLB Komercijalna Banka, Beograd, to NLB Skladi,
Ljubljana on 19 September 2024. In October 2024, it was
renamed to NLB Fondovi, Beograd. These acquisitions
represent more than an expansion of NLB Skladi’s asset
management capabilities. They are key milestones
in building a fully integrated financial ecosystem that
leverages the strength of NLB Group’s presence in the
region and ensures that cross-selling opportunities
between the Group’s banking and asset management
services meet the evolving needs of local investors.
Table 31: Key performance indicators of NLB Skladi, Ljubljana(i)
in EUR thousands
2024
2023
Change YoY
Key performance indicators
Net interest income
2
31
-94%
Net non-interest income
24,858
19,141
30%
Total costs
-9,283
-7,453
-25%
Impairments and provisions
0
0
-
Result before tax
15,577
11,719
33%
Result after tax
12,113
9,498
28%
Financial position statement indicators
Total assets
29,761
18,525
61%
Equity
22,971
13,707
68%
Key financial indicators
ROE a.t.
68.0%
81.0%
-12.9 p.p.
ROA a.t.
52.9%
60.3%
-7.4 p.p.
CIR
37.3%
38.9%
-1.5 p.p.
Market share by assets under management
40.7%
39.6%
1.1 p.p.
Total assets under management
3,048,581
2,359,847
29%
(i) Data on a standalone basis as included in the consolidated financial statements of the Group.
NLB Fondovi, Skopje
Since the end of May 2024, NLB Group has been
enriched with a new member in the field of asset
management. After obtaining all relevant approvals,
NLB Skladi, Ljubljana, acquired Generali Investments,
Skopje, on 23 May 2024 and rebranded the company to
NLB Fondovi, Skopje, on 7 August 2024.
NLB Fondovi, Skopje, is the third-largest asset manager
in the North Macedonian market, holds an 18.8% market
share. The company manages EUR 66.4 million in
assets in different investment funds and portfolios. Net
inflows in investment funds amounted to EUR 11.7 million,
highlighting steady growth.
NLB Fondovi, Beograd
On 6 May 2024, NLB Skladi, Ljubljana, signed a
Shares Purchase Agreement with NLB Komercijalna
Banka, Beograd, to acquire a 100% stake in KomBank
Invest, Beograd. Following all relevant approvals, the
transaction was successfully completed on 19 September
2024. On 10 October 2024, KomBank Invest, Beograd
was rebranded to NLB Fondovi, Beograd. The company
manages EUR 58 million of assets in different investment
funds and holds a 3.5% market share. The company
recorded in 2024 net inflows in investment funds of EUR
9.6 million, reflecting promising investor confidence and
market expansion.

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Risk Management
The self-funded model, strong liquidity, and solid capital position continued in 2024, demonstrating the Group’s
financial resilience. Efficient management of risks and capital is crucial for the Group to sustain long-term profitable
operations. A robust Risk Management framework is comprehensively integrated into the Group’s decision-making,
steering, and mitigation processes, and it aims to support its business operations proactively. The Group contributes
to sustainable finance by incorporating environmental, social, and governance risks into its business strategies, risk
management framework, and internal governance arrangements.
The Group has a well-diversified business model. Under
its strategic orientations, it intends to be sustainably
profitable, predominantly working with clients on its
core markets, providing innovative but simple customer-
oriented solutions, and actively contributing to a
sustainable, more balanced, and inclusive economic
and social system. Efficient management of risks and
capital is crucial for the Group to sustain long-term
operations. Risk Management in the Group manages,
assesses, and monitors risks within the Bank as the
main entity in Slovenia and the competence centre for
banking and leasing subsidiaries.
Figure 56: Risk profile of NLB Group as at 31 December 2024
Based on the Group’s business strategy, credit risk
is the dominant risk category, followed by credit
spread, interest rate risk in the banking book, and
operational risk. Credit risk management focuses on
moderate risk-taking, striving to assure a diversified
credit portfolio, adequate credit portfolio quality, the
sustainable cost of risk, and optimal returns considering
the risks assumed. The Group has limited exposure to
the other aforementioned risks, while market and other
non-financial risks are less important from a materiality
perspective. The Group integrates and manages ESG
risks within the existing types of risks, such as credit,
liquidity, market, and operational risk, as part of its risk
management framework. These risks are estimated as
low, except for transition risk in the area of credit, which
is assessed as low to medium. Liquidity risk tolerance is
low. The Group must always maintain an appropriate
level of liquidity and pursue a proper structure of
financing sources.
Table 32: NLB Group’s Key Risk Appetite Indicators (KRIs)
KRIs
31 Dec 2024
Total capital ratio
18.7%
CET1 ratio
15.3%
LCR
197.2%
NSFR
167.6%
Cost of risk
14 bps
NPL ratio (EBA definition)
2.0%
NPE (EBA definition)
1.1%
Interest rate risk (EVE)
5.0%
Lending growth, which was modest in the previous year
due to increasing interest rate trends, peaked in 2024.
During 2024, the Group’s credit portfolio remained of
high-quality and well-diversified, with a stable rating
structure and low level of NPL. There was no large
concentration in any particular industry sector. The
latter is particularly important as geopolitical tensions,
the green transition, and other macro developments
could materially impact specific industry sectors. The
Group closely monitored the macroeconomic and
geopolitical circumstances, remaining very prudent in
identifying any increase in credit risk at a very early
stage and being proactive in NPL management.
Furthermore, unfavourable trends in the German
automotive industry did not have a significant impact on
Slovenian export-oriented industry. Nevertheless, the
Bank downgraded some clients in the "Manufacturing of
1. 1%
low level of NPE (EBA def.)
2.7%
2.4%
10.6%
8.8%
5.0%
3.4%
67.1%
Credit risk
Concentration risk
Credit spread risk
Interest rate risk in banking book
Operational risk
Market risk
Business, Strategic and Other risks

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basic metals" sub-industry to stage 2 and formed
additional impairments. Despite this, the cost of risk
remained relatively low, at 14 bps. The established
impairments derive from portfolio development, new
financing, and any portfolio deterioration. In contrast,
the successful collection of previously written-off
receivables and changes in risk parameters contributed
positively to a low total net impact.
The Group remained well capitalised and well above the
risk appetite at both the Group and banking member
levels. The Group’s liquidity position also remained
strong, with liquidity indicators well above the regulatory
requirements, indicating a low tolerance for liquidity
risk. Significant attention was given to the structure
and concentration of liquidity reserves while at the
same time considering the potential adverse negative
market movements. Investment activity continued with
a balanced approach, focusing on identifying attractive
market opportunities while managing credit spreads,
interest rate risk, and capital consumption effectively.
Interest rate risk exposure remained moderate and
stayed well within the risk appetite tolerance.
As a systemically important institution, the Group
participates in the EBA EU-wide and ECB SSM Stress
Test exercise. This EU-wide stress test is designed to
assess the resilience of the European banking sector
in the current uncertain and evolving macroeconomic
environment, namely the aggravation of geopolitical
tensions, which could lead to a significant decline in
GDP. The results are expected to be published in early
August 2025.
In addition, in 2024, the Group participated in two ECB
Stress test exercises: the 2024 EBA Fit-for-55 climate risk
scenario analysis and the 2024 ECB Cyber Resilience
Stress Test Exercise. These exercises allowed the ECB to
assess how banks are prepared to handle with financial
and economic shocks related to climate and cyber risk.
Risk Management and control are carried out through
a clear organisational structure with defined roles
and responsibilities. The organisation and delineation
of competencies are designed to prevent conflicts of
interest and ensure a transparent and documented
decision-making process subject to an appropriate
upward and downward flow of information.
Competence line Risk Management in NLB is, by
encompassing several professional areas,
responsible for:
• formulating and controlling the Group’s Risk
Management policies,
• setting limits,
• overseeing the harmonisation,
• regular monitoring of risk exposures and limits based
on centralised reporting on a Group level.
The Group greatly emphasises the risk culture and
awareness across the entire Group. The Group’s Risk
Management framework is forward-looking and
tailored to its business model and corresponding risk
profile. The main risk principles and limits are defined by
the Group’s Risk Appetite and Risk Strategy, which are
designed in accordance with its business strategy. The
Group regularly conducts risk identification as part of
the ICAAP and ILAAP frameworks. All topical risks in this
process, including ESG-related ones, are
comprehensively assessed, monitored, and mitigated
where necessary. Particular attention is given to
integrating risk analysis into the decision-making
process at both strategic and operating levels, ensuring
diversification to avoid large concentrations, optimising
capital usage and allocation, setting appropriate risk-
adjusted pricing, and ensuring overall compliance with
internal rules and regulations. To adequately manage
ICT risks and ensure compliance with the Digital
Operational Resilience Act (DORA) requirements, a
dedicated second line of defence has been established
within the risk management function and ICT risk
management framework.
Risk Management focuses on managing and mitigating
risks in line with the Group’s Risk Appetite and Risk
Strategy, which form the foundation of the Group’s Risk
Management framework. Within these frameworks,
the Group monitors a range of risk metrics to ensure
its risk profile remains consistent with its Risk Appetite.
In addition, the Group is constantly enhancing its Risk
Management system, where consistent integration of
ICAAP, ILAAP, the Recovery plan, and other internal
stress-testing capabilities into the Risk Management
system is essential. Moreover, the Group emphasises
their integration into the overall Risk Management
system to assure proactive support for informed
decision-making.
14 bps
cost of risk
on the Group level
Proactive Risk
Management
in 2024
As a systemically important bank, the Bank is part
of the Single Supervisory Mechanism (SSM).
Supervision falls under the jurisdiction
of the Joint Supervisory Team (JST) of:
The Group adheres to ECB regulations, with its
subsidiaries operating outside Slovenia complying
with the rules set by the local regulators. Third-
party equivalents are approved in Serbia,
Bosnia and Herzegovina, and North Macedonia,
aligning local regulations with CRR rules.
Across the Group, risks are assessed, monitored,
managed, or mitigated in a uniformed manner, as
outlined in the Group’s Risk Management Standards,
while also considering the specifics of the markets
in which individual Group members operate.
ECB
BoS

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The uniform stress-testing programme, which includes
internally developed models, stress scenarios,
and sensitivity analysis, is regularly revised and
complemented. The Group has established an internal
ESG stress-testing framework to identify the most relevant
financial vulnerabilities stemming from climate risk, which
is continuously enhanced by incorporating available
ESG-related data. This comprehensive stress-testing
framework undergoes a regular internal validation cycle,
and is supported by a robust validation framework.
The Group ensures strict controls over the applied and
selected risk approaches and internal models.
The business and operating environment relevant
to the Group’s operations is evolving, driven by
trends such as sustainability, social responsibility,
governance, changing customer behaviour, emerging
new technologies, and competitors. These trends are
actively contributing to a more sustainable, balanced,
and inclusive economic and social system, alongside
increasing new regulatory requirements. It should be
noted that Risk Management is continuously adapting to
identify and address new potential emerging risks.
Figure 57: NLB Group’s Risk Management Framework
Business strategy
ICAAP & ILAAP
inputs
Risk identification
Risk Appetite / Risk strategy
(Limit system)
Capital and Financial planning
Results
Recovery plan
Assessment of liquidity and capital
(significant deterioration)
ILAAP
• Economic and normative
assessment of liquidity
• Stress tests
• Liquidity contingency plan
(LCP)
ICAAP
• Economic and normative
assessment of capital
• Stress tests

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Proactive Risk Management in 2024
A prudent capital-level
position and attainment of
interim MREL targets
One of the key objectives of Risk Management is to
maintain a prudent capital position for the Group. The
Group monitors its capital position at both the Group
and individual subsidiary bank levels in accordance
with its Risk Appetite. It also incorporates normative and
economic perspectives as part of the established ICAAP
process. As at 31 December 2024, the Group maintained
a solid capital position and TCR of 18.7% (1.5 p.p. YoY
decrease). The CET1 ratio, representing the highest
quality capital, stood at 15.3% (1.1 p.p. YoY decrease).
Capital is higher mainly due to the partial inclusion
of the 2024 profit (EUR 257.3 million) and revaluation
adjustments (EUR 56.5 million). An increase in RWA
in NLB Group for credit risk primarily relates to the
ramping up lending activity across all NLB Group banks
and the contribution from the acquired SLS Group.
The growth in RWA was partially mitigated by CRR-
eligible real estate collaterals. The increase in RWAs for
market risks and Credit Valuation Adjustments (CVA) is
largely due to higher RWA for FX risk. The rise in RWA
for operational risks mainly derives from the higher net
interests and net fee and commission income, which led
to an increased three-year average of relevant income.
As at 31 December 2024, the Group meets all fully loaded
regulatory requirements. Moreover, the regular ECB
SREP assessment resulted in a stable P2R, remaining at
2.12%, while Pillar 2 Guidance remains at a low level of 1%.
The MREL requirement forms part of the Group’s risk
appetite, whereby its fulfilment is regularly analysed and
monitored. NLB complies with all interim targets. More
information on MREL is available in the chapter Funding
Strategy, MREL Compliance, and Capital.
Maintaining a solid
liquidity position and
structure
Maintaining a solid liquidity position and structure
is another key risk objective. The liquidity position
remained stable and strong at the Group and individual
subsidiary bank levels. The Group’s LCR decreased
to 197.2% (down 48.5 p.p. YoY), remaining well above
the risk appetite limit. The level of the unencumbered
eligible liquid reserves remained high, representing
33.2% of total assets. The Group holds sufficient liquidity
reserves in the form of placements with the ECB, prime
debt securities, and money market placements. The
Group’s core funding base predominately consists of
retail customer deposits, which are very stable and
consistently growing. The LTD ratio increased to 73.7%
from 66.2% at the end of 2023, though it remains at a
very comfortable level.
Figure 58: NLB Group’s Pillar 2 Requirement evolution
2018
2019
2020
2021
2022
2023
2024
3.50%
3.25%
2.75%
2.75%
2.60%
2.40%
2.12%

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Maintaining adequate
credit portfolio quality
Maintaining an adequate credit portfolio quality is the
most important goal, focusing on cautious risk-taking
and the quality of new loans, and leading to a diversified
portfolio of customers. The Group constantly develops
a wide range of advanced approaches in the credit risk
assessment segment, in line with best banking practices,
to further enhance the existing risk management tools
while enabling faster customer responsiveness. The
restructuring approach in the Group is focused on the
early detection of clients facing potential financial
difficulties and their proactive management.
The Group actively supports the SEE markets by
financing both existing and new creditworthy clients.
The Group’s lending strategy focuses on its core retail
and SME markets and selected corporate business
activities within the region and the EU. In the Slovenian
market, the focus is on providing tailored solutions for
retail, medium-sized companies, and small enterprises.
In the corporate segment, the Bank has established
partnerships with selected corporate clients through
different types of lending or investment instruments.
All other banking members in the SEE region where
the Group operates are universal banks, mainly
focused on retail, medium-sized companies, and small
enterprise segments. Their primary goal is to provide
comprehensive services to clients while adhering to
prudent risk management principles. In addition, with
the acquisition of the SLS Group, the Group strengthened
its leasing position in the Slovenian market and entered
the Croatian market.
Figure 59: NLB Group structure of the corporate and retail credit portfolio (gross loans) by segment and geography (in EUR millions)
(i) The largest part represents EU members.
27%
26%
19%
28%
Retail
consummer
4,213
SME
4,633
Retail
hosing
4,522
Corporates
3,138
EUR 16. 5
billion
SME
Corporate
Retail/Housing
Retail/Consumer
3,649
2,897
3,932
2,812
3,764
2,865
4,105
3,131
4,368
3,101
4,522
3,642
4,633
3,138
4,522
4,213
31 Dec 2022
31 Dec 2023
31 Dec 2024 w/o SLS Group
31 Dec 2024
Slovenia
BiH
N. Macedonia
Montenegro
Kosovo
Serbia
Other(i)
50% 48% 49%
8%
9%
8%
9%
9%
9%
4%
5%
4%
6%
7%
6%
20%
1%
21%
2%
20%
3%
31 Dec 2022
31 Dec 2023
31 Dec 2024
N. Macedonia
1,468
Montenegro
706
Kosovo
1,067
Serbia
3,375
Slovenia
8,026
BiH
1,350
Other(i)
514
EUR 16. 5
billion

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Lending growth, which was modest in 2023 due to rising
interest rates, peaked in 2024. In the retail segment,
fixed-interest rate lending prevailed, especially in the
housing loan market. In the corporate segment, the Bank
seized opportunities to finance some of the region’s
top corporate clients while focusing on SMEs as its key
segment. The current structure of the credit portfolio
(gross loans to corporate and retail customers) consists
of 53% retail clients, 19% large corporate clients, and 28%
SME clients. The retail portfolio represents a significant
share of the whole credit portfolio, with housing loans
continuing to be the still prevailing segment.
The corporate credit portfolio is well diversified, with
no large concentration existing in any specific industry.
This is particularly important to maintain, as geopolitical
tensions, the green transition, and other macro factors
could pose challenges to specific economic sectors.
Table 33: Overview of the NLB Group corporate loan portfolio by industry as at 31 December 2024
Credit portfolio
in EUR millions
Corporate sector by industry
NLB Group
%
∆ Q4 2024
∆ YtD 2024
Accommodation and food service activities
241.9
3%
50.2
43.0
Act. of extraterritorial org. and bodies
0.0
0%
0.0
0.0
Administrative and support service activities
150.8
2%
3.9
39.5
Agriculture, forestry and fishing
383.9
5%
16.7
39.2
Arts, entertainment and recreation
20.9
0%
-0.8
0.8
Construction industry
773.9
10%
23.8
216.9
Education
23.2
0%
5.2
8.3
Electricity, gas, steam and air conditioning
616.5
8%
55.9
73.2
Finance
229.1
3%
59.0
84.8
Human health and social work activities
48.0
1%
0.0
10.6
Information and communication
233.6
3%
-24.3
-58.0
Manufacturing
1,764.5
23%
24.8
239.7
Mining and quarrying
42.5
1%
-1.3
-3.6
Professional, scientific and techn. act.
348.1
4%
77.9
113.2
Public admin., defence, compulsory social.
213.9
3%
10.6
14.4
Real estate activities
442.3
6%
49.5
64.9
Services
19.5
0%
5.2
5.5
Transport and storage
634.6
8%
4.7
15.6
Water supply
66.1
1%
-0.5
8.9
Wholesale and retail trade
1,517.3
20%
19.3
227.0
Other
0.1
0%
0.0
-2.6
Total Corporate sector
7,770.7
100%
379.9
1,141.4

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Table 34: Main manufacturing activities of NLB Group by stages as at 31 December 2024
Credit portfolio
in EUR millions
Main manufacturing activities
%
NLB
Group
- o/w
Stage 1
- o/w
Stage 2
- o/w
Stage 3
∆ 2024
- o/w
Stage 1
- o/w
Stage 2
- o/w
Stage 3
∆ Q4
2024
- o/w
Stage 1
- o/w
Stage 2
- o/w
Stage 3
Manufacture of food products
3.9%
303.4
271.6
24.6
7.2
21.4
25.9
-8.5
4.0
20.9
22.0
-4.4
3.3
Manufacture of fabricated metal products,
except machinery and equipment
2.6%
203.4
152.5
41.9
9.0
10.0
-24.6
32.7
1.9
-3.6
-4.2
0.4
0.2
Manufacture of basic metals
2.5%
192.1
122.3
68.7
1.1
36.1
-17.3
52.7
0.8
13.0
-44.9
57.2
0.6
Manufacture of electrical equipment
2.4%
183.4
179.0
4.0
0.3
-7.4
-10.4
3.0
-0.1
-28.1
-30.8
2.8
0.0
Manufacture of other non-metallic mineral products
1.5%
118.7
111.3
3.1
4.3
20.8
23.3
-5.1
2.6
0.9
1.7
-0.6
-0.2
Manufacture of motor vehicles,
trailers and semi-trailers
1.3%
98.5
94.2
0.2
4.1
12.6
12.6
-1.8
1.7
3.2
3.2
-1.6
1.6
Manufacture of machinery and equipment n.e.c.
1.1%
86.8
79.1
6.5
1.2
7.4
6.5
0.1
0.8
-6.3
-6.3
-0.8
0.8
Manufacture of rubber and plastic products
1.1%
85.7
82.2
2.4
1.1
10.9
10.3
0.6
-0.1
2.3
0.6
1.6
0.0
Manufacture of basic pharmaceutical products
and pharmaceutical preparations
1.0%
74.5
74.5
0.0
0.0
47.7
49.8
-2.0
0.0
-0.5
1.6
-2.0
0.0
Manufacture of wood and products of wood
and cork, except furniture; manufacture of
articles of straw and plaiting materials
0.7%
54.0
40.7
10.2
3.1
3.5
3.4
0.8
-0.7
-1.2
-1.6
0.8
-0.4
Manufacture of furniture
0.6%
44.9
38.5
4.2
2.3
-0.4
-3.8
2.5
0.9
-0.7
-3.4
2.9
-0.2
Manufacture of wearing apparel
0.6%
43.9
43.4
0.2
0.3
33.9
34.1
-0.1
-0.1
-0.2
0.1
-0.3
0.0
Other manufacturing activities
3.5%
275.3
248.3
22.6
4.4
43.3
47.6
-5.1
0.8
25.1
21.6
3.0
0.4
Total manufacturing activities
22.7%
1,764. 5
1,537.5
188.6
38.4
239. 7
157.3
69.8
12.6
24. 8
-40.4
59.2
6.0
A moderate transition to Stage 2 occurred in the sub-
industry "Manufacturing of basic metals" during Q4
2024. The Bank identified several qualitative factors
that led to the downgrade of certain clients and the
recognition of Stage 2 impairments in 2024.
The German automotive industry, which significantly
influences the European market, is currently facing
unfavourable trends. These challenges could affect
Slovenia’s economy, as its automotive industry is
export-oriented and integrated into the European
supply chain. NLB Group has reviewed its portfolio
and anticipates no significant threats to companies
involved in manufacturing of automotive components
or those related to car sales and maintenance services.
Financing for both automotive industry segments
represents a small part of the Bank’s portfolio –
manufacturing accounts for 2.0% and sales for 2.9% of
the corporate sector.
Figure 60: NLB Group exposure to the automotive industry as at 31 December 2024
BiH
10%
N. Macedonia
10%
Montenegro
4%
Slovenia
40%
Serbia
12%
Kosovo
24%
˜EUR 130
million
Car sales & maintence in NLB Group banks
Car sales & maintence in NLB Group leasing companies
Manufacturing of car components in NLB Group
Slovenia
74%
Croatia
20%
Serbia
5%
Other
1%
˜EUR 95
million
Serbia
5%
Slovenia
76%
France
13%
N. Macedonia
6%
˜EUR 158
million

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The Bank’s corporate portfolio also includes financing
of real estate activities (projects), which account for a
smaller part of the portfolio. These projects are carefully
monitored at each phase of construction. For income-
producing CRE projects in the operational phase, the
DSCR ranges from 1.2 to 1.4, and the LTV is, on average,
below 60%. This ensures that a sufficient reserve and
repayment to the Bank is not at risk. For most approved
loans, an amortisation repayment structure was backed
against the background of concluded long-term rental
contracts (offices and shopping malls segment).
In the development phase, the Bank requires a minimum
equity contribution of 25% and a pre-lease/pre-sale
commitment of 30% for office spaces, 60% for shopping
malls, and 20% for residential real estate before the first
disbursement. The Bank finances projects sponsored by
investors with proven track records. In this portfolio, no
issues with occupancy rates or rent deterioration have
not been observed.
At the end of 2024, the specific commercial real-estate
financing projects were predominantly in the operational
phase, with 83% of retail shopping centres, 88% of hotels,
and all office and conference centres fully operational.
Figure 61: NLB Group specific Commercial Real-Estate Financing as at 31 December 2024
Retail shoping centres
BiH
5%
Slovenia
37%
Kosovo
2%
N. Macedonia
22%
Montenegro
11%
Serbia
23%
˜EUR 202
million
Office & Congress centres
Slovenia
37%
Serbia
63%
˜EUR 126
million
Hotels
Slovenia
73%
Others
2%
Kosovo
16%
N. Macedonia
2%
Montenegro
6%
Serbia
1%
˜EUR 151
million

NLB Group
Annual Report 2024
104
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
In the current macroeconomic environment, the Group’s
asset quality remains robust. The majority of the
Group’s loan portfolio is classified as Stage 1 (93.4%),
a relatively small portion as Stage 2 (5.0%), and Stage
3 (1.6%). The Stage 2 allocation has increased in the
corporate and retail segments. The increase in Stage
2 in Q4 within the corporate sector was affected by
the deteriorating financial position in the basic metals
manufacturing industry. The increased Stage 2 exposure
in the retail segment results from the improved process
and methodological changes in the early detection of
SICR. However, the increase remains modest compared
to the total portfolio volume, with 72.2% of the Stage 2
exposure showing no delays. The loans in Stages 1 to 3
are measured at amortised cost, while no receivables
are measured at fair value through profit or loss (FVTPL).
The outflow in the state and institutions segment is due
to the redistribution of excess liquidity into high-quality
sovereign bonds and financing newly acquired leasing
companies. On a consolidated level, the portfolio in the
retail and corporate segments has replaced exposures
to sovereign and institutions.
Table 35: NLB Group loan portfolio by stages as at 31 December 2024 (in EUR millions)
in EUR millions
Credit portfolio
Provisions and FV changes for credit portfolio
Stage 1
Stage 2
Stage 3 & FVTPL
Stage 1
Stage 2
Stage 3 & FVTPL
Credit
portfolio
Share of
Total
YTD
change
Credit
portfolio
Share of
Total
YTD
change
Credit
portfolio
Share of
Total
YTD
change
Provision
Volume
Provision
Coverage
Provision
Volume
Provision
Coverage
Provisions
& FV
changes
Coverage
with
provisions
and FV
changes
Total NLB Group
19,313.8
93.4%
74.6
1,036.8
5.0%
332.6
330.5
1.6%
30.0
89.9
0.5%
62.1
6.0%
207.3
62.7%
o/w Corporate
6,960.6
89.6%
955.0
626.5
8.1%
172.2
183.7
2.4%
14.2
42.4
0.6%
27.4
4.4%
109.5
59.6%
o/w Retail
8,178.1
93.6%
1,323.3
410.3
4.7%
160.7
146.7
1.7%
15.7
45.1
0.6%
34.7
8.4%
97.5
66.5%
o/w State
3,766.7
100.0%
-2,161.4
0.0
0.0%
0.0
0.0
0.0%
0.0
2.3
0.1%
0.0
2.7%
0.0
80.3%
o/w Institutions
408.4
100.0%
-42.3
/
/
-0.3
0.2
0.0%
0.1
0.2
0.0%
/
/
0.2
100.0%
Figure 62: NLB Group corporate and retail loan portfolio by stages as at 31 December 2024

The portfolio quality remains stable, with increasing
Stage 1 exposures and a relatively low percentage
of NPLs. The acquisition of the SLS Group increased
Stage 1 exposure to the nonfinancial sector, increasing
corporate loans by EUR 404 million and retail
loans by EUR 562 million. Although the Stage 1 loan
portfolio percentage slightly decreased compared to
31 December 2023, it remains high at 93.6% in the retail
segment and 89.6% in the corporate segment.
6,006
6,961
454
169
626
184
5,920
426
200
6,855
250
131
8,178
410
147
6,423
193
128
Corporate
Retail
Corporate
Retail
Corporate
Retail
31 Dec 2022
31 Dec 2023
31 Dec 2024
+16% YoY
+19% YoY
+38% YoY
+64% YoY
+8% YoY
+12% YoY
Stage 1 by segment (in EUR millions)
Stage 2 by segment (in EUR millions)
Stage 3 by segment (in EUR millions)
Figure 63: NLB Group corporate and retail loan portfolio (in %) by interest rates as at 31 December 2024
The portfolio interest rate structure shows that 59.3%
of the Group corporate and retail loan portfolio is tied
to a fixed interest rate and the rest to a floating rate,
primarily the Euribor reference rate. Floating interest
rates dominate the corporate segment. In the retail
segment, 75.1% of the retail loan portfolio is linked to a
fixed interest rate, with the percentage rising to 75.8%
in the housing loan segment. This structure reduces the
sensitivity of the retail sector to potential changes in
reference rates.
31 Dec 2022
31 Dec 2023
31 Dec 2024
31 Dec 2022
31 Dec 2023
31 Dec 2024
31 Dec 2022
31 Dec 2023
31 Dec 2024
Fix
Float
Corporate (incl. SME)
Consumer
Housing
64%
36%
40%
60%
36%
64%
63%
37%
34%
66%
30%
70%
59%
41%
26%
74%
24%
76%

NLB Group
Annual Report 2024
105
Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
New NPLs formation and
NPL management
In 2024, NPL formation amounted to EUR 170 million or
0.8% of the total loan portfolio. In addition to normal
portfolio development, the new non-performing
loans reflect the macroeconomic circumstances and
the harmonisation of the default definition within the
acquired SLS Group companies. Despite this, the net
NPL increase during 2024 remained low, as evident in
the nearly unchanged NPL ratios. The Group’s credit
portfolio remains high quality due to cautious lending
standards and effective early warning systems.
2022
2023
2024
Corporate
SME
Retail
Formation /
gross loans
(stock)
51
70
7
127
43
76
118
77
93
170
0.7%
0.6%
0.8%
0
0
Figure 64: NLB Group gross NPL formation (in EUR millions)
In 2024, the Group established impairments and
provisions for credit risk of EUR 20.6 million. The
established impairments derive from portfolio
development mostly in the retail segment (Stage
2 and Stage 3 exposures), new financing, and any
deterioration in the portfolio. However, material
repayments of written-off receivables and changes in
models helped to mitigate the overall impact. As a result,
at year-end, the cost of risk was 14 bps, remaining at a
relatively low level. While macroeconomic conditions in
the region may continue to be influenced by factors such
as relatively high inflation, lower-than-expected GDP
growth, and rising unemployment, these developments
are unlikely to have a substantial negative impact on the
cost of risk.
-20.6
Changes in models/
risk parameters
Portfolio
development
Repayments of
written-off receivables
Net impairments
and provisions for
credit risk in 2024
24.9
-62.1
16.7
Release
Establishment
Figure 65: Cumulative net new impairments and provisions for credit risk in NLB Group (in EUR millions)

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Report
Precisely defined targets and various proactive workout
approaches have supported the management of the
non-performing portfolio. The Group’s approach to NPL
management puts a strong emphasis on restructuring
and the use of other active NPL management tools, such
as the foreclosure of collateral, the sale of claims, and
pledged assets. In 2024, the multi-year declining trend of
the non-performing credit portfolio stock stopped, as the
growth of new NPLs slightly exceeded repayments and
recovery of existing NPLs, mainly through repayments,
cured clients, and the collection. The acquisition of the
SLS Group, whose loans were recognised at fair value,
also contributed to the NPL increase at the end of Q3
2024. As a result, the non-performing credit portfolio
stock in the Group increased to EUR 330.5 million by
the end of 2024, up from EUR 300.5 million at the end of
2023. This slight increase in the non-performing credit
portfolio, combined with credit growth in a higher-
quality portfolio, resulted in an NPL ratio of 1.6%. The
internationally comparable NPE ratio, based on the EBA
methodology, stood at 1.1%. The Group’s indicator gross
NPL ratio, as defined by the EBA, was 2.0%.
1.5%
2.4%
1.8%
1.6%
31 Dec 2021
31 Dec 2022
31 Dec 2023
31 Dec 2024
NPLs
NPL ratio
Coverage ratio 1
Coverage ratio 2
Collateral coverage
58.1%
57.1%
57.9%
367
328
301
330
55.9%
61.7%
61.0%
62.7%
64.6%
86.1%
98.9%
108.7%
110.0%
Figure 66: NLB Group NPL, NPL ratio, NPL collateral coverage and coverage ratio(i)
An important strength of the Group is its NPL coverage
ratio 1 (coverage of gross NPLs with impairments for all
loans), which remains high at 108.7. Furthermore, the
Group’s NPL coverage ratio 2 (coverage of gross NPLs
with impairments for NPL) stands at 62.7%, well above
the EU average published by the EBA (41.2% for Q4
2024). This strong coverage provides the Group with the
capacity to further reduce NPLs without significantly
impacting the cost of risk in the coming years.
The Group strives to ensure the best possible collateral
for long-term loans, typically in the form of mortgages.
Thus, the real-estate mortgage is the most common type
of collateral for corporate and retail loans. In corporate
loans, government and corporate guarantees are also
common types of collateral.
Through extensive experience gained over the past few
years in managing clients facing financial difficulties –
resulting primarily from legacy portfolios – the Group has
developed an extensive knowledge base. This expertise
encompasses both the prevention of financial difficulties
for clients to restructure viable clients in case of need and
to efficiently manage exposures with no realistic recovery
prospects. This extensive knowledge base is accessible
4
1
4
Slovenia
50%
Other
8%
Kosovo
5%
N. Macedonia
11%
BiH
7%
Montenegro
9%
Serbia
9%
Slovenia
Serbia
N. Macedonia
Montenegro
BiH
Kosovo
Other
54
30
83
166
9
16
29
12
13
11
37
21
9
31
9
7
6
22
6
6
17
7
13
8
28
No delays(i)
D rating
E rating
Figure 67: NLB Group NPL by geography as at 31 December 2024
(i) Considering materiality of delays, namely 2% or EUR 50 thousand.
(i) By internal definition.

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across the Group. Risk units, along with restructuring and
workout teams, are adequately staffed and equipped to
handle considerably increased volumes, if needed, in a
professional and efficient manner.
Low market risk in the
trading book
Regarding market risks in the trading book, the Group
maintains a low-risk appetite. The exposure to trading (as
defined by the CRR) is permitted only for the parent Bank,
as the main entity of the Group, and is highly limited.
The Group carries its main business activities in euros,
and the subsidiary banks, in addition to their domestic
currencies, also operate in euros, the Group’s reporting
currency. The Group’s net open FX position from
transactional risk is low, at 0.7% of capital. Regarding
structural FX positions on a consolidated level, assets
and liabilities held in foreign operations are converted
into euro currency at the closing FX rate on the balance
sheet date. FX differences in non-euro assets and
liabilities are recognised in the other comprehensive
income, impacting shareholder’s equity and CET1 capital.
Proactive management
of interest rate risk in the
banking book
The Group follows a strategy of maintaining a low
Economic Value of Equity (EVE) indicator while
simultaneously monitoring the effects on Earnings at
Risk (EaR). Bonds and loans with a fixed interest rate
contribute the most to the interest rate risk exposure in
terms of the Economic Value of Equity (EVE) indicator. In
contrast, exposure is primarily managed through core
deposits, which present the most important and material
element of interest rate risk management. To a lesser
extent, the Group also uses plain vanilla derivatives to
hedge risk.
The exposure to interest rate risk remains modest
and within the Group’s risk appetite limits. The Group
applies different scenarios when assessing the EVE
sensitivity. In 2024, the Group continued to enhance the
measuring of interest rate risk according to the new EBA
Guidelines, which impacted the EVE result. From the EVE
perspective, the estimated capital sensitivity of the worst
regulatory scenario (parallel up +200 bps) is 5.0% of the
Group’s T1 capital.
Robust operational risk
management
In operational risk management, the Group has
established a robust operational risk culture. The main
qualitative activities focus on reporting loss events and
identifying, assessing, and managing operational risks.
Based on this, continuous improvements are made
to control activities, processes, and the organisation.
Additionally, the Group also focuses on proactive
mitigation, prevention, and minimisation of potential
damage. Special attention is given to the stress-testing
system, based on a scenario analysis referring to the
potentially high severity, low-frequency events and
modelling data on loss events. The Bank uses the
gamma distribution technique for modelling, which
proved to be the most suitable. From an economic
perspective, the aim is to ensure the necessary capital
for materially important risks that could occur extremely
rarely. Consequently, data on realised loss events are
used with a confidence interval of 99.9%. Moreover,
some add-ons are added for specific current and
significant risks. In a normative view, a 90% confidence
level is used for more plausible but still severe events,
which would be absorbed through P&L.
In NLB Group, the reported incurred net loss arising
from loss events in 2024 was lower than in the previous
year, and remained within the set tolerance limits for
operational risk. Certain litigation costs mainly occurred
due to systemic issues such as litigation risk (e.g., cases
related to loan processing fees and loan insurance
premiums in Serbia). For other realised operational
losses, banking members of the Group conducted
a comprehensive analysis and defined adequate
mitigation measures to prevent or minimise such events
in the future.
In addition to losses already included in the loss
event database, the Bank could face one-off and
unpredictable extreme events. The list of such potential
events is updated annually, based on current risks in
the Bank’s environment or past realised events in the
banking industry. For these potential and topical events,
scenario analyses are prepared. The cyber-attack
scenario as an umbrella scenario was further divided
into five more detailed scenarios to address different
types of attacks. The results indicate that the most
significant loss could arise from the following potential
events: possible difficulties operating electronic banking
channels, anti-money laundering, cyber-attacks, and
legal risks. For these scenarios, existent controls were
additionally revised and mitigation measures were
defined to address any potential deficiencies.
Furthermore, key risk indicators serve as an early
warning system for the broader field of operational
risks (such as HR, processes, systems, and external
conditions). They are regularly monitored, analysed, and
reported to improve the existing internal controls system
and enable timely reactions.
The Group supports proactive discussion of operational
risks at all levels of the organisation. Every employee
can report loss events. The most significant/important
operational risks are escalated quickly and discussed
at the Operational Risk Committee meeting, while the
implementation of the mitigation measures is closely
monitored.
In addition, the Group diligently manages other non-
financial risks, related to its business model or arising
from other external circumstances within the established
ICAAP process.
Incorporating ESG risks
The Group contributes to sustainable finance by
incorporating ESG risks into its business strategies, risk
management framework, and internal governance
arrangements. The Group integrates and manages
them within the established risk management
framework in credit, liquidity, market, and operational
risk. The management of ESG risks follows ECB
and EBA guidelines, following the tendency of their
comprehensive integration into all relevant processes.
The Group conducts a materiality assessment as part
of its overall risk identification process to determine
the level of transitional and physical risk to which the
Group is exposed. This process involves identifying
environmental risk factors, relevant transmission

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channels, and assessing their materiality and impact on
the Group’s financial performance over short-, mid-, and
long-term periods.
The management of ESG risks is incorporated into
the Group’s overall credit approval process and the
related credit portfolio management. Sustainable
financing is implemented in accordance with the Group’s
Environmental and Social Management System (ESMS).
In addition to addressing ESG risks at all relevant stages
of the credit-granting process, applicable ESG criteria
were also considered in the collateral evaluation process.
At the portfolio level, the Group does not face any
significant concentration in specific NACE industrial
sectors exposed to climate risk, with the role of
transitional risk being more prominent. Based on
the industry segmentation of the portfolio and
corresponding emissions, the Group has a relatively
low exposure to emission-intensive sectors within its
corporate clients’ businesses. As part of its strategy, the
Group does not finance companies involved in fossil
fuels extraction or operation of coal-fired power plants.
Moreover, as a member of the UN Net-Zero Banking
Alliance, the Bank pledged to align its lending and
investment portfolio with net-zero emissions by 2050. In
its initial round of NZBA targets, NLB Group has focused
on fossil fuel-based and highly energy-intensive sectors
(such as power generation and iron and steel) and
other sectors where the Bank has substantial emissions
and/or exposure and available data. These include
residential mortgages and commercial real estate.
Activities for setting a second round of NZBA targets for
sectors such as transport and agriculture are underway.
The Group carefully evaluates potential reputational
and liability risks that may arise from the sustainable
financing of its clients. Special attention is given to
approving new products and monitoring the fulfilment
of relevant criteria by the clients. Additional key risk
indicators have been established to serve as an early
warning system for ESG risks. Besides, physical risks,
as part of ESG risks in the area of operational risk, are
addressed through the Group’s business continuity
management (BCM). As such, BCM is carried out to
protect lives, goods, and reputation. Business continuity
plans included relevant ESG risks. They are prepared to
be used in the event of natural disasters, IT disruptions,
and the undesired effects of the environment to mitigate
their impact.
An internal ESG stress-testing framework was developed
to identify the most relevant financial vulnerabilities
stemming from transitional and physical climate risks.
This was further revised and enhanced by incorporating
disposable ESG-related data. The results of the climate
stress tests showed no material impacts on the Group’s
capital and liquidity positions. Further information on
risk management is available in the Financial Report
and the Sustainability Statement of this Annual Report
and Pillar 3 Disclosures.

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Annual Report 2024
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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
IT and Cyber Security
The Group remains committed to providing its clients with sustainable and efficient services supported by highly
reliable and secure technology platforms. The Bank is also advancing its technology transformation programme and
consolidating core banking systems. IT has made significant progress in the consolidation process at the Group level.
Additionally, the Bank has rolled out further group-wide business solutions, including the launch of a new web
portal, the implementation of a new eDMS, and the enhancement of digital channels across multiple group
members. To address the increased risk in cyber security, the Bank has prioritised investments in additional
resources and products to strengthen its overall cyber security resilience.
IT Strategy
The current IT Strategy 2020–2024 incorporating the
Group dimension covers the following:
IT Strategy 2025–2030
With the adoption and publication of the new Business
strategy 2030 (New Horizons) and the conclusion of the
current IT Strategy, work on the new IT Strategy for the
period of 2025–2030 is underway. The key elements of
the new IT Strategy are:
• transformation of IT to support the implementation of
the new Business Strategy;
• continue to implement agile ways of development to
ensure better deliverable and support for business;
• enhance architecture with a focus on cloud-native
solutions;
• future development and enhancement of information
and cyber security capabilities.
IT Infrastructure: Ensuring
reliability and resilience
Confirmed high performance with numbers
IT performance is monitored through a set of relevant
indicators that are linked to the Balanced Scorecard
(BSC) system. The indicators reflect the high
performance of IT operations and successful risk
management in this segment. With 99.95% IT system
availability and a very low 0.05% unplanned
interruptions, the Bank prioritises stability. In 2024, the
percentage of days without system/service interruptions
reached 80% (2023: 79%). Harmonised Service Level
Agreements (SLA) are in place with users of the
information system, which the Bank has managed to
fulfil to a very high degree. The Group members
recorded high IT operational performance (between
99.87% and 99.99%).
Main IT initiatives
Transformation with expanding group-wide
capabilities
The primary focus is to transform IT, covering the
organisation, group perspective, processes, people,
and technology. IT has supported a more agile way
of delivery to make a better partner to businesses,
resulting in higher efficiency. Specifically, a Group IT
domain concept was introduced that promotes shared
teams and IT solutions across the Group.
Group-wide capabilities are still expanding, and the
Group Competence Centre in Belgrade, Serbia, which
was transferred from the Bank to a separate IT service
company called "NLB DigIT," significantly supports
development on the Group level. The company is the
IT hub that supports Group members and spearheads
digital transformation projects. NLB DigIT’s primary
focus is to deliver services of a high level of quality
to Group entities in domains where IT resources and
expertise are scarce throughout the region. It mainly
provides services in key areas such as IT security
setup for all the banks, IT delivery, etc. NLB DigIT is
dedicated to the digital enablement and reliable IT
operations of NLB Group.
Vision
Build the best digital banking IT team in the SEE region.
Main principles
• Increase client satisfaction in all segments with a
new digital omnichannel platform, digitise client
journeys and interactions (CRM), and achieve
operational excellence.
• Have an effective IT architecture using cloud
solutions and open-source software where possible.
• Introduce a new way of agile development and
DevOps transformation, leading to shorter release
cycles, automated testing, and fewer manual tasks.
• Ensure the necessary development capacity.
• Introduce modern collaboration tools and digitise
internal processes.
• Ensure quality, security, and availability of IT systems
and applications.
• Have a highly motivated, effective, and satisfied IT
team working closely with the business side.
Mission
Enable the best client and employee experiences
through reliable, effective, secure, accessible, and
scalable IT solutions.
99. 95%
availability of IT systems
in NLB

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Change in our delivery approach
The IT team has made significant achievements in the
key strategic directions regarding solution delivery.
The new operational CRM solution was introduced in
Serbia, and the digital banking solution for retail in
Slovenia was enhanced with origination processes for
several products. A new retail and corporate web and
mobile banking solution was launched in Montenegro
(NLB Banka, Podgorica) and Bosnia and Herzegovina
(NLB Banka, Sarajevo and NLB Banka, Banja Luka).
Additionally, the IT team made progress in reducing
reliance on the mainframe and migrated the next set of
applications from the mainframe to distributed systems.
Various enhancements have been implemented across
the Group, including digitalising the KYC process,
automating back-office processes, and digitalising
paper documents.
Core systems consolidation
IT has followed the core banking system strategy, and
the consolidation of core banking systems is in progress.
Following the N Banka integration in Slovenia and
the first migration associated with it, IT has continued
working on consolidation into the target core system.
Key achievements include the migration of the term
deposit portfolio and the successful launch of term
deposit origination in the target system.
Enterprise and application architecture
Enterprise architecture focuses on ensuring new
solutions (focusing on Group standard solutions) adhere
to Group standards and associated Group roadmaps.
The introduction of standard components provides API-
first and event-driven integration capabilities to ensure
the integrability of the new platforms and solutions.
New Group platforms have been selected for electronic
archiving, document management, data governance
and data quality, and the ERP system.
The implementation of the standardised enterprise
architecture tool is ongoing, ensuring all data is
populated to simplify application portfolio management,
mitigate software obsolescence, enhance IT risk
management, and support compliance with the Digital
Operational Resilience Act (DORA) requirements.
Data management
The Bank continues to pursue its mission of becoming a
data-driven organisation through a series of initiatives.
The aim is to make necessary data and reports
readily accessible across the Group to foster the use
of data and analytics in daily operations and strategic
decision-making.
The Group addresses data management throughout
its entire life cycle through data governance policies
and tools, necessary frameworks, as well as setting
modern technological foundations across the Group
(EDWH, advanced analytics, risk management analytics,
profitability, and consolidated Group regulatory
reporting). Special focus is placed on defining the
Group-wide GenAI strategy and delivery model to
ensure GenAI becomes an integral part of day-to-day
business at all Bank levels.
Outlook
In the coming years, the Bank will remain committed to
investing in newly adopted technologies crucial for
supporting the business strategy, especially in digital,
data, Cloud, and customer relationship management.
The aim is to consolidate the Group’s infrastructure and
to endorse the Cloud as a key enabler, simplify core
systems, and elevate the client experience in terms of
quality, innovation, reliability, and security.
Digital transition
The Group is advancing its digitalisation efforts by
leveraging cutting-edge information technology
tools to boost efficiency and deliver more innovative,
personalised, accurate, and timely client services. With
the increase in smartphone usage, the Group aims to
transition more customers to alternative distribution
channels. Committed to developing a comprehensive
suite of 24/7 digital solutions, the Group seeks to
bring clients closer by offering anchor products and
accessible, personalised digital services. The primary
objective is to promote digital banking adoption among
active customers.
Figure 68: Digital users and penetration(i) of the Group banks as at 31 December 2024
(i) Share of active digital users in # of active clients.
NLB,
Ljubljana
NLB KB,
Beograd
NLB Banka,
Skopje
NLB Banka,
Banja Luka
NLB Banka,
Sarajevo
NLB Banka,
Prishtina
NLB Banka,
Podgorica
464,849
43,265
238,067
38,349
85,141
346,594
78,775
Active digital users
Active users penetration
63.8%
32.6%
50.5%
40.4%
32.6%
32.4%
39.9%
More than
1. 8 million
digital users in the Group

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NLB Group Key Members
Risk Management
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Report
Cyber security*
Strengthening the team and implementing new
solutions
The Group focuses on cyber security, ensuring the
confidentiality, integrity, and availability of data,
information, and IT systems that support clients’ banking
services and products. Cyber security within the Group is
constantly tested and upgraded through security
assessments, independent reviews, and penetration
testing. It is also regularly discussed at the Bank’s
Information Security Steering Committee, Operational
Risk Committee, and Management Board meetings.
In 2024, the main focus was the DORA regulation and
establishing Group IT Security Operations. This will
lead to appropriate segregation of duties and faster
delivery in the cyber security segment. The IT Security
Operations team has been established with seven FTEs,
while the rest of the Group IT Security team consists of
31 staff members. To fulfil all requirements, the Group
IT Security team has created or updated 10 Group
Guidelines and/or Policies in collaboration with all
relevant stakeholders. Bank members have reached
approximately 80% of CIS v8 requirements, marking a
significant increase compared to the previous year.
Management continues to strongly support security
functions and investments in the security area. In
2024, following Cloud’s first strategy, OPEX slightly
increased compared to previous years and ended with
approximately EUR 4 million, while CAPEX remained at
the same level. To achieve the defined goals in terms of
optimisation and orchestration, the Group IT Security
team has delivered tools to consolidate the network
security domain. To improve clients’ satisfaction, the
Group selected an anti-fraud solution and immediately
began its implementation. The main focus will also
remain on improving the monitoring and response
segment in line with best practices. Further information
on cyber security is available in the chapter Compliance
and Integrity.
Continuous employee education and information
exchange
All employees in the Group are continuously educated
about the importance of information/cyber security,
as well as social engineering techniques. The banks
in the Group provide employees and customers with
security notifications, especially regarding threats in
the (global) environment with potential impact on the
banks’ IT systems, services, products, and clients. The
Bank also tests the awareness of its employees with
social engineering attack simulations. Threat intelligence
data is shared by the Group team, where all Group
members provide information on the latest threats and
recommendations on mitigation measures. In conjunction
with routine phishing simulations, the Group Cyber
Security team has deployed its proprietary phishing
platform and effectively executed simulated internal
employee phishing tests across all Group members.
Strengthening the team
and extra investments in
cyber
security
* Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter Cybersecurity, subchapter Key activities and progress - only the first, second, and fourth paragraph.

Each expert in our field
cultivates knowledge and
growth across the entire
financial sector.
We constantly invest in
the development of our
employees. In 2024, a NLB
Group banking employee
received an average of
7. 7 days or 46. 2 hours of
training, mostly in the
fields of banking, personal
development, generative
AI, data analytics and ESG.
All these programmes
are carefully selected
and provided by NLB's
Education Centre with more
than 50 years of experience.

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Human Resources
As a frontrunner in the region, the Group is further striving to embed modern people practices into the everyday
focus of Human Resource Management activities. The new Group HR Strategy, a joint creation, sets high standards
and aims to support the business strategy in the future.
The Group continues to invest in its employees, focusing on their development and expertise, and creating a modern
and healthy workplace that promotes everyone’s well-being. Recognising that engaged employees are pivotal to
achieving business goals and driving successful outcomes, the Group will make further investments in leadership
development and empowerment. Employees play a key role in transferring good practices and improving
organisational culture and employee experience. Additionally, the Group is nurturing a new generation of talents
for the future, aiming to provide them with on-the-job training by being part of strategic projects.
Employee headcount
The Group continues optimising processes and
transitioning to digital banking through transparent and
sustainable workforce planning, including a review of
the skills and competencies needed.
Table 36: NLB Group headcount by countries
Country
31 Dec 2024
31 Dec 2023
Change YoY
Slovenia
2,856
2,689
167
Serbia
2,515
2,480
35
BiH
1,025
990
35
N. Macedonia
995
962
33
Kosovo
478
468
10
Montenegro
410
390
20
Croatia
41
1
40
Germany
0
0
0
Switzerland
2
2
0
Group Total
8,322
7,982
340
Employer of choice
The Group’s Human Resource teams work as one,
continuously sharing best practices and introducing
novelties to their workplaces by following trends. These
efforts contribute to a stimulating work environment and
the well-being of employees.
A testament to this excellence is the Top Employer
Certificate. In 2025, NLB received the Slovenia Top
Employer recognition for the 10th consecutive year.
Additionally, NLB Komercijalna Banka, Beograd
earned its first certification, reflecting dedication to
extending excellent and proven HR practices across the
Group. This achievement, confirmed by Top Employer
Institute, demonstrates the high level of expertise
and contribution in people strategy, leadership,
digitalisation, talent acquisition and development,
performance management, sustainability, and more.
The Bank will continue to adopt new practices and
adapt to workplace trends. The mission is to become
the best employer in the region within the banking and
financial services sector.
A long tradition of learning
and development:
50 years of the NLB
Education Centre
In 2024, the NLB Education Centre celebrated its
50-years anniversary. Located in Slovenia, the
Education Centre was the first in the region to create,
deliver, and maintain vital knowledge of banking and
finances and is now a treasurer of valuable knowledge
libraries for the entire NLB Group. In the last decade,
it has been modernised and digitalised, becoming the
central conductor of the Group’s education, training, and
development. Besides delivering core banking/financial
skills, necessary competencies (leadership, change
management, and communication) and obligatory
training, the main role of the Education Centre today
is to follow trends in the market and to predict vital
skills and competencies that will have an impact on the
Group’s future and support knowledge accumulation
that supports the changing business environment.
In 2024, special focus across the Group was given to
upskilling existing employees in generative AI, data
analytics, the Microsoft 365 environment, and ESG
topics, among other areas. The Education Centre is also
a central point of support for all new group initiatives,
such as educating competency communities, rolling out
and building awareness of new technologies, AI, and
automation tools.
Retaining recognition as
"Top
Employer"
On average,
employees spent
7. 7 days
on training activities

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All Group members incorporated the philosophy of
utilising well-established training and development
programmes, as well as maintaining awareness of the
learning culture. Employees have embraced the value
and are proactive in self-managed learning, using the
Udemy platform, which offers over 7,000 trainings that
are open to anyone. One of the Group’s core values is
developing people, and endeavours will continue in the
direction of upskilling and reskilling, as well as
introducing new knowledge and skills for the future.
Investing in people drives
all-time high engagement
Talent cultivation
The Group has entered a new generation of talent
development, recognising and developing employees in
leadership, professionalism, and youth potential. Talents
received thorough feedback based on assessment and
individual development conversations regarding their
strengths and career aspirations. The latest generation
of talent across the Group has been successfully
deployed and promoted, with a talent retention rate of
more than 90%.
Developing NLB employer brand
The Group continued to strengthen its employer brand
regionally through various internal and external
activities. As a caring mentor, the Bank cooperates with
multiple regional universities, offering scholarships
and career opportunities to young talents. It also
invites internal ambassadors to promote and share
recommendations for employment, offers various
benefits to employees and introduces continuous
improvements to its processes.
Employee well-being & health
Employee well-being is becoming a vital part of people
management. The Bank has introduced anonymous
psychological support services and offers a range of
additional benefits, including those under the Family
Friendly certificates.
In 2024, the Bank continued to raise awareness about
employee well-being by addressing various topics,
including stress management, healthy habits, mental
well-being, mindfulness, personal energy, and effective
communication. Various programmes run regionally
under the Healthy Bank programme and the Family
Friendly certificate. The Bank also provides anonymous
psychological support via external institutions and
several health-focused prevention programmes.
The Bank organised a Group-wide "Sustainability
Festival," celebrating environmental awareness and eco-
friendly practices, featuring engaging activities, insightful
workshops, and showcases of sustainable initiatives.
The Bank’s value, "Improving Lives" is also manifested
in offering work-from-home flexibility where possible
to ensure a healthy work-life balance for its employees.
By end of 2024, almost all countries were offering the
possibility to work from home, only in Slovenia around
30% of employees had this possibility.
Employee engagement
The Bank’s constant focus is recognising the importance
of engaged and motivated employees. The 2024
employee engagement results show an all-time high
employee engagement score, with 54% engaged
employees and so the lowest-ever percentage of
disengaged employees. The employer Net Promoter
Score (26) also proves that employees are the Bank’s
best ambassadors. The Bank will continue to enhance
employee engagement by implementing results-based
activities and interventions, constructive dialogue, and
employee listening.
Figure 69: NLB Group Employee Engagement comparison
8,322
employees in the
Group family
Engaged
Not engaged
Actively disengaged
2023
2024
54%
36%
10%
50%
37%
13%
Employer Net Promoter
Score
26

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Corporate Governance
Corporate governance of the Bank is based on legislation in the RoS, particularly (but not exclusively) the provisions
of the Companies Act (ZGD-1) and the Banking Act (ZBan-3), the Decision of the BoS on Internal Governance,
Management Body, Adequate Internal Capital Assessment Procedure for Banks and Savings Banks, relevant
EBA Guidelines on internal governance, EBA Guidelines on the assessment of the suitability of members of the
management body and key function holders, EBA Guidelines on prudent remuneration, relevant EU regulations
regarding sustainability issues and other applicable RoS and EU regulations.
Apart from a binding legal framework, the Bank
complies with the Slovenian Corporate Governance
Code for Listed Companies. The mentioned Code
stipulates governance, management, and leadership
principles based on the "comply or explain" principle
for companies listed on the Ljubljana Stock Exchange.
Deviations from the recommendations of this Code are
published in the NLB Group Annual Report in the section
Corporate Governance Statement of NLB. This statement
is prepared in accordance with Article 70 (Paragraph 6)
of the Companies Act (ZGD-1). The previously mentioned
statement is also published on the Bank’s website.
Rules and procedures
The Bank’s Corporate Governance includes processes
through which Bank objectives are set and pursued
(directed and controlled). Lately, it has become an
efficient way to channel investor-driven initiatives
related to sustainability. Corporate governance
principles identify the distribution of rights and
responsibilities among different stakeholders in
the Bank (the Management Board of NLB d.d. and
Supervisory Board of NLB d.d., shareholders, investors,
creditors, auditor, regulators, and other stakeholders)
and include the rules and procedures for decision-
making in corporate affairs. The most important rules
and procedures are:
Articles of Association of NLB d. d.
NLB operates under a two-tier governance system, as
defined by the Banking Act (ZBan-3) and Companies Act
(ZGD-1). The Management Board manages the Bank’s
operations, and the Supervisory Board provides for
control and supervision of the Management Board’s
work. Shareholders exercise their rights at General
Meetings of Shareholders. For more information, refer to
the Bank’s website, Corporate Governance.
Corporate Governance Policy
of the NLB and NLB Group
Governance Policy
The Corporate Governance Policy of NLB, which is
the corporate governance framework of the Bank, is
drawn up jointly by the Management and Supervisory
Boards of the Bank. In this Policy, the Management and
Supervisory Boards publicly disclose commitments to
shareholders, clients, creditors, employees, and other
stakeholders as a whole and explain how the Bank is
managed and supervised, as well as adopt decisions
on which corporate governance code the Bank
follows, outlined on the Bank’s website. The Corporate
Governance Policy of NLB should be read together with
the NLB Group Governance Policy, in which the corporate
governance principles and mechanisms of the Group
members (NLB excluded) are defined and governed.
NLB Group Code of Conduct
In the NLB Group Code of Conduct, the values, mission,
and core principles of conduct are defined together with
a set of guidelines to which the Group is committed. The
Code describes the values and basic principles of ethical
business conduct that the Group respects, promotes,
and expects to be followed by the whole Group.
Operating with integrity and responsibility is key to the
Group’s corporate culture. The Code demands that
every employee, regardless of their job or location of
work, and every other stakeholder of the Group comply
with the highest standards of integrity.

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The Bank’s governing
bodies
The Bank’s corporate governance is based on a two-tier
system in which the Management Board manages the
Bank’s daily operations, and the Supervisory Board
controls and supervises the Management Board’s work.
The General Meeting of
Shareholders
The shareholders exercise their rights related to
the Bank’s operations at the General Meetings of
the NLB. Decisions adopted by the General Meeting
of shareholders of NLB d. d. include, among others,
adopting and amending the Articles of Association
of the NLB d. d. , use of distributable profit, granting
a discharge from liability to the members of the
Management and Supervisory Boards, changes to
the Bank’s share capital, appointing and discharging
members of the Supervisory Board who represent
the shareholders’ interests, remuneration and profit-
sharing by the members of the Supervisory and
Management Boards and employees, annual schedules,
and characteristics of issues of securities convertible
into shares and equity securities of the Bank.
On the 42nd General Meeting dated 17 June 2024,
shareholders took note of the adopted NLB Group Annual
Report 2023 and adopted the Report of the Supervisory
Board on the results of the examination of the NLB Group
Annual Report 2023. They also adopted the Report on
Remuneration for the members of the Management Body
of NLB d.d. in the 2023 Business Year and the Additional
Information to the Report on Remuneration in the 2023
Business Year on the basis of SSH’s Baselines and the
Internal Audit Report for 2023, adopted decisions on
election of the Supervisory Board members members (as
mentioned below).
The General Meeting also adopted decisions on the
allocation of distributable profit for 2023 and the first
tranche of a dividend payout, granted a discharge
from liability to the members of the Management and
Supervisory Boards, and considered the changes to the
Remuneration Policy for the members of the Supervisory
Board of NLB d.d. and Management Board of NLB d.d.
On the 43rd General Meeting of shareholders held on
9 December 2024, the shareholders approved the
payment of the second tranche of the dividend payout. In
2024, two tranches of dividends totalling EUR 220 million,
derived from the profits generated in 2023, were paid out,
representing a 100% increase compared to the previous
year. More information on dividends is available in
subchapter Capital and capital adequacy in chapter
Funding Strategy, MREL Compliance, and Capital.
More information on the work of the General Meeting
of the Shareholders activities is available in the chapter
Corporate Governance Statement of NLB and on the
Bank’s website.
General Meeting of Shareholders
Supervisory Board
Management Board

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The Supervisory Board*
According to the Articles of Association of the NLB d. d. , the Supervisory Board of NLB consists of 12 members, of
which eight represent the interests of shareholders, and four represent the interests of employees. Members of the
Supervisory Board representing the interests of shareholders are elected and recalled by the General Meeting from
persons proposed by shareholders or by the Supervisory Board. Members of the Supervisory Board representing
the interests of employees are selected and placed by the Workers' Council of NLB d. d. , considering the conditions
for members of the Supervisory Board laid down in the regulations and the Articles of Association of NLB d. d.
As at 31 December 2024:
At the beginning of 2024, the composition of the
Supervisory Board was as follows: Primož Karpe –
Chairman; Shrenik Dhirajlal Davda – Deputy Chairman;
David Eric Simon, Verica Trstenjak, Islam Osama Zekry,
Mark William Lane Richards, Cvetka Selšek, André-Marc
Prudent-Toccanier (shareholders’ representatives); and
Sergeja Kočar and Tadeja Žbontar Rems (employee
representatives).
As the mandates of Primož Karpe, David Eric Simon,
and Verica Trstenjak expired in 2024, three members
were proposed for election at the forthcoming General
Meeting of Shareholders in June 2024. At the meeting, the
General Meeting re-elected Primož Karpe as a member
of Supervisory Board. It also elected two new members:
Natalia Olegovna Ansell, a seasoned banker with global
experience and detailed knowledge of all technical
aspects of corporate banking, retail banking, wealth
management, and above all, of payment and card
systems; and Luka Vesnaver, Chairman of the Board of
Directors of the British-Slovenian Chamber of Commerce
who has vast knowledge and experience in the field of
corporate finance in the region. Luka Vesnaver began
his term as a member of the Supervisory Board on
30 September 2024, while Natalia Olegovna Ansell
began her term on 8 November 2024 (both following
ECB’s decision not to object to their appointments).
Primož Karpe was elected the Chairman of the
Supervisory Board on 7 July 2024 for the third consecutive
term. The Supervisory Board also consists of: Deputy
Chairman Shrenik Dhirajlal Davda, Islam Osama Zekry,
André-Marc Prudent-Toccanier, Mark William Lane
Richards, Cvetka Selšek; and employee representatives
Tadeja Žbontar Rems (whose mandate expires by the
end of regular annual General Meeting in 2025) and
Sergeja Kočar (re-appointed in 2024 by the NLB Workers’
Council for another term). The mandate of Islam Osama
Zekry expires in 2025, while the mandates of Shrenik
Dhirajlal Davda, Mark William Lane Richards, Cvetka
Selšek and André-Marc Prudent-Toccanier expire in 2027.
Number of members:
10 4
eight are
shareholders’
representatives,
while two are
employees’
representatives
out of 10
members were
female (40%)
Diversity:
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.

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As at 31 December 2024, the Supervisory Board had the following members:*
Representatives of Capital
Primož Karpe, MSc
Chairman
Term of office: 2016–2020,
2020–2024, renewed term 2024–2028
Shrenik Dhirajlal Davda, MBA
Deputy Chairman
Term of office: 2019–2023,
renewed term 2023–2027
Luka Vesnaver, MSc
Member
Term of office: 2024–2028
Islam Osama Zekry, PhD
Member
Term of office: 2021–2025
Link to CV
Link to CV
Link to CV
Link to CV
Membership in
NLB Supervisory Board committees:
• Nomination Committee (Chairman)
• Audit Committee (Member)
• Operations and IT
Committee (Member)
Membership in
NLB Supervisory Board committees:
• Remuneration Committee
(Chairman)
• Risk Committee (Member)
• Nomination Committee (Member)
Membership in
NLB Supervisory Board committees:
• Audit Committee (Member)
• Risk Committee (Member)
Membership in
NLB Supervisory Board committees:
• Operations and IT Committee
(Deputy Chairman)
• Nomination Committee (Member)
• Remuneration Committee (Member)
Membership in management bodies
of related or unrelated companies:
• Angler d.o.o., Zagreb – Director
Membership in management bodies
of related or unrelated companies:
• Charity Commission of England
and Wales – Commissioner
and Board Member
• IPSO, UK – Lay Member
of the Board
Membership in management bodies
of related or unrelated companies:
• British Slovenian Chamber
of Commerce – President of
the Management Board
• Managers’ Association of
Slovenia – Member
• Alpine Ski Club Olimpija,
Ljubljana – President
Membership in management bodies
of related or unrelated companies:
• Commercial International Bank,
Egypt – Group Chief Financial
Officer and Board Member
• CIB Housing association –
President of the Supervisory Board
André-Marc Prudent-Toccanier, MSc
Member
Term of office: 2023–2027
Mark William Lane Richards, MSc
Member
Term of office: 2019–2023,
renewed term 2023-2027
Cvetka Selšek
Member
Term of office: 2023–2027
Natalia Olegovna Ansell
Member
Term of office: 2024-2028
Link to CV
Link to CV
Link to CV
Link to CV
Membership in
NLB Supervisory Board committees:
• Risk Committee (Chairman)
• Audit Committee (Deputy Chairman)
• Remuneration Committee (Member)
Membership in
NLB Supervisory Board committees:
• Operations and IT
Committee (Chairman)
• Remuneration Committee
(Deputy Chairman)
• Nomination Committee
(Deputy Chairman)
Membership in
NLB Supervisory Board committees:
• Audit Committee (Chairwoman)
• Risk Committee
(Deputy Chairwoman)
Membership in
NLB Supervisory Board committees:
• Operations and IT
Committee (Member)
• Risk Committee (Member)
Membership in management bodies
of related or unrelated companies:
• None
Membership in management bodies
of related or unrelated companies:
• VenCap International plc, UK
– Chairman
• Berry Palmer & Lyle Ltd. (BPL Global)
(Lloyds of London Insurance
Broker) – Non-Executive Director
• Enza Group Global, Cairo
– Chairman
Membership in management bodies
of related or unrelated companies:
• Managers’ Association of Slovenia –
Member of the Honourable Tribunal
Membership in management bodies
of related or unrelated companies:
• Equity Bank Kenya Limited,
Nairobi – Member of the Board
Further information about the work and composition of the Supervisory Board is available in the chapter Corporate Governance Statement of NLB.
Representative
of Employees
Tadeja Žbontar Rems, MSc
Member
Term of office: 2021–2025
Link to CV
Membership in
NLB Supervisory Board committees:
• Operations and IT
Committee (Member)
• Audit Committee (Member)
Membership in management bodies
of related or unrelated companies:
• None
Sergeja Kočar, MSc
Member
Term of office: 2020–2024,
renewed term 2024–2028
Link to CV
Membership in
NLB Supervisory Board committees:
• Nomination Committee (Member)
• Remuneration Committee (Member)
Membership in management bodies
of related or unrelated companies:
• None
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.

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Committees of the
Supervisory Board
The Supervisory Board appoints committees that
prepare proposals for resolutions passed by the
Supervisory Board, ensures their implementation, and
performs other expert tasks. The Bank’s Supervisory
Board has five collective decision-making and
advisory committees.
Audit Committee
Risk Committee
Nomination
Committee
Remuneration
Committee
Operations and
Information
Technology (IT)
Committee
Cvetka Selšek,
Chairwoman
(from 9 September
2024)
André-Marc
Prudent-Toccanier,
Chairman
Primož Karpe,
Chairman
Shrenik Dhirajlal
Davda,
Chairman
Mark William Lane
Richards,
Chairman
David Eric Simon,
Chairman
(until 17 June 2024)
Cvetka Selšek,
Deputy Chairwoman
Mark William Lane
Richards,
Deputy Chairman
Mark William Lane
Richards,
Deputy Chairman
Islam Osama Zekry,
Deputy Chairman
Cvetka Selšek,
Deputy Chairwoman
(until 9 September
2024)
Shrenik Dhirajlal
Davda,
Member
Sergeja Kočar,
Member
Islam Osama Zekry,
Member
(from 9 September
2024)
Primož Karpe,
Member
André-Marc
Prudent-Toccanier,
Deputy Chairman
(from 9 September
2024)
Luka Vesnaver,
Member
(from 30 September
2024)
Islam Osama Zekry,
Member
Sergeja Kočar,
Member
Tadeja Žbontar
Rems,
Member
Primož Karpe,
Member
Natalia Olegovna
Ansell,
Member
(from 8 November
2024)
Shrenik Dhirajlal
Davda,
Member
(from 9 September
2024)
André-Marc
Prudent-Toccanier,
Member
(from 9 September
2024)
Natalia Olegovna
Ansell,
Member
(from 8 November
2024)
Tadeja Žbontar
Rems,
Member
(from 9 September
2024)
Islam Osama Zekry,
Member
(until 9 September
2024)
Verica Trstenjak,
Member
(until 17 June 2024)
Verica Trstenjak,
Member
(until 17 June 2024)
André-Marc
Prudent-Toccanier,
Member
(until 9 September
2024)
Luka Vesnaver,
Member
(from 30 September
2024)
David Eric Simon,
Member
(until 17 June 2024)
Tadeja Žbontar
Rems,
Member
(until 9 September
2024)
Shrenik Dhirajlal
Davda,
Member
(until 9 September
2024)

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The Management Board*
According to the Articles of Association of the NLB
d. d. , the Management Board consists of three
to seven members (the president and up to six
members) that are appointed and dismissed by the
Supervisory Board. The president and members of the
Management Board are appointed to a five-year term
of office and may be re-appointed or dismissed early
by the law and Articles of Association of the NLB d. d.
As at 31 December 2024:
The composition of the Management Board has
remained unchanged since May 2022. It is as follows:
Blaž Brodnjak as President & CEO; and the following
members: Archibald Kremser as Chief Financial Officer
(CFO); Peter Andreas Burkhardt as Chief Risk Officer
(CRO); Hedvika Usenik as Chief Marketing Officer
(CMO), who is responsible for Retail Banking and
Private Banking; Antonio Argir who is responsible for
Group governance, payments, and innovations; and
Andrej Lasič as CMO, who is responsible for Corporate
and Investment Banking. The mandates of President
Blaž Brodnjak, and members Archibald Kremser, and
Peter Andreas Burkhardt expire in July 2026, while the
mandates of Hedvika Usenik, Antonio Argir, and Andrej
Lasič expire in April 2027.
Number of members:
6 5
members
-year term
of office
Mandate:
Blaž Brodnjak
CEO (since 2016)
Term of office: 2012–2016, 2016–2021,
renewed term 2021–2026
Peter Andreas Burkhardt
CRO
Term of office:
2013–2016, 2016–2021,
renewed term 2021–2026
Archibald Kremser
CFO
Term of office:
2013–2016, 2016–2021,
renewed term 2021–2026
Deputy CEO (since 2023)
Link to CV
Link to CV
Link to CV
Other important functions
and achievements:
• More than 24 years of experience
in managerial positions on all levels
of international banking groups.
• Was a chairman or member
of the supervisory boards of
13 commercial banks in six
countries, three insurance
companies in three countries,
a leading asset management
company in Slovenia, and a
multinational production group.
Other important functions
and achievements:
• More than 23 years of
experience in banking,
especially in Central Europe.
• Member or Chairman of Supervisory
Boards of several banks in the
Group from 2013 until present.
Other important functions
and achievements:
• More than 24 years of experience
in the financial services industry in
Austria, CEE, and SEE, focusing on
finance and asset management,
strategy and corporate
development, and performance
improvement assignments.
Direct responsibility:
• Strategy and Business Development
• Legal and Secretariat
• Brand and Communication
• Human Resources and
Organisation Development
• Internal Audit
• Compliance and Integrity
Direct responsibility:
• Global Risk
• Credit Risk – Corporate
• Credit Risk – Retail
• Workout and Legal Support
• Restructuring
• Evaluation and Control
• Financial Instruments Processing
• Corporate Clients Review and
Account Products Delivery
• Corporate Loans and
Trade Finance Delivery
• Retail Banking Processing
Direct responsibility:
• Financial Accounting
and Administration
• Controlling
• Financial Markets
• Group Real Estate Management
• Investor Relations
• IT Delivery
• IT Infrastructure
• Data and Artificial
Intelligence Governance
• IT Governance and Architecture
• Business Intelligence and Analytics
• Procurement
Membership in management or
supervisory bodies of related
or unrelated companies:
• Chairman of the Supervisory
Board of NLB Banka, Skopje
• Chairman of the Supervisory
Board of Summit Leasing
Slovenija, Ljubljana
• President of the Supervisory Board
of Bank Association of Slovenia
• Member of the Board of Directors of
Basketball Club Cedevita Olimpija
Membership in management or
supervisory bodies of related
or unrelated companies:
• Chairman of the Supervisory
Board of NLB Banka, Banja Luka
• Chairman of the Supervisory
Board of NLB Banka, Sarajevo
• Chairman of the Supervisory Board
of NLB Lease&Go, leasing, Ljubljana
Membership in management or
supervisory bodies of related
or unrelated companies:
• Chairman of the Board of
Directors of NLB Komercijalna
Banka, Beograd
As at 31 December 2024, the composition of the Management Board was as follows:
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.

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Antonio Argir
Responsible for Group governance,
payments, and innovations
Term of office: 2022–2027
Andrej Lasič
CMO (responsible for Corporate
and Investment Banking)
Term of office: 2022–2027
Hedvika Usenik
CMO (responsible for Retail
Banking and Private Banking)
Term of office: 2022–2027
Link to CV
Link to CV
Link to CV
Other important functions
and achievements:
• Under the management of Antonio
Argir, NLB Banka, Skopje marked
exceptional growth in all segments
of its operations and was perceived
as the most innovative bank on the
market, with a significant increase
in the bank’s profitability and
share price increasing fivefold.
Other important functions
and achievements:
• Over 27 years of experience in
corporate and investment banking
in international banking groups.
Other important functions
and achievements:
• Over 22 years of experience in
international banking groups,
thereof more than 18 years of
managerial experience.
Direct responsibility:
• Group Steering
• Cash Processing
• Payments Processing
• Payments and Cards Services
and Business Development
Direct responsibility:
• Capital Structure Advisory and
Cross-Border Financing
• Large Corporates
• Small and Mid-Corporates
• Trade Finance Services
• Investment Banking and Custody
• NLB Group Corporate and
Investment Banking Management
Direct responsibility:
• Private Banking
• Call Centre 24/7
• Distribution Network
• Customer, Product Management,
and Digital Services
• Development of Lending
Solutions for Retail
Membership in management or
supervisory bodies of related
or unrelated companies:
• Deputy Chairman of the
Supervisory Board of
• NLB Lease&Go, leasing, Ljubljana
• Chairman of the Supervisory
Board of NLB Banka, Podgorica
• Chairman of the Board of Directors
of NLB Banka, Prishtina
Membership in management or
supervisory bodies of related
or unrelated companies:
• Member of the Supervisory
Board of NLB Banka, Sarajevo
• Deputy President of the
Supervisory Board of Bank
Association of Slovenia
Membership in management or
supervisory bodies of related
or unrelated companies:
• Chairwoman of the Supervisory
Board of NLB Skladi, Ljubljana
• Member of the Supervisory Board
of NLB Banka, Banja Luka
• Member of Management Board of
the Institute for Economic Research
• Member of Management
Board of British–Slovenian
Chamber of Commerce
Further information about the work and composition of the Management Board is available in the chapter Corporate Governance
Statement of NLB.

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Collective decision-making bodies
The Management Board appoints different committees, commissions, boards, and
working bodies to execute relevant tasks within the powers of the Management Board.
Corporate Credit Committee
Assets and Liabilities Management
Committee of the NLB Group
NLB Operational Risk Committee
Change the Bank Committee
Chairman: CRO
Chairman: CFO
Chairman: CRO
Chairman: CEO
Number of members: 7
Number of members: equal to the
number of the appointed members
of the Management Board
Number of members: 16
Number of members: equal to the
number of the appointed members
of the Management Board
The Committee determines credit ratings,
makes decisions on the reclassification
of clients, and approves commercial
banking investment transactions and limits
beyond the directors’ competences. The
Committee adopts decisions on investment
transactions in commercial banking
within the statutory powers in corporate
banking in the Bank (all companies,
banks, and financial institutions),
operations with clients in intensive
care, and NPL. As a rule, committee
meetings are convened once a week.
The Committee monitors conditions in the
macroeconomic environment. It analyses
the balance sheet, changes to and trends in
the assets and liabilities of the Bank and the
Group companies, and drafts resolutions
and issues guidelines for achieving the
structure of the Bank’s and the Group’s
balance sheet. Committee meetings are
generally convened once a month.
The Committee is responsible for
monitoring, guiding, and supervising
operational risk management in the
Bank and transferring this methodology
to the Group members. As a rule, the
Committee meets once every two months.
The Committee is responsible for
adopting decisions related to the
development portfolio to transform the
Bank and decisions associated with
adopting the development guidelines.
As a rule, the Committee meetings
are convened once a month.
Risk Committee
Group Real Estate
Management Committee
Sales Committee
Private Individual Credit
Committee
Climate Change Committee
Chairman: CRO
Chairman: CFO
Chairman: CMO (responsible
for Corporate and
Investment Banking)
Chairman: Director of
Credit Risk – Retail
Chairman: CEO
Number of members: 5
Number of members: 6
Number of members: 15
Number of members: 5
Number of members: 12
The Risk Committee is a decision-
making and advisory body. It is
in charge of approving certain
internal acts, preparing a
proposal for topical or selected
strategic guidelines, monitoring
credit portfolio quality, topical or
certain areas/segments of credit,
commercial and other related
risks in NLB and NLB Group.
The Committee shall inform the
Management Board about the
conclusions, recommendations,
and other relevant changes.
As a rule, committee meetings
are convened quarterly.
The committee gives opinions
and decides for real estate
in use (so-called "in use"
real estate), for real estate
intended for divestment (so-
called "run-off" real estate),
for real estate projects (so-
called "development") and
general real estate matters.
As a rule, Committee meetings
are convened once a week.
The Sales Committee adopts
decisions on managing the range
of products and services and the
relations with the clients in sales.
As a rule, Committee meetings
are convened once a week.
The Committee decides on the
approval of loans and other
investment proposals, the
conditions of which deviate from
standard banking products
and services, and which
represent additional risks for
the Bank. As a rule, meetings
are convened when necessary.
The Climate Change Committee
at NLB Group is a decision-
making and advisory body
responsible for implementing the
net-zero strategy. It comprises
Management Board members
and core team representatives
from key departments. The
committee oversees strategic
and operational decarbonisation
efforts, including target setting
and KPI monitoring. As a
rule, Committee meetings
are convened biannually.
The Management Board also appointed working bodies that operate at a lower level:
Committee for New and Existing
Products
Committee for Business IT
Architecture
Data Governance Council
Anti-Money Laundering
Commission
Corporate Customer
Acceptability Committee

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Advisory bodies of the Bank’s Management Board
Watch List Committee
NLB Group Non-Performing Assets Divestment Committee
NLB d.d. Sustainability Committee
Chairman: CRO
Chairman: Director of Workout and Legal Support
Chairman: CEO
Number of members: 8
Number of members: 7
Number of members: 20
The Watch List Committee is a body which monitors the
progress of activities for clients on the Watch list. As a
rule, committee meetings are convened quarterly.
The NLB Group Non-Performing Assets Divestment
Committee monitors the operations of Non-
Core Group Members and issues opinions,
recommendations, and initiatives. As a rule,
committee meetings are convened quarterly.
The Committee oversees the integration of the ESG factors to
the NLB d.d. and the NLB Group members’ business model
in a focused and coordinated way across the company,
issues opinions, recommendations, and initiatives, and
takes relevant decisions when needed. The Committee shall
discuss, develop, and approve sustainability strategies,
policies, initiatives, methodologies, KPIs and other applicable
procedures. It shall influence sustainability-related strategic
objectives and shall monitor its development and realisation.
As a rule, committee meetings are convened quarterly.
NLB Group’s governance
As the parent bank, NLB implements the corporate
and business governance of the Group members
in compliance with EU and BoS legislation, the
local legislation, and regulatory requirements
applicable to respective Group members while also
considering internal rules, ECB Guidelines, and
other relevant regulations.
The NLB Group Governance Policy comprehensively
defines the Group operating model through corporate
and business governance rules, principles, criteria, and
mechanisms that define relevant stakeholders’ roles,
authorisations, and responsibilities to ensure that they
act orchestrated and achieve the set business goals. In
the Bank, the Group Steering Department is the principal
partner of the Bank’s Management Board in the
corporate also partially so in the business governance of
strategic and non-strategic Group companies.
The model of the Governance of NLB Group consists of
three pillars:
1. Corporate Governance, which is carried out following
fundamental corporate rules and governance
principles comprised of:
• shareholder voting at the General Meeting of NLB
Group members,
• proposing candidates for supervisory bodies of NLB
Group members,
• offering professional support to supervisory bodies of
NLB Group members,
• offering professional support in the selection of
candidates for management of NLB Group members,
• proposing candidates for various committees of NLB
Group members.
2. Business Governance which is carried out through
mechanisms that ensure efficient business guidance
and oversight:
• setting up a formal business governance framework by
Group Steering,
• standardisation and harmonisation of operations
across NLB Group by Competence Lines.
3. The Internal Control Functions serve as the second and
third lines of defence. In addition to standardisation
and harmonisation in their respective areas, they
also oversee the implementation of Group rules and
requirements (Internal Audit, Risk Management and
Compliance, including AML, Information Security,
Prevention and investigation of fraud to detriment of
the bank, and Physical Security).

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Figure 70: NLB Group Governance Model
NLB Group consists of NLB and Group members who
represent:
• financial core members: banks, leasing companies,
and asset management companies;
• non-financial core members: real estate management
companies, a company for IT operations and other
non-financial companies;
• non-core members: companies in the wind-down
process or companies considered non-strategic to
NLB Group.
At the end of 2024, the Group comprised 33 members,
three more than the previous year. NLB successfully
completed the transaction and became the sole
shareholder of SLS HOLDCO, Ljubljana, the parent
company of Summit Leasing Slovenija, Ljubljana, and
its subsidiary in Croatia Mobil Leasing, Zagreb. NLB
thus became the leading leasing provider in Slovenia
and re-entered the Croatian market after almost three
decades. The remaining changes were as follows:
• NLB Skladi, Ljubljana, has taken over 100% ownership
of Generali Investments, Skopje, and further renamed
NLB Fondovi, Skopje.
• The establishment of NLB Car&Go, Ljubljana by NLB
Lease&Go, leasing, Ljubljana.
• The merger of the company NLB Leasing, Ljubljana, – v
likvidaciji, with the company NLB Lease&Go, leasing,
Ljubljana.
• The merger of the company PRIVATINVEST, Ljubljana,
with NLB Real Estate, Ljubljana.
The NLB Group Governance Policy was renewed by
enhancing the role of Competence Lines, which is
the main business governance counterpart of the
Group members. It is responsible for harmonising and
standardising the Group operations, and therefore,
represents the highest level of business governance
hierarchy with professional, competent, and qualified
teams that are entirely or at least primarily dedicated to
the Group.
Recently, the governance of the two subgroups (leasing
and asset management) has been more precisely
defined in such a way that NLB is responsible for the
business and corporate management of its direct
subsidiary, i.e. the parent company of the subgroup,
and the parent company of the subgroup is responsible
for the business and corporate governance of its direct
subsidiaries following the rules and requirements of
the NLB Group (where appropriate). NLB, however,
established governance monitoring mechanisms over
all subgroups.
The legal and organisational structure of the banking
group, including a description of the internal governance
arrangements, the arrangements about close links
and the arrangements regarding the governance of
subsidiaries, are available on the Bank’s website.
Sustainability Management
General Assembly of NLB
Supervisory Board of NLB
Management Board of NLB
Corporate Governance
Supervisory Bodies
of NLB Group members
Management Board
of NLB Group members
Business Governance
Competence Lines
Group functions
Competence Centres
Centres of Excellence
Group domains
Internal Control Functions
Internal Audit
Risk Management
Compliance(i)
(i) Including also AML, CISO, Prevention and investigation of fraud to detriment of the bank, and Physical Security.
General Assembly
of NLB Group members

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Compliance and Integrity*
The Group systematically approaches compliance, addressing the complexities of evolving regulatory requirements
to ensure that employees and decision-makers understand that the objectives of these regulations remain a
priority. The Group continues to strengthen its compliance function and enhance operational due diligence.
14 Core financial members included, excluding NLB.
* Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter G-1 Corporate culture, ethical governance and integrity, and regulatory compliance
** Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter G-1 Prevention of money laundering and terorrism financing.
A culture of compliance is integrated into the Group’s
day-to-day business to support its operations,
contribute to its robust internal control environment, and
mitigate compliance risks.
Group-wide ethics and
integrity standards*
Compliance and Integrity addresses the following areas:
• Prevention and investigation of fraud to detriment of
the bank;
• Prevention of money laundering and terrorist financing
(MLTFP), and restrictive measures;
• Personal data protection (DPO);
• Information security (CISO);
• Regulatory compliance;
• Prevention of corruption and bribery (ABC) and
management of conflicts of interest;
• Prevention of abuse on the financial instruments market;
• Cooperation in the procedure of assessment of the
suitability of key function holders;
• Efficient, consistent, and proportional actions in the
event of identified deviations from compliance
and integrity;
• Cooperation in the system of internal controls;
• General professional ethics;
• Physical/technical security.
Within the programme’s framework for ensuring
business compliance, the Group also addresses the
ethics and integrity of the organisation. By upholding the
highest standards of ethical conduct, it fosters a culture
of trust, responsibility, and accountability among
employees and stakeholders. Transparency and
sustainable practices are integral to its approach,
supporting long-term value creation for clients,
shareholders, and the broader community. Through its
actions, the Group strengthens trust, contributes to
economic stability and fosters positive change in the
markets it serves.
Prevention*
As part of the Group’s commitment to ethics and
integrity, it has implemented various prevention activities
to protect the Group and its stakeholders from the risk of
reputation, money laundering, terrorist financing, fraud,
corruption, and other forms of financial crime.
To manage compliance risks effectively, the Group
conducts regular Enterprise Compliance Risk
Assessments (ECRA), further refined in 2024 using
insights from the 2023 assessment. These assessments
enable the Group to identify, evaluate, and mitigate
compliance and integrity risks effectively. The
compliance programme also involves risk assessments
for new and modified products, outsourcing
arrangements, fit and proper assessments, and other
material changes impacting the Group’s operations.
The Group actively promotes a culture of compliance
through awareness-raising initiatives. Annual employee
e-training covers critical topics such as ethics, anti-
corruption, conflict of interest mitigation, and personal
data protection. Regular newsletters provide updates on
regulatory changes and practical case studies, ensuring
employees are equipped to address compliance
challenges effectively. In 2024, the Group placed special
emphasis on raising employee awareness regarding
the importance of reporting conflicts of interest and the
acceptance of gifts. In addition to mandatory e-learning
training, focused workshops were held with employees
in business units to deepen their understanding of these
critical compliance areas.
In 2024, the Group introduced a new Compliance Tool
to enhance compliance management. This digital
solution streamlines compliance activities, automates
processes, and enables efficient monitoring of
regulatory obligations. By leveraging technology, the
Group ensures greater accuracy, cost-effectiveness, and
flexibility in managing its compliance framework while
responding to increasing regulatory demands.
The Group continuously strengthens its compliance
framework by refining internal policies and aligning with
new regulations, industry standards, and best practices
to ensure effective risk management and support
sustainable business operations.
Prevention of money
laundering and terrorism
financing, and financial
sanctions compliance**
The Bank complies with national regulations on Anti-
Money Laundering and Countering the Financing of
2,562 NLB /
4,494 NLB Group14
the number of employees
who completed
anti-corruption training
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Terrorism (AML/CFT), including the EBA, BoS, and other
competent authorities’ guidelines and standards. As a
member of the EU, the Republic of Slovenia (RoS) is
subject to the European AML/CFT Directives, which is
how the EU transposes the Financial Action Task Force
recommendations throughout the EU. For the Bank,
effectively mitigating the risk of money laundering,
terrorist financing, and breaches of financial sanctions is
of paramount importance. For these reasons, the rules,
procedures, and technology in the AML/CFT area are
subject to strict and unified policies and standards. The
same principles also apply to the Bank’s framework on
financial sanctions.
The Bank regularly updates and enhances its
governance in line with directions set by the BoS.
Through the system of performing risk assessment,
regular reporting, and constant on-site and off-site
control, the headquarters effectively monitor the
implementation and execution of standards throughout
the Group.
The Bank regularly performs customer due diligence
following the risk-based approach, applying additional
measures in cases of increased risk within the "Know
your customer" segment and in the ongoing monitoring
of transactional activities. In cases of detected deviations
and considering the AML/CFT indicators, the Bank’s
AML function ensures a review and, if required by
AML/CFT legislation, reports customers and transactions
to the competent Financial Intelligence Unit. In its
15 Core financial members included, excluding NLB.
* Incorporation by reference: A reference is made to this chapter from the Sustainability Statement chapter S-4 Cyber security and personal data protection.
Acceptance Policy, the Bank has also adopted additional
measures to prevent onboarding customers who do not
correspond to its risk appetite. The Bank also ensures a
high awareness of the AML/CFT and financial sanctions
by regular training of all Bank employees.
Information security and
personal data protection*
The information security area is focused on
implementing measures to increase the Bank’s cyber
resilience and strengthen its digital capabilities. Key
activities include enhancing cyber threat intelligence,
improving situational awareness, and conducting
penetration tests to assess and bolster the resilience of
information systems.
In 2024, the Bank assessed the information security
status of 48 outsourcing providers in line with
EBA guidelines. Special mandatory e-trainings on
information security and social engineering tested all
employees and were divided into three focus groups.
A dedicated training session was held for the Bank’s
Management Board members as part of a wider
preventative effort.
In response to an uptick in cyber fraud attempts
targeting its customers, the Bank implemented a
robust Brand Intelligence/Brand Protection service and
activated Dark Web monitoring. These steps enabled
swift detection and proactive takedowns of fraudulent
phishing portals, which mimic the Bank, thereby
mitigating threats posed by malicious campaigns.
The Bank continues to enhance and optimise security
approaches across the Group, ensuring consistent
visibility and autonomy for local Chief Information
Security Officer (CISO) offices in its core subsidiaries. This
alignment emphasises each subsidiary’s local
accountability for information security in accordance
with its executive management’s risk appetite and
applicable regulations. The Bank also remains active in
the global cyber intelligence-sharing community
exclusively for financial services, providing all local CISO
offices with access to intelligence exchange platforms,
cyber resilience resources, and threat mitigation
capabilities. NLB Group’s cyber threat intelligence
service is actively utilised, focusing on swift intelligence
access, strategies to address crisis events, and a trusted
network of relationships. In 2024, the Group continued
conducting cyber-attack incident response exercises
and participated in the FS-ISAC CAPS (cyber-attack
against payment systems) simulation, testing incident
response teams against a simulated attack involving
locked bank data and a ransom demand.
The Bank adheres to GDPR requirements in its daily
operations, especially the retention and processing of
personal data under the supervision of a dedicated
Data Privacy Officer, as well as through employee
education and training. Following the adoption of the
new Slovenian Personal Data Protection Act (ZVOP-2) in
2022, the Bank continues to integrate its provisions into
its processes and systems.
Fraud prevention
and investigation
The Bank has implemented a unified system and
standards for preventing and investigating suspected
misconduct that may negatively impact the Bank.
The Bank ensures full protection of reporters from any
potential retaliation in line with commitments outlined
in the Whistleblower Protection Act. This system enables
anyone, both internal and external parties, to report
misconduct freely and anonymously through several
different communication channels. A specialised team
centrally manages all received reports in accordance
with detailed internal procedures.
650 NLB /
3,028 NLB Group15
the number of employees
who participated in the
2024 Ethics and
Compliance Survey
114
data subject requests
under GDPR submitted to
NLB in 2024

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In 2024, the Bank achieved significant milestones in
safeguarding its brand’s integrity by implementing a
robust brand protection tool, reinforcing customers’
trust and confidence in the Bank. Additional security
measures were introduced in both web and mobile
e-banking channels.
The Bank has strengthened its approach to cyber risk
management and the prevention of unauthorised
payment transactions, reflecting its commitment to
safeguarding the security of the Bank’s customers and
employees. The Bank has also been actively involved
in The Bank Association (ZBS) initiatives, contributing
to public awareness campaigns on cyber and payment
fraud prevention.
Recognising that well-informed employees are critical
to maintaining a strong defence, the Bank devoted
significant attention to employee training, sharing
insights into observed fraud patterns, and offering
recommendations to improve processes.
Fraud prevention in loan origination processes is
intricately linked to operational risk and requires
a comprehensive approach. The Bank has
implemented rigorous verification processes for
new loan applications, including identity verification
checks, thorough credit history analysis, and cross-
referencing information from multiple sources to identify
inconsistencies or fraudulent indicators.
The Bank’s involvement in these activities underscores
its dedication to fostering a secure and transparent
business environment. NLB remains steadfast in its
mission to uphold the highest standards of business
ethics, ensuring that its customers can confidently
engage with its brand.

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Internal Audit
Internal Audit reviews key risk areas in the Group’s operations, advises management at all levels, and deepens
understanding of the Bank’s operations. It provides independent and impartial assurance regarding the
management of key risks, management of the Bank, and functioning of internal controls, thereby strengthening and
protecting the value of the Bank.
Internal Audit is an independent, objective assurance
and advisory service designed to add value and
improve the Bank’s operations. It is primarily answers
to the Supervisory Board and its Audit Committee,
and secondarily to the Management Board of the
Bank. It helps to accomplish the Bank’s objectives by
bringing a systematic, disciplined approach to evaluate
and improve the effectiveness of governance, risk
management, and control processes.
Internal Audit strengthens the Bank’s ability to create,
protect, and sustain value by providing the Management
and Supervisory Boards with independent, risk-based,
and objective assurance, advice, insight, and foresight.
Performed audits
Internal Audit performs its tasks and responsibilities at
its discretion and in compliance with the Annual Audit
Plan approved by the Management and the Supervisory
Boards. Based on its internal methodology and
comprehensive risk assessment for 2024, Internal Audit
planned 95 audits, of which 84 were completed,
covering various areas of operations within the Bank
and the Group. Among these, 27 were branch
inspections, eight were group audits, one was conducted
as a joint audit with a local auditor, three were quality
reviews in banking subsidiaries, and two new audits
were initiated.
In addition, Internal Audit was involved in several
strategic projects as an advisor. Five planned audits
were postponed for objective reasons, and one audit
was removed from the plan as it was covered by another
audit. Most recommendations issued in 2024 were
implemented within the agreed-upon deadlines.
Implementation of
uniform rules
Internal Audit continuously increases efficiency. It
focuses on monitoring the implementation of audit
recommendations, training and education, advising
management, and ensuring high-quality and
professional operations of the internal audit function
within the Group. In November 2024, the Internal Audit
Charter and Manual were updated and aligned with
the Global Internal Audit Standards, effective 9 January
2025. Internal Audit also introduces uniform rules of
operation for the internal audit function and regularly
monitors compliance with these rules within the Group.
Following the highest
standards
In 2022, an external quality review of the internal audit
function was performed and confirmed that Internal
Audit and other internal audit services within the Group
operate in accordance with the following:
Code of
Internal
Auditing
Principles
Code of
Ethics of
an Internal
Auditor
International
Standards
for the
Professional
Practice of
Internal
Auditing
Banking Act
(ZBan-3) or other
relevant laws
regulating the
operations of a
Group member
84
planned audits
conducted in the Bank
39
Internal Audit experts

NLB Group
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Corporate Governance Statements

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The Statement of Management’s Responsibility
16 MFIA, Official Gazette of the RoS, No. št. 77/18, 17/19 – corr., 66/19, 123/21 and 45/24.
In accordance with the provisions of Article 134
(Paragraph 2, Point 3, 2nd bullet) of the Market and
Financial Instruments Act16, the Management Board
hereby confirms the statements made in the business
report, which are in accordance with the attached
financial statements as of 31 December 2024, and
represent the actual and fair financial standing of the
Bank and the NLB Group as well as their operating
results in the year that ended 31 December 2024.
The Management Board confirms that the Business
Report gives a fair view of developments and operating
results of the Bank and the Group and their financial
standings, including a description of the material
types of risks the Bank and the NLB Group companies
included in the consolidation are exposed as a whole.
Ljubljana, 25 March 2025
Management Board of the NLB
Hedvika Usenik
Andrej Lasič
Archibald Kremser
Peter Andreas Burkhardt
Antonio Argir
Blaž Brodnjak
Member
Member
Member
Member
Member
Chief Executive Officer

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Authorisation to Perform Banking Services
Nova Ljubljanska banka d.d., Ljubljana has an
authorisation to perform banking services pursuant to
Article 5 of the Banking Act (Official Gazette of the RoS,
No. 92/2021, with Amendments; hereinafter: the ZBan-3).
Banking services are the acceptance of deposits and
other repayable funds from the public and the granting
of credits for its own account.
The bank has an authorisation to perform mutually
recognised and additional financial services.
It may perform the following mutually recognised
financial services, pursuant to Article 5 of the ZBan-3:
1. receiving deposits;
2. granting of loans, including:
· consumer loans,
· mortgage loans,
· purchase of receivables with or without recourse
(factoring),
· financing of commercial transactions, including
export financing based on the purchase of
non-current non-past-due receivables at a
discount and without recourse, secured by
financial instruments (forfeiting);
4. payment services and electronic money issuing
services;
5. issuance and management of other payment
instruments (i.e. travellers’ cheques and banker’s
drafts) in the part in which this service is not
included in service of point 4 of this Article;
6. issuing of guarantees and other commitments;
7. trading for own account or for the account of
clients:
· in money-market instruments,
· in foreign exchange, including currency
exchange transactions,
· financial futures and options,
· exchange and interest-rate instruments,
· in transferable securities;
8. participation in securities issues and the provision
of associated services;
9. corporate consultancy with regard to capital
structure, operational strategy and related matters,
and consultancy and services in connection with
corporate mergers and acquisitions;
10. monetary intermediation on interbank markets;
11. advice on portfolio management;
12. safekeeping of securities and other related
services;
13. credit rating services: collecting, analysing
and disseminating information regarding
creditworthiness;
14. leasing of safe deposit boxes;
15. investment services and transactions, and ancillary
investment services in accordance with the ZTFI.
It may perform the following additional financial
services, pursuant to Article 6 of the ZBan-3:
1. insurance agency service pursuant to the law
governing the insurance industry
4. custodian and administrative services according
to the law governing investment funds and
management companies
5. credit brokerage for consumer and other types of
loans
6. other services or transactions:
6.1. intermediation in financial leasing
6.2. sale and purchase of investments in gold
Authorisation to perform banking services is published
on the official website of BoS.

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Corporate Governance Statement of NLB
17 The Companies Act (ZGD-1; Official Gazette of the RoS, No. 65/09 and consecutive changes).
18 The Corporate Governance Policy of NLB was adopted in February 2023.
19 Slovenian Corporate Governance Code for Listed Companies, December 2021 (valid for this Corporate Governance Statement for the business year 2024). Nevertheless, the mentioned code was changed in December 2024, is valid
from 1 January 2025, and will apply to the companies for the first time when preparing the Corporate Governance Statement for the 2025 financial year.
20 Published on the Bank’s website.
21 ZGD-1M recent changes to Companies Act, Official Gazette of the RoS, No. 102/24, valid from 18 December 2024.
Pursuant to Article 70, paragraph 6 and 7 of the
Companies Act (further in text: ZGD-1)17, NLB hereby
gives the following Corporate Governance Statement
of NLB as part of the Business Report of the NLB Group
Annual Report 2024. The main function of this statement
is to prompt informing investors on the coherence of the
Bank’s corporate governance system.
1. COMPLIANCE WITH THE CORPORATE GOVERNANCE CODE
1. 1. References to the Code on
Corporate Governance
The recommended best corporate governance practices
contribute to a transparent and understandable
corporate governance system, which promotes both
domestic and foreign investor confidence, as well
as the confidence of employees, other stakeholders
(shareholders, regulators, suppliers, etc.), and the public.
A decision on which code the Bank will follow was made
jointly by the Management and the Supervisory Boards
of the Bank by adopting the Corporate Governance
Policy of NLB18.
Compliance with the Slovenian Corporate Governance
Code for Listed Companies19 is explained in this
statement on a "comply or explain basis," in which the
Bank provides an explanation regarding deviations,
the reasoning for non-compliance with a certain
recommendation, or alternative practices performed
mostly due to stricter banking regulation. The statement
refers to the Bank’s system of corporate governance
from the beginning to the end of the financial year,
which also corresponds to the beginning and the end of
the calendar year (from 1 January until 31 December).
The Corporate Governance Statement of NLB is included
in the Business Report of the NLB Group Annual Report
(published on NLB’s website and is also published as a
separate report on the Bank’s website under the chapter
on Corporate Governance.
NLB strives to increase the level of its business
transparency and informs the shareholders and other
expert community in line with Guidelines on Disclosure
for Listed Companies (Ljubljana Stock Exchange,
25 March 2024) and in line with Rules and Regulation of
the Luxembourg Stock Exchange, as well as in line with
Rules of the London Stock Exchange through Regulatory
News Services (RNS) of the London Stock Exchange.
NLB also upholds its own code of conduct. The NLB
Group Code of Conduct, which was revised in May 2023,
is a standardised document for all members of the
Group that defines values, lays down the standards of
ethical business conduct, and serves as the guideline
for all Bank’s relationships regardless of whether it
involves clients, competitors, business partners, state
authorities, regulators, shareholders, or internal
relationships between employees. At the same time, it
is the basis of the Group values and basic principles of
conduct, which provide specific conduct guidelines to its
employees. This approach aims to ensure compliance
with all applicable laws, regulations, and standards. It is
published on the Bank’s website.
Regarding the representation of gender in the
Management and Supervisory Boards, the NLB
implements an internal Policy on the Provision of
Diversity of the Management Body and Senior
Management (June 2022), which defines the principles
and procedures that promote gender-balanced
planning for the Management and Supervisory Boards,
as well as for senior management20.
The Corporate Governance system of the Bank and
all relevant information on Bank’s management that
exceeds the requirements of Article 70 of the Companies
Act (ZGD-1) are published in the chapter in Risk
Management of this Annual Report. Some other aspects
of the functioning of the Bank’s managing bodies are
described in the chapter in Corporate Governance
of this Annual Report, as well as in the Corporate
Governance Policy of NLB published on the NLB’s
website. Information on the ESG Risk Management
for the year 2024 is described in the Sustainability
Statement as part of this Annual Report. Information
on the Diversity Policy is according to recent changes
to ZGD-1M21 described in the Sustainability Statement
of this Annual Report. Diversity Policy, Remuneration
Policy and ESG risks are also described in the Pillar 3
Disclosures according to Basel standards.

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2. COMPLIANCE WITH THE SLOVENIAN CORPORATE GOVERNANCE CODE
FOR LISTED COMPANIES
22 Recent changes are primarily the result of alignment with the amendment to the Companies Act (ZGD-1M) and the development of good corporate governance practices (diversity, remuneration and independence).
The Code provides recommendations for good
management, control and management practices
of public joint-stock companies whose shares are
listed on the organized market in Slovenia. In 2024,
the Code was updated and entered into force on
1 January 2025. However, the companies should use
the recommendation of this Code for the first time when
preparing the Corporate Governance Statement for
the 2025 financial year22. Nevertheless, NLB already
complies with some of the changes of the Code.
The Bank does not follow, partially implements,
or adhere to different, in most cases stricter,
banking regulations with regard to the following
recommendations:
Recommendation 5.6: NLB does not provide an
external assessment of the adequacy of the
Corporate Governance Statement of NLB at least
every three years since NLB is a systemically important
bank with demanding regulation that takes into
account high standards of corporate governance. The
Bank is highly regulated by a regulator and examined
by the external auditor.
Recommendation 7.4: The Sustainability Policy of
NLB d.d. and NLB Group contains basic due diligence
guidelines and measures for identifying risks and
prevention of serious harm in relation to areas that
are defined in this recommendation. Additionally, due
diligence guidelines and measures for identifying risk
are further elaborated in the Policy on the Respect
for Human Rights in NLB and the NLB Group, and are
implemented in other domain-specific policies covering
respective business areas in NLB Group.
Recommendation 12.1: In assessing a candidate’s
eligibility to be a Supervisory Board member, statutory
criteria are applied. However, according to the Policy to
Assess the Suitability of the Management and Supervisory
Board Members in NLB (June 2022), it is not necessary
for candidates to have a certificate evidencing their
specialised professional competence for membership
on a Supervisory Board, such as the Certificate of
Slovenian Directors’ Association, or any other relevant
certificate. However, all strict conditions must be fulfilled
according to banking legislation, including a wide range
of knowledge, skills, and experience.
Recommendation 14.2: Currently, valid Rules of
Procedure of the Supervisory Board of NLB d.d.
(November 2024) are prepared according to strict rules
governing banks. They do not include provisions on the
Agreement on access to the archives after expiration
of the term of office of the members of the Supervisory
Board, as the access to the archives after expiration of
the term of office is determined by the provisions of the
Rules of Procedure of the Supervisory Board of NLB and
not in a special agreement.
Recommendation 14.3: The Rules of Procedure of
the Supervisory Board of NLB d.d. do not include the
scope of topics and timeframe to be respected by the
Management Board in its periodic reporting of the
Supervisory Board. However, the scope of topics and
time frames of periodic reporting to the Supervisory
Board are included in the annual Action Plan of the
Supervisory Board. Competent organisational units of
the Bank ensure that timely information is provided to
the Supervisory Board.
Recommendation 14.4: In 2024, the NLB Workers’ Council
did not report to the Supervisory Board. In 2023, the NLB
Workers’ Council sent a letter stating that it would inform
the professional services of NLB if it intended to report to
the Supervisory Board in the future.
Recommendation 14.6: Access to the archives after
the expiration of the term of office of the members
of the Supervisory Board is determined by the Rules
of Procedure of the Supervisory Board of NLB d.d.
Members of the Supervisory Board do not sign a special
Agreement on the access to the archives upon taking up
the position. See also Recommendation 14.2 above.
Recommendation 17.6: The President of the Supervisory
Board, together with the Secretary of the Supervisory
Board or an expert from the Bank designated by the
Secretary of the Supervisory Board, takes care of
the minutes of the Supervisory Board meeting. Only
exceptionally, can a Supervisory Board member also
be the minute-taker. The President of the Supervisory
Board and the Director of Legal and Secretariat ensure
that the resolutions formulated at the meeting are
clearly formulated and comprehensible.
Recommendation 19.1: In 2024, the Supervisory Board
members (representatives of capital and representatives
of workers) did not receive attendance fees but received
payments for performing their function based on the
decisions of the General Meeting of Shareholders
dated 21 October 2019, 15 June 2020 and 19 June 2023.
Remuneration of the Members of the Supervisory Board
is regulated by the Articles of Association of NLB d.d., the
decisions of the General Meeting of shareholders from
the previous sentence and the Remuneration Policy for
the Members of the Supervisory Board of NLB d.d. and
the Members of the Management Board of NLB d.d.
Recommendation 20: Minutes of the Supervisory Board
meeting are taken by the Secretary of the Supervisory
Board or an expert from the Bank designated by the
Head of Secretariat. Only exceptionally, a Supervisory
Board member can also be the minute-taker.
Recommendation 23.5: In accordance with regulations
and the Remuneration Policy of the Members of the
Supervisory Board of NLB d.d. and the Members of
the Management Board of the NLB d.d. in 2024, NLB
awarded to the members of its Management Board 50%
of their variable remuneration for 2023 in share-linked
instruments: 50% of such instruments were handed over
to the members of the Management Board without any

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deferral, and the remaining 50% of such instruments
will be handed over to the members of the Management
Board during a 5-year deferral period.
Recommendation 26.6: The Bank maintains a list of
transactions with related persons according to the
Banking Act (ZBan-3). A list of transactions with related
persons is submitted to the Supervisory Board by
special demand.
Recommendation 30.4: NLB draws up its Financial
Calendar, published on the Banks’ website and
includes the date of the Annual General Meeting of NLB.
However, it doesn’t provide information on the dividend
payment date. The date is announced in the publication
of the Agenda and Proposed Resolutions to be passed
at the Annual General Meeting. The dividend payment
date is determined based on KDD’s Operations Rules
(Central Securities Clearing Corporation).
Recommendation 32.7: NLB does not publish the
rules of procedure of its bodies (Management Board,
Supervisory Board, and its committees) on its website.
However, each year, the Bank discloses the composition,
competences, and work of its managing bodies in
the Corporate Governance Statement of NLB that is
published in this NLB Group Annual Report, as well as on
the Bank’s website.

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3. MAIN FEATURES OF INTERNAL CONTROL AND RISK MANAGEMENT SYSTEMS IN
RELATION TO FINANCIAL REPORTING
NLB is governed by the provisions of the Capital
Requirements Regulation (CRR), with amendments,
together with all applicable delegated acts, the Banking
Act (ZBan-3) and the Regulation on Internal Governance
Arrangements, the Management Body and the Internal
Capital Adequacy Assessment Process for Banks and
Savings Banks regulating, and relevant EBA Guidelines,
among other, the Bank’s obligation to set up, maintain
appropriate internal control, and risk management
systems. Due to the above, the NLB has developed
a steady and reliable internal governance system
encompassing the following:
3. 1. Internal control mechanisms
The Suitability of the internal control mechanisms is
determined by the independence, quality, and validity of:
• the rules for and controls of the implementation of the
Bank’s organisational, business, and work procedures
(internal controls) and
• the internal control functions and departments
(internal control functions).
3.1.1. Internal Controls
The policy entitled "Internal Control System" defines a
system of internal controls as a set of rules, procedures,
and organisational structures. The system of internal
controls in NLB is designed to ensure that for each
key risk, there is a process or other measure to reduce
or manage that risk, and that process or measure is
effective for that purpose.
The Mentioned policy introduces a new description of
the three lines of defence, namely:
1. First-level (or line) controls are implemented into
business and non-business organisational units (OU).
2. Second-level controls are divided between Risk
Management and Compliance control functions
(including AML/CTF and Information security
management), which carry out independent
controls and supervision over the operation of the
first line of defence.
3. The third level of control is performed by the internal
audit function, which assesses and regularly checks
the completeness, functionality, and adequacy
of the internal control system. An internal audit is
completely independent of both the first-line and
the second-level control functions.
In the event of deficiencies, irregularities, or breaches
identified in the process of implementation of internal
controls, the breaches are discussed at the Operational
Risk Committee (which is the collective decision-making
body appointed by the Management Board of the
Bank that is established for the execution of individual
tasks within powers of the Management Board of the
Bank). The mentioned committee adopts decisions to
take appropriate actions and informs the Management
Board of the Bank about deficiencies and actions taken
on that behalf.
As NLB advances its commitment to sustainable and
responsible banking, updates to the Internal Control
System policy, implemented in November 2023, reflect
the Bank’s dedication to ensuring a comprehensive
approach to ESG governance, addressing ESG risks, and
promoting responsible business practices.
3.1.2. Internal Control Functions
Internal control functions are part of the system of
internal governance in the Bank. Internal control
functions include:
a) The Internal Audit Function
The Internal Audit function is organised in accordance
with the Internal Audit Charter of NLB d.d., approved by
the Management Board, to which the Supervisory Board
of NLB gave its consent.
The Management Board of NLB has established and
organised an independent Internal Audit function.
The main purpose of the Internal Audit is to provide
the Bank’s Management and Supervisory Boards with
objective and independent assurance and advisory
services designed to add value and improve an
organisation’s operations.
Internal auditing is an independent, objective assurance
and advisory service designed to add value and
improve the Bank’s operations, which is primarily
responsible to the Supervisory Board of NLB and its
Audit Committee and secondarily to the Management
Board of the Bank. It helps to accomplish the Bank’s
objectives by bringing a systematic, disciplined
approach to evaluate and improve the effectiveness of
governance, risk management, and control processes.
In addition, the Internal Audit conducts regular Quality
reviews of the Internal Audit functions in the Group and
ensures continuous development of the internal auditing
function in NLB Group.
The Supervisory Board of NLB must give its agreement
to the appointment and dismissal of the Chief Audit
Executive, which ensures his independence and, thus,
the independence of the Internal Audit function.
b) The Risk Management Function
The Risk Management Function is organised according
to the Charter of the Risk Management Function of NLB
adopted by the Management Board, in agreement with
the Supervisory Board of NLB.
The Risk Management Function represents an important
part of the overall management and governance system
in the Group. This function in NLB is organised within the
Risk stream, covered by the member of the Management
Board in charge of risk (Chief Risk Officer – CRO).
The Risk Management Function is performed by
the Global Risk function. In accordance with the
competences, authorisations, and responsibilities,
Global Risk is represented by its General Manager.
Global Risk is in functional and organisational terms
separate from other functions where business decisions
are adopted and where a potential conflict of interest
may arise with the Risk Management Function. The head
of the Risk Management Function has direct access to
the Management Board of the NLB and, at the same
time, has unhindered and independent access to the
Supervisory Board of NLB and the Risk Committee of the
Supervisory Board of the NLB.

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Risk management and control is performed through
a clear organisational structure with defined roles
and responsibilities. The organisation and delineation
of competences are designed to prevent conflicts of
interest, to ensure a transparent and documented
decision-making process, and are subject to an
appropriate upward and downward flow of information.
The competence line, Risk Management in NLB,
encompasses several professional areas and is in
charge of formulating and controlling the Group’s risk
management policies, setting limits, overseeing the
harmonisation, regular monitoring of risk exposures and
limits based on centralised reporting at the Group level.
In members of the Group, the risk management
function is organised according to the local legislation,
considering the bases for setup, organisation, and
activities in risk management in the members, as
defined in the document "Risk Management Standards
in the NLB Group."
c) The Compliance Function, Information Security
Function, and AML/CTF Function
Compliance and Integrity in the Group, in its role as
internal control function, performs control activities with
respect to the main following areas:
• anti-money laundering and counter-terrorist financing
(separately for NLB and the Group);
• information security and data protection;
• personal data protection;
• regulatory compliance management;
• prevention and investigation of fraud to detriment
of the bank;
• security;
• development of compliance risk methodologies, and
setting and monitoring ethics and integrity standards;
• harmonisation of policies and practices within the
Group (Competence line Compliance and Integrity).
Compliance and Integrity is an organisational unit of
the Bank, placed directly under the Bank’s Management
Board in the organisational structure. The Bank adopted
the Integrity and Compliance Policy of the NLB and the
NLB Group. This Policy regulates the method and scope
of the activities of the compliance function in the Bank.
Supervision over compliance of operations is within the
competence of Compliance and Integrity. This enables
23 According to Recommendations for the Audit Committees (SDA&KPMG 2022, point 10.1), the Bank provides an explanation of the selection of an audit firm and the independence of the statutory auditor.
Compliance and Integrity to operate independently from
other Bank departments.
The Director of Compliance and Integrity does not
perform any other function at the Bank that could
possibly lead to a conflict of interest. To ensure his
independence, the Director reports directly to the
Management and Supervisory Boards. Additionally,
the Director provides regular updates to a designated
member of the Bank’s Management Board responsible
for overseeing compliance areas (including information
security, personal data protection, and AML/CTF
functions). This arrangement provides additional
assurance for the independence of the Compliance and
Integrity operations.
As information security, AML/CTF, and Group AML
functions are organised within Compliance and Integrity,
CISO for NLB and NLB Group (Chief Information Security
Officer), DPO (Data Protection Officer), the head of the
AML/CTF area for NLB, and head of Group AML are
ensured full independence through equal reporting lines
as the Director of Compliance and Integrity. Following
NLB’s model, the compliance function was established in
the core members of the Group, as well as based on the
Group standards for the compliance and integrity area.
3. 2. Financial reporting
To ensure appropriate financial reporting procedures,
NLB pursues the adopted Policy on Accounting Controls.
The accounting controls are provided through the
operation of the complete accounting function with the
purpose of ensuring quality and reliable accounting
information and, thereby, accurate and timely financial
reporting. The principal identified risks in this area are
managed with an appropriate system of authorisations,
segregation of duties, compliance with accounting
rules, documenting of all business events, a custody
system, posting on the day of a business event, in-
built control mechanisms in source applications, and
archiving pursuant to the laws and internal regulations.
Furthermore, the policy precisely defines primary
accounting controls, performed in the scope of analytical
bookkeeping, and secondary accounting controls, i.e.,
checking the efficiency of implementation of primary
accounting controls. With an efficient mechanism of
controls in accounting reporting, NLB ensures:
• a reliable decision-making and operation support
system;
• accurate, complete, and timely accounting data, the
resulting accounting, and other reports of the Bank;
• compliance with legal and other requirements.
a) Selection of an audit firm23
Through a process, the Bank selects auditing companies
in which management bodies, the Audit Committee, and
the Supervisory Board actively participate and appoint
an auditing company that will ensure an independent
and impartial audit of the financial statements in
accordance with professional and professional-ethical
auditing principles and other auditing rules.
Before the start of the selection process, a proposal for
the criteria for the appointment of the audit company
and the minimum conditions for cooperation are
prepared, which also include the mandatory disclosure
of all possible non-audit services that the audit company
has performed for the Bank or its affiliated companies in
the last year (namely statement that an audit firm or any
member of the network to which the audit firm belongs,
did not directly or indirectly provide to the audited
entity, to its parent undertaking or to its controlled
undertakings any prohibited non-audit services in the
financial year immediately preceding the period being
audited). The proposed criteria are approved by the
Audit Committee and the Supervisory Board. After
considering the report on the selection process, the
Audit Committee submits a recommendation on the
appointment of an audit company to the Supervisory
Board. Based on the recommendation of the Audit
Committee, the Supervisory Board proposes the
appointment of an audit company, which is approved by
the Shareholders’ Meeting.
The financial statements of NLB and consolidated
financial statements of NLB Group are audited by the
auditing company KPMG Slovenia d.o.o., Ljubljana.
The mentioned auditing company was appointed
as the auditor of NLB by the 38th General Meeting of
shareholders of the Bank dated 20 June 2022 for the
financial years 2023 to 2026.

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The selected audit company audits all members of NLB
Group, except in case of other valid reasons (possible
legal or other local restrictions).
In 2023, there was a change of audit company due to the
expiration of the statutory period of 10 business years,
when the same audit firm can perform the audit.
b) Independence of the Statutory Auditor
The statutory auditor must assess and document
compliance with independence requirements before
accepting or continuing a statutory audit engagement.
The Audit Committee annually requires written
declarations of independence from the statutory auditors,
which must apply to the audit firm, the audit partners,
and senior personnel involved in the audit engagement.
When assessing the auditor’s independence, all areas of
potential conflict of interest are considered, such as:
• direct or indirect financial investments in the company,
• personal and business relationships (which also
include close family members, close relatives and
business partners),
• the relationship between the key audit partner,
members of the board and key employees,
• economic dependence,
• the type and scope of other services performed by the
auditor in addition to the audit.
Independence is ensured during the period covered by
the financial statements being audited and during the
period during which the statutory audit is carried out.

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4. INFORMATION ON POINT 4, PARAGRAPH 6, OF THE ARTICLE 70 OF THE ZGD-1
regarding points 3, 4, 6, 8, and 9 of paragraph 8 of the same article
Explanation regarding significant direct and indirect
ownership of the company’s securities in the sense of
achieving a qualified stake as determined by the act
regulating acquisitions
(Point 3 of the eight paragraph of Article 70 of the ZGD-1)
Significant direct and indirect ownership of the
company’s securities in terms of achieving a qualifying
holding as defined in the Takeovers Act (as at 31
December 2024).
Table 37: NLB’s main shareholders as at 31 December 2024(i)
Shareholder
Number of shares
Percentage of shares
Bank of New York on behalf of the GDR holders(ii), (iii)
9,659,425
48.30
• of which EBRD
/
>5 and <10
• of which Brandes Investment Partners, L.P.
/
>5 and <10
Republic of Slovenia (RoS)
5,000,001
25.00
Other shareholders
5,340,574
26.70
Total
20,000,000
100.00
(i) This information is sourced from the NLB’s shareholders’ book that is accessible at the web services of CSD (Central Security Depository, Slovenian: KDD
- Centralna klirinško depotna družba) and available to CSD members.
(ii) The Bank of New York holds shares in its capacity as the depositary (the GDR Depositary) for the GDR holders and is not the beneficial owner of such shares.
(iii) The information on GDR ownership is based on self-declarations by individual GDR holders as required pursuant to the applicable provisions of Slovenian law.
More information on the Bank’s Share Capital is available on the NLB website.
Explanation regarding the holders of securities that
carry special control rights
(Point 4 of the eight paragraph of Article 70 of the ZGD-1)
The Bank did not issue any securities carrying special
controlling rights.
Explanation regarding the restrictions related to voting
rights, in particular: (i) restrictions of voting rights to a
certain stake or certain number of votes, (ii) deadlines
for executing voting rights, and (iii) agreements in
which, based on the company’s cooperation, the
financial rights arising from securities are separated
from the rights of ownership of such securities
(Point 6 of the eight paragraph of Article 70 of the ZGD-1)
The shares of the Bank are freely transferable, subject to
the provisions of the Articles of Association of the Bank,
which require the approval of the Supervisory Board,
namely for the transfer of shares of the Bank by which
the acquirer, together with the shares held by the holder
before such an acquisition and the shares held by third
parties for the account of the acquirer, exceeds the
share of 25% of the Bank’s voting shares. Approval for
the transfer of shares is issued by the Supervisory Board.
The Bank rejects the request for approval of transfer
shares if the acquirer, together with the shares held by
the acquirer before the acquisition and the shares held
by third parties for the account of the acquirer, exceeded
the 25% share of the Bank with voting rights, increased
by one share.
Notwithstanding the provision mentioned in the first
paragraph, approval for the transfer of shares is not
required if the acquirer of the shares has acquired them
for the account of third parties, so that it is not entitled
to exercise voting rights from these shares at its sole
discretion, while at the same time committing to the
Bank, it will not exercise voting rights on the basis of
the instructions of an individual third party for whose
account it has acquired the shares if, together with
the instructions for voting, it does not receive a written
guarantee from that person that this person has shares
for his own account, and that this person is not, directly
or indirectly, a holder of more than 25% of the Bank’s
voting rights.
The acquirer who exceeds the share of 25% of the
Bank’s shares with voting rights and does not require the
issuance of approval for the transfer of shares, or does
not receive the approval of the Bank, may exercise the
voting right from 25% of the shares with the voting rights.
There are no restrictions other than those mentioned
and those that are regulatory.

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Explanation on the (i) company’s rules on appointment
or replacement of members of the management or
supervisory bodies, and (ii) changes to the company’s
Articles of Association
(Point 8 of the eight paragraph of Article 70 of the ZGD-1)
The appointment or replacement of members of the
management or supervisory bodies*
The Management Board*
Articles of Association define that the Management
Board of the Bank is comprised of three to seven
members, one of whom is appointed President of
the Management Board of the Bank. The number
of Management Board members is determined by
a resolution of the Bank’s Supervisory Board. The
President and other members of the Management Board
are appointed and recalled by the Supervisory Board
of the Bank; the President of the Management Board
may propose to the Supervisory Board of the Bank to
appoint or recall an individual member or the remaining
members of the Management Board of the Bank.
The President and members of the Management Board
shall be appointed for a period of five years and may be
re-appointed for another term of office. The President
and members of the Management Board may be recalled
prior to the expiry of their term of office in accordance
with applicable laws and Articles of Association. Each
member of the Management Board of the Bank may
prematurely resign her/his term of office with a period of
notice of three months. Written notice shall be delivered to
the Chair of the Supervisory Board of the Bank. The notice
term may be shorter than three months if requested by
the resigning member of the Management Board of the
Bank in his/her notice and is subject to the approval of
the Supervisory Board of the Bank.
A member of the Bank’s Management Board may only
be a person who fulfils the legally prescribed conditions
for a management board member under the law on
banking and who obtained a licence from the BoS or
the ECB, if executing the competences and tasks from
Item (e) of paragraph 1 of Article 4 of Regulation (EU)
no. 1024/2013 for the performance of the function of
a bank’s management board member under the law
regulating banking. The Bank assesses every candidate
following the Bank’s Policy governing the Fit & Proper
assessment prior to the appointment.
The Supervisory Board*
According to the Articles of Association of the NLB
d.d., the Supervisory Board consists of a total of twelve
members, of which eight members represent the
interests of shareholders and four members represent
the interests of employees. Members of the Supervisory
Board representing the interests of shareholders are
elected and recalled by the General Meeting from
persons proposed by shareholders or the Supervisory
Board. Members of the Supervisory Board representing
the interests of employees are elected and recalled by
the Workers' Council, taking into account the conditions
for members of the Supervisory Board laid down in the
regulations and the Articles of Association of NLB d.d.
At the end of 2024, the Supervisory Board of the
Bank consists of a total of 10 members, of which eight
members represent the interests of shareholders and
two members represent the interests of employees.
Members representing the interests of shareholders
shall be elected and recalled by the Bank’s General
Meeting from persons proposed by shareholders or
the Supervisory Board of the Bank, and members
representing the interests of employees shall be elected
and recalled by the Workers’ Council of the Bank.
Members of the Supervisory Board representing the
interests of shareholders are elected by an ordinary
majority of votes cast by the shareholders.
The term of office of the Supervisory Board members
commences on the day their appointment enters into
force (at the start of the term of office) and lasts up
until the end of the Bank’s Annual General Meeting of
shareholders, which decides on the use of accumulated
profit for the fourth business year since the start of their
term of office unless otherwise stipulated at the time
of appointment of individual members. In this context,
the first year is deemed the business year in which the
members of the Supervisory Board of the Bank started
their term of office.
The General Meeting of the Bank may dismiss an
individual or all members of the Supervisory Board
(representatives of shareholders) even before the
expiration of their term of office. A resolution on
dismissal shall be valid if adopted with at least a
three-quarter majority of all votes cast.
The Supervisory Board of the Bank shall, at its first
meeting after an appointment, elect from among its
members a Chair and at least one Deputy Chair of the
Supervisory Board of the Bank. A member representing
the interests of employees cannot be elected Chair or
Deputy Chair of the Supervisory Board of the Bank. All
the Supervisory Board members shall be independent
professionals, as defined by the Articles of Association.
A member of the Bank’s Supervisory Board may only
be a person who fulfils the legally prescribed conditions
for a supervisory board member under the Banking Act
and who obtained a licence from the BoS or the ECB, if
executing the competences and tasks from Item (e) of
paragraph 1 of Article 4 of Regulation (EU) no. 1024/2013
for the performance of the function of a bank’s
supervisory board member under the law regulating
banking. The Bank assesses every candidate following
the Bank’s Policy governing Fit & Proper assessment
prior to the appointment.
Amendments to Articles of Association
A qualified majority of at least 75% (seventy-five per cent)
of the votes cast by shareholders at the general meeting
of the Bank’s shareholders is required for the adoption of
any amendments of the Articles of Association.
Explanation regarding the authorisation of
the members of the management, particularly
authorisations to issue or purchase own shares
(Point 9 of the eight paragraph of Article 70 of the ZGD-1)
No authorisation exists which would authorise the
members of the management to issue or purchase own
shares of the Bank.
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.

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5. INFORMATION ON THE WORK AND KEY POWERS OF THE SHAREHOLDERS’ MEETING
AND OF ITS KEY POWERS, AND A DESCRIPTION OF SHAREHOLDERS’ RIGHTS AND THE
METHOD OF THEIR EXERCISING
The General Meeting is a body of the Bank through
which shareholders exercise their rights, which include,
among others: adopting and amending the Articles of
Association of the NLB d.d., use of distributable profit,
granting a discharge from liability to the members of
the Management and Supervisory Board, changes to
the Bank’s share capital, appointing and discharge
members of the Supervisory Board who represent
the shareholders’ interests, remuneration and profit-
sharing by the members of the Management Board and
employees, annual schedules, and characteristics of
issues of securities convertible into shares and equity
securities of the Bank.
The General Meeting is convened by the Management
Board. The General Meeting may be convened by the
Supervisory Board in cases where the Management
Board fails to convene the General Meeting or where
a convocation is necessary to ensure unhindered
operations of the Bank. The Supervisory Board may
amend the agenda of the General Meeting convened in
line with the bylaws.
As a rule, the General Meeting shall be convened
at the registered office of the Bank, yet it may also
be convened at another venue specified by the
convenor. The Management Board may stipulate
that shareholders may attend or vote before or at the
General Meeting by electronic means without their
physical presence. The General Meeting of shareholders
shall adopt resolutions by a simple majority of the votes
cast unless the applicable laws or the Bank’s Articles
of Association stipulate a larger majority or other
conditions (adoption and amendments of the Articles of
Association, issue of convertible bonds or other equity
securities of the Bank, exclusion of a pre-emptive right
of existing shareholders, decrease in share capital, the
status restructuring of the Bank, liquidation of the Bank,
and discharge of Supervisory Board members).
The shareholders have the right to participate in the
General Meeting, the voting right, the pre-emptive right
to subscribe for new shares in case of share capital
increase, the right to profit participation (dividends), the
right to a share in surplus in the event of liquidation or
bankruptcy of the Bank, and the right to be informed.
According to Article 296 of the Companies Act, NLB
informs shareholders of their rights as shareholders
in an Information on the Rights of Shareholders that is
published among the documents for the convocation
of each General Meeting (i.e., on the expansion of the
agenda, proposals by shareholders, voting proposals by
shareholders’, and the shareholders right to be informed).
There were two General Meetings in 2024. At the 42nd
General Meeting dated 17 June 2024, shareholders
took note of the adopted NLB Group Annual Report
2023 and adopted the Report of the Supervisory Board
on the results of the examination of the NLB Group
Annual Report 2023. They also adopted the Report on
Remuneration for the members of the Management
Body of NLB d.d. in the 2023 Business Year, the
Additional information to the Report on Remuneration
in the 2023 Business Year on the basis of SSH’s Baselines
and the Internal Audit Report for 2023, adopted
decisions on the election of Supervisory Board members
(as already mentioned above) and voted on the
Remuneration Policy for the Members of the Supervisory
Board of NLB d.d. and the Members of the Management
Board of NLB d.d.
The General Meeting also adopted decisions on the
allocation of distributable profit for the 2023 (the first
dividend payment of EUR 5.5 gross per share or EUR
110 million was paid out on 26 June 2024) and granted
a discharge from the liability to the members of the
Management Supervisory Boards.
At the 43rd General Meeting held on 9 December 2024,
the shareholders confirmed the payment of the second
dividend at EUR 5.5 gross per share or EUR 110 million
(paid out on 16 December 2024). Together, both pay-outs
in the amount of EUR 220 million from the profit generated
in 2023, represent a 100% increase from dividend
payments made that year. The outcome of the vote is
available to all interested stakeholders on NLB’s website.

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6. INFORMATION ABOUT THE COMPOSITION AND WORK OF THE MANAGEMENT AND
SUPERVISORY BOARDS AND THEIR COMMITTEES*
6. 1. Composition of the
Management Board*
The composition of the Management Board has
remained unchanged since May 2022, and is as follows:
Blaž Brodnjak as President & CEO; and the following
members: Archibald Kremser as Chief Financial Officer
(CFO); Peter Andreas Burkhardt as Chief Risk Officer
(CRO); as well as Hedvika Usenik as Chief Marketing
Officer (CMO) who is responsible for Retail Banking
and Private Banking; Antonio Argir who is responsible
for Group governance, payments and innovations,
and Andrej Lasič as CMO, who is responsible for
Corporate and Investment Banking. The mandates of
Blaž Brodnjak, Archibald Kremser, and Peter Andreas
Burkhardt expire in July 2026, while the mandates of
Hedvika Usenik, Antonio Argir, and Andrej Lasič expire
in April 2027.
Work of the Management Board
In 2024, the Management Board prepared a new Group
Strategy 2030 that was adopted by the Supervisory
Board. The strategy stipulates a doubling of the NLB
Group balance sheet (more than EUR 50 billion assets),
recurring revenues of more than EUR 2 billion, and a
profit of more than EUR 1 billion by 2030, combining
organic growth with selected M&As. The new strategy is
designed to enable NLB Group to grow and develop in
a rapidly changing financial environment. The strategy
includes key goals and directions for the future, such as
digitalisation, sustainable development, and expansion
into new markets.
In line with the new strategy, NLB launched an all-cash
voluntary public takeover offer aimed at acquiring control
over Addiko Bank AG for all issued and outstanding
Addiko Bank AG shares, requiring acceptance for at least
75% of its issued shares. By 16 August 2024, the offer did
not achieve a sufficient acceptance percentage of shares,
so the offer was not successful.
The Management Board worked on an acquisition
that marks NLB’s re-entry into the Croatian market
with Leasing Services after nearly three decades. After
obtaining all regulatory approvals in September 2024,
NLB completed the transaction and became the sole
shareholder of SLS HOLDCO, Ljubljana, the parent
company of Summit Leasing Slovenija, Ljubljana and
its Croatian subsidiary Mobil Leasing, Zagreb, together
forming SLS Group.
In line with the new NLB Group Strategy, a subsidiary
company, NLB Skladi, Ljubljana successfully completed
the takeover of Generali Investments, Skopje (renamed
NLB Fondovi, Skopje).
The Management Board is aware that digitalisation is
one of the key strategic priorities for NLB Group, which
aims to streamline processes, improve scalability, and
increase efficiency. To that extent, NLB enhanced its
digital services, as Apple Pay became available to NLB
customers in Slovenia and Montenegro, and Google
Pay became available to NLB customers in Slovenia,
Montenegro, North Macedonia, Bosnia and Herzegovina,
Kosovo and Serbia, while Garmin Pay became available
in Slovenia, Montenegro, North Macedonia, Bosnia and
Herzegovina, and Kosovo. In 2024, NLB Group continued
its digital transformation, which included transitioning
to a fully digital business model. This involved using
advanced technologies such as artificial intelligence (AI),
cloud services, and data analytics.
The Management Board stayed focused on the growth
of its core business and was aware of all the possible
risks and eventual distresses, while the Bank helped
customers facing difficulties due to strengthened market
conditions. In 2024, NLB Group delivered remarkable
business results. They enabled the Bank to pay out a
distributable profit for 2023 in the form of dividends in a
total amount of EUR 220 million, thereby reaffirming NLB
Group’s stable and successful business operations and
strong capital position.
The Management Board is deeply aware of the Banks’
vital role in fighting climate change by supporting
the global transition of the real economy towards
net-zero, and implementing sustainable practices as
key drivers of long-term business success. The Group
has integrated a sustainability perspective and ESG
factors (environmental, social and human rights, and
governance) in the new Group Strategy and into its daily
operations. The Group’s progress was also recognised
by ratings. In November 2024, where NLB Group
received a Sustainalytics ESG Risk Rating of 10.5, which
was assessed as being at a low risk of experiencing
material financial impacts driven by ESG factors. That
rating places NLB in the top 5 percentile of all banks
assessed by Morningstar Sustainalytics. Besides
environmental issues, the Management Board is equally
active in addressing social and governance topics,
advocating equal opportunities, as well as independent
and professional corporate governance.
Detailed information on the composition of the
Management Board can be found in Table 38 in
Appendix of this statement.
6. 2. Composition of the
Supervisory Board*
At the beginning of 2024, the composition of the
Supervisory Board was as follows: Primož Karpe –
Chairman; Shrenik Dhirajlal Davda – Deputy; David
Eric Simon, Verica Trstenjak, Islam Osama Zekry, Mark
William Lane Richards, Cvetka Selšek, André-Marc
Prudent-Toccanier (shareholders’ representatives); and
Sergeja Kočar and Tadeja Žbontar Rems (employee
representatives). As the mandates of Primož Karpe,
David Eric Simon, and Verica Trstenjak expired in
2024, three members were proposed for election at the
forthcoming General Meeting in June 2024.
The General Meeting of Shareholders in June 2024
elected Primož Karpe, Natalia Olegovna Ansell,
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.
The reference includes subchapter 6.1 - only the first paragraph, and subchapter 6.2, paragraph 1 and subchapter Statement of Independence of the Members of the Supervisory Board.

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and Luka Vesnaver as members of the Supervisory
Board of NLB. Luka Vesnaver took up his office as a
member of the Supervisory Board on 30 September
2024, while Natalia Olegovna Ansell took up her office
on 8 November 2024 (both after the ECB adopted a
decision not to object to their appointments).
Primož Karpe was elected as President of the
Supervisory Board on 7 July 2024 for the third time in
a row. The Supervisory Board also consists of Deputy
Chairman Shrenik Dhirajlal Davda, Islam Osama Zekry,
André-Marc Prudent-Toccanier, Mark William Lane
Richards, Cvetka Selšek, and employee representatives
Tadeja Žbontar Rems (whose mandate expires in 2025)
and Sergeja Kočar (re-appointed in 2024 by the NLB
Workers’ Council for another term). The mandate of
Islam Osama Zekry expires in 2025, while the mandate
of Shrenik Dhirajlal Davda, Mark William Lane Richards,
Cvetka Selšek and André-Marc Prudent-Toccanier
expires in 2027.
Statement of Independence of the Members of the
Supervisory Board*
In accordance with Article 16 of the Articles of
Association of NLB, all Supervisory Board members
must be independent experts. Persons representing the
interests of employees in the Supervisory Board of the
Bank are considered independent despite the existence
of an employment relationship with the Bank upon
fulfilling certain terms and conditions.
A Statement of Independence, in which they declare
themselves on their meeting of the criteria of a conflict
of interest, is provided by a candidate for a function of
a member of the Supervisory Board, upon each change
that would mean a change of his/her independence
status, and once a year (with the new statements
published as of February 2025). The statement is
published on the Bank’s website.
Work of the Supervisory Board
In 2024, the Supervisory Board held seven regular, five
extraordinary, and seven correspondence sessions.
In its work, the Supervisory Board of NLB received
professional assistance from five operational committees
(as further defined below). Based on their findings, the
Supervisory Board passed the appropriate resolutions.
At the beginning of May 2024, the Supervisory Board
adopted a new business strategy until 2030. The
strategy is very ambitious, with the aim of transforming
the Bank. It is focused on unlocking even more
shareholder value, backed by higher dividend payout
ratios and/or inorganic equity value creation. It
envisages doubling the balance sheet total of NLB
Group (to more than EUR 50 billion), also by tapping into
the untapped revenue pools that exist already today,
with regular revenues of more than EUR 2 billion and a
target profit of more than EUR 1 billion by 2030 (through
a combination of organic growth and selected mergers
and acquisitions), while at the same time, the strategic
goal of the Group remains to create sustainable growth
to support individuals and companies.
Throughout the year, the Supervisory Board
acknowledged regular reports on documents received
from the regulator(s), namely, the BoS and ECB, and the
implementation of the requirements of regulators. The
Supervisory Board acted within its powers to ensure that
the Bank’s business goals, strategies, and policies were
properly coordinated with the strategies and policies for
assuming and managing risks. The Supervisory Board
was regularly informed on the risk profile of the Group
and the corresponding types of risk to steer the Group’s
fulfilment of internal strategic objectives and all external
requirements. Tackling a comprehensive assessment
of the main risks and vulnerabilities for NLB Group, the
Supervisory Board adopted the IT Security Architecture
and Protection of the NLB Group and updated NLB.
Moreover, key strategic risk documents such as the NLB
Group Risk Appetite, the NLB Group Risk Strategy, the
IRRBB management report and improvement agenda,
and the NLB Group Recovery Plan were regularly
revised, upgraded, and discussed.
The functioning of NLB management bodies has always
been a priority of a Supervisory Board. To that extent,
the Supervisory Board adopted the Internal Audit’s
Annual Report for 2024, the Internal Audit Plan (2025 &
the long-term plan), the Action Plan for Compliance &
Integrity for 2025, the regular periodic reports on the
Internal Audit, Compliance, IT and Cyber Security, and
monitored implementation of the Policy on the Provision
of Diversity of the Management Body and senior
management by adopting the Annual review of the
Diversity Policy of the Bank. In line with increased focus
on the risk culture, and impact on how incentives align
risk-taking behaviour with NLB’s risk profile and long-
term interests, the Supervisory Board also approved
goals for each member of the Management Board of
NLB, as well as adopted changes to the Remuneration
Policy of the members of the Supervisory Board of NLB
d.d. and members of the Management Board of NLB d.d.
(on 17 June 2024 approved by the General Meeting of
shareholders, whereby the vote on this resolution is of a
consultative nature in accordance with ZGD-1).
NLB Group strives to actively contribute to a more
balanced and inclusive economic and social system.
The Supervisory Board monitored the implementation
and effectiveness of NLB Group’s Strategy and adopted
the regular NLB Group Sustainability Implementation
Updates. The Supervisory Board issued approvals to
the Management Board related to the adopted NLB
Group Annual Report 2023 and NLB Group Sustainability
Report 2023, Information on NLB Group’s sustainability
reporting process for 2024, and engagement of the NLB
Management and Supervisory Boards in the Double
Materiality Analysis, the Annual Internal Audit Plan,
the Plan of Compliance & Integrity, and adopted the
Comprehensive Opinion of the Internal Audit.
Furthermore, the Supervisory Board adopted decisions
regarding the convocation of the two General
Meetings of shareholders. At the General Meeting of
shareholders dated 17 June 2024, the General Meeting
acknowledged itself with the NLB Group Annual
Report 2023, Report of the Supervisory Board of NLB,
on the results of the examination of the NLB Group
Annual Report 2023, Report on Remuneration for the
members of the Management Body of NLB d.d. in the
2023 Business Year, Independent Auditor Report, as
well as on Additional information to the Report on
Remuneration in the 2023 Business Year on the basis
of SSH’s Baselines and acknowledged the adopted
Internal Audit Report for 2023. The General Meeting
adopted a decision on the allocation of distributable
profit for 2023 (the first tranche of the distributable profit
for 2023 at EUR 5.5 gross per share or EUR 110 million)
and granted a discharge from liability to the members
of the Management and Supervisory Boards. The
General Meeting adopted decisions on four proposed
candidates for the Supervisory Board and determined
payments to members of the Supervisory Board of
*Incorporation by reference: The reference is made to this chapter from the Sustainability Statement chapter ESRS-2 GOV-1 The role of administrative, supervisory and management bodies.

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NLB and its committees. The shareholders adopted
changes to the Remuneration Policy for the Members
of the Supervisory Board of NLB d.d. and the Members
of the Management Board of NLB d.d. (the vote on this
resolution is of a consultative nature).
The General Meeting of shareholders dated 9 December
2024, adopted a decision on the allocation of the second
tranche of the distributable profit for 2023 at EUR 5.5
gross per share or EUR 110 million, making a total
dividend pay-out in 2024 EUR 220 million. EUR 110 million
were already paid-out to shareholders in June 2024, and
approved the Remuneration Policy for the Members of
the Supervisory Board of NLB d.d. and the Members of
the Management Board of NLB d.d., whereby the vote
on this resolution was of a consultative nature.
During the year, the Supervisory Board adopted
periodic reports of the Internal Audit and Compliance,
and issued approval for the transactions with persons
in a special relationship with the Bank, and for the
conclusion of legal transactions in accordance with
Article 170 of the Banking Act.
According to the recommendation of the Slovenian
Corporate Governance Code for Listed Companies,
the evaluation of efficiency and self-assessment of the
Supervisory Board of NLB and the Audit Committee
of NLB was performed by the Slovenian Directors’
Association (SDA) at the beginning of 2024. Based on
the findings of SDA, an Action Plan was made, and
deficiencies were eliminated.
Throughout the year, the Supervisory Board has
maintained a well-balanced professional relationship
with the Management Board and enjoyed timely,
comprehensive, and data-supported inputs from the
latter, enabling the Supervisory Board to adopt all its
decisions in line with the professional interests of the
Bank, whilst always adhering to banking regulations
and its statutory powers.
To ensure transparent decision-making at the
Supervisory Board and sessions of committees,
members of the Supervisory Board, in particular, take
into account all necessary precautionary measures to
avoid conflicts of interest.
Pursuant to Article 282 of the Companies Act (ZGD-1)
and the above report, the Supervisory Board of NLB
established and ensured that it regularly and thoroughly
monitored the Bank’s and NLB Group’s operations in
2024 within its powers, and efficiently supervised the
Bank’s and NLB Group’s management and operations.
The composition of the Supervisory Board members is
described in Table 39 in Appendix of this statement.
6. 3. The Supervisory Board
Committees
All five Committees for the Supervisory Board function
as consulting bodies of the Supervisory Board of NLB
and discuss the material and proposals of Management
Board of NLB for the Supervisory Board meetings
related to a particular area. The Supervisory Board has
the following committees:
• The Audit Committee
• The Risk Committee
• The Nomination Committee
• The Remuneration Committee
• The Operations and IT Committee.
Committees are composed of at least three members of
the Supervisory Board, although at the end of 2024 the
actual number of members in the committees was five.
The Workers' Council can nominate one Supervisory
Board member – a representative of the workers to each
Committee. The member of the Committee may only be
appointed from among the members of the Supervisory
Board. The term of office of the Chair, the Deputy Chair,
and members of the Committee should not exceed
their term of office as Supervisory Board members. The
responsibilities of Committees are defined in the Rules of
Procedure of the Committees of the Supervisory Board
of NLB d.d. (November 2024).
6.3.1 The Audit Committee of the Supervisory Board
of NLB
The Audit Committee monitors and prepares draft
resolutions for the Supervisory Board on accounting
reporting, internal control and risk management, internal
audit, the compliance of operations, and external audit. It
also supervises the setup of policies, monitors reporting
procedures related to sustainability, and monitors the
implementation of regulatory measures.
At the end of 2024, the composition of the Committee
was as follows: Cvetka Selšek (Chairwoman),
André-Marc Prudent-Toccanier (Deputy Chairman),
Primož Karpe, Tadeja Žbontar Rems and Luka Vesnaver
(members). Changes in the Committee’s membership
that occurred during the year, as well as the academic
degrees of the Audit Committee members are reflected
in the chart on the Supervisory Board Committees (Table
39 in Appendix below).
There were six regular and one extraordinary sessions
of the Audit Committee. The following is a summary of
the key topics considered by the Audit Committee:
• Report of the NLB Group Operations and Business
Performance Indicators for NLB d.d. and NLB Group for
2023; NLB Group Annual Report 2023; KPMG External
Auditor’s report after the final audit of financial
statements 2023; Internal Audit Overall Opinion for
2023; Internal Audit Annual Report for 2023; Corporate
Governance Statement of NLB; Statement on the
Management of Risk, NLB Group Sustainability Report
for 2023; Report of the Supervisory Board of NLB on
the results of the examination of the NLB Group Annual
Report 2023;
• Report of the of the Audit Committee of NLB on the
statutory audit for financial year 2023; Assessment of
the satisfaction rating at the NLB Group level regarding
the quality of audit services provided by the external
auditing firm KPMG for 2023; Annual Report for the
2023 ECRA compliance risk assessment at the NLB and
NLB Group levels;
• Regular interim reports on the operations of the NLB
Group, Periodic Internal Audit Reports, Compliance,
and Integrity Reports, Anti-Money Laundering Reports;
• NLB Group Sustainability Implementation update;
External audit of the NLB Group’s Sustainability
Report 2024 and an increase in the price of the audit
of the Annual Report due to the merger of N Banka;
Presentation of the audit plan for 2024 audit by auditor
KPMG; Information on NLB Group’s sustainability
reporting process for 2024 and engagement of the NLB
Management and Supervisory Board in the Double
Materiality Analysis;
• Reports of the Internal Audit of NLB; NLB Group
Internal Audit Plan (2025 & long-term), Reports of the
Compliance of NLB; Action Plan for Compliance and
Integrity Centre for 2025;
• Reports on the documents received from the BoS and

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ECB, and on the implementation of the requirements of
the BoS and ECB;
• Appointment / Prolongation of the mandate and
a salary increase for the Director of Global Risk
and for the Director of Compliance and Integrity;
a Salary increase for the Director of Internal Audit;
Confirmation of the goals assessment of the heads
of control or supervisory functions for the year
2023; Acknowledgment with Self-assessment of the
performance, effectiveness, and efficiency of the Group
Compliance function, and with an Evaluation of the
Audit Committee;
• Information about the costs of the Management and
Supervisory Boards; Cash withdrawals in Branches for
Legal Entities in NLBG (excl. Slovenia);
• Integrity and Compliance Policy of the NLB d.d. and
the NLB Group; Approval of Other assurance and
non-assurance services pre-approval Policy for NLB
and NLB Group; Information on updated Rules on the
relations of NLB d.d. and the Audit Committee with the
audit firm; Internal Audit Manual; Internal Audit Charter;
• NLB Audit Committee Self-Assessment for 2023 (Status
Report) and approval of the Action Plan.
The Audit Committee performs its tasks both at the
meetings themselves and outside of the meetings.
In addition to considering materials at the meetings
themselves and preparing proposals for the Supervisory
Board, the Committee also meets regularly with
representatives of professional services for individual
areas covered by the Committee. The President of the
Committee also meets regularly with representatives of
the external auditor and regulators.
In 2024, the Audit Committee carried out a self-assessment
of its work (evaluation of the year 2023) with the help of an
external independent evaluator, the Slovenian Directors’
Association. Based on the findings, an action plan was
prepared, which was discussed and approved at the
Supervisory Board meeting in March 2024.
6.3.2 The Risk Committee of the Supervisory Board
of NLB
The Risk Committee monitors and drafts resolutions
for the Supervisory Board in all risk areas relevant to
the Bank’s operations. It is consulted on the Group’s
current and future risk appetite, the corresponding
risk profile and risk management strategy, and helps
carry out control over senior management concerning
implementation of the risk management strategy.
At the end of 2024, the composition of the Committee
was as follows: André-Marc Prudent-Toccanier
(Chairman), Cvetka Selšek (Deputy Chairwoman),
Shrenik Davda, Luka Vesnaver, and Natalia Olegovna
Ansell (members). Changes in the Committee’s
membership that occurred during the year are reflected
in the chart on Supervisory Board Committees (Table 39
in Appendix below).
There were seven regular sessions of the Risk Committee
in 2024. The following is a summary of key topics
considered by the Risk Committee:
• Risk Report (Dashboard) of NLB and NLB Group;
Periodic Reports on information security in NLB and
NLB Group; Pillar III Disclosures for 2023 and periodic
disclosures for 2024;
• Internal liquidity adequacy process (ILAAP) for 2023;
The Internal Capital Adequacy Assessment Process
(ICAAP) for 2023; ALM update: IRRBB management
report and improvement agenda;
• Report on the documents received from the BoS and
the ECB, and the report on the implementation of the
requirements;
• IT Security Architecture and Protection of NLB Group;
The Trinity of Data Quality;
• Presentation & Report on the Top 50 groups of clients
by exposure in the NLB Group; Top 20 restructuring
cases; Report on passive court proceedings in NLB and
NLB Group; Information about the final deletions of the
receivables over EUR 5 million from the off-balance for
2023; Report on the real estate market and collateral
management for NLB for 2023;
• Consent of goals assessment of the heads of control or
supervisory functions for the year 2023;
• NLB Group Risk Strategy update; Risk Appetite NLB
Group update; NLB Group Recovery Plan;
• Annual Review of Prior Consent for Limit application
(that exceeds certain percentages of NLB Tier 1 capital);
Prior consent of the Supervisory Board of NLB to
conclude legal transactions with Central Banks; Prior
consent for the conclusion of legal transactions with a
client in a special relationship with NLB.
6.3.3. The Nomination Committee of the Supervisory
Board of NLB
The Nomination Committee drafts proposed
resolutions for the Supervisory Board concerning the
appointment and dismissal of the Management Board
members; recommends candidates for Supervisory
Board members; recommends to the Supervisory
Board the dismissal of members of the Management
and Supervisory Boards (representatives of capital);
prepares the content of executive employment contracts
for the President and members of the Management
Board; evaluates the performance of the Management
and Supervisory Boards; and assesses the knowledge,
skills, and experience of individual members of the
Management and Supervisory Boards and the bodies
as a whole.
At the end of 2024, the composition of the Committee
was as follows: Primož Karpe (Chairman), Mark Richards
(Deputy Chairman), Sergeja Kočar, Islam Osama
Zekry, and Shrenik Davda (members). Changes in the
Committee’s membership that occurred during the
year are reflected in the chart on Supervisory Board
Committees (Table 39 in Appendix below).
There were four regular and one extraordinary session
of the Nomination Committee in 2024. The following is
a summary of key topics considered by the Nomination
Committee:
• Assessment of collective suitability of the Management
Board of NLB; Assessment of collective suitability of
the Supervisory Board of NLB; Regular yearly fit and
proper assessment of members of the Supervisory
Board for 2024; Reassessment of fit and proper for
Management Board member;
• Election of members of the Supervisory Board of NLB;
• Annual review of the Diversity Policy of the Bank;
• Suitability assessment of the members of the
Management Board, Assessment of collective suitability
of the Supervisory Board.
6.3.4. The Remuneration Committee of the Supervisory
Board of NLB
The Remuneration Committee carries out expert and
independent assessments of the remuneration policies
and practices and formulates initiatives for measures
related to improving the management of the Bank’s
risks, capital, and liquidity; prepares proposals for

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Financial
Report
remuneration-related decisions of the Supervisory
Board; and supervises the remuneration of senior
management performing the risk management and
compliance functions.
At the end of 2024, the composition of the Committee was
as follows: Shrenik Davda (Chairman), Mark William Lane
Richards (Deputy Chairman), Islam Osama Zekry, Sergeja
Kočar, and André-Marc Prudent-Toccanier (members).
Changes in the Committee’s membership that occurred
during the year are reflected in the chart on Supervisory
Board Committees (Table 39 in Appendix below).
There were five regular, three extraordinary and
one correspondence sessions of the Remuneration
Committee in 2024. The following is a summary of key
topics considered by the Remuneration Committee:
• Proposal of financial goals of NLB Group, goals for
each member of the Management Board of NLB
for the short-term and long-term incentive (STI and
LTI), additional performance criteria for subsequent
performance period, and financial goals of NLB;
Proposal for the confirmation of fulfilment of conditions
for the increase of the salaries of the members of
Management Board of NLB; and for the conclusion of
annexes to their employment contracts;
• Confirmation of the Assessment of the NLB Group
and NLB financial results, goals assessment of the
members of the Management Board of NLB d.d. and
heads of control or supervisory functions for the year
2023; Confirmation of goals of identified employees
in controlled and supervisory functions for 2024;
Confirmation of an annual self-assessment of the
identified employees (2023);
• Awarding and payment of the variable part of the
salary for the business year 2023 for the members of
the Management Board and payment of the deferred
part of the variable part of the salary for previous
years for the members of the Management Board
and identified staff – heads of control or supervisory
functions;
• Draft Remuneration Policy for the Members of the
Supervisory Board of NLB d.d. and the Members
of the Management Board of NLB d.d.; Proposal of
Amendments to the Remuneration Policy for employees
in NLB d.d. and in NLB Group.
6.3.5. The Operations and IT Committee of the
Supervisory Board of NLB
The Committee monitors and prepares draft resolutions
for the Supervisory Board, whereby the main tasks
that it performs are the following: monitoring the
implementation of the IT Strategy including the
infrastructure and use of AI, its orientation in the area of
sustainability, goals, and measures for their achievement,
related to the Bank’s strategy, IT Security Strategy, and
Operations Strategy; monitoring the management of
information technologies; monitoring integration of AI
into operations; monitoring responsibility in the AI area;
monitoring compliance with the rules on AI; monitoring
key projects and initiatives related to operations, IT
and artificial intelligence; monitors key operations
and IT KPI’s and service quality indicators; monitors
key operations and IT projects and initiatives related
to operations, IT and artificial intelligence; monitors
operating risks in the area of Operations, IT, and Security;
monitors the recommendations for ensuring and
increasing the level of information/cyber security issued
by CISO; addresses the report on potential violations,
events, and incidents in the area of IT security; and
monitors the Target Operating Model implementation
in the areas of IT, the Security Operating System,
Competence Centre, and Operations.
At the end of 2024, the composition of the Committee was
as follows: Mark William Lane Richards (Chairman), Islam
Osama Zekry (Deputy Chairman), Primož Karpe, Tadeja
Žbontar Rems, and Natalia Olegovna Ansell (members).
Changes in the Committee’s membership that occurred
during the year are reflected in the chart on Supervisory
Board Committees (Table 39 in Appendix below).
There were four sessions of the Operations and IT
Committee 2024. The Operations and IT Committee
acknowledged itself with:
• Periodic Review of IT KPIs;
• Digitalise the Bank (Product / Process / Digital metrics)
& periodic reports; Initiative progress, status, lessons
learned (BackBase case) & periodic reports;
• Report on implementation of the Procurement Strategy.

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Financial
Report
7. DESCRIPTION POLICY ON THE PROVISION OF DIVERSITY OF THE MANAGEMENT BODY
AND SENIOR MANAGEMENT
Pursuant to Article 70 (paragraph 7) of the ZGD-1, NLB
included information on description of the diversity
policy implemented in relation to representation in the
management or control bodies of the company (from
the point of view of gender and other aspects, and a
statement of the goals and results of the policy) in the
Sustainability Statement of this Annual Report (Chapter:
General Information, Sub-Chapter: The Role of the
Administrative, Management And Supervisory Bodies),
which is part of this Annual Report.
7. 1. Statement on changes that
occurred between the end of
the accounting period up to the
publication of this statement
In accordance with Guidelines on Disclosure for
Listed Companies, point 7.3.2 (Ljubljana Stock
Exchange, 25 March 2024), NLB hereby states that
on 20 February 2025, the Supervisory Board of NLB,
following a recommendation from the Management
Board, appointed Reinhard Höll as the seventh
member of the Management Board. Following the
necessary approvals, he will assume the role of
Chief Transformation Officer (CTO), overseeing the
acceleration of the mobile/digital-first business model
transition of NLB and its Group members.
Ljubljana, 20 February 2025
Management Board of the NLB
Hedvika Usenik
Andrej Lasič
Archibald Kremser
Peter Andreas Burkhardt
Antonio Argir
Blaž Brodnjak
Member
Member
Member
Member
Member
Chief Executive Officer
Supervisory Board of NLB
Primož Karpe
President of the Supervisory Board

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Statement
Financial
Report
Table 38: Composition of Management in financial year 2024
Name and
Surname
Position held
(President,
Member)
Area of work
covered within the
Management Board
First appointment
to the position
Conclusion
of the position/
term of office
Citizenship
Year of birth
Qualification
Professional
profile
Membership in
supervisory bodies in
companies not related to
the company
Blaž Brodnjak
President
CEO
6 July 2016(i)
6 July 2026
Slovenian
1974
MBA
Banking/Finance
Bank Association
of Slovenia,
Basketball Club
Cedevita Olimpija
Archibald Kremser
Deputy CEO/
Member
CFO
31 July 2013
6 July 2026
Austrian
1971
MBA
Banking/Finance
Peter Andreas
Burkhardt
Member
CRO
18 September
2013
6 July 2026
German
1971
MBA
Banking/Finance
Antonio Argir
Member
Responsible for
Group governance,
payments and
innovations
28 April 2022
28 April 2027
Macedonian
1975
MBA
Banking/Finance
Andrej Lasič
Member
CMO (responsible
for Corporate and
Investment Banking)
28 April 2022
28 April 2027
Slovenian
1970
Bachelor’s
degree
Banking/Finance
Bank Association
of Slovenia
Hedvika Usenik
Member
CMO (responsible for
Retail Banking and
Private Banking)
28 April 2022
28 April 2027
Slovenian
1972
MBA
Banking/Finance
Institute for Economic
Research,
British–Slovenian
Chamber of Commerce
(i) Member of the Management Board since 2012.

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Financial
Report
Table 39: Composition of Supervisory Board and Committees in financial year 2024
Name and
Surname
Position
held
(Chairman,
Deputy
Chairman,
Member)
First
appointment
to the
position
Conclusion
of the
position /
term of
office
Representative
of the company‘s
capital structure /
employees
Attendance
at SB session
in regard
to the total
number of SB
session (for
example 5/7)
applicable
on his/her
mandate
Gender
Citizenship
Year of
birth
Qualification
Professional
profile
Independence
under Article
23 of the Code
(YES/NO)
Existence
of conflict
of interest,
in the
business
year
(YES/NO)
Membership in
supervisory bodies in
other companies or
institutions
Primož
Karpe
Chairman
10 February
2016
2028
Representative
of the company‘s
capital structure
7/7
male
Slovenian
1970
MSc
Banking/
Finance
YES
YES
Angler d.o.o., Zagreb
Shrenik
Dhirajlal
Davda
Deputy
Chairman/
Member
10 June 2019
2027
Representative
of the company‘s
capital structure
7/7
male
British
1960
MBA
Finance
YES
NO
Charity Commission of
England and Wales
IPSO, UK
David Eric
Simon
Member
4 August
2016
17 June
2024
Representative
of the company‘s
capital structure
4/4
male
British
1948
Higher
National
Diploma in
Business
Studies
Banking/
Finance
YES
NO
Jihlavan a.s.
Jihlavan Real Estate a.s
Czech Aerospace
industries sro, Praga
Central Europe
Industry Partners a.s.
Islam
Osama
Zekry
Member
14 June 2021
2025
Representative
of the company‘s
capital structure
7/7
male
Egyptian
1977
PhD
IT
YES
NO
Commercial
International
Bank, Egypt
CIB Housing
association, Egypt
Mark
William
Lane
Richards
Member
10 June 2019
2027
Representative
of the company‘s
capital structure
7/7
male
British
1966
MSc
Banking/
Finance
YES
NO
Enza Group
Global, Cairo
BPL Global
(Lloyds of London
insurance Broker)
VenCap International
plc, UK
Verica
Trstenjak
Member
15 June 2020
17 June
2024
Representative
of the company‘s
capital structure
4/4
female
Slovenian
1962
PhD
Law
YES
NO
Cvetka
Selšek
Member
19 June 2023
2027
Representative
of the company‘s
capital structure
7/7
female
Slovenian
1951
University
Degree
Banking/
Finance
YES
NO
Honourable Tribunal of
Managers’ Association
of Slovenia
André-Marc
Prudent-
Toccanier
Member
19 June 2023
2027
Representative
of the company‘s
capital structure
7/7
male
French
1955
MSc
Banking/
Finance
YES
NO
Natalia
Olegovna
Ansell
Member
17 June 2024
2028
Representative
of the company‘s
capital structure
1/1
female
British
1972
Finance
YES
NO
Equity Bank Kenya
Limited, Nairobi
Luka
Vesnaver
Member
17 June 2024
2028
Representative
of the company‘s
capital structure
2/2
male
Slovenian
1972
MSc
Banking/
Finance
YES
NO
British Slovenian
Chamber of Commerce
Managers’ Association
of Slovenia
Alpine Ski Club
Olimpija, Ljubljana
Sergeja
Kočar
Member
17 June 2020
2028
Representative
of the company’s
employees
6/7
female
Slovenian
1968
MSc
Management
YES
NO
Tadeja
Žbontar
Rems
Member
22 January
2021
2025
Representative
of the company’s
employees
7/7
female
Slovenian
1968
MSc
IT
YES
NO

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Name and Surname
Membership in committees (audit, nominal,
income committee, etc.)
First appointment to the
position
Conclusion of the
position/term of office
Chairman/Deputy
Chairman/Member
Attendance at sessions of
SB’s Committees in regard
to the total number of SB’s
session (applicable on his/her
mandate)(i)
Shrenik Dhirajlal Davda
Remuneration Committee
28 June 2019
2027
Chairman
5/5
Mark William Lane Richards
Remuneration Committee
26 June 2020
2027
Deputy Chairman
5/5
Islam Osama Zekry
Remuneration Committee
9 September 2024
2025
Member
2/2
André-Marc Prudent-Toccanier
Remuneration Committee
9 September 2024
2027
Member
2/2
Sergeja Kočar
Remuneration Committee
26 June 2020
2024
Member
5/5
Primož Karpe
Nomination Committee
15 April 2016
2024
Chairman
5/5
Mark William Lane Richards
Nomination Committee
18 September 2023
2027
Deputy Chairman
5/5
Shrenik Dhirajlal Davda
Nomination Committee
9 September 2024
2027
Member
2/2
Sergeja Kočar
Nomination Committee
26 June 2020
2024
Member
5/5
Islam Osama Zekry
Nomination Committee
18 September 2023
2025
Member
5/5
Cvetka Selšek
Audit Committee
9 September 2024
2027
Chairwoman
6/6
André-Marc Prudent-Toccanier
Audit Committee
9 September 2024
2027
Deputy Chairman
1/1
Primož Karpe
Audit Committee
15 April 2016
2024
Member
5/6
Tadeja Žbontar Rems
Audit Committee
9 September 2024
2025
Member
1/1
Luka Vesnaver
Audit Committee
30 September 2024
2028
Member
0/0
André-Marc Prudent-Toccanier
Risk Committee
18 September 2023
2027
Chairman
7/7
Cvetka Selšek
Risk Committee
18 September 2023
2027
Deputy Chairwoman
7/7
Shrenik Dhirajlal Davda
Risk Committee
8 July 2021
2027
Member
7/7
Luka Vesnaver
Risk Committee
30 September 2024
2028
Member
2/2
Natalia Olegovna Ansell
Risk Committee
8 November 2024
2028
Member
1/1
Mark William Lane Richards
Operations and IT Committee
28 June 2019
2027
Chairman
4/4
Islam Osama Zekry
Operations and IT Committee
8 July 2021
2025
Deputy Chairman
4/4
Primož Karpe
Operations and IT Committee
15 April 2016
2024
Member
4/4
Tadeja Žbontar Rems
Operations and IT Committee
8 April 2021
2025
Member
4/4
Natalia Olegovna Ansell
Operations and IT Committee
8 November 2024
2028
Member
0/0
(i) There were also extraordinary sessions of the committees that are not reflected in this table.

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Statement of Management of Risk
NLB d.d.’s Management and Supervisory Boards
provide herewith a concise statement of risk
management according to Article 17 of the Decision on
Internal Governance Arrangements, the Management
Body, and the Internal Capital Adequacy Assessment
Process for Banks and Savings banks (Official Gazette of
the RS, no. 73/15 and 115/2021), Regulation (EU) 575/2013,
article 435 (Risk management objectives and policies),
point (e) and (f), as well as the EBA Guidelines on Internal
Governance (EBA/GL/2021/05) and EBA Guidelines on
Disclosure requirements (EBA GL/2016/11).
Risk management in NLB Group, representing an
important element of the Group’s overall corporate
governance, is implemented in accordance with the set
strategic guidelines, established internal policies, and
procedures which take into account European banking
regulations, the regulations adopted by the Bank of
Slovenia, the current EBA guidelines, and the relevant
good banking practices. EU regulations are followed
by NLB Group, where the Group subsidiaries operating
outside Slovenia are also compliant with the rules set by
the local regulators. NLB Group gives high importance
to the risk culture and awareness of all relevant risks
within the entire Group. Maintaining risk awareness is
engrained in the business and risk strategy of the Group.
The business and operating environment, relevant for
the Group’s operations, is changing with trends such
as sustainability, social responsibility, governance,
changing customer behaviours, emerging new
technologies, and competitors, as well as increasing new
regulatory requirements. Respectively, risk management
is continuously adapting with the aim of detecting and
managing new potential emerging risks.
NLB Group uses the ‘three lines of defence framework’
as an important element of its internal governance,
whereby the Risk management function acts as a second
line of defence. The Group’s Risk management function
has enhanced overall corporate governance, which is
reflected in lower SREP requirement in recent years. A
robust and comprehensive Risk Management framework
is defined and organised with regard to the Group’s
business and risk profiles, and is based on a forward-
looking perspective to meet internally set strategic
objectives and all external requirements. The proactive
Risk management and control system is primarily based
on Risk appetite and Risk strategy, which are consistent
with the Group’s Business and focused on early risk
identification and efficient risk management. Set
governance and different risk management tools enable
adequate oversight of the Group’s risk profile, proactive
support of its business operations and its management
by incorporating escalation procedures, and use of
different mitigation measures when necessary. In
this respect, the Group is constantly enhancing and
complementing the existing methods and processes in all
risk management segments.
NLB Group is engaged in contributing to sustainable
finance by incorporating environmental, social, and
governance (ESG) risks into its business strategies, risk
management framework, and internal governance
arrangements. With the adoption of the NLB Group
Sustainability programme, the Group implemented the
main sustainability elements into its business model.
The goal of this strategic, organisation-wide initiative
is to ensure the sustainable financial performance of
the Group by considering ESG risks and opportunities
in its operations, and to actively contribute to a more
balanced and inclusive economic and social system.
So, sustainable finance integrates ESG criteria into
the Group’s business and investment decisions for
the lasting benefit of the Group’s clients and society.
Moreover, NLB as a member of the UN Net-Zero
Banking Alliance, publicly disclosed its Net-Zero
commitment and corresponding targets. With this step,
the Bank pledged to align its lending and investment
portfolio with net-zero emissions by 2050.
The NLB Group Sustainability Committee oversees the
integration of the ESG factors to the NLB Group business
model. The management of ESG risks addresses the
Group’s overall risk management framework, namely its
credit approval process, collateral evaluation process,
and related credit portfolio management. It follows
ECB and EBA guidelines, with the tendency for their
comprehensive integration into all relevant processes.
The availability of ESG data in the region where NLB
Group operates is still lacking. Nevertheless, the Group
has set up the process of obtaining relevant ESG-related
data from its clients, being a prerequisite for adequate
decision-making and the corresponding proactive
management of ESG risks.
NLB Group plans for a prudent risk profile, optimal
capital usage, and profitable operations in the long
run, considering the risks assumed. The Business
Strategy, the Risk Appetite, the Risk Strategy, and the
key internal risk policies of NLB Group, approved by
the Management and Supervisory Boards of NLB
d.d., specify the strategic objectives and guidelines
concerning risk assumption, including the approaches
and methodologies of monitoring, measuring,
mitigating, and managing all types of risk at different
relevant levels. Moreover, main strategic risk guidelines
are consistently integrated into a regular business
strategy review, the budgeting process, and other
strategic decisions, whereby informed decision-
making is assured. NLB Group regularly monitors
its target risk appetite profile and internal capital
allocation, representing the key component of proactive
management. Risk limits usage and potential deviations
from limits or target values are regularly reported to the
respective committees and/or the Management Board
of the Bank, the Risk Committee of the Supervisory
Board, and the Supervisory Board of the Bank.
Additionally, NLB Group established a comprehensive
stress-testing framework and other early warning
systems in different risk areas with the intention of
contributing to setting and pursuing the Group’s
business strategy, to support decision-making on
an ongoing basis, to strengthen the existing internal
controls, and to enable a timely response when
necessary. The stress-testing framework includes all
material types of risk, as well as those related to ESG,
and various relevant stress scenarios or sensitivity
analyses according to the vulnerability of the Group’s
business model. Stress testing has an important role
when assessing the Group’s resilience to stressed
circumstances, namely from profitability, capital
adequacy, and liquidity, with a forward-looking
perspective. As such, it is embedded into the Group’s
Risk Management system, namely Risk Appetite,
ICAAP, ILAAP, and the Recovery Plan, as an important
component of sound risk management. Besides internal
stress testing, NLB Group, as a systemically important

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bank, also participates in the regulatory stress test
exercises carried out by the ECB.
NLB Group is the largest Slovenian banking and financial
group with an important presence in the SEE region.
In accordance with its new Strategy 2030, NLB intends
to be the leading bank in SEE and aims to provide
international best-practices across the customer and
operating models. The Group continues strengthening its
market position in its home region, actively participating
in market growth and consolidation, and promoting
the ESG agenda. Moreover, the Strategy focuses on
the transformation of NLB into the leading operating
platform in the region through rigorous simplification
and digitalisation while maintaining its prudent risk
practices. NLB Group has a well-diversified business
model. Efficient managing of risks and capital is crucial
for the Group to sustain long-term profitable operations.
Based on the Group’s business strategy, credit risk is
the dominant risk category, followed by credit spread
risk on the banking book portfolio, interest rate risk in
the banking book, operational risk, liquidity risk, market
risk, and other non-financial risks. The Group integrates
and manages ESG risk within the established risk
management framework, where the aforementioned risk
is one of risk drivers of the existing type of risks, such as
credit, liquidity, market, and operational risk. Regular
risk identification and their assessment is performed
within the ICAAP process with the aim to assure their
overall control and effective risk management on an
on-going basis.
Managing risks and capital efficiently at all levels is
crucial for NLB Group sustained long-term profitable
operations. Management of credit risk, representing
the Group’s most important risk, focuses on the taking
of moderate risks – with a diversified credit portfolio,
adequate credit portfolio quality, a sustainable cost of
risk, and ensuring an optimal return considering the risks
assumed. The liquidity risk tolerance is low. NLB Group
must maintain an appropriate level of liquidity at all
times to meet its short-term liabilities, even if a specific
stress scenario is realised. Furthermore, with the aim of
minimising this risk, the Group pursues an appropriate
structure of sources of financing. The Group limited
exposure to credit spread risk, arising from the valuation
risk of debt securities portfolio servicing as liquidity
reserves to the medium level. The NLB Group’s basic
orientation in the management of interest rate risk is to
limit unexpected negative effects on revenues and capital
that would arise from changed market interest rates and,
therefore, a medium tolerance for this risk is stated.
Moreover, in 2024 the Group comprehensively
enhanced the existing interest rate risk management.
When assuming operational risk, the NLB Group
pursues the orientation that such risk must not
significantly impact its operations. The Risk Appetite
for operational risks is low to medium, with a focus
on mitigation actions for important risks and key risk
indicators servicing as an early warning system. To
adequately manage ICT risks and ensure compliance
with the requirements of the Digital Operational
Resilience Act (DORA), a dedicated second line of
defence within the risk management function and
ITC risk management framework were established.
The conclusion of transactions in derivative financial
instruments at NLB is primarily limited to servicing
customers and hedging the Bank’s own positions. In
the area of currency risk, NLB Group thus pursues
the goals of low to moderate exposure. Based on our
environmental and climate risk assessment, the impact
of these risks is estimated as low, except for transition
risk in the area of credit risk, which is assessed as low to
medium. The tolerance for all other risk types, including
non-financial risks, is low, with a focus on minimising
their possible impacts on the Group’s operations.
The main NLB Group Risk Appetite Statement objectives
are the following:
• preservation of regulatory and internal capital
adequacy;
• fulfilment of MREL requirement;
• maintenance of low leverage;
• maintaining adequate quality of the credit portfolio,
sufficient NPL coverage, sustainable credit risk
volatility, sustainable cost of risk across the economic
cycle, limited Stage 2 exposures, sustainable industry
and individual concentration, sustainable exposure to
cross border, leverage transactions, M&A, real estate
financing and specialised lending;
• maintenance of a solid liquidity position, maintaining
stable customers’ deposits as the main funding base,
• diversification of risk in exposures to banks and
sovereigns;
• limited exposure to credit spread risk;
• limited exposure to interest rate risk;
• limited exposure to foreign exchange risk;
• sustainable exposure to ESG risks, including portfolio
decarbonisation strategy, which is based on
NZBA-aligned targets;
• sustainable tolerance to net losses from operational
and ICT risk.
Values of the most important risk appetite indicators
of NLB Group as at the end of year 2024, reflecting
interconnection between strategic business orientations,
the risk strategy and the targeted risk appetite profile,
were the following:
• Total capital ratio 18.7%,
• Tier 1 capital ratio 15.8%,
• Common Equity Tier 1 ratio (CET1) 15.3%,
• MREL ratio 37.5%
• Leverage ratio 9.9%,
• Cost-of-risk 14 bps,
• The share of non-performing exposure (NPE %)
by EBA 1.1%,
• Non-performing loans coverage ratio (NPL CR) 62.7%,
• Loan-to-deposit ratio (LTD) 73.7%,
• LCR 197.2%,
• NSFR 167.6%,
• EVE sensitivity (of 200 bps) 5.0% of capital,
• Transactional FX risk 0.7% of capital,
• No new financing of coal mining and coal-fired
electricity generation (0 EUR),
• Net losses from operational risk 13.0% of capital
requirement for operational risk.
Sustainable ESG financing in accordance with the
Environmental and Social Management System (ESMS)
is integrated in the Group’s Risk appetite and overall
risk management framework. In addition, the Group has
publicly disclosed its Net-Zero commitment, which is
addressed in the Group’s Risk Appetite. In its initial round
of NZBA targets, NLB Group has focused on the fossil
fuel-based and highly energy-intensive sectors, such as
power generation and iron and steel, and other sectors
where the Bank has substantial emissions and/or
exposure and available data. These include residential
mortgages and commercial real estate. Defined Net
Zero targets are regularly followed. Activities for setting
a second round of NZBA targets, for sectors such as
transport and agriculture, are underway.

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Lending growth, which was modest in the previous year
due to increasing interest rate trends, picked up in 2024.
During 2024, the Group’s credit portfolio remained high-
quality and well-diversified, with a stable rating structure
and lower NPLs level. There was no large concentration
in any selected industry sector. The latter is particularly
important as geopolitical tensions, the green transition,
and other macro developments could materially impact
on specific industry sectors. The Group monitored the
macroeconomic and geopolitical circumstances closely,
remaining very prudent in identifying any increase in
credit risk at a very early stage and proactive in NPL
management. Furthermore, unfavourable trends in the
German automotive industry did not severely influence
the Slovenian export-oriented industry. Having that in
mind, the Bank downgraded some selected clients in
Stage 2 and formed additional impairments. The cost-
of-risk remained at a relatively low level. The established
impairments derive from portfolio development, new
financing, and any portfolio deterioration. In contrast,
the successful collection of previously written-off
receivables and changes in risk parameters contributed
positively to a low total net impact.
The Group stayed well capitalised and well above
the risk appetite at both the Group and Banking
member levels. The liquidity position of the Group
also remained solid, with liquidity indicators high
above the regulatory requirements, indicating its low
tolerance for this risk. Significant attention was put into
the structure and concentration of liquidity reserves,
while at the same time, we considered potential
adverse negative market movements. Investment
activity continued with a balanced approach to finding
attractive market opportunities while pursuing a well-
managed credit spread and interest rate risk, as well
as capital consumption. Interest rate risk exposure
remained moderate and stayed well within the Risk
Appetite tolerance.
Consequently, NLB Group concluded the year 2024 as
self-funded, with strong liquidity and a very solid capital
position, demonstrating the Group’s financial resilience.
NLB’s ESG Risk Rating that was assigned by Morningstar
Sustainalytics further improved in 2024, reflecting a low
risk of material financial impacts from ESG factors.
In September 2024, Summit Leasing Slovenija, Ljubljana
was acquired, increasing the existing leasing presence
in Slovenia and enabling the entrance into the Croatian
leasing market. Moreover, in May 2024 acquisition of
Generali Investments, Skopje by NLB Skladi, Ljubljana
was concluded, enabling NLB Skladi to expand to
the North Macedonian market. Otherwise, during
2024, there were no other transactions of a sufficiently
material nature to impact on NLB Group’s risk profile or
distribution of the risks on the Group level.
The Condensed Statement of the Management of Risk
is also published on the NLB intranet with the aim
of strict adherence of the banks’ employees at daily
operations of the Bank, as regards the definition and
importance of a consistent tendency of the adopted
risks and ways to take into account when adopting its
daily business decisions.
Ljubljana, 20 February 2025
Management Board of NLB
Hedvika Usenik
Andrej Lasič
Archibald Kremser
Peter Andreas Burkhardt
Antonio Argir
Blaž Brodnjak
Member
Member
Member
Member
Member
Chief Executive Officer
Supervisory Board of NLB
Primož Karpe
President of the Supervisory Board

With our experience and future
vision, we keep pace with modern
times, as well as the desires and
needs of our clients.
More than 56. 4% of
our clients actively
use digital channels
for payment and
cash transactions,
primarily mobile
banking.

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Disclosure on Shares and
Shareholders of NLB
1. Information pursuant to
the Companies Act (ZGD-1),
Article 70, paragraph 8
1. 1. Structure of the Bank’s
share capital
The Bank has issued only ordinary registered no-par
value shares, the holders of which have a voting right
and the right to participate in the General Meeting of the
Bank’s shareholders, the pre-emptive right to subscribe
for new shares in case of a share capital increase, the
right to profit participation (dividends), the right to a share
in the surplus in the event of liquidation or bankruptcy of
the Bank, and the right to be informed. All shares belong
to a single class and are issued in book-entry form.
Information regarding the shareholder structure
of NLB (as at 31 December 2024) is available in the
subchapter Shareholder structure of NLB in the chapter
Shareholder Structure and Market Performance of
NLB’s Shares and GDRs.
1. 2. All restrictions relating to the
transfer of shares and the
restrictions on voting rights
The shares of the Bank are freely transferable, subject to
the provisions of the Articles of Association of the Bank,
which require the approval of the Supervisory Board,
namely for the transfer of shares of the Bank by which
the acquirer, together with the shares held by the holder
before such an acquisition and the shares held by third
parties for the account of the acquirer, exceeds the
share of 25% of the Bank’s voting shares. Approval for
the transfer of shares is issued by the Supervisory Board.
The Bank rejects the request for approval of transfer
shares if the acquirer, together with the shares held by
the acquirer before the acquisition and the shares held
by third parties for the account of the acquirer, exceed
the 25% share of the Bank with voting rights, increased
by one share.
Notwithstanding the provision mentioned in the first
paragraph, approval for the transfer of shares is not
required if the acquirer of the shares has acquired them
on account of third parties so that (s)he is not entitled
to exercise voting rights from these shares at his/her
sole discretion, while at the same time committing to the
Bank, (s)he will not exercise voting rights on the basis of
the instructions of an individual third party for whose
account (s)he has acquired the shares if, together with
the instructions for voting, (s)he does not receive a written
guarantee from the person that this person has shares on
his/her own account and that this person is not, directly or
indirectly, a holder of more than 25% of the Bank’s voting
rights. The acquirer who exceeds the share of 25% of the
Bank’s shares with voting rights and does not require the
issuance of approval for the transfer of shares or does not
receive the approval of the Bank may exercise the voting
right from 25% of the shares with the voting rights.
There are no restrictions other than those mentioned
and those that are regulatory.
1. 3. Qualifying holdings
This information is included in the chapter Corporate
Governance Statement of NLB.
1. 4. Securities carrying special
controlling rights
This information is included in the chapter Corporate
Governance Statement of NLB.
1. 5. The employee share scheme, if
used by the company, for shares
to which the scheme relates and
about the method of exercising
control over this scheme, if
the controlling rights are not
exercised directly by employees
The Bank does not have an employee share scheme. In
accordance with the relevant remuneration policies (when
required by ZBan-3), a part of variable remuneration
of NLB’s Identified Staff shall consist of NLB shares or
NLB share-linked instruments or equivalent non-cash
instruments (the instrument used is determined by the
Supervisory Board). So far, the Bank has not used its
own shares for this purpose. It currently uses NLB share-
linked instruments. More information will be available
in the Report on Remuneration for the members of the
Management Body of NLB d.d. in the 2024 Business Year.
1. 6. Explanation regarding
restrictions related to
voting rights
This information is included in the chapter Corporate
Governance Statement of NLB.
1. 7. All agreements among
shareholders which are known
to the company and could result
in restrictions relating to the
transfer of securities or voting
rights
The Bank is not aware of such agreements.
1. 8. The company’s rules on the
appointment or replacement of
management and supervisory
board members and changes of
the articles of association
This information is included in the chapter Corporate
Governance Statement of NLB.

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1. 9. Authorisations given to
management, particularly
authorisations to issue or
purchase own shares
This information is included in the chapter Corporate
Governance Statement of NLB.
1. 10. All major agreements to which
the company is a party, and
which take effect, are changed
or cancelled following a change
in control over the company
resulting from a bid, as laid
down by the Act governing
M&A, and the effects of such
agreements
There are no major agreements to which the Bank is
a party, and which would take effect, be changed, or
cancelled following a change in control over the Bank
resulting from a bid.
1. 11. All agreements between the
Bank and the members of its
management or supervision
bodies or its employees which
envisage compensation if, due
to a bid as laid down by the Act
governing M&A, these persons
resign, are dismissed without a
well-founded reason, or their
employment is terminated
In line with the employment contracts of the members of
the Management Board, if the Supervisory Board recalls a
member of the Management Board for other business and
economic reasons, such a member of the Management
Board is entitled to compensation for early discontinuation
of his term of office. The Supervisory Board may reduce
the compensation for early discontinuation of the term of
office before its payment (it may even reduce it to zero)
in accordance with the Remuneration Policy in the Bank
that regulates the remuneration of the members of the
Management Board. The member of the Management
Board shall not be entitled to compensation for early
discontinuation of the term of office if he/she continues
to be employed in the Bank or the NLB Group after
the discontinuation of the term of office or in case of
regular termination of the term of office. In the event
of resignation, the member of the Management Board
shall not be entitled to any compensation for early
discontinuation of the term of office.
2. Number of shares held
by members of the
Supervisory Board and
Management Board
Table 40: Number of shares held by members of the
Supervisory Board and Management Board
Shares held as at
31 Dec 2024
Name of member of
Supervisory Board
Number
%
Primož Karpe
1,286
0.006%
Shrenik Dhirajlal Davda
—
—
Islam Osama Zekry
—
—
Mark William Lane Richards
—
—
André-Marc Prudent-Toccanier
—
—
Cvetka Selšek
—
—
Luka Vesnaver
—
—
Natalia Olegovna Ansell
—
—
Sergeja Kočar
190
0.001%
Tadeja Žbontar Rems
—
—
Name of member of
Management Board
Number
%
Blaž Brodnjak
1,700
0.009%
Archibald Kremser
791
0.004%
Peter Andreas Burkhardt
800
0.004%
Antonio Argir
620
0.003%
Hedvika Usenik
450
0.002%
Andrej Lasič
325
0.002%
3. Stock option agreements
The Bank has no stock option agreements in relation to
its listed shares.
4. Dividend taxation
Withholding tax
In 2024, a Slovenian payer was required to deduct and
withhold the amount of Slovenian corporate or personal
income tax from dividend payments made to the certain
categories of payees:
• Individuals: 25%
• Intermediaries: 25%
• Legal entities (other than Intermediaries): 15%.
There are some exemptions if dividends are paid to
intermediaries and legal entities
For the purposes of Slovenian tax legislation, the GDR
depositary will qualify as an intermediary. Therefore, the
dividends paid by the custodian to the GDR depositary
will be subject to the deduction and withholding of
Slovenian tax at the rate of 25%. A holder, an owner of
a GDR or a beneficial owner will be entitled, if and to the
extent applicable, to claim a refund of the withholding tax.
In the case of legal entities, the exemptions are related
to the characteristics of the legal entities.
Application of double tax treaties
If the payee is not an intermediary, Financial
Administration of the RoS (FURS) may approve the
application of a lower tax rate specified in the double
tax treaty between the RoS and the country of residence
of the payee if the Slovenian payer provides certain
information on the payee and a confirmation that the
payee is a resident for taxation purposes in such a
country, issued by the tax authorities of such a country.
Refund of withholding tax
If the Slovenian tax was deducted and withheld at a
higher tax rate than it would be paid if a Slovenian
payer would make the dividend payment directly to
such person as a payee or a higher tax rate than the
one specified in the double tax treaty, the payee of the
dividend is entitled to the refund of the overpaid tax. The
tax refund is enforced by filing a claim to the Financial
Administration of the RoS (FURS).
Legal persons
Dividends with respect to the shares received by a legal
person who is a Slovenian resident are exempt from
Slovenian corporate income tax (davek od dohodkov
pravnih oseb).
Individuals
The amount of tax withheld from a dividend payment
received by an individual constitutes the final amount of
Slovenian Personal Income Tax (dohodnina) with respect
to such a dividend payment.

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Events after the End of the 2024 Financial Year
On 21 January 2025, NLB issued new 4NC3 senior
preferred notes of EUR 500 million to meet its MREL
requirements (ISIN: XS2972971399).
On 5 February 2025, NLB executed the early redemption
of NLB Tier 2 notes in the aggregate nominal amount of
EUR 10.5 million (ISIN: XS2113139195).
On 20 February 2025, the Supervisory Board of NLB,
following a recommendation from the Management
Board, appointed Reinhard Höll as the seventh
member of the Management Board. Following the
necessary approvals, he will assume the role of
Chief Transformation Officer (CTO), overseeing the
acceleration of the mobile/digital-first business model
transition of NLB and its Group members.
In March 2025, NLB received the decision of the Bank
of Slovenia (BS) relating to MREL requirement, which
replaces the previous decision from the BS. NLB must
comply with MREL requirement on a consolidated
basis at NLB Resolution Group, consisting of NLB
d.d., Ljubljana and other members of the NLB Group
excluding banks, which amounts to 29.93% of TREA
(excluding CBR) and 11.24% of LRE. This decision
supersedes the previous BS decision on MREL
requirement from December 2023, which amounted to
30.66% of TREA (excluding CBR) and 10.69% of the LRE.

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Reconciliation of Financial Statements
in Business and Financial Part of the Report
Table 41: Income Statement of NLB Group for the annual period ended 31 December 2024
Business report
in EUR millions
Financial report
in EUR thousands
Notes
Net interest income
934.2
Interest and similar income
1,207,638
4.1.
Interest and similar expenses
(273,477)
4.1.
Net fee and commission income
312.9
Fee and commission income
435,284
4.3.
Fee and commission expenses
(122,360)
4.3.
Dividend income
0.1
Dividend income
116
4.2.
Net income from financial transactions
24.1
Gains less losses from financial assets and liabilities
not measured at fair value through profit or loss
(160)
4.4.
Gains less losses from financial assets and liabilities held for trading
33,229
4.5.
Gains less losses from non-trading financial assets
mandatorily at fair value through profit or loss
3,263
4.6.
Gains less losses from financial liabilities measured
at fair value through profit or loss
(2,903)
Fair value adjustments in hedge accounting
(1,411)
5.5.a)
Foreign exchange translation gains less losses
(3,644)
4.7.
Gains less losses from modification of financial assets
(4,280)
4.12.
Net other income
(26.5)
Gains less losses on derecognition of non-financial assets
3,032
Other operating income and expenses
10,020
4.8.
Cash contributions to resolution funds and
deposit guarantee schemes
(40,213)
4.10.
Gains less losses from non-current assets held for sale
676
Net non-interest income
310.6
310,649
Total net operating income
1,244.8
1,244,810
Employee costs
(322.2)
Administrative expenses
(543,995)
4.9.
Other general and administrative expenses
(221.8)
Depreciation and amortisation
(58.2)
Depreciation and amortisation
(58,217)
4.11.
Total costs
(602.2)
(602,212)
Result before impairments and provisions
642.6
642,598
Impairments and provisions for credit risk
(20.6)
Provisions for credit losses
10,728
4.13.
Impairment of financial assets
(31,306)
4.14.
Other impairments and provisions
(16.9)
Provisions for other liabilities and charges
(12,847)
4.13.
Impairment of non-financial assets
(4,014)
4.14.
Impairments and provisions
(37.4)
(37,439)
Gains less losses from capital investment in
subsidiaries, associates, and joint ventures
3.0
Share of profit from investments in associates and joint
ventures (accounted for using the equity method)
2,990
5.12.h)
Result before tax
608.1
Profit before income tax
608,149
Income tax
(77.9)
Income tax
(77,916)
4.15.
Result of non-controlling interests
15.7
Attributable to non-controlling interests
15,681
Result after tax
514.6
Attributable to owners of the parent
514,552

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Table 42: Statement of Financial Position of NLB Group as at 31 December 2024
Business Report
in EUR millions
Financial Report
in EUR thousands
Notes
ASSETS
Cash, cash balances at central banks, and
other demand deposits at banks
4,039.6
Cash, cash balances at central banks and
other demand deposits at banks
4,039,581
5.1.
Loans to banks
458.9
Financial assets measured at amortised
cost - loans and advances to banks
458,921
5.6.b)
Net loans to customers
16,363.6
Financial assets measured at amortised cost
- loans and advances to customers
16,363,649
5.6.c)
Financial assets
6,324.5
6,324,478
- Trading book
18.3
Financial assets held for trading
18,338
5.2.a)
- Non-trading book
6,306.1
Non-trading financial assets mandatorily at fair value
through profit or loss - part (without loans)
17,429
5.3.a)
Financial assets measured at fair value
through other comprehensive income
2,563,516
5.4.
Financial assets measured at amortised cost - debt securities
3,725,195
5.6.a)
Investments in subsidiaries, associates, and joint ventures
14.7
Investments in associates and joint ventures
14,661
5.12.g)
Property and equipment
310.0
Property and equipment
310,017
5.8.
Investment property
26.1
Investment property
26,132
5.9.
Intangible assets
100.5
Intangible assets
100,496
5.10.
Other assets
397.4
Financial assets measured at amortised
cost - other financial assets
136,854
5.6.d)
Derivatives - hedge accounting
77,771
5.5.b)
Fair value changes of the hedged items in
portfolio hedge of interest rate risk
(6,353)
5.5.c)
Current income tax assets
604
Deferred income tax assets
120,701
5.17.
Other assets
56,819
5.13.
Non-current assets held for sale
11,036
5.7.
TOTAL ASSETS
28,035.4
Total assets
28,035,367
LIABILITIES
Deposits from customers
22,206.3
Financial liabilities measured at amortised cost - due to customers
22,206,310
5.15.a)
Deposits from banks and central banks
136.0
Financial liabilities measured at amortised cost
- deposits from banks and central banks
136,000
5.15.a)
Borrowings
225.1
Financial liabilities measured at amortised cost -
borrowings from banks and central banks
120,612
5.15.b)
Financial liabilities measured at amortised
cost - borrowings from other customers
104,519
5.15.b)
Subordinated debt securities
560.1
Financial liabilities measured at amortised cost -
debt securities issued
1,608,939
5.15.c)
Other debt securities in issue
1,048.8
Other liabilities
560.9
Financial liabilities held for trading
6,995
5.2.b)
Financial liabilities measured at fair value
through profit or loss
9,633
5.3.b)
Financial liabilities measured at amortised cost -
other financial liabilities
296,725
5.15.d)
Derivatives - hedge accounting
3,592
5.5.b)
Provisions
104,388
5.16.
Current income tax liabilities
18,026
Deferred income tax liabilities
17,694
5.17.
Other liabilities
103,889
5.19.
Equity
3,226.0
Equity and reserves attributable to owners of the parent
3,225,960
Non-controlling interests
72.1
Non-controlling interests
72,085
TOTAL LIABILITIES AND EQUITY
28,035.4
Total liabilities and equity
28,035,367

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Report
Alternative Performance
Indicators
The Bank has chosen to present these APIs, either because they are in common use within the industry or because
they are commonly used by investors and as such are useful for disclosure. The APIs are used internally to monitor
and manage operations of the Bank and the Group, and are not considered to be directly comparable with similar
KPIs presented by other companies. The Bank’s APIs are described below together with definition.
Table 43: Alternative Performance Indicators
Alternative Performance Indicators(i)
Description
Calculation
Notes
Cost of risk (CoR)
Calculated as the ratio between credit
impairments and provisions annualised
from the income statement and
average net loans to customers.
Numerator:
Credit impairments
and provisions
NLB internal information. Credit impairments and provisions are annualised,
calculated as all established and released impairments on loans and provisions
for off-balance (from the income statement) in the period divided by the number
of months for the reporting period and multiplied by 12. The net established
Credit impairments and provisions are shown with a positive sign, and the net
released Credit impairments and provisions are shown with a negative sign.
Denominator:
Average net loans
to customers
NLB internal information. Average net loans to customers are calculated as
the sum of the balance of the previous year end (31 December) and monthly
balances of the last day of each month from January to month t divided by (t+1).
Cost to income ratio (CIR)
Indicator of cost efficiency, calculated
as the ratio between the total costs
and total net operating income.
Numerator:
Total costs
Denominator:
Total net operating
income
Total average cost of funding
(quarterly)
Calculated as the ratio between
interest expenses annualised and
average interest-bearing liabilities.
Numerator:
Interest expenses
Interest expenses (quarterly) are annualised, calculated as the sum
of interest expenses in the period divided by the number of days
in the quarter and multiplied by the number of days in the year.
Interest expenses on interest-bearing liabilities also include interest
income from negative interest rate on financial liabilities.
Denominator:
Average interest-
bearing liabilities
NLB internal information. Average interest-bearing liabilities
(quarterly) for the NLB Group are calculated as the sum of
monthly balances (t) for the corresponding quarter and monthly
balance at the end of the previous quarter divided by (t+1).
Average cost of wholesale funding
(quarterly)
Calculated as the ratio between interest
expenses on deposits from customers
annualised and average wholesale funding.
Wholesale funding includes deposits from
banks and central banks, borrowings, debt
instruments, and subordinated liabilities.
Numerator:
Interest expenses from
wholesale funding
Interest expenses from wholesale funding (quarterly) are
annualised, calculated as the sum of interest expenses from
wholesale funding in the period divided by the number of days in
the quarter and multiplied by the number of days in the year.
Denominator:
Average wholesale
funding
NLB internal information. Average wholesale funding (quarterly) for the NLB
Group, calculated as the sum of monthly balances (t) for the corresponding
quarters and monthly balance at the end of the previous quarter divided by (t+1).
Average interest rate for deposits from
customers (quarterly)
Calculated as the ratio between
interest expenses on deposits from
customers annualised and average
deposits from customers.
Numerator:
Interest expenses on
deposits from customers
Interest expenses on deposits from customers (quarterly) are
annualised, calculated as the sum of interest expenses on deposits
from customers in the period divided by the number of days in the
quarter and multiplied by the number of days in the year.
Denominator:
Average deposits
from customers
NLB internal information. Average deposits from customers (quarterly) for the
NLB Group, calculated as the sum of monthly balances (t) for the corresponding
quarters and monthly balance at the end of the previous quarter divided by (t+1).
Deposit beta
Calculated as the ratio between the
change of interest rate on deposits from
customers and change of ECB deposit facility
interest rate over the selected period.
Numerator:
Interest rate on deposits
from customers
NLB internal information. Interest rate on deposits
from customers (quarterly average).
Denominator:
ECB deposit facility
interest rate
Data from the ECB. Deposit facility interest rate (quarterly average).

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Alternative Performance Indicators(i)
Description
Calculation
Notes
Credit portfolio under IFRS 9
IFRS 9 requires an expected loss model,
where an allowance for the expected credit
losses (ECL) is formed. Loans measured at
amortised costs (AC) are classified into the
following stages (before deduction of loan
loss allowances):
Stage 1 – A performing portfolio: no
significant increase of credit risk since
initial recognition, NLB Group recognises an
allowance based on a 12-month period.
Stage 2 – An underperforming portfolio:
a significant increase in credit risk since
initial recognition, NLB Group recognises an
allowance for a lifetime period.
Stage 3 – An impaired portfolio: NLB Group
recognises lifetime allowances for these
financial assets. The definition of default is
harmonised with the EBA guidelines.
A significant increase in credit risk
is assumed: i) when a credit rating
significantly deteriorates at the reporting
date in comparison to the credit rating
at initial recognition; ii) when a financial
asset has material delays over 30 days
(days past due are also included in the
credit rating assessment); iii) if NLB Group
expects to grant the client forbearance or
if the client is placed on the watch list.
Financial assets measured
mandatorily at fair value through
profit or loss (FVTPL)
Financial assets measured mandatorily at
fair value through profit or loss represent
the minor part (0.002% December 2023;
no FVTPL portfolio in December 2024) of
the loan portfolio (before the deduction
of fair value for credit risk; loans with
contractual cash flows that are not solely
payments of principal and interest on the
principal amount outstanding). Classification
into stages is calculated in the internal
data source, by which the NLB Group
measures the loan portfolio quality, and
which is also published in the Business
Report of Annual and Interim Reports.
AC - IFRS 9 classification into Stage 1
Numerator:
Total (AC) loans in Stage 1
Denominator:
Total gross loans
and advances
AC - IFRS 9 classification into Stage 2
Numerator:
Total (AC) loans in Stage 2
Denominator:
Total gross loans
and advances
AC + FVTPL - IFRS 9 classification into
Stage 3
Numerator:
Total (AC) loans in Stage
3 + Total (FVTPL) non-
performing loans
Denominator:
Total gross loans
and advances
AC - Corporates - IFRS 9 classification
into Stage 1
Numerator:
Total (AC) loans in
Stage 1 to Corporates
Denominator:
Total gross loans
to Corporates

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Alternative Performance Indicators(i)
Description
Calculation
Notes
AC - Corporates - IFRS 9 classification
into Stage 2
Numerator:
Total (AC) loans in
Stage 2 to Corporates
Denominator:
Total gross loans
to Corporates
AC + FVTPL - Corporates - IFRS 9
classification into Stage 3
Numerator:
Total (AC) loans in
Stage 3 to Corporates
+ Total (FVTPL) non-
performing loans
Denominator:
Total gross loans
to Corporates
AC - Retail - IFRS 9 classification into
Stage 1
Numerator:
Total (AC) loans in
Stage 1 to Retail
Denominator:
Total gross loans to Retail
AC - Retail - IFRS 9 classification into
Stage 2
Numerator:
Total (AC) loans in
Stage 2 to Retail
Denominator:
Total gross loans to Retail
AC - Retail - IFRS 9 classification into
Stage 3
Numerator:
Total (AC) loans in
Stage 3 to Retail
Denominator:
Total gross loans to Retail
Leverage ratio
Its calculation uses Tier 1 as the numerator,
and the denominator is the total exposure
of all active balance sheet and off-
balance-sheet items after the adjustments
are made in the context of which the
exposures from individual derivatives,
exposures from transactions of security
funding, and other off-balance sheet
items are especially pointed out.
Numerator:
Tier 1
The leverage ratio is a non-risk based supplementary measure to the risk-
based capital requirements. A minimum leverage ratio requirement is 3%.
The purpose of the leverage ratio is to limit the size of the Bank balance
sheets, and with a special emphasis on exposures which are not weighted
within the framework of the existing capital requirement calculations.
Denominator:
Total Leverage Ratio
exposure measure
Liquidity coverage ratio (LCR)
LCR refers to high-quality liquid assets
held by the financial institution to
cover its net liquidity outflows over a
30-calendar day stress period.
Numerator:
Stock of HQLA
The LCR requires financial institutions to maintain a sufficient reserve of high-
quality liquid assets (HQLA) to withstand a crisis that pressure their cash flows.
The assets to hold must equal to or greater than their net cash outflow over a
30-calendar-day stress period (having at least 100% coverage). The parameters
of the stress scenario are defined under Basel III guidelines. The calculations
presented are based on internal data sources.
Its calculation is based on the European Commission’s Delegated Act on LCR.
Denominator:
Net liquidity outflow
Net loan to deposit ratio (LTD)
Calculated as the ratio between net loans to
customers and deposits from customers.
Numerator:
Net loans to customers
There is no regulatory defined limitation on the LTD; however, this
measure aims to restrict the extensive growth of the loan portfolio.
Denominator:
Deposits from customers
Net interest margin on the basis of
interest-bearing assets
Calculated as the ratio between
net interest income annualised and
average interest-bearing assets.
Numerator:
Net interest income
Net interest income is annualised, and calculated as the sum of interest
income and interest expenses in the period divided by the number of
days in the period and multiplied by the number of days in the year.
Denominator:
Average interest-
bearing assets
NLB internal information. Average interest-bearing assets for NLB are
calculated as the sum of total assets of the previous year end (31 December)
and daily balances in the period (from 1 January to day d – the last day in the
reporting month) divided by (d+1). Average interest-bearing assets for NLB
Group and for individual bank members are calculated as the sum of balance
of the previous year end (31 December) and monthly balances of the last
day of each month from January to the reporting month t divided by (t+1).

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Alternative Performance Indicators(i)
Description
Calculation
Notes
Net interest margin on the basis of
interest-bearing assets (quarterly)
Calculated as the ratio between the
net interest income annualised and
average interest-bearing assets.
Numerator:
Net interest income
Net interest income (quarterly) is annualised, calculated as the sum of
interest income and interest expenses in the period divided by the number
of days in the quarter and multiplied by the number of days in the year.
Denominator:
Average interest-
bearing assets
NLB internal information. Average interest-bearing assets (quarterly) for the NLB
Group are calculated as the sum of monthly balances (t) for the corresponding
quarter and monthly balance at the end of the previous quarter divided by (t+1).
Net interest margin on total assets
Calculated as the ratio between net interest
income annualised, and average total assets.
Numerator:
Net interest income
Net interest income is annualised, and calculated as the sum of interest
income and interest expenses in the period divided by the number of
days in the period and multiplied by the number of days in the year.
NLB internal information. Average total assets for the NLB Group are calculated
as the sum of balance of the previous year end (31 December) and monthly
balances of the last day of each month from January to month t divided by
(t+1). Average total assets for NLB are calculated as the sum of total assets of
the previous year end (31 December) and daily balances in the period (from
1 January to day d – the last day in the reporting month) divided by (t+1).
Denominator:
Average total assets
NPE per cent. (EBA def.)
In accordance with EBA methodology, NPE as
a percentage of all exposures to clients in the
Finrep18 before the deduction of allowances
for the ECL; the ratio is in gross terms.
Numerator:
Total Non-Performing on-
balance and off-balance
Exposure in Finrep18
NPE includes risk exposure to D- and E-rated clients (includes loans and
advances, debt securities, and off-balance exposures, which are included in the
report Finrep18; before the deduction of allowances for the ECL). Non-performing
exposures measured by fair value loans through P&L (FVTPL) are considered at
fair value increased by the amount of negative fair changes for credit risk.
The share of NPEs is calculated based on an internal data source,
with which the NLB Group monitors the portfolio quality.
Denominator:
Total on-balance
and off-balance
exposures in Finrep18
NPE per cent. (EBA def.) (BoS)
The NPE indicator, according to the
BoS calculation, differs from the EBA
methodology in the treatment of debt
instruments measured at FVOCI. Due
to impairments, value adjustments
increase the carrying amount of debt
instruments measured at FVOCI.
Numerator:
Total Non-Performing on-
balance and off-balance
Exposure in Finrep18
Denominator:
Total on-balance and
off-balance exposures
in Finrep18, where
carrying amount of
FVOCI is increased
by value adjustments
due to impairments
NPL per cent.
Non-performing loans as a percentage of
total loans to clients before deduction of
loan loss allowances; ratio in gross terms.
Numerator:
Total Non-
Performing Loans
Non-performing loans include loans to D- and E-rated clients, namely loans
at least 90 days past due or loans unlikely to be repaid without recourse to
collateral (before deduction of loan loss allowances).
The share of non-performing loans is calculated based on an internal data
source, with which the NLB Group monitors the loan portfolio quality.
Denominator:
Total gross loans
NPL coverage ratio 1 (NPL CR 1)
The coverage of the gross non-performing
loans portfolio with loan loss allowances on
the entire loan portfolio - loan impairment
in respect of non-performing loans.
It shows the level of credit provisions
that the entity has already absorbed
into its profit and loss accounts with
respect to the total of impaired loans.
Numerator:
Loan loss allowances
for entire loan portfolio
The NPL coverage ratio 1 is calculated based on an internal data source,
with which the NLB Group monitors the quality of the loan portfolio.
Denominator:
Total Non-
Performing Loans
NPL coverage ratio 2 (NPL CR 2)
The coverage of the gross non-performing
loans portfolio with loan loss allowances
on the non-performing loans portfolio.
Numerator:
Loan loss allowances
for non-performing
loan portfolio
The NPL coverage ratio 2 is calculated based on an internal data source,
with which the NLB Group monitors the loan portfolio quality.
Denominator:
Total Non-
Performing Loans
Net NPL ratio
The share of net non-performing loans in
total net loans: non-performing loans after
deduction of loss allowances on the non-
performing loans portfolio as a percentage
of total loans to clients after the deduction of
loan loss allowances; the ratio is in net terms.
Numerator:
Net volume of non-
performing loans
The calculations are based on internal data sources.
Denominator:
Total Net Loans

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Alternative Performance Indicators(i)
Description
Calculation
Notes
Received collaterals for NPLs/NPL
The coverage of the gross non-
performing loans portfolio with
collateral for non-performing loans.
Numerator:
Gross volume of Non-
Performing Loans
covered by collaterals
The collateral market value is used for calculation. The
calculations are based on internal data sources.
Denominator:
Total Non-
Performing Loans
Gross NPL ratio (EBA def.)
The ratio of the gross carrying amount of
non-performing loans and advances to
the total gross carrying amount of loans
and advances, in accordance with the
EBA methodology (report Finrep18).
Numerator:
Gross volume of Non-
Performing Loans and
advances without loans
held for sale, cash
balances at CBs and
other demand deposits
Non-performing loans include loans and advances in accordance with EBA
Methodology that are classified as D and E, namely loans at least 90 days past
due or loans unlikely to be repaid without recourse to collateral (before deduction
of loan loss allowances).
For calculation, loans and advances classified as held for sale, cash balances
at CBs, and other demand deposits are excluded from the denominator
and the numerator. The calculations are based on internal data sources.
Denominator:
Gross volume of Loans
and advances in Finrep18
without loans held for
sale, cash balances
at CBs and other
demand deposits
Gross NPL ratio (EBA def.) (BoS)
The ratio of the gross carrying amount of
non-performing loans and advances to
the total gross carrying amount of loans
and advances, in accordance with the
EBA methodology (report Finrep18).
Numerator:
Gross volume of Non-
Performing Loans
and advances
Cash balances at CBs and other demand deposits are included in the
calculation. The EU banking sector indicator is published quarterly by the EBA
in the Risk dashboard. The calculations are based on internal data sources.
Denominator:
Gross volume of Loans
and advances in Finrep18
NPL coverage ratio (EBA def.)
The ratio of the amount of accumulated
impairment, negative changes in fair value
due to credit risk to the non-performing
loans and advances, in accordance with
the EBA methodology (report Finrep18).
Numerator:
Volume of allowances
and value adjustments
for credit losses on
Non-Performing loans
and advances
Loans and advances classified as held for sale, cash balances at CBs and other
demand deposits are excluded from the denominator and the numerator.
Denominator:
Gross volume of Non-
Performing loans
and advances
NPL coverage ratio (EBA def.) (BoS)
The NPL coverage ratio is the ratio of
the amount of accumulated impairment,
negative changes in fair value due to
credit risk to the non-performing loans
and advances, in accordance with the
EBA methodology (report Finrep18).
Numerator:
Volume of allowances
and value adjustments
for credit losses on
Non-Performing loans
and advances
Cash balances at CBs and other demand deposits are included in the calculation.
Denominator:
Gross volume of Non-
Performing loans
and advances
NPL collateral coverage ratio (EBA def.)
The NPL collateral ratio is the ratio of the
collateral received for non-performing
loans and advances to the gross carrying
amount of collateralised non-performing
loans and advances, in accordance with
the EBA methodology (report Finrep18).
Numerator:
Volume of collateral
received up to the
carrying amount of
each loan or advance
The calculation is provided on a single loan basis. The NPLs where
the amount of collateral received exceeds the net non-performing
of each loan exposure are the subject of calculation.
Denominator:
Gross volume of
collateralized Non-
Performing loans
and advances

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Alternative Performance Indicators(i)
Description
Calculation
Notes
Net stable funding ratio (NSFR)
The net stable funding ratio is a liquidity
risk standard requiring financial institutions
to hold enough stable funding to cover
the duration of their long-term assets.
Numerator:
Amount of available
stable funding
NSFR is defined as the amount of available stable funding relative to the
amount of required stable funding and is based on the current Basel Committee
guidelines. This ratio should be equal to at least 100% on an ongoing basis.
"Available stable funding" is defined as the portion of capital and liabilities
expected to be reliable over the time horizon considered by the NSFR, which
extends to one year. The amount of such stable funding required of a specific
institution is a function of the liquidity characteristics and residual maturities of
the various assets held by that institution and those of its off-balance-sheet (OBS)
exposures. The calculations presented are based on internal data sources.
Denominator:
Amount of required
stable funding
EVE as % of Equity
The EVE (Economic Value of Equity) method
measures the sensitivity of changes in
market interest rates on the economic
value of financial instruments. EVE
represents the present value of net future
cash flows and provides a comprehensive
view of the possible long-term effects of
changing interest rates under at least six
prescribed standardised interest rate shock
scenarios or more if necessary, according
to the situation on financial markets.
Numerator:
Interest risk in banking
book – EVE
Calculations take into account behavioural and automatic options, as well as the
allocation of non-maturing deposits.
The assessment of the impact of a change in interest rates of 200
bps on the economic value of the banking book position.
Denominator:
Equity (Tier I)
Operational business margin (OBM)
Calculated as the ratio between
operational business net income
annualised and average assets.
Numerator:
Operational business
net income
Operational business net income is annualised, and calculated as operational
business income in the period divided by the number of days in the period and
multiplied by the number of days in the year. Operational business income
consists of net interest income (excluding interest expenses from subordinated
securities), net fees and commissions and net gains and losses from financial
assets and liabilities held for trading that derive from foreign exchange trading.
Denominator:
Average total assets
NLB internal information. Average total assets are calculated as a sum of
balance as at the end of the previous year end (31 December) and monthly
balances of the last day of each month from January to month t divided by (t+1).
Operational business margin (OBM)
(quarterly)
Calculated as the ratio between
operational business net income
annualised and average assets.
Numerator:
Operational business
net income
Operational business net income (quarterly) is annualised, and
calculated as operational business income in the period divided by the
number of days in the quarter and multiplied by the number of days in
the year. Operational business income consists of net interest income
(excluding interest expenses from subordinated securities), net fees
and commissions and net gains and losses from financial assets and
liabilities held for trading that derive from foreign exchange trading.
Denominator:
Average total assets
NLB internal information. Average total assets (quarterly) for the NLB Group are
calculated as the sum of monthly balances (t) for the corresponding quarter
and monthly balance at the end of the previous quarter divided by (t+1).
Return on equity before tax (ROE b.t.)
Calculated as the ratio between result
before tax annualised and average total
equity (including non-controlling interests).
Numerator:
Result before tax
The result before tax is annualised and calculated as the
result before tax in the period divided by the number of
months for the reporting period and multiplied by 12.
Denominator:
Average total equity
NLB internal information. Average total equity (including non-controlling
interests) is calculated as the sum of the balance as at the end of the
previous year end (31 December) and monthly balances of the last
day of each month from January to month t divided by (t+1).
Return on equity after tax (ROE a.t.)
Calculated as the ratio between result
after tax annualised and average equity.
Numerator:
Result after tax
The result after tax is annualised and calculated as the result
after tax in the period divided by the number of months
for the reporting period and multiplied by 12.
Denominator:
Average equity
NLB internal information. Average equity is calculated as the sum of the balance
as at the end of the previous year end (31 December) and monthly balances
of the last day of each month from January to month t divided by (t+1).
Return on equity after tax (ROE a.t.)
normalised
Calculated as the ratio between result
after tax annualised and average risk
adjusted capital. Result a.t. w/o negative
goodwill divided by Average risk adjusted
capital. Average risk adjusted capital is
calculated as a Tier 1 requirement of average
Risk Weighted Assets (RWA) reduced for
minority shareholder capital contribution.
Numerator:
Result after tax
Result after tax is annualised, calculated as a result after tax in the period
divided by the number of months for the reporting period and multiplied by 12.
Denominator:
Average risk
adjusted capital
NLB internal information. Average risk adjusted capital is calculated as a sum
of Risk Weighted Assets (RWA) balance as at the end of the previous year end
(31 December) and monthly Risk Weighted Assets (RWA) balances of the last
day of each month from January to month t divided by (t+1), multiplied by Tier 1
regulatory capital requirement and decreased by minority shareholder capital.

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Alternative Performance Indicators(i)
Description
Calculation
Notes
Return on assets before tax (ROA b.t.)
Calculated as the ratio between result before
tax annualised and average total assets.
Numerator:
Result before tax
The result before tax is annualised and calculated as the
result before tax in the period divided by the number of
months for the reporting period and multiplied by 12.
Denominator:
Average total assets
NLB internal information. Average total assets are calculated as the sum of the
balance as at the end of the previous year end (31 December) and the monthly
balances of the last day of each month from January to month t divided by (t+1).
Return on assets after tax (ROA a.t.)
Calculated as the ratio between result after
tax annualised and average total assets.
Numerator:
Result after tax
The result after tax is annualised and calculated as the result
after tax in the period divided by the number of months
for the reporting period and multiplied by 12.
Denominator:
Average total assets
NLB internal information. Average total assets are calculated as the sum of
balance as at the end of the previous year end (31 December) and monthly
balances of the last day of each month from January to month t divided by (t+1).
Total capital ratio (TCR)
TCR is the own funds of the institution
expressed as a percentage of the
total risk exposure amount.
Numerator:
Total capital (Own funds)
Denominator:
Total risk exposure
Amount (Total RWA)
(i) All alternative performance indicators are expressed in %, except the cost of risk (CoR) is expressed in bps.

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Report
Legend: The chart shows voting rights shares. The Group includes entities according to the definition in the Financial Conglomerates Act (Article 2).
(i.a) 100% direct ownership Prvi Faktor d.o.o., v likvidaciji, Ljubljana.
(i.b) 90% direct ownership Prvi Faktor d.o.o., v likvidaciji, Ljubljana, 5% NLB d.d., 5% SID banka d.d.
(ii) - 46.03% direct ownership NLB d.d.

- Abanka merged into Nova KB and, in addition, in September 2024 Nova KBM and SKB merged into OTP banka d.d., therefore the share in Bankart
increased from 29.22% to 43.06%. This is over the 25% treshold set in the Founding agreement - no shareholder other than NLB can have more than
25% capital share in Bankart.
(iii) 51% direct ownership NLB Lease&Go, leasing, d.o.o., Ljubljana, 49% NLB Banka AD Skopje.
(iv) 50.89% direct ownership NLB Lease&Go, leasing, d.o.o., Ljubljana, 48.91% NLB Komercijalna Banka AD Beograd.
(vi) 100% direct ownership NLB Skladi d.o.o., Ljubljana.
(viii) 100% direct ownership Summit Leasing Slovenija d.o.o., Ljubljana.
(ix) 100% direct ownership NLB Lease&Go, leasing, d.o.o., Ljubljana.
Nova Ljubljanska banka d. d. , Ljubljana
Banks
Core
Non-Core
Financial organisations
Companies
Financial organisations
Companies
Slovenia
Bankart,
Ljubljana(ii)
46.03%
46.03%
NLB Skladi,
Ljubljana
100%
100%
Prvi faktor,
v likvidaciji, Ljubljana
50%
50%
ARG-Nepremičnine,
Horjul
75%
75%
SLS HOLDCO,
Ljubljana
100%
100%
Slovenia
Slovenia
Slovenia
Summit Leasing Slovenija,
Ljubljana(vii)
100%
100%
NLB MUZA,
Ljubljana
100%
100%
PRO-REM,
Ljubljana – v likvidaciji(v)
100%
100%
Foreign markets
Foreign markets
Foreign markets
Foreign markets
Foreign markets
NLB Banka,
Sarajevo
97.35%
97.35%
NLB Banka,
Podgorica
99.87%
99.87%
NLB Banka,
Prishtina
82.38%
82.38%
NLB Banka,
Banja Luka
99.85%
99.85%
NLB Banka,
Skopje
86.97%
86.97%
NLB Komercijalna Banka,
Beograd
100%
100%
NLB Fondovi, Beograd(vi)
100%
100%
NLB Lease&Go
Skopje(iii)
51%
100%
NLB Lease&Go Leasing
Beograd(iv)
50.89%
99.80%
NLB DigIT,
Beograd
100%
100%
NLB InterFinanz in
Liquidation, Zürich
100%
100%
NLB InterFinanz,
Beograd – u likvidaciji
100%
100%
LHB AG,
Frankfurt am Main
100%
100%
NLB Crna Gora,
Podgorica
100%
100%
NLB Srbija,
Beograd
100%
100%
OL Nekretnine
u likvidaciji, Zagreb
100%
100%
Subsidiary
% direct share
% indirect share at the group level
Associate
% direct share
% indirect share at the group level
Joint Venture
% direct share
% indirect share at the group level
Prvi faktor u likvidaciji,
Zagreb(i.a)
100%
100%
Prvi faktor-faktoring,
Beograd – u likvidaciji(i.b)
90%
95%
NLB Group Chart*
NLB Lease&Go, leasing,
Ljubljana
100%
100%
NLB Fondovi, Skopje(vi)
100%
100%
Mobil Leasing, Zagreb(viii)
100%
100%
NLB Real Estate,
Ljubljana
100%
100%
NLB Car&Go,
Ljubljana(ix)
100%
100%
NLB Real Estate,
Beograd
100%
100%
NLB Real Estate,
Podgorica
100%
100%
*The reference is made to this chapter from the Sustainability Statement chapter SBM-1 Strategy, business model, and value chain.

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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Organisational Structure of NLB
Workers’ Council(i)
Compliance and Integrity
Group Steering
Strategy and Business
Development
Legal and Secretariat
Brand and Communication
Human Resources and
Organization Development
Global Risk
Credit Risk - Corporate
Credit Risk - Retail
Evaluation and Control
Restructuring
Workout and Legal support
CRO
CFO
CMO
IT Delivery
Business Intelligence and Analytics
Data and Artificial Intelligence
Governance
IT Governance and Architecture
IT Infrastructure
Procurement
Payments and Cards Services
and Business Development
Payments Processing
Cash Processing
COO
Understanding of the tasks and responsibilities of Global Risk, Compliance and Integrity and Internal Audit is taken into account in accordance to the definitions of the (currently valid) Banking Act (ZBan-3).
(i) Workers’ Council is independent organisational unit with no subordinate or superior organisational units, and it operates in accordance with ZSDU.
Internal Audit
Management Board
Supervisory Board
Group Real Estate Management
Controlling
Financial Accounting and
Administration
Financial Markets
Investor Relations
Distribution Network
Area Branch Ljubljana
Area Branch Northwest and
Central Slovenia
Area Branch Northeast Slovenia
Area Branch East Slovenia
Area Branch Southeast Slovenia
Area Branch Southwest Slovenia
Micro Enterprises
Mobile Banking
Distribution Network Coordination
CSA & Cross-Border Financing
Large Corporates
Small and Mid-Corporate
Trade Finance Services
Investment Banking and
Custody
NLB Group Corporate and
Investment Banking Management
Customer, Product Management
and Digital Services
Private Banking
KC 24/7
Development of Lending
Solutions for Retail
Financial Instruments Processing
Corporate Clients Review and
Account Products Delivery
Retail Banking Processing
Corporate Loans and Trade
Finance Delivery
CEO
Anti-Money Laundering and
Counter-Terrorism Financing

SUSTAINABILITY
STATEMENT
Sustainability is embedded in
our strategy and guides our
efforts to improve the quality of
life in our home region. In this
chapter of the Business report
we disclose our material impacts
on people and the environment,
related risks and opportunities,
and explain their importance to
the NLB Group’s development,
performance, and position.

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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Content
General Information. . . . . . . . . . . . . 170
NLB Group Sustainability Journey* . . . . . . . . . . . . . . . . . . 174
General Disclosures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 178
Environmental Information. . . . . 209
Climate Change . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 210
(Mitigation andAdaptation)
Social Information . . . . . . . . . . . . . . 253
Own Workforce. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 254
Affected Communities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 272
Consumers and End-users. . . . . . . . . . . . . . . . . . . . . . . . . . 280
Governance Information . . . . . . . . 289
Business Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 290
Complementary Information:
Sustainable Supply Chain* . . . . . . . . . . . . . . . . . . . . . . . . . . 303
Appendices. . . . . . . . . . . . . . . . . . . . 306
ESRS Appendices
Appendix 1:
EU Taxonomy Regulation Disclosures . . . . . . . . . . . . . . . 307
Appendix 2:
Methodological Outline for Operational
GHG Emission Calculation. . . . . . . . . . . . . . . . . . . . . . . . . . . 354
Appendix 3:
Disclosure Requirements in ESRS Covered in the
Sustainability Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . 359
Appendix 4:
List of Datapoints That Derive from
Other EU Legislation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 361
Complementary Appendices
Appendix 5*:
UNEP FI Principle for Responsible Banking
Progress Statement – Summary. . . . . . . . . . . . . . . . . . . . . 365
Appendix 6*: TCFD Index Table. . . . . . . . . . . . . . . . . . . . . . 367
* Not subject to external assurance.

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

KPMG SLOVENIJA, podjetje za revidiranje, d.o.o.

Telefon: +386 (0) 1 420 11 60

Železna cesta 8a

Internet: http://www.kpmg.si

SI-1000 Ljubljana

Slovenija

družba z omejeno odgovornostjo in članica globalne organizacije
št. reg. vl.: 061/12062100

neodvisnih članic, ki so povezane s KPMG International Limited,
osnovni kapital: 54.892,00 EUR

zasebno angleško družbo z omejeno odgovornostjo. Vse pravice
ID za DDV: SI20437145

pridržane.
matična št.: 5648556000

Independent Auditor’s Limited
Assurance Report on the
Sustainability Statement
To the shareholders of NOVA LJUBLJANSKA BANKA D.D.,
LJUBLJANA
Limited Assurance Conclusion
We have performed a limited assurance engagement on whether the Consolidated Sustainability
Statement of Nova Ljubljanska banka d.d., Ljubljana (»the Bank«) and its subsidiaries (collectively, »the
Group«) as of and for the year ended 31 December 2024, included in the Sustainability Statement
section of the Group’s Business Report, including the information incorporated by reference, as laid out
in Table 1: Incorporation by reference, within the BP-2 Disclosures in relation to specific circumstances
section of the Sustainability Statement (»the Sustainability Statement«), has been prepared in
accordance with articles 70(c) and 70(č) of the Companies Act dated 4 May 2006 (Official Gazette of
the Republic of Slovenia no. 42/2006 with amendments), including the requirements of the Commission
Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of
the European Parliament and of the Council with regard to regulatory technical standards on the
specification of a single electronic reporting format (»Delegated Regulation«) (collectively, »the
applicable legal requirements«).

Based on the procedures performed and evidence obtained, nothing has come to our attention to cause
us to believe that the Group’s Sustainability Statement as of and for the year ended 31 December 2024
is not prepared, in all material respects, in accordance with the applicable legal requirements, including:
•
compliance with the European Sustainability Reporting Standards (ESRS), including that the
process carried out by the Group to identify the information reported in the Sustainability Statement
(» the Process«) is in accordance with the description set out in the note titled Impacts, risk, and
opportunity management;
•
compliance of the disclosures in the EU Taxonomy Regulation section within Appendix 1: EU
Taxonomy of the Sustainability Statement with the reporting requirements of Article 8 of Regulation
(EU) 2020/852 (»the Taxonomy Regulation«); and
•
compliance of the Sustainability Statement with the XHTML format referred to in the Delegated
Regulation.

Our conclusion on the Sustainability Statement does not extend to any other information that
accompanies or contains the Sustainability Statement and our limited assurance report thereon, nor to
any information within the Sustainability Statement not in scope of our assurance engagement. We have
not performed any assurance procedures as part of this engagement with respect to such information.

Independant Auditor's Report

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

However, we audited the Group’s consolidated and the Bank’s separate financial statements as of and
for the year ended 31 December 2024 prepared in accordance with International Financial Reporting
Standards as adopted by the European Union, forming part of the other information, and our auditor’s
reports thereon are also included with the other information.
Basis for Conclusion
We conducted our limited assurance engagement in accordance with International Standard on
Assurance Engagements (ISAE) 3000 (Revised), Assurance Engagements Other Than Audits or
Reviews of Historical Financial Information, issued by the International Auditing and Assurance
Standards Board (IAASB). Our responsibilities under this standard are further described in the
‘Our responsibilities’ section of our report.

We have complied with the independence and other ethical requirements of the International Code of
Ethics for Professional Accountants (including International Independence Standards) issued by the
International Ethics Standards Board of Accountants (IESBA Code), together with the ethical
requirements that are relevant to our assurance engagements on the Sustainability Statement in
Slovenia.

Our firm applies International Standard on Quality Management (ISQM) 1, Quality Management for
Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services
Engagements, issued by the IAASB. This standard requires the firm to design, implement and operate
a system of quality management, including policies or procedures regarding compliance with ethical
requirements, professional standards and applicable legal and regulatory requirements.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Other Matter – Comparative information
Our assurance engagement does not extend to comparative information in respect of earlier periods.
Our conclusion is not modified in respect of this matter.
Responsibility for the Sustainability Statement
The Management of the Bank is responsible for designing, implementing and maintaining a process to
identify the information reported in the Sustainability Statement in accordance with the ESRS and for
disclosing this process in the Impacts, risk, and opportunity management note of the Sustainability
Statement. This responsibility includes:
•
understanding the context in which the Group’s activities and business relationships take place and
developing an understanding of its affected stakeholders;
•
identifying the actual and potential impacts (both negative and positive) related to sustainability
matters, as well as risks and opportunities that affect, or could reasonably be expected to affect,
the Group’s financial position, financial performance, cash flows, access to finance or cost of capital
over the short–, medium–, or long–term;
•
assessing the materiality of the identified impacts, risks and opportunities related to sustainability
matters by selecting and applying appropriate thresholds; and
•
developing methodologies and making assumptions that are reasonable in the circumstances.

The Management of the Bank is further responsible for the preparation of the Sustainability Statement,
in accordance with the applicable legal requirements, including:
•
compliance with the ESRS;
•
preparing the disclosures in the EU Taxonomy Regulation section within Appendix 1: EU Taxonomy
of the Sustainability Statement, in compliance with Article 8 of the Taxonomy Regulation;
•
designing, implementing and maintaining such internal controls that the Management determines
are necessary to enable the preparation of the Sustainability Statement such that it is free from
material misstatement, whether due to fraud or error; and
•
selecting and applying appropriate sustainability reporting methods and making assumptions and
estimates about individual sustainability disclosures that are reasonable in the circumstances.
Those charged with governance are responsible for overseeing the reporting process for the Group’s
Sustainability Statement.
Inherent Limitations in Preparing the Sustainability Statement
In reporting forward–looking information in accordance with the ESRS, Management of the Bank is
required to prepare the forward–looking information on the basis of disclosed assumptions about events
that may occur in the future and possible future actions by the Group. The actual outcome is likely to be
different since anticipated events frequently do not occur as expected. Also, as described in the BP-2
Disclosures in relation to specific circumstances note within the Sustainability Statement, greenhouse
gas emissions quantification is associated with measurement uncertainty as a result of both scientific
and estimation uncertainty.
In determining the disclosures in the Sustainability Statement, Management of the Bank interprets
undefined legal and other terms. Undefined legal and other terms may be interpreted differently,
including the legal conformity of their interpretation and, accordingly, are subject to uncertainties.
Our Responsibilities
Our objectives are to plan and perform the assurance engagement to obtain limited assurance about
whether the Sustainability Statement is free from material misstatement, whether due to fraud or error,
and reporting our limited assurance conclusion to the Bank’s shareholders. Misstatements can arise
from fraud or error and are considered material if, individually or in the aggregate, they could reasonably
be expected to influence decisions of users taken on the basis of the Sustainability Statement as a
whole.

Our responsibilities in relation to the Process for reporting the Sustainability Statement, include:
•
obtaining an understanding of the Process but not for the purpose of providing a conclusion on the
effectiveness of the Process, including the outcome of the Process; and
•
designing and performing procedures to evaluate whether the Process is consistent with the
Group’s description of its Process, as disclosed in the Impacts, risk, and opportunity management
note.

Our other responsibilities in respect of the Sustainability Statement include:
•
obtaining an understanding of the Group’s control environment, processes and information systems
relevant to the preparation of the Sustainability Statement but not evaluating the design of particular
control activities, obtaining evidence about their implementation or testing their operating
effectiveness;
•
identifying disclosures where material misstatements are likely to arise, whether due to fraud or
error; and
•
designing and performing procedures focused on disclosures in the Sustainability Statement where
material misstatements are likely to arise. The risk of not detecting a material misstatement

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

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.
Summary of the Work we Performed as the Basis for Our Conclusion
A limited assurance engagement involves performing procedures to obtain evidence about the
Sustainability Statement. We designed and performed our procedures to obtain evidence about the
Sustainability Statement that is sufficient and appropriate to provide a basis for our conclusion. The
nature, timing and extent of our procedures depended on our understanding of the Sustainability
Statement and other engagement circumstances, including the identification of disclosures where
material misstatements are likely to arise, whether due to fraud or error, in the Sustainability Statement.
We exercised professional judgment and maintained professional scepticism throughout the
engagement.
In conducting our limited assurance engagement, with respect to the Process, the procedures we
performed included:
•
obtaining an understanding of the Process by:
-
performing inquiries to understand the sources of the information used by management
(including stakeholder engagement, business plans and strategy documents); and
-
inspecting the Group’s internal documentation of its Process; and
•
evaluating whether the evidence obtained from our procedures about the Process was consistent
with the description of the Process set out in the Impacts, risk, and opportunity management note.
In conducting our limited assurance engagement with respect to the Sustainability Statement, the
procedures we performed included:
•
obtaining an understanding of the Group’s reporting processes relevant to the preparation of its
Sustainability Statement by performing inquiries of the relevant personnel and inspecting the
Group’s internal documentary evidence;
•
evaluating whether material information identified by the Process is included in the Sustainability
Statement;
•
evaluating whether the structure and the presentation of the Sustainability Statement is in
accordance with the ESRS;
•
performing inquiries of relevant personnel and analytical procedures on selected disclosures in the
Sustainability Statement;
•
performing substantive assurance procedures on a sample basis on selected disclosures in the
Sustainability Statement;
•
obtaining evidence on the methods, assumptions and data for developing material estimates and
forward–looking information and on how these methods were applied;
•
obtaining an understanding of the process of calculating by the Group of the Green Assets Ratio
and preparing related disclosures;
•
evaluating whether the standardised reporting templates required by the Taxonomy Regulation
were appropriately used to present the key performance indicators;
•
assessing whether the taxonomy disclosures reconciled, where relevant, with the Group’s
consolidated financial data;
•
performing substantive assurance procedures on selected taxonomy disclosures; and
•
assessing whether the Sustainability Statement has been properly prepared in the XHTML format
referred to in Delegated Regulation.

The procedures performed in a limited assurance engagement vary in nature and timing from, and are
less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance
obtained in a limited assurance engagement is substantially lower than the assurance that would have
been obtained had a reasonable assurance engagement been performed.
On behalf of audit firm

KPMG SLOVENIJA,
podjetje za revidiranje, d.o.o.

Domagoj Vuković, FCCA

Certified Auditor

Partner

Ljubljana, 9 April 2025

General Information
This section starts with highlighting the NLB Group's sustainability journey, key milestones,
performance indicators, and overview of received awards and recognitions. The General
Disclosures chapter sets the stage with the basis and circumstances of Sustainability
Statement preparation. We present essential disclosures on governance, strategy, and
management of impacts, risks, and opportunities (IROs), including an overview of the
double materiality assessment (DMA), the backbone of our sustainability reporting.

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group
Sustainability
Journey*

At NLB Group, we recognize the significant global
challenges of climate change, social equity, and ethical
governance. This is why the Group has responsibly
committed to "sustainable development that meets the
needs of the present without compromising the ability
of future generations to meet their own needs". 1
As a systemically important financial institution in
the region, NLB Group has set the goal to actively
contribute to the sustainable transformation of the
economy and society to a greener, more just, and
inclusive future.
To achieve this, the Group has integrated sustainability
and ESG (environmental, social and human rights,
and governance) factors into its business model,
strategy and daily operations. Sustainability is also
firmly embedded in NLB Group’s vision "to take care of
the financial needs of its clients and at the same time
improve the quality of life of the home region where we
operate", and its core values which are growing people,
encouraging entrepreneurship, and improving lives.
NLB Group's commitment to sustainability is
concentrated on the markets within the Southeast
Europe (SEE) region, where the Group operates. The
commitment extends beyond the Group’s companies
in Slovenia and Croatia, both EU members, by
harmonizing a sustainable approach in financing,
investing, and own operations across companies in
all other countries of operation: Serbia, Bosnia and
Herzegovina, North Macedonia, Montenegro, and
Kosovo. Hence, the harmonization process groupwide
considers EU legislation as well as national strategies
and laws in each market.
1 Definition by United Nations General Assembly, 1987
*Not subject to external assurance.
Key milestones
Since its establishment, NLB Group has upheld a tradition of responsible, stakeholder-centric operations. This tradition
has evolved over time, and has been enhanced in recent years.
• NLB Group’s sustainability journey
was formally established with an
organization-wide initiative and
the adoption of the Sustainability
Programme.
• NLB was the first bank from
Slovenia to join the UNEP
FI Principles for Responsible
Banking, thus committing to the UN
Sustainable Development Goals
(United Nations Development
Programme) and the Paris Climate
Agreement. NLB Group started
to integrate these commitments
into its operations, financing,
investments, and societal
contributions across its regions.
• The Sustainability Programme was replaced by the
NLB Group Sustainability Framework which became
the mandatory framework for all NLB Group core
members in the region.
• The Sustainability Committee was established as the
central sustainability-related advisory body to the
Management Board of NLB.
• The Environmental and Social Management System
(ESMS) was established as a part of a comprehensive
risk management system within NLB Group, aiming
to improve ESG risk management capacity in the
financing process, and to reduce credit and liability
risks arising from ESG considerations.
• NLB joined the UNEP FI
Net-Zero Banking Alliance
(NZBA). Guided by NZBA
principles, the Group aims
to reduce emissions in credit
and investment portfolios
and its own operations by
reaching net-zero emissions
by 2050 or sooner.
• The comprehensive NLB Group Sustainability
Policy was established, enhancing the existing
internal framework and reaffirming a foundation
for integrating ESG factors into the Group’s business
model, strategy, and daily operations.
• The first NLB Group Net-Zero Disclosure Report
was published aligned with NZBA methodology and
reaffirming our commitment to achieving net zero by
setting targets for reducing its financed emissions
and maintaining a coal exclusion policy.
• Sustainability was integrated in the
NLB Group’s new business
• strategy (New Horizons), in which
commitment to environmental risk
management and sustainable
banking reflects in several
strategic projects.
• The Climate Change Committee
was established.
• NLB Group adopted the
Operational Emissions Net-
Zero Strategy aiming to reduce
emissions from the Group’s own
operation.
2020
2021
2022
2023
2024

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Business Report
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Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
ESG Risk Rating history
Improved ESG Risk Rating
NLB Group’s efforts and progress on its sustainability
journey have been recognized by Morningstar
Sustainalytics, one of the world’s leading independent
ESG research, ratings, and data firms, which has
comprehensively assessed the financial materiality
of risks stemming from NLB Group’s environmental,
social, and governance issues.

In recent years, the Group’s ESG Risk Rating has been
assessed as low and has constantly improved:
• In 2022, the Group received its first ESG Risk Rating
of 17.7 points, being at the same time the first bank
with headquarters and exclusive strategic interest in
SEE to obtain this rating, as well as the first among
companies listed on the Ljubljana Stock Exchange.

• In 2023, the ESG Risk Rating improved by 1.7 points to
16.0 points, ranking the Group in the top 13 percent of
all banks assessed.

• In 2024, NLB Group recorded a significant 5.4-point
improvement, achieving an overall ESG Risk Rating
of 10.5 points. The Group ranked 42nd among 1,027
rated banks, positioning it in the top 5th percentile and
among 432 highest rated companies in Europe. This
achievement placed the Group among the Top-rated
companies in Europe and the Top-rated banks globally.
NEG
0-10
LOW
10-20
MEDIUM
20-30
HIGH
30-40
SEVERE
40+
10. 5
LOW RISK
2022
17. 7
LOW RISK
2023
16. 0
LOW RISK
2024
Low ESG Risk Rating
placed NLB Group
among the Top-rated
companies in Europe
and the Top-rated
banks globally

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Key Sustainability Performance Indicators
Social
Governance
Environmental
EUR
439million
New sustainable financing
Net asset value
EUR
151 million
Asset management
in two sub-funds that promote environmental and
social characteristics
EUR
341. 1 million
Green Bond allocation
as at 31 March 2024
tCO2eq
11. 183 million
GHG emissions
financed and operational emissions
(market-based)
54%
Employee engagement
Client satisfaction
32
Net Promoter Score
with positive trend since 2019
EUR
2. 2 million
Donations in SEE region
days/employee
7. 7
in NLB Group banking members
Completed training and education
17%
Gender diversity
40%
Gender diversity
employees
7,056
in NLB Group core financial members
Completed anti-corruption training
cases
0
in NLB Group
Fines for corruption and bribery
retail and corporate green financing
in 10 NLB Group members
women in the NLB Management Board
women in the NLB Supervisory Board

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Performance Overview
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Statement
Financial
Report
Awards and Recognitions
In 2024, several NLB Group banking members received notable awards for their sustainability-related contributions:
Slovenia
NLB, Ljubljana

Top Employer for the 9th consecutive year (Dutch Top Employer Institute)
The best mobile and online bank in Slovenia (independent study by E-laborat, January 2025)
Serbia
NLB Komercijalna Banka, Beograd

The first certified family-friendly bank in Serbia (since 2023)
Top Employer of the year
Title "The campaign with the purpose" for three CSR initiatives: "Frame of support",
"A world full of heart is a world full of opportunities", "NLB Organic"
The special award for the socially responsible campaign "NLB Organic", which has been held
for 13 consecutive years and promotes organic food producers in Serbia
Bosnia and Herzegovina
NLB Banka, Banja Luka and NLB Banka, Sarajevo

Both banks received the Golden BAM award for innovation in the banking sector for introducing Smart POS services to the market
The CEO of NLB Banka Sarajevo received the 2024 Women of the year award in the corporate social responsibility category
Kosovo
NLB Banka, Prishtina

Employer of the year (Kosova Chamber of Commerce)
Taxpayer of the year (Kosova Chamber of Commerce)
The "Friend of Children" award in recognition of its significant contributions to child protection efforts in Kosovo
North Macedonia
NLB Banka, Skopje

"Oscar of Humanity" (the Red Cross of the City of Skopje)
Recognition for special contribution and support of the Special Olympics of North Macedonia
"Golden Supporter" of the activities of the Red Cross of the Republic of North Macedonia
Recognition for good ESG practices from the Macedonian Stock Exchange and the American Chamber of Commerce
"Leaders in donating" ("Konekt" organization and USAID North Macedonia)
"Best Practices in Corporate Philanthropy" (American Chamber of Commerce, USAID North Macedonia and the organization "Konekt")
Recognition from the European bank for reconstruction development (EBRD) for its
contribution to the success of the Green Economy Financing Facility
Montenegro
NLB Banka, Podgorica

National Award "Iskra" for philanthropy recognizing the bank's commitment to embedding social
responsibility into its corporate culture and identity (The Fund for Active Citizenship)

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Business Report
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Performance Overview
Segment Analysis
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Risk Management
Sustainability
Statement
Financial
Report
NLB Group has a strong tradition of sustainability
reporting, which has evolved significantly over
the years.

Until 2020, the Group published CSR or non-financial
reports guided by the GRI framework. In subsequent
years, additional frameworks like Pillar III, EU Taxonomy,
UNEP FI Principle for Responsible Banking, Net Zero
Banking Alliance and Taskforce for Climate Related
Financial Disclosures, were included in reporting. In
2023, the Group started to prepare to comply with the
new CSRD and ESRS requirements effective from the
fiscal year 2024.
The presented Sustainability Statement replaces
previous reports, while still integrating various above-
mentioned frameworks. It is prepared in accordance
with the EU Corporate Sustainability Reporting
Directive (CSRD) and European Sustainability Reporting
Standards (ESRS) as transposed to the Slovenian
Companies Act (ZGD-1) in December 2024, and the
disclosure requirements related to Article 8 of the EU
Taxonomy and underlying delegated acts. The report is
a result of extensive collaboration across NLB Group.
The statement aims to provide stakeholders with
information on NLB Group’s material impacts on people
and the environment, and the effects of sustainability
matters on the Group’s development, performance,
and position. It includes material matters from the 2024
Double Materiality Assessment and additional insights
for consistency with previous reports.
The Sustainability Statement has been prepared on a
consolidated basis following the same principles as those
following from the financial reporting. This means that
the statement includes the parent bank NLB but also all
subsidiaries (over which NLB has control as at
31 December 2024) from date on which NLB obtains direct
or indirect control over the financial and operational
management and receives a variable return.
The Sustainability Statement covers the financial
reporting period from 1 January to 31 December 2024,
except for:
• Financed emissions, which included data as of 31
December 2023 due to the unavailability of data for the
2024 year-end.
• Operational emissions calculations for entities acquired
during the financial year (Summit Leasing Slovenija,
Mobil Leasing Zagreb, NLB Car & GO, NLB Fondovi
Skopje). In this case, emissions were included from the
month of acquisition onwards.
• NLB Green Bond, which included data as of 31 March
in line with the annual issuance calendar of the Green
Bond Allocation and Impact report.

Figures are stated in EUR thousands and millions tonnes
of CO2 equivalent (tCO2eq), with possible rounding
discrepancies.
Although disclosure of comparative information in
respect of the previous period is not required in the
first year of ESRS application, NLB Group opted to
present such comparisons for certain disclosures, such
as EU Taxonomy, GHG emissions, and some of S1 Own
workforce and E1 Climate Change disclosures. Only
disclosures for the fiscal year 2024 were subject to
external review.
Data quality, coverage,
and availability are
gradually improving

NLB Group's Sustainability Statement and Double
Materiality Assessment were prepared using available
data. Data collection and assessment in the downstream
value chain and certain non-EU and non-strategic
NLB Group members are still developing. Therefore,
some data were unavailable or inapplicable, leading to
the use of management judgments, estimates, and third-
party data, with explanations provided for any gaps.
NLB Group expects improvements in data quality,
coverage, and availability due to increased reporting
obligations. The Group plans to extend the assessment
scope to more activities, including upstream and
downstream. Efforts will continue to enhance the
accounting data framework, upgrade IT solutions, and
engage in industry-wide initiatives to standardize and
improve sustainability data quality.

NLB Group's DMA considered its entire value chain:
upstream, own operations, and downstream.
›› For details, please refer to the chapters NLB Group’s
Value Chain; and Description of the processes to identify
and assess material IROs.

No classified or sensitive information corresponding to
intellectual property, know-how, or innovation results
has been omitted from the Sustainability Statement.
The Group partially used an exemption from disclosing
sustainability information about the Group’s own
operations and about its downstream and upstream
value chain for the first three years after CSRD came into
effect. The partial exemption refers to cases where all
the necessary information regarding the Group's value
chain was not available or could not be obtained. In
such cases, explanations and estimates are provided
alongside respective disclosures.
ESRS 2 General Disclosures
BP-1 General basis for preparation of the Sustainability Statement

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Time horizon
Impacts, risks, and opportunities were assessed over
time horizons as defined in ESRS, namely short (1
year), medium (1-5 years) and long-term (more than
5 years), with the exception of physical risks. These
were assessed for the following time horizons: short-
term: until 2030; mid-term: 2030–2050; and long-term:
2050–2100, as internal methodology relies on studies
and scenarios mainly project temperature and climate
change until 2100.
Value chain estimation, sources of estimation, and
outcome uncertainty
When disclosing metrics for downstream value chain
data, the information includes data from clients and
estimates from third-party providers or sector averages.
These estimates may significantly impact the reported
information, and the Group cannot influence these
estimates. Hence, reported GHG emissions data reflect
measurement uncertainty due to methodological and
data limitations, including reliance on third-party data.
Our analysis and climate targets use estimates based
on recognized frameworks available at the time. As
methods and data evolve, our sources and figures may
become outdated. GHG emission factors are expected
to increase as more data becomes available and
associated companies are included. In cases where the
disclosed quantitative metrics and monetary amounts
were subject to a high level of measurement uncertainty,
this is clearly stated and explained along the metrics.
Expectations, forecasts and statements
Sustainability targets and initiatives, particularly
climate-related ones, require long-term horizons and
forward-looking parameters. Future developments
described in this Sustainability Statement are based
on current expectations, projections, and estimates,
which involve several factors that will come into play
in the future. These factors include evolving science,
methodologies, standards, market conditions,
technological developments, data maturity and
availability, data accuracy, and regulatory changes.
Changes in preparation or presentation of
sustainability information and reporting errors in
prior periods
Based on further understanding of the continuously
evolving sustainability data frameworks and our internal
controls, we have identified some non-significant
errors or minor inconsistencies in the 2023 calculations
related to the calculation of the EU Taxonomy-GAR
and operational emissions. These inconsistencies have
been adequately addressed and corrected and are not
considered as material.
Disclosures stemming from other legislation
or generally accepted sustainability reporting
pronouncements
NLB Group’s Transition plan, disclosed in the chapter
Environmental information, applies NZBA guidelines.
Use of phase-in provisions
NLB Group opted to use all phase-in provisions in
accordance with Appendix C of ESRS 1, except for S1 Own
workforce information, where available data is disclosed
in this Sustainability Statement for the following phase-
in provisions despite they will be mandatory to report
in 1-3 years: S1-8 Collective bargaining coverage and
social dialogue, S1-13 Training and skills development;
S1-14 Health and safety.
BP-2 Disclosures in relation to specific circumstances

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Key Highlights
Business Report
Strategy
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Performance Overview
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Risk Management
Sustainability
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Financial
Report
Incorporation by reference
Parts of ESRS disclosures in this Sustainability Statement
are incorporated by reference to other information in
other parts of the Annual Report as shown in the
table below.
Table 1: Incorporation by reference
Disclosure requirement
Chapter in the Annual Report
Page
GOV-1 The role of administrative, supervisory,
and management bodies, page 181
The Supervisory Board
117, 118
The Management Board
120, 121
The appointment or replacement of members of the management or supervisory bodies, subchapters:
• The Supervisory Board
• The Management Board
139
Information about the composition and work of the management and Supervisory boards and their committees
141, 142
SBM-1 Strategy, business model, and value chain, page 197
Strategy
32, 33
Segment Analysis
67
NLB Group Chart
166
S4 Consumers and end-Users, chapter
Cybersecurity, page 269
Cyber security
111
Information security and personal data protection
126
G1 Business Conduct, chapter Corporate
culture, ethical governance and integrity, and regulatory
compliance. page 293
Compliance and Integrity, subchapters:
• Group-wide ethics and integrity standards
• Prevention
125
G1-4 Business Conduct, chapter Prevention of
AML and financing of terrosism, page 296
Prevention of Money Laundering and Terrorism Financing, and Financial Sanctions Compliance
125, 126
G1 Financial performance , page 302
Income Statement for the Annual Period ended 31 December
378
Other references in this Sustainability Statement to other
information, outside the Business report or the Financial
Report, which are not included in the table above, are
for informational purposes only and are not subject to
external review. The contents of such other documents
or websites are not incorporated by reference into this
Sustainability Statement, nor should they be considered
part of it for any purpose.

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Performance Overview
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Report
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181
Composition
NLB Group, which is organized as a so-called corporate
group, consists of NLB as a parent bank and members of
the NLB Group. Members of NLB Group are independent
legal entities, each with its own management bodies
and statutory duties and responsibilities in line with
legislation in the operating market.
The NLB’s corporate governance is based on a two-tier
system in which the Management Board manages the
daily operations, and the Supervisory Board controls
and supervises the Management Board’s work.
The composition of the NLB Management Board and
Supervisory Board, including the number, representation
of employees and other workers, the information on the
Supervisory Board Independancy are presented in the
following chapters of the Business Report:
• The Supervisory Board
• The Management Board
and in the Corporate Governance statement:
• The appointment or replacement of members of the
management or supervisory bodies.
• Information about the composition and work of the
management and supervisory boards and their
committees.
The relevant experience of the Management Board and
Supervisory Board is described in Chapter Governance of
sustainability-related impacts, risks, and opportunities.
Diversity
The general diversity framework aimed at management
bodies is stipulated in the Policy on the Provision
of Diversity of the Management Body and Senior
Management of NLB (hereinafter: Diversity Policy). As
part of its ongoing efforts, NLB is progressively adapting
these diversity principles across its financial group
members, prioritizing compliance in regions where
local regulations mandate such policies. Currently, NLB
actively monitors gender diversity ratios and raises
the awareness of the importance of gender balance in
management bodies.
The main goal of the Diversity Policy is ensuring that
the composition of the management body and senior
management encompasses a collective proficiency
in knowledge, skills, and experience, while taking
into consideration business and strategic goals and
principles of meritocracy. This comprehensive approach
aims to foster a deep understanding of NLB Group’s
strategy, challenges, and the associated risks.
The diversity principles are considered when appointing
or re-appointing members of the management body
and senior management (in line with internal policies
for selecting suitable candidates) and also in the
annual assessment of the collective suitability of the
management bodies.
The Diversity Policy concurrently establishes a
framework to promote diversity across the following
dimensions:
• Gender diversity: ensuring a balanced pool of
candidates during recruitment, promoting adequate
gender representation in the management. If two
candidates for the management body meet all
criteria and gender representation targets are unmet,
the underrepresented gender will be selected.
• Age diversity: attracting candidates across age
groups to reflect its demographics, balancing
younger and older members in management.
• Professional competencies: ensuring diverse
knowledge, skills, and experience of the management
body and senior management, adhering to criteria
like experience, reputation, and independence.
• Continuity: maintaining a suitable ratio between
existing and new members by not changing all members
of the management body or senior management
simultaneously when their mandates expire.

• International experience: ensuring that management
body and senior management has international
experience, aligning with policies for selecting
qualified candidates.
• Personal integrity: the management body and
senior management must demonstrate high personal
integrity, following the NLB Group Code of Conduct.
• Geographical provenance: seeking diverse
geographical backgrounds in the management
body and senior management to ensure a suitable
knowledge of the culture, market characteristics,
and legal framework in the areas where NLB Group
operates.

Target representation of the management body is
achieved through a predetermined replacement
plan and fulfilling roles as defined by the Articles
of Association. In line with the Diversity Policy, the
conditions and required profiles for management roles
are established before appointments and various
recruitment pathways are used to attract a wide range
of candidates. NLB regularly monitors the achievement
of target representation.
NLB will amend the Diversity Policy in 2025 with inclusion
of provisions from new EU Directive regarding gender
balance, which was transposed to Slovenian Companies
Act (ZGD-1) in December 2024. Following this provisions
NLB will determine what proportion of gender balance it
aims to achieve by 30 June 2026:
• or at least a 40% representation of the
underrepresented gender (i.e. women) among the
members of the supervisory body,
• or at least a 33% representation of the
underrepresented gender (i.e. women) in total among
the members of the management and supervisory
bodies.

While the directive is binding only for NLB, its principles
will be included in NLB Group members as best practice
and where applicable.
Governance
GOV-1 The role of administrative, supervisory, and management bodies

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Report
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Annual Report 2024
182
Governance of
sustainability-related IROs
NLB Group has established a comprehensive
framework for sustainability-related governance.
The framework encompasses oversight of IROs related
to sustainability matters, setting targets, and monitoring
progress towards them. The framework also sets out
roles, responsibilities, and procedures, and reporting
lines for:
• the Supervisory Board of NLB and supervisory bodies
of NLB Group members, and their committees.
• the Management Board of NLB and the management
boards of NLB Group members, and their committees.
• the NLB Sustainability Unit.
• competence lines and organizational units in
NLB Group members.
• internal control functions.

Sustainability-related roles and responsibilities for all
the above-mentioned bodies and functions are outlined
in the Sustainability Policy, Standard – Rulebook for
Sustainability Management in NLB Group. In addition,
their sustainability roles are intertwined with their scope
of work and, therefore, also described in domain-
specific internal rules of procedures.

NLB Group acknowledges the complexity and
interconnectivity of sustainability matters; therefore,
all business areas are involved in sustainability
governance to some extent. The highest responsibility
for managing and overseeing the sustainability and
related impacts, risks, and opportunities lies with
the management boards and supervisory boards
of each NLB Group member. In accordance with
Group governance, collective decision-making and
consultative bodies are appointed by the management
and supervisory bodies to execute tasks within their
respective powers. Operational responsibility is
assigned to competence lines, organizational units,
and sustainability experts, which manage and monitor
impacts, risks, and opportunities within their specific
areas of work, expertise and authority. The progress is
monitored in daily operations and is reported regularly
to the management boards or its respective bodies and
quarterly to the Sustainability Committee.
Table 2: Share of women in governance bodies at the end of 2024
Share of women
in NLB
Share of women
in banking members(i)
Share of women
in NLB Group(ii)
Supervisory Board
40%
(4 of 10 members)
36%
(16 of 44 members)
38%
(33 of 87 directors)
Management Board
16.7%
(1 of 6 members)
19%
(5 of 26 members)
22%
(13 of 59 members)
Notes:
(i) Banking members: NLB and 6 subsidiary banks
(ii) NLB Group: all banks, asset management companies, leasing companies and other core non-financial companies, excluded non-core members
Table 3: Diversity of the NLB management bodies and senior management in 2024 and (actual and plan) –
breakdown by diversity objectives
Supervisory Board
of NLB
Management Board
of NLB
Senior Management
of NLB
2024
Plan for 2024
2024
Plan for 2024
Plan for 2024
Plan for 2024
Wide range of knowledge, skills,
and professional experience
High
High
High
High
High
High
International experience of the
members in different areas
Medium
High
Medium
High
Medium
High
Medium
High
Medium
High
Medium
High
Continuity of composition of
the management body
High
High
High
High
High
High
Personal integrity
High
High
High
High
High
High
Geographical provenance
Medium
High
Medium
High
Medium
High
Medium
High
Low
Low
Age structure
20-30 = 0
0
20-30 = 0
0
20-30 = 0
0
30-40 = 0
0
30-40 = 0
0
30-40 = 1
1
40-50 = 1
2
40-50 = 2
1
40-50 = 24
18
50-60 = 6
5
50-60 = 4
5
50-60 = 18
16
60+ = 3
5
60+ = 0
0
60+ = 2
2
Share of women
40%
42%
17%
30%
43%
45%

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group
Annual Report 2024
183
In accordance with the Banking Act and the EBA
guidelines on assessing the suitability of members
of the management body (i.e. the NLB Management
Board and the NLB Supervisory Board) and holders
of key functions, NLB carries out self-assessments
of the collective suitability of its management body,
including its collective knowledge. By this, NLB detects
potential deficiencies in the collective suitability and
ensures that the management body always has a wide
range of knowledge, skills, and experience to be able
to understand the NLB Group’s activities and its main
risks. In this context, climate-related and other ESG risks
and opportunities, as well as broader sustainability
considerations, have become increasingly important
topics for the Management Board and Supervisory
Board alike.
Once a year, the Supervisory Board assesses the
composition of the Management Board, performance,
potential conflicts of interest of individual members,
and performance of individual members and the
Management Board as a whole, as well as its efficiency.
If it establishes that the number of the members of
the Management Board is inappropriate or that the
number of members of the Management Board must
be increased, or that certain knowledge, skills, and
experience are lacking, or that the members of the
Management Board are no longer qualified to perform
this function because they do not meet the required
conditions, or because one or several members are
unsuitable and thus the Management Board as a whole
no longer meets the required collective suitability, the
process of finding a suitable candidate (or candidates)
is started. In 2024, the composition of the Management
Board remained the same as in 2023.
The collective suitability of the members of its
management bodies covers five major pillars: business
model requirements, governance, risk management,
compliance and audit, management and decision-
making and experience overview of its members. Each
of these pillars relates to several sustainability topics,
such as (and not limited to): discovering and exploiting
opportunities with regard to business sustainability,
i.e. actions of the company that influence the reduction
of adverse environmental and social impact, social
ethical, and professional standards, risk strategy, risk
culture and risk appetite, internal culture, remuneration,
compliance, whistleblowing, group governance, and
internal controls. The Supervisory Board conducted a
collective assessment of sustainability topics in December
2024, concluding that their knowledge, skills, and
experience are generally high. Similarly, the Management
Board's assessment in March 2024, which included the
assessment of the same pillars, also yielded a high
evaluation2.
In particular, the management and supervisory bodies
of NLB Group core financial members are expected to
have adequate competences regarding climate and
other environmental risk, which is stipulated in the
internal policies for suitability assessments and Fit and
Proper procedures (the Policy on the selection of suitable
candidates for members of the Supervisory Board of
NLB d.d. and the Policy on the selection of suitable
candidates for member of the Management Board of
NLB d.d.) As stipulated in both policies, the selection
process for the management bodies’ members
encompasses seven steps: identification of the need to
search for and nominate a candidate for the member,
definition of the profile, search for candidates, selection
of the candidates, "Fit & Proper" assessment of the
candidates, proposal for appointment of a candidate,
appointment of a candidate as a management body
member. In NLB, candidates provide a self-assessment
of their competencies in the questionnaire, which
are further assessed by the HR department and then
at the Nomination Committee, which submits an
opinion to the Supervisory Board. In the second step,
their competencies are also assessed by the Bank of
Slovenia and the ECB as part of the licensing procedure.
The assessment of climate-related competencies is
indirectly included also in the Fit and Proper procedures
of management and supervisory bodies in other
NLB Group financial members, within the overall risk
assessment.
Throughout 2024, several training courses on
sustainability-related topics were organized for different
internal stakeholders, organizational levels, and
addressing different needs. The training programme
contents for the Management Board members,
covering their pertinent area, focused on topics of
strategic relevance, including sustainability. Key training
programmes that the Management Board members
completed in 2024 (and were also in focus in 2023)
included Respecting Human Rights, Cybersecurity Risk,
and Compliance.
In last two years, several Supervisory Board members
completed the sustainability-related programmes with
the following topics:
• in 2024: INSEAD Business School for the World, the
Management of ESG and Sustainability – competence
building for supervisors (legal, strategic, and financial
aspects, sustainability reporting and oversight), the
Corporate Sustainability Due Diligence Directive,
Executive and non-executive remuneration,
Cybersecurity, Governance and risk culture,
• in 2023: Sustainability Leadership Programme, Diverse
and effective boards and committees in a changing
and competitive landscape, and an internal session on
ESG – regulatory requirements and commitments.
Some members of the management boards and
supervisory boards in NLB Group were guest-speakers
on sustainability related topics at conferences, panel
discussions, and other events organized by partnering
professional associations. Thus, NLB Group enhances
knowledge and promotes best practice sharing within the
financial sector in entire region.
NLB also continued collaboration with the Chapter
Zero Slovenia initiative, which was launched in April
2023 under the patronage of the Slovenian Directors’
Association (SDA) and British-Slovenian Chamber of
Commerce (BSCC). Taking part in this initiative enables
the Supervisory Board Members to build their capacity
in regard to principles and frameworks for climate
change strategy and action. At the beginning of 2025 the
collaboration was extended internationally to Chapter
Zero Adriatic, which will extend the impact to all other
NLB Group members in the region.
An overview of the governance framework for
sustainability matters is shown in the figures on the next
page, followed by explanations of the roles of each body
or function and related internal controls.
2 The assessment scale: A=absent, L=low, ML=Medium-low, MH=medium-high and H=high

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184
Collective Decision-Making Body
Supervisory Board of NLB
The Audit Committee
The Risk Committee
The Nomination Committee
The Remuneration Committee
The Operations and IT Committee
Management Board of NLB
Corporate Credit Committee
Assets and Liabilities Committee of
NLB d.d. and NLB Group
Operational Risk
Committee of NLB d.d.
Group Real Estate Asset
Management Committee
Sales Council
Committee for New and
Existing Products
Committee for Business
IT Architecture
Data Governance Council
Advisory Body
Sustainability Committee
Risk Committe
Strategy and Business
Development Division -
Sustainability Unit
Sustainability management in NLB Group Core Members
Internal Controls
Sustainability-related risks are included in the NLB Group's internal control system. This system is designed to ensure that
a process and measures are in place for each key risk to actively reduce and manage that risk, and that the process or
measures are effective for this purpose.
All bodies,
competence lines,
and organizational
units manage
sustainability-
related IROs within
their respective
work areas and
responsibilities,
reporting to their
respective superiors,
committees, or
boards.
Management Board Members
are supported by directors at B-1 level
in 3 decision-making bodies
Discussing key topics and
monitoring progress in the
management of sustainability-
related IROs across NLB Group
Appointed ESMS officers, ESG Coordinators, Sustainability Representatives, responsible for active collaboration with Sustainable
Development Unit, for managing and executing the sustainability initiatives locally and to report to their local Management Boards.
Overseeing the management of sustainability-related IROs.
Managing sustainability-related IROs and reporting to the Supervisory Board.
Climate Change Committee
Figure 1: Governance framework for sustainability matters
Sustainability Unit makes
proposals related to Sustainability
Policy, drives and oversees the
implementation of sustainability-
related roadmap, measuring results
and reporting on the status

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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group Steering co-operates in the process of sustainability/ESG harmonization
and management in NLB Group banking members
NLB d. d.
(parent bank)
Supervisory Board,
Management Board,
Committees
Sustainability
Committee
Sustainability Unit
Head of Sustainability
Sustainability
Coordinators
ESMS Team
Sustainability
representatives in key
OUs that constitute CL
Banking members
Supervisory Board,
Management Board,
Committees
Sustainability-related
body (committee,
workgroup…)
Sustainability Manager
and a substitute/deputy
OR Sustainability Unit
OR Sustainability Advisor
to the MB
ESMS Officer(s)
Sustainability
representatives in key
OUs that constitute CL
Sustainability matters are
integrated in NLB Group’s
established governance.
Advisory bodies to
the Management Boards on
sustainability matters are
established.
Central sustainability / ESG
steering at NLB d.d. and
NLB Group level is ensured.
ESG Risk Management is
implemented throughout the
Risk Competence Line.
Sustainability management is
implemented in other business areas
through other key Competence Lines /
Organizational Units.
Internal controls in each NLB Group member through the first (organizational units), the second (risk management, compliance), and the third level of control (internal audit)
Mutual collaboration among all bodies, competencel lines, organizational units, sustainabilty profiles, capacity and culture-building
Leasing and asset
management
companies
Supervisory Board,
Management Board,
Committee
Sustainability-related
body (committee,
workgroup…)
Sustainability Manager/
Coordinator
and a substitute/deputy
Sustainability
Representatives in key
OUs that constitute CL
Non-financial core
members
Supervisory Board,
Management Board,
Committees
Sustainability-related
body (committee,
workgroup…)
Sustainability
Coordinator
and a substitute/deputy
Sustainability
Representatives in key
OUs that constitute CL
Coordinating, Delivering and
overseeing an overarching
NLB Group sustainability
policies, strategies, guidelines,
expert advisory
Delivering and overseeing ESG Risk
management framework, including
credit process, stress testing,
business continuity
Delivering and overseeing busines
lines specific policies, strategies,
guidelines, expert advisory
Figure 2: Organization of sustainability management in NLB Group
Mandatory body/function/profile
Optional body/function/profile

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Governance bodies
The Supervisory boards of NLB and supervisory
bodies of NLB Group members perform their function
by monitoring the individual NLB Group members’
operations, including those that are sustainability-
related, within their competencies in line with local
legislation, and in accordance with established
Corporate Governance Policy in NLB d.d. and the
NLB Group Governance Policy and the Guidelines,
respectively. Moreover, the Supervisory Board of NLB
monitors the operation of the entire NLB Group within
their competences and by obtaining information and
performing site visits in the NLB Group members.
The Management Board of NLB and NLB Group
member represents the entity and manages its daily
operations, independently and at its discretion, as
provided by the applicable laws and the articles of
association. The Management Board of NLB represents
and acts on behalf of NLB, including the governance of
the entire NLB Group.
Governance bodies of NLB and other NLB Group
members are expected to follow regulators3
guidelines (expectations and principles) regarding
sustainability and ESG matters in NLB Group. Their key
responsibilities include:
• integrating sustainability and ESG (environmental,
social, governance) into business strategy and risk
management.
• allocating roles for sustainability matters, appoint a
board member responsible for ESG.
• assessing board members' knowledge on
sustainability and climate risks.
• overseeing sustainability and ESG risks.
• aligning remuneration policies with sustainability and
ESG goals.
• ensuring adequate resources for managing
sustainability, including training and appointing
experts.
Committees
To assist and advise in sustainability implementation
processes, as well as to execute individual tasks within
the powers of the Management Board, there are several
committees in place:
• six collective decision-making bodies that provide
decision-making support to the whole Management
Board: Corporate Credit Committee, NLB Group
Assets and Liabilities Management Committee, NLB
Operational Risk Committee, NLB Group Real Estate
Management Committee, Sales Committee, and Risk
Committee.
• three decision-making bodies that provide decision-
making support to respective Management Board
members: Committee for New and Existing Products,
Committee for Business IT Architecture, and Data
Governance Council.

Committees identify and address IROs related to
environmental, social, and governance issues within
their area of work. Committees operate in line with their
rules and procedures and regularly report to the NLB
Management Board. Meetings are convened according
to the meetings plan, regularly and frequently. In 2024,
the majority of them were held once a week, some of
them monthly or every two or three months. Ad-hoc
meetings are convened if certain issues need to be
addressed urgently.
The expert support for the NLB Supervisory Board’s
work is provided by its five committees, namely:
the Audit Committee, Risk Committee, Nomination
Committee, Remuneration Committee, and the
Operations and IT Committee. They all participate in
sustainability-related matters and discuss the proposed
materials and proposed resolutions of the Management
Board in individual areas intended for discussion or
adoption at meetings of the NLB Supervisory Board. In
line with the internal rules and procedures committee
meetings are convened according to the financial
calendar prior to each Supervisory Board session.
In 2024, altogether there were 19 meetings of NLB
Supervisory Board’s committees.
The Supervisory Board’s committees (audit, risk,
nomination, remuneration) mainly exist in banking
members of the NLB Group but may also exist in other
NLB Group members if specific regulation requires so.
In line with a member’s specific needs, the Supervisory
Board may also establish other committees and bodies.
In addition, NLB Group has established committees that
are dedicated exclusively to sustainability matters, i.e.
the Sustainability Committee in NLB and similar bodies
in NLB Group members, and the NLB Climate Change
Committee.
The NLB Sustainability Committee is the central
sustainability-related advisory body to the Management
Board of NLB. The Committee oversees the integration
of the ESG factors into NLB and the NLB Group
members’ business model in a focused and coordinated
way across the company and issues opinions,
recommendations, and initiatives, and takes relevant
decisions when needed. The Committee discusses,
develops, and validates sustainability strategies,
policies, initiatives, methodologies, KPIs, and other
relevant documents and procedures, and recommends
these for the approval of the NLB Management Board.
The Sustainability Committee has an influence over
sustainability-related strategic objectives and monitors
their development and realization. It provides the overall
vision and sustainability strategy, defines key policies,
reviews progress on major initiatives, decides on specific
external partnerships and agreements, and ensures
cohesion of the overall programme with the Bank’s
mission. The Rules of Procedure of the Sustainability
Committee determine the composition and powers of
the Sustainability Committee and its members, as well
as the manner of its operation and decision-making.
The Committee is convened quarterly and is composed
of the senior officials across all areas of the Bank and
chaired by the CEO of NLB.
3 Expectations for significant institutions stipulated in the Guide on climate-related and environmental risks, Supervisory expectations relating to risk management and disclosure, ECB, November 2020, taking into account the materiality
of their exposure to climate-related and environmental risks and in connection with Basel Committee Principles for the effective management and supervision of climate-related financial risks, Basel Committee on Banking Supervision
(BCBS), June 2022.

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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group members establish local sustainability-
related bodies considering the nature, scale, and
complexity of the activities and organizational structure
of the member. Sustainability-related bodies are
established in various forms, such as sustainability
teams, project groups, working groups, committees, etc,
and may include internal and external members. The
members of the local sustainability-related body are
appointed by the management body of the NLB Group
member, and the NLB Group member adopts the basic
rules of procedure of such body.
The Climate Change Committee has full authority and
responsibility over the development and implementation
of the NLB Group Net-Zero Strategy, to streamline
decision-making and enhance accountability related to
set decarbonization targets. The Climate Committee is
composed of key individuals who cover both strategic
and operational aspects of the decarbonization efforts.
The Committee comprises all six members of the
Management Board, as well as at least six core team
members. The core team members include a project-
lead from the Sustainability Unit and representatives
of Global Risk, Retail Banking, Corporate Banking,
Data/IT, and Group Steering divisions/departments.
The core team is charged with designing the second
round of target setting scheduled for mid-2025. The
composition of the committee ensures a holistic
approach to the decarbonization process. It brings
together executives and experts from various areas
to provide comprehensive guidance and insight.
This collaborative effort aligns different areas of the
organization, enhancing interdepartmental coordination
and facilitating effective decision-making.
The Sustainability Unit
The Sustainability Unit is set up within the Strategy and
Business Development Division (which is part of the
CEO stream) in the parent bank NLB. In this manner,
sustainability in NLB Group is coordinated through
the central coordination team. The team consists of
sustainability coordinators and is led by the head of
the Sustainability Unit, who reports to the director
of the Strategy and Business Development Division,
who reports directly to the CEO of NLB The latter also
reports to the Management Board and Supervisory
Board of NLB d.d. The Sustainability Unit is the overall
coordinator of sustainability management and closely
cooperates with the individual competence line, which
is a responsible owner of the entire process in its field
of work, without unduly infringing upon the established
internal governance system and control functions.
The general roles and responsibilities of the
Sustainability Unit are described in detail in the
Rules of the organization of NLB.
Competence lines
Sustainability and ESG are important topics that need
to be strongly embedded in all key business areas
in NLB Group. Each key competence line is therefore
responsible for the harmonization and oversight of the
implementation of sustainability and ESG matters in its
field of work. Relevant sustainability and ESG matters
are communicated to the relevant key competence line
in advance by the Sustainability Unit. The established
governance mechanism of the competence lines in
general is stipulated in the NLB Group Governance
Policy and Competence Lines Guidelines. Consequently,
in the context of harmonization and standardization
of NLB Group operations in terms of sustainability and
ESG, the main roles of key competence lines are:
• to monitor that all NLB Group members nominate
sustainability representatives in the competence lines’
field of work.
• to ensure that the relevant rules and principles
(group-wide) related to sustainability and ESG are
incorporated into the competence line’s documentary
framework.
• to monitor that members of the NLB Group operate
in accordance with group-wide rules and principles
of sustainability and ESG that are related to the
competence line’s field of work.

NLB Group members are responsible for complying
with the local or sector-specific regulatory requirements
applicable in the country of each NLB group member.
Sustainability expert profiles
In each NLB Group member, sustainability expert
profiles are appointed who are responsible for the
implementation of sustainability matters subject to their
scope of work: head of sustainability, sustainability
coordinators, sustainability manager, sustainability
manager deputies, ESMS officers, and sustainability
representatives.
Sustainability
is embedded
in all NLB Group
key business areas

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Performance Overview
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Sustainability
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Financial
Report
Internal controls
To ensure efficient and consistent implementation of
strategies and operations of NLB Group, its processes
and procedures, protection of the value of bank
assets, and reliability and integrity of accounting and
management data and information, an efficient system
of internal controls has been set up in NLB Group
members. The appropriateness of the internal control
mechanisms is defined based on the independence,
quality, and applicability of the rules and controls of
performance of organizational, business, and work
processes of the internal controls in NLB Group,
and the internal control functions. The foundation is
defined by the internal document NLB Internal Control
System, which outlines the internal control system and
the responsibilities for its establishment, continuous
operation, and improvement. In accordance with
internal procedures, the internal document is also
implemented in NLB Group members.
Sustainability
is integrated into
NLB Group's internal
control system

Sustainability IROs are integrated into NLB Group's
internal control system through three levels of defence.
Each level has clearly defined sustainability-related
responsibilities, ensuring effective management and
oversight.
First line of defence
First-level controls ensure proper implementation
of business activities in each organizational unit.
Competent units supervise and implement procedures
according to the Rules on Authorizations and Signing.
All units are the first line of defence, responsible for daily
risk management in climate and sustainability matters,
especially frontline employees in corporate, retail, and
financial markets. Their main responsibilities include:
• conducting client activities within the ESMS
framework, managing climate and ESG risks.
• gathering sustainability profiles of clients and
identifying new commercial opportunities.
• informing clients about new sustainable banking
products while avoiding greenwashing.
• providing clear directions on new products and
processes.
• managing ESG risks related to their work.
• ensuring data for reporting and disclosures meet
industry standards.
• participating in awareness activities and training on
sustainability topics.

Back office employees also identify and manage
sustainability IROs in their work, following internal
principles and procedures, reporting to superiors, and
engaging in training.
Second line of defence
Second-level controls are divided between internal
control functions, risk management, and business
compliance; the latter carries out independent controls
and supervision over the operation of the first line
of defence.
The risk management function defines rules for risk
appetite, strategy, policies, and ESG and climate-related
risks. It focuses on holistic risk management and cross-
risk oversight to enhance risk steering and mitigation
within NLB Group. Additionally, it ensures data for
reporting and disclosures meet industry standards and
provides training on efficient ESG risk management,
especially for climate-related risks.
The business compliance function supervises and
ensures compliance with the regulatory framework at
NLB Group. It identifies, assesses, prevents, and monitors
risks to compliance and integrity, including ESG and
climate-related risks. Responsibilities include overseeing
the implementation of laws, directives, standards,
and regulations, and providing guidance to ensure
compliance.
In line with the internal document Rules on the
Management of Changes in the Legal Environment,
managing changes in the legal environment includes
climate-related and ESG risks. Compliance monitors
regulatory developments, communicates updates
to relevant units through internal channels, such as
newsletters on regulatory changes, and is included
in the general sustainability activities to have proper
oversight over the implementation activities.
The status of legal changes or adjustments to the
Group's operations is reported at least quarterly to the
Management and Supervisory Boards, and as needed
to Risk Management and other units. Compliance
also participates in sustainability working groups, the
Sustainability Committee, and cooperates with the
Sustainability Unit.
Third line of defence
The third level of control is performed by the
independent internal audit function, which assesses the
internal control system's completeness, functionality,
and adequacy. Sustainability and ESG matters are
included in the Audit Universe and integrated into the
annual planning process of NLB and other
NLB Group members.

We remain fully committed
to sustainable development
and empower the green
transition with sustainable
financing.
We continuously create services
and solutions that address
environmental challenges,
and actively manage
environmental and social,
human rights and governance
matters in our operations and
financing. We are pleased that
our commitment has been
recognised with a significantly
improved ESG risk rating of 10. 5
as awarded by Morningstar
Sustainalytics.

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
GOV-2
Information provided
to and sustainability
matters addressed
by the administrative,
supervisory, and
management bodies

Throughout 2024, information on the NLB Group's
sustainability performance related to IROs was provided
to the highest governance bodies:
• at Management Board and Supervisory Board
sessions,
• at meetings of the Management Board and
Supervisory Board committees,
• quarterly at Sustainability Committee sessions,
• twice a year at the Climate Change Committee.

Additionally, ad-hoc in-depth insights into sustainability-
related topics were provided to the Management Board
or Supervisory Board, when needed or required.
Management and Supervisory Boards’ review and
approval process is supported by their advisory
and collective decision-making bodies and other
organizational units. They prepare and coordinate the
statements and reports and submit them for discussion
and approval to the Management Board, which then
reports to the Supervisory Board. The NLB Management
Board also reviewed and approved the Double
Materiality Assessment and the Sustainability Statement,
which underline and present the NLB Group's approach
to sustainability matters.
GOV-3
Integration of
sustainability-related
performance in
incentive schemes
Overview of the
remuneration policies

NLB Group remuneration policies are designed to
support the achievement of strategic and business
targets, as well as the recruitment, motivation, and
retention of members of management bodies, senior
executives, and other employees.
The target-setting, performance evaluation, and
remuneration framework for identified employees, i.e.
the governance bodies, and other identified employees
(those who can significantly impact the risk profile of
NLB and/or NLB Group in the scope of their tasks and
activities), is set out in the Remuneration Policy for
Members of the Supervisory Board and Management
Board of NLB d.d. (hereinafter: Remuneration Policy
for Management Bodies) and in the Remuneration
Policy for Employees in NLB d.d. and in NLB Group
(hereinafter: Remuneration Policy for Employees),
which principles are, based on the group guidelines,
also implemented in the NLB Group members.
In 2024 both policies were updated:
• The 2024 remuneration policy for management
bodies was amended to clarify wording and
definitions, set new maximum rental costs, define
guaranteed variable remuneration, remove retention
bonus stipulations, and introduce provisions for
Instruments with yields equal to NLB d.d. dividends.
It also detailed performance indicators for LTI and
removed compensation for early termination due to
resignation. Adopted by the Supervisory Board on
22 April 2024, approved at the General Meeting on
17 June 2024, and effective from 1 January 2024.
• The 2024 remuneration policy for all employees was
amended to include yields of instruments (equal as
defined in the Remuneration Policy for Management
Bodies), adjust target weights in the NLB Group, and
allow variable payouts up to EUR 50,000 or 1/3 of
total remuneration in cash without deferral. Adopted
by the Supervisory Board on 7 November 2024, it is
effective from 1 January 2024.

Supervisory Board remuneration
In relation to their function, a member of the
Supervisory Board may only receive remuneration
that is compliant with the relevant resolutions of the
General Meeting. Supervisory Board members are
entitled to remuneration for performing their function
and/or attendance fees for their membership in the
Supervisory Board, and members of the committees
of the Supervisory Board to reimbursement of travel
expenses, meal allowance and accommodation costs
up to the amount provided by the regulations governing
the tax treatment of reimbursements of expenses
and other income from the employment relationship.
Remuneration for members of the Supervisory Board
is related only to performing their function and is not
related to achieving business goals.
Management Board remuneration
The remuneration of a Management Board member
consists of a fixed part of the salary and a performance
bonus, which is divided into short-term incentive (STI)
and long-term incentive (LTI), and reflects sustainable
and risk-adjusted performance. The amount of the
performance bonus of a Management Board member
depends on performance criteria which comprise:
• the achievement of the financial goals of the
NLB Group,
• the achievement of the financial and or strategic
business goals specifically set for each Management
Board member with respect to individual functional
responsibilities,
• the personal goals of the Management Board
member,
• upon separate assessment at the end of the
subsequent performance period the LTI is adjusted
for realized performance over the same period.

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
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Risk Management
Sustainability
Statement
Financial
Report
The Remuneration policy also sets out rules for
guaranteed variable remuneration, compensation
for early termination of the term of office, and
compensation for the non-competition period, as
well as for malus, retention and return of variable
remuneration (clawback), and pension benefits.
Sustainability-related
targets in the Management
Board remuneration4
Members of the NLB Management Board and other
identified employees are committed to achieving
sustainability-related targets set out in their respective
areas. Where applicable, targets are delegated
to the organizational units and then further
to employees under the responsibility of each
management board member.

The annual performance evaluation process for the
NLB Management Board is based on financial and
non-financial goals, i.e. other measurable targets,
including those which are related to the implementation
of sustainability strategy in NLB Group and material
sustainability matters: ESG risk management, climate
change, sustainable finance, corporate culture,
employee development and engagement, gender
pay gap, service quality and customer satisfaction,
digitalization, contribution to society.

In 2024, the weighting for sustainability-related targets
was as follows:
• CEO of NLB: 45% weighting
• Other members of the NLB Management Board:
from 26–38% weighting

E1, GOV-3
Targets related to climate change are allocated to
all members of the NLB Management Board, with a
4%–5% weight, and refer to the development and
implementation of climate (net-zero) strategy, and
energy consumption reduction. Thus, the performance
of the Management Board is assessed against the
emission targets.
In addition, the Long-Term Incentive (LTI) plan for 2026–
2028 for the NLB Management Board was approved by
the Supervisory Board in January 2025. The plan defines
the following non-financial targets with 50% weighting
in the overall LTI plan:
• linked to organizational culture, employee
development: decrease in gender pay gap, decrease
in actual, and desired organizational culture.
• linked to customer relations: reaching the sustainable
loan portfolio target by 2028.

Detailed breakdown of targets per each member of the
NLB Management Board for the financial year 2024 is
presented in the following tables.
Table 4: Overview of the remuneration policy for identified employees

Remuneration policy
How this applies to identified employees
Fixed remuneration
Is set regarding appropriate professional
experience, responsibilities, powers, and
duties of a Management Board member.
Considering the regional benchmark of comparable banks with regard to the
position/segment covered by an individual member of the Management Board.
Performance assessment
A system of setting smart goals is in use, cascading
top-down. Performance is assessed against agreed
goals of the Management Board Member.
Qualitative and quantitative performance measuresand objectives
are set at the beginning of each year with focus on supporting our core
values – entrepreneurship, growing people, and improving lives.
Short-term incentive (STI)
The Short-Term Performance Criteria and methodology
for evaluating the performance of the Management
Board members is set by the Supervisory Board.
STI consists of financial goals of NLB Group, financial or development
goals in the areas covered by the member of the Management Board,
and personal goals of the member of the Management Board.
Long-term incentive (LTI)
The Long-Term Performance Criteria and related
methodology for evaluating the performance of the
Management Board members during the Subsequent
Performance Period is set by the Supervisory Board.
LTI consists of relative total shareholder return (RTSR) and goals that derive
from the Bank’s long-term strategy and are related to the sustainability and
development of the Bank and are linked to the promotion of organizational culture,
employee development, and customer relations (cost of risk for CRO only).
NLB Management Board
26-45%
weighting of
sustainability-related
targets in variable
remuneration
4 In line with the NLB financial calendar and corporate governance, the 2024 remuneration report will be published after the approval at the shareholders' meeting in June 2024.

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Financial
Report
Tables 5a-f: Breakdown of sustainability-related targets in the remuneration of the NLB Management Board member

Target
Mapping to the material
sustainability topic
Weight per
target
Weight (total)
Targets for areas under the
responsibility of CEO
Enhancement of NLB Group NPS
Service quality and
customer satisfaction
5%
30%
Implementation of the NLB Group HR Strategy and ensure
consistent practice and collaboration throughout NLB Group
Employee attraction
and development
15%
ESG rating improvement
Sustainability strategy
4%
Development of the NLB Group Climate Strategy
Climate change
4%
Contribution to society: enhanced youth engagement in sports
activities, sponsored by NLB; and enhanced engagement in financial
and/or digital literacy training or programme organized by NLB
Sponsorships and donations
2%
Personal targets of CEO
Acting in accordance with the NLB Group values
Corporate culture
5%
20%
Employee engagement enhancement in NLB Group
Employee attraction
and development
5%
Employee development / succession planning
Employee attraction
and development
5%
Realization of the individual development plan
5%
Sustainability-related weights (Total)
45%

Targets for areas under the
responsibility of CFO
Enhancement of NLB Group NPS
Service quality and
customer satisfaction
5%
30%
Implementation of NLB Group IT strategy (strategic projects with IT component)
15%
Groupwide reduction of energy consumption
Climate change
5%
Development of an ESG IT & data strategy to support ESG
data management (collection and reporting)
Sustainability strategy
5%
Personal targets of CFO
Acting in accordance with the NLB Group values
Corporate culture
5%
20%
Employee engagement enhancement in NLB Group
Employee attraction
and development
5%
Employee development / succession planning
Employee attraction
and development
5%
Realization of the individual development plan

5%
Sustainability-related weights (Total)
3030%

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Financial
Report

Target
Mapping to the material
sustainability topic
Weight per
target
Weight (total)
Targets for areas under the
responsibility of CRO
Cost of risk
30%
60%
Implementation of the NLB Group Risk strategy

10%
Cross functional goal related to efficient delivery of LOPA /
Veriloan and its Operational Efficiency with Head of IT
10%
NLB Group Climate Strategy: implementation & execution of NLB
Group Net0 portfolio strategy related to risk management
Climate change
4%
Implementation and upgrades to risk management framework
and process according to action plans (in line with ECB
Guide on climate-related and environmental risks)
ESG risk management
4%
Developing templates and data collection process for the
regular reporting (quarterly basis) on the ESMS funnel
(on the level of transaction, client, and portfolio)
ESG risk management
2%
Personal targets of CRO
Acting in accordance with the NLB Group values
Corporate culture
4%
20%
Realization of the individual development plan

4%
Enhancement of NLB Group NPS
Service quality and
customer satisfaction
4%
Employee development / Succession planning
Employee attraction
and development
4%
Employee engagement enhancement in NLB d.d. CRO stream
Employee attraction
and development
4%
Sustainability-related weights (Total)
3026%
Targets for areas under the
responsibility of CGPO
Delivery of measurable targets for Payments System, Cards
and Payment Operations as per Payments Strategy
7%
30%
Increase groupwide digital and specifically mobile penetration
Digitalization and inovation
8%
Enhancement of NLB Group NPS
Service quality and
customer satisfaction
5%
New Sustainability Policy and Rulebook: implementation in core subsidiaries
Sustainability strategy
5%
NLB Group Climate Strategy:
a) implement Net0 operations strategy in core subsidiaries
b) implement Net0 portfolio strategy in core subsidiaries
(including ESG risk management related enhancements)
Climate change
5%
Personal targets of CGPO
Acting in accordance with the NLB Group values
Corporate culture
5%
20%
Realization of the individual development plan

5%
Employee engagement enhancement in NLB d.d. CGPO STREAM
Employee attraction
and development
5%
Employee development / succession planning
Employee attraction
and development
5%
Sustainability-related weights (Total)
3038%

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Performance Overview
Segment Analysis
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Risk Management
Sustainability
Statement
Financial
Report

Target
Mapping to the material
sustainability topic
Weight per
target
Weight (total)
Targets for areas under the
responsibility of
CMO CORPORATE
Develop credible granular segment Groupwide SME strategy
5%
30%
Grow market share in Serbia and enhance capacity
to serve specialized target sub segments

5%
Enhancement of NLB Group NPS - Corporate
Service quality and
customer satisfaction
5%
Implementing critical IT projects: CRM, OMNI for
corp, credit granting process tool for SME

5%
Corporate green lending portfolio: annual growth of Groupwide corporate
green lending portfolio (volume of new production or exposure planned)
Climate change, Sustainable finance
5%
NLB Group Climate Strategy: implement Net0 portfolio strategy;
developing & and implementing a client engagement strategy
together with systematic training for frontline employees
Climate change, Sustainable finance
5%
Personal goals
of CMO CORPORATE
Acting in accordance with the NLB Group values
Corporate culture
5%
20%
Realization of Individual development plan

5%
Employee engagement enhancement in NLB d.d. Corporate stream
Employee attraction
and development
5%
Employee development / Succession planning
Employee attraction
and development
5%
Sustainability-related weights (Total):
3030%
Targets for areas under the
responsibility of CMO RETAIL
Group Operational CRM and Omni channel project delivery
5%
30%
Enhancement of NLB Group NPS (Retail)
Service quality and
customer satisfaction
5%
Growth in market share of retail lending

5%
Retail green lending portfolio: annual growth of Groupwide retail green
lending portfolio (volume of new production or exposure planned)
Climate change, Sustainable finance
5%
NLB Group Climate Strategy: implement Net 0 portfolio strategy
Climate change, Sustainable finance
5%
Digital penetration: achieve annual growth
Digitalization and inovation
5%
Personal goals of CMO RETAIL
Acting in accordance with the NLB Group values
Corporate culture
5%
20%
Realization of the individual development plan

5%
Employee engagement enhancement in NLB d.d. retail stream
Employee attraction
and development
5%
Employee development / Succession planning
Employee attraction
and development
5%
Sustainability-related weights (Total):
3035%

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Report
In 2024, sustainability targets were integrated into
personal goals, with a 10%–15% weight for training and
corporate culture. These targets were also included
in the goals of organizational units, with varying
weights depending on the unit's field of work. Units in
sustainability-related domains have higher weights
than others.
Table 6: Sustainability-related goals in the variable remuneration structure for other identified employees
Goal Category
NLB /NLB Group goals
Organisation Unit Goals
Personal goals
Identified employees
50%
30%
20%
Identified employees
in control/supervisory function
20%
60%
20%
Sustainability - related
targets for other
identified employees

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GOV-4
Statement on due
diligence
NLB Group performs various due diligence activities
that are guided by UN Guiding Principles on Business
and Human Rights and the OECD Guidelines for
Multinational Enterprises. The Group’s due diligence
process is strongly integrated within its strategic and
business model framework, which ensures that due
diligence is part of the Group’s ongoing operations,
specifically in identifying and managing negative
impacts.
GOV-5
Risk management
and internal controls
over sustainability
reporting
Sustainability Unit in NLB is responsible for coordinating
the Sustainability Statement and the underlying Double
Materiality Assessment, while competence lines and
business units are responsible for data accuracy,
collection, and providing the data to the Sustainability
Unit. In recent years, NLB Group has actively developed
an implementation of IT system support to reporting
on green financing, GHG emissions, EU Taxonomy,
and other sustainability-related topics. To mitigate
operational risks in sustainability reporting which
may result in incompleteness, inaccuracy, and errors,
the development of a comprehensive sustainability-
related data governance framework is underway,
which includes risk management and an internal
control framework supported by adequate IT solutions.
The goal is to integrate this framework into data
governance, controls, and risk management across all
competence lines, similar to financial reporting.
The risk and control framework for this Sustainability
Statement were based on detailed data points and
their underlying definitions. Calculation methodologies
aligned with ESRS and a "comply or explain"
approach were used for disclosures. The following risk
management and internal control procedures were
applied:
• As responsible for preparation of the Sustainability
Statement, the experts in Sustainability Unit
conducted several workshops with subject-matter
experts from competence lines who were identified
as data point owners and were thus responsible
for collecting, preparing, and verifying data for
disclosure requirements.
• The reporting on each disclosure requirement
was compiled by one or more employees in the
responsible competence lines, checked for accuracy
and completeness, and reviewed by the immediate
superior.
• Each disclosure requirement was then assessed by
one or more members of the Sustainability Unit team
to check that the reporting is complete and adequate
in relation to the disclosure requirement.
• Given the early stages of implementing new
legislation, the external auditor has also made
recommendations on the sustainability statement’s
format, structure, and disclosure requirements, prior
to issuing a limited assurance.
• During the preparation of the Sustainability
Statement, the Sustainability Unit reported at least
quarterly to the NLB Management Board or Audit
Committee or NLB Supervisory Board about the
sustainability reporting process.

In 2024 NLB Group also adopted a Greenwashing
Policy. This policy outlines the key processes that require
caution to prevent any form of greenwashing in the
process or reporting in general. Policy is in accordance
with the EBA guidelines.
Table 7: The Group's due diligence approach and activities in 2024 referenced in this Sustainability Statement
Core elements of due diligence
Paragraphs in the sustainability statement
Embedding due diligence in
governance, strategy, and
the business model
ESG Risk Management (section due diligence)
Human rights commitments related to clients, Human rights commitments
Human rights commitments related to employees
Human rights commitments related to suppliers
Engaging with affected stakeholders
in all key steps of the due diligence
ESRS 2 General information: Stakeholder engagement
Processes for engaging about impacts
• S1-2 Processes for engaging with employees and workers’ representatives about IROs
• S3-2 Processes for engaging with affected communities about impacts
• S4-2 Processes for engaging with clients and end-users about impacts
Identifying and assessing
adverse impacts
SBM-3: Material impacts, risks and opportunities and their
interaction with strategy and business model
• E1 Climate change
• S1 Own workforce
• S3 Affected Communities
• S4 Consumers and End-users
G1 Business Conduct IRO -1 Description of processes to identify and assess material IROs
G1-3 Prevention of corruption and bribery
Taking actions to address
those adverse impacts
E1-1 Transition plan for climate change mitigation
E1-3 Actions and Resources related to climate change mitigation and adaptation
IRO-1 Impacts, risks, and opportunity management:
• S4-1, S4-4, S4-5 Consumers and End-users
• S1 Own workforce
S3-3 Processes to remediate negative impacts and channels for affected communities
S4-3 Processes to remediate negative impacts –
complaint management s to raise concerns
G1-10 Managing concerns about unlawful or harmful conducts
G1-10 Whistleblower protection
Tracking the effectiveness of these
efforts and communicating
E1-4 Targets related to climate change mitigation and adaptation
IRO-1 Impacts, risks, and opportunity management:
• S1-4 Own workforce: Key action and progress
• S3-4, S3-5 Affected communities: Key actions and targets
• S4-1, S4-4, S4-5 Consumers and End-users

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Strategy
SBM-1 Strategy,
business model,
and value chain
Strategy and business
model
NLB Group is the leading banking and financial group
with headquarters and an exclusive strategic interest in
our home region – Southeast Europe.
The NLB Group is comprised of six subsidiary banks,
several companies for ancillary services (asset
management, real estate management, leasing services,
etc.), and a limited number of non-core subsidiaries
in a controlled wind-down, operating in the markets
of Bosnia & Herzegovina, Montenegro, Kosovo, North
Macedonia, Serbia, and Croatia. The Group utilizes
a universal banking model, and operates in core
segments and non-core segments.
›› For details please refer to the chapters NLB Group
Chart and Segment Analysis in the Business Report.

In May 2024, the NLB Group launched its new Group
Strategy 2030, to which the sustainability is integrated,
while ESG IROs have been gradually embedded into the
Group’s business processes over last few years.

›› For details please refer to Chapter Strategy in the
Business Report.

At the end of 2024, NLB Group had 8,322 employees.
›› For overview of employee headcount per countries
and other data please refer to the chapter S1-6
Employees characteristic metrics.
Value chain
The value chain of the NLB Group integrates its internal
operations with the upstream and downstream activities
of NLB as the parent company and its subsidiaries. This
holistic approach includes activities, resources, and
relationships that drive value creation within the Group's
business mode.
Own operations
NLB Group impacts the environment and society
through its own operations and internal processes.
These operations involve resources in all business units,
such as HR and organization development, governance,
compliance, legal, tax, financial markets and treasury,
IT services (including NLB Digit, core non-financial
member with supportive expert function, which is
established as a separate legal entity providing services
to NLB Group).
Key subsidiaries in own operations are NLB as a parent
bank and other financial core members: banks, leasing
companies, and asset management companies. At
the end of 2024, NLB and six subsidiary banks (NLB
Komercijalna Banka, NLB Banka Banja Luka, NLB
Banka Sarajevo, NLB Banka Skopje, NLB Banka
Prishtina, NLB Banka Podgorica), accounted for as
much as 93% according to the number of employees
in NLB Group, more than 99% according to its client
base, 92% of total equity and net revenue, and 97%
of profit after tax. Derived from its core business, i.e.
financing, they generate the greatest impact, risks, and
opportunities related to the environment and society.
With that said, other non-financial core members (own
real estate management companies, NLB Cultural
Heritage Institute MUZA), and non-core members
(companies in the wind-down process or companies
which are considered non-strategic for NLB Group) are
deemed to have significantly lower sustainability impact
and financial materiality.
Upstream value chain
The key upstream value chain actors are suppliers of
products or services to NLB Group through direct and
indirect business relationships. Key suppliers include
providers of utilities, goods, and services. NLB Group has
a direct impact on the environment and society through
its procurement decisions, while the Group’s impact
on the suppliers’ management procedures, including
employee working conditions and human rights is indirect
and limited. DMA assessed suppliers and their workforce
as not-material to NLB Group. Nevertheless, in recent
years the Group has started to implement sustainability in
procurement processes as we acknowledge the relevance
of this process, the impact and financial materiality
of which may increase in the future. Moreover, due to
expectations of rating agencies, analysts, and other
stakeholders who occasionally seek such information
and to provide consistency with reporting in previous
years, we decided to include general information on
the supply chain in the Sustainability Statement. This
disclosure is guided by ESRS requirements, but does not
fully comply with them and is described in the section
Complementary information.
Downstream value chain
The key downstream value chain actors are clients
receiving products or services from NLB Group, such
as loans, funding through debt or equity issuance,
interest on deposits, investments in companies, and
leased assets. NLB Group has a direct impact on
the environment and society through financing and
investment policies aimed at clients. On the other hand,
the Group has very limited and indirect impact through
provision of funds to clients and may not directly impact
clients’ management procedures in this respect or
clients’ relations with their workforce. Investors provide
capital to NLB Group, and regulatory authorities
provide the regulatory context for their operations. By
collaborating with regulators and investors NLB Group
has an indirect impact on the environment and society.

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UPSTREAM
Stakeholder
Suppliers
Investors
Regulatory authorities
Impact on environment
and society
DIRECT
INDIRECT
Description
Suppliers of utilities provide electricity, heating, water, waste collection Suppliers
of goods provide office supplies, IT equipment, etc.
Suppliers of services provide various services, such as: security, logistics,
communications, cleaning, data, consulting etc.
Providing capital for NLB Group
to grow, innovate, and expand.
Providing regulatory context for
operations and strategy, future
sustainable development.
Key dependencies/resources
NLB Group depends on provided utilities to perform basic business operation,
provision of IT equipment and other goods necessary to perform basic business
operations, provision of key services, such as cleaning and logistics, as well
as provision of data and other types of services necessary to perform basic
business operations. NLB Group is not dependant on supply of specific resources
or materials.
NLB's shareholders provide capital
and express expectations regarding
business dvelopment and performance.
NLB Group operates in a highly
regulated sector and thereby
the role of regulators is critical.
NLB Group collaborates with
them in line with legislation and
engages in policy discussions.
OWN OPERATIONS
Stakeholder
Retail banking
Corporate
banking
Investment
banking
Asset and wealth
management
Real estate asset
management
Leasing
Cultural Heritage
Organisational
operations
Impact on environment
and society
DIRECT
Description
Providing loans
and other types of
banking products
and services to
individuals and
microcompanies.
Providing loans
and other types of
banking products
and services to
corporate clients
(large, SMEs).
Providing
investment
banking services
to retail and
corporate
clients.
Providing asset
management
products and
services to private
individuals and
business clients.
Management
of owned
real estate.
Providing
leasing to
private and
business
clients.
Preserving
and promoting
Slovenian cultural
heritage and
providing culture
experience to
general public
Carrying out all basic
business functions
necessary to perform
business operations (e.g.
HR and organization
development,
governance,
compliance, legal,
tax, financial markets
and treasury, IT…).
Key dependencies/resources
NLB Group depends on human capital, i. e. , own employees to create value, ensure day-to-day running of operations, manage business, develop strategy, etc.
DOWNSTREAM
Stakeholder
Retail clients
Corporate clients
Retail and corporate clients
Impact on environment
and society
DIRECT
INDIRECT
Description
Using provided products and services to
fund various goods and activities.
Using provided products and services
to fund business operations.
Product and services and project realized as
a result of funding provided by NLB Group.
Key dependencies/resources
NLB depends on client relationships as clients provide funds, repay loans, realize projects that the bank funds.
Clients operating in resource and/or energy intensive sectors depend on
various natural resources and energy to produce goods.
Notes: The figure presents key actors in the value chain through which NLB Group has either direct or indirect impact on and environment and society, and constitutes dependencies with them. As per segment analysis investment
banking, leasing, asset management is allocated both in retail banking and corporate banking. See details in the Business Report, Chapter Segment Analysis.
Figure 3: NLB Group’s value chain

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NLB Group’s approach to
sustainability
Sustainability policy
NLG Group’s approach to sustainability is laid down in
the Sustainability Policy in NLB and NLB Group, adopted
at the beginning of 2024. The overall objectives of the
Policy are:
• to implement sustainability-related legislative
requirements, recommendations, and guidelines of
the supervisory bodies, professional institutions, and
initiatives in the financial industry, in NLB d.d. and
other NLB Group members’ business models and
processes.
• to describe mechanisms for ensuring that the
aforementioned requirements, recommendations,
and guidelines related to sustainability are
recognized and respected in NLB d.d. and NLB Group
members.
• to comprehensively provide the three pillars of
NLB Group sustainability: sustainable operations,
sustainable finance, and contribution to society.
• to establish overarching and forward-looking
sustainability-related principles and objectives, as
well as governance and management rules and
procedures to integrate sustainability and ESG
factors in NLB Group’s business model and processes.

Policy is supplemented by the internal document
Standard – Rulebook for Sustainability Management
in NLB Group. Together, they define a top-down and
bottom-up process for sustainability governance that
extends from individual business units and countries
to the management bodies. The Policy is intertwined
with domain-specific policies and instructions related
to risk management, environmental management,
HR, diversity and inclusion, human rights, compliance,
anti-corruption, tax, procurement, and other specific
internal documents, developed in the Sustainability Unit
and respective business areas (competence lines), in
accordance with the NLB Group Governance Policy.
The Policy and the Standards are in the custody of the
Sustainability Unit in NLB and were adopted by the
management boards of NLB and other core financial
members. Both documents are mandatory for all core
financial members: banks, leasing companies, and asset
management companies across all markets where NLB
Group operates. For non-financial core members (real
estate management companies and other non-financial
companies) and non-core members (companies in the
process of being dissolved or companies that are not
strategic for the NLB Group) the Policy and the Standard
are be followed as best practice on a voluntary basis.
The Policy and the Standard are available to employees
on the intranet in the internal documents register.
›› The overview of the Sustainability Policy is also
communicated to external stakeholders and is available
on the NLB website.
Sustainability mission
By implementing sustainability, NLB Group aims to
achieve three overarching objectives:
• to ensure the sustainable financial performance of
NLB Group, and at the same time
• to achieve added value for its key stakeholders
(clients, employees, suppliers, shareholders, etc.) by
considering ESG factors, and to
• to successfully manage ESG impacts, risks and
opportunities arising from these factors.
The figure on the next page presents NLB Group’s
approach to sustainability, anchored by three pillars:
sustainable finance, sustainable operations, contribution
to society.
The three-pillar approach ensures that sustainability is
integral to NLB Group’s commercial and other activities.
It is embedded in its lending activities, leasing, asset
management, treasury activities, and trading with
financial instruments.

›› Current significant products, markets, and customer
groups in relation to sustainability are presented in the
chapter Sustainable finance.
Moreover, sustainability is also integrated in functions in
NLB Group’s own operations, and in our relations with
communities in the broader society. Current activities in
these areas are presented in respective chapters of this
Sustainability Statement.
The main mission of
sustainability in
NLB Group is to
improve the quality of
life and contribute to a
sustainable economy
and society, and to
lead these processes
by example

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Figure 4: NLB Group's approach to sustainability
3
2
SUSTAINABLE
OPERATIONS
SUSTAINABLE
FINANCE
CONTRIBUTION
TO SOCIETY
Sustainability
Mission
Sustainability
Objectives
Sustainability
Pillars
The way we
deliver
Sustainable financial performance
+ adding value for stakeholders
+ successfully manage ESG impacts, risks, and opportunities
1
Leading by example
Improving quality of life
Contributing to ª sustainable economy and society
Commitments to global sustainability initiatives and goals
Comprehensive and efficient ESG stewardship, based on double materiality
Stakeholder engagement and inclusion, developing partnerships
High corporate governance standards, compliance, integrity and respecting human rights
Strong sustainability governance and culture

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NLB GROUP SUSTAINABILITY PILLARS
Principle 1:
Alignment
Principle 2:
Impact &
Target Setting
Principle 3:
Clients &
Customers
Principle 4:
Stakeholders
Principle 5:
Governance &
Culture
Principle 6:
Transparency &
Accountability
SDG 3:
Ensure healthy
lives and
promote
well-being for
all at all ages
SDG 4:
Ensure inclusive
and equitable
quality education
and promote
lifelong learning
opportunities
for all
SDG 5:
Achieve gender
equality and
empower all
women and girls.

SDG 6:
Ensure availability
and sustainable
management
of water and
sanitation for all
SDG 7:
Ensure access
to affordable,
reliable,
sustainable, and
modern energy
for all
SDG 8:
Promote inclusive
and sustainable
economic growth,
employment,
and decent
work for all
SDG 9:
Build resilient
infrastructure,
promote inclusive
and sustainable
industrialization,
and foster
innovation
SDG 11:
Make cities
and human
settlements
inclusive, safe,
resilient, and
sustainable
SDG 12:
Ensure a
sustainable
consumption
and
production
pattern
SDG 13:
Take urgent
action to
combat
climate
change and
its impacts
5
GENDER
EQUALITY
8
DECENT WORK AND
ECONOMIC GROWTH
4
QUALITY
EDUCATION
7
AFFORDABLE AND
CLEAN ENERGY
3
GOOD HEALTH
AND WELL-BEING
6
CLEAN WATER
AND SANITATION
9
INDUSTRY, INNOVATION
AND INFRASTRUCTURE
11
SUSTAINABLE CITIES
AND COMMUNITIES
12
RESPONSIBLE
CONSUMPTION
AND PRODUCTION
13
CLIMATE
ACTION
Sustainable
Operations
Sustainable
Finance
Contribution
to Society
UN PRINCIPLES FOR RESPONSIBLE BANKING
UN SUSTAINABLE DEVELOPMENT GOALS
• to decarbonize NLB Group’s own operations by
achieving net-zero operational emissions by 2050 or
sooner
• to ensure positive impacts and to minimize adverse
impacts of NLB Group’s own non-financial operations
on key stakeholders
• to identify and mitigate risks, and to pursue
opportunities stemming from business relations
with key stakeholders that might affect financial
operations of NLB Group or our stakeholders
• to align the lending and investment portfolio with
achieving net-zero emissions by 2050 or sooner
• to ensure a positive impact by financing a sustainable
transition (green and social)
• to identify and mitigate climate-related and other
ESG risks in relation to NLB Group’s lending or
investments
• to ensure responsible asset management
• to align each CSR activity with at least one UN
Sustainable Development Goal
• to create added value by focusing on genuine societal
needs and actively responding to these societal
needs with appropriate initiatives and partnerships,
in particular in the following areas:
• Care for NLB Group employees, Financial literacy
and mentoring, Responsibility to the environment,
Sustainable entrepreneurship, Supporting
professional and youth sports, Culture and protection
of cultural heritage, Philanthropy
3
2
Sustainable Operations
Sustainable Finance
Contribution to Society
1

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To deliver on the Bank’s mission and objectives in all
three sustainability pillars, NLB Group embraces and
invests in overarching sustainability drivers:
• responsible engagement with key stakeholders
and their inclusion in business models and business
decisions
• high standards of corporate governance,
responsibility, compliance, ethics, and integrity in
everything we do
• comprehensive and efficient sustainability
stewardship through all three ESG pillars
(environmental, social and human rights, and
governance factors)
• building strong corporate governance and culture
with regard to sustainability matters
• commitment to global sustainability initiatives and
goals, such as the UN Sustainable Development
Goals, UNEP FI – Principles for Responsible Banking,
and the Net-Zero Banking Alliance

Commitments to UN SDGs
NLB Group officially endorsed the UN SDGs by
becoming a signatory to the UNEP FI Principles for
Responsible Banking in 2020. In 2021, NLB Group defined
five initial priority SDGs which reflected its greatest and
direct impact on the environment and society: 3 – good
health and well-being, 7 – affordable and clean energy,
8 – decent work and economic growth, 12 – responsible
production and consumption, 13 – climate action.

Since then, the Group has gradually implemented
several additional sustainability-related commitments
and initiatives, which address additional SDGs: 4 quality
and education, 5 – gender equality, 6 – clean water and
sanitation, 9 – industry, innovation and infrastructure, 11
– sustainable cities and communities. Therefore, in 2023
the Group enlarged the list to 10 priority SGDs.

At the same time, the Group indirectly contributes
to all 17 SDGs to varying degrees, as all of them are
interconnected.
Commitment to UN PRBs
Following the commitment to the UNEP FI Principles for
Responsible Banking, NLB aligns its business with the
six principles for responsible banking and transparently
reviews and publicly discloses the progress annually in a
self-assessment report. The six underlying principles are:
• Principle 1: Alignment: NLB Group aligns our business
strategy to be consistent with and contribute to
individuals’ needs and society’s goals, as expressed in
the UN SDGs, Paris Climate Agreement, and relevant
national and regional frameworks such as the Sofia
Declaration on the Green Agenda for the Western
Balkans, and national energy and climate plans.
• Principle 2: Impact and target setting. NLB Group
continuously increases our positive impacts while
reducing the negative impacts on, and managing the
risks to, people and the environment resulting from
our activities, products, and services. To this end, we
will set and publish targets where we can have the
most significant impacts.
• Principle 3: Clients. NLB Group works responsibly
with its clients to encourage sustainable practices
and enable economic activities that create shared
prosperity for current and future generations.
• Principle 4: Stakeholders. NLB Group proactively and
responsibly consults, engages, and partners with
relevant stakeholders to achieve society’s goals.
• Principle 5: Governance and culture. NLB Group
implements its commitment to the UNEP FI
Principles for Responsible Banking through effective
governance and a culture of responsible banking.
• Principle 6: transparency and accountability.
We will periodically review our individual and
collective implementation of these Principles and be
transparent about and accountable for our positive
and negative impacts and our contribution to
society’s goals.

›› For the UNEP FI PRB self-assessment report, please
refer to the Appendix 5.
›› A comprehensive overview of UNEP FI Principles for
Responsible Banking is available at the website of UNEP FI
Commitment to the Net-Zero Banking Alliance
In line with NLB’s commitment to a climate-positive
future (i.e. creating a mindset of doing more good, not
just less bad) and its net-zero ambition, NLB officially
joined the UNEP FI Net-Zero Banking Alliance (NZBA) in
May 2022.
›› For a comprehensive overview of NLB Group
decarbonization activities and net-zero commitment,
please refer to the chapter Environmental information.
NLB Group follows
Paris Climate
Agreement, and
its commitments
to the UN global
sustainability initiatives
and goals

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SBM-2
Interests and views of
stakeholders
Stakeholder engagement
NLB Group continually engages with a wide range of
stakeholders to provide them with relevant information
on various topics, to consider their views, concerns, and
aspirations in business decisions, and to enhance trust
and partnerships. A materiality analysis, conducted in
2021, identified the six key stakeholder groups, which
were reconfirmed in the 2024 Double Materiality
Assessment: employees, investors/shareholders,
private individual clients, corporate clients (large and
SMEs), regulatory authorities, suppliers and contractual
partners. In addition, NLB Group ensures constructive
dialogue with other stakeholders, such as local
communities, professional and business associations,
and the media.
Stakeholders are regularly informed about general as
well as sustainability-related issues through various
communications channels, such as the NLB Group
members’ internet sites, public reports, marketing
communications, social media channels, etc. In addition,
NLB Group pursues regular personal communication,
meetings in person or on-line, consultations, and
conferences and special events.
The engagement activities also include insight
gathering, feedback, and dialogue instruments such
as polls and research.
Sustainability-related topics are included in stakeholder
engagement in several ways. The Sustainability
Unit primarily, and also other NLB Group expert
representatives (in connection with their field of
work), participate in the dialogue with internal and
external stakeholders. To enhance communication
with stakeholders about sustainability, NLB Group core
financial members have established the sustainability
e-mail inbox (for example in NLB: sustainability@nlb.si),
which is accessible on their internet sites. This channel
also provides a grievance mechanism for affected
stakeholders and communities.
In addition, the importance of stakeholder engagement
was re-confirmed in the conducted Double Materiality
Assessment included views of the key stakeholders
through their assessment of sustainability-related
impacts. Employees, clients, investors, and suppliers
were engaged directly via a questionnaire, while
regulatory authorities were included indirectly via a
conducted context analysis.
›› For details please refer to the Chapter Double
Materiality Assessment.
Our objective is to comprehensively understand
stakeholder perspectives and interests, that they
are considered in our business strategy design
and implementation. Consequently, stakeholder
engagement is deeply integrated into our business
model, continuously shaping and informing our strategic
direction now and in the future.
Namely, stakeholders’ views are important and are
considered when designing and implementing NLB
Group policies and activities in different business
areas. The highest governance bodies are informed on
key findings, views, and interests via the established
communication and reporting framework. These
topics are regularly discussed in board sessions and
committees and are included in policies and decisions
that affect stakeholders.
Table 8: Key areas of stakeholder engagement

Purpose and content of the engagement (on-going)
Employees
• Transparent and open communication through all internal channels (intranet, internal newsletters, personal
meetings, coaching, etc.)
• Measuring employee engagement, providing feedback opportunities and a grievance mechanism
• Ensuring equal opportunities, respecting diversity
• Improving the work environment, employee engagement, growth and personal development
• Providing various training possibilities to enhance knowledge and skills
• Ensuring work/life balance
• Ensuring teamwork and well-being activities (social events, sports associations., etc.)
Please refer to S1 – Own workforce for more information on activities and engagement process with employees.
Investors –
Shareholders
• Identification and communication of topics and initiatives relevant for investors’ decisions
• Regular discussion on strategies to follow global trends
• Integration of investors’ requirements into our operations
• Organising special investor days
• Presenting business results of NLB Group (reports, presentations, website publications, with publications
in the electronic information system of the Ljubljana Stock Exchange (SEOnet) and the London Stock
Exchange (RSN)), regular information at relevant business events
Clients:
Retail (Private
Individuals, micro
companies)
Corporates (large
companies, SME)
• Ensuring professional and friendly relationships with clients through sales and legal obligations through
day-to-day operations
• Supporting corporates and private individuals in their sustainability-related projects with financial
products, professional services and relevant dialogue
• Offering new green products, at a lower interest rate, and new digital solutions, adhering to principles of
responsible marketing and communication
• Keeping clients informed about reliable sustainability solutions
• Special focus on data and cybersecurity
• Promoting the sustainability agenda at various regional events
• Measuring client satisfaction, providing feedback opportunities and a grievance mechanism.
Please refer to S4 – Consumers and End-users for more information on activities and engagement process with clients.
Regulatory
Authorities
• Regular cooperation with the ECB, Bank of Slovenia and EBA
• Promptly meeting all the regulatory requirements
• Personal meetings and frequent dialogue on relevant topics
Suppliers and
Contractual
Partners
• Implementation of sustainability requirements in the procurement process
• Personal meetings, dialogue on cooperation, challenges and issues
Please refer to G1 – Complementary information (Sustainable supply chain) for more information on activities and
engagement process with clients.
Local
Communities
• Maintaining a close relationship with key representatives to support local communities in achieving
their goals
• Supporting various local community projects through building partnerships, donations and sponsorships
Please refer to S3 – Affected communities for more information on activities and engagement
process with communities.
Professional
associations
• Active membership in banking, leasing, asset management associations and participation in policy and
regulation discussions
• Active memberships in key international initiatives, principles, recommendations and associations in
sustainability-related areas.
Media
• Professional communication with the media through press releases, statements, press conferences,
information briefings and other media events.

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SBM-3
Material IROs and
their interaction
with strategy and
business model
Impacts of material IROs

By conducting a double materiality analysis NLB Group
identified 50 material impacts (negative or positive,
actual or potential), 4 risks and 20 opportunities, which
were mapped to 21 material sustainability sub-topics.
Material IROs are connected with our business model
and value chain and derive from own operation and
downstream (clients), while upstream (suppliers,
regulators, investors) no material IROs were identified.
74 material IROs
were identified which
were mapped to
21 material topics

In line with the Group’s risk management and the
business model, the IROs and their current and
anticipated effects are managed through NLB Group’s
competence lines, responsible for particular IROs. This
will remain the Group’s approach in the future.
The financial effects of material risk and opportunities are
integrated into NLB Groups existing business practices,
and such effects are taken into consideration when the
Group sets capital targets and establishes tolerance limits
to manage potential profit and loss effects. No significant
changes to this approach are expected over the course of
the next annual reporting period.
A detailed overview of IROs is presented in chapters
on particular topic standard, including a description
and the connection with NLB Group’s business model,
location in the value chain, and expected time horizon
of each IRO.
NLB Group demonstrates a solid performance,
maintains a robust financial position, and has effective
risk management processes. This enables the Group to
implement its strategy and manage material IROs (IROs)
effectively. A climate resilience analysis of the Group’s
lending and investment activities is conducted across
short-, medium- and long-term horizons. The uniform
stress-testing programme includes internally developed
models, stress scenarios, and a sensitivity analysis,
which are regularly revised and complemented.
›› For details see the chapter Resilience Analysis in
Environmental information.
NLB Group conducted its first materiality analysis in
2021, using a different methodology from one used for
the DMA in 2024. The 2021 methodology assessed two
dimensions: (1) the economic, environmental, and social
impacts on the environment and society according to
NLB Group, (2) Stakeholders' needs and expectations
relating to NLB Group’s operations.
Due to these methodological differences, direct
comparisons between the two analyses are not possible.
Among identified subtopics5, 7 derived from ESRS 1,
while additional 14 entity-specific subtopics were
identified as crucial to NLB Group operations and
the local context through document analysis and
stakeholder engagement.
Table 9: Material sustainability topics
Material Topical
Standard
Material ESRS
sub-topic
Material entity-specific
sub-topic
E1 Climate change
• Climate change
• Energy
• Sustainable finance
S1 Own workforce
• Working conditions
and human rights
• Employee attraction and development
• Diversity, equity and inclusion
• Cybersecurity
S3 Affected
communities
• Financing community and regional development
• Sponsorships and donations
S4 Consumers
and end users
• Responsible marketing and
communication
• Financial health and inclusion
• Service quality and customer satisfaction
• Cybersecurity
• Digitalization and innovation
G1 Business conduct
• Corporate culture, regulatory
compliance and governance,
• Prevention of corruption and
bribery
• Whistleblower protection
• Financial performance (stability)
• ESG risk management
• Prevention of money-laundering and financing terrorism
• Tax transparency
• Participation in associations and policy discussion
Not material standards/topics.
E2 - Pollution, E3 - Water, E4 - Biodiversity, E5 - Resource and waste
S2 – Workers in the value chain: working conditions and human rights of employees in the supply chain and of corporate clients’ employees
Overview of ESRS and entity-specific topics
5 Cybersecurity is counted as one subtopic which refers to two standards (S1 and S4)

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Overview of
material IROs
Material environmental topics (E1) are mainly
connected to impacts of NLB Group’s financing activities,
climate-related risks, and sustainable finance offering
to reduce our negative impacts and capitalize on the
opportunities of the green transition.
Material social topics relate to our workforce (S1)
included care for Working conditions and human rights
of employees, Diversity, equality and inclusion as well
as Talent attraction and development. NLB Group
affects communities (S3) in the region through our
financing operations, within the Financing community
and regional development topic, and through our
contribution to society through Sponsorships and
donations. Impacts, risks and opportunities linked to
our clients (S4), correspond to the topics of Financial
health and inclusion, Responsible marketing and
communication, Service quality and customer
satisfaction and Cybersecurity. Digitalization and
Innovation are seen as key tools to improve our
services and continue to foster meaningful relationships
with our clients.
Several business conduct and governance-
related topics (G1) were identified as material,
reflecting the critical importance of governance,
compliance, and integrity in the banking
sector. These include Corporate culture and
regulatory compliance and governance,
Whistleblower protection, ESG risk management,
Tax transparency, Participation in associations
and policy discussion related to sustainability.
Prevention of corruption and bribery, and
Prevention of money-laundering and financing of
terrorism were recognized as foundational efforts
to preserve our integrity. Financial performance
(stability) of the NLB Group was recognized as a
necessary precondition that allows us to manage
our material IROs effectively.
Note: IROs under topics "Climate change, Energy, Water, Resource use and waste, Pollution and Biodiversity, include both own operations and value chain considerations.
Financial
materiality
25
24
23
22
21
20
19
18
17
16
15
14
13
12
11
10
9
8
7
6
5
4
3
2
1
0
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Sustainable
finance
Climate
change
Energy
Pollution
Water
Biodiversity
Resource use
and waste
Working conditions and
human rights of employees
Diversity,
equity and
inclusion
Employee attraction and development
Cybersecurity
Working conditions
and human rights
of employees of
the supply chain
Working conditions
and human rights
of employees of
corporate clients
Financing
community
and economic
development
Sponsorships
and donations
Responsible marketing
and communication
Financial health
and inclusion
Service quality
and customer
satisfaction
Digitalization
and innovation
Corporate culture,
regulatory
compliance and
governance
Whistleblower
protection
Participation in
associations and
policy discussions
Sustainable
supply chain
Prevention
of corruption
and bribery
Financial
performance
Tax
transparency
ESG risk
management
Prevention
of money
laundering and
financing of
terrorism
Material topics
Envronmental topic
Social topic
Governance topic
Non-material topics
Impact materiality
Figure 5: Double materiality matrix

Each sustainable step
that we take today leads
to a better future for
all of us.
The NLB Group is the
first bank headquartered
in South-Eastern Europe
committed to achieve
climate neutral financing
and investment portfolio
by 2050.

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DMA methodology
The basis for the preparation of this Sustainability
Statement the conducted DMA, which defined the
matters that are material from at least one of the
following perspectives:
• impact materiality: NLB Group’s operations may
have positive or negative impacts on people and the
environment.
• financial materiality: Sustainability topics may
involve risks and opportunities for the Bank’s financial
position and performance.

The Double Materiality Assessment followed the
methodology outlined in ESRS 1 and ESRS 2, guidelines
from the European Financial Reporting Advisory Group
(EFRAG), and included specifics of the banking sector by
using best available tools and data, such as the UNEP
FI Impact Materiality Tool. The top-down approach was
used with the Sustainability Unit and the established
internal subject matter expert group in NLB who took
into consideration the entire NLB Group. The internal
expert group included sustainability representatives of
key competence lines in NLB as a parent bank for the
banking stream, and sustainability representatives from
the leasing and asset management stream.
In the initial stage of the DMA, all NLB Group members
were preliminarily assessed for their impact on
sustainability and financial performance in line with
NLB Group’s business model, governance principles,
and value chain. As the most relevant activities in NLB
Group are executed by core financial members (NLB
and its subsidiaries: banks, asset management, leasing
companies), these were deemed to have the highest
IROs. An internal expert group identified and assessed
IROs bearing in mind the operations of all core financial
members, and their stakeholders were engaged via a
pool to assess impacts. Non-financial members were
considered to have minor IROs, and their operations
were assessed indirectly by the internal expert group.
Non-core members (e.g. companies in liquidation and
those with a small number of employees) were deemed
to have negligible or no impact, risk, or opportunity,
and were not subject to further DMA stages. Finally,
IROs at the NLB Group level were assessed by the NLB
Management Board, a member of the NLB Supervisory
Board, and investors.
DMA process
1. Defining the sustainability context
We first scanned various information sources to identify
relevant ESG topics for the wider financial sector and
specifically for the NLB Group. This "sustainability
context analysis" included a review of internal
documents, specific regulatory requirements, sector
specific standards and materiality assessments, the
annual reports of peers, and an analysis of our value
chain and portfolios.
2. Preparation of the list of sustainability topics
After analyzing the sustainability context, we prepared
a long list of topics based on the list of topics and
subtopics from paragraph 16 of Annex A to ESRS 1,
as well as additional topics specific to the sector and
NLB Group. We then excluded all topics that were
deemed irrelevant, i.e. they were not detected in the
reviewed documentation, and prepared a shortlist of 28
potentially material topics by grouping several
sub-topics together.
3. Identification of IROs
Based on the shortlist, we performed further analytical
work, and organized workshops and stakeholder
consultations to identify positive and negative, actual
and potential IROs (IROs). We identified the source of
each IRO, namely own operations, portfolio, upstream
value chain (namely, supply chain), or downstream
value chain (excluding portfolio-related impacts). Each
impact was assessed to be either short-term, medium-
term or long-term, based on the expectation of when it
would materialize. We also identified short-, medium-
and long-term risks and opportunities. Risks and
opportunities either originated from our existing risk
management registries derived from specific impacts
we identified, or were identified based on additional
research and internal expert input. Altogether, 141 unique
impacts, 84 unique risks and 46 unique opportunities
were identified.
4. Impact materiality assessment
Internal NLB experts assessed each impact considering
the severity and likelihood on a 1–5 scale (with an
individual assessment scale, scope and irremediability
within the severity parameter).
Impact identification and assessment were further
supported by the results of the UNEP FI Impact
Assessment, which was used as an input for assessing
positive and negative impacts related to our portfolios.
The UNEP FI has created an ESRS interoperability
package to improve compliance using the analysis tool.
This package includes mapping UNEP FI's impact topics
to ESRS sustainability topics in Appendix A of ESRS 1,
mapping tool outputs to the 'Scale', 'Scope', 'Severity',
and 'Irremediable character' parameters required by
ESRS 1, and describing how to calibrate and translate
these parameters into thresholds to identify the most
significant impacts. Following the UNEP FI Impact
Assessment Toolkit, we identified impacts of our retail,
corporate and investment portfolios for our banking
units in Slovenia, Bosnia and Herzegovina, Serbia, North
Macedonia, Montenegro, and Kosovo. Consolidated
assessments by internal experts were corroborated
through the impact assessment within an extensive
stakeholder engagement. The final score reflects the
assessment of all stakeholders.
Impacts, Risk, and Opportunity Management
IRO-1 Description of the processes to identify
and assess material IROs (Double Materiality Assessment)

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5. Financial materiality assessment
Internal NLB experts assessed each financial risk and
opportunity considering the magnitude of financial
effects, defined as positive or negative impact on our
profit or reputation and likelihood. A 1–5 scale was used,
estimating the approximate financial effect of each risk
and opportunity in monetary terms.
Throughout the process, we worked to align and
integrate our methodology and procedures with already
existing risk procedures of NLB Group. Climate-related
and environmental risks were already assessed by
NLB Group risk materiality following ECB guidelines as
outlined in chapter SBM-3 Material climate-related IROs
and were not subject to additional assessment. In the
coming years, we plan to enhance the integration of the
risk identification and assessment procedures utilized in
the Double Materiality Assessment into our overarching
risk management framework and overall management
in the competence lines.
6. Stakeholder engagement
We carried out stakeholder consultations using a
survey to gather the views of internal and external
stakeholders on the IROs that are most material from
their point of view.
Stakeholder engagement was focused on affected
stakeholders, namely employees, clients, and suppliers
(and vendors in the case of our leasing activities), who
were given the opportunity to assess different ESG topics
(based on identified impacts) and also provide their
own input on potentially missing impacts. Investors as
key users of financial statements were also included in
the consultations, and they were asked to assess and
validate different ESG topics from the impact, risk, and
opportunity perspective. The Management Board and
the Supervisory Board member were similarly included,
assessing IROs through a survey.
The survey was conducted in Slovenia, Croatia,
Bosnia and Herzegovina, Serbia, North Macedonia,
Montenegro, and Kosovo. In total, we gathered 2,179
responses from our stakeholders.
The results of stakeholder engagement were integrated
into the final Double Materiality Assessment.
7. Analysis and selection of material IROs and topics
Finally, the materiality for each topic was determined,
with the highest assessment of any impact, risk,
or opportunity, identified under a specific topic,
determining the materiality. A materiality threshold
for impact materiality and financial materiality was
determined at 50% of the average assessed value,
determining 76 IROs and 21 topics as material.
The list of material topics is presented in chapter
Overview of ESRS and entity-specific topics. The list of
material IROs is presented alongside each sustainability
topic in Environmental, Social, and Governance
information.
Decision-making process
Double Materiality Assessment (DMA) was conducted
by internal subject matter experts from all relevant
NLB competence lines and in cooperation with the
Management Board. This ensured the assessment was
informed and objective. The Sustainability Unit led the
entire process, coordinating with various competence
lines and NLB Group members to maintain a clear
decision-making line. Together with representatives
from the Competence Lines, the Sustainability Unit
made key decisions on the methodology and process.
Internal control was done by the Sustainability Unit, who
oversaw the entire DMA process. The final results of the
DMA were confirmed by the NLB Management Board
and presented to the Supervisory Board.
The DMA process, methodology, and key decisions
were documented ensuring the replication and
upgrade of the process. The Group will also monitor the
development of the DMA for financial institutions and
adjust the process as needed to improve assessment
quality. Since the DMA, in line with CSRD, was conducted
for the first time, the Group will report any process
changes in future sustainability statements.
Key steps in the DMA process
Defining the
sustainability
context
Preparation
of the list of
sustainability
topics
Identification
of IROs
Impact
materiality
assessment
Financial
materiality
assessment
Stakeholder
engagement
Analysis and
selection of
IROs and
material topics
1
2
3
4
5
6
7

Environmental Information
The conducted DMA reconfirmed Climate Change as a material sustainability
topic for NLB Group. In this section, we unveil our transition plan, ie. the NLB Group
Climate (net-zero) strategy, and our climate-related IROs across three material
sustainability matters - Climate Change, Energy, and Sustainable Finance. We
highlight our policies, targets, metrics, and actions for reducing emissions and
managing climate risks, and report on our energy consumption. This showcases
our proactive approach to resilience and long-term value creation, reinforcing our
commitment to sustainability.

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E1 Climate Change
NLB Group acknowledges the pivotal role it plays in
supporting the transition to a net-zero6 emissions
economy by 2050. Thus, NLB Group has committed
to managing the impacts, risks, and opportunities
stemming from climate change. This includes
decarbonizing its financing and investment portfolio,
supporting clients in high-impact sectors with credible
transition plans, and reducing emissions in its own
operations.

Transitioning to a net-zero emissions world subsequently
implies that all economic actors need to work towards
this objective. For financing institutions, including NLB
Group, this requires changes in their capital allocation
or granting criteria, engagement with clients to
navigate their net-zero journeys, managed phaseouts
of carbon-intensive economic activities, and a massive
re-orientation of capital flows towards "transition"
activities and solutions. By acting in an aligned manner,
banks can support a consistent best practice approach
and drive further efficiency across the whole economy
towards a net-zero emissions pathway.
Financed emissions (Scope 3, Category 15 under the
GHG Protocol) make up more than 99% of NLB Group’s
carbon footprint, making them the core focus of the
overall NLB Group net-zero transition strategy. Reducing
these emissions through targeted measures, client
engagement, and climate-positive financing is essential
to achieving net-zero commitments and sectoral
decarbonization. Following an holistic approach, in
addition to the Net-Zero Portfolio Strategy, NLB Group
has established an Operational Emissions Net-Zero
Strategy, which focuses on emissions from NLB Group’s
operational activities.
In line with NLB’s commitment to a climate-positive
future (i.e. fostering a mindset of proactive positive
impact, rather than merely reducing harm) and its net-
zero ambition, NLB group officially joined the UNEP
FI Net-Zero Banking Alliance (NZBA) in May 2022.
Thus, NLB Group committed to aligning its financing
activities with decarbonization and climate resilience.
This commitment is supported by policies such as the
Coal Exclusion Policy and active backing for renewable
energy and energy efficiency projects.
The NLB Group is included in the EU benchmarks
aligned to the Paris Agreement according to the
exclusion criteria of Commission Delegated Regulation
(EU) 2020/1818 (the Climate Benchmark Standards
Regulation).
Alignment with Paris
Agreement

Net-Zero portfolio targets
As the first part of its Net-Zero Portfolio Strategy,
NLB Group has set emissions intensity targets for high-
emitting sectors, specifically Power Generation and
Iron & Steel, while focusing on financing commitments
and tracking portfolio intensity progress for Residential
and Commercial Real Estate, in line with its NZBA
commitment. These targets are benchmarked against
science-based sectoral pathways to ensure alignment
with a 1.5°C trajectory as per the NZBA target-setting
guidelines. NLB's approach is iterative, reflecting the
General scope
Baselining
Net-Zero Strategy
Transformation
Roadmap
Steering and
Implementation
Reporting and Assurance
Targets shall cover lending
activities and should
cover (on balance sheet)
investment activitis
100% coverage to be
gradually committed
over time
Banks shall establish an
emission baseline
Banks’s targets apply to
the bank’s lending and
investment activities and
shall include their clients‘
Scope 1 Scope 2 (and
Scope 3 emissions, where
possible
Within 18 months of joining,
set 2030 targets and 2050
target
Further sector targets to
be set within 36 months
Banks shell use widely
accepted science-based
decarbonization
scenarios
Banks’ first 2030
targets will focus on
priority sectors
where the bank can
have the most
significant impact
(most GHG-intensive)
Targets shall be
approved by the highest
executive level within
the bank
Intermediary targets to
be set every five years
from 2030 onwards
Annualy publish absolute
emissions intensity
Banks shall publicity disclose
their targets and report
annualy on progress
Disclose progress against
a board-level reviewed
transition strategy
The targets shall be reviewed
at a minimum every five
years
E1-1 Transition plan for climate change mitigation
6 GFANZ defines net zero as the state when anthropogenic emissions of greenhouse gases to the atmosphere are balanced by anthropogenic removals. Organisations are considered to have reached a state of net zero when they
reduce their GHG emissions following scienced-based pathways, with any remaining GHG emissions attributable to that organisation being fully neutralised, either within the value chain or through purchase of valid offset credits.
Financial Institution Net-zero Transition Plans

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dynamic nature of sectoral decarbonization, data
availability, and market developments.
To achieve its 2030 NZBA sector targets, NLB does not
rely on offsets but instead focuses on sector-specific
decarbonization levers, including client engagement,
portfolio alignment with credible net-zero pathways,
and financing solutions that drive low-carbon
transitions.
Target development follows a structured governance
framework with executive oversight and cross-functional
collaboration. Targets are reviewed at least every five
years to ensure ongoing alignment with evolving climate
science, regulatory developments, and international
commitments. Annual disclosures will track progress,
while continuous enhancements in data quality, internal
monitoring systems, and client engagement strategies
will support the Group’s climate transition efforts.
The second round of NZBA-aligned sector-specific
targets, covering additional carbon intensive sectors
such as, is scheduled for public disclosure in Q2 2025,
further advancing the Group’s net-zero commitments.
Sector-specific scenario selection, decarbonization
levers, and risk factors are detailed in the transition plan
to ensure credibility and alignment with science-based
targets, as outlined in chapter E1-4 Targets related to
climate change mitigation and adaptation.
Net-Zero targets for own operations
Target setting for operational emissions, as part
of the Operational Emissions Net-Zero Strategy,
is progressing. Given the energy market specifics
and complexity in each country where NLB Group
operates, along with the impact of carbon reduction
measures on OPEX and CAPEX, the finalization of
these targets is expected by the end of 2025.
Decarbonization
levers and key
activities
NLB Group is committed to accelerating the transition to
a low GHG emissions, climate-resilient economy through
a comprehensive strategy that focuses on leveraging its
capabilities to support high-emitting sectors in the real
economy. To drive this transition, the Group is prioritizing
key actions such as financing low-carbon technologies,
mobilizing transition finance, fostering partnerships,
developing innovative financial products, and integrating
climate risks into decision-making frameworks. As
targets evolve, NLB Group will continually refine its
approach to incorporate emerging climate risks and
opportunities, ensuring steady progress toward its net-
zero and climate resilience objectives.
This strategic approach outlined in the NLB Group’s
comprehensive Net-Zero Climate Strategy focuses on
two core levers:
• Net-Zero Portfolio Strategy (Portfolio Strategy)–
Aligning financing activities with net-zero objectives
by setting science-based targets for priority sectors,
steering capital towards sustainable activities, and
engaging with clients on their transition pathways.
• Operational Emissions Net-Zero Strategy
(Operational Strategy)– Reducing the Group’s
direct and indirect emissions mainly through energy
efficiency measures, zero-emission electricity
procurement, and operational optimizations.
Operational
strategy
Portfolio strategy
Operational strategy approved
(action plans will be prepared in 2025)
Scope 3
(financed emissions -
category 15 of GHG Protocol)
UNEP FI’s NZBA Commitment
NLB Group signed the commitment
in May 2022
First Net Zero target setting
(18 months after NZBA
commitment Q4 2023)
Second Net Zero target setting
(36 months after NZBA
commitment Q2 2025)
Scope 1
(vehicle fleet, gas combustion
for office heating)
Scope 2
(vehicle fleet, gas combustion
for emissions from purchased
electricity and heat)
Scope 3
(indirect emissions from the
value chain e.g. business travel,
waste management, employee
commuting)
Iterative process
Strategy
Emission scope
Timeline
Climate
(Net Zero)
Strategy
Figure 6: The overview of the Net-Zero Climate Strategy

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Key activities
Portfolio strategy
The levers and key actions essential for achieving
NLB Group's climate targets are further elaborated
in the chapter E1-3, where the Group outlines specific
steps and resources for climate change mitigation and
adaptation, separately for operational and portfolio
strategies.
Through a baselining exercise, NLB Group has identified
key decarbonization levers in carbon-intensive
sectors central to its financed emissions baseline,
with approximately 95% of emissions concentrated
in six sectors. For the initial net-zero targets, further
elaborated in the chapter E1-4, the Group has set
objectives for four priority sectors—Iron & Steel, Power
Generation, Residential Real Estate, and Commercial
Real Estate—which together contribute around 50%
of financed emissions. Agriculture and Road Freight
Transport have been excluded from the initial targets
due to data challenges and will be monitored for future
disclosures.
NLB Group is committed to engaging clients in these
sectors to implement decarbonization plans, including
expanding renewable energy capacity, adopting low-
emission technologies, and financing energy-efficient
real estate projects. The Group’s capital allocation
strategy supports sector-specific decarbonization
objectives and integrates policies such as coal
exclusions.
Operational strategy
In 2024 NLB Group continued to focus on its
environmental impact, especially by conducting
qualitative assessments of operational emissions
and adopting its first Operational Emissions Net-
Zero Strategy, which defines the steps and necessary
activities in climate change mitigation and adaptation to
achieve a net-zero GHG emissions balance at the latest
by 2050.
Key activities are further elaborated under E1-3 Chapter,
whereas among the main important ones are:
• Energy efficiency and reduced energy consumption
in offices: Emission reduction is closely linked to
energy consumption reduction through improvements
in energy efficiency. Main anticipated activities
are introducing energy-efficient technologies and
practices, building renovations, implementing energy
management systems, conducting energy audits and
educating employees on energy-saving practices.
• Transition from fossil fuel driven vehicles to low/
zero emission vehicles: steadily transform NLB Group
fleet to be electrified, by installing adequate charging
infrastructure, supply the vehicles with zero-emission
electricity and explore possibilities of fuel change for
special vehicles.
• Refrigerants: Cooling systems use refrigerants with
high GWP value resulting in difficulties to reduce
GHG emissions. As EU adopted legislation to reduce
emissions from refrigerants, which NLB Group will
follow as well as closely monitor technical quality of
cooling systems to prevent any leakage.
• Procurement/investment in renewable sources
for electricity production: Procuring and installing/
investing in renewable energy sources is vital for
reducing GHG emission of NLB Group’s operational
activities. Main activities in facilitating the transition
to low-carbon economy are installing photovoltaic
panels and entering into power purchase agreements
with renewable energy providers where markets
have this possibility.
• Engaging employees: home office and low-emission
commuting: During COVID-19 years first positive
experiences with work from home stimulated NLB
Group to introduce possibility for employees to
work from home. After that period NLB is promoting
homeoffice work by establishing legal basis for
employees with expected results in reducing working
area and reducing energy consumption.
• Reduced paper and water consumption and waste
production.
›› For a detailed list of measures in NLB Group in 2024,
please sefer to the chapter E1-3 Actions and resources
related to climate change mitigation and adaptation -
Operational emissions net-zero strategy.

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Resources for
transition plan
implementation

For timely and effective implementation of the transition
plan, both on the portfolio and operational level, the
Group utilizes human and financial resources for various
activities, including:
• Employee training: enhanced skills and knowledge
contribute to guaranteeing compliance with the
latest regulations, technologies, and best practices,
while well-trained employees are more efficient
and effective in their role. Consequently, employee
retention is higher, indirectly influencing the NLB
Group's reputation.
• IT infrastructure: essential to providing the NLB
Group's internal and external stakeholders with
comprehensive, relevant, trustworthy, and timely
information on sustainability and ESG matters.
• External consulting services: when implementing the
transition plan, external expertise is needed, offering
an unbiased, third-party perspective on certain
aspects. Consequently, this helps internal teams in
identifying gaps and improvement opportunities.
• Real estate and fleet: investments in energy efficiency
measures have lower operating costs and increased
market value, while at the same time lowering the
environmental impact. Additionally, it helps the Bank
to comply with the EU legislation.
• Advertising and communication: it is essential
in raising awareness about the NLB Group's
sustainability initiatives and commitments, which
not only builds trust but also attracts sustainable
investments and grows the retail business, giving the
NLB Group a competitive advantage.
Locked-in GHG
emissions

The progress towards NLB Group’s Net-Zero Portfolio
targets is significantly influenced by external factors,
particularly the decarbonization of industry and
infrastructure. Locked-in emissions, stemming from
long-term assets and investments like infrastructure,
present a considerable challenge for the Group, as these
emissions, embedded in past financing activities, limit
flexibility in meeting near-term reduction goals.

Each target has been set with an understanding of
the sector-specific dependencies on external parties,
including the pace of decarbonization in high-emitting
sectors. Achieving net-zero requires collaboration
between NLB Group, industry stakeholders, and
governments. NLB Group will continue to support public
policy developments in Slovenia and the region, as these
measures are vital to decarbonization at scale.

However, NLB Group’s role is limited, as net-zero
requires collective action. Clients must take steps
towards decarbonization, and governments need
to establish frameworks and policies to guide the
transition. Decarbonizing the industrial energy mix is
crucial, with carbon capture and storage infrastructure
playing a key role in sectors like steel production. In
Residential and Commercial Real Estate, national
energy mixes influence efficiency milestones, especially
in regions where fossil fuels still dominate electricity
production. For instance, Slovenia’s coal-fired TEŠ
power plant is scheduled for decommissioning by
2033. Additionally, homeowner engagement in energy
efficiency measures, such as retrofitting and energy-
saving investments, is critical. This progress relies on
consumer willingness and financial capacity, as well as
external factors like energy price volatility, which can
affect consumption patterns. Ultimately, joint efforts from
all stakeholders are needed for meaningful progress.

Although operational GHG emission reduction targets
are yet to be finalized, locked-in emissions have been
considered. In terms of reducing operational GHG
emissions, there will always be a certain number of
residual emissions which are not under the Group’s
control. The reasons are the following: i) dependency
on the technological (under)development/innovation
of national utility companies. For example, the Group
cannot influence the (state) utility companies’ energy
mix providing district heating, upgrade the electricity
infrastructure, provide more charging stations for
electric vehicles, open the energy market for new supply
products, etc., which consequently limits its reduction
measures to a certain extent and ii) due to the nature of
the banking business and employees’ commute to work,
causing emissions from transport. When conducting
a qualitative assessment, it is believed that residual
emissions can be reduced with the use of carbon
removal credits to offset; however, the NLB Group has
yet to decide how it will strategically address this and
will continue to closely monitor carbon credit market(s).

Alignment of
transition plan with
business strategy and
financial planning

The inaugural Net-Zero Disclosure Report, aligned with
NLB Group’s new business strategy (New Horizons), sets
a clear path for the Group’s ambition to become a leader
in transition finance and a regional ESG frontrunner.
NLB Group has established clear financial metrics and
targets to support its broader strategic ambition of
contributing to the real-economy transition, through
both financing activities and its internal operational
goals. These metrics are aligned with the Group's
overarching sustainability objectives, including the
reduction of emissions in its financing activities and
the mobilization of capital for sustainable finance. The
financial targets set by the Group reflect its commitment
to advancing its transition plan’s strategic ambition,
with a focus on key sectors such as renewable energy,
green buildings, energy efficiency, and sustainable
transportation. NLB Group classifies activities as green
using the EU Taxonomy, NLB Green Bond Framework,
and MIGA and EBRD standards, where a transaction is
considered green if it meets at least one criterion under
these frameworks.

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NLB Group has committed a total of EUR 1.9 billion in
transition financing by 2030, with the pledge divided
between Retail Banking and Corporate and Investment
Banking Green Transition Financing, focusing on
renewable energy, sustainable infrastructure, and
energy efficiency projects. In addition, NLB d.d. has
committed to financing at least 30% of new production
in the most energy-efficient commercial buildings
(<50 kg CO₂/m²) and at least 15% of new production
in top-rated mortgages (EPC class A & B) in Slovenia
by 2030.
The Group monitors progress against financial targets
quarterly, with planned annual public disclosures
against set commitments, which is presented in the table.
By the end of 2024, NLB Group had achieved EUR
1,028 million, or 54%, of its total EUR 1.9 billion
commitment in green financing by 2030. This includes
EUR 701 million (51%) of the EUR 1.37 billion target
for Corporate and Investment Banking and EUR 327
million (62%) of the EUR 528 million target for Retail
Banking.
NLB has exceeded its annual commitments for energy-
efficient buildings. As 85% of newly approved loans
were allocated to the most energy-efficient commercial
buildings (<50 kg CO₂/m²), surpassing the 30% annual
commitment. At the same time, 27% of new mortgages
fell into the highest energy class (A and B energy
performance certificates) in Slovenia, exceeding the
15% annual commitment.
Table 10: Green Financing Commitments and Progress (outstanding stock volume) in EUR thousands
Segment
Description
Target 2030
Target
coverage
FY 2024
FY 2024
Relative
to Target
Corporate and
Investment Banking
Green Transition
Financing
Renewable
Energy Projects
Solar, wind, hydro, geothermal,
bioenergy, and related
infrastructure
1,370,000
NLB
Group
700,999
51%
Green Building
Financing
EPC A, NZEB, LEED Gold,
BREEAM Excellent
Energy Efficiency
Projects
Manufacturing of batteries,
electric heat pumps, and other
energy-efficient technologies
Clean Transportation
Projects
Rail and low-carbon
transport infrastructure
Pollution Prevention
and Water Treatment
Pollution prevention and
water treatment projects
Sustainable Water
and Wastewater
Management
Projects focused on sustainable
water and wastewater
management
Retail Banking
Green Transition
Financing
Renewable Energy
Financing
Solar power plants
528,000
NLB
Group
327,143
62%
Green Building
Financing
Financing of energy-
efficient buildings (EPC A &
B, where available). Target:
15% of new production in A
& B EPC class by 2030
Energy Efficiency
Financing
Energy renovations and installation
of energy-efficient equipment
(e.g. heat pumps, lights)
Clean Transportation
Financing
Zero-emission vehicles powered
by electricity (cars and light
commercial vehicles)
Total NLB Group
Green Transition
Financing
1,900,000
NLB
Group 1,028,142
54%
Commitment to
Finance Energy-
Efficient
Commercial
buildings
Financing at least 30% of new production in
most energy efficient commercial buildings
(<50kg CO2/m2) in Slovenia by 2030
30%
NLB
85%
283%
Commitment to
Finance Energy-
Efficient Mortgages
Financing at least 15% of new production in top-rated
mortgages (A & B EPC class) in Slovenia by 2030
15%
NLB
27%
180%

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EU Taxonomy
regulation

NLB Group has developed a structured approach
to monitor and progressively increase its share
of taxonomy-aligned revenues in line with its
sustainability commitments and regulatory disclosure
requirements.

Overview
The EU Taxonomy is a classification system designed to
determine the environmental sustainability of economic
activities within the European Union. For banks, it serves
as a crucial framework for evaluating and disclosing the
environmental impact of their investments and lending
practices. By adhering to the EU Taxonomy, banks
can identify and prioritize investments that contribute
to environmental objectives, such as climate change
mitigation and adaptation. This taxonomy provides
clear criteria and standards, enabling banks to assess
the alignment of their portfolios with sustainable
goals, mitigate risks associated with environmentally
harmful activities, and support the transition to a more
sustainable economy.
Compliance with the EU Taxonomy is mandated under
Article 8 and Article 10 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, amending Regulation
(EU) 2019/2088. This legislation establishes the criteria
for determining whether an economic activity is
environmentally sustainable and provides the basis
for the EU Taxonomy's implementation across various
sectors, including banking and finance.
In line with regulation, NLB discloses in this Sustainability
Statement for the first time information about Taxonomy
alignment for all six environmental objectives as at year-
end 2024:
1. Climate change mitigation
2. Climate change adaptation
3. Sustainable use and protection of water
and marine resources
4. Transition to a circular economy
5. Pollution prevention and control
6. Protection and restoration of biodiversity
and ecosystems
Green Asset Ratio
The Green Asset Ratio (GAR) within the framework
of the EU Taxonomy measures the proportion of a
bank's assets that meet the criteria for environmentally
sustainable economic activities. This ratio serves as a
key metric for stakeholders to assess how much of a
bank's portfolio supports environmental sustainability
objectives. Banks are required to report their GAR
as part of their sustainability reporting obligations,
ensuring transparency and accountability in their
sustainability efforts.
However, while the Green Asset Ratio enhances
transparency, it does not fully capture the transition
efforts of banks. A substantial portion of the Group’s
portfolio is excluded—for example, loans to smaller
companies and international non-EU business—
meaning the actual number of aligned activities is
higher. Furthermore, banks rely on counterparties for
data, and since many of these entities are at the early
stages of their green transformation, they may struggle
to evaluate their own sustainability. Therefore, GAR
should be analyzed alongside additional disclosed
metrics and other relevant information on NLB Group’s
efforts to finance the transition.
In the Pillar III report, GAR is disclosed only for the
first two climate objectives. Therefore, there is a
methodological difference between the calculation of
both GARs, although for 2024, there is no difference in
result due to low environmentally sustainable exposures
from the last four climate objectives.
GAR flow
The Draft Commission notice issued on 21 December
2023, aims to provide clarity and improve disclosure
requirements. Notably, the Green Asset Ratio (GAR)
flow disclosure should now include all newly acquired
exposures throughout the year, rather than only net
changes.
Developments
As of 31 December 2024, the NLB Group’s GAR stands at
1.34% of total covered assets, reflecting an increase of
0.35 percentage points compared to 31 December 2023.
›› The complete reporting templates, covering
disclosure requirements, are presented in the Appendix 1
EU Taxonomy Regulatory Disclosures.
These templates are part of the Sustainability Statement
and are under limited assurance.

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Transition plan
governance

Effective governance, strategic oversight, and regular
monitoring of NLB Group’s net-zero decarbonization
plans are entrusted to the highest executives. A robust
sustainability governance structure, which includes
the Climate Change Committee, ensures that the net-
zero decarbonization plans and sustainable financing
are guided by top-level executives and implemented
effectively across all sectors.

›› Please refer to the chapter Governance for a detailed
description of the Climate Change Committee.
The transition plan, focusing on financed emissions
from NLB Group’s portfolio and incorporating the end-
of-year 2024 figures, was approved by the Climate
Change Committee and the NLB Management Board
in 2025.
NLB Group's portfolio targets have been developed
under the supervision of internal risk functions and
are approved at the executive level, in line with NZBA
guidelines. The Net-Zero strategy is regularly reported
at the Management Board of NLB d.d. as well as at the
Audit Committee of the Supervisory Board. In addition,
content, latest achievements, and plans are reported
and discussed at regular sessions of the Sustainability
Committee.
The Operational Emissions Net-Zero Strategy, which
focuses on reducing emissions from NLB Group’s own
operations, was adopted in 2024 and confirmed by
the NLB Management Board, with regular updates
presented at sessions of the Supervisory Board’s Audit
Committee. In alignment with NLB Group’s sustainability
governance structure, the operational carbon footprint
emissions are reported regularly, with interim quarterly
reports shared at regular sessions of the Sustainability
Committee. Annual results and corresponding
action plans are reviewed and approved by the NLB
Management Board.
Transition plan
implementation
progress

Significant actions have been undertaken to implement
NLB Group’s climate strategy, focusing on both the
Operational Emissions Net-Zero Strategy and the Net-
Zero Portfolio Strategy.
Following the publication of NLB Group’s first sector
targets in December 2023, to operationalize the bank’s
Net-Zero Portfolio Strategy and enhance climate-related
governance, policies, and actions these advancements
have were made in 2024:
• Governance structures have been strengthened
through two Climate Change Committee sessions,
which track portfolio progress and adjust strategies
as needed. The adoption of a sustainability policy,
approved by the Management Board, has reinforced
the integration of sustainability considerations,
including climate-related ones, into business
processes and risk management.
• Key policies to operationalize the Bank’s Net-Zero
Portfolio Strategy were adopted, incorporating
targets for emissions-intensive sectors. These policies
guide lending, investment, and risk management
decisions, aligning operations with decarbonization
goals.
• NLB Group developed a green financing offer with
clear criteria defining green transactions to support
climate change mitigation.

By the end of 2024, NLB Group had achieved 54%
of its EUR 1.9 billion green financing commitment by
2030, with progress in both Corporate and Investment
Banking and Retail Banking, further strengthening its
decarbonization efforts.
• NLB Group developed and approved its Operational
Emissions Net-Zero Strategy, marking a significant
step towards reducing its operational emissions.
Operational emissions interim targets, supported by
a detailed action plan outlining the most immediate
measures, are scheduled for preparation in 2025.

In terms of reducing emissions from our own
operations to achieve net-zero by 2050, the Bank has
continued to follow the NLB Group Carbon Footprint
Measurement and Reporting Policy, which defines
the measurement, management, and reporting of
NLB Group’s operational performance in terms of CO2
emissions. To support the reduction of GHG emissions
from our own operations, NLB Group has in place the
following three important policies:
1. The NLB Group Real Estate Strategy builds on
reducing CO2 emissions by implementing climate
change mitigation measures, mostly focused on
energy efficiency and zero-carbon electricity
procurement (where possible).
2. The NLB Group Sustainable Fleet and Company
car Management Policy provides a framework for the
use of cleaner fuels and technologies by transforming
the whole car fleet.
3. Since employee commute is one of the categories
where the expected share of residual emissions is to
be significant, NLB has adopted the Regulation on
Work From Home, which outlines conditions, health
and safety regulations, and data protection to raise
the share of employees working from home.
›› For details, please see the chapter Climate change
mitigation and adaptation policies and the chapter
Sustainable Finance.

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In accordance with the Methodology for the Assessment
of Environmental Risks in NLB Group, NLB Group
classifies climate and environmental risks into three
categories: transition risk, physical risk, and other
environmental risk. Each category is then broken
down into multiple subcategories as presented in the
table below. NLB Group has addressed many risk
drivers within each category; however, only risk drivers
typical for the region where NLB Group operates were
addressed in the materiality assessment.
Table 11: Classification and materiality of environmental risk
Climate risk
Materiality
Transition risk
• Climate policy changes
• Technological changes
• Behavioural changes
(investor and consumer sentiment)
All categories of transition risk are assessed as material over the
short- and medium-term horizons whereas the climate policy
changes are the most significant risk driver within transition risk.
Physical risk
Acute physical risk:
• Floods
• Drought
• Heat waves
• Windstorms
• Wildfires
• Hailstorms
• Freezing rain
• Landslides
Floods and drought are assessed as material over the short- and
medium-term horizons, other hazards are assessed as immaterial.
Chronic physical risk:
• temperature changes
• Reduced water availability
• Biodiversity loss
Chronic risk is assessed as immaterial over
the short- and medium-term horizons.
Other environmental risk
Ecosystem dependency risk:
• Depletion of resources
• Ecosystem service disruption
• Biodiversity loss
• Climate change impact
Ecosystem impact risk:
• Pollution
• Land use
• Habitat degradation
Other environmental risk is assessed as immaterial risk
over the short-term horizon. Over the medium-term
horizon the ecosystem impact risk is assessed as material
and ecosystem dependency risk as non-material.
SBM-3 Material climate-related IROs and their
interaction with strategy and business model

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Resilience analysis

The uniform stress-testing programme, which includes
internally developed models, stress scenarios,
and sensitivity analysis, is regularly revised and
complemented. The Group has established an internal
ESG stress-testing concept to identify the most relevant
financial vulnerabilities stemming from climate risk,
which is constantly further enhanced by considering
available ESG-related data. The stress testing considers
three NGFS II long-term scenarios (orderly, disorderly,
hot-house world), encompassing transition, physical,
and other climate & environmental risks associated with
each scenario.
The combined stress test incorporates both transition
and physical risks until 2050. This entails a permanent
impact from transition risk and projected one-time
events of physical risk (flood and drought), while
effects of the combined stress materialize after 2030.
Nevertheless, the results of the climate stress tests
showed no material impacts on the Group’s capital and
liquidity position.
As a systemically important institution, NLB Group was
included into the 2022 ECB Climate Stress test exercise,
consisting of three modules. The exercise was conducted
in the first half of 2022 and aggregate results were
published in July 2022. By performing this exercise the
ECB assessed how prepared banks are for dealing with
financial and economic shocks stemming from climate
risk. The Group’s overall results were within the range of
average peer results.
IRO-1 Identification
and assessment
of material
climate-related IROs

NLB Group has established processes for identifying
and assessing material climate-related impacts, risks,
and opportunities. The Group employs a comprehensive
approach that includes a risk assessment framework
integrating climate-related risks into our overall risk
management processes (identification and materiality
assessment of climate physical and transition risk on
the portfolio level, transaction and client due diligence,
credit approval process, alignment with climate targets,
green finance), stakeholder engagement to understand
concerns and expectations, and scenario analysis to
assess the potential impacts of different climate-related
scenarios on our operations and financial performance.
Additionally, the Group’s sustainability governance
structure includes dedicated committees and roles
responsible for overseeing climate-related risks and
opportunities, ensuring that climate considerations are
integrated into decision-making processes at all levels
of the organization. These processes enable NLB Group
to proactively manage climate-related risks and
leverage opportunities, contributing to our overall
sustainability goals.
Climate-related topics were included in the 2024 double
materiality assessment, among other sustainability
topics. The material topics for NLB Group are Climate
Change, Energy, and Sustainable Finance.
As part of the DMA, the financial materiality assessment
integrated the existing risk management procedures
and results of a comprehensive materiality analysis,
which NLB Group performs annually within its broader
risk management process.
›› Climate-related topics are also predominant in ESG risk
management, which was identified as an overall material
sustainability topic. For further details, please refer to the
section ESG Risk Management.
C&E Risk
Scenarios
(orderly, disorderly, hot house)
Transition Risk
Physical Risk
Other C&E Risk
Figure 7: NLB Group's internal ESG stress-testing concept

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Table 12: Climate – related impacts, risks, and opportunities (Climate change adaptation and mitigation)
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in the
value chain
Time horizon
Climate change
Climate-related risk
Climate-related physical risks, such as extreme weather events, can lead
to loan defaults, asset devaluation, and increased insurance claims,
thereby undermining a bank’s financial stability and risk exposure.
Risk
Downstream
Short, Medium,
Long-Term
Climate-related transition risks, driven by shifts to a low-carbon
economy through policy changes, technological advancements,
or evolving market preferences, can result in stranded assets,
increased operational costs, and credit risk for a bank’s borrowers,
potentially affecting the bank’s financial performance.
Risk
Downstream
Short, Medium,
Long-Term
Reducing financed emissions
(towards net-zero) as part of
Climate (Net-Zero) Strategy
Reducing financed emissions as part of a Climate (Net-Zero)
Strategy enhances asset value, mitigates risks, opens new revenue
streams, and improves regulatory compliance, despite potential
initial costs. This approach aligns investment with long-term
sustainability goals, positively impacting ROI and shareholder
value while building a strong reputation and competitive edge.
Opportunity
Downstream
Short, Medium,
Long-Term
Operational scope 1 emissions
NLB Group's own GHG emissions from electricity use, heating
and of own real estate and use of own vehicles contribute to
a rise in the GHG concentration in the atmosphere. This leads
to changing climate patterns, including droughts, flooding and
heatwaves, increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Own operations
Short-term
Operational scope 2 emissions
from purchased electricity and
heat and fuel for own vehicles
NLB Group's downstream GHG emissions due to production
of electricity and heating contribute to a rise in the GHG
concentration in the atmosphere. This leads to changing
climate patterns, including droughts, flooding and heatwaves,
increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Downstream
Short-term
Operational scope 3 emissions
(limited categories)
NLB Group's indirect emissions related to employee travel to and
from work, and to business travels, contribute to a rise in the
GHG concentration in the atmosphere. This leads to changing
climate patterns, including droughts, flooding and heatwaves,
increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Own operations
Short-term
Operational scope 3 emissions
from bought goods and
services (supply chain)
NLB Group's indirect emissions related to the carbon footprint of
purchased goods and services from the supply chain, contribute
to a rise in the GHG concentration in the atmosphere. This leads
to changing climate patterns, including droughts, flooding and
heatwaves, increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Downstream
Short-term
Financed emissions
from loan activity
Financed emissions related to lending to retail clients, governments and
corporates contribute to a rise in the GHG concentration in the atmosphere,
and form the largest share of NLB Group's total GHG emissions. This
leads to changing climate patterns, including droughts, flooding and
heatwaves, increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Downstream
Short-term
Financed emissions of asset and
wealth management operations
Financed emissions related to asset and wealth management,
and related investments, contribute to a rise in the GHG
concentration in the atmosphere. This leads to changing
climate patterns, including droughts, flooding and heatwaves,
increase in average temperature and sea level rise.
Impact - Actual
Negative impact
Downstream
Short-term

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Table 13: Climate – related impacts, risks, and opportunities (Energy)
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in the
value chain
Time horizon
Energy
Operational use of energy
from zero-carbon sources
Using energy from zero-carbon sources in operations reduces direct
environmental impact and aligns with sustainability goals, while also
mitigating risks like future carbon taxes and energy cost fluctuations. This
transition enhances green credentials, lowers long-term operational costs,
and appeals to stakeholders prioritizing environmental responsibility.
Opportunity
Own operations
Short, Medium,
Long-Term
Need for green investments
in renewables
Green investments in renewables drive decarbonization, reduce
reliance on fossil fuels, and support long-term climate goals.
They offer growth potential through clean energy innovations,
meet regulatory demands, and align with increasing investor
preferences for sustainable, environmentally conscious projects.
Opportunity
Downstream
Short, Medium,
Long-Term
Need for investments in
house renovation and
energy efficient buildings
Investments in house renovations and energy-efficient buildings
lower energy consumption, reduce emissions, and increase property
value. They support climate targets, meet evolving regulations,
and attract demand from environmentally conscious buyers, while
offering long-term savings and enhancing energy resilience.
Opportunity
Downstream
Short, Medium,
Long-Term
Operational use of zero-
carbon own vehicles
Utilizing zero-carbon vehicles for operations reduces emissions,
lowers operational costs, and enhances corporate sustainability
efforts. This transition improves brand reputation, meets regulatory
standards, and aligns with the growing consumer preference
for environmentally friendly practices, ultimately contributing
to a more resilient and responsible business model.
Opportunity
Own operations
Short, Medium,
Long-Term
Operational energy use
for heating and electricty
in own real estate
By using energy from non-renewable sources the company is contributing
to environmental degradation (air pollution due to emission of air
pollutants from fossil fuel combustion used for energy production).
Impact - Actual
Negative impact
Own operations
Short-term
Operational use of energy
from zero-carbon sources
NLB Group is already purchasing over half of its energy
from zero-carbon sources, thus reducing the negative
environmental impacts related to combustion of fossil fuels,
such as GHG emissions and air pollutant emissions.
Impact - Potential
Positive impact
Own operations
Medium-term
Financing and leasing of
convential vehicles
By financing loans and lease of personal vehicles with internal combustion
engines NLB Group is indirectly contributing to environmental degradation
(air pollution due to emission of air pollutants from fossil fuel combustion).
Impact - Actual
Negative impact
Downstream
Short-term

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Table 14: Climate – related impacts, risks, and opportunities (Sustainable finance)
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in the
value chain
Time horizon
Sustainable
finance
Sustainable lending products
for retail banking
Sustainable lending products for retail banking promote eco-
friendly practices by offering favorable terms for environmentally
responsible projects, such as energy-efficient home renovations
or electric vehicle purchases. These products enhance customer
loyalty, attract a growing segment of environmentally conscious
consumers, and align with regulatory expectations, while supporting
broader sustainability goals and fostering a positive brand image.
Opportunity
Downstream
Short, Medium,
Long-Term
Green lending to corporates
Green lending to corporates supports environmentally sustainable projects,
such as renewable energy initiatives and energy-efficient upgrades.
This approach mitigates climate risk, aligns with regulatory demands,
and enhances corporate reputation while attracting socially responsible
investors and fostering long-term partnerships for sustainable growth.
Opportunity
Downstream
Short, Medium,
Long-Term
Green lending to corporates
NLB Group is providing green lending to corporates and is aiming
to significantly increase its volume of green lending to corporates.
Green lending is a means to reduce the volume of financed emissions
through financing of sustainable activities of corporate clients.
Impact - Actual
Positive impact
Own operations
Short-term
Green leasing
Green leasing structures lease agreements to promote sustainable
practices and reduce environmental impacts, enabling the bank to
support eco-friendly initiatives and attract conscious tenants. This
approach enhances asset value, improves tenant satisfaction, and
demonstrates a commitment to sustainability, ultimately contributing to
long-term financial performance and a positive market reputation.
Opportunity
Downstream
Short, Medium,
Long-Term
Sub-funds in investment banking
and asset management
Sub-funds which promote environmental and social characteristics,
targeting companies and projects that prioritize sustainability
and ESG criteria. These funds attract a growing base of socially
conscious investors, enhance portfolio resilience against climate
risks, and align with regulatory demands, ultimately supporting a
shift toward sustainable finance and long-term value creation.
Opportunity
Downstream
Short, Medium,
Long-Term
Sub-funds in investment banking
and asset management
NLB Group is offering investment opportunities in sub-funds
in its asset management portfolios. This increases financing
sustainable goals. Once implemeneted, financed activities
will have a positive impact on the environment.
Impact - Actual
Positive impact
Downstream
Short-term
Sustainable lending products
for retail banking
NLB Group is providing green lending to private individuals
and micro companies. Green lending is a means to reduce
the volume of financed emissions through financing of
sustainable activities and purchases of private clients.
Impact - Actual
Positive impact
Downstream
Short-term
Issuing of green bonds
NLB Group has issued a green bond, raising several hundred
million euros for financing sustainable projects. Sustainable
projects, once implemented, will have a positive impact on the
environment. The issuing of the green bond will have positive
signalling effect on other banks and companies in the region.
Impact - Actual
Positive impact
Own operations
Short-term
Issuing green bonds provides capital for environmentally sustainable
projects, such as renewable energy, energy efficiency, and pollution
reduction initiatives. This financing option enhances market
reputation, attracts socially responsible investors, and demonstrates
a commitment to sustainability, while also meeting growing
regulatory expectations and supporting broader climate goals.
Opportunity
Downstream
Short, Medium,
Long-Term
Financing of energy
efficient buildings
NLB Group is providing finance for energy efficient buildings and has
committed to significantly increase its share of financing of most energy
efficient buildings by 2030. Energy efficient buildings require less energy,
thus contributing to lower need for energy, and to lower GHG emissions.
Impact - Actual
Positive impact
Downstream
Short-term

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IRO-1 Identification
and assessment of
climate-related risks

NLB Group conducts a materiality assessment as part
of its overall risk identification process to determine the
level of transition and physical risk to which NLB Group
is exposed. In addition, NLB Group uses all disposable
climate and environmental data and studies available
for its region (namely those provided by different
relevant state institutions) to determine the level of
environmental risk to which NLB Group is exposed. In
this process, identification of environmental risk factors,
relevant transmission channels, and their materiality
and impact on the Group’s financial performance in the
short-, medium- and long-term period are assessed.
NLB Group performs the materiality assessment in the
following steps:
• In the first step, the climate and other environmental
risk drivers relevant for Slovenia and other countries
where NLB Group is present are identified. Beside
physical and transition risk, NLB Group also considers
exposure to other environmental risks, such as
ecosystem dependency and impact (including
biodiversity risk).
• In the next step, NLB Group defines the transmission
channels to better understand how the climate and
environmental risk drivers translate into traditional
financial risk categories.
• In the third step, NLB Group assesses the probability
and impact of each identified risk driver, using
internal and external sources and methodologies.
The assessment considers the geographic location
and industry (segment) of the counterparty.
• Furthermore, NLB Group assesses how other
factors (sources of variability) which determine
the probability or the size of the impact, so-
called amplifiers, mitigants, and geographical
heterogeneity, impact its operations.
• In the final step, the materiality of the impact is
assessed. Considering probability and impact
score, final vulnerability score is determined and
assigned to each exposure. A heatmap tool is used
for representation of vulnerability to each climate and
environmental risk driver.

In line with the internal risk management rules and
procedures, NLB Group uses a 5-level scale for
assessing climate-related physical and transition risk
drivers and other environmental risk drivers:
1
Low
2
Moderately
Low
3
Moderate
4
Moderately
High
5
High
A detailed assessment of each category is performed
separately and will be described in the following
chapters. First, an extensive materiality assessment of
physical and transition risk was performed during 2023
and updated 2024. The methodology for assessment of
other environmental risks was changed in 2024, hence
the new materiality assessment was performed as of 30
June 2024 and updated as of 31 December 2024.
Real estate plays an important role in the debate
on the transition to a carbon-neutral economy. NLB
Group’s evaluation process for ESG risk management
in collateral is focused on real estate climate transition
and physical risks. Identification and materiality of
specific ESG risks for real estate in collateral is assessed
through NLB Group’s methodology for environmental
risks. Climate transition and physical risks are measured
through real estate energy performance data and
collateral location data.
Physical risk
Each of the identified physical risk drivers (presented
in the previous chapter) is assessed from a probability
(likelihood) and impact perspective. The assessment
is performed in line with internally developed
methodology, which relies on available climate and
environmental data (including insurance companies’
loss statistics), vulnerability and climate studies available
for the region (provided by different relevant state
institutions), and expert judgement. While the probability
of a severe physical risk event is evaluated based on
the location (NUTS-3 level mapping) of the exposure,
the impact of such an event relies more on the industry
(segment) of the counterparty. Probability and impact
scores are then combined into a vulnerability score. For
Residential Mortgages, the Group assesses flood risk by
using flood maps, which means that the exact flood risk
level is determined based on the micro location (exact
geospatial coordinates) of the real estate.
Climate scenarios
Assessment was performed for the short-term, medium-
term, and long-term period. While studies and scenarios
mainly project temperature and climate change until
2100 and climate change is a slow and gradual process,
the Group has defined the time horizons for assessment
of physical risks as follows:
• Short term: until 2030
• Mid-term: 2030–2050
• Long-term: 2050–2100.

Such assessment is used in the budget, forecast, or
stress test process based on the defined time parimeter
and maturity of the exposure.
In relation to physical risk, the Group considers two
different climate scenarios in the long-term period (after
2050), namely pessimistic RCP 8.5 and optimistic RCP
2.6 scenarios. Based on these two scenarios, impact
assessments were performed for different physical risks
and were used in the materiality assessment.

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A Representative Concentration Pathway (RCP) is
a greenhouse gas concentration (not emissions)
trajectory adopted by the IPCC. Four pathways were
used for climate modelling and research for the IPCC
Fifth Assessment Report (AR5) in 2014. The pathways
describe different climate change scenarios, all of which
are considered possible depending on the amount of
greenhouse gases (GHG) emitted in the years to come.
The RCPs—originally RCP 2.6, RCP 4.5, RCP 6, and
RCP 8.5—are labelled after a possible range of radiative
forcing values in the year 2100 (2.6, 4.5, 6, and 8.5
W/m2, respectively). The Group decided to use RCP 2.6
scenario, which is a "very stringent" pathway scenario,
and RCP 8.5 scenario which assumes emissions will
continue to rise throughout the 21st century.
In the short-term period, the use of different climate
scenarios for assessment of physical risk was assessed
as not material and therefore not considered. Long-
term assessment of physical risk, considering both
scenarios described, relies on the findings of climate
studies performed for our region and different studies
performed by the EU Joint Research Centre (JRC) where
different climate scenarios were considered.
Findings of the materiality assessment of physical risk
Key findings on the latest assessment as of 31 December
2024:
• Short-term exposure to physical risk is not material;
however, it is expected to increase gradually due to
climate change.
• Over the medium-term horizon, the level of physical
risk is assessed as moderately low.
• Over the long-term horizon, considering the RCP 2.6
scenario, the level of physical risk is higher, although
still at the moderately low level. Considering the
RCP 8.5 scenario, the level of physical risk over the
long-term is increased and assessed as moderate.
• From the materiality perspective we can conclude
that floods and drought are currently the only
material risk driver in certain industries and regions.
Other events are not material from a financial
perspective, though they cannot be completely
neglected. Chronic risk is also not determined as a
material risk in the short- and medium-term. From
the perspective of direct corporate exposure, mostly
the Agriculture sector in some countries is materially
exposed to physical risk (high and moderately
high level of drought) in the mid-term horizon.
Vulnerability to physical risk in other industries is
less material. Within the short- and medium-term
horizon, no exposure is allocated to the high-risk
bucket. Considering the long-term horizon, 7% of
the corporate portfolio is allocated to the high-risk
bucket under the RCP 2.6 scenario and 17% under the
RCP 8.5 scenario, which remains on the same level as
in 2023.

The impacts of climate change on physical risk
exposure of NLB Group’s credit portfolio
and business model (sensitivity)
The most relevant natural disasters are drought and
floods, while hail- and windstorms are also frequent but
less material. However, we can expect that its impact will
increase in the long run if no adequate policy changes
are implemented in a timely manner. Other events are not
material for the region and the Group’s business model.
A model for assessing flood risk based on national and
EU flood risk zones was developed – determining flood
risk on the actual location of the real estate collateral; a
model for other countries, where NLB Group is present,
is in development. For all collaterals in our portfolio,
flood risk based on micro location (high, moderately
high, moderate, moderately low, low) is expected to be
determined. Based on the analysed data, floods and
drought do cause material losses, but they do not have
a material effect on the Group’s portfolio.
Chronic physical risks in Slovenia are assessed as
immaterial to the Bank’s collateral exposure.
Some past losses in the region were observed in public
infrastructure and agriculture, but such losses were
mostly reimbursed by the government (impact on
sovereign debt). Further on, as supported by insurance
statistics, many losses caused by physical risk are
covered by insurance which also limits the impact of
these risks on the Bank’s performance.
The Group’s credit portfolio is well diversified (from the
industry and location perspectives) which reduces the
impact of such events. Stress tests performed on the
portfolio level reveal that some losses could occur due
to physical risk, though with no significant impact on the
Group’s performance.
The impacts of climate change on physical risk
exposure of collateral and real estate
These impacts could arise from both an increase of
extreme weather events (acute impacts) as well as from
gradual global warming (chronic impacts). A model for
assessing acute flood risk based on national (Slovenian)
flood risk zones and EU flood risk zones (NLB Group
members) was developed – determining flood risk on
the actual location of the real estate in collateral. For
all collaterals in the Slovenian portfolio, flood risk (high,
moderately high, moderate, moderately low, low) was
determined; flood risk assessment on the micro location
of real estate for NLB Group members is still upgrading
as countries have different available data. Currently
other physical climate risks are assessed through NLB
Group methodology for environmental risks as not
material to the Bank’s collateral exposure. NLB is in
the process of obtaining flood end other physical risk
exposure for all the collateral portfolio in NLB and
NLB Group. Measures for reducing the climate physical
risk of collateral are part of the credit approval process.

Transition risk

The assessment of transition risk is focused on the
mid-time horizon. It is based on the assumption that
the transition to a low-carbon economy will materialize
by 2050, and that transition risk will peak in the mid-
term horizon (2030–2050) as defined by the Group.
Afterwards the level of transition risk is expected to
decrease.
The assessment of transition risk factors is based on the
UNEP FI methodology, which was elaborated by
NLB Group to a more granular level. The methodology is
combined with actual emission data of a counterparty
or proxy emissions data. For Residential Mortgages
the Group assesses transition risk by using energy
performance certificate (EPC) labels, primary energy
consumption and CO2 emissions, and other information
derived from the EPC.
The methodology assumes full implementation of the
Net-Zero 2050 scenario. Other less optimistic scenarios
(slower transition) are not considered in the materiality
assessment of transition risk, while the level of transition
risk is lower in such cases. However, the Group uses
different scenarios in the climate stress test, which is
described within the resilience analysis.

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Findings of the materiality assessment of transition risk
Key findings on the latest assessment as of 31 December
2024:
• Transition risk is already recognized as a material risk
driver and is expected to reach its peak over the mid-
term horizon.
• Over the short-term horizon, the level of transition risk
is assessed as moderately low.
• Over the mid-term horizon, the level of transition risk
will increase to moderate level.
• Over the long-term horizon, the level of transition risk
is expected to start decreasing.
• As such, exposure to transition risk over the long-term
horizon is less material, therefore the focus of the
materiality assessment is the mid-term horizon. Using
UNEP-FI methodology for classification of transition
risk, only 4% of the corporate portfolio is allocated to
the high-risk bucket and 11% to the moderately high
risk bucket. 40% of the portfolio is allocated to the
low or moderately low risk bucket and the remaining
part is allocated to the moderate-risk bucket.
• From the industry perspective, above-moderate
exposures are in manufacturing, the wholesale and
retail trade, and the construction and electricity
production sectors in Slovenia and Serbia.Such
exposures are less material in Kosovo and other
countries. For these sectors, direct and indirect
emission cost factors are contributing to the above-
average risk score, although many industries will
also be heavily impacted by capital expenditure
needs (higher, above average, CAPEX risk score).
Country-wise, the overall transition risk is the lowest
in Slovenia and highest in Serbia, even though the
UNEP-FI methodology is not country specific. In
countries other than Slovenia (the rest of NLB Group),
we expect delayed transition. This means lower short-
term risk and faster transition in the mid-term period
and hence higher risk in the mid-term period.

The impacts of climate change on transition risk
exposure of NLB Group’s credit portfolio
nd business model (sensitivity)
Transition risks already arise in the short term due to
the EU’s determination reduce carbon emissions in
accordance with its ambitious net-zero by 2050 strategy.
With the implementation of NLB Group’s Net-Zero
Strategy in 2023 it is expected that the impacts of
transition risks will gradually diminish in the long run.
Nevertheless, the Group assessed transition risk as
more of a material than a physical risk. This can already
be observed through higher energy and emission
costs. There are certain industries which are directly or
indirectly related to fossil fuels and such industries are
considered riskier.
The level of transition risk does not depend only on
the industry itself but also on the companies (ESG
awareness, strategy, efficiency, etc.) and their location
(outside the EU there is less regulation).
On the portfolio level, the Group does not face any
large concentration of specific NACE industrial sectors
exposed to climate risk, whereby the role of transitional
risk is more prevalent. Based on industry segmentation
of the portfolio and corresponding emissions, the Group
has relatively low exposure to emissions-intensive
sectors in its corporate clients’ business. There is some
exposure in more emissions-intensive industries, such
as energy, transportation, industry, and agriculture;
however, exposure to clients with high emissions is
rather limited. As part of its strategy, NLB Group does
not finance companies that extract fossil fuels or operate
coal-fired power plants. In Residential Mortgages
the most important input for GHG calculation are the
buildings’ energy performance certificates.
In its initial round of NZBA targets, NLB Group has
focused on fossil-fuel-based and highly energy-intensive
sectors, such as Power Generation and Iron and Steel,
and other sectors where the Bank has substantial
emissions and/or exposure and available data. These
include Residential Mortgages and Commercial Real
Estate. Defined net-zero targets are regularly followed.
Activities are underway for setting the second round
of NZBA targets for sectors such as transport and
agriculture.
The impacts of climate change on transition risk
exposure of collateral and real estate
NLB Group's Net-Zero Disclosure Report outlines the
Group’s commitments regarding real estate, specifically
Residential Real Estate (RRE) and Commercial Real
Estate (CRE) as they represent an important part of
exposure and financed emissions.
The Group is dedicated to reducing financed emissions
in these sectors as part of its broader goal to achieve
net-zero emissions and through that reduce exposure
to climate transition risk. Therefore, specific targets
are set for reducing emissions from our real estate
portfolio, which includes both RRE and CRE. The Group
is committed to integrating sustainability criteria into
its lending and investment decisions. This approach
ensures that the Group’s real estate financing supports
the transition to a low-carbon economy and aligns with
overall sustainability goals.
Energy performance certificates provide banks with
relevant information on the energy efficiency of
buildings in collateral and exposure to climate transition
risk, so an EPC data collection initiative is in force. NLB
Group uses different sources and methods to obtain
data on EPC of the real estate in collateral as the Group
is present on EU and non-EU markets. On the Slovenian
market there is the publicly available EPC database
from the Ministry of the Environment and Spatial
Planning and the full national base is periodically
matched with NLB’s real estate in collateral; proxy EPC
were also developed for collateral stock based on the
national database. For new production information
on EPCs is also collected from the borrower at loan
origination and included in the NLB database, and
official EPC has been mandatory for new residential
mortgage loans for private individuals since the end
of 2023 (before that only in cases when EPC was
mandatory according to Slovenian law) which will, in
time, increase the share of official EPC data. In other
non-EU countries multiple difficulties were discovered
during the EPC data collection initiative. In some
countries EPCs are not established in the local legislation
(e.g. Kosovo), while in others EPCs do exist but are not
enforced by local law. NLB Group proactively acts on
those markets so that official and proxy calculations
of EPC and other energy performance documents are
obtained where possible. All missing EPCs in the NLB
and NLB Group portfolio are periodically modelled
based on available characteristics of real estate in
collateral (specifically for each country). Additional
measures are in development to increase the share of
official EPC data on all markets.

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Overview of vulnerability
to physical and transition
risk by country and by
industry

The results of the materiality assessment of transition
and physical risk over the medium-term horizon, as
explained in the previous chapters, are presented in the
following two charts. The first chart shows the exposure
of the corporate portfolio to physical and transition risk
by country, and the second by industry.

Other environmental risk
In addition to physical and transition risk assessment,
NLB Group has conducted an assessment of other
environmental risk on the Group level. Besides EBRD
methodology, the Bank also uses the ENCORE
knowledge database, which provides assessment
of other environmental risks from the dependency
(depletion of resources, ecosystem service disruption,
biodiversity loss, climate change impact) and impact
perspective (pollution, land use and habitat degradation).
The ENCORE knowledge database provides a mapping
tool to link specific economic sectors to their natural
capital dependencies and impacts. It also provides a
risk matrix that categorizes risks by their risk drivers,
severity, and likelihood. Using the ENCORE database
we have linked the environmental risks to our credit
portfolio to determine the vulnerabilities. For economic
activities where ENCORE assessment is not available
(e.g. Wholesale and Retail Trade), EBRD methodology
is applied.
ENCORE does not provide the assessment over
the different time horizons and does not consider
different climate scenarios. Therefore, the assessment
of other environmental risk based on ENCORE and
EBRD methodology is defined as mid-term horizon
assessment. However, other sources like the Aqueduct
Water Risk atlas can be used to surpass this deficiency
and to address each specific risk. Combining ENCORE
and the Aqueduct Water Risk Atlas, assessment of water
stress risk over different time horizons and climate
scenarios was performed.
3.2
3.0
2.8
2.6
2.4
2.4
2.0
1
1.5
2
2.5
3
3.5
Slovenia
Serbia
North Macedonia
Montenegro
Kosovo
Bosnia and
Herzegovina
Other
Physical Risk
4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0.0
1
1.5
2
2.5
3
3.5
A
C
G
L
I
B
F
K
H
M-S
E
D
BIH
Kosovo
Montenegro
North Macedonia
Serbia
Slovenia
Other
Physical Risk
Figure 8: NLB Group physical and transition risk by country (as of 31 December 2024)
Figure 9: NLB Group physical and transition risk by industry (as of 31 December 2024)
Transition
Risk
Transition
Risk
A
Agriculture, Forestry and Fishing
B
Minning and Quarring
C
Manufacturing
D
Electricity, gas, steam and air condiioning supply
E
Watter supply, sewerage, waste managment
and remedetion activities
F
Construction
G
Wholesale and retail trade, repair of motor
vehicles and motorcycle
H Transportation and storage
I
Accomodation and food service activities
K
Financial and insurance activities
L
Real estate activities

Other: J, M-S

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5,0
4,0
3,0
2,0
1,0
0.0
0,5
1
1,5
2
2,5
3
3,5
4
4,5
5
Findings of the materiality assessment of other
environmental risk
NLB Group a performed the materiality assessment of
other environmental risk as of 31 December 2024. Key
findings were as follows:
• Short-term exposure to other environmental risk is not
material; however, it is expected to gradually increase
and will reach its peak in the mid-term horizon.
• Over the medium-term horizon, the level of other
environmental risk is assessed as moderately low.
• In contrast to transition risk, other environmental risk is
not expected to decrease in the long-term.
• ENCORE methodology (combined with EBRD
methodology) was applied to the corporate portfolio.
17% of the portfolio is allocated to the above-moderate
risk level, of which 8% is allocated to the high-risk
bucket. 26% of exposure is allocated to the moderate
risk level and the remaining 57% is allocated to the low
or moderately low risk bucket.

The impacts of climate change on other environmental
risk exposure of the portfolio
Exposure to other environmental risk (dependency on
ecosystem services, including biodiversity loss, and impact
on the ecosystem), is not material in the short run, though
its long-term potential impact is taken into consideration.
In the short-term and mid-term horizon risk from the
impact perspective prevails while economic activities that
cause harm to the environment will be subject to increased
regulatory scrutiny. In the long-term horizon dependency
perspective should also be considered due to possible
nature degradation, also driven by climate change.
Considering the impact, dependency, and materiality
perspectives, mainly Agriculture is significantly vulnerable
to other environmental risks. Other industries are less
affected, although there are some specific industries
which are either dependent on certain natural assets or
are negatively impacting the environment and will be
subject to greater regulatory scrutiny. The main exposure
in the Agriculture sector is in Serbia; therefore, Serbia is
more vulnerable to other environmental risks than other
countries in our portfolio. This can be observed from the
charts below, which represent the materiality of other
environmental risk from the impact and dependency
perspectives. Only exposures where impact and
dependency assessment is available in the ENCORE
database are shown.
3.5
3
2.5
2
1.5
1
1
1.5
2
2.5
3
3.5
Other
Slovenia
Serbia
Montenegro
North Macedonia
Kosovo
Dependency
Bosnia and Herzegovina
Figure 10: NLB Group dependency and impact risk by country (as of 31 December 2024)
Impact
A Agriculture, Forestry and Fishing
C Manufacturing
I Real estateactivities
B Minning and
Quarring
E Construction
H Financial
and insurance
activities
F Transportation and storage
J Other
Dependency
D Electricity, gas, steam and
air condiioning supply
G Accomodation
and food service
activities
Figure 11: NLB Group dependency and impact risk by industry (as of 31 December 2024)
Impact
BIH
Kosovo
Montenegro
North Macedonia
Serbia
Slovenia
Other
A
Agriculture, Forestry and Fishing
B
Minning and Quarring
C
Manufacturing
D
Electricity, gas, steam and air condiioning supply
E
Construction
F
Transportation and storage
G
Accomodation and food service activities
H Financial and insurance activities
I
Real estate activities

Other: J, M-S

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E1-2 Policies
related to
climate change
mitigation and
adaptation
NLB Group’s transition plan to achieve net-zero
emissions by 2050 is underpinned by a comprehensive
set of policies that manage emissions-intensive and
climate-vulnerable activities. A key implementation is
the adoption of policies and internal acts that integrate
climate mitigation and adaptation into core financing
operations, such as loan origination, underwriting,
risk management, and its own operations.

These policies ensure that climate-related risks and
opportunities are embedded in decision-making
processes, guiding the approval of loans and investments
in alignment with the Group’s Net-Zero targets. They
focus on the phase-out of GHG-intensive assets by:
• reducing exposure to high-emission sectors in line
with emissions reduction targets,
• climate-related lending and investment by integrating
climate-related criteria to ensure financed projects
contribute to emissions reduction,
• portfolio engagement by supporting clients’ transition
to a low-carbon economy with climate transition
plans and aligned projects,
• and safeguards against adverse impacts by
ensuring all transactions and investments adhere to
environmental and social governance standards to
minimize negative environmental consequences.

NLB Group has also established a range of policies
focusing on reducing emissions in its own operations
and enhancing energy efficiency.
Climate-related risk
management policies
The risk management function defines rules about
risk appetite, risk strategy, credit risk, and other
risk-related topics, which are embedded in policies
and other internal acts. Unless stated otherwise, all
presented policies in this chapter apply to all NLB
Group core financial members, and their management
boards are the most senior level responsible for their
implementation. At the operational level, employees
in various departments in corporate banking, risk
management, restructuring, and others have to adhere
to rules and procedures. The policies are available to
employees in the register of internal acts, while affected
clients are informed about their contents through
communication in sales procedures, due diligence,
and agreements.
Risk Appetite and Lending Policy
Content and purpose: Integrates sustainable finance
and ESG risks into the business strategy, with a focus
on phasing out coal industry financing and setting
net-zero targets for high-emission sectors.
ESG Exclusion List (on the NLB website)
Content and purpose: Identifies sectors and risky
investments such as coal, oil, and deforestation for
exclusion from NLB’s financing portfolio.
GHG Emissions Data Collection and Assessment
Content and purpose: Mandates data collection for
clients with significant exposure, tracking carbon
intensity and ensuring progress toward sector-specific
emissions reduction targets.
Criteria and Procedures for Granting Transactions to
Legal and Private Entities in NLB and NLB Group
Content and purpose: Defines transaction approval
criteria, emphasizing risk assessment, client
cooperation, and operational standardization. It
applies to legal and private entities but excludes
private individuals and treasury transactions. The
policy aligns with NLB Group Code of Conduct, Anti-
Corruption, AML, ESG Due Diligence frameworks, and
EBRD/MIGA standards. Collaboration with clients,
regulators, and internal teams ensures compliance.
Environmental and Social Transaction
Categorization Methodology Framework in
NLB and NLB Group
Content and purpose: This policy assesses and
manages environmental and social risks in
transactions, promoting responsible practices
among corporate clients of NLB and other banking
members, excluding retail financing but covering
individuals in business activities. It addresses climate
change mitigation, water resource sustainability,
circular economy transition, pollution prevention,
and biodiversity protection while identifying and
managing associated risks. Monitoring includes
exclusion list screening, compliance checks, project
categorization, ESG risk assessment, and continuous
oversight of transactions.
NLB and NLB Group Lending Policy for
Non-Financial Companies
Content and purpose: The policy defines transaction
approval principles based on client creditworthiness,
industry concentration, ESG factors, and financing
purpose, reflecting NLB Group’s risk appetite. It
aims to generate value while avoiding speculative
transactions. Monitoring includes creditworthiness
assessment, ESG compliance, collateral requirements,
and ongoing oversight. The policy guides employees
on responsible lending practices and governance.
Lending Policy for Specific Client Segments in
NLB and NLB Group
Content and purpose: The policy defines reference
frameworks and principles for approving transactions
for specific client segments, including municipalities,
state-owned enterprises, international corporates,
project finance, and farmers. It complements the
Lending Policy for Non-Financial Companies by
specifying rules for these segments. It addresses risks
related to creditworthiness, industry concentration,
ESG factors, and financing purposes, ensuring value
generation while avoiding speculation. Monitoring
includes credit assessments, ESG compliance,
collateral requirements, and ongoing oversight.
The policy guides employees on governance,
sustainability, and compliance.

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General Methodology for Credit Rating Classification
in NLB and NLB Group
Content and purpose: The methodology defines
credit rating classification of legal entities and
entrepreneurs, excluding clients subject to specialized
methodologies. It is based on financial and qualitative
indicators, risk assessment, and creditworthiness
evaluation, integrating ESG factors. Monitoring
includes regular rating updates, qualitative
assessments, and ESG risk adjustments. The policy
guides employees on credit assessment and risk
governance.
Climate change and
energy-related policies
NLB Group Carbon Footprint Measurement and
Reporting Policy
Content and purpose: The policy defines the
measurement, management, and reporting of the
NLB Group’s operational performance in terms of CO2
emissions (Scope 1, Scope 2, and limited Scope 3).
The policy follows the Greenhouse Gas Protocol
Standard, specifically the Corporate Accounting and
Reporting Standard, prepared by the World Resources
Institute/World Business Council for Sustainable
Development. Until 2024, the external assurance of the
carbon footprint report was done by the Jozef Stefan
Institute, and the calculations verification protocol
was ISO 14064-3:2019: Greenhouse gases - Part 3:
Specification with guidance for the validation and
verification of GHG assertions.
General objectives of the policy are the following:
1. To reduce CO2 emissions footprint from own operations
and hence contribute to the fight against global
warming.
2. To comply with regulatory demands.
3. To set climate-related KPIs.
4. To identify the largest emission sources and take
adequate measures for cost-effective reduction.
5. To achieve the ultimate goal of being carbon neutral
by no later than 2050.
6. To meet the needs of external and internal
stakeholders.
7. To improve corporate reputation and accountability
through public disclosure and leadership.
NLB Group Real Estate Strategy
Content and purpose: The strategy refers to the
entire portfolio of NLB Group real estates (RE) and
is divided into three main pillars: in-use RE, run-off
RE, and development RE. The sustainable emphasis
in the document focuses on investments in energy-
efficient sources, using energy from renewable
sources, and decreasing the amount of waste to
reduce the operational carbon footprint. A special
sustainability team within the real estate area is to be
established with the responsibility of optimizing in-use
RE. In addition to the already mentioned priorities,
it would focus on upgrading the RE databases
with environmental KPIs and predicting measures
to reach set targets based on already executed
measurements and the targets set in 2025. Further to
this, space optimizations (including digitalization and
remote work possibilities) and space demands are
also incorporated, with all eventual excess space in
premises and non-business-related premises to be
monetized or used as part of local social responsibility
projects. Each NLB Group member is responsible for
the implementation of the strategy in its entity.
Sustainable Car Fleet Management and Company
Car Policy
Content and purpose: The policy responds to the
NLB Operational Emissions Net-Zero Strategy
and supplements the policy on measuring and
reporting operational carbon footprint. It defines
the assumptions and emission model for achieving
the NLB Group's operational net-zero emissions by
2050. The policy’s main goals are oriented towards
using cleaner fuels and technologies, electrifying
the internal NLB Group fleet, and considering
the limitations of the electric car park (efficient
charging infrastructure and range). It further sets
the foundation for cooperation with external and
contracted suppliers. The policy is adopted at the NLB
Group level, where NLB is the policy owner and NLB
Lease&Go is in the role of a steering function. Each
NLB Group member is responsible for the adoption
and implementation of the policy in its local entity.
Regulation on Work from Home
Content and purpose: The regulation outlines
prerequisite conditions and regulations for work from
different locations (home or abroad). It specifically
addresses the relevance, procedures to gain
this right, detailed health and safety regulations,
data protection, and information infrastructure
specifications, and follows all national health and
safety regulations. It concerns all employees in NLB
whose nature of work allows for work from home.

For more than a decade, the
NLB Youth Sports project
has been supporting dozens
of sports clubs in many
disciplines, taking more than
10,000 young people to sports
fields every year, promoting
fair play, responsible behaviour
and a healthy lifestyle.
We help build
resilience and
strengthen
values such
as discipline,
responsibility
and
cooperation.

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Net-Zero portfolio
strategy

Establishing an emissions
baseline for target setting
and lever identification
NLB Group’s net-zero journey aligns with the NZBA7
Guidelines for Climate Target Setting for Banks, focusing
on defining key sectors, levers, and establishing a
comprehensive emissions baseline. In establishing
the baseline for defining key sectors and levers for
the management of portfolio financed emissions, NLB
Group aligns its reporting and target-setting processes
with distinct regulatory frameworks. The total financed
emissions disclosed publicly follow the Pillar III Basel
framework , as defined by the European Banking
Authority (EBA), focusing primarily on non-financial
corporations and exposures in the banking book. This
provides transparency on risk and corporate exposure.
For target-setting and the establishment of an emissions
baseline, NLB Group refers to the broader perimeter of
the Net-Zero Banking Alliance (NZBA) guidelines, which
extend to a wider range of counterparties, including
general governments, credit institutions, other financial
corporations, non-financial corporations, and households.
For the 2021 baseline established in the 2023 target
setting exercise, the total financed emissions, under
the NZBA framework, of NLB Group amount to 2,516
kilotons of CO2. This includes Scope 1 and Scope 2 client
emissions from the Bank’s lending portfolio, as well as
financed emissions from the Bank’s investment portfolio,
encompassing both debt and equity investments.
The implementation of the CSRD mandates a significant
number of clients to report on their emissions. This, in
turn, will enable the Bank to progressively incorporate
the Scope 3 emissions of its clients into its financed
emissions baseline.
NLB Group remains committed to evolving its
methodologies and refining its commitments in a
dynamic process requiring continuous resource
allocation and adaptation.
Baseline breakdown by
asset class
Nearly 50% of baseline emissions are linked to
sovereign bond exposure. However, significant concern
arises from the methodological double-counting in
financed emissions, as emissions from clients, previously
accounted for in corporate and retail loans, are included
redundantly when aggregating at a national level within
sovereign bond emissions. For the sovereign bond
portfolio, GHG emissions for 2020 were applied, with
Scope 1 emissions attributed using GDP adjusted by PPP.
The lack of consensus on metrics and methods
for calculating country-level emissions presents
challenges, particularly in deciding whether to include
governmental, territorial, production, or consumption
emissions, and whether to account for LULUCF. The time
lag in verifying data further complicates the process.
As a result, the decarbonization process is expected
to unfold indirectly, with limited practical approaches
currently available. Emissions are concentrated in
Slovenia and Serbia, which together account for nearly
80% of total financed emissions, primarily due to
financial exposure rather than carbon intensity.
Figure 12: NLB Group baseline 2021, split by asset class and
entity, Total 2.516 ktCO2
49% Sovereign
bonds
46%

Corporate loans
Mortgages
5%
Car loans
1%
NLB d.d
39%
38%
NLB Komercijalna Banka, Beograd
NLB Banka, Skopje
8%
5% NLB Banka, Banja Luka
3% NLB Banka, Sarajevo
NLB Banka, Prishtina
5%
2% NLB Banka, Podgorica
0% Lease & Go
E1-3 Actions and resources related to climate
change mitigation and adaptation
Figure 13: NLB Group baseline 2021 split by asset class and
entity (total=2,516 ktCO2)
7 Guidelines for Climate Target Setting for Banks

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Figure 14: Split of NLB Group financed emissions by 10 NZBA priority sectors (ktCO2)
564
251
NLB Group
Power
Commercial Real Estate
Iron & Steel
Residential Real Estate
Agriculture
Road Freight Transport
Aluminium
Oil & Gas
0% Cement
0% Coal
4%
1%
19%
31%
3%
4%
18%
19%
8%
9%
41%
42%
Key identified levers
Among the 10 carbon-intensive priority sectors eligible
under NZBA, approximately 95% of financed emissions
are concentrated within six specific sectors: Agriculture,
Residential Real Estate, Commercial Real Estate, Road
Freight Transport, Iron & Steel, and Power Generation.
In the agricultural sector, there is currently no well-
established net-zero pathway. Moreover, the sector
exhibits significant heterogeneity, encompassing a
diverse range of activities such as crops, livestock,
fishing, and forestry. Obtaining client-level data proves
challenging due to its limited availability, primarily
because a substantial portion of the portfolio is
concentrated among smaller companies. In road freight
transport, challenges related to data are analogous to
those encountered in agriculture. Furthermore, there are
no anticipated short-term technological advances in
the near future. The progress in these two sectors will be
monitored, with specific targets for each sector expected
to be disclosed in the second phase of target setting. The
Oil & Gas, Cement, Coal, and Aluminium sectors were
excluded from the first round of target setting due to
their non-material exposure, both in terms of emissions
and financial impact within NLB Group's portfolio.
Therefore, for the initial set of net-zero targets, NLB
Group set objectives for the four sectors considered most
significant in terms of emissions, along with the financial
exposure to these sectors. The four sectors collectively
contribute to approximately 50% of financed emissions
within the prioritized sectors identified by the NZBA.

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Key actions
Building on the established baseline, NLB Group's
decarbonization strategy targets the most carbon-
intensive sectors identified in the first round of target
setting, namely Power Generation, Iron & Steel, and
Commercial & Residential Real Estate. Key actions,
outlined below, focus on reducing emissions in these
sectors, which represent a significant share of the
Group’s financed emissions.
• Data Collection – Enhancement of data collection
processes to obtain reliable emissions data from
clients, with a focus on key emission sources (Scope 1,
Scope 2, and Scope 3).
• Methodology Improvements – Continuous refinement
of calculation and monitoring processes to ensure
alignment with evolving regulatory frameworks and
industry best practices.
• Portfolio Monitoring – The establishment of portfolio
monitoring for emissions intensity to track progress
and ensure effective steering of commitments in
carbon-intensive sectors.
• Client Engagement – Engagement with clients across
relevant sectors to implement decarbonization plans,
ensuring alignment with NLB Group's targets and
facilitating the transition to low-carbon alternatives.
• Portfolio Steering and Capital Allocation – Focused
financing activities in key sectors based on set
targets, with a commitment to mobilize EUR 1.9 billion
in sustainable and transition financing by 2030.

Robust data collection is essential for tracking progress
across the portfolio and enabling effective action where
reliable data is available to drive measurable impact.
Specific actions are tailored to each sector, addressing
unique decarbonization challenges.
In Power Generation, the focus is on supporting clients'
transition through renewable energy projects and plant
upgrades. In Iron & Steel, NLB Group will facilitate the
adoption of low-emission technologies by financing
credible transition plans. For Commercial Real Estate,
NLB d.d. prioritizes the financing of energy-efficient
new builds and promoting the retrofitting of existing
properties. In Residential Real Estate, NLB d.d. aims to
support energy-efficient homes and retrofitting efforts
through green financing solutions.
Sector-specific key actions, levers, and achieved GHG
reductions for the transition plan implementation are
further elaborated under Disclosure E1-4, alongside
sector-specific targets and disclosures.
Operational
emissions Net-Zero
strategy
The operational Emissions Net-Zero Strategy is fully
in line with the Paris Agreement (1.5 °C temperature
increase) trajectory. Methodologically, the Operational
Strategy is built on Greenhouse Gas Protocol and
it incorporates the Bank's commitment to become
net-zero by 2050 (NZBA), while fulfilling the
requirements of the SBTi. Also, relevant EU legislation
with an impact to reduce the potential of GHG emissions
has been transferred into principles and assumptions
of the NLB Group operational emission model and
reduction target setting8.
Establishing an
operational emissions
baseline
Even though NLB Group started to report its operational
carbon footprint already in 2021 for the period 2019–
2021, the Operational Emissions Net-zero Strategy has
been harmonized with the Portfolio Net-Zero Strategy
and sets its baseline year to 2021. The Strategy was
prepared according to the internationally recognized
carbon footprint corporate reporting standard,
the Greenhouse Gas Protocol. For the purpose of
calculation of NLB Group’s carbon footprint the
Corporate Standard (Corporate Accounting and
Reporting Standard) and Corporate Value Chain (Scope
3) Accounting and Reporting Standard were used. In
setting the approach for consolidating GHG emissions,
NLB Group followed the accounting principles and
hence used the financial control approach in terms of
setting organizational boundaries.
The calculation was made using key principles
as introduced by the GHG Protocol: relevance,
completeness, consistency, transparency, and accuracy.
To provide the highest level of the adoption of key
principles, a centralized approach was used for data
gathering and calculation, i.e. data were gathered and
calculated on the individual group member level and
reported to the corporate level, where the total
NLB Group GHG emissions were calculated.
The Operational Emissions Net-Zero Strategy considers
full Scope 1 and Scope 2, and limited Scope 3, including9:
• Category 1 (Purchased Goods and Services): use of
paper and water supply
• Category 3 (Fuel- and energy- related activities):
Fuel- and energy-related activities not included in
scope 1 (well to tank - WTT) or scope 2 (transmission
and distribution losses – T&D)
• Category 5 (Waste Generated in Operations)
• Category 6 (Business Travel)
• Category 7 (Employee Commuting) of GHG Protocol
Scope 3

›› For details on the exclusion list with detailed
explanations of each Scope and Category, please refer to
Chapter E1-6.
8 Energy efficiency Directive, National Energy and Climate Plan
9 NLB Group operational emissions measurements for 2021 do not yet include the Scope 3 categories water, waste, and business travel, since the data were insufficient at the time; however, it develops the trajectories until 2050.

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Operational emissions
model
NLB Group’s operational emissions model has been
prepared based on the Paris Agreement 1.5°C trajectory,
the EU’s climate change mitigation obligations, input
data from carbon footprint calculations, assumptions on
the level of each emission source, and various already
planned emissions reduction activities. The model
provides a tool to explore potential changes in net-
zero and intermediate targets using potentially stricter
emissions targets or requirements.
NLB Group’s net-zero emissions baseline GHG emissions
account for 35,804 t CO2eq in 2021 for all reported
scopes (considering the number of NLB Group members
at the time). Projected possible reductions have
been determined to guide the implementation and
operational strategy. Using the NLB Group emissions
model and relevant assumptions, along with planned
activities and legislative measures, significant reductions
in emissions are anticipated by 2050 and 2030
compared to the baseline year 2021.
The strategy trajectories follow the EU proposal, which
is in -line with the Paris Agreement, to reduce emissions
by 55% by 2030 and 90% by 2040 (EU target proposal).
The highest emissions reduction is to be achieved in
Scope 2.1, electricity usage. NLB Group recognizes the
immediate need to start preparing everything necessary
to reach demanding net-zero and intermediate targets
and start implementing the NLB Group Operational
Emissions Net-Zero Strategy.
Scope 3.6
Scope 3.7
Transport model
Electricity model
Refrigerants model
Vehicles model
Building model
NLB Group
Emissions model
Scope 1.1
Fuels
Scope 1.2
Pasenger vehicles - fuels
Special vehicles - fuels
Scope 1.3
Refrigerants
Scope 2.1
Electricity - El. vehicles
Electricity offices
Pasenger km
Pasenger km
Scope 2.2
Disctrict heating
Scope 3.1
Paper/Water
Scope 3.5
Waste
Figure 15: Structure of the NLB Group Net-Zero Operational Emissions Model

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Table 15: Key energy efficiency and emission reduction measures
File of operation
Measure category
Activities in 2024 in NLB Group
Electricity supply
Zero-carbon electricity
procurement
Continuation of zero-emissions supply in Slovenia and Serbia
and as of August onwards also North Macedonia.
Renewable electricity
self-sufficient supply
Review of PPA possibilities in the Region
Installation of solar power plants where possible according to technical capabilities
of the facilities and the possibility of obtaining appropriate approvals
Energy
consumption
Energy efficiency
Start of preparations for energy audit visits to all
high-consumption locations (Serbia)
Energy certification of all RE and adapting renovations
according to energy class (Sarajevo)
Installation of energy-efficient windows in the renovated branches,
Installation of LED lights when renovating facilities and motion sensors for lights
Full or partial switching-off of night lighting and illuminated signs at night
Adjusting the lighting intensity depending on the number of employees in the room
Heating & Cooling
Recommended heating and cooling temperatures where possible (maximum
heating during winter is 21°C, during summer maximum cooling is 25°C).
Installation of BMS / CNS systems where possible and economically justifiable
Replacing fossil fuels heating with heat pump heating where possible
Reduction of time for ventilation/heating in facilities and, where technically
possible, an increase of the percentage of waste air recovery
Resources use
Water
Reduced water consumption by installation of water pipes with sensors
Fixing malfunctions in water infrastructure
Paper
Continuation of achieving set goal in Paperless project
Waste
Separation and start of activities (in some cases together with utility
companies) to provide more exact waste consumption volumes.
Waster & Water
Raising awareness among employees on waste
separation and resources use (reduction)
Employee's commute
Possibility to work from home
Sustainable living
Celebrating Earth Day
Sustainability Festival with a special emphasis on workshops
on Digital Waste Cleaning and Sustainable Mobility
Real estate use
De-investment
Optimization of space-demand

Relocation to facilities with optimized areas and more energy efficient facilities
Sale of facilities not needed for operations
Renovation
Renovation of buildings and implementation of energy-efficient materials/devices
Sustainable
mobility
Fleet
Fleet replacement for hybrid, plug-in hybrid, and electric vehicles
Installation of electric vehicle charging stations
Energy consumption and energy efficiency
In accordance with the accepted Operational Emissions
Net-Zero Strategy, the necessary action plan for
individual NLB Group members is being prepared, to
achieve the goal of being carbon neutral by 2050 or
sooner. Electricity consumption represents over 30% of
the contribution to the operational CO2 footprint; when
adding heating and cooling, this is over 50% of all NLB
Group CO2 operational emissions. For this reason, NLB
Group places considerable focus on reducing electricity
consumption and ensuring that electricity is purchased
from zero-emission sources where this is possible and
in accordance with local energy legislation and the
availability of CO2-free sources.
To achieve the goal of net-zero by 2050, a
comprehensive review of individual buildings that
represent the largest consumption of energy and/or are
the least energy efficient is being conducted.
In addition, a detailed real estate database has been
established (iNep) for all NLB Group properties, where
various indicators of energy consumption, including
calculation of CO2e, are visible. Such an approach
provides additional information on facilities that need
increased attention to energy efficiency.
Waste
In NLB Group, we strive to separate all waste according
to various materials, mainly paper, plastic, organic
substances, and glass, which are removed by local
utility companies. Hazardous waste, construction waste,
and waste electronics are also sorted and disposed of
into the appropriate containers or to an appropriate
disposal site. We constantly strive to increase awareness
among employees to reduce the generation of waste.
In some locations we also compress certain waste
ourselves, which reduces the need to take waste to the
disposal site.
Water
When renovating buildings, we look into the possibility
of installing taps with water flow sensors, as well as
the installation of toilet cisterns with the possibility of
flushing different amounts of water. We constantly strive
to increase awareness among employees regarding the
reduction of water consumption.

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Sustainable mobility
Preventing and mitigating the negative impacts of
climate change is vital for NLB Group. In 2022, the
entire NLB Group adopted the umbrella NLB Group
Sustainable Car Fleet Management and Company
Car Policy, which all NLB Group members follow in
all member countries to achieve the replacement of
fossil-powered fleet vehicles with alternative-powered
vehicles, according to the plan and in alignment with
the possibilities and planned costs of the vehicle
replacement.
Table 16: Overview of car mix in NLB Group
Status
Status
Plan
2023
2024
2025
Plug-in hybrid (PHEV)
2%
15%
16%
Hybrid (HEV)
19%
37%
58%
Battery electric
vehicle (BEV)
15%
23%
26%
Internal combustion
engine vehicle (ICE)
64%
25%
0%
Note: Summit Leasing Slovenia and Mobil Leasing, Zagreb are not
included.
In the NLB Group’s Operational Emissions Net-Zero
Strategy it is assumed that the NLB Group replacement
of fossil-powered fleet vehicles with alternative-
powered vehicles will continue to take place in all NLB
Group members in the four-year cycle. The second
replacement cycle starts in 2025 and will last until
2029. The first important milestone for the NLB Group
Fleet will be achieved in 2025 as all vehicles with
internal combustion engines (ICE) will be replaced
with alternative-powered vehicles. In addition, the
main emission reduction measure will be vehicle fleet
modernization with a strong increase in the share of
battery electric vehicles (BEV).

Key activities in the electrification of the fleet:
• Use of cleaner fuels and technologies.
- Efficient vehicle use: raising environmental
awareness of drivers and ECO driving.
- Respect for the speed limits.
- Careful fleet company car selection between
BEV, PHEV, and HEV based on Total Rental
Costs (TRC).
- Usage comparison, and based on operational
requirements for each working position or
specific use.
- Supporting the change in the mindset of
company car users.
- The FMO (Fleet Management Office) will follow
new technologies and organize presentations
and training, if needed, to ensure a smooth
transition.
- Use of electric energy obtained from RES
(Renewable Energy Sources) to support own
company car charging network.
• Limitation of the electric car range risk (selection of
cars based on demand and real range).
• Efficient charging infrastructure (higher capacity
batteries and efficient and faster charging will
contribute to better BEV range and usability).

Paper use – paperless project
NLB Group is actively encouraging the reduction of
paper use while enhancing the digitalization of its
operations, including digitizing services and client
documents, as well as automating and streamlining
internal processes across the Group. The goal is to
improve user experience, boost operational efficiency,
improve employee and operational efficiency and
minimize environmental impact. The Paperless
Collaboration project, initiated in 2020, aims to enhance
user experience, increase operational efficiency, and
reduce environmental impact. The objective is to achieve
a 50% reduction in paper prints by 2025 (compared to
2019) through the elimination of paper use wherever
possible, supported by optimized digital processes
and tools.
In 2024, the largest decline was achieved in NLB
lowering prints by 18% (by 2.2 million pages compared
to 2023). Among all banks in the Group, NLB KB
Belgrade has the largest share in paper usage (47%)
and the biggest environmental impact by lowering
prints by 3 million pages (9% less prints than in
2023). Not all NLB Group members had a reduced
paper consumption due to anti-money-laundering
requirements, high sales growth, and limited possibility
of usage of electronic signature.
130,685
119,272
108,450
89,841
73,433
2019
2020
2021
2022
2023
2024
-9%
-9%
-17%
-18%
17%
31%
68.448
48%
-7%
44%
Figure 16: Paper consumption in NLB Group: number of prints (in thousands)

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Development of GHG
reduction targets
Financed emissions, falling under GHG Protocol Scope
3 Category 15, account for 99.9% of total emissions
within NLB Group, making them the primary focus of
our emissions reduction targets. While the Operational
Emissions Net-Zero Strategy is in place, operational
emissions targets will be defined and implemented
in 2025. This approach highlights the pivotal role of
portfolio emissions in achieving NLB Group's long-term
climate goals.
NLB Group uses science-based scenario pathways to
limit global warming to 1.5°C, committing to meet its
2030 sector targets without reliance on offsets. Instead,
the Group focuses on monitoring industry standards
for offsets as they evolve. Targets, developed under
internal risk supervision and executive approval, are
aligned with NZBA guidelines and will be reviewed
every five years to remain consistent with international
agreements or national goals.
NLB Group’s Net-Zero Portfolio Strategy, which covers
financed emissions (Scope 3, Category 15), addresses
lending activities that include clients' Scope 1 and Scope
2 emissions. Initial emissions reduction targets were
set within 18 months of joining the NZBA, focusing on
the identified priority sectors under the established
baseline, including high-emission industries and key
areas of financial exposure, as detailed in the chapter
E1-3 Decarbonization Actions and Levers, where
prioritization is explained. The second round of target
setting, encompassing additional relevant sectors, is
scheduled for public disclosure in Q2 2025, marking
the 36-month milestone of NLB’s Net-Zero NZBA
commitment.
However, significant gaps remain in Scope 3 data
quality, particularly for small and medium-sized
enterprises in the SEE region. NLB is committed to:
• Encouraging client participation in GHG accounting
and reporting.
• Enhancing proxy calculation methodologies through
collaboration with leading data providers.
• Continuously refining target-setting approaches to
align with international best practices.
• Including facilitated emissions from capital market
activities in set targets by November 2025.
• Integrating Scope 3 client emissions into target setting
and the overall target structure by 2026.
E1-4 Targets related to climate change
mitigation and adaptation
Table 17: GHG reduction commitment in the first round of NZBA target setting
Sector
Details
GHG Baseline
Performance
Target
Coverage
GHG 2030
Targets
Target
Coverage
Scope(s)
included
Scenario
used
Unit of
measurement
Baseline year
Baseline
2023
2023 relative to
baseline
2030 Target
Relative to
baseline
Power Generation
1 and 2
IEA NZE
t CO2/Mwh
2021
0.232
0.201
-13%
0.165
-29%
NLB Group
Iron & Steel
1 and 2
IEA NZE
t CO2/t
2021
0.600
0.839
40%
1.070
/
NLB Group
Commercial Real Estate
1 and 2
IEA NZE
kg CO2/m2
2021
120
57
-53%
39
-68%
NLB
Residential Real Estate
1 and 2
IEA NZE
kg CO2/m2
2021
43
37
-14%
19
-56%
NLB
Notes:
(i) NLB continues its commitment to coal exclusion introduced in 2021, with the existing exposure to be phased out.
(ii) The majority of exposure is covered by clients’ decarbonization plans. The increase in intensity stems from missing clients' Scope 2 data in the baseline but remains below the pathway scenario and 2030 target,
ensuring alignment with decarbonization goals.
(iii) National Energy and Climate Plans do not exist outside the EU, and there are inconsistencies in Energy Performance Certificate (EPC) methodologies within the region. Despite these challenges, NLB is committed to financing at least
30% of new production in the most energy-efficient commercial buildings (<50 kg CO₂/m²) and at least 15% of new production in top-rated mortgages (A & B EPC class) in Slovenia by 2030.
(iv) Emission intensity targets are set as gross targets, A location-based approach is used for portfolio monitoring, ensuring transparency and consistency in tracking progress. Compared to the market-based method, which reflects
emissions from electricity that companies have purposefully chosen, the location-based approach accounts for the average emissions intensity of the grid where consumption occurs.
(v) NLB intends to forgo the utilisation of offsets to achieve its 2030 NZBA sector targets. Instead, the bank will monitor and contribute to the development of industry standards for offsets as they emerge. NLB will also engage with its
clients to encourage them to formulate their own net-zero strategies, which may involve utilising carbon credits to offset residual emissions in accordance with scientific guidance.
Overview of GHG emissions reduction targets

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NLB Group reports on progress for the first time
since the disclosure of targets. Due to the reliance
on publicly reported emissions data from clients,
required for the calculation of sector emissions
intensity, reporting on emissions profiles is based
on a one-year lag, in comparison to the timeline for
financial reporting.

Effective data collection and stakeholder engagement
are essential for setting emission intensity targets and
monitoring progress. Data gathering plays a crucial
role in ensuring the accuracy and relevance of targets,
requiring direct engagement with stakeholders. Scope
1 and 2 emissions data were collected from various
sources, including annual disclosures, publicly available
information, direct communication with relevant
stakeholders, and collections of Energy Performance
Certificates (EPC) for individual properties in the
Residential Real Estate (RRE) and Commercial Real
Estate (CRE) sectors. This comprehensive data collection
process ensures that the targets reflect an accurate and
thorough understanding of emissions across key sectors.

Annual progress reports will track performance, and
NLB Group is enhancing internal systems for target
monitoring and tracking. Individual sectoral specifics,
such as scenario selection and specific decarbonization
levers, are further detailed in the sectoral breakdown,
providing a comprehensive explanation of the
approaches to emission reductions within each sector.
Power generation target
NLB Group has set the target for its Power Generation
portfolio on the Group level, guided by the IEA NZE
WEO 22 pathway. In the NZE 2050 scenario, global
power generation reaches net-zero emissions by 2040,
enabling the global economy to meet its 2050 target.
The scenario envisions an average energy efficiency
of -0.005 tCO2 /MWh across our power generation
portfolio by 2050 and interim target of 0.165 tCO2 /
MWh by 2030. This target builds on the Group's 2021
commitment to exclude coal financing and phase out
existing coal exposures.
In 2023, NLB Group achieved a 13% reduction in
emissions intensity for Power Generation, lowering it
from 0.232 tCO2/MWh to 0.201 tCO2/MWh compared
to the 2021 baseline. This progress is attributed to a
focused effort on financing renewable energy sources at
the Group level, with key challenges including the need
for unified data collection across the Group and the
integration of Scope 1 and 2 emissions from all
legal entities.
NLB Group will achieve its net-zero target through
ongoing client engagement, incentivizing the
development and implementation of decarbonization
plans, including expanding renewable energy capacity,
decommissioning fossil-based power production, and
upgrading renewable energy plants for improved
efficiency. With significant exposure to renewable
energy, the Group has committed to further boosting this
carbon-neutral sector through targeted financing.
Achieving this target will require support from the EU and
national-level incentives to develop renewable-energy
production facilities, including funding for such projects.
Despite NLB Group's significant exposure to renewable
energy, progress will be contingent on these external
incentives.
Target science-based alignment,
methodology, and decarbonization levers
Figure 17: Power generation
Emission Intensity in tCO2/MWh
0.495-
0.395-
0.295-
0.195-
0.095-
-0.005-
0.232
0.165
2020
2025
2030
2035
2040
2045
l
l
l
l
l
l
0.201
NLB Group baseline
2030 target
NLB Group EoY2023 status
Decarbonization Pathway IEA NZE WEO 22
NLB Group Progress
-29%
Emission Intensity
-13%
2021-2023

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Iron & steel target
NLB Group’s target scenario for its Iron & Steel portfolio
follows the IEA NZE 1.5°C pathway, aligned with global
net-zero data from IEA scenarios. This scenario aims
for an average energy efficiency of 0.108 tCO2/t steel by
2050, with an interim target of 1.070 tCO2/t steel by 2030,
set at the Group level. NLB Group’s 2021 baseline stands
at 0.600 tCO2/t steel, already significantly below the
2030 target.
The steel industry can achieve net-zero targets by
adopting low-emission technologies, using low-carbon
feedstock, and advancing existing decarbonization
plans. Key actions include supporting clients using low-
emission technologies (e.g., electric arc furnaces) and
ensuring clients with decarbonization commitments
implement their plans. Additionally, decarbonizing the
regional industrial energy mix and establishing carbon
capture and storage networks will be essential for
enabling steel producers to meet net-zero targets.
In FY 2023, NLB Group observed an increase in emissions
from the baseline of 0.600 tCO2/t to 0.839 tCO2/t in the
Iron & Steel portfolio. This increase is primarily due to
the unavailability of some client Scope 2 emissions data
at the time of baseline calculation. Additionally, the
portfolio's limited exposure to a small number of clients
can lead to significant fluctuations in intensity levels from
new business.
NLB Group’s exposure is largely with clients already
progressing in their decarbonization efforts. The majority
of our existing clients produce steel via the electric arc
furnace (EAF) route using scrap steel, resulting in a
current sector portfolio intensity well below the European
average of 1.81 tCO2/t for integrated steel production, as
reported in the JRC Technical Report on Greenhouse Gas
Intensities of the EU Steel Industry10.
For less advanced clients, NLB Group aims to
understand their current carbon intensity and strategic
targets for 2030 and beyond, positioning itself as a
strategic partner. Moving forward, NLB Group aims to
facilitate the transition of integrated steel producers
to the scrap route based on credible client transition
plans. While this may lead to a temporary increase in
portfolio emissions, it will have a significant medium- to
long-term environmental impact, contributing to the
decarbonization of production processes.
Commercial real estate
commitment
The commitment set for the Commercial Real Estate
sector is guided by the trajectory scenario aligned with
the SBTi 1.5°C pathway and data from IEA global net-
zero scenarios, This scenario envisions an average
energy efficiency of 0.4 kg CO2 /m2 across our CRE
portfolio by 2050. This science-based trajectory is
established for NLB d.d. in Slovenia, where sufficient
official EPC data allows for a robust baseline and target
setting. The national green transition targets in Slovenia,
supported by legislation, further reinforce this objective.
To meet the benchmark, NLB will focus on financing
the construction of commercial buildings with the best
energy performance certificates and promote green
loans for retrofitting and renovating existing commercial
properties to enhance energy efficiency, including the
installation of heat pumps.

In FY 2023, the Commercial Real Estate sector saw a
significant reduction in emissions intensity, dropping
from the established baseline of 120 kg CO2/m² to 57 kg
CO2/m². This progress was supported by key activities,
including the recalculation of the current emissions
intensity, factoring in actual EPC data. However,
challenges arose due to the new national energy
legislation and EPC methodologies in Slovenia.
10 JRC Publications Repository - Greenhouse gas intensities of the EU steel5industry and its trading partners
1.6-
1.4-
1.2-
1-
0.8-
0.6-
0.4-
0.2-
0-
0.6
2020
2025
2030
2035
2040
2045
2050
l
l
l
l
l
l
l
0.839
Figure 18: Iron & steel
Emission Intensity in tCO2/t steel
1.070
NLB Group baseline
2030 target
NLB Group EoY2023 status
Decarbonization Pathway IEA NZE 1.5 0C
NLB Group Progress
150-
125-
100-
75-
50-
25-
0-
120
2020
2025
2030
2035
2040
2045
2050
l
l
l
l
l
l
l
57
NLB Group baseline
2030 target
NLB Group EoY2023 status
SBTi 1.5 0C Pathway
NLB Group Progress
Reduction according to SBTi 1.5 0C
39.0
Figure 19: Commercial real estate
Emission Intensity in kg CO2/m2
-68%
Emission Intensity
+40%
2021-2023
Emission Intensity
-53%
2021-2023

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The small portfolio size means that a single transaction
can significantly impact the overall portfolio intensity.
Additionally, the 10-year validity of EPCs in Slovenia
does not reflect passive decarbonization or efficiency
improvements implemented by property owners. The
shift from calculated to metered EPCs for commercial
premises could also pose challenges, as metered EPCs
account for full consumption at metering points, whereas
calculated EPCs only account for key building systems
defined in the EPC calculation methodology.
Currently, we notice in the market only moderate
demand for the best energy-efficient buildings, as they
have substantially higher construction costs which are
not always passed on to tenants. However, NLB d.d. is
committed to decarbonizing the Commercial Real Estate
sector by ensuring at least 30% of new production
volumes in Slovenia is directed toward highly energy
efficient buildings (<50 kg CO2/m²) by 2030.
In FY 2024, this commitment was exceeded, with 85% of
new NLB Commercial Real Estate financing allocated
to energy-efficient buildings (<50 kg CO2/m²), reflecting
strong progress toward the set commitment.
Residential real estate
commitment
The benchmark scenario for Residential Real Estate is
guided by the SBTi 1.5 °C pathway and data from IEA
global net-zero scenarios. This scenario envisions an
average energy efficiency of 0.4 kg CO₂/m² across the
mortgage portfolio by 2050, with an interim benchmark
of 19.0 kg CO₂/m² by 2030.
As with Commercial Real Estate, the interim science-
based benchmark is set only for NLB d.d., as Slovenia
is the only market with sufficient official EPC data to
establish a robust baseline. Additionally, as part of
the EU, Slovenia has national green transition targets
supported by legislation.
In FY2023, NLB achieved an emissions intensity of 37 kg
CO₂/m², marking a 14% reduction from the 43 kg CO₂/
m² baseline set in 2021. This progress continued efforts to
improve the energy efficiency of the mortgage portfolio.
Key activities during the reporting year included the
recalculation of portfolio emissions intensity and the
mandatory requirement for EPCs on all new retail
mortgage loans starting in Q4 2023. Despite these
advancements, several challenges affected portfolio
assessment, including the impact of the new EPC
methodology and regulatory changes under the
Regulation on the Efficient Use of Energy in Slovenia, as
well as the 10-year EPC validity period, which does not
account for passive decarbonization or homeowner-
initiated energy efficiency improvements. For properties
without EPCs, emissions intensity was modelled using
available real estate characteristics from collateral data.
To emphasize its commitment to energy efficiency, NLB
has set a commitment of at least 15% of new mortgage
production in Slovenia to be in EPC classes A and B, with
plans to increase this share over time.
In FY2024, NLB exceeded this target, achieving 27%
of new mortgage production in these high-efficiency
classes. Additionally, the share of new mortgage
production in NLB with official EPC data is steadily
increasing, with the figure expected to rise further due to
the mandatory EPC requirement for new retail mortgage
loans introduced in Q4 2023, enhancing the accuracy of
energy performance tracking.
Achieving net-zero carbon emissions in the real estate
sector requires collaboration among all stakeholders
– banks, governments, industry players, energy
providers, and homeowners. NLB remains committed to
accelerating this transition by prioritizing financing for
high-efficiency new homes (EPC A & B) and expanding
green loan offerings for retrofits, renovations, and heat
pump installations.
However, systemic change is essential, including
stronger government policies, enhanced subsidies,
and a faster transition to renewable energy. While NLB
continues to develop innovative financial solutions
to support modernization, achieving climate goals
ultimately depends on grid decarbonization, regulatory
action, and active homeowner participation.
NLB advocates for an inclusive approach to energy
efficiency, ensuring that financing is accessible to all
homeowners, regardless of their property's current
energy label. The Bank’s objective is to empower
homeowners to make the necessary improvements and
will continue to develop innovative products, services,
and partnerships to drive progress.
-56%
50 -
40 -
30 -
20 -
10 -
0 -
43
2020
2025
2030
2035
2040
2045
2050
l
l
l
l
l
l
l
37
19.0
Figure 20: Residential real estate
Emission Intensity in kg CO2/m2
NLB Group baseline
2030 target
NLB Group EoY2023 status
SBTi 1.5 0C Pathway
NLB Group Progress
Reduction according to SBTi 1.5 0C
Emission Intensity
-14%
2021-2023

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Note: The data is not validated by any external source other than the limited assurance provider (for 2024).
Share of renewable energy production in NLB Group in
2024 equals the consumption of self-generated non-fuel
renewable energy 9 MWh (solar PV). Compared with
2023, the share of fossil fuels used dropped, while the
share of renewable sources in total energy consumption
was increased. This gives a clear sign that the measures
which NLB Group has taken to reach its goal (net zero)
are adequate and well on track.
›› For a detailed list of measures related to energy
consumption and mix, please see the chapter
Key actions - Operational emissions
Net-Zero strategy.
E1-5 Energy consumption and mix
Table 18: Overview of NLB Group energy consumption and mix
Energy consumption and mix
Unit
2023
2024
1
Fuel consumption from coal and coal products
[MWh]
-
-
2
Fuel consumption from crude oil and petroleum products
[MWh]
7,013
7,156
3
Fuel consumption from natural gas
[MWh]
3,368
2,980
4
Fuel consumption from other fossil sources
[MWh]
-
-
5
Consumption of purchased or acquired electricity, heat, steam, or cooling from fossil sources
[MWh]
24,474
21,379
6
Total fossil energy consumption (calculated as the sum of lines 1 to 5)
[MWh]
34,855
31,515
Share of fossil sources in total energy consumption
[%]
67%
63%
7
Consumption from nuclear sources
[MWh]
10,408
9,917
Share of consumption from nuclear sources in total energy consumption
[%]
20%
20%
8
Fuel consumption for renewable sources, including biomass (also comprising industrial
and municipal waste of biologic origin, biogas, renewable hydrogen, etc.)
[MWh]
54
34
9
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources
[MWh]
6,967
8,236
10
The consumption of self-generated non-fuel renewable energy
[MWh]
0
9
11
Total renewable energy consumption (calculated as the sum of lines 8 to 10)
[MWh]
7,021
8,279
Share of renewable sources in total energy consumption
[%]
13%
17%
12
Total energy consumption (calculated as the sum of lines 6, 7 and 11)
[MWh]
52,284
49,711

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E1-6 Gross Scopes 1, 2, 3
and total GHG emissions
The table presents NLB Group’s gross emissions,
encompassing both operational emissions and those
arising from financing and investment activities
(in alignment with the Pillar III framework). The
methodologies used to calculate and disclose these
emissions are detailed in the following sections,
providing transparency and consistency in the
NLB Group emissions reporting approach.
Table 19: NLB Group gross GHG emissions (operational and financed) (in tCO2eq)
Base year
Comparative
N
% N/N-1
2021
2023
2024
Scope 1 GHG emissions
Gross Scope 1 GHG emissions
3,703
3,418
3,029
-11.4%
Percentage of Scope 1 GHG emissions from
regulated emission trading schemes (%)
-
-
-
-
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions
32,952
20,320
17,127
-15.7%
Gross market-based Scope 2 GHG emissions
28,570
11,822
10,718
-9.3%
Significant Scope 3 GHG emissions
Total gross indirect (Scope 3) GHG emissions
3,531
11,003,756
11,169,097
1.5%
Purchased goods and services
466
341
465
36.4%
Capital goods
-
-
-
-
Fuel and energy-related Activities (not included in Scope1 or Scope 2)
0
0
1,573
-
Upstream transportation and distribution
-
-
-
-
Waste generated in operations
0
20
9
-54.8%
Business traveling
0
326
446
36.8%
Employee commuting
3,065
3,389
3,608
6.5%
Upstream leased assets
-
-
-
-
Downstream transportation
-
-
-
-
Processing of sold products
-
-
-
-
Use of sold products
-
-
-
-
End-of-life treatment of sold products
-
-
-
-
Downstream leased assets
-
-
-
-
Franchises
-
-
-
-
Investments
-
10,999,680
11,162,996
1%
Total GHG emissions

Total GHG emissions (location-based)
40,186
11,027,494
11,189,253
1.5%
Total GHG emissions (market-based)
35,804
11,018,996
11,182,844
1.5%
Note: The measurements are not validated by an external body other than a limited assurance provider (for 2024).

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Table 20: Operational Carbon footprint of NLB Group (excluding Financed emissions Category 3.15 and including new Category 3.3
in 2024)
Name
Year Description
Unit
2019
Total
2020
Total
2021
Total
2022
Total
2023
Total
2024
Total
Scope 1-3
All emissions
from all Scopes
[tCO2eq]
36,935
37,789
35,804
20,627
19,316
19,848
Scope 1-2
Emissions from
Scopes 1 and 2
[tCO2eq]
31,922
33,948
32,273
16,793
15,240
13,747
Scope 1
Total Scope 1
emissions
[tCO2eq]
3,680
3,350
3,703
3,648
3,418
3,029
Scope 1.1
Fuel Combustion
[tCO2eq]
1,472
1,569
960
887
818
704
Scope 1.2
Vehicle fleet
[tCO2eq]
1,882
1,447
1,720
1,756
1,684
1,788
Scope 1.3
Refrigerant
[tCO2eq]
326
333
1,023
1,004
916
537
Scope 2
Total Scope 2
emissions
[tCO2eq]
28,242
30,598
28,570
13,145
11,822
10,718
Scope 2.1
Electricity
[tCO2eq]
21,992
24,410
21,904
7,542
7,243
6,095
Scope 2.2
District heating
and cooling
[tCO2eq]
6,250
6,188
6,666
5,603
4,579
4,623
Scope 3
Total Scope 3
emissions
[tCO2eq]
5,013
3,842
3,531
3,834
4,076
6,101
Scope 3.1
Paper and water
[tCO2eq]
-
-
466
418
341
465
Scope 3.3
Fuel- and Energy-
Related Activities
Not Included in
Scope 1 or Scope 2
[tCO2eq]
-
-
-
-
-
1,573
Scope 3.5
Waste
[tCO2eq]
-
-
-
21
20
9
Scope 3.6
Business travel
[tCO2eq]
-
-
-
185
326
446
Scope 3.7
Employee (work)
commute
[tCO2eq]
5,013
3,842
3,065
3,210
3,389
3,608
Note: The data is not validated by any external source other than the limited assurance provider (for 2024).
NLB Group continues to reduce its environmental
footprint on Scopes 1 and 2, where the substantial
amount of operational emissions comes from. The
reduction is a direct consequence of measures taken
to improve energy efficiency and change the energy
sources to zero emissions, where possible. Within
Scope 3, NLB Group improved in category 3.5 (Waste),
although a need to improve the quality of data
gathering and measurements remains. Generally, the
increase in Scope 3 emissions is due to the introduction
of the new category (3.3), as well as a moderate increase
in business travel and employees commuting (due to the
rise in the number of employees).
›› For a detailed list of measures related to reducing
operational emissions, please see the chapter Key
actions - Operational emissions Net-Zero strategy.
Significant changes
affecting year-to-year
comparability
In the GHG emission report for the year 2024, the main
changes to previous years are the holistic presentation
of emissions, including Scope 1, Scope 2 and Scope 3,
and financed emissions. Namely, under the Pillar III
framework, NLB Group reported Scope 3, Category
15 financed emissions in 2022, but without inclusion
of Scope 3 client emissions. In 2023, the Group began
incorporating Scope 3 client emissions, significantly
increasing the reported value, as they represent the
majority of total financed emissions. The 2024 report
marks the first year where year-to-year comparability is
possible, as the figure is presented with updated values
and a consistent Scope. The calculation methodology
relies on both proxies and actual client data, meaning
that changes in the reported emissions may result
from updates to client data or adjustments in proxies.
Changes in reported emissions may also stem from
shifts in exposures to individual sectors, defined by
NACE codes, from the perspective of lending activity and
new business. This approach ensures alignment with
regulatory requirements, enhances transparency, and
supports risk management under the Pillar III disclosure
framework.
Further to this, in terms of operational emissions, a
new category (3.3 Fuel—and energy-related activities
not included in Scope 1 (well to tank—WTT) or Scope
2 (transmission and distribution losses—T&D)) was
added for the year 2024, which was not reported in the
previous year.
The emission calculation for 2024 and previous years
has been adapted to entail the greenhouse-gas
principle, which results in less than 0.5% of the total
tCO2eq difference.
Table 21: GHG Intensity based on net revenue
2024
Total GHG emissions
(market-based) (tCO2eq)
11,182,844
Total GHG emissions
(location-based) (tCO2eq)
11,189,253
Net revenue (EUR thousands)
1,244,810
GHG Intensity-based per net revenue
(market-based) (tCO2eq/EUR thousands)
8.984
GHG Intensity-based per net revenue
(location-based) (tCO2eq/EUR thousands)
8.989
Accountancy policy and reconciliation:
Net revenue (EUR 1, 244,810 thousands) is reconciliated
with the financial statements notes.

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Methodologies,
assumptions, and
emissions factors
Aiming to report GHG emissions according to
internationally recognised and neutral standards,
the NLB Group's calculations follow the GHG Protocol
guidelines. To calculate NLB Group carbon footprint, the
following standards are used:
• Corporate standard (Corporate Accounting and
Reporting Standard)
• Corporate Value Chain (Scope 3) Accounting and
Reporting Standard

We used the centralized approach to data collection.
Data were gathered on an individual level of NLB Group
members and reported to the corporate level, where
GHG emissions were calculated.
In terms of setting organisational boundaries, NLB
Group used the financial control approach on a
consolidated basis and has thus followed the same
principles as those from financial reporting. This
means that the Sustainability Statement includes the
parent bank NLB and all subsidiaries from when NLB
obtains direct or indirect control over the financial and
operational management and receives a variable return.
The Sustainability Statement covers the financial
reporting period from 1 January to 31 December 2024.
However, there are certain specifics, namely:
• Summit Leasing Slovenija and Mobil Leasing, Zagreb
were acquired on 11 September 2024; hence, the
reporting period is from 11 September to 31 December
2024.
• NLB Car & GO was established on 21 October 2024.
Hence, the reporting period is from 21 October to
31 December 2024.
• NLB Fondovi Skopje (previously Generali Investments
AD Skopje) was acquired on 23 May; hence, the
reporting period is from 23 May to 31 December 2024.

Key subsidiaries in own operations are NLB as a
parent bank and other financial core members: i)
banks, ii) leasing companies and iii) asset management
companies. The calculation of GHG emissions has been
made for operational offices with significant material
impact and individuals as per the following Scopes
(operational boundaries):
Scope 1 – direct emissions
• Combustion of fuels
• Company-owned vehicle fleet (internal combustion
engine)
• Company-controlled fleet (internal combustion
engine)
• Refrigerants (for HVAC systems)

Scope 2 – indirect emissions from purchased energy
• Electricity consumption (both location and market-
based)
• Owned vehicle fleet – electric vehicles and PHEV
(included in electricity consumption)
• District heating

Scope 3 – indirect emissions (selected emission
categories; for more details, please see exclusion list)
• 3.1 Purchased Goods and Services: use of paper and
water supply
• 3.3 Fuel- and energy-related activities not included in
Scope 1 (well to tank - WTT) or Scope 2 (transmission
and distribution losses – T&D)
• 3.5 Waste Generated in Operations
• 3.6 Business Travel
• 3.7 Employee Commuting

Because some NLB Group entities are located at the
premises of another Group member, the reporting is
done by the member that owns the premises and has
the most accurate data (i.e., a locally consolidated
approach).
›› For more details on operational boundaries, please see
the table below and the chapter Exclusions.
Even though NLB Group started reporting its operational
carbon footprint in 2021 for the period 2019-2021, the
2024 GHG Emission Report has been harmonized with
the Portfolio Net-Zero Strategy and ESRS demand and
reset its baseline year to 2021.
Scope 3 category 15 – Investments
NLB Group calculates its portfolio (financed) emissions
by using the Partnership for Carbon Accounting
Financials (PCAF) Standard. However, disclosures of
financed emissions are aligned with the requirements
of the Pillar III disclosure framework, ensuring banking
sector comparability, regulatory compliance, and year-
to-year consistency in reported data. This approach
enables transparent and consistent assessment of
financed emissions across sectors, supporting risk
management and alignment with industry benchmarks.
By maintaining methodological consistency, the Group
enhances the reliability of its disclosures, ensuring
comparability over time while adhering to regulatory
requirements.
Application of the Partnership for Carbon Accounting
Financials (PCAF) Standard ensures consistency with
industry best practices and regulatory expectations.
The PCAF methodology was selected due to its wide
acceptance among financial institutions, transparency,
and alignment with international reporting frameworks
such as the Greenhouse Gas Protocol (GHG Protocol)
and the Task Force on Climate-related Financial
Disclosures (TCFD) recommendations. The approach
enables a standardized and comparable assessment of
financed emissions across asset classes.
The Group has recognised greenhouse gas (GHG)
emissions data as the primary and crucial factor when
assessing the level of transition risk. Therefore, obtaining
good-quality emission data is a high priority. The
priority is the data obtained directly from the clients.
While operating in a region where such information is
not commonly available, the Group supports the clients
with the know-how and motivates them to calculate
GHG emissions.

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Due to data limitations, particularly in sectors with
scarce primary disclosures, the Group applies proxy
data and sectoral benchmarks where necessary. The
calculation is based on the following assumptions:
• The calculation and disclosure of financed emissions
is based on the perimeter defined under Pillar III
rules, encompassing exposures in the banking book.
This includes the Gross Carrying Amount of loans and
advances, debt securities, and equity instruments to
non-financial corporations, excluding those held for
trading purposes. The financed emissions assessment
specifically focuses on non-financial corporations,
considering direct and indirect emissions from
financial activities such as lending, investing, and
financing. Sovereign, sub-sovereign, institutions
and supranational exposures are excluded from the
calculation while not materially contributing to direct
emissions. Emissions related to the retail portfolio
(mortgages, vehicle loans) are not subject to Pillar III
disclosures.
• Where available, actual client data for Scope 1,
2, and 3 emissions is used to calculate financed
emissions. The data is provided by the clients using
questionaries.
• Whenever client Scope 1 and Scope 2 emission data
are not available, the Group uses proxies provided
by the Jožef Stefan Institute (IJS), Energy Efficiency
Centre , a leading institute in this area with a proven
background. Proxies are calculated at the lowest
possible granularity level, considering the available
data for each country where NLB Group operates.
However, granularity varies across industries and
countries depending on the availability of the data.
The proxies delivered by IJS express the average
economic intensity of each industry and are primarily
used for portfolio emissions calculations, as well as
for target setting and decision-making purposes.
Based on the client’s industry code and revenues, the
Group calculates Scope 1 and Scope 2 emissions of
each client by multiplying the value of a specific proxy
with the revenues of a client.
• When client Scope 3 emission data is unavailable,
NLB uses proxies from the Intercontinental Exchange
(ICE), selected for their transparency and as the
ICE's dataset was also used in the ECB’s economy-
wide climate stress test. ICE collects data from public
sources, which undergoes statistical treatment and
rigorous checks, with verification by ICE’s Quality
Assurance team. Data is classified as reported,
inferred, or statistically treated, with transparency on
the source. Based on the client’s industry code and
revenues, the Group calculates the Scope 3 emissions
of each client by multiplying the value of a specific
Scope 3 proxy with the revenues of a client, as it does
for the Scope 1 and Scope 2 calculations.
• Attribution methodology follows the PCAF’s
financial exposure-based attribution model,
allocating emissions based on a loan or investment’s
proportional contribution to a client’s total balance
sheet. The attribution factor is calculated using
on-balance-sheet data as Gross Carrying Amount
/ (Short-term Financial Debt + Long-term Financial
Debt + Equity).
• Finally, financed emissions are calculated by
multiplying the attribution factor with the client’s
Scope 1, Scope 2 and Scope 3 emissions, which are
either obtained from the client or calculated using
proxies.

›› Scopes, metrics, emission definitions, emission and
conversion factors for operational emissions are detailed
in Appendix 2-Methodological outline for operational
GHG emissions calculation.

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Table 22: List of exclusions
Scope 1
Exclusion
Fuel combustion
-
Vehicle fleet (ICE)
-
Refrigerant
Included only in following organizations: NLB, NLB Komercijalna Banka, NLB Banka Skopje,
NLB Banja Luka and NLB Interfinanz Zurich. For other organizations data not available.
Scope 2
Electricity (market-based)
-
District heating and cooling
-
Vehicle fleet (Electric, PHEV, Hybrid))
-
Scope 3
Purchased goods and services
Included use of paper and water. Emissions of Scope 3 categories "3.1 – Purchased goods and services" and "3.2 – Capital goods (assets)", represented by
paper and water emissions only, do not reflect actual emissions of these two categories. The cost for these two reported categories reached 115 MEUR
in 2023. Paper and water are a small part of these emissions. Therefore, additional emission categories will have to be introduced in carbon footprint
reporting in the future to be able to cover a substantial part of Scope 3 operational emissions. Based on 2023 figures non- included Scope 3 category
1 and 2 emissions account for 14.300 t CO2eq (using US EPA Supply Chain GHG Emission Factors, Offices of Bank Holding Companies – 130 t CO2eq/
MUSD ). The reason for the non-inclusion of these Scope 3 categories is also reflected in the lack of reliable emission factors for emission sources (goods,
services and assets). Also, NLB Group has not yet used a supplier engagement approach to stimulate its suppliers to report their product emissions.
Capital goods
Not included. Emissions of Scope 3 categories "3.1 – Purchased goods and services" and "3.2 – Capital goods (assets)", represented by
paper and water emissions only do not reflect actual emissions of these two categories. Cost for these two reported categories reached
115 MEUR in 2023. Asset emissions category will have to be introduced in carbon footprint reporting in the future, to be able to cover
substantial part of Scope 3 operational emissions. Based on 2023 figures non-included Scope 3 category 1 and 2 emissions account for
14,300 t CO2eq (using US EPA Supply Chain GHG Emission Factors, Offices of Bank Holding Companies – 130 t CO2eq/MUSD). Reason for non-
inclusion of these Scope 3 categories is reflected also in lack of reliable emission factors for emission sources (goods, services and assets).
Also, NLB Group has not yet used supplier engagement approach to stimulate its suppliers to report their product emissions.
Fuel- and energy- related activities
-
Upstream transport and distribution
Not included.
Waste generated in operations
-
Business travel
-
Employee commuting
-
Upstream leased assets
Included in Scope 1 and 2 report.
Downstream transport and distribution
Not relevant.
Processing of sold products
Use of sold products
End-of-life treatment of sold products
Downstream leased assets
This category has not been included in the Group's gross emissions reporting for the year 2024. The transport segment, including leasing,
along with the corresponding methodology for calculating financed emissions, is scheduled to be evaluated in the second round of target
setting and will be included in future reporting. This delay is due to data challenges related to vehicle-specific information, which are being
addressed as part of the Group's ongoing efforts to refine and enhance its emissions data collection and reporting processes.
Franchises
Not relevant.
Investments
Reported separately. Portfolio (financed) emissions are calculated using the Partnership for Carbon Accounting Financials (PCAF) Standard;
however, disclosures of financed emissions are aligned with the requirements of the Pillar III disclosure framework, ensuring banking sector
comparability, regulatory compliance, and year-to-year consistency in reported data. This approach enables transparent and consistent assessment
of financed emissions across sectors, supporting risk management and alignment with industry benchmarks. By maintaining methodological
consistency, the Group enhances the reliability of its disclosures, ensuring comparability over time while adhering to regulatory requirements.
Exclusions

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Sustainable finance, including transition finance, has
a high impact on the environment and society and is
recognized as a strategic opportunity for NLB Group. It
is firmly embedded in the NLB Group’s new business
strategy (New Horizons) as well as its net-zero
strategy. Risks related to sustainable finance are
managed through ESG risk management in lending
and investing.

NLB Group offers its clients a diverse range of financing
products and solutions to support climate change
mitigation and climate adaptation. These include
green lending and leasing, sub-funds aligned with
EU regulations promoting environmental and social
characteristics, issuing green bonds, and investing in
ESG-labelled bonds.

This chapter outlines NLB Group's key policies, activities,
metrics, and progress in delivering sustainable
finance solutions to its clients. The organizational units
responsible for each product regularly monitor progress
against internally set KPIs. They report at least monthly
to the management boards of NLB Group members
and at least quarterly during Sustainability Committee
sessions.
Accountancy note and reconciliation:
Unless stated otherwise, reported data in the
Sustainable Finance section refers to the financial
statements note 5.6. Financial assets measured at
amortised cost.
Green financing for
corporate and retail
clients

Policies
As a part of its climate-change-related adaptation and
mitigation activities, NLB Group provides financing
to various sustainable economic activities that meet
the financial and sustainability eligibility criteria of
relevant frameworks, such as the EU Taxonomy, MIGA,
EBRD, NLB Group Green Bond Framework (following
ICMA Green Bond Standards). Financing Rules,
and procedures stipulated in lending and ESG risk
management policies.
›› For an overview of policies related to green financing,
please refer to the section Policies in the chapter
Environmental Information.
Sustainable Finance
Metrics and progress
In 2024, total green financing for corporate and
retail clients experienced a significant growth, with
a 153% increase in new production and a 183% rise
in outstanding stock compared to 2023. The total
outstanding stock in 2024 represents 54% of the 2030
target.
Table 23: NLB Group green financing in EUR thousands(i)
Green financing
(in EUR millions)
31 Dec
2024
31 Dec
2023
Target
2030
Corporate

New production
volume
308,582
198,203

Outstanding
stock volume
700,999
330,837
1,370,000
Retail

New production
volume
130,064
89,293

Outstanding
stock volume
327,143
229,421
528,000
Total
(corporate and retail)

New production
volume
438,646
287,496
Outstanding stock
volume(ii), (iii)
1,028,142
560,358
1,900,000

(i) Data refer to NLB and 6 subsidiary banks in the region. Green lending
classification refers to the internal methodology of NLB Group, which
refers to EBRD, MIGA, Green Bond and EU Taxonomy frameworks. If a
loan is mapped to either of these frameworks (and NZBA in case of retail
green financing), it is currently considered a green loan. To ensure a robust
and standardized overview of green lending, this methodology will be
fully aligned with CSRD, ESRS and EU Taxonomy within the regulatory
timeframes.
(ii) The total target for 2030 is set at EUR 1,900,000 thousands. The
discrepancy in the total sum reflects rounding in the budgeting of sub-
categories.
(iii) Targets were set only for outstanding stock volume.

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Renewable Energy
Green Building
Energy Efficiency
Clean Transportation
Pollution
Prevention & Control
Sustainable Water and
Wastewater Management
Electricity generation
using solar photovoltaic
technology
Construction of
new buildings
Manufacture of batteries
Passenger interurban
rail transport
Construction, extension
and operation of water
collection, treatment and
supply systems
Production of
heat/cool using
waste heat
Electricity generation
using concentrated solar
power (CSP) technology
Renovation of existing
buildings
Storage of electricity
Freight rail transport
Renewal of water
collection, treatment and
supply systems
Collection and transport
of non-hazardous waste
in source segregated
fractions
Electricity generation
from wind power
Acquisition and
ownership
of buildings
Installation and operation
of electric heat pumps
Urban and suburban
transport, road passenger
transport
Construction, extension
and operation
of wastewater collection
and treatment
Material recovery from
non-hazardous waste
Electricity generation
from hydropower
Installation, maintenance
and repair of energy
efficiency equipment
Transport by motorbikes,
passenger cars and light
commercial vehicles
Renewal of wastewater
collection and treatment
Electricity generation
from geothermal energy
Infrastructure for personal
mobility, cycle logistics
Electricity generation
from bioenergy
Infrastructure for
rail transport
Transmission and
distribution of electricity
Infrastructure enabling
low-carbon road
transport and public
transport
Cogeneration of heat/
cool and power from
solar energy
Installation, maintenance
and repair of renewable
energy technologies
Table shows a detailed non-exhaustive list of overarching areas that serve as a guide for NLB Group sustainable
financing or refinancing, while eligible projects are defined in detail in the aforementioned frameworks and specified
in NLB Group internal documents. The list will continue to evolve over time, reflecting changes in classifications of
sustainability criteria, stakeholders’ needs and expectations, and regulatory requirements.
Table 24: NLB Group sustainable financing and refinancing areas (non-exhaustive list)
Key activities

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Leasing
Leasing companies in NLB Group integrate sustainability
matters and IRO management ESG into its leasing
operations, positioning these elements as important
components of the Group’s sustainable financing.
Policies

Sustainability Policy and Standard
Content and purpose: The policy sets out a general
framework for sustainability-related activities,
being a harmonized version of the NLB Group
Sustainability Policy and Standard, adapted to
leasing activities. Thus, the policy follows the
same sustainability pillars, overarching goals, and
principles as the parent bank.
Scope: All leasing companies. Summit Leasing
Slovenija and Mobil Leasing, Zagreb, which were
acquired in September 2024, will harmonize the
Policy and Standards in 2025.
Most senior level accountable: Management
Boards / Board of Directors and Risk department
(Coordinator for sustainable development) in
leasing companies.
Availability: Register of Internal Acts.
Domain-specific policies related to sustainability
Content and purpose: The implementation of the
internal acts related to ESG risks in the process of
financing is covered by the Risk department. Several
internal acts in NLB Lease&Go frame the process
of financing ESG items for legal entities, such as:
Lending Policy for Non-Financial Companies,
Policy Environmental and Social Transaction Policy
Framework in NLB and NLB Group, Methodological
Framework for Environmental and Social
Categorization of Investments in NLB d.d. and NLB
Group, Environmental and Social Categorization by
NACE and SKD codes in NLB d.d. and NLB Group.
An internal act, the Lending Policy for Non-Financial
Companies in NLB d.d. and NLB Group, sets out
the full list of cross-sectoral and sector-specific
prohibited (exclusion list), restricted, and normal
activities from the ESG perspective, including EBRD
requirements, that NLB Lease&Go adheres to in its
financing decisions and process.
Scope: All leasing companies. Summit Leasing
Slovenija and Mobil Leasing, Zagreb, which were
acquired in September 2024, will harmonize the
internal acts in 2025.
Most senior level accountable: Senior managers
(directors) who are responsible for a specific policy
domain.
Availability: Register of Internal Acts.
Key activities
In 2024, Leasing companies in NLB Group financed
sustainable vehicles in Slovenia, Serbia, and North
Macedonia, which contributed to cleaner transportation.
It also financed smaller sustainable projects in the
field of renewable energy production, in particular
solar power plants. Leasing companies in NLB Group
was also actively involved in developing NLB Group’s
Operational Emissions Net-Zero Strategy, adopted in
2024. Among other goals, the strategy aims to achieve
the net-zero emission vehicle mix by replacing its fossil-
powered fleet. In line with the NLB Group Sustainable
Car Fleet Management and Company Car Policy, NLB
Lease&Go steers the transition process to be followed
by all NLB Group members. In 2025 Leasing companies
in NLB Group will actively participate in NZBA target
setting for the Transport sector; finance green items for
the purpose of Clean Transportation and Renewable
Energy; and continue with green product development.
Table 25: Leasing companies in NLB Group green financing at the end of 2023 and 2024 (in EUR thousands)

Year
(EOY)
New
production
Outstanding stock
Leasing companies in
NLB Group green financing
2023
9,763
11,343
Leasing companies in NLB Group
2024
6,441
14,198
Notes:
(i) Green lending or financing classification refers to the internal methodology of NLB Group, which refers to EBRD, MIGA, Green Bond and EU Taxonomy
frameworks. If a loan or financing is mapped to either of these frameworks, it is currently considered a green loan or financing. To ensure a robust and
standardized overview of green lending or financing, this methodology will be fully aligned with CSRD, ESRS and EU Taxonomy within the regulatory
timeframes.
(ii) Data refers to NLB Lease&Go d.o.o. and subsidiaries NLB Lease&Go Skopje and NLB Lease&Go Leasing d.o.o. Beograd. Data do
not include the leasing companies Summit Leasing Slovenija and Mobil Leasing, Zagreb (acquired in September 2024) as they will
perform classification of green financing in line with the internal methodology of NLB Group from the fiscal year 2025 onwards.
Metrics and progress

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Asset management
Policies
NLB Funds, Asset Management, Ltd. (hereinafter: NLB
Funds) offers three asset management services:
1. portfolio management
2. mutual investment fund management
3. alternative investment fund management
For each of these services, NLB Funds has adopted
service-specific internal acts that determine how
each service will be performed and how funds will
be managed. While portfolio management services
are performed in accordance with the Portfolio
management general Terms and conditions and
do not take sustainability into account, NLB Funds
has established two sub-funds which promote
environmental and social characteristics and related
internal acts.
Prospectus of the NLB Skladi umbrella fund
including the management rules
Content and purpose: This act determines that the
sub-fund NLB Funds – Equity Socially Responsible
Global Advanced Markets promotes environmental
and social characteristics and the sub-fund
NLB Funds – Equity Environmental promotes
environmental characteristics. How the mentioned
two sub-funds achieve environmental and social
characteristics, and which activities are excluded for
these 2 sub-funds is explained below in the section
"Key activities". This act also determines that the
company NLB Funds only manages sustainability
risks that are required by national and EU law in
relation to mutual investment funds. To manage
these risks, NLB adopted the Rulebook on Due
Diligence of Investments and Tab Keeping and
the Mutual Funds Risk Management Plan which
determines how sustainability risks are identified
and mitigated.
Scope: NLB Skladi
Most senior level accountable: Head of the Risk
Management department
Tender document including the Fund Management
Rules NLB Funds – Green Transition I, Specialized
Investment Fund
Content and purpose: This act determines that the
fund promotes environmental characteristics (for
details see the section "Key activities").
NLB Funds manages sustainability risks that are
required by national and EU law in relation to
alternative investment funds. How this is performed
is determined by the Alternative Investment Fund
Due Diligence Policy and the Alternative Investment
Funds Risk Management Plan.
Scope: NLB Skladi
Most senior level accountable: Risk Management
department and the ESG coordinator
Sustainability Policy of NLB Funds
Content and purpose: The Sustainability policy
does not apply to assets managed by NLB Funds
(assets managed in mutual funds, alternative
investment funds and portfolios) and determines
that NLB Funds does not currently consider adverse
impacts of investment decisions on sustainability
factors. NLB Funds plans to review this provision
in the Sustainability policy in the future as the
environmental regulation evolves. The Sustainability
policy also determines how NLB Funds will conduct
its business operations sustainably.
It determines that NLB Fund will take into account
impacts, risks, or opportunities created by its
business operations and that NLB Funds will adhere
to the NLB Group exclusion list published on
NLB web page.
Scope: NLB Skladi; NLB Fondovi, Beograd; and NLB
Fondovi, Skopje
Most senior level accountable: the Supervisory
Board to which the NLB Skladi ESG coordinator
regularly (half yearly) reports.
Availability: publicly available at:
NLB Skladi web page.
Key activities
NLB Funds offers two sub-funds which promote
environmental and social characteristics and adhere to
Article 8 of Regulation SFDR (EU) 2019/2088, whereas
NLB Funds Beograd and Skopje currently do not have
any such funds in their offer.
The sub-fund NLB Funds – Equity Socially Responsible
Global Advanced Markets (introduced in 2018)
promotes a combination of environmental and social
characteristics but does not invest in sustainable
investments. Therefore, this sub-fund invests in
issuers with above-average environmental and social
awareness in their operations, provided that they
respect good governance practices.
The reference value for the achievement of the
environmental and social characteristics promoted
by this sub-fund has been determined as the required
minimum allowable weighted average score of the
environmental, social, and governance characteristics of
all investments of the sub-fund.
This sub-fund also promotes environmental and social
characteristics in such a way that it eliminates individual
activities or sub-activities that it considers controversial.
Such controversial activities or sub-activities in which
the sub-fund will not invest are aviation and defence,
gambling, tobacco, breweries, spirit drinks and wine
producers, energy, metals and mining, paper and forest-
based industry, and road transport
The sub-fund NLB Funds – Equity Environmental
(introduced in 2018) promotes a combination of
environmental characteristics provided that companies
adhere to good governance practices but does not
invest in sustainable investments. Therefore, this
sub-fund invests in issuers with above-average
environmental awareness in their operations, provided
that they respect good governance practices.
The reference value for the achievement of the
environmental characteristics promoted by this sub-
fund has been determined as the required minimum
allowable weighted average score of the environmental
and governance characteristics of all investments of the
sub-fund.

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In 2024, NLB Funds additionally launched an
alternative investment fund named the Green
Transition I, Specialized Investment Fund. This fund
also promotes environmental characteristics by
investing in projects that enhance energy efficiency and
generate electricity from renewable energy sources
and any other projects related to the energy transition,
provided that good governance practices are observed.
As such this fund also adheres to Article 8 of Regulation
SFDR (EU) 2019/2088 but does not invest in sustainable
investments.
In 2025, NLB Funds will be required to implement ESMA
Guidelines on funds' names using ESG or sustainability-
related terms as two sub-funds and the alternative
investment fund have such terms in their names. As
the aforementioned guidelines prohibit investments in
companies that perform certain activities, funds to which
these guidelines will apply need to form exclusion lists
for prohibited investments (e.g. tobacco, controversial
weapons, etc).
Metrics and progress
NLB Skladi aims to maximize the asset value of two
sub-funds that promote environmental and social
characteristics. In 2024, compared to 2023, the total net
asset value of these sub funds has increased by 62%.
Green bond
Policy
NLB Green Bond Framework
Content and purpose: The NLB Green Bond
Framework (GBF) defines commitments related to
green bond issuance(s) and key activities to meet
commitments. The most relevant are (i) criteria for
selection of the eligible portfolio (use of proceeds),
(ii) how the portfolio is managed, and (iii)
respective allocation and impact reporting content
and dynamic. The GBF follows the International
Capital Market Association (ICMA) Green Bond
Principles with the following focus areas: renewable
energy, energy efficiency, green buildings, clean
transportation, sustainable water and wastewater
management, and pollution prevention and control.
Scope: Under the GBF NLB can only issue any debt
security to finance or refinance loans, assets, and
projects with positive environmental benefits. The
eligible loans, assets, and projects to satisfy the
commitments can be contributed by NLB, its seven
subsidiary banks, and several companies providing
ancillary services (including asset management,
real estate management, leasing, etc.).
Most senior level accountable: While a Green
Bond Working Group was established for the
governance of the GBF, the main responsibility for
the implementation lies with the NLB Management
Board who confirm the GBF as well as the eligible
portfolio and reports.
Availability: The GBF is publicly available on NLB
website: NLB Green Bond Framework
Key activities
Based on the NLB Green Bond Framework (GBF), NLB
issued its inaugural green bond in a benchmark size of
EUR 500 million in June 2023. The eligibility criteria, as
outlined in the use of proceeds section of the NLB Green
Bond Framework, take into account the EU Taxonomy
Regulation and the EU Taxonomy Climate Delegated
Act, with the intention to apply them on a best-efforts
basis. In that respect, the Group will focus on compliance
with technical screening criteria for determining
substantial contribution to climate change mitigation
and, as they enter into law, to sustainable use and
protection of water and marine resources, as well as
pollution prevention and control.
Key activities in 2024 were focused on building up the
green bond eligible assets portfolio. This focus will
continue to be a priority in 2025.
Target and progress
With the issuance of the green bond in June 2023, NLB
committed to strive to allocate the full amount of the
green bond (EUR 500 million) within 36 months after
issuance (target amount), i.e. by 26 June 2026.
The target amount was set on the outcome of the
analysis made by Corporate and Investment Banking
Management (for CIB stream) and Customer, Product
Management and Digital Services (for retail stream)
before green bond issuance. Based on the projections, it
was concluded that the target is within reach. The target
amount was confirmed by the Management Board.
Internally, progress on meeting the allocation targets is
followed monthly/quarterly, while progress is regularly
reported on at the Sustainability Committee.
Table 26: Net Asset Value at the end of 2023 in EUR thousands

Sub-fund
NLB Funds –
Equity Socially
Responsible
Global
Advanced
Markets
Sub-fund
NLB Funds
– Equity
Environ-
mental
Total
Net Asset
Value 2023
81,737
11,287
93,024
Net Asset
Value 2024
128,539
22,519
151,058
Accountancy policy and reconciliation:
The value is a proportion of total net asset value
reported in the business report (Asset management
operations)

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Externally, progress is reported with the publication
of the NLB Green Bond Allocation and Impact Report.
Based on the NLB Green Bond Framework, such report
has to be prepared annually at least until full allocation.
The first Allocation and Impact report was published
in June 2024 on data as of 31 March 2024. The report
reveals that the portfolio of eligible assets amounted
to EUR 341 million, with 943 loans granted. The report
underwent a limited assurance review performed by
Sustainalytics (Morningstar).

The next Allocation and Impact Report will be published
in June 2025 and will be accessible on the NLB website.
›› For 2024 disclosures, please refer to NLB Green Bond,
June 2024 (English version only) on the NLB website.
The document is not subject to external review of
Sustainabillity Statement.

Table 27: Eligible portfolio - allocation by categories as at 31 March 2024 in EUR thousands
Allocated proceeds
Unallocated
proceeds
CMA Green Projects Categories
Total amount
of proceeds
allocated
Number of
loans
New
financing
Refinancing
Renewable Energy
238,470
296
31,971
206,499
158,890
Green Building
77,423
238
0.282
77,141
Clean Transportation
15,083
408
8,119
6,964
Energy Efficiency
10,134
1
-
10,134
Total
341,110
943
40,372
300,730
ESG bonds in the
NLB Group’s banking
book debt securities
portfolio

Policy
NLB Group Investment Strategy
Content and purpose: When managing banking
book debt securities, the portfolio reflects different
characteristics in order to diminish the risk derived
from within. This is described in the NLB Group
Investment Strategy: Investment Portfolio Plan –
Definition and Monitoring and the Trading and
Treasury Framework for Managing Debt Securities.
While the former only sets the ESG as a component
in the portfolio overview, the latter document
includes a definition of ESG component, which
constitutes a social, green, or sustainability tag
based on the 2021 Social Bond Principles (SBP),
the 2021 Green Bond Principles (GBP), and the 2021
Sustainability Bond Guidelines (SBG) published
by the International Capital Market Association
(ICMA).
Scope: The NLB Group Investment Strategy is the
highest level document for managing banking
book debt securities and all banking members are
obliged to comply.
Most senior level accountable: Each banking
member has its own debt securities portfolio under
its supervision and as such reports to the local
Assets Liabilities Committee (ALCO). Every quarter
an overview of portfolios is reported to the Group
ALCO.
Availability: Register of Internal Acts.

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Key activities
In 2024, the Group was actively present on the ESG-
labelled debt securities issuances, whether primary or
secondary, following the policy and the target related
to the banking book debt securities portfolio. This will
continue in 2025. With this approach constant growth
of the Group’s ESG awareness in the debt securities
portfolio is ensured.
Target and progress
The Group’s strategy is to invest at least the share of
issued ESG debt securities on the primary market in the
total issued amount of issuers where the Group has risk
appetite, on a yearly basis.
At the end of 2024, NLB Group had EUR 670 million
invested in ESG-labelled bonds which represents 10.8%
of the Group’s banking book debt securities portfolio
and marked a 66% growth in compared to 2023
(6.5% share). More than half of the ESG portfolio was
invested into government, government-guaranteed,
and multilateral bank bonds. In 2024, EUR 373 million of
ESG-labelled bonds were added into the debt securities
portfolio which is 13% of all new investments in 2024 on
the Group level.
Table 28: ESG Debt Securities in NLB Group portfolio as of 31 December 2024 (in EUR thousands)
Green financing
(in EUR millions)
Banks & corporate
Government and
multilat. banks
Total
Purchased YtD in 2024
Environmental
219,961
171,696
391,657
170,116
Social
41,684
142,301
183,985
155,551
Governance
0
94,532
94,532
47,758
Total ESG
261,645
408,529
670,174
373,424
Total portfolio
1,007,434
5,185,686
6,193,120
2,865,601
% of ESG
25.97%
7.9%
10.8%
13.0%

Accountancy policy and reconciliation:
Reported values for ESG Bonds in the Group’s banking
book debt securities portfolio for refers to the financial
statements notes 5.3. Non-trading financial instruments
measured at fair value through profit or loss, 5.4.
Financial assets measured at fair value through other
comprehensive income, and 5.6.Financial assets
measured at amortised cost.
35%
5%
1%
1%
26%
32%
Multilateral bank bonds & GGB's
Bank senior unsecured bonds
Government bonds
Covered bonds
Subordinated debt
Corporate bonds
Figure 21: Distribution of ESG debt securities by asset class

Social Information
In this section, we report on three material standards: Own Workforce,
Affected Communities, and Consumers and End-users. Our employee-
related disclosures cover Working conditions and human rights, Diversity,
eqiity and inclusion, Talent attraction and development, and Health and
Safety, showcasing our commitment to a thriving workforce. We highlight our
community impact through financing, regional development, sponsorships,
and donations. Finally, we present disclosures on financial health, responsible
marketing, service quality, customer satisfaction, and cybersecurity,
emphasizing our management of social IROs.

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GROWING
PEOPLE
ENCOURAGE
ENTREPRENEURSHIP
IMPROVING
LIVES
We are ambitious, curious
people who want to learn
continuously. We are skilled
professionals and effective
communicators.
• We are honest speakers and
active listeners
• We acquire and share
knowledge
• We are persistent in striving for
continuous improvement
• We support each other to learn
and improve
• We act together towards
common purpose
We understand our clients and
colleagues, and continuously
innovate to enhance their
experience. We drive and
embrace the changes.
• We are looking everything
through digital eyes
• We are always going one step
further
• We are respecting our
agreements and promises
• We are proposing innovative
and simplified improvements.
• We ask for empowerment and
take responsibility
We are changing ourselves
to improve the quality of life
in our home region.
• We are advocating and
applying sustainable
practices
• We show interest and
understanding for one
another
• We personally lead the
change
• We take care of our personal
impact on environment
• We look for opportunity in
every challenge
S-1 SBM3 material
IROs and their
interaction with
strategy and the
business model

At NLB Group, sustainable practices and human
resource management are strongly interconnected.
Sustainability is firmly embedded in the Group’s values
which are key drivers of organizational culture.
Sustainability is also one of core foundations of NLB's
new 2025–2030 Human Resources Strategy, adopted
in December 2024 and set for gradual group-wide
implementation. The HR Strategy incorporates and
supports Business Strategy 2030 (People and Culture
pillar), which focuses on the following key goals:
• ensuring adequate skills and capacity across the
business initiatives and across the Group, in line with
changing business needs,
• providing framework for effective and modern people
management and development,
• and strengthening and streamlining HR processes.
The conducted double materiality assessment identified
4 material sustainability topics, which are directly or
indirectly connected with the new strategies: Working
conditions and human rights of employees; Employee
attraction and development; Diversity, equity and
inclusion, and Cybersecurity.
The Group continuously embeds sustainable principles
into human resource management and organization.
In this respect, NLB Group members establish respective
HR internal documents, rules and procedures, initiatives,
and practices which:
S1 Own Workforce
• respect the human rights and labour rights enshrined
in both domestic and international law.
• include diversity and inclusion, equal opportunities,
and non-discrimination for reasons of gender,
ethnicity, age, or any other circumstance.
• ensure efficient addressing of diversity, in particular
gender equality, in the highest governance bodies
and senior positions.
• ensure fair pay and remuneration, and reduction of
the gender pay gap.
• promote and ensure the safety, health, work-life
balance, and well-being of employees.
• attract and manage talents in order to drive the local
and international career development of employees.
• promote internal dialogue and communication, and
measure employee satisfaction through regular
organizational culture and engagement surveys.
• maintain high standards of labour management
relations and social dialogue.
• promote and implement training and other measures
to ensure that employees build their sustainability
capacities, awareness, and engagement.
• build and promote a sustainability culture which
is an important driver for successfully steering the
sustainability and ESG agenda in NLB Group.

Tables on the next page describe the connection of 14
material IROs with overall business model of NLB Group.

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Table 29: Own workforce related impacts, risks, and opportunities (Working Conditions)
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in
the value
chain
Time horizon
Working conditions
and human rights
of employees
Work-related
health impacts
For some employees, office work results in long-term health impact, such as back
pain, damaged eyesight and related issues, thus reducing their life quality.
Impact - Actual
Negative impact
Own
operations
Short-term
Enabling
healthy work-
life balance
The Group consistently prioritises imparting knowledge about healthy habits, mental
health, employee assistance support programs, and advocates activities that contribute
to employees’ well-being and satisfaction. It fosters a healthy work environment
conducive to meaningful interpersonal connections and a work-life dynamic.
Impact - Actual
Positive impact
Own
operations
Short-term
Enabling a
healthy and
safe working
environment
NLB Group has implemented numerous health-related initiatives aiming to reduce negative
impacts of work and promote a healthy lifestyle, which may results in a positive impact on
employee health. Health and safety measures are implemented to prevent accidents. No
high-risk workplaces were identified during a workplace risk assessment in 2023.
Impact - Potential
Positive impact
Own
operations
Short-term
Enabling low
turnover rate
and long-term
contracts
NLB Group implements policies to ensure fair remuneration, adequate working
conditions, and social dialogue to promote employee satisfaction and retention. This
includes transparent and fair remuneration standards, monitoring working hours
to prevent burn-out, and maintaining open communication with employees.
Impact - Actual
Positive impact
Own
operations
Short-term
Fair
remuneration
of employees
Through remuneration policies, NLB Group is ensuring transparent and fair
remuneration standards for its employees, fostering fairness and equity.
Impact - Actual
Positive impact
Own
operations
Short-term
Enabling social
dialogue
NLB Group members are committed to establishing constructive relations among
employees and management, maintaining high standards of social dialogue and
ensuring timely communication. This also includes open communication on relevant
topics and informing employees and their representatives prior to the implementation
of significant operational changes that could substantially affect them.
Impact - Actual
Positive impact
Own
operations
Short-term
Enabling
collective
agreements
with employees
Employees are covered by a Collective Agreement, which allows for
stronger representation and better bargaining position.
Impact - Potential
Positive impact
Own
operations
Short-term
Table 30: Own workforce related impacts, risks, and opportunities (Employee Attraction and Development, DEI, Cybersecurity)
Employee
attraction and
development
Enabling
trainings
and skills
development
NLB Group is continuously committed to leverage trainings throughout the region
and make development of its employees its core value. Investing in training raises
career prospects for employees and improved workplace satisfaction.
Impact - Actual
Positive impact
Own
operations
Short-term
Trainings
and skills
development
Training and skills development are crucial for enhancing employee capabilities and fostering
innovation within banks. By investing in continuous learning opportunities, banks can improve
employee performance, adapt to industry changes, and strengthen workforce engagement,
ultimately leading to better service delivery and long-term competitiveness in the financial sector.
Opportunity
Own
operations
Short-term
Enabling talent
management
and retention
of talent
Enabling talent management and retention of talent ensures that the organization can
maintain a skilled and motivated workforce with improved career prospects.
Impact - Potential
Positive impact
Own
operations
Short-term
Key talent
management
and retention
of talent
Effective talent management and retention strategies are essential for banks to maintain a competitive
edge and drive organizational success. By focusing on career development, employee engagement,
and a positive workplace culture, banks can attract top talent, reduce turnover, and ensure a
skilled workforce that is committed to achieving long-term goals and enhancing service quality.
Opportunity
Own
operations
Short-term
Diversity, equity
and inclusion
Gender pay gap
in remuneration
NLB Group has commited to redue the gender pay gap, which in NLB in 2023. Gender pay gap may
negatively impact work satisfaction of female employees and damage the company's reputation.
Impact - Actual
Negative impact
Own
operations
Short-term
Cybersecurity
Protection
of employee
personal data
Protection of employee personal data ensures privacy and fosters trust among
employees, contributing positively to their sense of security and overall morale.
Impact - Actual
Positive impact
Own
operations
Short-term
Cyber crime
Cybersecurity risks, particularly regarding the protection of employee and customer data, can
significantly impact a bank's financial performance through potential data breaches that lead to
costly remediation efforts, regulatory fines, and litigation, as well as reputational damage that erodes
customer trust and confidence, ultimately resulting in loss of business and diminished market value.
Risk
Downstream
Short,
Medium,
Long-Term

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Employee classification in NLB Group
The conducted DMA and disclosures in this Social
Information chapter relate to all employees who
are and could be materially impacted by the Group.
In accordance with ESRS, NLB Group classifies its
workforce into two categories:
• Employees: Individuals engaged by a contract with
any NLB Group member, either full-time or part-time,
and identified by an ID number.
• Non-Employees: Individual contractors supplying
labour to NLB Group members, including self-
employed individuals with signed contracts, and
workers provided by third-party providers (NACE
Code N78), such as HR agencies, institutions, and
students.

As stipulated in the ESRS requirements, information
on non-employees may be excluded in the first year
of sustainability reporting (for FY 2024). NLB Group
opted to apply this exclusion and plans to report on this
employee type in the future, in line with the regulation at
the time.
Identified IROs, presented in tables on previous page
relate to all of NLB Group’s employees and do not differ
among particular types of employees. For example,
while the impact of office work on employee health is
widespread in all countries where NLB Group operates,
the Group acknowledges that at the same time, some
employee groups may be more exposed to work-related
illnesses, security, and injuries (such as front-facing
employees and security drivers).
Material negative impacts
The identified actual material negative impact of office
work on employee health is widespread in all countries
where NLB Group operates.
For example, employees with impairments and older
employees may be more exposed to work-related
illnesses, and specific group of employees (branch staff,
employees in vault, money transporters, etc.) may be
more exposed to security issues such as violence or
robberies.
Material positive impacts
Material positive impacts of NLB Group on employees
spans across material sustainability topics, which are
described in the table of material IROs above. As a
parent bank, NLB strives to harmonize related policies,
practices, and measures that enhance positive impacts
and minimize negative impacts in all NLB Group
members so that all NLB Group employees are or
could be equally positively affected. These efforts have
some limitations due to different legislations and socio-
economic environments in non-EU countries and the
size of the entities.
Material risks and opportunities arising from impacts
and dependencies
NLB Group relies on a skilled workforce to achieve
strategic objectives and deliver complex financial
services. Talent development and succession planning
are crucial for realizing the opportunities and business
goals set in the Group’s strategy. The DMA reveals
several material opportunities arising from impacts and
dependencies as presented in the table above. Although
only identified material risk above the threshold is
related to cybersecurity, the Group recognizes other
non-material (below the threshold) potential negative
impacts and risks, and embeds their mitigation in its
policies and procedures.
Impact on employees that may arise from
transition plans
The implementation of NLB Group’s transition plan
may have some negative and some positive impacts
on employees; however, none of these are deemed to
be material. If not appropriately addressed, negative
impacts may include increased workload derived from
fulfilling new requirements and establishing new work
processes. On the other hand, the implementation of the
transition plan may have a positive impact and provide
opportunities for new job creation, reskilling, and
upskilling. These impacts will be adequately addressed
in the further development and implementation of the
transition plan.
Risk regarding forced labour or child labour
NLB Group has established a strong policy on human
rights, which prohibits any kind of forced, compulsory,
or child labour and no minors under 18 years of age
are employed in any of NLB Group members. As a
result, none of NLB Group members or activities in own
operations are at significant risk regarding these issues.

The Group has also implemented due diligence
mechanisms to monitor, identify, and act upon any
deviations and incidents which may occur.

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Accounting methodology and reconciliation:
For employee characteristic calculation in this chapter,
the head count methodology was used as at December
2024. The number of employees is reconciled with the
financial statements, note 4.9 Administrative expenses.
Compared to the previous year, at the end of 2024 the
number of employees in NLB Group members increased
by 340 to a total of 8,322 employees. The increase was
mainly due to the acquisition of Summit Leasing Slovenija
and Mobil Leasing, Zagreb. The share of women was
69%, which is the same as at the end of 2023.
Table 33: Number of NLB Group employees by gender and countries (headcount)
31 Dec 2024
31 Dec 2023
Country
Number
Women
Men
Number
Women
Men
Bosnia and Herzegovina
1,025
74%
26%
990
74%
26%
Croatia
41
63%
37%
1
0
100%
Germany
0
0%
0%
0
0%
0%
Kosovo
478
59%
41%
468
59%
41%
Montenegro
410
67%
33%
390
66%
34%
North Macedonia
995
65%
35%
962
65%
35%
Serbia
2,515
71%
29%
2,480
71%
29%
Slovenia
2,856
68%
32%
2,689
68%
32%
Switzerland
2
0%
100%
2
0
100%
Total
8,322
69%
31%
7,982
69%
31%
Note: The measurement of metrics on this page was not validated by an external body other than the assurance provider (for 2024).
S1-6 Employee characteristic metrics
Table 32: Number of employees in countries with at least 50 employees and 10% of total NLB
Group number of employees
Country
31 Dec 2024
31 Dec 2023
Bosnia and Herzegovina
1,025
990
Kosovo
478
468
Montenegro
410
390
North Macedonia
995
962
Serbia
2,515
2,480
Slovenia
2,856
2,689
Table 31: Number of NLB Group employees by gender (headcount)
Gender
31 Dec 2024
31 Dec 2023
Men
2,597
2,503
Women
5,725
5,479
Other
0
0
Not reported
0
0
Total
8,322
7,982

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Table 34: Number of NLB Group’s permanent, temporary and non-guaranteed hours employees by gender and by country (headcount)
31 Dec 2024
31 Dec 2023
Women
Men
Other
Not
reported
Women
Men
Other
Not
reported
Total number of employees
5,725
2,597
0
0
5,479
2,503
0
0
Permanent employees
5,324
2,456
0
0
5,190
2,386
0
0
Temporary employees
401
141
0
0
289
117
0
0
Non-guaranteed
hours employees
0
0
0
0
0
0
0
0
Table 35: Number of NLB Group’s permanent, temporary and non-guaranteed hours employees by country (headcount) - 2024
31 Dec 2024
Bosnia and
Herzegovina
Croatia
Kosovo Montenegro
North
Macedonia
Serbia
Slovenia
Switzerland
Total
Total number of employees
1,025
41
478
410
995
2,515
2,856
2
8,322
Permanent employees
936
41
322
366
890
2,393
2,830
2
7,780
Temporary employees
89
0
156
44
105
122
26
0
542
Non-guaranteed
hours employees
0
0
0
0
0
0
0
0
0
Table 36: Number of NLB Group’s permanent, temporary and non-guaranteed hours employees by country (headcount) - 2023
31 Dec 2023
Bosnia and
Herzegovina
Croatia
Kosovo Montenegro
North
Macedonia
Serbia
Slovenia
Switzerland
Total
Total number of employees
990
1
468
390
962
2,480
2,689
2
7,982
Permanent employees
909
1
335
360
912
2,388
2,669
2
7,576
Temporary employees
81
0
133
30
50
92
20
0
406
Non-guaranteed
hours employees
0
0
0
0
0
0
0
0
0
Note: The measurement of metrics on this page was not validated by an external body other than the assurance provider (for 2024).

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Table 37: Total number of employees who have left NLB Group banking members (headcount)
2024
2023
Entity
Number
Women
Men
Number
Women
Men
NLB, Ljubljana
256
180
76
221
155
66
NLB Banka, Banja Luka
79
57
22
70
53
17
NLB Banka, Podgorica
41
27
14
29
18
11
NLB Banka, Prishtina
42
24
18
26
12
14
NLB Banka, Sarajevo
75
54
21
117
86
31
NLB Banka, Skopje
106
71
35
68
50
18
NLB Komercijalna banka,
Beograd
326
219
107
507
382
125
Total
925
632
293
1,038
756
282
Table 38: Rate of employee turnover in NLB Group banking members
2024
2023
Entity
Number
Women
Men
Number
Women
Men
NLB, Ljubljana
10%
70%
30%
8%
70%
30%
NLB Banka, Banja Luka
15%
72%
28%
14%
76%
24%
NLB Banka, Podgorica
10%
66%
34%
9%
62%
38%
NLB Banka, Prishtina
8.8%
57%
43%
7.3%
46%
54%
NLB Banka, Sarajevo
15%
72%
28%
23%
74%
26%
NLB Banka, Skopje
11%
67%
33%
7%
74%
26%
NLB Komercijalna banka,
Beograd
14%
67%
33%
19%
75%
25%
Total
12%
68%
32%
14%
73%
27%
Notes:
(i) Turnover number and rate refer to NLB Group banking members, which accounts for 93% (7,725) of the total NLB Group employee headcount (8,322).
Data from other NLB Group members were not available for 2024.
(ii) The measurement of metrics on this page was not validated by an external body other than the assurance provider (for 2024).

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At NLB Group, strong working conditions and human
rights commitments are intertwined. The Group
manages them through several policies and procedures,
and pays a special attention to identified material IROs,
which relate to ensuring secure employment and fair
remuneration, safe and healthy working environment,
work-life balance, enabling social dialogue, equal
opportunities for all employees, ensuring cybersecurity
(data and privacy), and enabling development of
employees.
On a high level, the general internal regulation
framework related to the Bank’s own employees
is set out in the Code of Conduct (described in the
chapter Governance information). In addition to the
Code of Conduct and Policy on Respecting Human
Rights, specific IROs are addressed in domain
specific policies, and other internal acts, rules, and
procedures. The purpose, content, and availability are
described for each relevant policy, while scope and
accountability are common to all policies as follows
unless stated otherwise in each policy description.
Scope: NLB Group has established mechanisms for
document and processes harmonization in all NLB
Group members. In line with the Guidelines for the
adoption of NLB Group documents (policies, strategies,
methodologies, criteria, procedures, etc.), internal
documents related to employees are first prepared by
the human resources competence line and adopted by
the competent body in NLB as the parent bank. As a
rule, sustainability-related policies and other internal
documents are adopted first in the parent bank NLB,
whereas Group members are responsible for adapting
them and implementing them in their operations
according to the guidelines of the parent bank and
local legislation. Accordingly, the competence line
defines the level of obligation: whether the NLB
Group document is mandatory, partially mandatory
(mandatory and best practice), or just practice for
other NLB Group members.
Most senior function accountable: The policies
related to employees are in the custody of different
departments, mainly human resource departments.
The Policy on Respecting Human Rights is in the
custody of Sustainability Unit, and policies on
protecting personal data are in the custody of legal,
the general affairs department, compliance, or IT.
Departments are responsible for policy preparation,
updates and first-level implementation, as well as
for building awareness and training related to the
policies. The Management Board or director of each
NLB Group member is accountable for oversight of
policies, while directors of designated departments
are responsible for their operational implementation.
Availability: After a NLB Group member adapts
and adopts its internal acts, they are published on
the intranet site, making them accessible to all its
employees.
Description of actions, targets, and metrics related to
material IROs and sustainability topics are included in
the following sections. In general, NLB Group members
have established specific action plans for executing
activities to achieve the targets and further develop
meaningful strategies related to employees. Progress
towards achieving targets and the effectiveness of
activities are tracked regularly within organizational units
or competence lines responsible for specific sustainability
topics, and through regular internal reporting to the
management bodies of each NLB Group member.
Employees or their representatives are included in target
setting where applicable, and subject to the type of the
target. All work-related activities are regularly discussed
and aligned with workers’ representatives, trade unions,
and employees’ immediate superiors.
Human rights
commitments
Human rights policy
NLB Group members ensure fair treatment and protect
the rights of workers while providing a structured
framework for employers to manage their workforce
effectively in accordance with local labour laws. To this
end, the principles and provisions related to human
rights are included in employment contracts, which are
signed by each employee and are also integrated into
domain-specific internal acts.
Policy on respect for human rights in NLB d. d. and
NLB Group
Content and purpose: The purpose of the policy,
adopted in 2023, is to set NLB Group’s commitment
to respect human rights in accordance with
international standards. These include (but are not
limited to) the Universal Declaration of Human Rights,
the International Covenant on Civil and Political
Rights, the International Covenant on Economic,
Social and Cultural Rights, the ILO Declaration on
Fundamental Principles and Rights at Work, the UN
Guidelines, Performance Standards 2,4,9 as per EBRD
Environmental and Social Policy, and the OECD
Guidelines. In addition to these, NLB follows the
National Action Plan of the Republic of Slovenia for the
Respect of Human Rights in Business and meaningfully
transposes its directions and recommendations to
other regions. The policy lays down principles and
commitments related NLB Group’s own operations,
financing and investing, or relationships with other
stakeholders. It also outlines diligence mechanisms
for identifying and preventing any risks or incidents
stemming from NLB Group’s value chain.
Scope: NLB Group employees.
Most senior function accountable: The policy is in
the custody of the Sustainability Department (or
sustainability coordinators or legal and general affairs
departments in smaller companies without established
sustainability-related functions), while the highest
responsibility lies with the management boards of
each NLB Group member. In addition, to steer the
human rights policy, NLB has appointed a Human
Rights Custodian to monitor and oversee human rights
compliance on the Group level, organize training,
and coordinate the development of due diligence
mechanisms.
Availability: The policy is available to all employee in
the register of internal acts and publicly on the
NLB website.
IRO Management

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The policy includes the following principles and
commitments:
• Employees have the right to a suitable and safe
working environment.
• Employees are encouraged to pursue personal and
professional growth and development.
• Striving to improve the representation of the under-
represented gender in management positions.
• Zero tolerance and prohibition of any form of
harassment to ensure the dignity of employees and
a work environment free from ill-treatment and
harassment.
• Employees are guaranteed the right to an effective
complaint mechanism to express their opinions,
complaints, and observations in confidence.
• Ensuring equal opportunities for women and men, i.e.
equal treatment irrespective of gender.
• Ensuring the inclusion of persons with disabilities
by making appropriate adjustments to workplaces
and work environments, in accordance with local
regulations.
• Recognizing the fundamental rights of employees
to form and join trade unions or other forms of
association, to bargain collectively, and to have the
protection of workers' representatives recognized in
accordance with labour law.
• Considering the safety and health of employees to be
of fundamental importance and giving priority to the
continuous improvement of working conditions.
• The NLB Group supports the elimination of all forms
of forced and child and adolescent labour, human
trafficking and does not employ minors (under 18
years of age).
Rules on the Prevention of Harassment
and Mobbing at Work
Content and purpose: NLB Group members have
adopted the Rules on the Prevention of Harassment
and Mobbing at Work or included these principles
in corresponding instructions, training and other
measures. The aim of this policy is to protect employees
in the event of mistreatment and harassment. As
employers, NLB Group members are obliged to
ensure the dignity of employees and create a working
environment in which no employee is exposed to
mistreatment or sexual or other means of harassment
by subordinates or superiors, colleagues, or anyone
else who performs work for the NLB Group member.
With this policy, all employees uniformly understand
the importance of the prohibition of ill-treatment and
harassment, which they all consistently respect in their
relations with all stakeholders of the Bank.
Scope: NLB Group employees.
Most senior function accountable: The management
boards and directors of HR departments or similar
functions in NLB Group members.

Key activities
In 2024, NLB Group focused on the following activities
related to the overall employee human rights approach:
• The NLB Group conducted a gap analysis in 2023 to
review its policies, processes, and mechanisms for
respecting human rights. The findings from this analysis
started to be implemented in 2024 and will continue to
be integrated into the development of the human rights
due diligence mechanism in 2025 and beyond.
• NLB Group banking members conducted a human
rights impact risk assessment. Additionally, NLB
conducted an employee survey to evaluate the
likelihood and severity of specific human rights
issues. The survey identified the three most important
employee human rights as: (1) equal pay for equal
work, (2) good and safe working conditions, and
(3) the right to rest and leisure. These rights were
included in the Disclosure Management Assessment
(DMA) and are reflected in the identified material
IROs and sustainability topics: working conditions
and human rights of employees, and diversity, equity,
and inclusion. Other human rights, such as child
labour, slavery, and forced labour, were not deemed
significant due to high awareness and existing
legislation in all NLB Group countries.
• Human rights topics were included in mandatory
annual training on sustainability, which was
completed in all NLB Group core members,
contributing to enhancing employee awareness
about human rights.
• Several grievance mechanisms are in place for all
stakeholders, including employees, where human
rights violations can also be detected and further
addressed according to the severity of the breach.
For details, see chapter S1-3.
• To ensure realisation of principles and commitments
related to human rights NLB Group conducts several
on going initiatives for each material sustainability
topic which are described in respective sub-
chapters in the remaining of Own workforce chapter:
Working conditions, Employee attraction and talent
development, Diversity, equity and inclusion, Cyber
security.
S1-17 Incidents, complaints,
and severe human rights
impacts
Table 39: Number of human rights incidents, complaints, and
severe human rights impacts related to employees(i)
2024
2023
Total number of confirmed incidents of
discrimination, including harassment
0
0
Number of complaints filed through
various channels, including
grievance mechanisms(ii)
9
5
Total amount of fines, penalties, and
compensation for damages as a result
of the incidents and complaints
0
0
Total number of severe
incidents (forced labour, human
trafficking or child labour)
0
0
Total number of fines, penalties,
and compensation for damages
as a result of severe incidents
0
0
Total
9
5
(i) Data refers to NLB Group banking members. Data from other NLB Group
members were not available for 2024.
The reports have been processed in accordance with the internal regulations and
no incidents, complaints, or severe human rights impacts were confirmed. Several
cases were concluded with a preliminary report and no further investigation was
opened because there were no indications of harmful behaviour. For others, the
investigation did not identify any harmful behaviour or could not be proceeded due
to anonymity and impossibility of identification.
(ii) The measurement of metrics was not validated by an external body other than
the assurance provider (for 2024).

We are aware that only
a satisfied employee,
one who feels the firm’s trust
and care for his or her
work/life balance and
potential, will help us address
the opportunities that await us.
To nurture an environment of
growth and satisfaction, we focus on
employee health, work-life balance,
stress management and family-
friendly benefits with activities such
as sports games, healthy lifestyle
workshops, stress management,
specialised medical examinations,
additional days off, etc.

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Working conditions
As resulting from the DMA, seven material impacts relate
to working conditions and human rights and cover three
main aspects:
• secure employment: enabling a low turnover rate and
long-term contracts, and fair renumeration of employees
• health: enabling a healthy and safe working
environment, prevention of work-related negative
health effects, enabling a healthy work-life balance,
raising awareness
• labour-management relations: enabling social dialogue,
enabling collective agreements with employees.

Secure employment and
fair remuneration
Policy
Collective agreements
Content and purpose: The general framework for
secure employment is set by collective agreements
or corresponding internal acts, adopted in line with
labour laws in countries of NLB Group operations. For
details about the collective agreements, see chapter
Enabling social dialogue and collective bargaining.
Remuneration Policy of employees in NLB d. d. and in
NLB Group
Content and purpose: This policy provides guidelines
for the prudent remuneration of all employees,
excluding management board members, and aligns the
performance management system and remuneration
across NLB Group. For core financial members, the
policy aligns with the principles used by NLB and
incorporates local regulations that are binding and
applicable at the time for the member. In other non-core
members, the principles of the remuneration policies
are implemented through the employment contract. The
policy defines fixed and variable pay, goal-setting, and
performance criteria (KPIs), and outlines conditions for
allocating and paying variable remuneration. The policy
adheres to EBA and ESMA guidelines, considering
proportionality, NLB Group assets, and local labour
laws. It ensures equal pay for equal work, regardless of
gender, making it gender-neutral.
Most senior function accountable: management
boards and supervisory boards of NLB Group members.
Key activities
Secure employment
All NLB Group members are committed to providing
their employees with long-term employment security by
offering indefinite contracts. However, due to specific
circumstances such as project-based work or temporary
substitutions, fixed-term contracts may be issued. In
Kosovo, labour law stipulates that an indefinite contract
is automatically granted after 10 years of continuous
employment with the bank.
Adequate wage
All NLB Group members are committed to ensuring
equal pay for equal work and setting salaries above
the market minimum, so no employee receives less
than an adequate wage. For example, NLB conducts
annual salary adjustments in accordance with the
minimum wage set by the government and the collective
agreement.
Employee performance assessment
Employee performance assessment is essential
for ensuring fair remuneration. The foundation of
performance evaluation is goal setting, which aligns
with NLB Group’s business strategy and the objectives
of each organizational unit. This goal-setting process
is followed by a performance reviews goal setting
meetings between the employee and their manager,
who discuss:
• key employee goals for achieving the Bank’s business
objectives
• goals and expected workplace competencies
(behaviour)
• performance criteria, divided into goals (what, how
much) and competencies (how, in what way)

Annual, semi-annual, or quarterly goal planning
and key competency definition form the basis for
performance appraisals and performance-based
earnings. The planning, monitoring, and evaluation
frequency depends on the tasks performed by
employees in the organizational unit.
Other ongoing activities related to collective agreements
include following the legislation, maintaining a
dialogue with employees, trade unions and workers
representatives, ensuring employees receive written
contracts at the beginning of the working relationship,
and enabling social protections coverage in case of
major life events related to the employment (such as
sickness, parental leave, retirement, unemployment).
Activities related to engaging employees and social
dialogue in setting collective agreements are described
in detail in section S1-3. To ensure proper execution of
the remuneration policy, NLB Group members make
adjustments based on monitoring the market conditions
(market salary benchmark), local legislation, and
dialogue with employees and/or trade unions and
workers’ representatives.

S1-13 Performance review metrics
In 2024, it is estimated that 99%-100% of NLB Group
eligible employees had a performance review. In line
with the remuneration policy eligible employees are all
employees excluding long-term absentees (longer than
half of the evaluation period), such as employees on
parental leave or long-term sick leave, and conducting
a performance and career development review is
mandatory.
Table 40: Performance and career development reviews
2024
Percentage of eligible employees
with performance and career
development reviews
99%-100%
(69% women, 31% men)
Notes:
(i) Data refers to all NLB Group members and includes all eligible
employees for performance and career reviews. The gender breakdown is
estimated taking into account a general gender breakdown in NLB Group.
(ii) The measurement of the metric was not validated by an external body
other than the assurance provider.

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S-10 Adequate wages metrics
The general objective related to secure employment
and fair remuneration is to increase the number of
employees with long-term or permanent contracts
(where applicable and based on employment needs)
and to secure adequate and appropriate wages taking
into account job context, market conditions, local
legislation, and employee satisfaction.
Table 41: Adequate wages metrics
2024
Percentage of employees paid an adequate wage
100%
Notes:
(i) Data refers to all NLB Group members
(ii) The measurement of metrics was not validated by an external body
other than the assurance provider
Safe and healthy working
environment
Policy

Occupational health and safety management system
(OHS)
Content and purpose: The OHS system in NLB Group
is based on legal requirements, which are determined
in the laws and regulations on health and safety
at work applicable in each member state. On this
foundation NLB Group members have established
internal documents, such as the Statement on Safety
and Risk Assessment or similar rulebooks on health
and safety. These regulate the rights, obligations,
and responsibilities of employers and employees in
connection with the implementation and improvement
of safety and health protection of employees at work,
as well as general principles of prevention, and a
system of rules of safety and health protection at work,
the application of which achieves the prevention of
injuries at work , occupational diseases, and other
diseases related to work, as well as protection of the
working environment, and other issues related to
safety and health protection at work. Among other
topics, special protection is prescribed in order to
preserve the mental and physical development of
young people, to protect women from risks that
could endanger the realization of motherhood, to
protect persons with disabilities and occupationally
ill persons from further damage to their health and
reducing their working capacity, and to preserve
the working capacity of older employees within the
limits appropriate to their life age. The statement also
includes a risk and health assessment for specific job
categories.
Scope: All NLB Group employees are covered by the
undertaking’s health and safety management system
based on legal requirements.
Most senior function accountable: The Management
Board of each NLB Group member. In addition,
all members (except those with fewer than three
employees) NLB Group members employ professional
workers for health and safety at work, who,
together with the help of managers, take care of the
implementation of measures to ensure safety and
health at work or they hire a licensed company to
implement occupational health and safety law and to
inspect the applicable measures.
Key activities
Ongoing activities to ensure a safe and healthy
environment include risk assessment and incident
investigation, health and safety training, and workplace
health promotion and initiatives. Their impact and
progress are monitored by organizational units in
charge of these activities.
• Occupational health risk assessments (technical
and health risk) are conducted according to specific
methodologies and on-site inspections, following
health and safety legislation. Measures to reduce
occupational emissions, regular safety training,
and provision of personal protective equipment are
implemented. Injuries are recorded, investigated,
and measures are adopted to prevent recurrence.
Risk assessment is a foundation for the Safety and
Risk Assessment Statement. Employees must report
any workplace risks or incidents to their supervisor.
If a danger is identified, they must stop working and
inform their superior, who will act in line with internal
protocol. Employees can only return to work once the
danger is eliminated.
• Employees take part in regular obligatory
(theoretical and practical) training on health and
safety, fire protection, first aid, and evacuation.
Employees who work in a higher risk position are
provided with special or additional training for
their specific jobs or tasks (e.g. handling cash and
securities, cash transport, debt collection). Training
sessions are provided by certified legal entities for
OSH and other professional companies.
• General periodical medical examinations are
mandatory for all NLB Group employees. Other
initiatives include improving work organization,
encouraging healthy activities, enabling healthy
lifestyle choices, and promoting personal
development. Specifically, projects like the Health
Bank, partnerships with healthcare institutions, and
employee memberships in sports associations further
support employee health awareness and care.
• NLB and several other Group members also offer
ergonomic workplace adaptations (such as
ergonomic chairs) to maintain employee health.
• A special awareness programme, Healthy Bank, was
established in NLB, providing webinars on various
topics. This programme started in NLB and is being
gradually implemented in other NLB Group members.
• Recognizing the need for increasing the awareness
of sound mental health and appropriate stress
management, an employee assistance programme
started in Slovenia and Serbia, offering anonymised
psychological and other support.
• Employees can also take part in several sport
events and activities provided by NLB or other
Group members (such as membership in internal or
external sports associations, NLB sport events and
gatherings, etc.)
• Employees can suggest improvements or express
concerns about occupational health and safety. The
Group has various methods for worker participation,
consultation, and communication. In some countries,
safety committees or trade union representatives help
prepare safety declarations and collect employee
feedback. Where there are no committees, employees
follow guidelines and can send suggestions by email.

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S1-14 Health and safety metrics
The general objective related to health and safety is to
ensure working conditions for preventing work-related
illness, injuries, excessive stress, and deterioration of
mental health.
Table 42: Health and safety metrics
2024
Percentage of employees covered by the health
and safety NLB Group management system
100%
Number of recordable work-related accidents(i)
29
Number of recordable work-related ill health
0
Number of days lost to work-related injuries
from work-related accidents or
work-related ill health(ii)
769
Number of work-related fatalities
0
(i) Work-related accidents relates to employees (non-employees
excluded) and were recorded only in NLB Group banking members, with
share ranging from 0.26% to 0.78% of total workforce in each bank.
(ii) Data refers to NLB Group banking members, which accounts for 93%
(7,725) of the total NLB Group employee headcount (8,322). Data from
other NLB Group members were not available for 2024.
(iii) The measurement of metrics was not validated by an external body
other than the assurance provider.
Work-life balance
NLB Group consistently prioritizes imparting knowledge
about healthy habits and advocates activities that
contribute to employees’ well-being and satisfaction.
It fosters a healthy work environment conducive to
meaningful interpersonal connections and a balanced
work-life dynamic.
Policy

Family-friendly measures, regulation on remote
work, and the right to disconnect
Content and purpose: The general framework for
enhancing awareness and implementing concrete
measures on work-life balance is stipulated in NLB
Group’s Code of Conduct, the Policy on Respecting
Human Rights, and the Sustainability Policy. Some NLB
Group members have adopted special regulations
and instructions related to work from home (hybrid,
remote work), flexible working hours, and working
time, or have these principles implemented in other
acts defining the employment relationship. Also, some
Group members have internal acts defining measures
and processes on creating a family-friendly company,
while all members strive to follow these principles. In
2024, all NLB Group members operating in Slovenia
adopted the Policy of the Right to Disconnect,
transposing the EU directive, which ensures that
employees have the right to disengage from work-
related electronic communications during non-work
hours, promoting a better work-life balance and
protecting their health and well-being.
Most senior function accountable: Directors of HR
departments or similar functions in each NLB Group
member.
Key activities
Family-friendly measures at NLB Group address
various aspects of the working environment to promote
work-life balance. These measures are continuously
implemented and developed across all NLB Group
members, with NLB and NLB KB holding national
certifications from Ekvilib Institute and Balance company
CEE. Internal teams, including HR and other department
representatives, monitor progress, provide reports, and
discuss improvements.
• In NLB 27 measures are in place, out of which 11
measures are related to family benefits. See the full
list on the NLB Website.
• In NLB Komercijalna banka Belgrade 19 measures
are in place: team for coordinating work-life balance;
external/internal communication; work-life balance
training for leaders; Work-life balance survey;
scholarships for employees' children; financing
for in vitro fertilization (IVF) and prenatal testing;
innovations in work processes; panel discussions on
work-life balance; family day.
• In October 2024, NLB Banka Banja Luka signed a
Memorandum of Understanding with the United
Nations programme to promote family-friendly
workplace and joined the Expanding Choices
programme.
• In countries without a family-friendly certificate,
NLB Group members adopt individual measures to
support working parents and provide family-related
leaves in accordance with the local legislation.
Common measures include hybrid work, well-being
webinars, days off for significant life events, and
limited overtime.
• Parental leave is enabled for female and male
employees in all countries. In addition, banking
members allow both genders additional family-
related leaves.

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Enabling social dialogue
and collective bargaining
NLB Group members are committed to establishing
constructive relations between employees and
management, maintaining high standards of social
dialogue, and ensuring timely communication. This also
includes open communication on relevant topics and
informing employees and their representatives prior to
the implementation of significant operational changes
that could substantially affect them.
Policy

Collective Agreement
Content and purpose: The Collective Agreement, being
an outcome of social dialogue between employees’
representatives, is a general framework stipulating the
rights and obligations of the employer and employees
in relation to the employment legal relationship.
Collective agreements of NLB Group members follow
local labour laws in the countries of their operations
and are respected by all NLB Group members.
The Collective Agreement regulates all matters of
importance for the employment relationship, rights,
obligations, and responsibilities, especially the
establishment of the employment relationship, its
duration, working hours, health and safety at work,
professional training, protection against discrimination
and abuse at work, and the right to freedom of
association. In addition, where applicable NLB Group
members adopted rulebooks regulating cooperation
between workers’ representatives; for example, in NLB
the Workers and Management Act and the Agreement
on Cooperation between the Workers’ Council and
Employer have been established.
Scope: All NLB Group financial members, except NLB
Banka Prishtina, NLB Banka Sarajevo, NLB Banka
Banja Luka, NLB Lease&Go Srbija and NLB Fondovi
Srbija have established collective agreements. In
countries where the collective agreements are not
adopted, NLB Group members adhere to the local
labour laws, ensuring that collective agreement
principles are respected.
Most senior functions accountable: The Management
Board and in some entities also the Supervisory Board.
Key activities
In NLB Group members with established collective
bargaining agreements (CBA), these are promptly
renewed.
During 2023 and 2024, social dialogue was conducted
with established trade unions across all NLB Group
members, resulting in renewed collective bargaining
agreements:
• NLB: Valid for 2 years, from January 2024 to
January 2026.
• NLB Komercijalna Banka Belgrade: Valid for 3 years,
from April 2023 to April 2026.
• NLB Banka Skopje: Valid indefinitely from
October 2024.
• NLB Banka Podgorica: Valid for 5 years,
starting December 2023.

NLB Banka Banja Luka, NLB Banka Sarajevo, and NLB
Banka Prishtina do not have CBAs as in Bosna and
Herzegovina and Kosovo there is no general collective
agreement or collective agreement for the financial
sector, hence workers' rights are regulated by the Labor
Law and by-laws. Therefore, these three banks have
adopted, in line with local labour law, the internal labour
rulebooks and use the NLB Collective agreement as
a best practice. NLB Banka Prishtina does not have a
representative trade union, while in NLB Banka Sarajevo
and NLB Banka Banja Luka those are established.
›› For additional description of key processes,
engagement and related activities, please refer to the
chapter S1-2.
S1-8 Collective bargaining coverage
and social dialogue
The general objectives related to social dialogue and
collective bargaining are to promptly discuss relevant
work-related topics and enable employees and their
representatives to express opinions or consensus.
Table 43: Social dialogue
31 Dec 2024
The percentage of employees
covered by collective agreements
94%
Notes:
The measurement of the metric was not validated by an external body
other than the assurance provider.
Table 44: Collective bargaining and social dialogue coverage
Collective bargaining coverage
Social dialogue
Coverage
rate
Employees
EEA
Employees
non-EEA
Workplace
representation
(EEA only)
0-19%

20-39%
40-59%
60-79%
80-100%
Slovenia
Serbia, North
Macedonia,
Bosnia and
Herzegovina,
Montenegro
Slovenia
Notes:
(i) Data refers to NLB Group banking members (in EEA and non-
EEA), which accounts for 93% (7,725) of the total NLB Group employee
headcount (8,322). Adequate data from other NLB Group members were
not available for 2024. NLB Banka Prishtina (Kosovo) does not have
collective agreement.
(ii) The measurement of metrics was not validated by an external body
other than the assurance provider.

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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Employee attraction
and talent
development
Policies

Human Resources and Organization Development
Strategy for NLB Group
Content and purpose: A general framework for
employee development is set out in the Group’s HR
Strategy and the Human Resources and Organization
Development Strategy for NLB Group, which
defines the basic areas (HR strategy, organization,
education) and work activities in NLB Group, which
contributes to the performance of individuals, teams,
and the entire Group as well as ensure sustainable
development and long-term business success. The
Policy is complemented with the Standards for the
Human Resources Business Line in NLB Group, the aim
of which is to set up the standards of operation and
harmonization of operations in NLB Group members.
Scope: NLB Group employees
Key Employees Management Policy in NLB
Content and purpose: Key employees are those
whose departure from the NLB Group would mean
a significant loss, for example because of the rare
know-how or experience of such employees. The
Policy aims to define all significant factors and
measures that contribute to increased and more
successful commitment of key employees with the
aim of improving their loyalty, efficiency, motivation,
responsibility, and creativeness, and in order to
retain their employment in the Group. Investing in
key employees is a long-term process aimed at
retaining the best employees, since this contributes
to maintaining their high performance, engagement,
and efficiency in the long run. At the same time, this
Policy has a positive impact on attracting talent from
the labour market and will thus be profitable in the
long run.
Scope: key NLB employees
Policy on mobility within the NLB Group
Content and purpose: The Policy defines the
frameworks and orientations that make it possible to
set uniform starting points for implementing mobility
within NLB Group and ensure compliance with the
targets, values, culture, and strategy of NLB Group.
Its purpose is to enhance agility and development of
all employees within the NLB Group on the horizontal
as well as the vertical levels with a high potential
for assuming complex assignments or positions
(in particular managers, talents, key employees,
successors) or for reassignment within NLB Group.
As the Group is present in different countries in SEE,
the Policy reflects the modern approach to employee
management, and acknowledges different forms of
employment and cooperation as the basic source of
competitive advantage and business results of
NLB Group.
Scope: NLB Group employees
Key activities
The Group is continuously committed to leverage
training throughout the region and make development
of its employees its core value. By establishing a broad-
based approach to training, NLB Group ensures that the
team remains agile and well-versed in both traditional
and emerging industry domains. Furthermore, the
Group is dedicated to fostering an inclusive environment
where every employee has equal access to learning
opportunities. By removing barriers to education and
development, mostly with the help of digital channels,
the Group ensures that all team members can grow,
contribute, and thrive within our organization.
In 2024, activities in following areas were conducted in
NLB Group members:
• NLB received the Top Employer certificate for the
9th consecutive year, and NLB Komercijalna Banka,
Belgrade, earned this certification for the first time.
• Various training activities provided by the NLB
Education Centre. Located in Slovenia, the centre
follows trends in the market to predict vital skills and
competencies that will have an impact on the Group’s
future. It provides learning opportunities to all Group
employees, in particular through the Udemy platform,
which offers over 7,000 training courses, available to
all employees as self-paced learning.
• Some Bank members have internal coaches and
internal trainers who conducting development
activities and training.
• All NLB Group members conducted mandatory
e-training sessions based on legislation and financial
industry specifics (in particular code of conduct,
compliance, AML, anti-bribery and corruption, IT
security, etc.).
• Several NLB Group members executed training
sessions for specific employee groups and topics, such
as leadership, coaching, and an executive monitoring
programme, innovation, sustainability and ESG, and
diversity and inclusion.
• NLB Group banking members conducted a talent
management programme with the same methodology,
and three members started the successor programme.

›› Please refer to the business report, section: Human
Resources for additional descriptions of activities for the
Bank’s own workforce.

Targets and metrics
In 2024, the annual Employee Engagement Survey was
conducted in 10 NLB Group members (core financial
members and NLB Digit), confirming a high employee
engagement score (improved by 4 p.p. compared to
2023) and high net-promoter score. NLB Group banking
members invested 7.7 training days/employee
(of which 8 days/woman and 7.2 days/man), showing
YoY improvement by 0.5 days, and exceeding 2030
target by 40%. The average sustainability-related
training days per employee stood at 0.3 days, showing
improvement by 0.13 days.
Table 45: Employee attraction and talent development metrics
2024
2023 Target 2030
Employee engagement(i)
54%
50%
>50%
Employee net promoter score(i)
26
23
>50
Average training hours per
employee(ii)
46.2
43.2
33
Average training days per
employee(ii)
7.7
7.2
5.5
(i) Data refers to 10 NLB Group members (NLB and 6 subsidiary banks,
NLB Digit, NLB Lease&Go, NLB Skladi) which are included in the regular
annual survey. The survey sample included 7,709 employees or 92.6% of
the total headcount of NLB Group (8,322).
(ii) In line with NLB Group’s internal methodology, 6 hours equal 1 training
day. Data refers to NLB Group banking members, which accounts for
93% (7,725) of the total NLB Group employee headcount (8,322). Adequate
data from other NLB Group members were not available for 2024.
(iii) The measurement of metrics was not validated by an external body
other than the assurance provider (for 2024).

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Overview
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Diversity, equity, and
inclusion

Policies
HR Strategy, Sustainability Policy
Content and purpose: The general framework for
diversity, equity and inclusion in the workplace is
set out in the Sustainability Policy, which set out a
commitment to include diversity and inclusion, equal
opportunities, and non-discrimination for reasons of
gender, ethnicity, age, or any other circumstance, and
to ensure efficient addressing of diversity, in particular
gender equality, in the highest governance bodies
and senior positions. In addition, an inclusive work
environment is one of the main strategic directions of
the new NLB Group HR Strategy 2025. The Strategy
outlines the principles of embedding diversity, equity,
and inclusion (DEI) in all elements of key HR processes.
It also outlines strategic initiatives to be followed by all
NLB Group members, taking into account their local
specific and legislation.
Scope: NLB Group employees.
Most senior function accountable: Management
Board and HR directors or similar functions in
NLB Group members.
Availability: Register of Internal Acts.
Key activities
Key activities in 2024 were as follows:
• The HR department and Sustainability Team
raised awareness on DEI group-wide with on-
line sessions on topics related to DEI, reporting on
the Sustainability Committee and through on-line
webinars in the Sustainability Festival.
• The Diversity Policy for the Management Board and
Supervisory Board was revised.
• To enhance the importance of diverse recruitment,
this commitment was communicated transparently,
both internally and externally, as the said proactive
approach not only attracts diverse candidates
but also signals to current employees that their
unique contributions are valued and integral to the
organization’s success.
• The gender pay gap analysis was conducted in
all strategic members (except leasing companies
pending merger) to identify the gaps and differences
due to different structures and job positions in
NLB Group members. The outcomes will serve as a
foundation to prepare measures to reduce gaps.

S1-9 Diversity metrics
Table 46: Gender distribution at top management as at
31 Dec 2024
Total
Women
Men
NLB Group (all
members) – number
226
120
106
NLB Group (all members)
– percentage
100%
53%
47%
Note:
In line with internal methodology, which is harmonized among NLB Group
members, top management refers to B-1 directors: managers who directly report to
the management board of the particular NLB Group member.
The measurement of metrics was not validated by an external body other than the
assurance provider.
Table 47: Age distribution as at 31 Dec 2024
Total
Under
30
30-50
Over
50
NLB Group (all members)
– number
8,322
822
5,350
2,150
NLB Group (all
members) – percentage
100%
10%
64%
26%
Notes:
(i) Age distribution for all NLB Group members is estimated. Actual age distribution
data included 8,174 employees, of which NLB Group banking members (7,725
employees) and other Group members where adequate data were available (449
employees). For NLB Lease&Go Ljubljana, Skopje, Belgrade, Car and Go, NLB
Muza, NLB Fondovi Skopje, Real estate Podgorica, NLB Interfinanz, OL Nekretnine,
NLB Srbija, were not available. For the remaining 148 employees, their distribution
was estimated by applying the same percentage breakdown derived from the
available data and proportionally adding them to the respective categories.
(ii) The measurement of the metric was not validated by an external body other
than the assurance provider.
S1-16 Pay gap and total
remuneration metrics
At NLB group, we acknowledge that monitoring the
gender pay gap and addressing related issues is
important for providing an equitable and inclusive
workplace.
The unadjusted pay gap reflects the composition of the
workforce and the spread of each gender in lower or
higher-paying roles. As unadjusted pay gap compares
the total salaries for men and women respectively,
and it may be skewed due to outliers and different
circumstances. These may include underrepresentation
of women in leadership positions, especially on the
executive level, and overrepresentation of women in
other, lower-paid positions. For this reasons, NLB Group
has reported in previous reports on the adjusted gender
pay gap, which measures differences in earnings
between men and women holding the same roles or
positions, and thus provides additional understanding.
It should be pointed out that gender pay is not the same
as equal pay. Gender pay looks at the difference in the
average pay between all men and all women employes,
regardless of their role or seniority. Equal pay, on the
other hand, is defined as ensuring that there is no direct
or indirect pay discrimination on grounds of sex. This
means that men and women should receive equal pay for
the same work or work of equal value. The assessment
of comparable work is based on criteria such as skills,
effort, responsibility, and working conditions, applied in
an objective and gender-neutral manner.
NLB Group is actively preparing for the new EU "Directive
of the European Parliament to strengthen the application
of the principle of equal pay for equal work or work
of equal value between men and women through pay
transparency and enforcement mechanisms", which
states that member states must implement the laws and
other regulations necessary to comply with this directive
by June 2026 and first reporting on salary gaps will have
to be carried out for year 2026 in 2027. According to these
requirements, the Group will strengthen its efforts to apply
this vision. Current activities are focused on monitoring
the data and systems to ensure adequate introduction of
those requirements.
Table 48: Remuneration and gender pay gap metrics(i)
31 Dec 2024
Average unadjusted gender pay gap of all
employees in NLB Group banking members(ii)
27%
Annual total remuneration in NLB
Group banking members(iii)
1:26

(i) Data refers only to NLB Group banking members, which account for 93% of the
employee headcount. Data from other NLB Group members were not available for
2024.
(ii) The average unadjusted gender pay gap is calculated per employee as of 31
December 2024 and includes basic salary with seniority bonus. It is calculated as
the difference between average gross basic earnings of men and women in NLB
Group banking members as a percentage of average gross basic earnings of male
employees.
(iii) The total annual remuneration ratio is based on remuneration data of all
employees who were employed in each individual bank from 1 January 2024 until
31 December 2024, taking into account purchasing power parity in the particular
country for 2024. The annual total remuneration is calculated as a ratio between
the annual total remuneration for the NLB Group banking member’s highest-paid
individual and the median employee annual total remuneration (excluding the
highest-paid individual).
(iv) The measurement of the metric was not validated by an external body other
than the assurance provider.

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Strategy
Risk Factors & Outlook
Performance Overview
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Risk Management
Sustainability
Statement
Financial
Report
Cybersecurity
NLB Group pays special attention to assuring the
confidentiality, integrity and availability of data,
information, and IT systems that support internal
processes used by employees, banking services, and
products for clients, especially when it comes to topic of
cybersecurity, which includes the protection of internet-
connected systems from cyberthreats.
In 2024, information security governance was enhanced
by establishing Group IT Security operations.
Also, with the adoption and publication of the new NLB
Group Strategy 2030 (New Horizons) and the conclusion
of the current IT Strategy, work on the new IT Strategy
for the period 2025–2030 is underway, which will
address, among other topics, the cybersecurity matters
related to the Bank’s own employees. In the remainder
of this chapter key policies on NLB Group level related to
information security are presented.
Policies
IROs related to cybersecurity are managed through
various policies, guidelines, and instructions. The most
overarching policies are described in detail below. The
provisions of these internal acts apply to all NLB Group
members, taking into account the provisions of local
legislation governing the protection of information,
persons, and property. The most senior function
accountable for implementation of the policies are the
management boards of NLB Group members. Policies
are available for employees in the Register of Internal
Acts. In addition, the key contents are included in the
mandatory annual training on information security.
NLB Group Information Security Policy
Content and purpose: The Policy outlines a
comprehensive cyber and information security
governance framework, adhering to the three lines
of defence model. The aim of this is to ensure robust
management and oversight of information security
risks across various levels of the organization,
encompassing business management, IT Security
function, CISO, and internal audit. The Policy
emphasizes the importance of integrating information
security into everyday operations, aligning with
organizational requirements and international
standards. Furthermore, it details specific roles,
responsibilities, and procedures to safeguard the
confidentiality, integrity, availability, and authenticity
of data, information assets, and ICT assets, thus
enhancing the overall digital operational resilience.
The Bank provides information protection in
accordance with the laws (the Banking Act, the
Personal Data Protection Act, the Companies Act,
the Business Secrets Act), other regulations, and the
principles of good practice defined in the ISO/IEC
27001:2013 and ISO/IEC 27002:2013 standards.
NLB Group IT Security Governance Policy
Content and purpose: The purpose of the Policy is to
ensure the continuity of critical business processes
and to minimize IT security-related risks and damages
by preventing and/or minimizing potential malicious
events – IT security incidents.
To this end, the Policy defines concepts of IT Security
organization in NLB Group and responsibility
allocation. It places IT security as a skilled specialized
organizational unit (hereinafter: IT Security Function)
within the Group. The Group IT Security function is
established by and responds to the Group CIO (in
alignment with IT CL). The local IT Security function is
located within the local IT department but has a high
level of independence within the local subsidiary.
NLB Group IT Security End-User/Employee
Protection
Content and purpose: The protection of end users,
including employees and their devices, is crucial
for maintaining the overall security of information
systems. The objective of this guideline is to establish
comprehensive security practices applicable to all
users within the organization, regardless of their
specific work settings. This document aims to enhance
security awareness and provide strategic measures to
mitigate risks associated with the use of organizational
IT assets.
›› For details on key activities, initiatives, and progress
related to cybersecurity, please refer to the business
report, chapter IT and Cyber Security and Compliance
and Integrity, subchapter Information Security and
Personal Data protection.

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Financial
Report
S1-2 Processes
for engaging
with employees
and workers’
representatives
about IROs
NLB Group members have established general process
for engaging with their employees.

The Group is committed to establishing constructive
relations between employees and management,
maintaining high standards of social dialogue, and
ensuring timely communication on various topics,
including impacts, risks, and opportunities. Following the
conducted DMA, NLB Group will enhance the inclusion
of material IROs in the discussions with employees and
their representatives.
In all countries of operations and entities, NLB Group
strives for a high level of consistency by using
NLB practice as a guideline and adhering to local
legislation. NLB Group members strictly respect and
follow national labour laws which stipulate the right for
workers to form trade (or labour) unions and to freely
associate through them.

NLB has two workers’ representative bodies: a
representative trade union and a workers’ council.
In other banking members a trade (labour) union is
also established, except in NLB Banka Prishtina. In
leasing companies, asset management and other
NLB Group members trade unions have not been
established. Therefore, the management boards of
companies conduct the social dialogue directly with
employees by regular communication channels, such as
personal meetings, management sessions, meetings of
organizational units, etc.
Processes for information, communication, negotiation
and complaints to or with representatives is defined in a
detailed agreement between the employer and workers’
representative bodies (where they are established) and
in local labour law legislation. For example, in NLB, the
cooperation with the labour unions and the Workers’
Council is stipulated by collective agreements, the Act
of workers and management and the Agreement on
Cooperation between the Workers’ Council and the
Employer.
Representatives in trade or labour unions collect
information and questions from employees and take
initiatives related to material impacts, such as collective
bargaining agreements, employees working conditions,
workers' rights and responsibilities, occupational health
and safety matters, matter regarding employees with
disabilities, other work-related issues, etc. In other NLB
Group members employees’ initiatives and requests
on the aforementioned topics are gathered via human
resources departments, internal communication
channels, or in person.
The engagement with workers’ representatives takes
place frequently, regularly, at all relevant business
decisions, and with established monitoring and
oversight. For example, in NLB the organizational setting
includes:
• The NLB representative trade union. Monthly
meetings are held with the trade union on open
topics. If open negotiation, then meetings are in line
with the negotiation process. The main topics of
interest are related to social status improvement.
• Workers’ Council. Regular monthly meetings are held.
The main topics of interest are related to working
conditions.
• Two representatives on the NLB Supervisory
Board of (at the time of the report) who participate
in discussion and oversight of IROs relating to
employees.
• An authorized representative who is assigned to
cooperation in labour relations who coordinates and
monitors the effectiveness of engagement with the
trade unions and the Workers’ Council.
In the case of business decisions and circumstances that
could have a material impact on employees, workers’
representatives' bodies are promptly informed or sought
for opinion. These include decisions such as:
• dismissals of employees due to redundancies
(economic, technical, organizational reasons)
• significant operational or organizational changes
• adoption of relevant work regulations (internal acts)
• for dismissal of employees who have committed a
serious breach of work obligation

Deadlines for informing employees and their
representatives prior to the implementation of significant
operational changes that could substantially affect them
range from 8 to 30 days, subject to the nature of the
operational change.
Operational responsibility for ensuring that social
dialogue happens lies with senior managers or
directors who are in charge of human resources
departments in each NLB Group member or authorised
for cooperation in labour relations. They are in on-going
communication with management boards. This ensures
that engagement results and other topics are promptly
addressed and that decisions are incorporated in the
operations of particular NLB Group member.
In line with the policies on respecting human rights and
principles for diversity, equity and inclusion, NLB Group
members include in their engagement processes all
employees, regardless of their sex, religion, seniority, or
any other characteristics or circumstances, as well as
employees with disabilities.

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Financial
Report
NLB Group has a process and grievance mechanisms
in place to remediate negative impacts and has
established channels for its employees to raise
concerns and complaints.

In all NLB Group core financial members employees
have access to different channels through which
they can report (even anonymously) any non-ethical,
inappropriate business practices or any potential or
actual negative impacts on employees or the company,
including any employee-related matters, such as
harassment or other inappropriate events. These
channels are established by NLB Group members
themselves and do not involve third-party mechanisms.
NLB Group
employees can raise
concerns through
established grievance
mechanisms
Employees may report:
• electronically and anonymously via the Whistler web
application
• via e-mail to a dedicated e-mail address
• in person or by telephone to authorized persons
for reporting and confidants under the local
whistleblower protection acts
• through other channels in place for employees to
express comments, questions, and concerns, such as
e-mail, HR department, authorized representatives in
trade unions, etc.

NLB Group core financial members support the
availability of these channels and increase trust in these
channels and mechanisms in several ways:
• by regular and transparent internal communication
on their intranet sites
• by including a description of how to raise concerns in
each specific internal policy
• by conducting training which raises awareness on
speak-up culture

The channels are estimated to be effective as there are
some anonymous cases reported every year and there
have been no complaints or breach of data identified or
reported. All reports are examined in line with internal
procedures, which are applied in a harmonized manner
to all NLB Group members to ensure consistency.
Accordingly, each NLB Group member tracks the
outcome, i.e. number of reported and remediated cases,
and takes appropriate remediation measures.

›› For details on grievance mechanisms please refer to
the Chapter Whistleblower protection.
S1-3 Processes to remediate negative impacts
and channels to raise concerns

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Financial
Report
As a financial institution, NLB Group fulfils four main
roles: employer, lender and investment service
provider, procurer of goods and services, and
facilitator of financial support and mentorship
programmes to society. Through these roles the Group
directly and indirectly affects the lives of many people,
specific groups, and various communities in the region,
including their economic, social, cultural, and other
components of human rights. In addition, understanding
community perceptions, needs and concerns (through
engagement, dialogue, polls and research) informs and
contributes to the NLB Group's daily business activities,
strategy and business model.

As the Group’s operations are centred around
financial transaction and services, it does not have
physical operations or supply chains that would
affect communities through production, logistics, or
distribution or would represent material dependencies.
Hence, the Group considers its indirect impacts on
communities and related risks through its environmental
and social risk assessment (ESMS) in lending and
investment decisions by identifying and evaluating
the impacts and risks of the potential or actual client’s
operations on the communities and by providing clients
with green and transition financing.
The DMA confirmed that the Group’s largest, though
indirect, impact on affected communities is through
its financing activities which are at the core of NLB
Group’s business model. These impacts stem from green
lending and investment, which are presented in detail
in the chapter Sustainable finance, and from financing
community and economic development in a broader
sense, which is presented in this chapter.
The Group also has an important social impact that
goes beyond lending and investing. We actively support
communities through sponsorships and donations,
which are at the heart of Contribution to Society, the
third pillar of the NLB Group Sustainability Policy.
Through this, various segments of local communities are
positively affected, either directly or indirectly.
Material impacts and opportunities are embedded
in the NLB Group’s strategy and business model as
presented in the table below.
S3 Affected Communities
SBM-3 Material impacts, risks, and opportunities, and their
interaction with strategy and business model
Table 49: NLB Group’s material actual and potential impacts on its communities mapped to material sustainability topics
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in
the value
chain
Time horizon
Financing community
and economic
development
Supporting housing
development in
the region
By financing private or corporate real estate projects, NLB Group is
contributing to new housing developments, a key social need.
Impact – Actual
Positive impact
Downstream
Short-term
Supporting systemic
financial stability
NLB Group is a key player in the regional monetary system; with prudent risk management
and financial stability it is contributing to macroeconomic stability in the region.
Impact – Actual
Positive impact
Downstream
Short-term
Supporting
regional economic
development
Supporting regional economic development allows banks to strengthen
local economies, create jobs, and foster community resilience. By financing
infrastructure projects, small businesses, and sustainable initiatives, banks
can enhance their reputation as community partners while driving long-term
growth and stability, ultimately benefiting both the region and the Group.
Opportunity
Downstream
Short-term
Sponsorships
and donations
Sponsorships
and donations
NLB Group is supporting environmental and social initiatives
through sponsorship and donations programmes.
Impact – Actual
Positive impact
Downstream
Short-term
Supporting
humanitarian
organizations
Supporting humanitarian organizations through enabling financing and donations.
Impact – Actual
Positive impact
Downstream
Short-term

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S3-1 Policies related to
affected communities
Managing NLB Group’s impacts, risks, and opportunities
related to communities is included in the Group’s policies
on financing, sponsorships, and donations.
Human rights commitments relevant for communities
that are affected by NLB Group’s financing,
sponsorships, and donations programmes are
stipulated in the Policy on Respect for Human Rights
in NLB d.d. and NLB Group (presented generally in the
chapter Own workforce, while principles related to
affected communities are explained below in the section
Key policies.
NLB Group is committed to respecting and preventing
violations of human rights in its own operations and its
value chain as well as acting on any detected violations.
This chapter outlines the approach to respecting human
rights that NLB Group has established as a financing
provider and contributor to society.
The human rights commitment and policies do not
particularly address impacts on indigenous people, as
such groups are not formally recognised in the markets
where NLB Group operates. NLB Group is committed to
considering all ethnic groups equally and in line with its
internal acts.
›› For additional information on respecting human rights
in employee relations and procurement, please see the
chapter S1-Own workforce and Sustainable supply
chain, respectively.
Policies related to financing community and
economic development
Content and purpose: The key internal documents
related to communities affected by the Group’s
financing are the NLB Group Lending Policy and
the Environmental and Social Transaction Policy
Framework in NLB and NLB Group.
As described in detail in the chapter E1 - Climate
Change, the Environmental and Social Transaction
Policy Framework sets out the ESMS (Environmental
and Social Factors/Risk Management System),
which stipulates the process of assessing and
managing ESG risks and impacts associated with
transactions, i.e. financing NLB Group clients. By this,
NLB Group identifies and assesses environmental,
social, including human rights, matters connected
with its clients.
Scope: NLB Group banking members. The policies
are binding for all NLB Group banking members.
Most senior level accountable: Directors of risk and
sales departments in each NLB Group member.
Availability: For employees in the Internal Acts
Register, while some financing principles are
included in the Sustainability Policy publicly
available on the NLB website.
NLB Group’s approach to human rights as financing
provider
As stipulated in the Policy on respect for human rights
and followed in daily operations, NLB Group indirectly
contribute to respecting human rights related to
communities by not directly financing activities that are
known to contain elements of human rights abuses and/
or where such abuses exist. However, if human rights
abuses are identified in existing clients operations,
NLB Group members cooperate with clients to adopt
appropriate measures to end such practices and
prevent further abuses in the future.
NLB Group expects its clients to comply with all
applicable human rights laws and standards and strive
to uphold them as set out in the Universal Declaration of
Human Rights and, where local legislation does not
meet these standards, at minimum:
- identify and manage human rights risks.
- review potential human rights impacts.
- avoid causing or contributing to human rights
violations.
- assess potential human rights risks in their supply
chains and use their influence to address human
rights violations by their suppliers and clients.
- engage with their stakeholders and provide access
to remedy where necessary.

To this end, respect for human rights is part of the
due diligence process before signing a contract with
a client. Human rights considerations are included in
NLB Group’s ESMS system and ESG questionnaires
that serve as a data-gathering and assessment tool
for clients with larger and high environmental or
social risk. Beside environmental and governance
data, clients must provide social and human rights
data: an explanation of whether a client has put in
place policies and measures relating to the social
aspects of operations in the areas of human rights,
equal opportunities / non-discriminatory practice,
encouragement of staff diversity, health and safety at
work, child labour illegal work, and modern slavery
prevention, ethical business conduct, employee
relations / labour standards, whistle-blowing
mechanisms, the company’s impact on the community/
society, programmes to support local communities,
information on social aspects in the client’s supply
chain, mitigation of social and human rights risks, etc.
In addition, NLB Group in the document Manual
Environmental & Social Industry Categorization by NACE
and SKD Codes in NLB d.d. and NLB Group describes
risk assessment that was prepared to better understand
clients' environmental and social risks. Assessment is
divided in four categories, including Health and Safety,
Labour and Community, which includes also human
rights risks.

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NLB Group considers consumer rights as one of
important components of human rights, which is
intertwined with responsible client relations. For
details on that please refer to the S4 – End users and
Consumer chapter.
Policy Sponsorships and Donations Policy in
NLB d. d. and NLB Group
Content and purpose: This Policy defines the
framework for sponsorships and donations in
NLB Group members. Its purpose is to ensure
that all activities in this area are aligned with the
Group’s business objectives, values, and socially
responsible approach. The aim of this Policy is
to promote positive changes in the community
and to strengthen the Group’s reputation. It
defines rules and procedures for managing
sponsorships, donations, and relations with NLB
Group's stakeholders across 6 pillars: Increasing
financial literacy and mentoring; Environmental
responsibility; Sustainable entrepreneurship;
Supporting professional, youth, and para sports;
Humanitarian activities; Culture and protection of
cultural heritage.
Scope: NLB Group banking members
Most senior level accountable: Directors of
marketing, brand, and communication departments
in each NLB Group member.
Availability: For employees in the Internal Acts
Register, while financing principles are included in
the Sustainability Policy publicly available on the
NLB website.
NLB Group’s approach to human rights as a
sponsorship and donation provider:
NLB Group actively monitors the operations of the
organizations it supports by tracking their activities,
maintaining an open dialogue, and observing
their media presence. The Group’s sponsorees and
beneficiaries are contractually obligated to align with
the Sustainability Pillars (ESG) and the UN Sustainable
Development Goals (UNSDG). Sponsorship applications
are managed by the Social Responsibility and Corporate
Communication department, and after an initial review,
promising proposals are forwarded to the Sponsorship
Committee for a final decision.
In contract negotiations, the Group strives to adapt
to the needs of its stakeholders, actively listening and
working together to achieve mutual goals, ensuring
that both our objectives and those of our partners
are met. In 2025, NLB Group will enhance its formal
due diligence process, incorporating human rights
compliance checks to assess the suitability of donation
and sponsorship recipients.
In general, NLB Group members engage in several
ways with communities that are affected in respect
of human rights by its financing and sponsorships.
The Group provides the open door and speak up
policy through various communication channels, and
grievance mechanisms are in place that enable affected
communities to offer opinions, ideas, or raise concerns,
which are described in detail in the chapter Governance.
The Group also strives to increase the understanding of
human rights topics in employee training and promote
them in relationships with clients and applicants for
sponsorships and donations. In addition to due diligence
mechanisms, the Group monitors human-rights-related
impacts, risks, and opportunities that could stem
from financing, sponsorships, and donations in public
debates and in the media. If deviations or opportunities
are detected, we engage with the clients and relevant
institutions and organizations in the community to
address them appropriately.
In 2024, NLB Group identified one potential human rights
violation related to working conditions among its clients.
No concerns or incidents were detected or reported that
could impact communities through sponsorships and
donations. NLB Group engages with all stakeholders
and offers access to remedies for potential negative
human rights impacts: these processes will be further
integrated into our due diligence processes for
sponsorships and donations.
As presented in this chapter, NLB Group identifies
human rights incidents through due diligence
on corporate clients during procurement and, to
some extent, among recipients of sponsorships
and donations. Additionally, in alignment with its
Environmental and Social Management System
(ESMS), NLB Group has implemented an Early Warning
System (EWS), managed by Credit Risk, to detect
environmental or social incidents, including human
rights violations such as modern slavery, child labour,
worker fatalities, and labour inspections. In 2024, NLB
Group did not detect any severe human rights issues or
incidents involving affected communities, employees, or
procurement activities.
Table 50: Human rights incidents related to financing,
sponsorships, and donations
2024
2023
Human rights incidents detected – clients
1
4
Human rights incidents detected –
applicants/sponsorships and donations
0
0
Human rights violations confirmed
0
0

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S3-2 Processes for
engaging with
affected communities
about impacts

NLB Group engages with affected communities on
multiple levels. When financing local communities,
such as municipalities, the engagement is conducted
indirectly through the clients’ legitimate representatives.
For other financing, especially projects that impact the
community and are classified as Type A or D (based on
environmental and social impact according to EBRD
classification), additional due diligence and special
criteria are applied.
According to internal policies, all financing undergoes
a thorough due diligence process to ensure that
environmental and social criteria are fully met. These
criteria must be satisfied by all candidates seeking
funding. The bank’s final approval of funding is based
on a comprehensive review of all documentation and
analysis. The most senior roles responsible for ensuring
this engagement are the heads and directors of sales
departments within NLB Group members.
In sponsorships and donations, cooperation is
maintained through legitimate representatives of
the partners, i.e. the recipients of such financing. This
cooperation occurs regularly, with some interactions
happening daily and at least monthly. The most
senior role responsible for ensuring this engagement
is the Head of Brand and Communication at NLB.
Sponsorships are evaluated, and based on the results,
we determine further actions. At the same time, the
Group listens to all partners and tries to assist in
implementing their activities, if possible. Significant
examples include:
• Organizing expert lectures at the NLB Sports
Academy for clubs that are part of NLB Sport for Youth
across the region and all clubs in Slovenia under
disciplines supported by NLB at the national level.
• Providing free NLB premises for press conferences or
internal needs.
• Assisting in organizing the NLB Wheel League,
including developing the league in areas where
NLB operates.
NLB Group is committed to respecting human rights
and treating all its clients and communities equally,
in accordance with internal policies and generally
accepted principles such as Policy on Respect for
Human Rights in NLB d.d. and the NLB Group or NLB
Group Code of Conduct. However, it pays special
attention to ensuring that the needs of the most
vulnerable within the community are not overlooked. For
example, NLB Group supports the Special Olympics,
NLB Wheel, and Sitting Volleyball, which are designed
for people with disabilities.
NLB Group strives for active engagement and dialogue
with communities that are indirectly affected either
by its financing or sponsorships and donations. To
this end, the Group’s representatives in all markets
monitor the economic and social situation and conduct
occasional meetings with clients, local governments and
municipalities, and organizations and institutions in local
communities to discuss the needs, impacts, risks, and
opportunities. The Group will proceed with the activities
that are already in place, continue and improve the
dialogue and collaboration practices, and consider
upgrading and formalizing the engagement processes
in the future.
S3-3 Processes to
remediate negative
impacts and
channels for affected
communities to raise
concerns

The DMA found no material negative impacts or risks
on communities from financing. However, NLB Group
acknowledges that some financed activities may
pose environmental, social, and governance risks.
Similarly, no material negative impacts were found
fromsponsorships and donations, but stakeholders or
the wider community may still have concerns.
To this end, NLB Group banking members have
established several channels for all stakeholders,
including affected communities, to raise concerns.
The overall approach, including availability of
these channels and mechanisms for identifying and
investigating, is described in the chapter G1-Business
Conduct.
In 2024, the Group did not record any complaints
regarding negative impacts on the communities of its
financing activities or its sponsorship and donation
activities or any other sustainability matters through the
grievance mechanism or any other channels.
S3-4 / S3-5 Key
actions and targets

The DMA did not identify any material negative impacts
stemming from NLB Group’s financing, sponsorships,
and donations. The general description of the Group’s
due diligence approach and mechanisms to address
potential and actual risks, negative impacts, and
provide remedies are described in previous sections of
this chapter.
On the other hand, NLB Group’s financing, sponsorships,
and donations have several material positive impacts.
Actions, initiatives, and related targets that NLB Group
has developed and implemented to provide and
enhance its positive impacts are summarized below.
NLB Group members do not have special measures in
place to engage directly with affected communities in
setting targets, tracking performance, or identifying
lessons or improvements as result of the Group’s
financing, sponsorships, and donations. This
engagement is performed indirectly through relationship
with clients, and institutions and organizations that NLB
Group directly collaborates with.
The effectiveness of actions regarding financing
community and economic activities is tracked regularly
and reported monthly to the Management Board and
quarterly to the Sustainability Committee. Sponsorship
and donation activities are regularly monitored, and
for all key implemented sponsorships and donations,
reports and project evaluations are prepared in the
marketing or communication departments. The overall
breakdown by UN SDGs is reported annually at the
Sustainability Committee sessions.

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Financing community and
economic development
The general objective is to provide financing for the
community and economic development in line with
annual plans and opportunities.
In 2024, NLB Group banking members financed
community and economic development through various
projects. Significant projects exceeding EUR 5 million
amounted to EUR 138,350 million, including green
financing. For example, such projects include financing
electricity generation from wind power and renewable
energy projects – investments in electrodistribution grids.
Sponsorships and
donations
In relation to sponsorships and donations NLB Group
has set the following general objectives:
• To provide financial contributions in line with annual
plans, needs, and opportunities, and in compliance
with the sponsorships and donations policy.
• To ensure that annually each CSR activity contributes
to at least one UN Sustainable Development Goal.
• To leverage the indirect positive impact by including
a special sustainability clause in each sponsorship
contract by the end of 2025. The clause will require
specific and mutually agreed actions of applicants
to enhance their positive impact on society and the
environment. At the end of 2024, the majority of all
sponsorship contracts concluded by NLB Group
members included the special sustainability clause.

Donations are typically received by communities facing a
crisis (for example, the floods in Bosnia and Herzegovina
in 2024) or institutions addressing a significant, possibly
long-term, social issue (for example: Association of
Interpreters for Slovenian Sign Language Institute,
Red Cross Slovenia) and cultural heritage (Institute for
Cultural Heritage – MUZA). Sponsorships are directed
toward communities where we can promote growth
and development across various fields (sport - Sport
for Youth, culture - Festival Ljubljana, entrepreneurship
– Help Frame, health – Supporting Healthy Recreation –
self-service bicycles rental, education – AmCham Hero)
and targeting specific groups, for example youth.
›› For additional information on the most significant
projects, see the chapter Overview of significant
sponsorships and donations by type.
Table 51: General objectives and progress related to sponsorships and donations
2024
2023
Donations (in EUR thousands)
2,187
12,008
In 2023 several donations were made for
flood relief after catastrophic floods in Slovenia
(above the regular donation plan)
Number of projects
436
300
Increasing financial literacy and mentoring, Environmental
responsibilit, Sustainable entrepreneurship, Supporting
professional, youth and para sports, Humanitarian activities,
Culture and protection of cultural heritage
Share of projects contributing
to at least one UN SDG
99.7%
97%
Notes:
(i) Data refers to all NLB Group members.
(ii) Accountancy policy and reconciliation: Reported values for donations refers to the financial statements notes 4.8 Other operating income and
expenses – Donations.
Table 52: Sponsorship and donations in NLB Group banking members – breakdown by contribution to UN SDGs, N= 436
UN SDG
Share of projects contributing
to the particular
1 UN SDG
3
GOOD HEALTH
AND WELL-BEING
Good health and well-being
63.68%
11
SUSTAINABLE CITIES
AND COMMUNITIES
Sustainable cities and communities
11.49%
13
CLIMATE
ACTION
Climate action
6.52%
17
PARTNERSHIP
FOR THE GOALS
Partnerships for the goals
5.73%
4
QUALITY
EDUCATION
Quality education
4.27%
15
LIFE
ON LAND
Life on land
2.47%
10
REDUCED
INEQUALITIES
Reduced inequalities
1.46%
8
DECENT WORK AND
ECONOMIC GROWTH
Decent work and economic growth
1.36%
5
GENDER
EQUALITY
Gender equality
0.92%
2
ZERO
HUNGER
Zero hunger
0.68%
Not supporting any UN SDG
0.32%
16
PEACE, JUSTICE
AND STRONG
INSTITUTIONS
Peace, justice, and strong institutions
0.31%
1
NO
POVERTY
No poverty
0.25%
6
CLEAN WATER
AND SANITATION
Clean water and sanitation
0.24%
7
AFFORDABLE AND
CLEAN ENERGY
Affordable and clean energy
0.17%
14
LIFE
BELOW WATER
Life below water
0.12%
Total
100%

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Environmental responsibility
We continue to create and support a variety of initiatives that aim to reduce carbon footprint, combat climate change, and increase positive impacts on the
environment. We also empower our stakeholders to raise their awareness and engage them in such initiatives.

Goal 13 – Climate action
Goal 15 – Life on land
NLB, Ljubljana
• The Bank continued the partnership as a Green Partner of the GLWF (Green Light World Flight) project, led by Slovenian aviator and climate change
researcher Matevž Lenarčič and Prof. Dr. Griša Močnik. Thus, we support and enable measurements of black carbon, in addition to carbon dioxide,
The combined measurements serve as input and validation data for regional models of climate change and the dispersion of pollutants.
• We continued with renovation of Kredarica hut on Triglav, the highest mountain in Slovenia. Complete renovation
of the solar power plant in 2023 was followed by the energy renovation of the roof in 2024.
• The Bank continued the long-lasting partnership encouraging sustainable mobility in the second largest Slovenian city, which enlarged the network to 230 city bikes.
• The Bank supports the Beekeeping Association with general sponsorship and with a significant donation towards the revival of the Anton Janša Beekeeping School.
• In cooperation with Beekeeping Association, NLB planted 2,500 trees in the region.
NLB Banka, Banja Luka
• The bank supported the Balkan Solar Summit, which is dedicated to the promotion and development of renewable energy in the region.
NLB Banka, Sarajevo
• The Bank supported the Festival of Ecology and Peace in Zenica. Over 300 people (children and their parents) were present at the Festival.
NLB Komercijalna
banka, Beograd
• Forests of Food – The Bank financed the planting of three permaculture orchards in agriculture schools in Serbia
where current and future generations of students can learn about sustainable agriculture.
Overview of significant sponsorships and donations by type
13
CLIMATE
ACTION
15
LIFE
ON LAND
Increasing financial literacy and mentoring
At NLB Group, we are dedicated to counselling in the field of financial literacy for various stakeholders, reducing inequalities and improving education.

Goal 4 – Quality education
Goal 10 – Reducing inequalities
NLB, Ljubljana
• NLB Muza, the banking museum of Slovenia, which is also a financial literacy centre, had 8,131 visitors in 2024. The museum includes
walking through six stages of personal finance management, visitors can play digital games and take quizzes, and learn or check their
financial literacy in a fun way. The centre is widely accepted and enjoyed by school groups (2,688 pupils have visited it).
• NLB Muza organized the temporary exhibition "Money and Crime". The topic was banking crime throughout history, with
an emphasis on how to protect oneself from cybercrime. The exhibition was viewed by 2,000 visitors.
• The Bank continued the Minicity initiative, which has made significant strides in promoting financial literacy throughout 2024. Besides playful education in finance
in which 80,000 have children participated, the Bank empowered prenatal families with crucial financial knowledge at three special education events.
• Partnering with Simbioza, NLB delivered four digital financial literacy workshops specifically designed
for retirees, ensuring they navigate the financial landscape with confidence.
NLB Banka, Podgorica
• The Bank educated 100 children from clubs that are supported through the NLB Sports for Youth project
about communication and teamwork skills within the project Pobjednički koraci".
• The Bank also held financial literacy workshops, which were attended by about 500 children.
NLB Banka, Skopje
• The Bank donated funds for refurbishing a reading room within the library in National and University Library Sv Kliment Ohridski.
4
QUALITY
EDUCATION
10
REDUCED
INEQUALITIES

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Sustainable entrepreneurship
We create and support several initiatives that promote entrepreneurship, innovative thinking, economic growth, and inclusiveness

Goal 10 – Reduced inequalities
Goal 2 – Zero hunger
NLB Banka,
Banja Luka
• In cooperation with the National Theater of the Republic of Srpska, the Bank enabled the purchase of equipment that will enable
blind, visually impaired, and hearing-impaired citizens to watch certain performances in the theatre repertoire.
NLB Komercijalna
banka, Beograd
• Cepora donation – The Bank supported a project which includes six months of education for young people (school of business skills, school of
personal development, peer education for high school students, recycling for young people and/or the tour of the play "Missed Chance" which gives
an opportunity to young people without parental care to indicate their position in society in an inclusive and positive way. It directly affected.
• NLB supported the creation of a cafe (Zvuci srca cafe) in Pančevo, a place where people with developmental disabilities work and can be more included
in society. The café opened in September and provided jobs for 10 people with developmental disabilities. Additionally, an estimated 100,000 citizens
can visit the cafe, interact with its workers, and learn more about the pressing issues people with developmental disabilities face every day.
Supporting professional, youth, and para sports
We promote positive values of sport, through support of various sports associations, clubs, and young athletes, whose talent and sportsmanship are an inspiration for
all of society, and contribute in particular to good health and well-being.

Goal 3 – Good health and well-being
Goal 5 – Gender equality
Goal 10 – Reduced inequalities
NLB, Ljubljana
• In the 2024/2025 season the Bank is supporting 69 sport clubs within the NLB Sport for Youth programme.
More than 11,000 children aged from 6 to 14 years have participated.
• Within the traditional NLB Sports Academy project, the Bank carried out 4 academies with more than 100 participants from Sport for Youth club representatives.
• As part of the NLB Wheel project, the Bank donated two sports wheelchairs for disabled athletes – basketball players.
• NLB helped the organization Special Olympics – a worldwide programme defined as a special sports and cultural programme for people with
intellectual disabilities. The result is the preservation of psychophysical abilities and general socialization of persons with intellectual disabilities.
NLB Banka, Sarajevo
• The Bank supported various sports activities via sports clubs. In addition, the Bank sponsored a basketball camp, which
promoted healthy living, transferring the knowledge of professionals to young generations (over 130 children).
NLB Banka, Skopje
• The Bank executed the Grassroot Sports Activities project (over 1000 children), and implemented the Special Olympics Macedonia "Young Athletes" programme
for the cities of Kumanovo and Makedonski Brod. The programme is intended for children with and without intellectual disabilities, aiming to enable the
development of children’s motor and social skills through sport and sports activities. The Bank also sponsored the Macedonian delegation in this competition.
NLB Komercijalna
banka, Beograd
• The bank supported 4 sports clubs (over 370 youngsters) in the region.
NLB Banka, Prishtina
• The Bank supported different sport clubs around Kosovo. The largest initiatives are sponsorship of Handball Federation of Kosovo,
the women’s league with 61 teams, and of the country’s most successful women’s handball club KHF Istog.
NLB Banka, Podgorica
• The Bank supported the campaign "Prava priča" and celebrated Pink October – 111 female colleagues underwent a preventive breast examination.
3
GOOD HEALTH
AND WELL-BEING
5
GENDER
EQUALITY
10
REDUCED
INEQUALITIES
Humanitarian activities
We contribute to society through philanthropy, charity, and volunteerism. These initiatives are particularly aimed at socially disadvantaged groups of citizens or
people in need due to various reasons and circumstances.

Goal 3 – Good health and well-being
Goal 5 – Gender equality
Goal 10 – Reduced inequalities
Goal 13 – Climate action
NLB Group
• Donations with a total value of EUR 1 million in all markets of our operations in the home region. Our donation helped with flood relief in Bosnia.
NLB, Ljubljana
• Donation to the Red Cross with the aim of supporting the implementation of a camp for young leaders and assistance in training young promoters of blood donation.
NLB Banka, Banja Luka
• The Bank supported the Brave Hearts with Love organization, which helps people suffering from various diseases and disabilities. The
organization has a a solidarity fund, which provides financial support for children who need medical treatment abroad.
NLB Banka, Prishtina
• The Bank continued to cover the costs of education and summer camp for vulnerable children, including
children without parental care or at risk of abandonment, in the Pristina region.
• The Bank also supported the humanitarian event Let's Dance for more than 130 mothers and children. The mission of this initiative is to
help mothers and children who need support, and ensuring access to quality healthcare for mothers and children in Kosovo.
NLB Banka, Skopje
• The Bank contributed to the procurement of a medical device for an interclinic transport system for respiratory
therapy for newborns for PHI University Clinic for Gynaecology and Obstetrics.
13
CLIMATE
ACTION
3
GOOD HEALTH
AND WELL-BEING
5
GENDER
EQUALITY
10
REDUCED
INEQUALITIES
10
REDUCED
INEQUALITIES
2
ZERO
HUNGER

Through digitalisation and
innovation, clients can access our
products and services anytime
and anywhere, with the added
benefit of 24/7 personal support
from our experts in the NLB
Contact Centre, who have been
providing knowledge and advice
for more than 30 years.
We put our clients
first in every way.

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The relationship with clients11 and maintaining their
trust is at the heart of NLB Group's business model.
With more than 2.9 million clients, NLB Group is one
of the leading financial groups in the SEE region. NLB
Group prioritizes a client-centric approach, focusing
on providing quality financial products and services
enhancing customer experience, efficient delivery, and
regulatory compliance. Regulatory adherence fosters
trust, safeguards the financial system, and reinforces
NLB Group's reputation.
As stipulated in the Sustainability Policy, NLB Group’s
relations with clients are underlined with the following:
• offer products adapted to clients’ needs, with
marketing policies reviewed by specific committees,
i.e. the committee for new and existing products in
NLB and equivalent committees in other NLB Group
members
• ensure that the marketing and sale of products and
related communications are performed regularly,
in compliance with all applicable regulations,
standards, and best practice in the financial industry
• deliver quality and value to clients, consistently and
reliably, to promote excellence in service quality, and
optimizing the client experience, measured by NPS
(Net Promotor Score)
• improve client experience and business performance
by comprehensive implementation of complaint
management into the overall client experience process
• protect the confidentiality and privacy of client data
and use them in a responsible manner
• provide information to clients in compliance with
regulations so that it is considered impartial, clear,
and never misleading, by using the appropriate
communication channels to clients
• implement digital products and channels which
enable better access to banking services and
promoting financial inclusion
• improve physical and technological accessibility to
the services of all NLB Group members for all people,
focusing on people with disabilities
• uphold the highest standards of cyber- and physical
security and therefore promote practices that
maximize the security of its products and services
• provide channels to clients which enable them to
raise questions and concerns and receive a timely
and qualitative response
• provide client education on sustainability matters

The overarching internal acts defining general
framework and main principles for managing IROs
related to the Group clients are Code of Conduct,
and Sustainability Policy. In addition, the Group has
established specific policies, processes and actions that
address material IROs and related sustainability topics,
which are presented in the following chapters.
The Group measures the effectiveness and progress of
its material sustainability-related policies, processes
and actions within departments that are responsible
for particular sustainability topic or IRO which report
to the management boards of NLB Group members at
least once a year or whenever important topic should
be addressed or decision taken and at least quarterly at
the Sustainability Committee session.
Disclosures and underlying DMA span across five
sustainability topics (see the detailed overview of IROs in
the table on the next page). Unless specified otherwise,
they relate to all clients, including private individuals,
micro, SME and large corporate clients using the Group’s
financing and investments products.
Several material positive (actual and potential) impacts
were identified across the downstream value chain and
in the Group's own operations.
The only potential negative impact arises from situations
where inadequate or inaccurate information might
be provided to a client, regardless of the client group.
Actual and potential cyberattacks represent a significant
risk in the whole financial industry, including NLB Group.
The organizational units responsible for managing
IROs, have set specific targets (where applicable) and
KPIs, which are used for internal monitoring purposes.
Clients are included in target setting indirectly, through
expressing their general opinions in research, pools, and
in direct communications, informing target setting and
overall business strategy alongside inputs from market
and other relevant research.
Human rights commitments related to clients
NLB Group policies regarding clients are embedded in
the overarching NLB Group Policy on Respect of Human
rights, which follows the Universal Declaration of Human
Rights and other internationally recognized frameworks
(see the policy description in the S1 chapter as it refers
also to clients).
As stipulated in the policy, NLB Group members do not
offer products and services that could have a negative
impact on human rights. This is ensured through due
diligence assessment and monitoring process in the
Group’s lending policy and throughout the product life-
cycle or during the timeframe of a contract. In addition,
NLB Group’s policies related to client relations are
intertwined with human rights commitments that we
follow in client relationships. For example, we consider
that the client’s right for inclusion and access to financial
services, non-discrimination, providing accurate
and timely information, financial health and literacy,
personal safety and privacy are strongly connected with
client’s human rights.
In 2024, no cases of non-compliance with the UN
Guiding Principles on Business and Human Rights,
ILO Declaration on Fundamental Principles and
Rights at Work, or OECD Guidelines for Multinational
Enterprises or human rights incidents related to clients
were reported.
S4 Consumers and End-users

SBM3 Material impacts, risks, and opportunities, and their interaction
with strategy and business model
11 NLB Group defines ESRS-term consumers and end users as clients or customers.

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Statement
Financial
Report
Table 53: NLB Group’s material actual and potential impacts on its communities mapped to material sustainability topics
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in the
value chain
Time horizon
Digitalization and
innovation
Innovative tools and
solutions enabling
sustainable consumer
behaviour
Introducing new products and services that allow for monitoring
of financial data, sustainable finance options, tracking
personal carbon footprint, energy saving tips, etc.
Impact – Potential
Positive impact
Downstream
Short-term
Digital solutions
for easier access to
banking services
Digital solutions for easier access to banking services enhance customer
convenience and streamline transactions. By implementing online platforms and
mobile applications, banks can improve user experience, reduce operational
costs, and reach a broader audience, ultimately driving customer engagement
and satisfaction while adapting to evolving consumer preferences.
Opportunity
Downstream
Short-,
Medium-,
Long-Term
Cybersecurity
Cybersecurity risks
Cybersecurity risks, particularly regarding the protection of employee and
customer data, can significantly impact a Group's financial performance through
potential data breaches that lead to costly remediation efforts, regulatory fines,
and litigation, as well as reputational damage that erodes customer trust and
confidence, ultimately resulting in loss of business and diminished market value.
Risk
Downstream
Short-,
Medium-,
Long-Term
Protection of client data
Protection of client data is essential for maintaining the privacy and trust of
customers and clients. Ensuring that client data is secure helps to prevent
unauthorized access and potential misuse, which could lead to financial loss.
Impact – Actual
Positive impact
Downstream
Short-term
Financial health
and inclusion
Contributing to financial
health of customers
Through various banking services and information, NLB Group is
contributing to the financial health of customers, which positively
impacts their stability and well-being by providing them with the
necessary tools and support to manage their finances effectively.
Impact – Actual
Positive impact
Downstream
Short-term
Enabling digital solutions
for easier access to
banking services
Enabling digital solutions for easier access to banking services
improves convenience and accessibility for all customers,
fostering greater financial inclusion and user satisfaction.
Impact – Actual
Positive impact
Downstream
Short-term
Maintaining a network of
physical banking offices
Maintaining a network of physical banking offices ensures that customers,
especially those who may not be comfortable with or have access to digital
banking, can still access banking services, improving overall service accessibility.
Impact – Actual
Positive impact
Downstream
Short-term
Service quality and
customer satisfaction
Ensuring quality of
services and client
satisfaction
Ensuring quality of services and client satisfaction leads
to positive outcomes by enhancing customer loyalty, trust,
and overall satisfaction with the Group's offerings.
Impact – Actual
Positive impact
Downstream
Short-term
Responsible marketing
and communication
Promoting financial
literacy
Promoting financial literacy enhances customers' financial understanding
and decision-making, empowering them to manage their finances better.
Impact – Actual
Positive impact
Downstream
Short-term
Provision of quality
information to clients
Provision of quality information to clients ensures that they have
access to accurate, timely, and useful information, leading to
better financial decisions and enhanced trust in the Group.
Impact – Actual
Positive impact
Downstream
Short-term
Providing inadequate
or inaccurate
information to clients
Providing inadequate or inaccurate information to clients
can lead to misunderstandings and poor financial decisions,
damaging the trust between the Bank and its customers.
Impact – Potential
Negative impact
Downstream
Medium-
term
Ensuring responsible
marketing practices
Ensuring responsible marketing practices has a positive
impact by promoting truthful and ethical communication with
consumers, building trust and safeguarding their interests.
Impact – Actual
Positive impact
Downstream
Short-term

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Digitalization and
Innovation
Digitalization is a key strategic priority for NLB Group,
driving growth by streamlining processes, enhancing
scalability, and boosting efficiency. In recent years, NLB
has been a pioneer of banking innovation in Slovenia
and introduced various advanced digital services and
channels, including 24/7 opening of personal accounts
and the full digital signing of documents in digital bank,
videocall functionalities with multichannel 24/7 support,
fully E2E digital loan capabilities for consumers & SMEs,
sending PINs for cards via SMS, implementing Flik P2M
(Person to Merchant) at all POS (Point of Sale), the NLB
Smart POS solution on mobile phone to merchants, card
management functionalities and biometric recognition,
and issuing digital-only debit cards.
The Group continues to prioritize digital innovation, by
enhancing its technological infrastructure to deliver
excellent client experience and maintain a competitive
edge. By rapidly expanding digital channels across the
region the Group reduces branch activities for routine
tasks, enhances client satisfaction, streamlines internal
processes, and supports paper usage reduction.
Therefore, NLB Group is committed to growth by
leveraging digital marketing channels and enhancing
connectivity, and developing innovative tools, while
maintaining adequate personal interaction with clients.
In addition to banks, digital channels are integrated into
the operations of asset management companies (within
the NLB Klik application) and leasing companies (almost
80% of all leasing contracts are concluded with the
NLB Lease&Go application).
Policies
Digital transition is firmly embedded in the new NLB
Group Horizon 2030 Strategy. The strategy focuses
on growth across three pillars: Retail, Corporate
and Investment Banking, and Payments, supported
by operating platform enhancement initiatives.
Transitioning to a fully digital business model is a
key focus, including offering users advanced digital
solutions (Klik, NLB Pay), modernizing digital processes
in the Bank, and setting up a central IT hub.
The policies related to digital solutions for clients are
included in overarching product development and
cybersecurity policies, which are described in detail in
respective chapters. In addition, specific instructions
and guidelines have been established for each digital
channel, providing regulatory compliance, efficient
internal processes, and delivery to the clients.
Key activities and progress
In 2024, NLB Group banking members saw the following
improvements:
• launched in 2023, NLB’s new digital banking platform
(NLB Klik) was recognized in 2024 as the Best Digital
Banking Solution in Slovenia by an independent
research agency. Itsimplementation across all
NLB Group markets is underway and will be
concluded in the coming years
• new digital bank launch in NLB Banka Sarajevo,
NLB Banka Banja Luka, NLB Banka Podgorica
• launch of digital sales processes in NLB (savings
accounts, deposits, account overdraft, credit card
limit, ordering a new credit card); NLB Banka Prishtina
(consumer loan), NLB Banka Skopje (consumer loan)
• strong focus on digitalizing clients across all markets
and ongoing best practice sharing among NLB Group
members to enhance digital penetration and channel
utilization
• several awareness-raising activities among clients in
under-digitalized clients, in particular the elderly.
See the chapter Sponsorships and donations for
details.
• in asset management (NLB Skladi):
- introduction of the electronic confirmation of
invoices and application for online monitoring of
the realization of daily activities in an individual
process (according to delimitations and carriers)
- the overview of customer transactions within
the asset management company has been
further extended within the NLB Klik application
(including umbrella fund investors and clients
engaged in portfolio management)
• In leasing companies: NLB Lease&Go continued its
journey towards digitalization and creating the core
for changing the business model towards more a
customer-centric and service-driven focus around
mobility. The most important milestone was acquiring
the platform doberavto.si portal. The acquisition is
in line with NLB's strategic ambition and is needed
to safeguard its market position in an increasingly
digital car market. The platform integrates value-
added services such as financing options, vehicle
insurance, and inspection services, offering users a
one-stop platform for all their automotive needs.

Going forward, the Group will intensify its focus on
digitalizing banking processes and clients, and further
enhance digital accessibility solutions. Additionally, the
Group will prioritize digital security and fraud prevention
by implementing advanced security measures to ensure
the highest levels of protection and client satisfaction.
Impacts, risks, and opportunity management

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Targets and metrics
In alignment with its strategic objectives and the UNEP
FI Principles for Responsible Banking, NLB Group set a
digital penetration target in 2021 to achieve 55% active
digital banking adoption (web or mobile) among private
individuals by 2025, and 80% by 2030. The 2025 target
was surpassed in 2024 by 1.4 percentage points.
In 2024, the Group increased the previously set digital
penetration target from 70% to 80% and the additional
goals were set related to digital penetration and
acquisition as detailed in the table below. The target
setting relied on market and client research and was
embedded in the process of the development of NLB
Group New Horizons 2030 strategy.
Cybersecurity
and personal data
protection
As in any financial institution, cybersecurity risks, if not
mitigated well, particularly regarding the protection of
customer personal data, can significantly impact the
Group's financial performance through potential data
breaches that may lead to costly remediation efforts,
regulatory fines, and litigation, as well as reputational
damage that erodes customer trust and confidence,
ultimately resulting in loss of business and diminished
market value. Protection of client data is therefore
essential for maintaining the privacy and trust of clients.
NLB Group has a positive impact on clients as it has
established policies and mechanisms to ensure that
client data is secure by preventing unauthorized access
and potential misuse, which could lead to financial loss.
Moreover, collecting and processing some personal data
allows the Group to adapt clients’ needs, to provide more
effective communication and a better user experience.
While information and cybersecurity policies are
presented in the chapter S1-Own workforce, this chapter
focuses on the data protection policy.
Policies
Rules on the Protection of Personal Data
Content and purpose: The Rules regulate the area
of personal data protection, including organizational
structure and allocation of tasks and the basic
rules of personal data. The purpose of the Rules is
to define the fundamental principles and rules in
relation to the processing of personal data and the
rights of the data subjects with the aim of ensuring
compliance with the legislation applicable in the area
of personal data protection. These include European
legislation on the General Data Protection Regulation
(GDPR) and the Slovenian legislation applicable in
the area of personal data protection – Personal Data
Protection Act (ZVOP-2). In line with the Policy, the
provisions are integrated into the Group’s processes
and systems, including those related to client data.
Scope: NLB and other NLB Group members who are
subject to the GDPR and their local legislation related
to data protection.
Most senior function accountable: the Management
Board and appointed Data Protection Officer
who professionally and independently assists the
management in ensuring that the processing of
personal data complies with the Rules
Availability: Employees access the Rules in the
Internal Act Register, while general information is
available for external stakeholders in branches and
on the websites, for example:
General Information on Personal Data Protection
Informacija o vastvu osebnih podatkov - NLB Skladi
NLB Lease&Go - Varstvo osebnih podatkov
Key activities and progress
The Group is focused on implementing measures to
increase the Group’s cyber resilience and strengthen
its digital capabilities. In 2024, key activities included
enhancing cyber threat intelligence, improving situational
awareness, and conducting penetration tests to assess
and bolster the resilience of information systems.

The Group also adheres to GDPR requirements in its daily
operations. In line with the Data Protection Policy, several
ongoing measures and activities are in place and were
also conducted in 2024:
• The DPO was responsible for monitoring compliance
with GDPR legislation and carrying out regular risk
assessments to identify and minimize personal data
breaches and compliance risk. The DPO reports to the
Operational Risk Committee and to the Management
Board in the scope of quarterly reporting.
• Policies, rules, standards, and procedures for personal
data and information protection (e.g. business secrets)
are used in the Group’s everyday operations in the
area of data protection. Thus, the Group ensures
compliance with the relevant regulatory provisions
that can differ significantly from one country to
another.
• Preventive measures and thorough control within the
Group and in relation to outsourced providers and
suppliers help prevent the loss or abuse of data and
the violation of data protection regulations, including
the protection of personal data.
• Information on protecting client privacy was provided
on the Bank’s website. The information includes
reasons for collecting the data and their usage, clients’
rights and how to enforce them, contact details of the
Data Protection Officer to report any violations.
• Mandatory training on personal data protection was
conducted for all employees (it constitutes a work
obligation).

›› For a detailed description of activities and progress,
please see the Business Report, chapter IT and
Cybersecurity, and the chapter Compliance and Integrity,
sub-chapters Information security and personal data
protection.
Table 54: Digital banking usage in NLB Group banking members
2021
Baseline
2023
2024 Target
2025
Target
2030
Digital
penetration(i)
29.5%
50.4%
56.4%
55%
80 %
Digital core
product sales

2-6%
>50%
Digital
acquisition
<1%
>30%
(i) The digital penetration is calculated as number of active digital banking
users – private individuals divided by the total number of private individuals.

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Financial health
and inclusion
Policies
On a high level, the principles of financial health and
inclusion are included in the Sustainability Policy, and
indirectly in all policies and other internal acts on client-
related products, services, and relationships. For NLB
Group, financial inclusion is about ensuring access to
financial products and services and "leaving no-one
behind". Although there is no specific policy in place
addressing financial health and inclusion exclusively,
these are embedded in the Group’s business model and
process by following the Group’s core value of improving
lives and the central principles of the 2030 Agenda for
Sustainable Development, in particular two SDGs:
• 8 – Decent work and economic growth (Strengthen
the capacity of domestic financial institutions to
encourage and expand access to banking, insurance,
and financial services for all), and
• 10 – reduce inequality (By 2030, empower and
promote the social, economic, and political inclusion
of all, irrespective of age, sex, disability, race,
ethnicity, origin, religion or economic or other status).

In addition, guided by the UNEP FI Principles for
Responsible Banking, NLB Group promotes universal
financial inclusion and in particular supports the
financial health and inclusion of its private individual
clients. These considerations are firmly embedded in the
NLB Group Policy on Respect for Human Rights, as well
as in policies and manuals and procedures that define
the sales process.
In terms of accessibility to banking services, which
was deemed as material impact in DMA, the Group
strategically balances the benefits and optimization
of its branch network. While branches remain central,
their role is evolving due to market changes and
digitalization, resulting in fewer in-branch transactions.
However, direct client contact in branches remains
crucial particularly for comprehensive services or
vulnerable groups. To mitigate potential negative
impacts, the Group continuously enhances both physical
and technological accessibility through our extensive
branch and ATM network, digital products and channels,
contact centres, email, website, and social media. This
includes accommodating people with disabilities and
promoting financial inclusion and literacy.
The Group also places great importance on managing
potential negative impacts, for example due to strategic
optimization of physical banking network in some areas
(not deemed as material in the conducted DMA). The
approach includes maintaining an adequate physical
network and appropriate communication about branch
closures with affected local communities and directly
with concerned clients via established communication
channels.
White Book for Branches
Content and purpose: The document describes
the critical role of branches in providing adequate
levels of physical accessibility and client experience.
It defines the standards and roles of branch offices
to ensure a modern, professional, and friendly client
experience. The aim is to increase sales and the
advisory role of the bank, improve client experience,
and support clients in transitioning to digital
channels and efficiency.
Scope: Distribution network, product and segment
managers, real estate managers in NLB Group.
The most senior function accountable: Director
of Customer, Product Management and Digital
Services or similar functions in NLB Group members.
In addition, the Group has established policies and
procedures to ensure employees, clients, and other
visitors in branches a high level of security and
measures to mitigate any security risks.
Availability: Register of Internal Acts.
Key activities and progress
NLB Group has implemented several activities to
enhance financial health and inclusion, financial literacy,
and accessibility to financial services, in particular to
vulnerable groups (impaired persons, women, older
persons, etc.). The most significant activities in 2024
were:
• Hearing loop devices in all NLB branches to enhance
communication and facilitate financial services for
hearing-impaired customers by transmitting sound
directly to their hearing aids.
• A mobile branch – a specially adapted vehicle, NLB
Bank&Go, that enables clients access to banking
services has been available to clients in smaller
Slovenian towns where there have been no bank
branches since 2020. In 2024, NLB Bank&Go regularly
visited 30 different locations.
• NLB continued its cooperation with the Association of
the Blind and Visually Impaired of Slovenia. 58 ATMs
throughout Slovenia have been installed to assist
blind and partially sighted persons with banking
operations. With the help of voice instructions through
headphones, blind and visually impaired persons can
withdraw cash or check their account balance.
• In North Macedonia, NLB Banka Skopje upgraded
the mClick mobile banking application with "built-in
voice reader" functionality, which clients should install
on their mobile phones. In this way, visually impaired
clients can have insight into all their accounts,
perform all banking transactions, or apply for a
mobile loan by using the voice guide, enabling them
to access financial services independently.
• In Kosovo, NLB Banka Prishtina and in Montenegro,
NLB Bank Podgorica run the Women in Business
programme in partnership with the EBRD. The
programme offers financial support and financial
education to women-led businesses.
• In Bosnia and Herzegovina, NLB Sarajevo
introduced the NLB Package for Financial Inclusion,
in accordance with the Decision on Measures to
Strengthen Financial Inclusion and Sustainable Bank
Operations adopted by the Agency for Banking in the
Federation of BiH.

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• Various sponsorships and donations programmes to
increase financial literacy were held in NLB (financial
literacy centre in the banking museum MUZA, Money
and Crime exhibition, financial literacy initiative for
families and children in Minicity, financial literacy
workshops for the elderly), and NLB Banka Skopje
(financial literacy workshops for children). See the
chapter Affected communities for details.With the
aim of promoting financial literacy, especially to
youth, NLB Funds organized several motivational-
educational events, published expert publications,
used social media, especially Instagram, and
participated in financial education events for youth,
organized by the national newspaper Finance.
In 2025, NLB Group will continue its initiatives, focusing
on implementing new Slovenian legislation transposing
the EU directive on digital accessibility effective June
2025. This will enhance accessibility and user experience
in NLB's digital banking channels for people with
disabilities (visual, motor, hearing, etc.). In Serbia, NLB
Komercijalna banka priority will be with developing
additional social/inclusion criteria in loan origination,
which will be followed by developing monitoring and
KPIs connected to social or inclusion loans.
Targets and metrics
In 2024, NLB Group reaffirmed its commitment to
financial literacy and inclusion by enhancing target
setting and further developing relevant initiatives. In line
with UNEP – FI methodology NLB, as the parent bank,
defined the baseline and set two concrete goals to be
achieved by 2030 for the impact area Financial Health
& Inclusion, which focuses on savings and investment
plans as a key priority area:
• By 2030 NLB will increase by 15% the percentage of
young clients (18–27 years) with products related to
long-term savings and/or investment plans.
• By 2030 NLB will increase by 15% the percentage
of clients aged 27+ up to retirement with products
related to long-term savings and/or investment plans.
Targets for other banks in the region will be developed
in the future. Also, the NLB Group will gradually develop
additional specific and meaningful targets for key
financial health and inclusion initiatives.
Table 55: Financial Health and Inclusion for NLB
2024
Baseline
Target
2030
Number of young clients (18–27 years)
with products related to long-term
savings and/or investment plans
29%
+15%
Number of clients aged 27+ up to retired
with products related to long-term
savings and/or investment plans
39%
+15%
Accountancy Policy and reconciliation: The percentage (share) is
calculated as the number of clients with at least 1 product related to a
long-term savings and/or investment plan in a particular age group
divided by the total number of customers. The number of such clients
represents a portion of 728,350, which is the total number of NLB clients
and represents a segment of total client base of NLB Group of 2.9
million, as detailed in the Business Report. (see Business Report, page
4).
Personal savings are crucial for long-term income
stability, especially for young clients. The foundations
for developing the targets were mostly the Slovenian
government’s 2017 Strategy for a Long-Lived Society
and data from the Pension and Disability Insurance
Institute of Slovenia (ZPIZ). The Strategy underscores the
importance of early pension savings to ensure financial
security in old age. Slovenia is experiencing significant
demographic changes, with the elderly population
expected to nearly double by 2060, from 17.3% in 2013
to 29.4%. This shift, coupled with a shrinking working-
age population, will strain the national pension system,
with expenditures projected to rise from 11.8% to 15.3% of
GDP by 2060. The ratio of contributors to pensioners will
worsen, threatening the system's financial sustainability.
Currently, many pensioners receive between EUR 700
and 800, below the poverty risk threshold of EUR 827,
indicating financial instability for nearly half of retirees.
Therefore, young Slovenians must prioritize personal
savings for retirement, as the national pension scheme
alone may not provide sufficient income.
Service quality and
client satisfaction
NLB Group develops and delivers quality financial
products and value to clients. Responsible product
development, marketing, and communication
significantly contribute to excellence in product and
service quality and enhances client experience and
satisfaction.
Responsible product
development
Policies
NLB Group members execute product development,
marketing activities, and provide information to clients
in compliance with regulations and local legislation
related to customer rights, guidelines, and codes of
professional associations. The general framework
related to products and services for clients is set at the
high level in the Code of Conduct and the Sustainability
Policy which is applied in all core financial members
(banks, asset management, and leasing companies). In
addition, various specific policies and guidelines have
been established, the most significant being related to
product development, data protection (see details in the
chapter Cybersecurity and personal data protection),
and marketing communication activities. Other internal
acts define specific areas, such as segmentation
and appropriate treatment of clients, the format and
the frequency of contacting clients, or receiving and
processing interactions in the contact centre.
NLB Group is bound to only offer products and services
that create value for our clients and shareholders, and
meet the client’s needs. The processes for approving
new products comprise a preliminary review required
for achieving these goals. NLB Group wishes to ensure
that clients can have full confidence in the products
offered to them. The procedures for approving products
and services apply to all new product offers, as well
as various existing products. The key control functions
must be involved in the process of product development
and monitoring, including the compliance function,
since it is important that every product is compliant
with regulatory requirements, particularly in the areas
of consumer protection, personal data protection,
and prevention of money laundering and financing of
terrorism.

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Policy for the Introduction of New Products and
Substantial Changes to Existing Products
Content and purpose: The Policy describes NLB
Group’s general approach to responsible product
development and defines the Bank's framework for
introducing new and significant changes to existing
products for private individuals and legal entities
and products for financial markets.
It is based on Slovenian and European legislation,
including the Banking Law, EBA, and ESMA
guidelines on product governance requirements. The
Policy also follows applicable national regulations
related to client loans, client protection, electronic
business and communication, and protection of
personal data. The purpose of the policy is to define:
1. the principles of introducing new products and
substantial changes to existing products
2. assessment factors for the introduction of new
products and significant changes to existing
products (before launching new or modified
products, NLB Group members analyse financial,
non-financial, compliance, legal, and capital/
liquidity impacts. Non-financial risk assessments
include evaluating ESG risks, defining mitigations,
and specifying ESG-related product features).
3. minimum standards of the organization when
introducing new products and significant changes of
existing products,
4. product discontinuation process
5. regulation of the area at the level of NLB Group
banks with the aim of taking into account the
interests, goals, and characteristics of consumers in
order to prevent in advance damage for the bank
and any damage that could occur to the consumer
and other customers of the Bank, as a result of the
behaviour and the conduct of the Bank's employees,
due to the composition of the product, its marketing,
or other procedures related to the product offer,
and to prevent a negative impact on the Bank's
reputation.
Scope: NLB Group banking members, mandatory for
all employees involved in product development.
Most senior function accountable: The Management
Board of each banking member oversees decisions
on new and existing products, delegating this to
the New and Existing Products Committee which is
established in each bank. This Committee reviews
new products and marketing policies before offering
them, to ensure that clients can have full confidence
in them. The highest level of accountability for policy
implementation are Directors of Customer Services,
Product Management, and Digital Services in each
NLB Group banking member.
Availability: Register of Internal Acts.
Key activities and progress
In 2024, NLB Group banking members introduced 46
new or substantially changed products and services,
while New and Existing Products Committees in NLB
have had 12 sessions, additional sessions were held in
other NLB Group members.
In addition, sales process and front-line staff support
was enhanced. ESG application API connection was
integrated into to loan origination process, which
enables entering green loan criteria into the core
system and transferring to DWH. A comprehensive sales
guideline related to green loans for private individuals
for front-line workers was introduced. They also
participated in green financing training, thus enhancing
their knowledge and skills, contributing to higher client
awareness and engagement for green products.
Going forward, NLB Group will focus on refining its
offerings, enhancing customer experience, further
streamlining internal processes and automatization of
the credit process, efficiently implementing sales tools,
and providing continuous training for front-line workers.
Responsible
communication
Policies
NLB Group manages material positive impacts related
to the provision of quality information to clients and
ensuring responsible marketing practices, as well as
potential negative impacts, i.e. provision of quality
information to clients on its policies, procedures, and
activities as described in this chapter.
Instructions for Implementing Marketing
Communication Activities of NLB Group
Content and purpose: The Instructions outline all
stages of the internal marketing and communication
process, aiming to standardize procedures and
eliminate inconsistencies or legal issues within NLB
Group's marketing and communication activities.
It is grounded in national legal, ethical, and
communication guidelines, as well as best practice in
marketing communication and public relations. The
Instructions emphasize compliance with legislation,
particularly the Consumer Protection Act, Code of
Advertising Practice, Advertising Law and Media
Law, and the Ethical Code of Designers to ensure
that activities within marketing plans consider their
impact on clients. The Instructions also stipulate
transparency and fairness and full communication
to the client by adhering to this instruction, NLB
Group aims to prevent and mitigate the risk of unfair
commercial practices in product marketing. As the
parent bank, NLB is a signatory to the commitment
to implement sustainability standards in advertising
(Slovenian Advertising Chamber) by 2030 or sooner.
These standards are gradually being implemented
in policies and procedures in all NLB Group
members.
Scope: NLB Group banking members.
Most senior function accountable: Directors of
Communication or similar functions in each NLB
Group banking member, while provisions apply to
all employees who are responsible for marketing
communication and external partners in these
processes.
Availability: Register of Internal Acts.

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Financial
Report
Key activities and progress
NLB Group members execute the following key activities
in their daily operations related to mitigating potential
negative impacts and to managing actual positive
impacts in relation to communication with clients:
• The Group offers clients financial products in
accordance with their needs and income profile, and
educate them about all of the aspects of a product,
including potential negative consequences and risks.
• By using a variety of communication channels, Group
members provide clients with impartial, transparent,
clear, and correct information, including clear and
ethical advertising industry.
• Communication complies with regulations related
to consumer rights, consumer protection in the
marketing and contracting of financial services, and
consumer protection against unfair commercial
practices, and guidelines and codes in the
communication and advertising industry.
• The Group’s direct communication enhances financial
literacy. For example, before approving a loan, in
communication with clients, NLB Group emphasizes
responsible lending practices, such as keeping
monthly obligations manageable and being aware of
the risk of variable interest rates. In addition, several
NLB Group members provide clients and the general
public with professional advice on their websites (e.g.
in NLB, such as how to manage personal finances
in various life events, how to improve saving habits
or establish a contingency fund, and other aspects
of financial literacy. For additional information on
how NLB Group promotes financial literacy, see the
chapter Affected communities.
These activities align with our business strategy,
informed by market and client research, and client
feedback comments, opinions expressed in direct
communication in daily operations and through other
communication channels. If a potential negative impact
related to communication becomes actual, clients can
access complaint or grievance mechanisms as detailed
in the chapter Processes to remediate negative impacts
– complaint management.

Targets and metrics
To gain deeper insight into retail customer satisfaction
NLB Group conducts annual Net Promoter Score (NPS)
survey, which measures brand NPS, a widely used
metric for assessing customer loyalty and satisfaction.
It reflects the general recommendation of NLB, using
a representative sample from each market where NLB
Group operates. NPS has been constantly increasing
throughout the years as a result of continuous service
development, enhancement of the existing and
development of the new products and digital solutions.
In 2024, NPS experienced a slight decline due to various
market conditions, though the overall trend since 2019
remains positive. As a key performance indicator and
integral part of NLB's strategy, the NPS results were
thoroughly analysed, and an action plan was developed
to enhance customer satisfaction moving forward.
NPS is measured in accordance with the standard
methodology, which gauges customer sentiment and
identify areas for improvement. It is calculated based on
responses to a single question: "How likely are you to
recommend NLB to a friend or colleague?" Respondents
rate their likelihood on a scale from 0 to 10. Based on
their scores, customers are categorized into three
groups: Promoters (9-10), Passives (7-8), and Detractors
(0-6). The NPS is then calculated by subtracting the
percentage of Detractors from the percentage of
Promoters. The resulting score ranges from -100 to +100,
with higher scores indicating greater customer loyalty
and satisfaction.
Table 56: Client satisfaction NPS - NLB Group banking
members
2022
2023
2024
Target
2030
Average NPS
31
36
32
>50%
Notes:
(i) Accountancy policy: NPS is calculated as a difference between satisfied
(promoters) and dissatisfied (detractors) customers. The result for the NLB group
banking members is calculated as a simple mean of individual banking members.
The result for a single year is calculated as a moving average, meaning that the
result for a year includes the average of two measurements conducted in that year
and is calculated as a mean of these two measurements.
This represents a change in the calculation and reporting before 2024, where
only the last measurement in a year was considered, and the NPS values were as
follows: 28 in 2022 and 36 in 2023.
S4-3 Processes to
remediate negative
impacts – complaint
management
All NLB Group members strive to ensure a constructive
dialogue with their clients and to resolve any
disagreements, misunderstandings, or errors which
may occur in daily operations. If, however, clients are
dissatisfied with the products and services, NLB Group
members provide channels which enable them to raise
questions, complaints, and concerns and receive a
timely and qualitative response.
Moreover, clients’ feedback, including complaints,
is considered an opportunity to improve services,
processes, and customer relationships. Therefore,
the Group embeds complaint management into the
overall client experience process and conducts regular
employee training to improve the overall customer
experience.
To this end, NLB Group has established grievance and
complaints channels, which are communicated and
available to clients in branches and on the websites
of NLB and other subsidiary banks in line with local
legislation.

›› For details on the grievance mechanisms please
refer to the chapter G1-Business Conduct, sub-chapter
Managing concerns about unlawful or harmful
conducts.

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Report
Policies
Instructions for Handling Complaints
Content and purpose: The Instructions set the
general framework for complaint management,
defines types of complaints, and the two-level
internal complaints process. It describes the two-
tier customer complaint resolution system and
selected institutions responsible for extra-judicial
settlement of customer claims (IRPS), and provides
clarifications about the methods and procedures to
solve complaints. Moreover, the Instructions define
the minimum standards or general objectives which
are being harmonized group-wide and include:
- fast, efficient, and professional complaint settlement
at all levels of the process, and settlement of
satisfactory reimbursement requests in a unified way.
- registration of complaints so as to enable content
analysis with the purpose of improving products,
processes, and customer experience (transparency,
quality, customer relations, etc.).
- the formation of proposals for improvements with
the purpose of preventing a larger number of similar
mistakes and consequences of a negative customer
experience.
Scope: All employees involved in the complaint
management and resolutions.
Most senior function accountable: Directors of
sales departments and head of branches with direct
business relationship with clients.
Availability: For employees in the Register of
Internal Acts, while the rules and procedures related
to complaints are available to clients in branches
and on the websites of NLB and other subsidiary
banks in line with local legislation.
Key activities and progress
In 2024, the focus was on harmonization of the
complaint management process across the Group.
Regular monthly meetings were organized to align
the mechanisms and methodology, to monitor and
coordinate activities in the group, and to share our
practice. NLB Group banking members have made
progress in harmonizing the complaint management
system, enabling consolidated reporting. Mandatory
e-learning was conducted for all employees involved in
the complaint process. KPIs were regularly assessed and
reported quarterly to the Operational Risk Committee.
Targets and metrics
KPIs set to monitor efficiency and risks related to
complaints management includes number and share
of complaints, average resolution time, and other
indicators. The average share of all banking customers
who complained annually complaint was 2%. Similarly
to the banking system in the region, card services
account for the largest share in the total number of
complaints, whereas the share of complaints in relation
to the total number of card transactions was low, below
0.1%). To mitigate risk of card abuse which represent the
large share of credit card-related complaints, the Group
has a system in place to detect and prevent card abuse
and raising client awareness of the dangers of online
commerce and shopping, thereby contributing to risk
management in this area.
The average resolution time (card complaints excluded)
of all banking members was approximately 6 days. In
the parent bank NLB, 92% of all received complaints in
NLB were resolved positively, which is an increase of 2
percentage points compared to 2023.
Table 57: Complaints in NLB Group banking members
2024
Share of customers who have complained annually
2.0%
Number of complaints
83,259
(i) The percentage (share) is calculated as a number of complaints divided by
a total number of all NLB Group clients (active+other) in NLB Group banking
members.
At the asset management company level (NLB Funds,
asset management), investor complaints remain
extremely low, with only 0.0094% of investors submitting
a complaint in 2024. The company approaches the
potential gap in customers' financial product knowledge
with great understanding, always striving to uphold the
highest standards of customer interest and satisfaction.
Leasing companies have established general internal
procedures related to complaint management,
which will be enhanced in the future by monitoring
mechanisms.
S4-2 Processes for
engaging with clients
and end-users about
impacts
NLB Group prioritizes engagement with corporate and
retail clients to maintain their trust and transparency in
the relationship with them. Therefore, the Group interacts
regularly with clients directly through daily business
processes, which relate to both physical and digital
channels. Physical channels include regular personal
communication with their customer relationship officer
or branch employees, and contact centres, providing
information and assistance via the website, phone, or
a videocall (subject to each entity). The operational
responsibility for conducting such engagement lies with
sales, marketing, or communication directors in each
NLB Group member.
Daily engagement involves communicating the
characteristics and impacts of the Group’s financial
products and services, ensuring that clients are well-
informed and confident in their financial decisions and
maintain good relationship with the Group. In addition,
clients’ feedback is collected through daily interactions,
complaint management system and satisfaction surveys.
Their feedback informs the business strategy of NLB
Group and is taken into account in decision-making.
To manage the positive impacts of its products and
services on the financial health of our clients, NLB Group
financial members conduct regular desk-top and direct
client research to gain information about their needs
and preferences, which inform the Group’s product
development and communication strategies.
›› For additional information, please see the chapters
Responsible communication and Client satisfaction
metrics.

Governance Information
Several topics related to Business Conduct were identified as material,
underscoring the critical importance of governance, compliance, and integrity
at NLB Group. In this section, we disclose information on corporate culture,
regulatory compliance and governance, whistleblower protection, prevention
of corruption and bribery, and prevention of money laundering and financing
of terrorism. We also present ESG risk management, tax transparency, and our
participation in associations and policy discussions. Financial performance and
stability (being thoroughly disclosed in other parts of the business report and in
financial statements) are recognized as a material sustainability topic and are
essential for effectively managing the Group’s IROs.

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G1 Business Conduct
GOV-1 Role of
administrative,
supervisory, and
management bodies
related to business
conduct
All NLB Group employees, including members of the
management bodies (management board members,
supervisory boards, executive directors) are expected
to act in a fair, responsible, and ethical manner, in
adherence with the Bank’s compliance standards. The
overarching framework defining NLB Group’s policy on
responsible business conduct and the framework for
organizational culture, respecting values, and ensuring
integrity is the NLB Group Code of Conduct, with other
internal acts defining in detail the rules and procedures
for specific areas of business conduct. For more details,
please refer to the chapter Policies.
In line with corporate governance principles, the
management body discusses and adopts decisions,
rules, and procedure regarding business conduct in
managing impacts, risks, and opportunities in this area.
Managers at various levels of NLB Group set the
tone from the top as to what good and responsible
business conduct should be. They have specific roles
and responsibilities in promoting responsible business
conduct:
• Discussing the Code with team members to ensure
everyone understands it, thus promoting the ethical
culture in the NLB Group
• Ensuring the fundamental principles and rules of
conduct are implemented and complied with
• Striving to achieve the values of the Group in
accordance with the set principles and rules of conduct
• Encouraging open, fair, and honest relationships
among employees, free from fear and vindictiveness
• Promoting open discussions about all questions
addressed by the Code
• Setting an example through conduct and behaviour
that embodies the values and meets the basic
principles of NLB Group
• Reacting swiftly to any perceived ethical problems in
the environment
• Avoiding demanding any conduct from employees
that would be contrary to legislation, prescribed
rules, or the Code

The management body and senior management
members must demonstrate a high level of personal
integrity and act in accordance with the NLB Group
Code of Conduct. Integrity represents the expected
actions and responsibilities of individuals and
organizations in preventing and eliminating risks
associated with the misuse of authority, functions, or
other decision-making powers contrary to the law,
legally permissible goals, and the guidelines defined in
the NLB Group Code of Conduct.
The knowledge and expertise of management bodies
regarding organizational culture and business conduct
are critical components of corporate governance.
Accordingly, board members of banking members
regularly discuss on internal culture and compliance,
and complete annual training on topics related to
business conduct, including anti-bribery and corruption,
conflicts of interests, ethics, and code of conduct.
Furthermore, adherence to NLB Group values, which
supports corporate culture and responsible business
conduct, is a specific target included in the remuneration
criteria for NLB Management Board members. In
alignment with the NLB Group Governance Policy,
board members across other NLB Group entities have
instituted similar procedures, training programmes,
and targets.
IRO-1 Description of
processes to identify
and assess material
impacts, risks, and
opportunities
At NLB Group, we recognize that business conduct
and organizational culture are complex and multi-
dimensional. These aspects extend beyond the
prevention of corruption, bribery, and other harmful
incidents, as well as whistleblowing mechanisms derived
from the ESRS. They encompass various other aspects
critical for responsible business conduct in financial
institutions, such as ethical governance, integrity,
regulatory compliance, anti-money laundry system, tax
management, etc. Consequently, in addition to ESRS-
related topics, we have identified several entity-specific
material sustainability topics and IROs, as detailed in the
table below.
Although the DMA did not identify any material risks
related to business conduct (i.e. above the set threshold),
NLB Group acknowledges the inherent risks and
potential negative impacts associated with its operations.
Therefore, the mechanisms and policies outlined in the
following chapters also address these risks.

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Report
Table 58: Impacts, risks, and opportunities related to Business Conduct (Corporate Culture)
Material
Sustainability
Topic
Name of IRO
Description of IRO
Type of IRO
Location in
the value
chain
Time
horizon
Corporate culture,
regulatory compliance,
and governance
Ethical and transparent
corporate culture
An ethical and transparent corporate culture fosters trust, accountability, and
integrity within the Ban. By promoting open communication, adhering to ethical
practices, and encouraging employee feedback, the BGroup can enhance
employee morale, strengthen stakeholder relationships, and build a positive
reputation, ultimately contributing to long-term success and sustainability.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term
High standards of
corporate governance,
integrity, and transparency
High standards of corporate governance, integrity, and transparency are
essential for the BGroup to build trust with stakeholders and ensure accountability
in its operations. By adhering to these principles, the BGroup can enhance its
reputation, mitigate risks, and foster a culture of ethical behaviour, ultimately
supporting long-term success and stability in the financial sector.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term
Enabling an ethical
and transparent
corporate culture
Enabling an ethical and transparent corporate culture promotes trust and integrity
within the organization, enhances employee morale, and ensures compliance
with regulations, ultimately leading to sustainable business success.
Impact – Actual
Positive impact
Own
operations
Short-term
Ensuring high standards
of corporate governance,
integrity, and transparency
Ensuring high standards of corporate governance, integrity, and transparency enhances
corporate reputation, ensures compliance with laws, and builds stakeholder trust.
Impact – Actual
Positive impact
Own
operations
Short-term
Integrating principles
of ethical banking
Integrating the UNEP FI principles of ethical banking promotes fairness and
responsibility, improves customer trust, and supports long-term financial stability.
Impact – Actual
Positive impact
Own
operations
Short-term
Ensuring regulatory
compliance
Ensuring regulatory compliance helps maintain corporate integrity,
avoid legal penalties, and builds stakeholder trust.
Impact – Actual
Positive impact
Own
operations
Short-term
Table 59: Impacts, risks, and opportunities related to Business Conduct (other topics)
Prevention of corruption
and bribery
Preventing corruption
and bribery
Preventing corruption and bribery is essential for maintaining the integrity and
reputation of the Bank. By implementing robust compliance programmes, conducting
regular training, and promoting a culture of transparency, the Group can safeguard
its operations, build trust with stakeholders, and ensure adherence to ethical
standards, ultimately contributing to long-term sustainability and success.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term
Preventing corruption
and bribery
Preventing corruption and bribery fosters an ethical business environment,
enhances corporate reputation, and ensures compliance with laws.
Impact – Actual
Positive impact
Own
operations
Short-term
Prevention of money
laundering and
financing of terrorism
Preventing money
laundering and
financing of terrorism
Preventing money laundering is essential for maintaining the integrity and reputation
of the Bank. By implementing robust compliance programmes, conducting regular
training, and promoting a culture of transparency, the BGroup can safeguard
its operations, build trust with stakeholders, and ensure adherence to ethical
standards, ultimately contributing to long-term sustainability and success.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term
Prevention of anti-
money laundering and
financing of terrorism
Prevention of anti-money laundering and financing of terrorism ensures compliance
with legal regulations and fosters trust and integrity within the financial system.
Impact – Actual
Positive impact
Own
operations
Short-term
Whistleblower
protection
Enabling the protection
of whistleblowers
Enabling the protection of whistleblowers fosters an organizational
culture of transparency and accountability, encouraging employees
to report unethical practices without fear of retaliation.
Impact – Actual
Positive impact
Own
operations
Short-term
ESG risk management
Management of ESG risks
Effective management of ESG risks is crucial for the Group to identify, assess, and
mitigate potential environmental, social, and governance challenges that could impact
its operations and reputation. By proactively addressing these risks, the BGroup can
enhance resilience, improve decision-making, and attract socially responsible investors,
ultimately contributing to long-term sustainability and financial performance.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term
Adequate management
of ESG risks
Adequate management of ESG risks ensures a strategic approach to environmental, social,
and governance issues, reducing potential risks and enhancing long-term sustainability.
Impact – Actual
Positive impact
Own
operations
Short-term
Tax Transparency
Ensuring regular
tax payments
Ensuring regular tax payments demonstrates corporate responsibility, supports
public services, and enhances the company's reputation with stakeholders.
Impact – Actual
Positive impact
Own
operations
Short-term
Participation in
associations and
policy discussions
Advocating for sustainable
development through
professional associations
Advocating for sustainable development through professional associations
demonstrates the company's commitment to sustainability, enhances its
reputation, and contributes to broader industry and societal change.
Impact – Actual
Positive impact
Own
operations
Short-term
Financial performance
Ensuring sustainable
financial performance
of the company
Ensuring sustainable financial performance of the company supports
long-term growth, stability, and shareholder value.
Impact – Actual
Positive impact
Own
operations
Short-term
Sustainable financial
performance of
the company
Sustainable financial performance of the bank, which is achieved through responsible
resource management, ethical practices, and a commitment to long-term value creation.
Opportunity
Own
operations
Short-,
Medium-,
Long-Term

By supporting regional
culture and the arts, we
inspire a sense of community
that transcends borders.
Our NLB MUZA
programme combines
banking museum
and educational
programmes, as well
as art gallery activities
and buying works of art
in all the markets of our
operations.

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G1-1 Corporate
culture, ethical
governance
and integrity,
and regulatory
compliance
The Group is committed to ensuring an ethical
organizational culture, compliance, and integrity across
all NLB Group members and in the markets where the
Group operates. The foundation for managing material
IROs related to business conduct and to establish,
develop, promote, and evaluate the corporate culture is
laid down in the NLB Group Code of Conduct. The Code
is binding for all the Group’s employees and stipulates
the fundamental principles and rules of conduct on
which the operations and actions of the NLB Group are
based. These include:
• acting ethically and responsibly and comply with the
rules of the Code
• respecting colleagues and maintain a pleasant
working environment
• respecting customers
• avoiding conflicts of interest
• preventing unacceptable practices
• adhering to the rules and comply with regulation
• prudent and ethical handling of assets and property
• being socially responsible

For each principle, the Code provides employees with
practical guidelines for daily conduct, helping them
understand what is expected from each employee
and other stakeholders within the NLB Group. Ethical
governance, integrity, and compliance are deeply
intertwined with the rules of conduct and are detailed in
the Integrity and Compliance Policy.
NLB Group operates in sectors that are highly regulated
because of the urgency to ensure financial stability and
prevent system risks. Hence, the Group’s employees are
aware that compliance is the foundation of its business.
They understand that responsible business conduct
extends beyond merely adhering to applicable laws,
regulations, and standards. It also encompasses a
robust compliance programme. Compliance is therefore
integrated into the Group’s daily operations, contributing
to a strong internal control environment and effective
management of compliance risks.
The NLB Group members are obliged to regularly
(at least once a year) carry out the training of all
employees in the field of the Code. They also regularly
and actively promote it, raise awareness, and train, and
informemployees about the contents of the Code, as
well as providing explanations regarding their use in
specific situations faced by the employees. In addition,
NLB Group members provide specific training on anti-
corruption, anti-money laundering, and other business
conduct-related topics.
Policies
Key internal documents such as the Code of Conduct
and the Integrity and Compliance Policy are detailed
below. In addition, the Group has established policies
addressing specific topics related to fundamental
principles of responsible business conduct.
All these policies are adopted by each core financial
member, i.e. banks, asset management, and leasing
companies. If certain policies need to be aligned with
local laws, they are updated at the local level to ensure
full compliance. The implementation of policies is
the responsibility of designated compliance officers
within each subsidiary. They assess, monitor, and
evaluate corporate culture through specific indicators
and surveys on ethics and integrity. Consistency
across all core financial members is ensured by using
standardized evaluation methods and regular reviews.
Furthermore, the compliance function is integrated into
the Group’s daily operations, thereby contributing to a
strong internal control environment and ensuring the
effective management of compliance risks.
In non-financial core members and non-core members
of NLB Group the implementation of the policies is
subject to the principle of proportionality, based on
the size and the core business of the specific member.
Nevertheless, all members are required to adjust
their work procedures, organization, monitoring,
and reporting. The competence line responsible
for Compliance monitors and exercises constant
supervision of the meeting of requirements by setting
clear communication on the expectations, ensuring
regular training (or providing training materials),
conducting regular reviews, and monitoring the
activities of specific areas to address any compliance
issues. Oversight is performed by the person in charge
of Compliance and Integrity and focuses on areas
based on the principle of risk.
NLB Group Code of Conduct
Content and purpose: The Code describes the
values, basic principles, and rules of ethical business
conduct that the Group respects and promotes.
Operating with integrity and responsibility is key to
the Group’s corporate culture. The Code demands
that every employee, regardless of their job or place
of work, and every other stakeholder of the Group
comply with the highest standards of integrity. It
also reflects the standards that we expect in our
relationship with the rest of our stakeholders. NLB
Group expects that all business partners and other
stakeholders apply standards at least equal to those
written in this Code, including their attitude towards
employees.
›› The summary is publicly available also on the
NLB website (not subject to external review).
Integrity and Compliance Policy of NLB and
NLB Group
Content and purpose: The Policy sets a strong
strategic framework of the Bank’s comprehensive
programme of compliance operations to meet the
following goals: (1) Ensure compliance and integrity
by meeting requirements, preventing violations, and
fostering a compliance culture; (2) Limit losses from
violations, including business losses, sanctions, and
reputational damage, (3) Enhance legal protection
for the Group and its responsible persons against
liability for violations, (4) Strengthen NLB Group’s
brand reputation and meet stakeholder expectations
through integrity and compliance, (5) Boost NLB
Group’s competitive position by adhering to high
compliance and ethical standards, enhancing
corporate culture and employee commitment.

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Scope: Both internal documents are binding for
all employees in NLB Group across all markets,
including the management and supervisory bodies
of each NLB Group member. In addition, the internal
documents apply indirectly to suppliers and clients
in the parts related to their required behaviour.
Exclusions include activities that are not directly
related to NLB Group’s operations or where the
Group has limited influence.
Most senior level accountable: The management
boards of each NLB Group member.
Availability: The Code of Conduct and the Policy
are published in the Register of Internal Acts, and
each year internal meetings and workshops are
held to explain the policy and its implications are
organized. A summary of the Code with contents
that are relevant for external stakeholders is publicly
available on the NLB Group website, while the
Policy is communicated through relationships with
stakeholders.
Key activities and progress
Respecting the Code of Conduct and the Policy is an on-
going activity in daily operations.
›› For an overview of key activities in 2024, please refer
to the chapter Compliance and Integrity in the Business
Report.
Managing concerns about
unlawful or harmful
conducts
NLB Group has established procedures to promptly,
independently and objectively investigate business
conduct incidents, including incidents of corruption and
bribery. The procedures include a strong mechanism
for identifying, reporting, and investigating suspicions
of harmful behaviour to report concerns about unlawful
behaviour or behaviour in contradiction of internal
acts, including bribery and corruption. This mechanism
allows the Group to identify potential compliance risks
and take appropriate action in a timely manner.
One of the notable highlights of the Group’s compliance
programme is the emphasis on creating a speak-up
culture. NLB and other financial core members have
established rules regarding fraud investigations, case
handling, and protection of whistleblowers (or similar
internal acts). In line with internal rules, the prevention
of fraud, abuse, and other harmful conduct is the
responsibility of all employees. Harmful conduct is any
conduct committed by a specific person which could
incur property or non-property damage for the Bank, or
unlawful conduct from the aspect of cogent regulations
as well as general principles, or contrary to good practice.
Every important suspected violation or act of misconduct
(such as abuse or fraud, including suspected bribery or
any form of corruption) must be reported and dealt with.
The Group fosters an environment that encourages
employees to set questions and discuss them with
their managers or other employees in the Group,
including the experts in compliance, money-laundering
prevention, or the fight against bribery and corruption,
lawyers, or HR managers. The Group’s commitment
to the highest standards of corporate culture and the
procedure for reporting suspected harmful activities are
also communicated transparently to all employees via
newsletters and other notifications and at mandatory
training sessions.
Employees have the option to submit a report directly
to their supervisor, who then files the report with the
Compliance department using the prescribed form.
Alternatively, employees can also submit a report
themselves through various channels. The Group’s
financial core members have established various
channels to report potentially non-compliant, non-
ethical, or inappropriate business practices (including
anonymously), such as electronically via the Whistler
web application (internal and external stakeholders),
via e-mail to the dedicated e-mail address, in person, by
regular mail to the dedicated postal address or post box
(internal and external stakeholders), or by telephone.
Furthermore, it is the responsibility of every employee to
take all necessary steps to prevent all harmful conduct,
including that which results from negligence.
Upon receiving a report, the process is followed by
preliminary testing. If all circumstances of the case
are clarified during the preliminary testing, the case is
closed at this stage. Otherwise, further investigation
follows, as described in the chapter Managing concerns
about unlawful or harmful conduct.
The investigation is conducted efficiently, impartially,
professionally, prudently, and conscientiously, with the
confidentiality of the investigation and the collected data
and information ensured at every stage of the process.
The investigation must run continuously and without
unnecessary delays. Any suspension of the investigation
and the reasons therefore must be properly documented
in the report.
The objectives of the investigation are as follows:
• To confirm or dismiss the suspicion of harmful
practices and to protect evidence
• To establish any potential damage to the Group or the
client and determine the amount of damage caused
• To identify the alleged perpetrators (Group employees
or other individuals allegedly involved in the harmful
practices)
• To identify potential risks and weaknesses in
individual processes and provide proposals/
recommendations for their elimination
• To conduct a compliance risk assessment

Depending on the findings of the investigation,
subsequent actions may include notifying the
whistleblower about the closure of the case, informing
the HR department and the supervising director, filing a
criminal complaint, and other relevant steps.
In addition, at NLB Group members, the internal audit
and the compliance functions (where separately
established) check and control the respect of the basic
principles in regular internal audit procedures and
compliance review procedures as well as randomly. In
the scope of its regular tasks, the compliance function
of each NLB Group member performs regular activities
to investigate suspected corrupt practices and bribery.
Each NLB Group member ensures that accounting and
other internal controls are established as part of the
internal control mechanisms, by means of which corrupt
practices are prevented (e.g. no black funds for bribery
or facilitation payments, etc.). The Group also regularly
assesses conflict of interest and corruption risks in
accordance with the applicable methodology for the
general assessment of the integrity and compliance risks.

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G1-3 Prevention
of corruption and
bribery
Policy
At NLB Group, we acknowledge that all employees
may encounter situations that constitute or could
constitute a conflict of interest. NLB Group strongly
condemns bribery and corruption, and has a policy of
zero tolerance for such practices, deeming them unfair,
illegal, and harmful to societies and countries with
corrupt practices. We expect the same commitment
from our customers, business partners, and third
parties. To ensure integrity, all NLB Group employees
are subject to restrictions on accepting and giving gifts,
hospitality, and other influences on their conduct, with
concrete measures in place to manage associated
risks. Rules, guidelines, and procedures are set out in a
comprehensive anti-corruption and bribery policy.
The Policy on the Prevention of Corruption and
Bribery and on the Management of Conflicts of
Interest
Content, purpose: The Policy establishes a baseline
for behaviour in situations with identified corruption
risks. The Policy outlines specific measures to
manage these risks, aligning with international
standards in the fight against corruption. The
Policy is aligned with the Code of Corporate
Governance for listed companies, the Slovenian
Banking Act, EBA Guidelines on Internal Governance
and the Regulation on Internal Governance
Arrangements, the Management Body and the
Internal Capital Adequacy Assessment Process
for Banks and Savings banks. The Policy adheres
to the principles of the United Nations Convention
against Corruption (UNCAC) in terms of its core
points and substance, although it does not directly
reference the Convention. These standards cover
various aspects, including engagement with
agents and intermediaries, hiring services of
(former) civil servants, interactions with high (state)
representatives, preventing nepotism, averting
accelerated payments, and ensuring transparency in
NLB Group operations.
Scope: NLB Group members, whereby the level
of implementation is subject to the principle of
proportionality, based on the size and the core
business of the specific member.
Most senior level accountable: The management
boards of each NLB Group member.
Availability: Employees may access the policy in the
Register of Internal Acts. A summary of the policy is
publicly available at: NLB Group anti-corruption and
anti-bribery policy.
System and activities
to prevent and detect,
investigate, and respond
to allegations or incidents
relating to corruption and
bribery
As part of the fight against corruption and bribery,
and in line with internal policies, NLB Group carries out
several activities to manage related risks:
• Ensuring specific terms in written agreements and/or
general terms and conditions with third parties define
anti-corruption and anti-bribery standards as a
minimum requirement for investment and purchasing.
• Internal control mechanisms, including accounting
controls, are in place for the anti-bribery and anti-
corruption area.
• Regular, at minimum annual review, identification,
and assessment of risks of conflicts of interest and
corruption in the case of external contractors and
suppliers and other contractual partners of NLB and
NLB Group through due diligence processes.
• The compliance functions have strengthened the
approach to managing these risks in day-to-day
operations, through obligatory e-training for all
employees in core financial members, awareness-
raising activities in the field of prevention of
corruption and bribery, by implementing an
assessment of conflict of interest and corruption
risk in relations with suppliers, including the topic in
the monthly newsletter, and classroom and online
presentations and discussions.
• All employees are included in yearly training and
awareness-raising activities. In NLB Group various
(whistleblowing) channels are established for
reporting suspicions of harmful conduct (internally
and publicly available), including suspicion of corrupt
conduct.
• All employees are responsible for rejecting any
form of corruption and bribery with zero tolerance,
and to immediately report any identified suspected
misconduct through the established channels for
reporting suspected misconduct, proactively disclose
any conflict of interests, and adopt measures for the
appropriate management of such conflicts.
• The executives (members of the senior management)
shall ensure that employees act in accordance and
are familiar with the rules of the policies on anti-
corruption and bribery, and that these rules are
implemented in the scope of their duties and powers.

›› Responding to allegations and incidents relating
to corruption and bribery is determined within the
procedures, which are detailed in the chapter Managing
concerns about unlawful or harmful conduct.
The investigation teams in NLB Group banking members
are separate from the chain of management involved
in the reported matter. In line with the harmonization
principles, in NLB Group banking members the
investigating function has been established for years
and operates within the Compliance department.
The organization differs in other members, with some
members placing this function within a dedicated unit
depending on the size and organization of the member.
Investigators handling suspicions of harmful actions
constitute an independent investigation and provide
objective findings, that are verifiable with the collected
evidence. They prepare a report on the findings, serving
as the basis for follow-up measures. Among other
harmful actions, investigators are responsible also
for independent investigation of cases of suspected
corruption or bribery. In NLB the investigation team
handles suspected misconduct, represents the Group
in court in criminal proceedings, provides coordination
and support to the Group, and performs other tasks in
accordance with the Whistleblower Protection Act.

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In NLB, the Director of Compliance and Integrity reports
at his discretion (based on the risk assessment) on
all measures imposed on perpetrators and on other
activities directly to the Management Board. Immediate
informing is on a case-by-case basis, while all the
cases investigated are reported in regular quarterly
reports. In the case of an investigation into members
of the Management Board, the Director of Compliance
and Integrity directly informs the Chair of the Audit
Committee acting on the Bank's Supervisory Board.
In other NLB Group banking members Compliance
directly informs the Bank's Management Board about
all measures and activities undertaken as a result of the
investigation.
The compliance function of a NLB Group member
regularly performs activities to raise awareness and, at
least once annually, organizes training on preventing
corruption and bribery, which that is mandatory for all
employees (including the members of the management
body). We consider that all employees are considered
as "function at risk" with different levels of exposures to
such risks.
In 2024, the members of Supervisory Board and
Management Board in the majority of core financial
members also participated in classroom training; in
others such training will be performed in 2025 and
onwards.
During 2024, 7,056 employees in NLB and other
financial core members (84. 8% of all NLB Group
employees) completed anti-corruption training.
Metrics and progress
In relation to harmful actions, NLB Group has
established a standard of zero tolerance for illegal
and unethical actions and disrespect for the Group’s
values.
Zero tolerance refers to all intentional actions of
employees that represent harmful conduct for the
NLB Group member and are as such defined by
legal or implementing acts, internal legal acts, good
business practice, and other generally known good
business practice. Zero tolerance also applies to actions
of employees committed with gross negligence –
circumstances when employees should be aware of the
possibility that their actions might cause damage to NLB
or the NLB Group member, but failed to prevent them.
G1-4 Incidents of corruption
or bribery
In 2024, there were no cases of convictions for violation
of anti-corruption and anti-bribery laws and no fines
issued for these matters in the entire NLB Group.
Table 60: NLB Group Incidents of corruption or bribery
2024
Cases of convictions for violation of
anti-corruption and anti-bribery laws
0
Fines issued for convictions for violation of anti-
corruption and anti-bribery laws (EUR thousands)
0
Prevention of AML
and financing of
terrorism
Policy
Anti-Money-Laundering and Countering the
Financing of Terrorism Policy
Content and purpose: By this Policy NLB Group
manages impacts and risks related to AML and
CFT. The Policy lays down the key elements of the
AML/CFT system, and the content and the scope of
the tasks to be established and performed by NLB
Group, its members, and their employees. Key aims
of the Policy are: implementation of the legislative
requirements of the ZPPDFT-2 and guidelines of the
supervisory bodies in the procedures and framework
of banking operations and operations of other
members, definition of the control environment
elements of the members and NLB Group, efficient
implementation of the AML/CFT system, establishing
an efficient system of policies, procedures, and
internal controls at the level of individual members
and the level of the NLB Group in order to efficiently
combat all identified MLTF risks. By implementing
the requirements from the Policy and therefore
establishing the control environment, members and
therefore NLB Group as whole reduce the risks to an
acceptable level.
Scope: NLB Group members.
Most senior level accountable: The management
board in each NLB Group member.
Availability: for employees in the Register of Internal
Acts, for external stakeholders summarized in the
publicly available Code of Conduct.
Key activities and progress
›› For a detailed description of key activities, please refer
to the Business Report, chapter Prevention of Money
Laundering and Terrorism Financing, and Financial
Sanctions Compliance.

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Whistleblower
protection
At NLB Group, we understand the importance of
whistleblower protection, which was identified in the
DMA as a material sustainability topic. In the Republic
of Slovenia, the Whistleblower Protection Act (ZZPri)
came into force in 2023, transposing EU Directive
2019/1937 of the European Parliament and the Council.
The mechanisms and measures described in this
chapter also refer to the Bank’s own workers who are
whistleblowers in accordance with the applicable law
transposing EU Directive 2019/1937 of the European
Parliament and of the Council. Other countries where
NLB Group members operate have their own local legal
requirements regarding whistleblower protection.
All NLB Group members based in the Republic of
Slovenia who are mandated by the national law The
Whistleblower Protection Act (ZZPri), which transposes
the above-mentioned EU directive, comply with its
requirements. Members based outside Slovenia, who
are subject to local legal requirements regarding the
protection of whistleblowers, adhere to their respective
local laws. Years ago the Group has established
the whistleblowing system for internal and external
stakeholders with a strict procedure for whistle-blower
protection against retaliation measures and assurance
of anonymity, if the whistle-blower chooses not to reveal
their identity..
The integral part of the system, or one of the reporting
channels is also the Whistler – an application for
reporting (suspected) violations, accessible also on
the public websites of NLB Group banking members. It
allows whistleblowers to submit signed or anonymous
reports and also enables two-way communication
between the whistleblower and the investigator, even
in case of anonymity. When receiving, processing,
investigating and archiving individual reports, the
investigators ensure that the information in the report
and thus the personal data of the whistleblower are
strictly protected. All NLB Group banking members use
the Whistler in their local languages. Both, the Whistler
application and other reporting channels are available
24/7 and allow reports to be submitted from outside the
Groups’ IT systems or premises.
Policies
NLB Group has a long history related to whistleblower
protection. NLB has established more reporting
channels than required by local whistleblowing
protection law, with a more detailed procedure for
investigations, and in addition to the law, the Bank also
provides protection to the whistleblower. Namely, NLB
issued the Commitment to Protect Whistleblowers of
Harmful Conduct as early as 2014, several years prior
to the implementation of the Whistleblower Protection
Act in 2023. Since then, the principles and regulation
of whistleblower protection have been systematically
embedded in other NLB core financial members, unless
otherwise required by local legislation
Rules of Procedure – Regulation regarding fraud
investigations, case handling, and protection of
whistleblowers
Content, purpose, and regulatory framework:
These rules establish the framework for NLB
standards for investigations of harmful conduct by
NLB employees or external perpetrators, where
in both cases material and non-material damage
is caused or could be caused to the Bank. The
Regulation defines the tasks of Compliance and
Integrity in the investigation procedure, the tasks
and authorizations of the head of the investigation
and their deputies and other persons performing
investigations under the authorisation of the Director
of Compliance and Integrity, the methods to report
violations, the procedure for investigation of harmful
conduct, an action plan, measures to encourage
reporting and remunerate informants, mechanisms
to protect internal reporters, measures to eliminate
the consequences of the damage, and reporting to
Compliance and Integrity and informing the public.
Scope: NLB Group members (adopted in NLB, and
transposed to NLB Group members via standards).
Most senior level accountable: The management
board in each NLB Group member.
Availability: for employees in the Register of Internal
Acts, for all stakeholders summarized at:
NLB Whistler
Activities
NLB performs the following activities and measures to
protect whistleblowers against retaliation:
• The identity, if disclosed and the individual requests
protection, is stored separately (secured) from the
report file.
• The whistleblower is referred to in all documents by
a unique identification number (the identity is sealed
in a special envelope and stored in a metal cabinet,
accessible only to authorized investigators).
• The identity, if disclosed in the Whistler reporting
application, is strictly protected (external server) and
access is restricted to authorized investigators only.
• In the event the Group initiates further procedures
(legal, criminal), we always adhere to the principle of
never disclosing that it is the result of an individual’s
report.

NLB employees are informed (through newsletters,
website, training) about the possibility of submitting
reports under the Whistleblower Protection Act (ZZPri)
and the protection options provided by the law.
NLB Group banking members also conduct training
on fraud prevention, which includes presenting cases
and channels for submitting reports. This is achieved
through training sessions tailored to different target
groups of employees and through regular e-learning
programmes available to all employees. Some banking
members prepare newsletters, competitions, and other
engagement activities.
Specialized training for internal fraud investigations is
not formally required; however, investigators participate
in training programmes offered by external institutions
(Transparency International, ACFE, the Commission
for the Prevention of Corruption, universities, etc.).
Additionally, NLB as the parent bank, on average
once per quarter, organizes workshops or meetings
for investigators in NLB Group banking members to
address current topics in the field of fraud investigation.
In-person training for investigators in NLB Group is also
provided upon request.

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ESG Risk
management
Material impacts, risks,
and opportunities related
to ESG Risk management
Having in mind NLB Group’s overall operations, we
define ESG risks as any actual or potential negative
impact that arises from environmental, social (including
human rights) and governance factors related to
NLB Group itself or to any of our key stakeholders.
In the realm of financing activities (lending and
investments), we define as ESG risks the risks of any
negative financial impact on NLB Group stemming from
the current or prospective impacts of ESG12 factors on
NLB Group’s counterparties or invested assets. Given
the global importance of climate change, NLB Group
primarily focuses on developing and implementing
a strong climate-related and environmental risk
(CER) management framework for its portfolio and
investments. Moreover, in recent years the Group has
systematically upgraded the social and governance risk
management, which will remain the strategic direction
in the future.
Integration of ESG risk
management in the
business model, strategy,
and processes
At NLB Group, ESG risks do not represent a new risk
category, but rather one of the risk drivers of the
existing type of risks, such as credit, liquidity, market,
operational, and reputation risk. Therefore, the
Group integrates and manages ESG risks within the
established risk management framework in the area of
the aforementioned type of risks, business strategy, and
internal governance arrangements.
In this respect, we are focused on setting out efficient
processes to manage ESG risks comprehensively in all
respective business areas and all three sustainability
pillars: sustainable operations, sustainable finance, and
contribution to society.
ESG risk management follows ECB and EBA guidelines
with the tendency of their comprehensive integration
into all relevant processes in NLB Group. In addition,
NLB Group adheres to the national and EU regulatory
framework, recommendations, and guidelines, as well
as voluntary commitments and initiatives that
NLB Group has joined in recent years, such as the
UNEP FI PRB and the UNEP FI NZBA. NLB Group is also
a signatory of the Framework Agreements with the
EBRD and the Contract of Guarantees with MIGA. All
the above-mentioned regulations, recommendations,
and guidelines are integrated in the internal regulatory
framework of NLB Group.
In terms of social risk management, NLB Group also
follows international frameworks in the area of respect
for human rights, including the Universal Declaration
of Human Rights, the International Covenant on Civil
and Political Rights, the International Covenant on
Economic, Social and Cultural Rights, the International
Labour Organization (ILO) Declaration on Fundamental
Principles and Rights at Work, and OECD Guidelines.
NLB Group is committed to further developing processes
and policies in order to upgrade mitigating social as well
as governance risks in its internal operations, as well as
in relations with its counterparties.
The risk management function defines the rules about
risk appetite, risk strategy, and other risk policies and
guidelines. They are established in the risk management
framework of the existing type of risks, such as
credit, liquidity, market, operational, and reputation
risk. Besides that, risk monitoring and proactive
management in the area of ESG are established. The
mandate of the risk management function is to provide
and increased focus on holistic risk management and
cross-risk oversight to further enhance risk steering and
mitigation within the whole Group.
12 Definition in the EBA report on management and supervision of ESG risks for credit institutions and investment firms, EBA, 2021

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ESG risks in credit risk
management
NLB Group has implemented tools for the identification,
measurement, and management of ESG risks within
its overall credit risk management framework. This
includes the credit approval process, credit portfolio
management, and collateral evaluation process
A comprehensive risk assessment and monitoring
mechanism in NLB Group is the Environmental and
Social Risk Management System (ESMS), whose main
objectives are to identify and manage NLB Group’s
exposure to the ESG risks of its clients and to promote
their good environmental and social business practices.
The system is fully embedded in NLB Group’s loan
origination and monitoring processes and is regularly
updated with any material factors or procedures in line
with ESG-related developments and requirements.
The credit ratings of clients that are materially important
to NLB Group and the issuing of credit risk opinions
are centralized via the NLB Credit Committee. The
process follows the co-decision principle, in which the
credit committee of the respective group member first
approves their decision, following which the NLB Credit
Committee gives its opinion.
• ESG data collection is integrated into our KYC (know
your client) procedures. We collect different ESG data
through questionnaires and direct communication
with clients based on ESG initial risk of transaction,
type of transaction, and value of transaction. ESG
data collection is also an integral part of monitoring
procedures of transactions and clients and is raising
awareness on ESG risks among our clients.
• Once it is confirmed that the transaction is not on
the exclusion list, a Regulatory Compliance Check
is conducted. This check ensures that the client
complies with relevant laws, regulations, and
standards, including environmental and health and
safety regulations, planning permissions, operating
licences, and permits.
For transactions identified as having high
environmental or social risk, an enhanced risk
assessment is carried out
• during the annual review of the client, provided the
exposure and ESG risk level thresholds are met, and
when a new transaction proposal is made, under the
following conditions:
• New loans are related to project finance with a
total project value exceeding EUR 10 million.
• Financing applications pertain to secondary
market transactions or syndicated loans where
the bank's participation is below 25% of the total
loan value.
• A new loan exceeds EUR 3 million, has a maturity
of at least 36 months, and the client meets the
ESG review threshold at the annual review.
• Throughout the project's duration, ESG risk
monitoring is established to evaluate the impact of
each risk and develop mitigation strategies. This
ensures that risks are adequately managed and that
any changes or new risks are promptly identified and
addressed.
• If a client fails to comply with the ESG requirements of
the investment, we assess the situation to determine
the best course of action. This may involve exiting the
investment or implementing measures to mitigate
the risk of non-compliance. We consider potential
financial losses, legal consequences, and reputational
damage, as well as our overall ESG strategy and how
exiting the investment might affect our ESG goals.

ESMS system is
embedded in
loan origination
and monitoring
Exclusion List
Engagement
of RMs in collecting
ESG data
Regulatory Compliance Check
B
ESG Industry
Categorization by NACE
LOW MEDIUM HIGH
ESG Enhanced Risk Assessment
C
Transaction Characteristics
Decision
(approving / declining transaction)
E
ESG Risk monitoring
Exiting the Investment
F
Category A Projects
Conduct a Site Visit
A
D
Figure 22: Key steps of the transaction approval process:

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ESG risks in NLB Group’s
own operations
In addition to ESG risk management in the
aforementioned processes, NLB Group has established
a framework for comprehensive mitigation of
environmental, social, and governance risks that are
related to NLB Group’s operations.
Namely, ESG risks may occur in all key business areas
and operations, therefore identifying risks in key
competence lines’ areas of work and the early warning
system are essential steps of the planning phase of
the sustainability management process. Moreover,
competence lines define Key Risk Indicators (KRIs),
monitoring procedures, and indicative scenarios for
action in case such situations materialize, in accordance
with the rules and procedures stipulated in internal risk
operational documents.
In particular, physical risks, as part of ESG risks in the
area of operational risk, are addressed in the Group’s
business continuity management (BCM) and business
continuity plans. These plans are prepared for use
in the event of natural disasters, IT disasters, and
undesired effects of the environment, to mitigate their
consequences. Additionally, ESG risk screening in the
supply chain is part of the Group’s supplier selection and
regular assessment process.
Tax transparency
The DMA has confirmed the positive impact of NLB
Group’s responsible tax practices and transparency,
which demonstrate corporate responsibility, support
public services, and enhance the Group's reputation with
stakeholders.
Policies
Tax Policy of NLB Group
Content, purpose, and regulatory framework: The
Policy stipulates the general principles of conduct in
the tax field to which all units handling taxes adhere
and are described in detail above. NLB Group
conducts its tax operations in line with the purpose
and the requirements of the relevant legislation and
in accordance with the international standards if
applicable, e.g. OECD guidelines.
As the parent bank, NLB defines the Tax Policy of
NLB Group and controls the implementation of the
tax function in the Group, while NLB Group members
inform NLB about their tax position. Each member
is responsible for fulfilling its tax obligations in
accordance with their respective legislation. The
members are independent and entirely responsible
for their own tax compliance.
Scope: Applicable and mandatory for all NLB Group
members. Banks have included the provisions of
Tax Policy in their internal acts. The main strategic
members declared compliance with the Tax Policy.
Most senior level accountable: Financial Accounting
and Administration director in NLB and managers ion
similar positions in NLB Group banking members.
Availability: to employees in the Register of
Internal Acts.
In NLB, the tax expert unit Financial Accounting and
Administration reports to the Chief Financial Officer,
with important tax issues discussed and decided by the
Management Board. Subsidiary-level tax functions are
similarly managed under local CFOs.
Each NLB Group member is taxed according to local
legislation, with income tax rates ranging from
9% to 32%.
General principles of the Policy:
• NLB Group members conduct their tax operations
in line with the purpose and the requirements of
the relevant legislation and in accordance with the
international standards if applicable, e.g. OECD
guidelines.
• The attitude of members towards the Financial
Administration is respectful, transparent, and
professional.
• When determining tax obligations, members comply
with the legally permitted reliefs and exemptions from
the tax base.
• Members cooperate with the Financial Administration
to obtain the relevant explanations and information
for the provision of tax bases on a regular basis or
wherever possible.
• When establishing tax positions, members strive
to achieve certainty and implement a conservative
policy of assuming tax risks. We optimize taxes only in
legally permitted ways.
• Members do not use the structures for the purpose of
tax avoidance or aggressive tax planning. Members
do not use structures that are not in line with the
purpose of the legislation or the use of which would
subordinate its business motives to tax motives.
• The reasons for a member’s presence in a certain
country are purely business- and not tax-motivated.
Members do not do business in tax havens or use
them for tax avoidance and do not divert profits to tax
heavens and jurisdictions with low taxation.
• Members do not enable or support tax-motivated
arrangements of their clients and act preventively.
• Members strive to ensure that the appropriate part
of its taxable profit is considered in those members
of NLB Group where the value is generated. As a rule,
our operations with related persons are carried out
at comparable market prices and in the case of any
deviations, such fact is considered in the tax reports.

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Key activities
To assure effective management of tax risk, the control
framework, and awareness of the importance of the tax
function, a number of processes and on-going activities
are in place such as:
• Ensuring that tax risks throughout the organization
are identified, evaluated, managed, and
communicated.
• Maintaining a strong control environment and tax risk
framework to ensure compliance with tax laws.
• Tax risks are managed yearly by tax questionnaires
and detailed lists of controls for different types of tax.
• Detailed written instructions are prepared for
different taxes, together with internal controls which
have to be exercised.
• Reviewing the tax treatment of every new product or
business decision before its implementation.
• Handling tax-related topics by in-house qualified tax
experts who are provided with ongoing training.
• In-house tax experts of NLB regularly attend yearly
tax conferences and education on actual tax topics
(for instance at the Slovenian Audit Institute and
Slovenian Bankers Association). Employees involved
in performing tax function undertake continuous
training to enhance tax risk understanding provided
by internal tax experts (FATCA/CRS, DA6, Tax -
dealing with securities). For the tax topics important
to a wide range of employees, e-learning is also
prepared. There was a total of 530 participants from
NLB in the internal tax training (majority of employees
in branches, new employees).
• Monitoring of updates to changes in tax laws and
their impacts on NLB and industry.
• Discussing important tax issues related to the
banking industry within the Banking Association,
preparing comments on tax legislation proposals,
initiatives for changes of tax legislation, and questions
for tax opinions whenever possible or relevant at the
local level. Comments, initiatives, and questions are
professionally reasoned, coordinated with members
of the Group Association, and, where appropriate,
take into account the impact on the local community.
Execution of the activities stipulated in the Tax Policy in
banks is monitored yearly via tax questionnaires by tax
experts/Financial Accounting and Administration of the
parent bank. In banks and strategic members Internal
Audit reviews the tax in accordance with the annual plan
based on risk assessment. Financial strategic members
can be also reviewed by Compliance in line with the
annual plan.
Metrics and progress
NLB Group strives to prevent important tax risks through
internal controls. The Financial Administration of the
Republic of Slovenia has granted NLB a special tax
status which is based on cooperation, transparency,
understanding, voluntary payment of taxes, and mutual
trust. The goal of NLB is to maintain that status. Other
jurisdictions where NLB Group banking members
operate so far do not have legislation that would allow
them to obtain the special tax status.
Table 61: Country by Country Reporting (CBCR) for 2024 (in EUR thousands)
Number of
employees
Revenues
from
third-party
sales
Revenues from
intra-group
transactions
with other tax
jurisdictions
Profit/loss
before tax
Tangible
assets other
than cash
and cash
equivalents
Corporate
income tax
paid on a
cash basis
Corporate
income tax
accrued on
profit/loss
Slovenia
2,856
617,297
18,656
302,283
146,484
41,978
27,395
North Macedonia
995
105,436
-2,776
77,081
35,838
6,669
6,178
Serbia
2,515
299,252
3,018
160,113
127,239
26,659
19,107
Montenegro
410
56,720
-360
33,557
26,376
5,569
5,148
Croatia
41
3,039
-1,367
277
1,987
46
186
Bosnia and
Herzegovina
1,025
100,789
-2,275
47,807
38,481
4,768
4,236
Kosovo
478
61,800
-2,040
40,785
12,161
4,427
4,529
Germany
0
29
0
-160
66
0
0
Switzerland
2
530
-49
926
877
37
31
Notes:
(i) The table includes all NLB Group entities (banks and non-banking members). There are only non-banking members in Croatia, Germany and
Switzerland.
(ii) Number of employees is the number of employees as at 31 December 2024.
(iii) The columns Revenues from third-party sales and Revenues from intra-group transactions with other tax jurisdictions includes net interest income,
dividend income from non-Constituent Entities, net fee and commission income, the net effect of financial instruments, foreign exchange translation, the
effect on the derecognition of assets, net operating income, and gain less losses from non-current assets held for sale.
(iv) Accountancy policy and reconciliation: The reasons for the difference between income tax accrued and the tax due if the statutory rate is applied
to profit before tax are disclosed in the Annual Reports of NLB Group members in the notes to Income Tax Disclosure. The reported data refers to the
financial statement note 4.15 Income tax and note 2.29. A table is prepared by CBCR rules, i.e. corporate income tax accrued on profit/loss includes only
current tax, but no deferred tax and because of this there is a difference to the amount of income tax in 4.15.
(v) In accordance with OECD Guidance on the Implementation of Country-by-Country Reporting, dividends from Constituent Entities are not included in
the column Profit/loss before tax and income tax paid or income tax accrued with respect to dividends from Constituent Entities are not included in the
columns Corporate income tax paid on a cash basis and Corporate income tax accrued on profit/loss. The income tax paid with respect to dividends from
Constituent Entities in Slovenia amounts to EUR 10,065 thousand.

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Participation in
associations and
policy discussion

To strengthen and manifest our commitment to the
sustainable, green, and just transition, NLB Group has
voluntarily decided over the years to join and adhere to
key international initiatives, principles, recommendations,
and associations in sustainability-related areas.
Furthermore, the Group members in the region
frequently take part in local institutions and initiatives
as active members, supporters, or participants in expert
discussion groups, meetings, and webinars. Through
these activities, the Group is actively engaged in strategic
discussions about the role and benefits of sustainability.
Most importantly, such collaborations strengthen
capacities for NLB Group’s green transition, enhance
knowledge and experience sharing, which we embed
in our daily operation, and co-create future activities to
achieve local, regional and global sustainability goals.

Financial
performance

In the conducted DMA, the financial performance
(stability) of the NLB Group was identified as a crucial
prerequisite that enables effective management of
significant impacts, risks, and opportunities. Details on
financial performance are included in the Financial
Report.

G1-5 Political
influence and
lobbying activities

NLB Group is politically neutral, and giving
financial contributions to political parties, political
representatives or political campaigns is strictly
prohibited in NLB Group as the Sponsorships and
Donations Policy stipulates that members shall not pay
any political contributions – neither direct nor indirect.
NLB and other members of NLB Group are committed
to ensuring an apolitical reputation in their business
dealings, avoiding any perception that their decisions
are influenced by politics.
In 2024, no political contributions of any kind (either
financial or in-kind) were made in NLB or any of
NLB Group members.
Table 62: NLB Group political contributions (in EUR thousands)
2024
Political contributions (financial)
0
Political contributions (in-kind)
0
EBRD Women in Business
Programme
Greenhouse Gas Protocol
Multilateral Investment Guarantee
Agency
Sustainable Business Network
Slovenia
Bled School of Management
Chapter Zero Slovenia
Figure 23: Key memberships and collaborations
UN Sustainable Development
Goals
UNEP FI Principles for Responsible
Banking
UNEP FI Net-Zero Banking Alliance
European Banking Federation –
Sustainable Finance Expert Group
Slovenian Banking Association
– Sustainable Finance Working
Group
AmCham Slovenia – Commission
for Sustainable Growth

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In the double materiality assessment, management
of the relationship with suppliers was not assessed
as material. However, NLB Group opted to disclose
information on an informative basis to a similar extent,
which was also included in previous reporting to provide
Group stakeholders with a comprehensive overview
over time.
Procurement portfolio
overview
In 2024, the banking members of the NLB Group
cooperated with a total of 6,098 suppliers from 37
different countries, of which 5,627 (92%) were local
suppliers, covering 90% of the procurement spend,
which is a similar breakdown as in 2023. Since the
procurement process is not applicable for various
spend categories (e.g. taxes payable to municipalities,
ministries, central bank, donations, sponsorships, etc.),
cooperation based on procurement process covered
2,267 suppliers, of which 2,056 were local suppliers with
93% of the procurement spend.
Table 63: Suppliers by markets
Location of suppliers
Number of suppliers(i)
in 2024
Share in total supplier spend(i)
in 2024
Local markets (6 countries)
2,056
93%
European Union (19 countries)
945
49%
Europe (29 countries)
2,237
99.8%
Non-European countries
4
0.2%
(i) Based on the procurement process
Table 64: Suppliers by activity
Activity
Number of suppliers(i)
in 2024
Share in total supplier spend(i)
in 2024
Information and Communication
302
36.94%
Professional, Scientific and Technical
333
16.31%
Administrative and Support Services
160
9.94%
Wholesale and Retail trade, and Repair of Motor Vehicles
405
9.21%
Financial and Insurance
40
6.48%
Other activities
824
16.27%
Data not available
203
4.85%
(i) Based on the procurement process
Complementary information related to business conduct
Sustainable supply chain*
*This chapter provides complementary information and is not subject to external review.

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Procurement management
Management of the procurement process for
NLB Group banking members is established by the
Standard – Procurement in NLB Group Members and
other procurement-related internal documents, which
consider principles related to suppliers defined in
NLB Group Code of Conduct.
The purpose of the Standard is to ensure a uniform
and transparent procurement procedure for goods and
servicesneeded for performing business activities in NLB
Group. To manage sustainability-related impacts, risks,
and opportunities efficiently and in a harmonized way,
a synergy approach was established, whereby in the
majority of cases, NLB, as the parent bank, assesses and
integrates the needs of several NLB Group members,
predominately banks, and makes RFPs and purchases
at the level of the NLB Group. The rules and procedures
defined in the Standard are fully implemented in NLB
Group banking members, while in other members its
harmonization is underway. The most senior function
responsible for implementing the Standard are the
directors of procurement departments or similar
function in each NLB Group member.
The standard applies key principles and guidelines,
including fair dealing and good governance.
Accordingly, as a rule, NLB Group members must ensure
that the procurement process is fair, indiscriminatory,
and offers opportunities and equal treatment for
all suppliers in procedures. It defines clear terms of
cooperation between NLB Group, bidders, suppliers,
and external contractors, which must be respected by
all parties.
NLB Group members have regular engagements with
legal representatives of suppliers, aiming to ensure
appropriate business relationships and suppliers’
understanding and respect of sustainability-related
requirements.
The Group is committed to supporting local economies
and local communities’ welfare; therefore, it aims
to cooperate with local suppliers whenever this is
justified in line with its targets and policies. Local
suppliers are defined as those who are registered in
the countries where NLB Group operates (Slovenia,
Croatia, Serbia, Bosnia and Herzegovina, Montenegro,
North Macedonia, and Kosovo). Partnering with local
suppliers also reduces transport costs and contributes
to reducing emissions.
The standard requires the procurement process to
follow good governance principles, including respecting
contractual payment dates and avoiding payments
to sanctioned individuals. For banking members, the
standard payment term is 60 days from the invoice date,
with shorter terms (45, 30, 15 days) possible if agreed
upon. These terms apply to all suppliers, including SMEs,
across countries. The company has a system to review
and verify invoices, ensuring payments are made on
time. In 2024, there were no legal proceedings related to
payment delays.
Sustainability due
diligence
In line with procurement standards, all procurement
procedures require suppliers to operate ethically and
responsibly. Suppliers and their subcontractors must
prevent harmful practices, including corruption,
bribery, and discrimination, and adhere to NLB Group
sustainability-related requirements.
Sustainability and related due diligence are integrated
in the procurement procedures as follows:
• The supplier selection process starts with the request
for proposal specification of the services/goods that
will be the subject of purchase, which also includes
sustainability-related requirements, such as green
electricity, office paper with an FSC certificate, electric
cars, etc.
• All bidders must complete a questionnaire, which is
a formal tool for data gathering on environmental,
social, and human rights, as well as governance
practices of bidders and suppliers. For bidders to
become suppliers, they must meet legal, financial,
and non-financial criteria, including those related to
sustainability, and comply with predefined standards.
In addition to questionnaires, procurement officers
perform other monitoring activities, such as media
coverage on bidders and suppliers. If these criteria
and standards are not met, the bidder is not selected.
• Sustainability matters are also included in the
general provisions of the agreement (GPA), which
are signed by the majority of suppliers together with
the purchase contract. Thus, the supplier commits to
performing its contractual obligations, by adhering
to a comprehensive list of required environmental,
social, and governance practices, including
protecting human rights in its operations and its
own supply chain. In addition, the GPA stipulates
that the supplier's employees or its subcontractors
can report cases of non-compliance of the supplier's
commitments to the NLB grievance mechanism,
whereby NLB ensures discretion and protection of
the whistleblower’s identity in accordance with its
internal policy.

Suppliers with significant levels of engagement and
procurement value undergo an annual extended
assessment of their relationship with the NLB Group
member, including their sustainability practices. In
2024, the threshold was set at EUR 100,000. Suppliers
with low scores must prepare improvement measures
and their implementation is monitored by respective
procurement officers.
In addition, comprehensive due diligence is preformed
every three years, which includes the majority of
suppliers with an annual spend above a predetermined
threshold (ranging from EUR 10,000 to EUR 35,000,
subject to the size of the NLB Group banking member).
Based on the review of the completed questionnaires
and due diligence, NLB Group banking members
identify if there are any potential or actual regulations,
violations, and risks in suppliers’ operations. If these
are identified, correction measures are agreed and the
supplier must resolve them within the agreed time frame.
If a potential or existing supplier fails to ensure respect
for sustainability matters, including human rights, or
does not follow the correction measures, the NLB Group
banking member does not start to collaborate with such
companies or it terminates the contract, respectively.

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Human rights
The procurement procedures described above apply
also for human-rights related matters, including
workers’ rights. NLB Group banking members evaluate
whether potential or existing suppliers respect and
uphold human rights, including workers’ rights, and if
there are any risks associated with these matters.
The general approach is stipulated in the Group’s
human rights policy as well as the Standard for the
procurement. Since adoption of the policies in NLB,
they have been already implemented and harmonized
in all banking members, while in other members
the harmonization process is underway. NLB Group
members expect their suppliers to comply not only
with the financial but also non-financial and ESG
requirements, including:
• acting in compliance with the regulation on
environment and energy saving, health, security,
safety at work, social security, and respecting labour
law (and collective agreements).
• ensuring compliance with at least the following in its
operations (including along its own supply chain):
the right to free choice of employment, prohibition of
exploiting child labour, prohibition of discrimination,
prohibition of illegal work, the right to appropriate
payment, the right to appropriate working hours, the
right to organize and join trade unions and collective
bargaining, the right to respect one’s personality and
dignity, the right to health and safety, and the right to
diversity.
• when performing its business activities or business
activities of its subcontractors on any market, the
suppliers must operate in an ethical and socially
responsible manner and provide measures not
to use child labour, forced labour or slavery-like
working conditions, and not to abuse any human
rights in any way.

These requirements are included in due diligence
questionnaires that each bidder must complete at
the beginning of procurement process and confirm
that, among other ESG requirements, those related to
human rights are also met. In addition, suppliers must
confirm that they are acting in accordance with the
general terms and conditions of the contract, the NLB
Group Code of Conduct, and other internal regulations
governing responsible business practices. If these
requirements are not met, the bidder is not selected.
Due diligence reviews are executed prior to signing
a contract and in case non-compliance with legal
and sustainability-related requirements is identified
during the validity of the contract. If the suppliers do
not respect human rights or cannot guarantee this for
any reason, they cannot collaborate with NLB Group
banking members.
In addition, NLB Group banking members conduct
supplier reviews at least every three years. As part of this
process, suppliers provide information on whether they
respect human rights, the prohibition of child labour,
forced or compulsory labour, and other social impacts.
In 2025, we began monitoring for possible human
trafficking.
As part of the due diligence process, NLB Group
assesses whether suppliers have implemented
effective mechanisms for the anonymous reporting
and handling of labour law violations, significant
negative impacts on workers in the value chain, other
irregularities, and breaches of regulations, along with
ensuring corrective measures.
Before signing the contract, each potential supplier must
provide information on their established mechanisms
for anonymous reporting and addressing these issues.
If a supplier cannot provide this assurance, they must
submit additional clarification. If, after reviewing the
additional clarification, it is determined that the supplier
lacks an adequate reporting channel, a reporting
channel managed by a NLB Group member is included
in the supplier contract. The supplier must provide
proof that all employees have been informed about this
reporting channel. If this requirement cannot be fulfilled,
the potential supplier is disqualified.
Suppliers’ employees can also report violations via the
internet at NLB Whistler, a channel that provides full
anonymity and is widely accessible.
›› For a detailed description of the whistleblowing
mechanism, please refer to the chapter Whistleblower
protection.
Additionally, some banking addresses for reporting
irregularities. They regularly review and address such
reports, which can be made anonymously or with
personal data.
Progress
NLB Group has set a goal to have a zero tolerance for
suppliers’ harmful practices, including corruption,
bribery, and discrimination, and not adhering to the
sustainability-related requirements posed by NLB
Group and described in previous chapters.
Annual due diligence conducted in 2024 included most
of the Bank’s suppliers with an annual spend above
a predetermined threshold (ranging from EUR 10,000
to EUR 35,000, subject to the size of the NLB Group
banking member) and all new suppliers with contracts
signed in 2024 (2023). NLB Group executed 393 (212 in
2023) due diligence reviews which represents 56.8% (31%
in 2023) of spend based on the procurement process.
In 2024, NLB Group regular reviews and due diligence
of supplier operations found no harmful practices,
environmental or social impacts, human rights breaches,
or cases of child or forced labour. Consequently,
no supplier relationships within NLB Group were
terminated.

Appendices

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Financial
Report
The EU Taxonomy is a classification system designed to
determine the environmental sustainability of economic
activities within the European Union. For banks, it serves
as a crucial framework for evaluating and disclosing the
environmental impact of their investments and lending
practices. By adhering to the EU Taxonomy, banks
can identify and prioritize investments that contribute
to environmental objectives, such as climate change
mitigation and adaptation. This taxonomy provides
clear criteria and standards, enabling banks to assess
the alignment of their portfolios with sustainable
goals, mitigate risks associated with environmentally
harmful activities, and support the transition to a more
sustainable economy.
Compliance with the EU Taxonomy is mandated under
Article 8 and Article 10 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, amending Regulation
(EU) 2019/2088. This legislation establishes the criteria
for determining whether an economic activity is
environmentally sustainable and provides the basis
for the EU Taxonomy's implementation across various
sectors, including banking and finance.
Green Asset Ratio (GAR)
The Green Asset Ratio (GAR) within the framework
of the EU Taxonomy measures the proportion of a
bank's assets that meet the criteria for environmentally
sustainable economic activities. This ratio serves as a
key metric for stakeholders to assess how much of a
bank's portfolio supports environmental sustainability
objectives. Banks are required to report their GAR
as part of their sustainability reporting obligations,
ensuring transparency and accountability in their
sustainability efforts.
However, while the Green Asset Ratio enhances
transparency, it does not fully capture the transition
efforts of banks. A substantial portion of our portfolio
is excluded—for example, loans to smaller companies
and international non-EU business—meaning the actual
number of aligned activities is higher. Furthermore,
banks rely on counterparties for data, and since many
of these entities are at the early stages of their green
transformation, they may struggle to evaluate their
own sustainability. Therefore, GAR should be analyzed
alongside additional disclosed metrics and other relevant
information on banks’ efforts to finance the transition.
Mandatory Disclosures
For the first time, NLB discloses information about
Taxonomy alignment for all six environmental objectives
in the 2024 financial year.
The Draft Commission notice issued on December 21,
2023, aims to provide clarity and improve disclosure
requirements. Notably, the Green Asset Ratio (GAR)
flow disclosure should now include all newly acquired
exposures throughout the year, rather than only net
changes.
Our Calculation Approach
The Green Asset Ratio (GAR) is calculated as identified
taxonomy-aligned assets (numerator) divided by total
assets covered by the KPI (denominator). Data as of
the cut-off date 31.12.2023 was used. Exposures towards
central banks, central governments, supranational
entities, and the bank’s trading portfolio are excluded
from both the numerator and denominator, as they are
not covered by the KPI. Exposures to regional and local
public authorities and state-controlled entities, where
the use of proceeds is unknown, are also excluded from
both the numerator and denominator.
We have disclosed information related to all six
environmental objectives where actual data directly
published by counterparties is available.
To assess Taxonomy-related KPIs for non-financial
undertakings (NFRD corporates, i.e., corporates subject
to non-financial reporting requirements, including
taxonomy reporting), we use publicly available
information on the percentage of eligibility and
alignment of counterparties’ turnover-based (turnover)
and capital expenditure-based (CAPEX) metrics.
Explanations of the nature and objectives of Taxonomy-
aligned economic activities and the evolution of the
Taxonomy-aligned economic activities over time,
starting from the second year of implementation,
distinguishing between business-related and
methodological and data-related elements.
To determine household eligibility for KPIs, we consider
the entire portfolio of mortgage loans, with assets
subject to energy efficiency rules. For alignment KPIs
on the household portfolio, we focus on the "Purchase
and Ownership of Buildings" category under Delegated
Regulation 2021/2139, excluding the "Renovation"
category and "Motor vehicles" due to the lack of specific
information to identify green loans. We also include the
information on the purchases of electric vehicles for
households as taxonomy -aligned asset.
Regulatory disclosure requirement in accordance with Article 8
of the EU taxonomy regulation
Appendix 1: EU Taxonomy

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Table 65: Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation

Total environmentally
sustainable assets
(Turnover) (in 000 EUR)
KPI (Turnover - based)(ii)
KPI (Capex - based)(iii)
% coverage
(over total assets)(i)
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Main KPI
Green asset ratio (GAR) stock
258,974
1.34%
1.25%
69.15%
43.46%
30.85%
Total environmentally
sustainable activities
(Turnover)(in 000 EUR)
KPI (Turnover - based)(ii)
KPI (Capex - based)
% coverage
(over total assets)
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Additional KPIs
GAR (flow)
68,481
1.22%
0.84%
60.79%
28.51%
39.21%
Trading book
-
-
-
Financial guarantees
3,233
4.15%
13.21%
Assets under management
-
-
-
Fees and commissions income(ii)
-
-
-
Notes:
(i) Share (%) of assets covered by the KPI, over total assets.
(ii) based on the Turnover KPI of the counterparty
(iii) based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
The KPIs related to Trading book and Fees and commissions income are due for reporting from year 2026.
Criteria for Buildings:
For buildings built before December 31, 2020: The
building must have at least an energy performance
class A. Alternatively, it must be within the upper 15%
of the national or regional building stock in terms of
operational primary energy demand, demonstrated
by appropriate evidence comparing the asset’s
performance to national or regional benchmarks for
buildings constructed before December 31, 2020. This
distinction applies separately to residential and non-
residential buildings.
For buildings constructed after December 31, 2020: The
building must meet the criteria set out in Section 7.1 of
this Annex, applicable at the time of purchase.
For large non-residential buildings (with a rated thermal
input for heating systems, combined space heating
and ventilation systems, air-conditioning systems, or
combined air-conditioning and ventilation systems
above 290 kW), the building must be subject to energy
performance monitoring and assessment.
Description of the compliance with Regulation (EU)
2020/852 in the financial undertaking’s business
strategy, product design processes and engagement
with clients and counterparties
NLB Group as financial institution, Regulation (EU)
2020/852 includes in Business strategy, service
providing and engagement with clients through
different approaches, for example through due diligence
of clients as well issuing for example Green Bond. More
detailed description can be found in Sustainability
Statement (Chapters Sustainable Finance, Transition
Plan and S3 - Affected Communities.
Qualitative information on the alignment of trading
portfolios with Regulation (EU) 2020/852
NLB Group is not required to disclose quantitative
information on trading exposures, qualitative
information that demonstrates how our trading
portfolios align with Regulation (EU) 2020/852 are
disclosed in Sustainability Statement chapter ESG Bonds
in the Group’s banking book debt securities portfolio.
Additional or complementary information in support
of the financial undertaking’s strategies
NLB Group approach toward financing of Taxonomy
aligned economic activities are described in the
Sustainability Statement, chapter E1 – Climate change.

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Table 66: 1. Assets for the calculation of GAR (TURNOVER)_1/8
Disclosure reference date T
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
7,158,131
4,163,554
252,932
100,151
640
14,495
5,967
5,967
-
437
-
-
-
-
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
7,112,482
4,163,554
252,932
100,151
640
14,495
5,967
5,967
-
437
-
-
-
-
2 Financial undertakings
2,208,690
250,162
20,702
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
1,805,874
250,162
20,702
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
450,707
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
1,355,167
250,162
20,702
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
402,816
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
10,954
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
4,433
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
6,521
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
11,492
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
3,490
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
7,694
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
308
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
841,530
194,094
132,079
-
640
14,495
5,967
5,967
-
437
-
-
-
-
21
Loans and advances
772,855
193,978
132,079
-
640
14,495
5,967
5,967
-
437
-
-
-
22
Debt securities, including UoP
68,675
116
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
24 Households
3,850,031
3,719,298
100,151
100,151
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
3,717,814
3,717,814
98,667
98,667
-
-
-
-
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
132,217
1,484
1,484
1,484
-
-
28 Local governments financing
212,231
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
212,231
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
45,649
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
12,110,723
-
-
-
-
-
-
-
-
-
-
-
-
-

NLB Group
Annual Report 2024
310
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
33 Financial and Non-
financial undertakings
6,076,799
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
2,597,922
35
Loans and advances
2,597,905
36
of which loans collateralised
by commercial
immovable property
-
37
of which building
renovation loans
-
38
Debt securities
39
Equity instruments
17
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
3,478,877
41
Loans and advances
3,467,330
42
Debt securities
9,135
43
Equity instruments
2,412
44 Derivatives
71,418
45 On demand interbank loans
-
46 Cash and cash-related assets
540,282
47 Other categories of assets (e.g.
Goodwill, commodities etc.)
5,422,224
48 Total GAR assets
19,268,854
4,163,554
252,932
100,151
640
14,495
5,967
5,967
-
437
-
-
-
-
49 Assets not covered for
GAR calculation
8,596,041
50
Central governments and
Supranational issuers
4,999,206
51
Central banks exposure
3,577,239
52 Trading book
19,596
53 Total assets
27,864,895
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
77,904
669
42
-
-
-
3,191
3,191
234
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 67: 1. Assets for the calculation of GAR (TURNOVER)_2/8

NLB Group
Annual Report 2024
311
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
302
75
-
-
11
-
-
-
-
-
-
-
4,169,834
258,974
100,151
640
14,932
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
302
75
-
-
11
-
-
-
-
-
-
-
4,169,834
258,974
100,151
640
14,932
2 Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
250,162
20,702
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
250,162
20,702
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
250,162
20,702
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
302
75
-
-
11
-
-
-
-
-
-
-
200,374
138,121
-
640
14,932
21
Loans and advances
302
75
-
-
11
-
-
-
-
-
200,258
138,121
-
640
14,932
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
116
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24 Households
-
-
-
3,719,298
100,151
100,151
-
-
25
of which loans collateralised by
residential immovable property
-
3,717,814
98,667
98,667
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
1,484
1,484
1,484
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 68: 1. Assets for the calculation of GAR (TURNOVER)_3/8

NLB Group
Annual Report 2024
312
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
33 Financial and Non-
financial undertakings
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
35
Loans and advances
36
of which loans collateralised
by commercial
immovable property
37
of which building
renovation loans
38
Debt securities
39
Equity instruments
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44 Derivatives
45 On demand interbank loans
46 Cash and cash-related assets
47 Other categories of assets (e.g.
Goodwill, commodities etc.)
48 Total GAR assets
302
75
-
11
4,169,834
258,974
100,151
640
14,932
49 Assets not covered for
GAR calculation
50
Central governments and
Supranational issuers
51
Central banks exposure
52 Trading book
53 Total assets
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
-
-
-
-
-
70
-
-
-
-
-
-
3,930
3,233
-
-
234
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 69: 1. Assets for the calculation of GAR (TURNOVER)_4/8

NLB Group
Annual Report 2024
313
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 70: 1. Assets for the calculation of GAR (TURNOVER)_5/8
Disclosure reference date T - 1
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
10,413,876
3,476,162
157,973
84,175
601
14,495
-
-
-
-
-
-
-
-
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
10,353,396
3,476,162
157,973
84,175
601
14,495
-
-
-
-
-
-
-
-
2 Financial undertakings
1,474,013
235,243
16,877
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
1,274,660
235,243
16,877
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
297,166
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
977,494
235,243
16,877
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
199,353
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
5,446
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
2,889
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
2,557
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
3,243
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
3,033
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
210
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
957,104
72,674
56,921
-
601
14,495
-
-
-
-
-
-
-
-
21
Loans and advances
878,220
66,580
51,144
-
601
14,495
-
-
-
-
-
-
-
22
Debt securities, including UoP
78,884
6,094
5,777
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24 Households
7,672,026
3,168,245
84,175
84,175
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
3,168,245
3,168,245
84,175
84,175
-
-
-
-
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
-
28 Local governments financing
189,773
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
189,773
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
60,480
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
5,604,189
-
-
-
-
-
-
-
-
-
-
-
-
-

NLB Group
Annual Report 2024
314
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T - 1
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
33 Financial and Non-
financial undertakings
5,092,352
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
2,090,316
35
Loans and advances
2,088,998
36
of which loans collateralised
by commercial
immovable property
881,788
37
of which building
renovation loans
-
38
Debt securities
1,318
39
Equity instruments
-
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
3,002,036
41
Loans and advances
2,989,817
42
Debt securities
9,807
43
Equity instruments
2,412
44 Derivatives
37,407
45 On demand interbank loans
-
46 Cash and cash-related assets
470,901
47 Other categories of assets (e.g.
Goodwill, commodities etc.)
3,529
48 Total GAR assets
15,957,585
3,476,162
157,973
84,175
601
14,495
-
-
-
-
-
-
-
-
49 Assets not covered for
GAR calculation
9,775,289
50
Central governments and
Supranational issuers
3,996,027
51
Central banks exposure
5,763,444
52 Trading book
15,818
53 Total assets
25,732,874
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
91,625
1,074
815
12
39
-
-
-
-
-
1,074
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 71: 1. Assets for the calculation of GAR (TURNOVER)_6/8

NLB Group
Annual Report 2024
315
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T - 1
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
-
-
-
-
-
-
-
-
-
-
3,476,162
157,973
84,175
601
14,495
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
-
-
-
-
-
-
-
-
-
-
3,476,162
157,973
84,175
601
14,495
2 Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
235,243
16,877
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
235,243
16,877
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
235,243
16,877
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
72,674
56,921
-
601
14,495
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
66,580
51,144
-
601
14,495
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
6,094
5,777
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
24 Households
-
-
-
3,168,245
84,175
-
-
-
25
of which loans collateralised by
residential immovable property
-
3,168,245
84,175
84,175
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 72: 1. Assets for the calculation of GAR (TURNOVER)_7/8

NLB Group
Annual Report 2024
316
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T - 1
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
33 Financial and Non-
financial undertakings
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
35
Loans and advances
36
of which loans collateralised
by commercial
immovable property
37
of which building
renovation loans
38
Debt securities
39
Equity instruments
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44 Derivatives
45 On demand interbank loans
46 Cash and cash-related assets
47 Other categories of assets (e,g,
Goodwill, commodities etc,)
48 Total GAR assets
-
-
-
-
-
-
-
-
-
-
-
-
3,476,162
157,973
84,175
601
14,495
49 Assets not covered for
GAR calculation
50
Central governments and
Supranational issuers
51
Central banks exposure
52 Trading book
53 Total assets
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
-
-
-
-
25
-
-
-
-
-
-
-
2,173
815
12
39
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 73: 1.Assets for the calculation of GAR (TURNOVER)_8/8

NLB Group
Annual Report 2024
317
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 74: 2. GAR sector information (TURNOVER) _1/2
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Of which
environ-
mentally
sustainable
(CCM)
Of which
environ-
mentally
sustainable
(CCM)
Of which
environ-
mentally
sustainable
(CCA)
Of which
environ-
mentally
sustainable
(CCA)
Of which
environ-
mentally
sustainable
(SST)
Of which
environ-
mentally
sustainable
(SST)
Breakdown by sector - NACE 4 digits level (code and label)
1
02.10 Silviculture and other
forestry activities
1
-
-
-
-
-
2
20.16 Manufacture of plastics
in primary forms
10,064
-
-
-
-
-
3
21.20 Manufacture of
pharmaceutical preparations
-
-
-
-
-
-
4
24.42 Aluminium production
4,880
1,124
-
-
-
-
5
25.50 Forging and shaping metal
and powder metallurgy
33,358
53
-
-
-
-
6
33.17 Maintenance and repair of
other transport equipment
1
-
-
-
-
-
7
35.11 Production of electricity from
non-renewable sources
-
-
-
-
-
-
8
35.12 Transmission of electricity
59,111
-
-
-
-
-
9
35.13 Distribution of electricity
121,597
89,070
-
-
-
-
10
35.14 Trade of electricity
-
-
47,063
5,967
-
-
11
35.30 Steam and air
conditioning supply
55,716
25,245
-
-
-
-
12
36.00 Water collection,
treatment, and supply
9,491
-
-
-
-
-
13
42.12 Construction of railways
and underground railways
77
41
-
-
-
-
14
47.30 Retail sale of automotive
fuel in specialized stores
69,859
1,355
-
-
-
-
15
49.20 Freight rail transport
26,986
14,437
-
-
-
-
16
49.31 Urban and suburban
passenger land transport
6
3
-
-
-
-
17
49.50 Pipeline transport
21,129
-
-
-
-
-
18
52.10 Cargo handling
-
-
-
-
-
-
19
52.21 Supporting service activities
in land transport
168,404
-
-
-
-
-
20
52.23 Supporting service
activities in air transport
7,045
-
-
-
-
-
21
52.29 Logistics services
6,658
-
-
-
-
-
22
53.10 Universal postal
service activities
1,305
697
-
-
-
-
23
55.10 Hotels and similar
accommodation activities
7,673
-
-
-
-
-
24
61.10 Wired telecommunications
activities
74,202
7
-
-
-
-
25
64.20 Activities of holding
companies
1
-
-
-
-
-
26
70.10 Activities of head offices
10,489
45
-
-
-
-
27
71.12 Other engineering
activities and related
technical consultancy
1
-
-
-
-
-

NLB Group
Annual Report 2024
318
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Non-Financial
corporates (Subject
to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
Of which
environ-
mentally
sustainable
(CE)
Of which
environ-
mentally
sustainable
(CE)
Of which
environ-
mentally
sustainable
(PC)
Of which
environ-
mentally
sustainable
(PC)
Of which
environ-
mentally
sustainable
(Ecos)
Of which
environ-
mentally
sustainable
(Ecos)
Of which
environ-
mentally
sustainable
Of which
environ-
mentally
sustainable
Breakdown by sector - NACE 4 digits level (code and label)
1
02.10 Silviculture and other
forestry activities
-
-
-
-
-
-
1
-
2
20.16 Manufacture of plastics
in primary forms
-
-
-
-
-
-
10,064
-
3
21.20 Manufacture of
pharmaceutical preparations
-
-
11
-
-
-
11
-
4
24.42 Aluminium production
-
-
-
-
-
-
4,880
1,124
5
25.50 Forging and shaping metal
and powder metallurgy
-
-
-
-
-
-
33,358
53
6
33.17 Maintenance and repair of
other transport equipment
-
-
-
-
-
-
1
-
7
35.11 Production of electricity from
non-renewable sources
-
-
-
-
-
-
-
-
8
35.12 Transmission of electricity
-
-
-
-
-
-
59,111
-
9
35.13 Distribution of electricity
-
-
-
-
-
-
121,597
89,070
10
35.14 Trade of electricity
-
-
-
-
-
-
47,063
5,967
11
35.30 Steam and air
conditioning supply
-
-
-
-
-
-
55,716
25,245
12
36.00 Water collection,
treatment, and supply
-
-
-
-
-
-
9,491
-
13
42.12 Construction of railways
and underground railways
-
-
-
-
-
-
77
41
14
47.30 Retail sale of automotive
fuel in specialized stores
-
-
-
-
-
-
69,859
1,355
15
49.20 Freight rail transport
-
-
-
-
-
-
26,986
14,437
16
49.31 Urban and suburban
passenger land transport
-
-
-
-
-
-
6
3
17
49.50 Pipeline transport
-
-
-
-
-
-
21,129
-
18
52.10 Cargo handling
37,728
75
-
-
-
-
37,728
75
19
52.21 Supporting service activities
in land transport
-
-
-
-
-
-
168,404
-
20
52.23 Supporting service
activities in air transport
-
-
-
-
-
-
7,045
-
21
52.29 Logistics services
-
-
-
-
-
-
6,658
-
22
53.10 Universal postal
service activities
-
-
-
-
-
-
1,305
697
23
55.10 Hotels and similar
accommodation activities
-
-
-
-
-
-
7,673
-
24
61.10 Wired telecommunications
activities
-
-
-
-
-
-
74,202
7
25
64.20 Activities of holding
companies
-
-
-
-
-
-
1
-
26
70.10 Activities of head offices
-
-
-
-
-
-
10,489
45
27
71.12 Other engineering
activities and related
technical consultancy
-
-
-
-
-
-
1
-
Table 75: 2. GAR sector information (TURNOVER) _2/2

NLB Group
Annual Report 2024
319
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 76: 3. GAR KPI stock (TURNOVER) _1/6
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
21,61%
1,31%
0.52%
0.00%
0.08%
0.03%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
1,30%
0,11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
1,30%
0,11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0,00%
0,00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
1,30%
0,11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
1.01%
0.69%
0.00%
0.00%
0.08%
0.03%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
1.01%
0.69%
0.00%
0.00%
0.08%
0.03%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
19.30%
0.52%
0.52%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
19.29%
0.51%
0.51%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.01%
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
21.61%
1.31%
0.52%
0.00%
0.08%
0.03%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Table 77: 3. GAR KPI stock (TURNOVER) _2/6

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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
21.64%
1.34%
0.52%
0.00%
0.08%
25.52%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
1.30%
0.11%
0.00%
0.00%
0.00%
7.93%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
1.30%
0.11%
0.00%
0.00%
0.00%
6.48%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.62%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
1.30%
0.11%
0.00%
0.00%
0.00%
4.86%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.45%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.04%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.02%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.02%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.04%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.03%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
1.04%
0.72%
0.00%
0.00%
0.08%
3.02%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
1.04%
0.72%
0.00%
0.00%
0.08%
2.77%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.25%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
19.30%
0.52%
0.52%
0.00%
0.00%
13.82%
25
of which loans collateralised by
residential immovable property
19.29%
0.51%
0.51%
0.00%
0.00%
13.34%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.01%
0.01%
0.01%
0.00%
0.00%
0.47%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.76%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.76%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.16%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
21.64%
1.34%
0.52%
0.00%
0.08%
69.15%
Table 78: 3. GAR KPI stock (TURNOVER) _3/6

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Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 79: 3. GAR KPI stock (TURNOVER) _4/6
Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
21.78%
0.99%
0.53%
0.00%
0.09%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
1.47%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
1.47%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
1.47%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.46%
0.36%
0.00%
0.00%
0.09%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.42%
0.32%
0.00%
0.00%
0.09%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.04%
0.04%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
19.85%
0.53%
0.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
19.85%
0.53%
0.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
18.04%
0.82%
0.44%
0.00%
0.08%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

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Annual Report 2024
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Overview
MB Statement
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Table 80: 3. GAR KPI stock (TURNOVER) _5/6

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Overview
MB Statement
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Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
21.78%
0.99%
0.53%
0.00%
0.09%
21.78%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
1.47%
0.11%
0.00%
0.00%
0.00%
1.47%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
1.47%
0.11%
0.00%
0.00%
0.00%
1.47%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
1.47%
0.11%
0.00%
0.00%
0.00%
1.47%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.46%
0.36%
0.00%
0.00%
0.09%
0.46%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.42%
0.32%
0.00%
0.00%
0.09%
0.42%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.04%
0.04%
0.00%
0.00%
0.00%
0.04%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
19.85%
0.53%
0.00%
0.00%
0.00%
19.85%
25
of which loans collateralised by
residential immovable property

19.85%
0.53%
0.53%
0.00%
0.00%
19.85%
26
of which building
renovation loans

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
18.04%
0.82%
0.44%
0.00%
0.08%
18.04%
Table 81: 3. GAR KPI stock (TURNOVER) _6/6

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 82: 4. KPIs FlowT _1/3
% (compared to flow of
total eligible assets)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
41.67%
3.80%
0.92%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
7.55%
0.59%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
9.54%
0.74%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
13.38%
1.04%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
52.28%
52.12%
0.00%
0.05%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
55.11%
55.08%
0.00%
0.05%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
2.44%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
90.59%
2.38%
2.38%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
100.00%
2.53%
2.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.89%
0.89%
0.89%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing

30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
13.42%
1.22%
0.30%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

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Table 83: 4. GAR KPIs FlowT _2/3
% (compared to flow of
total eligible assets)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing

30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

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Table 84: 4. GAR KPIs FlowT _3/3
% (compared to flow of
total eligible assets)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
41.67%
3.80%
0.92%
0.00%
0.00%
19.58%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
7.55%
0.59%
0.00%
0.00%
0.00%
10.51%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
9.54%
0.74%
0.00%
0.00%
0.00%
8.31%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2.38%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
13.38%
1.04%
0.00%
0.00%
0.00%
5.93%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2.20%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.09%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.08%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
52.29%
52.12%
0.00%
0.05%
0.02%
0.96%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
55.11%
55.08%
0.00%
0.05%
0.02%
0.91%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
2.44%
0.00%
0.00%
0.00%
0.00%
0.05%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
90.59%
2.38%
2.38%
0.00%
0.00%
7.57%
25
of which loans collateralised by
residential immovable property
100.00%
2.53%
2.53%
0.00%
0.00%
6.85%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.89%
0.89%
0.89%
0.00%
0.00%
0.72%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.52%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.52%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
13.42%
1.22%
0.30%
0.00%
0.00%
60.79%

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% (compared to total eligible
off-balance sheet assets)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
1 Financial guarantees (FinGuar KPI)
0.859%
0.054%
0.000%
0.000%
0.000%
4.096%
4.096%
0.000%
0.300%
0.000%
0.000%
0.000%
0.000%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
Table 85: 5. FingGar, AuM KPIs stockT_1/3
% (compared to total eligible
off-balance sheet assets)
TOTAL
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally s
ustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI)
5.045%
4.150%
0.000%
0.000%
0.300%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
% (compared to total eligible
off-balance sheet assets)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of Biodiversity and
Ecosystems (Ecos)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
1 Financial guarantees (FinGuar KPI)
0.000%
0.000%
0.000%
0.000%
0.090%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
Table 86: 5.KPI off-balance sheet exposures (CAPEX) _2/3
Table 87: 5.KPI off-balance sheet exposures (CAPEX) _3/3

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Table 88: 1. Assets for the calculation of GAR (CAPEX)_1/8
Disclosure reference date T
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
7,158,131
4,103,099
218,652
100,151
2,610
3,682
21,015
21,015
-
14
-
-
-
-
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
7,112,482
4,103,099
218,652
100,151
2,610
3,682
21,015
21,015
-
14
-
-
-
-
2 Financial undertakings
2,208,690
228,905
19,501
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
1,805,874
228,905
19,501
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
450,707
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
1,355,167
228,905
19,501
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
402,816
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
10,954
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
4,433
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
6,521
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
11,492
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
3,490
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
7,694
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
308
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
841,530
154,896
99,000
-
2,610
3,682
21,015
21,015
-
14
-
-
-
-
21
Loans and advances
772,855
154,098
99,000
-
2,610
3,682
20,504
20,504
-
14
-
-
-
22
Debt securities, including UoP
68,675
798
-
-
511
511
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
24 Households
3,850,031
3,719,298
100,151
100,151
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
3,717,814
3,717,814
98,667
98,667
-
-
-
-
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
132,217
1,484
1,484
1,484
-
-
28 Local governments financing
212,231
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
212,231
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
45,649
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
12,110,723
-
-
-
-
-
-
-
-
-
-
-
-
-

NLB Group
Annual Report 2024
330
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
33 Financial and Non-
financial undertakings
6,076,799
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
2,597,922
35
Loans and advances
2,597,905
36
of which loans collateralised
by commercial
immovable property
37
of which building
renovation loans
-
38
Debt securities
39
Equity instruments
17
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
3,478,877
41
Loans and advances
3,467,330
42
Debt securities
9,135
43
Equity instruments
2,412
44 Derivatives
71,418
45 On demand interbank loans
-
46 Cash and cash-related assets
540,282
47 Other categories of assets (e,g,
Goodwill, commodities etc,)
5,422,224
48 Total GAR assets
19,268,854
4,103,099
218,652
100,151
2,610
3,682
21,015
21,015
-
14
-
-
-
-
49 Assets not covered for
GAR calculation
8,596,041
50
Central governments and
Supranational issuers
4,999,206
51
Central banks exposure
3,577,239
52 Trading book
19,596
53 Total assets
27,864,895
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
77,904
4,183
44
-
10,247
10,247
8
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 89: 1. Assets for the calculation of GAR (CAPEX)_2/8

NLB Group
Annual Report 2024
331
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
943
905
-
-
7
-
-
-
-
-
-
-
4,125,064
240,572
100,151
2,610
3,696
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
943
905
-
-
7
-
-
-
-
-
-
-
4,125,064
240,572
100,151
2,610
3,696
2 Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
228,905
19,501
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
228,905
19,501
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
228,905
19,501
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
20 Non-financial undertakings
943
905
-
-
7
-
-
-
-
-
-
-
176,861
120,920
-
2,610
3,696
21
Loans and advances
943
905
-
7
-
-
-
-
-
175,552
120,409
-
2,610
3,696
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
1,309
511
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
24 Households
-
-
-
-
3,719,298
100,151
100,151
-
-
25
of which loans collateralised by
residential immovable property
-
-
-
-
3,717,814
98,667
98,667
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
1,484
1,484
1,484
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 90: 1. Assets for the calculation of GAR (CAPEX)_3/8

NLB Group
Annual Report 2024
332
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
33 Financial and Non-
financial undertakings
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
35
Loans and advances
36
of which loans collateralised
by commercial
immovable property
37
of which building
renovation loans
38
Debt securities
39
Equity instruments
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44 Derivatives
45 On demand interbank loans
46 Cash and cash-related assets
47 Other categories of assets (e,g,
Goodwill, commodities etc,)
48 Total GAR assets
943
905
7
4,125,064
240,572
100,151
2,610
3,696
49 Assets not covered for
GAR calculation
50
Central governments and
Supranational issuers
51
Central banks exposure
52 Trading book
53 Total assets
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
-
-
-
-
46
-
-
-
-
-
-
-
14,476
10,291
-
-
8
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 91: 1. Assets for the calculation of GAR (CAPEX)_4/8

NLB Group
Annual Report 2024
333
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 92: 1. Assets for the calculation of GAR (CAPEX)_5/8
Disclosure reference date T - 1
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
10,413,876
3,549,016
202,449
84,175
2,610
3,682
20,504
20,504
-
52
-
-
-
-
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
10,353,396
3,549,016
202,449
84,175
2,610
3,682
20,504
20,504
-
52
-
-
-
-
2 Financial undertakings
1,474,013
226,557
19,274
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
1,274,660
226,557
19,274
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
297,166
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
977,494
226,557
19,274
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
199,353
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
5,446
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
2,889
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
2,557
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
3,243
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
3,033
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
210
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
957,104
154,214
99,000
-
2,610
3,682
20,504
20,504
-
52
-
-
-
-
21
Loans and advances
878,220
154,098
99,000
-
2,610
3,682
20,504
20,504
-
52
-
-
-
22
Debt securities, including UoP
78,884
116
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
24 Households
7,672,026
3,168,245
84,175
84,175
-
-
-
-
-
-

25
of which loans collateralised by
residential immovable property
3,168,245
3,168,245
84,175
84,175
-
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
-
28 Local governments financing
189,773
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
189,773
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
60,480
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
5,604,189
-
-
-
-
-
-
-
-
-
-
-
-
-

NLB Group
Annual Report 2024
334
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T - 1
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Total [gross]
carrying amount
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
33 Financial and Non-
financial undertakings
5,092,352
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
2,090,316
35
Loans and advances
2,088,998
36
of which loans collateralised
by commercial
immovable property
881,788
37
of which building
renovation loans
-
38
Debt securities
1,318
39
Equity instruments
-
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
3,002,036
41
Loans and advances
2,989,817
42
Debt securities
9,807
43
Equity instruments
2,412
44 Derivatives
37,407
45 On demand interbank loans
-
46 Cash and cash-related assets
470,901
47 Other categories of assets (e,g,
Goodwill, commodities etc,)
3,529
48 Total GAR assets
15,957,585
3,549,016
202,449
84,175
2,610
3,682
20,504
20,504
-
52
-
-
-
-
49 Assets not covered for
GAR calculation
9,775,289
50
Central governments and
Supranational issuers
3,996,027
51
Central banks exposure
5,763,444
52 Trading book
15,818
53 Total assets
25,732,874
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
91,625
4,183
44
-
10,247
7
-
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 93: 1.Assets for the calculation of GAR (CAPEX)_6/8

NLB Group
Annual Report 2024
335
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Disclosure reference date T - 1
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
3,569,520
222,953
84,175
2,610
3,734
1 Loans and advances,
debt securities and equity
instruments not HfT eligible
for GAR calculation
943
905
-
-
7
-
-
-
-
-
-
-
3,569,520
222,953
84,175
2,610
3,734
2 Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
226,557
19,274
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
226,557
19,274
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
226,557
19,274
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
20 Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
174,718
119,504
-
2,610
3,734
21
Loans and advances
-
-
-
-
-
-
-
-
-
174,602
119,504
-
2,610
3,734
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
116
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
24 Households
-
-
-
-
3,168,245
84,175
84,175
-
-
25
of which loans collateralised by
residential immovable property
-
-
-
-
3,168,245
84,175
84,175
-
-
26
of which building
renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 94: 1.Assets for the calculation of GAR (CAPEX)_7/8

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Performance Overview
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Report
Disclosure reference date T - 1
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
33 Financial and Non-
financial undertakings
34 SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
35
Loans and advances
36
of which loans collateralised
by commercial
immovable property
37
of which building
renovation loans
38
Debt securities
39
Equity instruments
40 Non-EU country counterparties
not subject to NFRD
disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44 Derivatives
45 On demand interbank loans
46 Cash and cash-related assets
47 Other categories of assets (e,g,
Goodwill, commodities etc,)
48 Total GAR assets
943
905
-
-
7
-
-
-
-
-
-
-
3,569,520
222,953
84,175
2,610
3,734
49 Assets not covered for
GAR calculation
50
Central governments and
Supranational issuers
51
Central banks exposure
52 Trading book
53 Total assets
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees
-
-
-
-
- 24.888
-
-
-
-
-
-
14.430
24.939
-
-
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Table 95: 1.Assets for the calculation of GAR (CAPEX)_8/8

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Table 96: 2.GAR sector information (CAPEX) _1/2
(in 000 EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Of which
environ-
mentally
sustainable
(CCM)
Of which
environ-
mentally
sustainable
(CCM)
Of which
environ-
mentally
sustainable
(CCA)
Of which
environ-
mentally
sustainable
(CCA)
Of which
environ-
mentally
sustainable
(SST)
Of which
environ-
mentally
sustainable
(SST)
Breakdown by sector - NACE 4 digits level (code and label)
1
02.10 Silviculture and other
forestry activities
1
-
-
-
-
-
2
20.16 Manufacture of plastics
in primary forms
10,064
-
-
-
-
-
3
21.20 Manufacture of
pharmaceutical preparations
-
-
-
-
-
-
4
24.42 Aluminium production
4,880
3,214
-
-
-
-
5
25.50 Forging and shaping metal
and powder metallurgy
33,358
1,204
-
-
-
-
6
33.17 Maintenance and repair of
other transport equipment
1
-
-
-
-
-
7
35.11 Production of electricity from
non-renewable sources
-
-
-
-
-
-
8
35.12 Transmission of electricity
59,111
-
-
-
-
-
9
35.13 Distribution of electricity
121,597
37,626
-
-
-
-
10
35.14 Trade of electricity
-
-
47,063
19,157
-
-
11
35.30 Steam and air
conditioning supply
55,716
37,931
-
-
-
-
12
36.00 Water collection,
treatment, and supply
9,491
-
-
-
-
-
13
42.12 Construction of railways
and underground railways
77
49
-
-
-
-
14
47.30 Retail sale of automotive
fuel in specialized stores
69,859
1,432
-
-
-
-
15
49.20 Freight rail transport
26,986
17,136
-
-
-
-
16
49.31 Urban and suburban
passenger land transport
6
4
-
-
-
-
17
49.50 Pipeline transport
21,129
-
-
-
-
-
18
52.10 Cargo handling
-
-
-
-
-
-
19
52.21 Supporting service activities
in land transport
-
-
168,404
1,347
-
-
20
52.23 Supporting service
activities in air transport
7,045
-
-
-
-
-
21
52.29 Logistics services
6,658
-
-
-
-
-
22
53.10 Universal postal
service activities
1,305
42
-
-
-
-
23
55.10 Hotels and similar
accommodation activities
7,673
318
-
-
-
-
24
61.10 Wired telecommunications
activities
74,202
15
-
-
-
-
25
64.20 Activities of holding
companies
1
-
-
-
-
-
26
70.10 Activities of head offices
10,489
29
-
-
-
-
27
71.12 Other engineering
activities and related
technical consultancy
1
-
-
-
-
-

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Statement
Financial
Report
(in 000 EUR)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of
Biodiversity and Ecosystems (Ecos)
TOTAL
Non-Financial
corporates (Subject
to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
Non-Financial
corporates
(Subject to NFRD)
SMEs and other
NFC not subject
to NFRD
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
[Gross] carrying
amount
Of which
environ-
mentally
sustainable
(CE)
Of which
environ-
mentally
sustainable
(CE)
Of which
environ-
mentally
sustainable
(PC)
Of which
environ-
mentally
sustainable
(PC)
Of which
environ-
mentally
sustainable
(Ecos)
Of which
environ-
mentally
sustainable
(Ecos)
Of which
environ-
mentally
sustainable
Of which
environ-
mentally
sustainable
Breakdown by sector - NACE 4 digits level (code and label)
1
02.10 Silviculture and other
forestry activities
-
-
-
-
-
-
1
-
2
20.16 Manufacture of plastics
in primary forms
-
-
-
-
-
-
10,064
-
3
21.20 Manufacture of
pharmaceutical preparations
-
-
11
-
-
-
11
-
4
24.42 Aluminium production
-
-
-
-
-
-
4,880
3,214
5
25.50 Forging and shaping metal
and powder metallurgy
-
-
-
-
-
-
33,358
1,204
6
33.17 Maintenance and repair of
other transport equipment
-
-
-
-
-
-
1
-
7
35.11 Production of electricity from
non-renewable sources
-
-
-
-
-
-
-
-
8
35.12 Transmission of electricity
-
-
-
-
-
-
59,111
-
9
35.13 Distribution of electricity
-
-
-
-
-
-
121,597
37,626
10
35.14 Trade of electricity
-
-
-
-
-
-
47,063
19,157
11
35.30 Steam and air
conditioning supply
-
-
-
-
-
-
55,716
37,931
12
36.00 Water collection,
treatment, and supply
-
-
-
-
-
-
9,491
-
13
42.12 Construction of railways
and underground railways
-
-
-
-
-
-
77
49
14
47.30 Retail sale of automotive
fuel in specialized stores
-
-
-
-
-
-
69,859
1,432
15
49.20 Freight rail transport
-
-
-
-
-
-
26,986
17,136
16
49.31 Urban and suburban
passenger land transport
-
-
-
-
-
-
6
4
17
49.50 Pipeline transport
-
-
-
-
-
-
21,129
-
18
52.10 Cargo handling
37,728
905
-
-
-
-
37,728
905
19
52.21 Supporting service activities
in land transport
-
-
-
-
-
-
168,404
1,347
20
52.23 Supporting service
activities in air transport
-
-
-
-
-
-
7,045
-
21
52.29 Logistics services
-
-
-
-
-
-
6,658
-
22
53.10 Universal postal
service activities
-
-
-
-
-
-
1,305
42
23
55.10 Hotels and similar
accommodation activities
-
-
-
-
-
-
7,673
318
24
61.10 Wired telecommunications
activities
-
-
-
-
-
-
74,202
15
25
64.20 Activities of holding
companies
-
-
-
-
-
-
1
-
26
70.10 Activities of head offices
-
-
-
-
-
-
10,489
29
27
71.12 Other engineering
activities and related
technical consultancy
-
-
-
-
-
-
1
-
Table 97: 2. GAR sector information (CAPEX) _2/2

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Table 98: 3. GAR KPI stock (CAPEX) _1/6
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
21.29%
1.13%
0.52%
0.01%
0.02%
0.11%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
1.19%
0.10%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
1.19%
0.10%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
1.19%
0.10%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.80%
0.51%
0.00%
0.01%
0.02%
0.11%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.80%
0.51%
0.00%
0.01%
0.02%
0.11%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
19.30%
0.52%
0.52%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
19.29%
0.51%
0.51%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.01%
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
21.29%
1.13%
0.52%
0.01%
0.02%
0.11%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

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Performance Overview
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Financial
Report
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Table 99: 3. GAR KPI stock (CAPEX) _2/6

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Overview
MB Statement
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Performance Overview
Segment Analysis
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Statement
Financial
Report
Disclosure reference date T
% (compared to total covered
assets in the denominator)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL (CCM)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
21.41%
1.25%
0.52%
0.01%
0.02%
25.52%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
1.19%
0.10%
0.00%
0.00%
0.00%
7.93%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
1.19%
0.10%
0.00%
0.00%
0.00%
6.48%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.62%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
1.19%
0.10%
0.00%
0.00%
0.00%
4.86%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.45%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.04%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.02%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.02%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.04%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.03%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.92%
0.63%
0.00%
0.01%
0.02%
3.02%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.91%
0.62%
0.00%
0.01%
0.02%
2.77%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.01%
0.00%
0.00%
0.00%
0.00%
0.25%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
19.30%
0.52%
0.52%
0.00%
0.00%
13.82%
25
of which loans collateralised by
residential immovable property

19.29%
0.51%
0.51%
0.00%
0.00%
13.34%
26
of which building
renovation loans

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans

0.01%
0.01%
0.01%
0.00%
0.00%
0.47%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.76%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.76%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.16%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
21.41%
1.25%
0.52%
0.01%
0.02%
69.15%
Table 100: 3. GAR KPI stock (CAPEX) _3/6

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MB Statement
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Business Report
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Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 101: 3. GAR KPI stock (CAPEX) _4/6
Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
22.24%
1.27%
0.53%
0.02%
0.02%
0.13%
0.13%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
1.42%
0.12%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
1.42%
0.12%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
1.42%
0.12%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.97%
0.62%
0.00%
0.02%
0.02%
0.13%
0.13%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.97%
0.62%
0.00%
0.02%
0.02%
0.13%
0.13%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
19.85%
0.53%
0.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
19.85%
0.53%
0.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
22.24%
5.70%
2.37%
0.07%
0.10%
0.58%
0.58%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

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Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.03%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Table 102: 3. GAR KPI stock (CAPEX) _5/6

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Disclosure reference date T -1
% (compared to total covered
assets in the denominator)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL (CCM)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
22.37%
1.40%
0.53%
0.02%
0.02%
22.37%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
1.42%
0.12%
0.00%
0.00%
0.00%
1.42%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
1.42%
0.12%
0.00%
0.00%
0.00%
1.42%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
1.42%
0.12%
0.00%
0.00%
0.00%
1.42%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
1.10%
0.75%
0.00%
0.02%
0.02%
1.10%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
1.10%
0.75%
0.00%
0.02%
0.02%
1.10%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
19.85%
0.53%
0.53%
0.00%
0.00%
19.85%
25
of which loans collateralised by
residential immovable property

19.85%
0.53%
0.53%
0.00%
0.00%
19.85%
26
of which building
renovation loans

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
100.60%
6.31%
2.37%
0.07%
0.11%
22.84%
Table 103: 3. GAR KPI stock (CAPEX) _6/6

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Report
Table 104: 4.GAR KPIs FlowC _1/3
% (compared to flow of
total eligible assets)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of Water
and Marine Resources (SST)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
41.13%
2.62%
0.92%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
6.19%
0.50%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
7.83%
0.63%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
10.97%
0.88%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
56.01%
29.07%
0.00%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
58.24%
30.72%
0.00%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
16.76%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
90.59%
2.38%
2.38%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
100.00%
2.53%
2.53%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.89%
0.89%
0.89%
0.00%
0.00%
0.00%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32 Total GAR assets
13.24%
0.84%
0.30%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

NLB Group
Annual Report 2024
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Overview
MB Statement
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Key Highlights
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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Table 105: 4.GAR KPIs FlowC _2/3
% (compared to flow of
total eligible assets)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralised by
residential immovable property
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing

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Table 106: 4.GAR KPIs FlowC _3/3
% (compared to flow of
total eligible assets)
Protection and Restoration of Biodiversity and Ecosystems (Ecos)
TOTAL
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1 Loans and advances.
debt securities and equity
instruments not HfT eligible
for GAR calculation
0.00%
0.00%
0.00%
0.00%
41.13%
2.62%
0.92%
0.00%
0.00%
19.58%
2 Financial undertakings
0.00%
0.00%
0.00%
0.00%
6.19%
0.50%
0.00%
0.00%
0.00%
10.51%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
7.83%
0.63%
0.00%
0.00%
0.00%
8.31%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2.38%
5
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
10.97%
0.88%
0.00%
0.00%
0.00%
5.93%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2.20%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
14
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.09%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
18
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.08%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20 Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
56.02%
29.07%
0.00%
0.03%
0.00%
0.96%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
58.25%
30.72%
0.00%
0.03%
0.00%
0.91%
22
Debt securities. including UoP
0.00%
0.00%
0.00%
0.00%
16.76%
0.00%
0.00%
0.00%
0.00%
0.05%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24 Households
90.59%
2.38%
2.38%
0.00%
0.00%
7.57%
25
of which loans collateralised by
residential immovable property
100.00%
2.53%
2.53%
0.00%
0.00%
6.85%
26
of which building
renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.89%
0.89%
0.89%
0.00%
0.00%
0.72%
28 Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.52%
29
Housing financing

0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.52%
31 Collateral obtained
by taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.01%
32 Total GAR assets
0.00%
0.00%
0.00%
0.00%
13.24%
0.84%
0.30%
0.00%
0.00%
60.79%

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% (compared to total eligible
off-balance sheet assets)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Sustainable Use and Protection of
Water and Marine Resources (SST)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
1 Financial guarantees (FinGuar KPI)
5.369%
0.056%
0.000%
0.000%
0.000%
13.153%
13.153%
0.000%
0.010%
0.000%
0.000%
0.000%
0.000%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
Table 107: 5.KPI off-balance sheet exposures (CAPEX)_1/3
% (compared to total eligible
off-balance sheet assets)
TOTAL
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally s
ustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
1 Financial guarantees (FinGuar KPI)
18.582%
13.210%
0.000%
0.000%
0.010%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
% (compared to total eligible
off-balance sheet assets)
Transition to a Circular Economy (CE)
Pollution Prevention and Control (PC)
Protection and Restoration of Biodiversity and
Ecosystems (Ecos)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
1 Financial guarantees (FinGuar KPI)
0.000%
0.000%
0.000%
0.000%
0.059%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
2 Assets under management (AuM KPI)
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which debt securities
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%

Of which equity instruments
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
0.000%
Table 108: 5.KPI off-balance sheet exposures (CAPEX) _2/3
Table 109: 5.KPI off-balance sheet exposures (CAPEX) _3/3

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Nuclear and fossil gas reporting
In accordance with Article 8(6), (7) and (8) of the amended Disclosures Delegated Act NLB prepared the exposure to nuclear energy and fossil
gas energy sectors i. The latter act outlines technical screening criteria and conditions under which activities in energy sector are qualified as
sustainable under the EU Taxonomy.
To calculate KPI’s, data available for this year's disclosure from NFRD undertakings has been used. Limited data availability for this year resulted
from providing complete and accurate representation of exposures to these activities.
With ongoing advancements in regulatory reporting practices and continual efforts to improve data collection, we anticipate a progressive
enhancement in the quality of available data. This improvement trajectory will facilitate more precise and thorough analyses of exposures related to
nuclear energy and fossil gas activities.
Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of
innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the
fuel cycle.
NO
2.
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations
to produce electricity or process heat, including for the purposes of district heating or industrial processes such as
hydrogen production, as well as their safety upgrades, using best available technologies.
NO
3.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce
electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen
production from nuclear energy, as well as their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities
that produce electricity using fossil gaseous fuels.
NO
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/
cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation
facilities that produce heat/cool using fossil gaseous fuels.
NO
Table 110: Template 1 Nuclear and fossil gas related activities, turnover- and CapEx-based

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Table 111: Template 2 Taxonomy-aligned economic activities (denominator)
TURNOVER
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
2.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
3.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
4.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
5.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
6.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1
to 6 above in the denominator of the applicable KPI
258,974
100.00%
252,932
100.00%
5,967
100.00%
8.
Total applicable KP
258,974
100.00%
252,932
100.00%
5,967
100.00%
CAPEX
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
2.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
3.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
4.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
5.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
6.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0.00%
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1
to 6 above in the denominator of the applicable KPI
240,572
100.00%
218,652
100.00%
21,015
100.00%
8.
Total applicable KP
240,572
100.00%
218,652
100.00%
21,015
100.00%

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TURNOVER
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
2.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
3.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
4.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
5.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
6.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1
to 6 above in the nominator of the applicable KPI
258,974
100.00%
252,932
100.00%
5,967
100.00%
8.
Total amount and proportion of taxonomy-aligned economic activities in the numerator of the
applicable KPI
258,974
100.00%
252,932
100.00%
5,967
100.00%
Table 112: Template 3 Taxonomy-aligned economic activities (numerator)

CAPEX
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
2.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
3.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
4.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
5.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
6.
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation 2021/2139 in the nominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1
to 6 above in the nominator of the applicable KPI
240,572
100.00%
218,652
100.00%
21,015
100.00%
8.
Total amount and proportion of taxonomy-aligned economic activities in the numerator of the
applicable KPI
240,572
100.00%
218,652
100.00%
21,015
100.00%

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TURNOVER
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaxonomyeligible but not taxonomy-aligned economic
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
2.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
3.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
4.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
5.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
6.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy eligible but not taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI
3,910,860
100.00%
3,910,622
100.00%
0
100.00%
8.
Total amount and proportion of taxonomy eligible but not taxonomyaligned economic
activities in the denominator of the applicable KPI
3,910,860
100.00%
3,910,622
100.00%
0
100.00%
CAPEX
Amount and proportion (the information is to be presented in monetary amounts and as percentages)
(in 000 EUR)
TOTAL
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Economic activities
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomyaxonomyeligible but not taxonomy-aligned economic
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
2.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
3.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
4.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
5.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
6.
Amount and proportion of taxonomyeligible but not taxonomy-aligned economic activity
referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
0.00
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy eligible but not taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI
3,884,492
100.00%
3,884,447
100.00%
0
100.00%
8.
Total amount and proportion of taxonomy eligible but not taxonomyaligned economic
activities in the denominator of the applicable KPI
3,884,492
100.00%
3,884,447
100.00%
0
100.00%
Table 113: Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities

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TURNOVER
CAPEX
Economic activities
Amount
%
Amount
%
1.
"Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with
Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI"
0
0.00%
0
0.00%
2.
"Amount and proportion of economic activity referred to in row 2 of Template 1 that is taxonomy-non-eligible in accordance with
Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI"
0
0.00%
0
0.00%
3.
Amount and proportion of economic activity referred to in row 3 of Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0
0.00%
4.
Amount and proportion of economic activity referred to in row 4 of Template 1 that is taxonomy-non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0
0.00%
5.
Amount and proportion of economic activity referred to in row 5 of Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0
0.00%
6.
Amount and proportion of economic activity referred to in row 6 of Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI
0
0.00%
0
0.00%
7.
Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
15,099,020
100.00%
15,143,790
100.00%
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI’
15,099,020
100.00%
15,143,790
100.00%
Table 114: Template 5 Taxonomy non-eligible economic activities

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Appendix 2: Methodological outline for
operational GHG emissions calculation
Table 115: Methodological outline for operational GHG emission calculation
Scope
Reported
metrics
Definition
Measure-ment
units
Reporting
units
Methodology and emission factors
Scope
1 - 1.1.1
Fuel Combustion
[pellets,
biomass]
Carbon emissions related to
consumption of natural gas
m3, kWh-GCV,
MWh-GCV,
conversion
factor from GCV
to NCV is 0.9,
conversion factor
from m3 to kWh
is 9.47 kWh/m3
t CO2eq
Consumption data is obtained in the following accuracy and priority manner:
1. Consumption data as provided by invoicing from the relevant utility company.
2. In cases, where the NLB Group member does not utilize the whole floor, consumption data were provided either i) by the
building manager based on a meter reading or ii) the renting provider based on a meter reading and proportional sharing
principle.
3. In cases where data were not available or costs were fixed per m2, a location benchmark is created [m3/m2] by dividing the
location's consumption [m3] in the same period but a different year by the occupied floor area [m2].
Each entity's calculation spreadsheet includes information on how energy consumption data has been attributed for each
branch.
Emission factors for this category are presented below (Scope 1).
Scope
1 - 1.2
Fuel Combustion
[heating oil]
Carbon emissions related to
consumption of heating oil
l, km
t CO2eq
Consumption data is provided by invoicing from the relevant heating oil Provider. Each entity's calculation spreadsheet
includes information on how energy consumption data has been attributed for each branch.
Emission factors for this category are presented below (Scope 1).
Scope
1 - 1.3
Fuel Combustion
[liquid petroleum
gas]
Carbon emissions related
to consumption of liquid
petroleum gas
Sm3
t CO2eq
Consumption data is obtained by invoicing from the relevant utility companyIf another unit used, the calculation is made in m3
(=Sm3).
Each entity's calculation spreadsheet includes information on how energy consumption data has been attributed for each branch.
Emission factors for this category are presented below (Scope 1).
Scope
1 - 1.1.4
Fuel Combustion
[pellets,
biomass]
Zero-emission source
kg
t CO2eq
Consumption data is provided by invoicing from the relevant pellet provider.
Emission factors for this category are presented below (Scope 1).
Scope
1 - 1.2
Vehicle Fleet
(Mobile
combustion)
[gasoline, diesel]
Carbon emissions related to
NLB Group's own fleet travel
l, km
t CO2eq
Data is obtained in the following accuracy and priority manner:
1. Information on the distance [km] as provided by the fleet managers.
2. Consumption data [l] as provided by the invoices from the fuel companies per relevant vehicles (reg. plate).
3. Consumption data [l/km] as provided by the fleet managers.
Emission factors for this category are presented below (Scope 1).
Scope
1 - 1.3
Refrigerants
GHG emissions related to
consumption of gases intended
for cooling purposes
kg
t CO2eq
Consumption data is obtained in the following accuracy and priority manner:
1. Consumption data as provided from invoices for maintenance of added refrigerant.
2. Refrigerant quantity data from HVAC system, 10% of yearly leakage.
Emissions factors based on IPCC, Assessment report AR5.
Emissions factors for this category are presented below (Scope 1).
Scope
2- 2.1
Electricity
(market-based)
Carbon emissions related
to purchased electricity
consumed by NLB Group
kWh
t CO2eq
Consumption data is obtained in the following accuracy and priority manner:
1. Consumption data as provided by invoicing from the relevant utility company.
2. In cases, where NLB Group member does not utilize the whole floor, consumption data were provided either i) by the building
manager based on a meter reading or ii) the renting provider based on a meter reading and proportional sharing principle.
3. In cases where data were not available or costs were fixed per m2, a location benchmark is created [kWh/m2] by dividing the
location's consumption [kWh] in the same period but a different year by the occupied floor area [m2].
Energy mix data with regard to electric energy production sources is obtained in the following accuracy and priority manner:
1. Data as provided by the electricity suppliers.
2. Where electricity suppliers have not provided this data, national electricity energy mix data is used.
In the case of electric vehicles, an location-based emissions factor is used as there is no data on electricity source for EV
charging.
Emissions factors for market-based emissions are used based on Guarantees of Origin or RES and nuclear electricity, otherwise
residual mix obtained from national or international databases (Slovene Energy Agency, AIB for other countries and Electricity
Map for Kosovo and North Macedonia).
Emissions factors for this category are presented below (Scope 2).

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Scope
2- 2.1
Electricity
(location-based)
Carbon emissions related
to purchased electricity
consumed by NLB Group
kg
t CO2eq
As for electricity (market-based),emissions factors for location-based emissions are used from
national or international databases – production mix (for Slovenia – Slovene Energy Agency,
AIB for other countries and Electricity Map for Kosovo and North Macedonia).
Emissions factors for this category are presented below (Scope 2).
Scope
2- 2.2
District heating
(location-based)
Carbon emissions related
to consumption of heat
from district heating
km
t CO2eq
Consumption data is obtained in the following accuracy and priority manner:
1. Consumption data as provided by invoicing from the relevant utility company.
2. In cases, where NLB Group member does not utilize the whole floor, consumption data
were provided either i) by the building manager based on a meter reading or ii) the renting
provider based on a meter reading and proportional sharing principle.
3. In cases where data were not available or costs were fixed per m2, a location benchmark is created [kWh/m2] by
dividing the location's consumption [kWh] in the same period but a different year by the occupied floor area [m2].
Each entity's calculation spreadsheet includes information on how energy
consumption data has been attributed for each branch.
Market based emission factors are used from DH producers, where data are known, otherwise
location based emission factor is used. For location-based emission factor for Slovenia is used for
all countries, due to regional similarities,as acknowledged by GHG Protocol (in absence of market-
based emissions factors, location-based factors can be used for market-based calculations).
Emissions factors for this category are presented below (Scope 2).
Scope
3 – Cat. 1
Purchase of
goods and
services
Carbon emissions related
to production/supply
of paper and water
km, type of
transport
t CO2eq
Water consumption data was used either from invoices or estimated. No estimation method is prescribed by the methodology.
Paper data are supplied by each entity using data on paper monitoring in the Paperless Office project. For all countries,
data from the UK Government, Department for Energy Security & Net Zero (former DEFRA), https://assets.publishing.
service.gov.uk/media/6722567487df31a87d8c497e/ghg-conversion-factors-2024-full_set__for_advanced_users__v1_1.xlsx.
Emissions factors for this category are presented below (Scope 3).
Scope
3 – Cat. 5
Waste in
operations
Carbon emissions related to
waste generated in offices
t CO2eq
For all countries data from UK UK Government, Department for Energy Security & Net Zero
(former DEFRA), https://assets.publishing.service.gov.uk/media/6722567487df31a87d8c497e/
ghg-conversion-factors-2024-full_set__for_advanced_users__v1_1.xlsx.
Emission factors for this category are presented below (Scope 3).
Scope
3 – Cat. 6
Business travel
Carbon emissions caused
by business travel
t CO2eq
Data from the company’s IT database on business travel in km and type of transport. In the case of public transport, for all
countries data from the UK Government, Department for Energy Security & Net Zero (former DEFRA), https://assets.publishing.
service.gov.uk/media/6722567487df31a87d8c497e/ghg-conversion-factors-2024-full_set__for_advanced_users__v1_1.xlsx.
In the case of airplane emissions, data from airline tickets is used or the International Civil Aviation Organization
(ICAO) calculator is used: https://www.icao.int/ENVIRONMENTAL-PROTECTION/CarbonOffset/Pages/default.aspx.
If data on the business trip is not in a format appropriate for calculation with the ICAO method, data from the UK
Government, Department for Energy Security & Net Zero (former DEFRA) is used.https://assets.publishing.service.gov.
uk/media/6722567487df31a87d8c497e/ghg-conversion-factors-2024-full_set__for_advanced_users__v1_1.xlsx.
Emission factors for this category are presented below (scope 3).
Scope
3 – Cat. 7
Employees
commuting to
and from work
Carbon emissions caused
by employees’ commute
to and from work
Anonymized data is obtained from internal HR databases. Selected based on data estimation of driving type. The
emissions factors source for Slovenia is the Jozef Stefan Institute, Energy Efficiency Centre; for other countries data
from the UK Government, Department for Energy Security & Net Zero (former DEFRA), https://assets.publishing.service.
gov.uk/media/6722567487df31a87d8c497e/ghg-conversion-factors-2024-full_set__for_advanced_users__v1_1.xlsx.
Emission factors for this category are presented below (scope 3).
Scope
Reported
metrics
Definition
Measure-ment units
Reporting
units
Methodology and emission factors

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Table 116: GHG Emission Factors
Scope 1
Emission source
Country
EF Source
2024
Unit
Energy source
Heating oil
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.268
kgCO2eq/kWh
LPG
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.228
kgCO2eq/kWh
Natural gas
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.204
kgCO2eq/kWh
Gasoline
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.251
kgCO2eq/kWh
Diesel
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.269
kgCO2eq/kWh
Biomass
All countries
IJS-CEU based on National inventory report, ARSO, Conversion to GHG with GWP AR5
0.034
kgCO2eq/kWh
Refrigerant
R410A
All countries
UK Defra
1,924
kgCO2eq/kg (AR5)
R417A
All countries
UK Defra
2,127
kgCO2eq/kg (AR5)
R422D
All countries
UK Defra
2,473
kgCO2eq/kg (AR5)
R134A
All countries
UK Defra
1,300
kgCO2eq/kg (AR5)
R1234f
All countries
UK Defra
1
kgCO2eq/kg (AR5)
R407C
All countries
UK Defra
1,624
kgCO2eq/kg (AR5)
R22
All countries
UK Defra
1,760
kgCO2eq/kg (AR5)
R32
All countries
UK Defra
677
kgCO2eq/kg (AR5)
R422A
All countries
UK Defra
2,847
kgCO2eq/kg (AR5)
Scope 2
Emission source
Country
EF Source
2024
Unit
Market based
Electricity
Slovenia
Agencija RS
0.459
kgCO2/kWh
Electricity
Slovenia TR3
Agencija RS
0.000
kgCO2/kWh
Electricity
BIH Banja Luka
AIB, Residual mix
0.720
kgCO2/kWh
Electricity
BIH Sarajevo
AIB, Residual mix
0.720
kgCO2/kWh
Electricity
Črna Gora Podgorica
AIB, Residual mix
0.748
kgCO2/kWh
Electricity
Srbija Beograd
AIB, Residual mix
0.967
kgCO2/kWh
Electricity
Srbija Beograd KB
AIB, Residual mix
0.967
kgCO2/kWh
Electricity
Makedonija Skopje
Electricity Map, Production mix
0.543
kgCO2eq/kWh
Electricity
Kosovo Prishtina
Electricity Map, Production mix
0.820
kgCO2eq/kWh
Electricity
Croatia
AIB, Residual mix
0.550
kgCO2/kWh
Electricity
Slovenia - Petrol d.d.
Petrol
0.390
kgCO2/kWh
Electricity
Slovenia - Energija Plus
Energija Plus
0.405
kgCO2/kWh
Electricity
Slovenia - E3
E3
0.433
kgCO2/kWh
Electricity
Slovenia - Elektro Energija
Elektro Energija
0.000
kgCO2/kWh
Electricity
Makedonija Skopje 2024
IJS-CEUI considering contract mix
0.158
kgCO2eq/kWh
Market-based
District heating
Slovenia - Energetika LJ
Energetika LJ
0.47
kgCO2/kWh
District heating
Slovenia - KP Velenje
KP Velenje
0.28
kgCO2/kWh
Location-based
Electricity
Slovenia
IJS-CEU
0.234
kgCO2eq/kWh
Electricity
BIH
AIB, Production mix
0.701
kgCO2/kWh

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Electricity
Montenegro
AIB, Production mix
0.467
kgCO2/kWh
Electricity
Serbia
AIB, Production mix
0.767
kgCO2/kWh
Electricity
North Macedonia
Electricity Map, Production mix
0.543
kgCO2eq/kWh
Electricity
Kosovo
Electricity Map, Production mix
0.820
kgCO2eq/kWh
Electricity
Croatia
AIB, Production mix
0.177
kgCO2/kWh
Location-Based
District heating
Slovenia
IJS-CEU
0.269
kgCO2eq/kWh
District heating
BIH-BA
IJS-CEU
0.269
kgCO2eq/kWh
District heating
Biomasa
IJS-CEU based on ARSO data
0.034
kgCO2eq/kWh
District heating
Other Countries
IJS-CEU
0.269
kgCO2eq/kWh
District heating
Slovenia NLB Lease&go
IJS-CEU based on ARSO data
0.204
kgCO2eq/kWh
District heating
Biomass
See Scope 1 above
0.034
kgCO2eq/kWh
District heating
Natural gas
See Scope 1 above
0.204
kgCO2eq/kWh
District heating
Heating oil
See Scope 1 above
0.268
kgCO2eq/kWh
Vehicles
Electricity_EV
Slovenia
Location-based EF
0.234
kgCO2eq/kWh
Electricity_EV
BIH
Location-based EF
0.701
kgCO2/kWh
Electricity_EV
Montenegro
Location-based EF
0.467
kgCO2/kWh
Electricity_EV
Serbia
Location-based EF
0.767
kgCO2/kWh
Electricity_EV
North Macedonia
Location-based EF
0.543
kgCO2eq/kWh
Electricity_EV
Kosovo
Location-based EF
0.820
kgCO2eq/kWh
Electricity_EV
Croatia
Location-based EF
0.177
kgCO2/kWh
Emissions source
Country
EF Source
2024
Unit
Scope 3
Emission source
Country
EF Source
2024
Unit
3.1 Purchased goods
Water
All countries
UK Defra (Water supply)
0.153
kgCO2eq/m3
Paper
All countries
UK Defra (Material use; Paper)
1.339
kgCO2eq/kg
3.3 WTT
WTT-Heating oil
All countries
UK Defra, WTT fuels, Gas oil, Net NCV
0.063
[kgCO2eq/kWh]
WTT-LPG
All countries
UK Defra, WTT fuels, NET NCV
0.027
[kgCO2eq/kWh]
WTT-Natural gas
All countries
UK Defra, WTT fuels, NET NCV
0.033
[kgCO2eq/kWh]
WTT-Gasoline
All countries
UK Defra, WTT fuels, Average biofuel blend, NET NCV
0.065
[kgCO2eq/kWh]
WTT-Diesel
All countries
UK Defra, WTT fuels, Average biofuel blend, NET NCV
0.062
[kgCO2eq/kWh]
WTT-Other heating
All countries
UK Defra, WTT bioenergy, Wood pellets
0.037
[kgCO2eq/kWh]
3.5 Waste
Waste
All countries
UK Defra (Plastics: average plastics)
0.009
kgCO2eq/kg
3.6 Work commute and
3.7 Business travel
public transport
Slovenia
IJS
0.079
[kgCO2eq/pkm]
on foot
Slovenia

0
[kgCO2eq/pkm]
personal car
Slovenia
IJS
0.138
[kgCO2eq/pkm]
Scope 2
Emission source
Country
EF Source
2024
Unit

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company car
Included in scope 1

[kgCO2eq/pkm]
electric car
Slovenia
UK Defra
0.0442
[kgCO2eq/pkm]
bicycle
Slovenia
IJS
0
[kgCO2eq/pkm]
electric scooter
Slovenia
IJS
0.03
[kgCO2eq/pkm]
motorcycle / moped
Slovenia
UK Defra
0.1009
[kgCO2eq/pkm]
bus
Slovenia
IJS
0.079
[kgCO2eq/pkm]
train
Slovenia
IJS
0.048
[kgCO2eq/pkm]
electric bike
Slovenia
UK Defra
0.014
[kgCO2eq/pkm]
taxi
Slovenia
IJS
0.089
[kgCO2eq/pkm]
airplane
Slovenia
UK Defra, International, average passenger, Without RF
0.1029
[kgCO2eq/pkm]
3.6 Work commute and
3.7 Business travel
public transport
Other countries
UK Defra
0.10846
[kgCO2eq/pkm]
on foot
Other countries

0
[kgCO2eq/pkm]
personal car
Other countries
UK Defra
0.16691
[kgCO2eq/pkm]
company car
Included in scope 1

[kgCO2eq/pkm]
electric car
Other countries
UK Defra
0.0442
[kgCO2eq/pkm]
bicycle
Other countries
UK Defra
0
[kgCO2eq/pkm]
electric scooter
Other countries
UK Defra
0.03
[kgCO2eq/pkm]
motorcycle / moped
Other countries
UK Defra
0.1009
[kgCO2eq/pkm]
bus
Other countries
UK Defra
0.10846
[kgCO2eq/pkm]
train
Other countries
UK Defra
0.03546
[kgCO2eq/pkm]
electric bike
Other countries
UK Defra
0.014
[kgCO2eq/pkm]
taxi
Other countries
UK Defra
0.14861
[kgCO2eq/pkm]
airplane
Other countries
UK Defra, International, average passenger, Without RF
0.1029
[kgCO2eq/pkm]
Scope 3
Emission source
Country
EF Source
2024
Unit

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Performance Overview
Segment Analysis
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Risk Management
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Statement
Financial
Report
Appendix 3: IRO-2 Disclosure requirements in
ESRS covered in the Sustainability Statement
List of material disclosure requirements
Page number (TBD)
ESRS 2
General Disclosures
178
BP-1
General basis for preparation of the Sustainability Statement
178
BP-2
Disclosures in relation to specific circumstances
179
GOV-1
The role of administrative, supervisory and management bodies
181
GOV-2
Information provided to and sustainability matters addressed by the administrative, supervisory and management bodies
190
GOV-3
Integration of sustainability-related performance in incentive schemes
190
GOV-4
Statement on due diligence
196
GOV-5
Risk management and internal controls over sustainability reporting
196
SBM-1
Strategy, business model and value chain
197
SBM-2
Interests and views of stakeholders
203
SBM-3
Material IROs and their interaction with strategy and business model
204
IRO-1
Description of the processes to identify and assess material IROs
207
E1
Climate change
210
GOV-3
Integration of sustainability-related performance in incentive schemes
190
E1-1
Transition plan for climate change mitigation
210
SBM-3
Material climate-related IROs and their interaction with strategy and business model
217
IRO-1
Identification and assessment of material climate-related IROs
218
IRO- 1
Identification and assessment of climate-related physical and transitional risks
222
E1-2
Policies related to climate change mitigation and adaptation
227
E1-3
Actions and resources related to climate change mitigation and adaptation
230
E1-4
Targets related to climate change mitigation and adaptation
236
E1-5
Energy consumption and mix
240
E1-6
Gross Scopes 1, 2, 3 and total GHG emissions
241
S1
Own workforce
254
SBM-2
Interests and views of stakeholders
203
SBM-3
material IROs and their interaction with strategy and business model
254
S1-1
Policies
260, 261, 263, 264, 265,
266, 267, 268, 269
S1-2
Processes for engaging with employees and workers’ representatives about IROs
270
S1-3
Processes to remediate negative impacts and channels to raise concerns
271
S1-4
Key activities
261, 263, 264,
265,266,267,268
S1-5
Metrics
267

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List of material disclosure requirements
Page number (TBD)
S1
Own workforce (contonued)

S1-6
Employees Characteristic Metrics
257
S1-8
Enabling social dialogue and collective bargaining
266
S1-9
Diversity metrics
268
S1-10
Adequate wages
264
S1-13
Performance review metrics
263
S1-14
Health and safety metrics
265
S1-16
Pay gap and total remuneration metrics
268
S1-17
Incidents, complaints and severe human rights impacts
261
S3
Affected communities
272
SBM-2
Interests and views of stakeholders
203
SBM-3
Material impacts, risks and opportunities and their interaction with strategy and business model
272
S3-1
Policies related to affected communities about impacts
273
S3-2
Processes for engaging with affected communities about impacts
275
S3-3
Processes to remediate negative impacts and channels for affected communities to raise concerns
275
S3-4
Key actions and targets
275
S3-5
Key actions and targets
275
S4
Consumers and end-users
280
SBM-2
Interests and views of stakeholders
203
SBM-3
Material impacts, risks and opportunities and their interaction with strategy and business model
280
S4-1
Policies
282, 283,284,285,286,288
S4-2
Processes for engaging with clients and end-users about impacts
288
S4-3
Processes to remediate negative impacts - complaint management
287
S4-4
Key activities and progress
282,283,284,286,287,288
S4-5
Targets and metrics
283,285,287,288
G1
Business conduct
290
GOV-1
Role of administrative, supervisory and management bodies related to business conduct
290
IRO-1
Description of processes to identify and assess material impacts, risks and opportunities
290
G1-1
Corporate culture, ethical governance and integrity, and regulatory compliance
293
G1-3
Prevention of corruption and bribery
295
G1-4
Incidents of corruption or bribery
296
G1-5
Political influence and lobbying activities
302

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Appendix 4: List of datapoints that derive from
other EU legislation (ESRS 2 appendix B)
List of datapoints in cross-cutting and topical standards that derive from other EU legislation
Disclosure Requirement
adn related datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate
Law reference
Material / Not
material
Page number (TBD)
ESRS 2 GOV-1
Board's gender diversity paragraph 21 (d)
Indicator number 13 of Table #1 of Annex 1
Commission Delegated
Regulation (EU)
2020/1816(5), Annex II
Material
182
ESRS 2 GOV-1
Percentage of board members who
are independent paragraph 21 (e)
Delegated Regulation
(EU) 2020/1816, Annex II
Material
181
ESRS 2 GOV-4
Statement on due diligence paragraph 30
Indicator number 10 Table #3 of Annex 1
Material
196
ESRS 2 SBM-1
Involvement in activities related to fossil
fuel activities paragraph 40 (d) i
Indicators number 4 Table #1 of Annex 1
Article 449a Regulation (EU) No
575/2013;
Commission Implementing
Regulation (EU) 2022/2453(6)
Table 1: Qualitative information
on Environmental risk
and Table 2: Qualitative
information on Social risk
Delegated Regulation
(EU) 2020/1816, Annex II
Material
227, 249, 250
ESRS 2 SBM-1
Involvement in activities related to
chemical production paragraph 40 (d) ii
Indicator number 9 Table #2 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Material
227, 249, 250
ESRS 2 SBM-1
Involvement in activities related to
controversial weapons paragraph 40 (d) iii
Indicator number 14 Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1818(7), Article
12(1) Delegated Regulation
(EU) 2020/1816, Annex II
Material
227, 249, 250
ESRS 2 SBM-1
Involvement in activities related
to cultivation and production of
tobacco paragraph 40 (d) iv
Delegated Regulation
(EU) 2020/1818, Article 12(1)
Delegated Regulation
(EU) 2020/1816, Annex II
Material
227, 249, 250
ESRS E1-1
Transition plan to reach climate
neutrality by 2050 paragraph 14
Regulation
(EU) 2021/1119,
Article 2(1)
Material
ESRS E1-1
Undertakings excluded from Paris-
aligned Benchmarks paragraph 16 (g)
Article 449a
Regulation (EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book-Climate
Change transition risk: Credit
quality of exposures by sector,
emissions and residual maturity
Delegated Regulation
(EU) 2020/1818, Article12.1
(d) to (g), and Article 12.2
Material
210
ESRS E1-4
GHG emission reduction targets paragraph 34 Indicator number 4 Table #2 of Annex 1
Article 449a
Regulation (EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453 Template
3: Banking book – Climate change
transition risk: alignment metrics
Delegated Regulation
(EU) 2020/1818, Article 6
Material
236
ESRS E1-5
Energy consumption from fossil sources
disaggregated by sources (only high
climate impact sectors) paragraph 38
Indicator number 5 Table #1 and
Indicator n. 5 Table #2 of Annex 1
Not Material
-

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ESRS E1-5 Energy consumption
and mix paragraph 37
Indicator number 5 Table #1 of Annex 1
Material
240
ESRS E1-5
Energy intensity associated with
activities in high climate impact
sectors paragraphs 40 to 43
Indicator number 6 Table #1 of Annex 1
Not Material
-
ESRS E1-6
Gross Scope 1, 2, 3 and Total GHG
emissions paragraph 44
Indicators number 1 and 2 Table #1 of Annex 1
Article 449a; Regulation (EU) No
575/2013; Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book – Climate
change transition risk: Credit
quality of exposures by sector,
emissions and residual maturity
Delegated Regulation
(EU) 2020/1818, Article
5(1), 6 and 8(1)
Material
241
ESRS E1-6
Gross GHG emissions intensity
paragraphs 53 to 55
Indicators number 3 Table #1 of Annex 1
Article 449a Regulation (EU) No
575/2013; Commission Implementing
Regulation (EU) 2022/2453 Template
3: Banking book – Climate change
transition risk: alignment metrics
Delegated Regulation (EU)
2020/1818, Article 8(1)
Material
242
ESRS E1-7
GHG removals and carbon
credits paragraph 56
Regulation
(EU) 2021/1119,
Article 2(1)
Not Material
-
ESRS E1-9
Exposure of the benchmark portfolio to
climate-related physical risks paragraph 66
Delegated Regulation
(EU) 2020/1818, Annex II
Delegated Regulation
(EU) 2020/1816, Annex II
Material, subject
to phase in
-
ESRS E1-9
Disaggregation of monetary amounts by
acute and chronic physical risk paragraph
66 (a)
ESRS E1-9
Location of significant assets at material
physical risk paragraph 66 (c).
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation (EU)
2022/2453 paragraphs 46 and
47; Template 5: Banking book
- Climate change physical risk:
Exposures subject to physical risk.
Material, subject
to phase in
-
ESRS E1-9 Breakdown of the carrying
value of its real estate assets by energy-
efficiency classes paragraph 67 (c).
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation (EU)
2022/2453 paragraph 34; Template
2:Banking book -Climate change
transition risk: Loans collateralised
by immovable property - Energy
efficiency of the collateral
Material, subject
to phase in
-
ESRS E1-9
Degree of exposure of the portfolio to
climate- related opportunities paragraph 69
Delegated Regulation
(EU) 2020/1818, Annex II
Material, subject
to phase in
-
ESRS E2-4
Amount of each pollutant listed in Annex
II of the E-PRTR Regulation (European
Pollutant Release and Transfer Register)
emitted to air, water and soil, paragraph 28
Indicator number 8 Table #1 of Annex 1
Indicator number 2 Table #2 of Annex 1
Indicator number 1 Table #2 of Annex 1
Indicator number 3 Table #2 of Annex 1
Not Material
-
ESRS E3-1
Water and marine resources paragraph 9
Indicator number 7 Table #2 of Annex 1
Not Material
-
ESRS E3-1
Dedicated policy paragraph 13
Indicator number 8 Table 2 of Annex 1
Not Material
-
ESRS E3-1
Sustainable oceans and seas paragraph 14
Indicator number 12 Table #2 of Annex 1
Not Material
-
ESRS E3-4
Total water recycled and
reused paragraph 28 (c)
Indicator number 6.2 Table #2 of Annex 1
Not Material
-
ESRS E3-4
Total water consumption in m3 per net
revenue on own operations paragraph 29
Indicator number 6.1 Table #2 of Annex 1
Not Material
-
ESRS 2- IRO 1 - E4 paragraph 16 (a) i
Indicator number 7 Table #1 of Annex 1
Not Material
-
ESRS 2- IRO 1 - E4 paragraph 16 (b)
Indicator number 10 Table #2 of Annex 1
Not Material
-

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ESRS 2- IRO 1 - E4 paragraph 16 (c)
Indicator number 14 Table #2 of Annex 1
Not Material
-
ESRS E4-2
Sustainable land / agriculture practices
or policies paragraph 24 (b)
Indicator number 11 Table #2 of Annex 1
Not Material
-
ESRS E4-2
Sustainable oceans / seas practices
or policies paragraph 24 ©
Indicator number 12 Table #2 of Annex 1
Not Material
-
ESRS E4-2
Policies to address deforestation
paragraph 24 (d)
Indicator number 15 Table #2 of Annex 1
Not Material
-
ESRS E5-5
Non-recycled waste paragraph 37 (d)
Indicator number 13 Table #2 of Annex 1
Not Material
-
ESRS E5-5
Hazardous waste and radioactive
waste paragraph 39
Indicator number 9 Table #1 of Annex 1
Not Material
-
ESRS 2- SBM3 - S1
Risk of incidents of forced
labour paragraph 14 (f)
Indicator number 13 Table #3 of Annex I
Not Material,
but disclosed
256, 261
ESRS 2- SBM3 - S1
Risk of incidents of child
labour paragraph 14 (g)
Indicator number 12 Table #3 of Annex I
Not Material,
but disclosed
256, 261
ESRS S1-1
Human rights policy commitments
paragraph 20
Indicator number 9 Table #3 and Indicator
number 11 Table #1 of Annex I
Material
260
ESRS S1-1
Due diligence policies on issues addressed
by the fundamental International Labor
Organisation Conventions 1 to 8, paragraph 21
Delegated Regulation
(EU) 2020/1816, Annex II
Material
261
ESRS S1-1
processes and measures for preventing
trafficking in human beings paragraph 22
Indicator number 11 Table #3 of Annex I
Material
261
ESRS S1-1
workplace accident prevention policy or
management system paragraph 23
Indicator number 1 Table #3 of Annex I
Material
264
ESRS S1-3
grievance/complaints handling
mechanisms paragraph 32 (c)
Indicator number 5 Table #3 of Annex I
Material
271
ESRS S1-14
Number of fatalities and number
and rate of work- related accidents
paragraph 88 (b) and (c)
Indicator number 2 Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Material
265
ESRS S1-14
Number of days lost to injuries, accidents,
fatalities or illness paragraph 88 (e)
Indicator number 3 Table #3 of Annex I
Material
265
ESRS S1-16
Unadjusted gender pay gap paragraph 97 (a) Indicator number 12 Table #1 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Material
268
ESRS S1-16
Excessive CEO pay ratio paragraph 97 (b)
Indicator number 8 Table #3 of Annex I
Material
268
ESRS S1-17
Incidents of discrimination paragraph 103 (a)
Indicator number 7 Table #3 of Annex I
Material
261
ESRS S1-17 Non-respect of UNGPs
on Business and Human Rights
and OECD paragraph 104 (a)
Indicator number 10 Table #1 and
Indicator n. 14 Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818 Art 12 (1)
Material
261
ESRS 2- SBM3 – S2
Significant risk of child labour or forced
labour in the value chain paragraph 11 (b)
Indicators number 12 and n.
13 Table #3 of Annex I
Not Material
-

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ESRS S2-1
Human rights policy commitments
paragraph 17
Indicator number 9 Table #3 and
Indicator n. 11 Table #1 of Annex 1
Not Material
260
ESRS S2-1 Policies related to value
chain workers paragraph 18
Indicator number 11 and n. 4 Table #3 of Annex 1
Not Material
-
ESRS S2-1Non-respect of UNGPs on
Business and Human Rights principles
and OECD guidelines paragraph 19
Indicator number 10 Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12 (1)
Not Material
-
ESRS S2-1
Due diligence policies on issues addressed
by the fundamental International Labor
Organisation Conventions 1 to 8, paragraph 19
Delegated Regulation
(EU) 2020/1816, Annex II
Not Material
-
ESRS S2-4
Human rights issues and incidents
connected to its upstream and
downstream value chain paragraph 36
Indicator number 14 Table #3 of Annex 1
Not Material
-
ESRS S3-1
Human rights policy commitments
paragraph 16
Indicator number 9 Table #3 of Annex 1 and
Indicator number 11 Table #1 of Annex 1
Material
260
ESRS S3-1
non-respect of UNGPs on Business
and Human Rights, ILO principles or
and OECD guidelines paragraph 17
Indicator number 10 Table #1 Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12 (1)
Material
196, 260, 280
ESRS S3-4
Human rights issues and
incidents paragraph 36
Indicator number 14 Table #3 of Annex 1
Material
275
ESRS S4-1 Policies related to consumers
and end-users paragraph 16
Indicator number 9 Table #3 and Indicator
number 11 Table #1 of Annex 1
Material
282
ESRS S4-1
Non-respect of UNGPs on Business
and Human Rights and OECD
guidelines paragraph 17
Indicator number 10 Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12 (1)
Material
274
ESRS S4-4
Human rights issues and
incidents paragraph 35
Indicator number 14 Table #3 of Annex 1
Material
274
ESRS G1-1
United Nations Convention against
Corruption paragraph 10 (b)
Indicator number 15 Table #3 of Annex 1
Material
295
ESRS G1-1
Protection of whistle- blowers
paragraph 10 (d)
Indicator number 6 Table #3 of Annex 1
Material
297
ESRS G1-4
Fines for violation of anti- corruption and
anti-bribery laws paragraph 24 (a)
Indicator number 17 Table #3 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II)
Material
296
ESRS G1-4Standards of anti- corruption
and anti- bribery paragraph 24 (b)
Indicator number 16 Table #3 of Annex 1
Material
296

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Appendix 5: Responsible banking progress
statement for PRB Signatories*
Principle 1:
Alignment
NLB Group aligns its business strategy to be consistent
with and contribute to individuals’ needs and society’s
goals, as expressed in the UN SDGs, Paris Climate
Agreement, United Nations Guiding Principles on
Business and Human Rights, and relevant national and
regional frameworks such as the Sofia Declaration
on the Green Agenda for the Western Balkans, and
national energy and climate plans. Through successful
acquisitions of Generali Investments AD Skopje and the
SLS Group, NLB Group has also expanded its operations
to the Croatian market.
Principle 2:
Impact & Target Setting
NLB Group is amplifying its positive impacts while
minimizing negative impacts in key areas: climate,
healthy and inclusive economies, and human rights
within its own workforce. In 2024, NLB Group conducted
a Double Materiality Analysis aligned with ESRS
standards, leveraging the UNEP FI Impact Analysis tool.
Furthermore, in 2024, NLB Group set new target in the
area of healthy and inclusive economies, while targets
related to climate and resource efficiency are further
being developed.
Principle 3:
Clients & Customers
The relationship with consumers and end users is at the
heart of NLB Group's business model. With more than 2.9
million clients, NLB Group is one of the leading financial
groups in the SEE region.
Summary template
NLB Group 2024
Links & references
For detailed information please refer to:
›› NLB Group at Glance
›› This is where our community thrives
›› Strategy
›› Incorporating ESG risks, p. 107, p. 222, p. 298
Links & references
For detailed information please refer to:
›› SBM-3 Material IROs and their interaction with the
strategy and business model p. 204, p. 207
›› Targets related to climate change mitigation and
adaptation, p. 214, p. 234
›› Financial health and inclusion targets
Links & references
For detailed information please refer to:
›› S-4 Consumers and end-users
›› E1 Climate Change
›› Appendix 1: Taxonomy
*Not subject to external assurance.

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Principle 4:
Stakeholders
NLB Group continually engages with a wide range of
stakeholders to provide them with relevant information
on various topics, to consider their views, concerns and
aspirations in business decisions, and to enhance trust
and partnerships.
Principle 5:
Governance & Culture
NLB Group constantly strives to improve its governance
structures in the area of sustainability. In 2024, it
adopted a revised Sustainability Policy, and in addition
to the existing sustainability committee, it established a
climate committee. Furthermore, NLB Group employees
are obliged to take sustainability training at least
once a year. With this, the Group is strengthening its
commitment to the set goals and responding to the
needs arising from the daily operations of various
stakeholders.
Principle 6:
Transparency & Accountability
NLB Group reports on sustainability in line with the EU
Corporate Sustainability Reporting Directive (CSRD) and
European Sustainability Reporting Standards (ESRS).
Third-party limited assurance has been obtained by
KPMG.
PRB Targets overview
Target
2024
Target value
Target year
Paper consumption (number in thousand)
68,448
65,343
2025
Share of electricity from zero-carbon sources
69%
75%
2030
Digital penetration (% of active digital users in total number of clients)
56,4
55
80
2025
2030
Green lending to corporates (large, SME) - outstanding stock in EUR million
701
1,370
2030
Green lending to micro and private individuals - outstanding stock in EUR million
327
528
2030
Number of young clients (18-27 years) with products related to long-term savings and/or investment plans
29%
+15%
2030
Number of age 27+ up to retired clients with products related to long-term savings and/or investment plans
39%
+15%
2030
Links & references
For detailed information please refer to:
›› Interests and views of stakeholders
Links & references
For detailed information please refer to:
›› Governance information
Links & references
For detailed information please refer to:
›› Limited Assurance Statement

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Appendix 6: TCFD Index Table*
As an issuer on the London Stock Exchange, NLB
discloses climate-related financial information related
to NLB Group for the third time in reference to the
Task Force on Climate-Related Financial Disclosures
(TCFD) recommendations regarding (1) governance,
(2) business strategy, (3) risk management, (4) metrics
and targets. NLB acknowledges that this framework is
fully incorporated in the IFRS S1 (General Requirements
for Disclosure of Sustainability-related Financial
Information) and IFRS S2 (Climate-related Disclosures)
as of year-end 2023. For fiscal year 2024, NLB prepared
the Sustainability Statement in accordance with the
Corporate Social Responsibility Directive (CSRD) and
ESRS (European Sustainability Reporting Standards),
which also incorporates elements of TCFD framework.
In addition, NLB Group has published the Pillar III
Disclosures, which is available on the NLB Group
website.
This content index provides to stakeholders the relevant
information on TCFD disclosure location in the NLB
Group Sustainability Statement 2024 and NLB Group
Pillar III Disclosures for the 2024.
RECOMMENDATIONS
Disclosure location
I.GOVERNANCE

a) The Board’s oversight of climate-
related risks and opportunities
b) Management’s role in assessing and managing
climate-related risks and opportunities
Sustainability Statement:
• Governance, pages 181 – 197
• Information provided to and sustainability matters addressed by the administrative, supervisory, and management bodies, page 190
• Integration of sustainability-related performance in incentive schemes, pages 190 - 194
II. STRATEGY
a) Describe the climate-related risks and
opportunities the organization has identified
over the short, medium, and long term.
b) Describe the impact of climate-related risks and
opportunities on the organization’s businesses,
strategy, and financial planning.
c) Describe the resilience of the organization’s strategy,
taking into consideration different climate-related
scenarios, including a 2 °C or lower scenario.
Sustainability Statement:
• Transition plan for climate change mitigation, page 210 - 2017
• Material climate-related impacts, risks and opportunities and their interaction with strategy and business model, page 217
• Resilience analysis, page 218
• Sustainable finance, page 246 - 251
d) Banks should describe significant concentrations
of credit exposure to carbon-related assets.
• Pillar III Disclosures for the 2024: Exposures to top 20 carbon-intensive firms, page 127
*Not subject to external assurance.

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Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
RECOMMENDATIONS
Disclosure location
e) Additionally, banks should consider disclosing their climate-
related risks (transition and physical) in their lending
and other financial intermediary business activities.
Sustainability Statement:
• Material climate-related impacts, risks and opportunities and their interaction with strategy and business model, page 217
• Pillar III Disclosures: Exposures subject to physical risk, pages 128-129
III. RISK MANAGEMENT

a) The organization’s processes for identifying
and assessing climate-related risks
Sustainability Statement:
• Material climate-related IROs and their interaction with strategy and business model, page 217
• Identification and assessment of material climate-related IROs, page 218 - 221
• Identification and assessment of material climate-related risks, page 222 - 226
• ESG Risk management, page 298 - 300
b) The organization’s processes for
managing climate-related risks
c) How processes for identifying, assessing, and
managing climate-related risks are integrated into
the organization’s overall risk management
d) Banks should consider characterizing their climate-
related risks in the context of traditional banking
industry risk categories such as credit risk, market risk,
liquidity risk, and operational risk. Banks should also
consider describing any risk classification frameworks
used (e.g., the Enhanced Disclosure Task Force’s
framework for defining “Top and Emerging Risks”)
IV. METRICS

a) Disclose the metrics used by the organization to
assess climate-related risks and opportunities in line
with its strategy and risk management process
Sustainability Statement:
• Identification and assessment of material climate-related risks, page 222 - 226
• EU Taxonomy regulation, page 215 and Appendix 1, page 307 - 353
b) Disclose Scope 1, Scope 2 and, if appropriate, Scope 3
greenhouse gas (GHG) emissions and the related risks
Sustainability Statement:
• Gross Scopes 1, 2, 3 and total GHG emissions, page 241
c) Describe the targets used by the organization to
manage climate-related risks and opportunities
and performances against targets.
Sustainability Statement:
• Targets related to climate change mitigation and adaptation, page 236
d) Banks should disclose GHG emissions for their lending
and other financial intermediary business activities where
data and methodologies allow. These emissions should
be calculated in line with the Global GHG Accounting and
Reporting Standard for the Financial Industry developed
by the Partnership for Carbon Accounting Financials
(PCAF Standard) or a comparable methodology.
• Pillar III Disclosures: Credit Quality of Exposures, page 120

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
FINANCIAL
REPORT
Transparency and accuracy are the
cornerstones of our integrity. This
chapter provides comprehensive
explanations of financial data,
additional disclosures, detailed
notes to the financial statements,
and supplementary information,
offering deeper insights into NLB
Group’s financial performance and
operations.

NLB Group
Annual Report 2024
370
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Contents
Independent Auditor’s Report . . . . . . . . . . . . . . . . . . . . 372
Statement of Management’s Responsibility. . . . . . . . 377
Income Statement for the Annual Period
ended 31 December. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 378
Statement of Other Comprehensive Income
for the Annual Period ended 31 December. . . . . . . . 379
Statement of Financial Position
as at 31 December. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 380
Statement of Changes in Equity
for the Annual Period ended 31 December. . . . . . . . 382
Statement of Cash Flows for the Annual Period
ended 31 December. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 384
Notes to the Financial Statements. . . . . . . . . . . . . . . . . 386
1. General Information on Reporting Entity. . . . . . . . 386
2. Summary of Material Accounting
Policy Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 386
2.1. Statement of compliance. . . . . . . . . . . . . . . . . . . . . . . 386
2.2. Basis for preparation the financial statements. . 386
2.3. Functional and presentation currency. . . . . . . . . . 386
2.4. Comparative amounts. . . . . . . . . . . . . . . . . . . . . . . . . . 386
2.5. Consolidation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 387
2.6. Business combinations, goodwill,
and bargain purchases. . . . . . . . . . . . . . . . . . . . . . . . . 387
2.7. Investments in subsidiaries, associates,
and joint ventures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 388
2.8. A combination of entities or businesses
under common control. . . . . . . . . . . . . . . . . . . . . . . . . 388
2.9. Foreign currency translation. . . . . . . . . . . . . . . . . . . . 388
2.10. Interest income and expenses. . . . . . . . . . . . . . . . . 389
2.11. Fee and commission income and expenses. . . . 389
2.12. Dividend income. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 389
2.13. Financial instruments . . . . . . . . . . . . . . . . . . . . . . . . . 389
2.14. Allowances for financial assets. . . . . . . . . . . . . . . . 392
2.15. Forborne loans. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397
2.16. Repossessed assets. . . . . . . . . . . . . . . . . . . . . . . . . . . 397
2.17. Offsetting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 397
2.18. Sale and repurchase agreements. . . . . . . . . . . . . 398
2.19. Property and equipment. . . . . . . . . . . . . . . . . . . . . . 398
2.20. Intangible assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 398
2.21. Investment properties. . . . . . . . . . . . . . . . . . . . . . . . . 398
2.22. Non-current assets and disposal groups
classified as held for sale . . . . . . . . . . . . . . . . . . . . . 398
2.23. Accounting for leases. . . . . . . . . . . . . . . . . . . . . . . . . 399
2.24. Cash and cash equivalents . . . . . . . . . . . . . . . . . . . 399
2.25. Borrowings, deposits,
and issued debt securities
with characteristics of debt. . . . . . . . . . . . . . . . . . . . 399
2.26. Other issued financial instruments
with characteristics of equity. . . . . . . . . . . . . . . . . . 400
2.27. Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 400
2.28. Contingent liabilities and commitments . . . . . . . 400
2.29. Taxes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 400
2.30. Fiduciary activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . 401
2.31. Employee benefits. . . . . . . . . . . . . . . . . . . . . . . . . . . . 401
2.32. Share-based
payment transactions. . . . . . . . . . . . . . . . . . . . . . . . . 402
2.33. Share capital . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 402
2.34. Segment reporting. . . . . . . . . . . . . . . . . . . . . . . . . . . . 402
2.35. Critical accounting estimates and judgments
in applying accounting policies . . . . . . . . . . . . . . . 402
2.36. Implementation of the new and revised
International Financial Reporting Standards. . 405
3. Changes in the Composition of the NLB Group. . . 406
4. Notes to the Income Statement . . . . . . . . . . . . . . . . . 408
4.1. Interest income and expenses. . . . . . . . . . . . . . . . . . 408
4.2. Dividend income. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 409
4.3. Fee and commission income and expenses. . . . . 409
4.4. Gains less losses from
financial assets and liabilities not measured
at fair value through profit or loss . . . . . . . . . . . . . . 412
4.5. Gains less losses from financial assets
and liabilities held for trading . . . . . . . . . . . . . . . . . . 412
4.6. Gains less losses from non-trading
financial assets mandatorily at fair value
through profit or loss. . . . . . . . . . . . . . . . . . . . . . . . . . . 413
4.7. Foreign exchange translation gains less losses. . 413
4.8. Other operating income and expenses. . . . . . . . . 414
4.9. Administrative expenses. . . . . . . . . . . . . . . . . . . . . . . . 415
4.10. Cash contributions to resolution funds
and deposit guarantee schemes. . . . . . . . . . . . . . 416
4.11. Depreciation and amortisation. . . . . . . . . . . . . . . . 417
4.12. Gains less losses from modification
of financial assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 417
4.13. Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 417
4.14. Impairment charge. . . . . . . . . . . . . . . . . . . . . . . . . . . 418
4.15. Income tax . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 419
4.16. Earnings per share . . . . . . . . . . . . . . . . . . . . . . . . . . . 421
5. Notes to the Statement of Financial Position. . . . . 421
5.1. Cash, cash balances at central banks,
and other demand deposits at banks. . . . . . . . . . . 421
5.2. Financial instruments held for trading . . . . . . . . . 422
5.3. Non-trading financial instruments
measured at fair value through profit or loss. . . . 423
5.4. Financial assets measured at fair value
through other comprehensive income. . . . . . . . . . 424
5.5. Derivatives for hedging purposes . . . . . . . . . . . . . . 426
5.6. Financial assets measured at amortised cost. . . 430
5.7. Non-current assets held for sale . . . . . . . . . . . . . . . 432
5.8. Property and equipment . . . . . . . . . . . . . . . . . . . . . . . 433
5.9. Investment property. . . . . . . . . . . . . . . . . . . . . . . . . . . . 435
5.10. Intangible assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 436
5.11. Leases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 437
5.12. Investments in subsidiaries, associates,
and joint ventures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 440
5.13. Other assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 450
5.14. Movements in allowance for the impairment
of financial assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . 450
5.15. Financial liabilities,
measured at amortised cost . . . . . . . . . . . . . . . . . . 460
5.16. Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 463
5.17. Deferred income tax. . . . . . . . . . . . . . . . . . . . . . . . . . 469
5.18. Income tax relating to components
of other comprehensive income. . . . . . . . . . . . . . . 472
5.19. Other liabilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 472

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
5.20. Share capital . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 473
5.21. Other equity instruments issued. . . . . . . . . . . . . . . 473
5.22. Accumulated other comprehensive income
and reserves. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 474
5.23. Capital adequacy ratios . . . . . . . . . . . . . . . . . . . . . . 475
5.24. Off-balance sheet liabilities. . . . . . . . . . . . . . . . . . . 478
5.25. Funds managed on behalf of third parties. . . . . 480
6. Risk Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 481
6.1. Credit risk management. . . . . . . . . . . . . . . . . . . . . . . . 484
6.2. Market risk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 507
6.3. Liquidity risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 514
6.4. Management of non-financial risks. . . . . . . . . . . . 528
6.5. Fair value hierarchy of financial
and non-financial assets and liabilities. . . . . . . . . 529
6.6. Environmental and climate-related risks. . . . . . . 539
6.7. Offsetting financial assets
and financial liabilities . . . . . . . . . . . . . . . . . . . . . . . . . 539
7. Analysis by Segment for NLB Group. . . . . . . . . . . . . 541
8. Related-Party Transactions. . . . . . . . . . . . . . . . . . . . 545
9. Events After the Reporting Date . . . . . . . . . . . . . . . . 554

NLB Group
Annual Report 2024
372
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Independent Auditor’s Report
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Independent Auditor's Report
To the shareholders of NOVA LJUBLJANSKA BANKA D.D.,
LJUBLJANA
Report on the Audit of the Separate and Consolidated Financial Statements

Opinion
We have audited the separate financial statements of NOVA LJUBLJANSKA BANKA D.D.,
LJUBLJANA (the “Bank”) and the consolidated financial statements of the Bank and its subsidiaries
(collectively, the “Group”), which comprise:
•
the separate and consolidated statements of financial position as at 31 December 2024;
and, for the period from 1 January to 31 December 2024:
•
the separate and consolidated statements of profit or loss;
•
the separate and consolidated statements of other comprehensive income;
•
the separate and consolidated statements of changes in equity;
•
the separate and consolidated statements of cash flows;
and
•
notes, comprising material accounting policies and other explanatory information.
In our opinion, the accompanying separate and consolidated financial statements give a true and fair
view of the unconsolidated and consolidated financial position, respectively, of the Bank and the Group
as at 31 December 2024, and of their respective unconsolidated and consolidated financial
performance and unconsolidated and consolidated cash flows for the year then ended in accordance
with International Financial Reporting Standards as adopted by the European Union (“IFRS EU”).
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs) 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 (OJ L 158, 27 May 2014, p. 77-112 -
Regulation (EU) No 537/2014). Our responsibilities under those standards are further described in the
Auditor’s Responsibilities for the Audit of the Separate and Consolidated Financial Statements section
of our report. We are independent of the Bank and the Group in accordance with International Ethics
Standards Board for Accountants International Code of Ethics for Professional Accountants (including
International Independence Standards) (IESBA Code) together with the ethical requirements that are
relevant to our audit of the separate and consolidated financial statements in Slovenia and we have
fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA 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 most significance in
our audit of the separate and consolidated financial statements of the current period. These matters
were addressed in the context of our audit of the separate and consolidated financial statements as
a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these
matters.
We have determined the following key audit matters:
Impairment of loans and receivables from customers
As at 31 December 2024, the gross carrying amount of loans and advances to customers of the
Bank and the Group, respectively: EUR 8,811,061 thousand and EUR 16,721,410 thousand; related
impairment allowance of the Bank and the Group, respectively: EUR 157,713 thousand and EUR
357,761 thousand and related impairment loss recognised in the income statement in the year then
ended, for the Bank and the Group, respectively: EUR 41,348 thousand and EUR 31,431 thousand
(31 December 2023: the gross carrying amount of loans and advances to customers of the Bank and
the Group, respectively: EUR 7,267,851 thousand and EUR 14,063,228 thousand; related
impairment allowance of the Bank and the Group, respectively: EUR 119,568 thousand and EUR
328,627 thousand and related impairment loss/(reversal) recognised in the income statement for the
Bank and the Group, respectively: EUR 11,435 thousand and EUR (3,764) thousand).
Refer to the Note 2.14. Allowances for financial assets, Note 2.35. Critical accounting estimates and
judgments in applying accounting policies, Note 4.14 Impairment charge, Note 5.6. Financial assets
measured at amortised cost, Note 5.14. Movements in allowance for the impairment of financial
assets and Note 6.1. Credit risk management.
Key audit matter
Our response
Allowances for impairment represent the
Management Board’s best estimate of the
expected credit losses (“ECLs”) within loans and
advances to customers (“loans”, “exposures”)
measured at amortized cost at the reporting date.
We focused on this area as the measurement of
allowances for impairment requires the
Management Board to make complex and
subjective assumptions and judgements.
The Bank and the Group calculate allowances for
credit losses in accordance with IFRS 9 Financial
Instruments, based on the ECL model under the
general approach, based on which the
impairment allowance is measured as either 12-
month expected credit losses or lifetime
expected credit losses, depending on whether or
not there has been a significant increase in credit
risk since initial recognition.
ECLs for performing exposures (Stage 1 and
Stage 2 in the IFRS 9 Financial instruments
hierarchy) and for non-performing (Stage 3)
exposures not exceeding EUR 0.5 million for
corporate exposures and EUR 0.1 million for
retail exposures, are determined by modelling
techniques relying on key parameters such as
the probability of default (PD), exposure at
default (EAD), credit conversion factor (CCF) and
Our audit procedures in this area, performed,
where applicable, with the assistance of our own
financial risk management (FRM) and
information technology (IT) audit specialists,
included, among others:
 Inspecting the Bank’s and the Group’s ECL
impairment
provisioning
methods
and
models, and assessing their compliance with
the requirements of the relevant regulatory
and financial reporting frameworks;
 Making relevant inquiries of the Bank’s and
the Group’s risk management and
information technology (IT) personnel to gain
an understanding of the loan impairment
process, IT applications used therein, as well
as key data sources and assumptions in the
ECL model. Also, testing of IT control
environment for data security and access,
assisted by our own IT specialists;
 Testing the design, implementation and
operating effectiveness of selected controls in
the process of approval, recording and
monitoring of loans, including, but not limited
to, those relating to the credit rating
classification, calculation of days past due,
collateral valuations and estimation of ECLs;

NLB Group
Annual Report 2024
373
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

loss given default (LGD), taking into account
historical experience, identification of exposures
with a significant increase in credit risk (SICR),
forward-looking information and management
judgment (together “collective impairment
allowance”).
ECLs for Stage 3 loans whose amounts exceed
EUR 0.5 million for corporate exposures and
EUR 0.1 million for retail exposures, are
determined on an individual basis by means of a
discounted cash flows analysis. The process
involves subjectivity and reliance on a number of
significant assumptions, including those in
respect of the expected proceeds from the sale
of the related collaterals and minimum period for
collateral disposal.
Due to the above factors, including the
significantly higher estimation uncertainty
stemming from the current volatile economic
outlook, slowing economic growth and rising
interest rates we considered allowance for
impairment of loans and advances to customers
to be associated with a significant risk of material
misstatement in the consolidated and separate
financial statements. Therefore, the area
required our increased attention in the audit and
as such was determined to be a key audit matter.
 Challenging the appropriateness of the
Bank’s and the Group’s application of the
significant increase in credit risk assumption
and definition of default; and classification of
exposures
into
performing
and
non-
performing.
For collective impairment allowance:
 Obtaining an understanding of the key internal
rating models for loans, and assessing the
relevance and reliability of the key data used
therein;
 Obtaining the forward-looking information and
key macroeconomic forecasted variables
used in the ECL assessment. Independently
assessing the information by reference to
publicly available data and corroborating
inquiries of the Management Board;
 Assisted
by
our
own
financial
risk
management specialist, challenging selected
key parameters within the collective ECL
model, such as PD and LGD by reference to,
among other things, our own analysis of the
Bank’s and the Group’s data on past default
occurrence and realised losses on those
defaults;
 Evaluating key overlays applied to the ECL
model, by reference to our knowledge of the
industry and our understanding of the current
macro-economic situation;
 For a risk-based sample of exposures
critically assessing the existence of any
triggers for classification to Stage 2 or Stage
3, by reference to the underlying evidence
(loan files), through inquiries of the loan
officers
and
credit
risk
management
personnel and by considering business
operations of the respective customers as
well as market conditions and historical debt
service.
For impairment allowances calculated
individually, for a risk-based sample of Stage 3
loans:
 challenging the Bank’s and the Group’s cash
flow projections and key assumptions used,
by reference to our knowledge of the relevant
industry and of the borrower.
 challenging the collateral valuations by
inspecting the underlying valuation reports
obtained by the Bank and the Group, and also
by reference to publicly available data;

For all impairment allowances:
 Critically
assessing
the
overall
reasonableness
of
the
allowances
for
impairment, including the loans provision
coverage, by benchmarking them against
publicly available industry data;
 Examining whether the Bank’s and Group’s
loan impairment and credit risk-related
disclosures in the separate and consolidated
financial statements appropriately address
the relevant quantitative and qualitative
requirements of the applicable financial
reporting framework.

Business combinations
As at 31 December 2024 the fair value of net assets acquired in material business combinations
during the year amounted to EUR 124,078 thousand resulting in a goodwill in the amount of EUR
3,138 thousand, which is recognised in the statement of financial position under Intangible assets.
Refer to: Note 2.6. Business Combinations, goodwill, and bargain purchases, Note 3. Changes in the
composition of the NLB Group and Note 5.12.c) Investments in subsidiaries, associates, and joint
ventures, Acquisition of SLS HOLDCO d.o.o., Ljubljana.
Key audit matter
Our response
As disclosed in the Note 5.12.c) Investments in
subsidiaries, associates, and joint ventures -
Acquisition of SLS HOLDCO d.o.o., Ljubljana,
during 2024, the Group concluded a share
purchase agreement for acquisition of controlling
stake in SLS HOLDCO d.o.o., the parent
company of Summit Leasing Slovenija d.o.o.,
Ljubljana, and its subsidiary Mobil Leasing d.o.o.,
Zagreb. The total purchase price amounted to
EUR 127,216 thousand.
With respect to business acquisitions, IFRS 3
Business combinations imposes a number of
requirements, including those relevant to
assessment of control over the acquired entity,
determination of the acquisition consideration,
identification of assets and liabilities acquired,
and measurement and recognition of identifiable
assets and liabilities at their acquisition-date fair
values.
Complying with the above requirements in the
context of the acquisitions required significant
judgement and complex assumptions, in
particular as regards the following:
Our audit procedures performed in this area
included:
 evaluating, based on analysis of the purchase
agreements as well as the criteria defined in
IFRS 10 Consolidated Financial Statements,
the assessment made by management with
regard to the control over entities acquired;
 assessing the completeness of the assets
acquired and liabilities assumed as a result of
the acquisitions, based on inspection of the
share
purchase
agreements,
our
understanding of the acquirees’ operations
and inspection of the acquirees’ accounting
records;
 assisted by our own valuation specialists, we
challenged the recognized acquisition-date
fair values of significant assets acquired and
liabilities assumed in the acquisitions, which
included:
o
assessment of the methods and
models applied to fair valuations of
specific assets and liabilities, by
reference
to
the
relevant
requirements
of
the
financial
reporting
standards
and
market
practice;

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Key Highlights
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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
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Risk Management
Sustainability
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Financial
Report

 Identification of all of the assets acquired,
with main focus on intangible assets
(primarily distribution agreements), and
 Measurement of distribution agreements
acquired with respect to which the Group
applied the multi-period excess earnings
method under the income approach to
determine fair value, with key assumptions
such as discount rates, churn rates, useful
lifetime, growth rates and terminal growth
rate.
As a result, the Group recognized total assets of
EUR 964,159 thousand, including distribution
agreement of EUR 21,959 thousand and goodwill
of EUR 3,138 thousand.
Due to the above factors, the business
combination and valuation of the distribution
agreement, was associated with an increased
risk of material misstatement to the consolidated
financial statements and required our increased
attention in the course of the audit, and was
considered by us to be a key audit matter.

o
testing the integrity of the model for
fair value measurement of distribution
agreement, including mathematical
accuracy, and evaluating the key
assumptions
applied
(such
as
discount rates, churn rates, useful
lifetime, growth rates and terminal
growth rate) for reasonableness
compared to both externally derived
data
and
historical
financial
performance;
 assessing the accuracy, completeness and
relevance of the disclosures on the
acquisitions made in the notes in the
consolidated financial statements against the
relevant requirements of the financial
reporting standards.

Other Information
Management is responsible for the other information. The other information comprises the “Overview”,
the “Business Report”, the “NLB Group Directory” and the “Definitions and Glossary of Selected
Terms” included in the Annual Report but does not include the separate and consolidated financial
statements and our auditor’s report thereon.
Our opinion on the separate and consolidated financial statements does not cover the other
information and, except to the extent otherwise explicitly stated in our report, we do not express any
form of assurance conclusion thereon.
With regard to the Sustainability Statement, which constitutes a separate part of the Business Report,
we performed a limited assurance engagement, the results of which were presented in a separate
assurance report with an unmodified conclusion.
In connection with our audit of the separate and consolidated financial statements, our responsibility is
to read the other information identified above and, in doing so, consider whether the other information
is materially inconsistent with the separate and consolidated financial statements or our knowledge
obtained in the audit, or otherwise appears to be materially misstated. If, based on the work we have
performed, we conclude that there is a material misstatement of this other information, we are required
to report that fact. We have nothing to report in this regard.
Other Reporting Responsibilities Related to Other Information – Business Report
In addition, with respect to the Business Report, we are required to report on its consistency with the
separate and consolidated financial statements and on whether the Business Report includes the
disclosures required by the Companies Act dated 4 May 2006 (Official Gazette of the Republic of
Slovenia no. 42/2006 with amendments - hereafter referred to as »the applicable legal requirements«)
excluding the requirements relevant for Sustainability Statement. Based solely on the work required to
be undertaken in the course of the audit of the separate and consolidated financial statements and the
procedures above, in our opinion:

•
the information given in the Business Report for the financial year for which the separate and
consolidated financial statements are prepared is consistent, in all material respects, with the
separate and consolidated financial statements; and
•
the Business Report has been prepared in accordance with the applicable legal requirements.
In addition, in light of the knowledge and understanding of the Bank and its environment obtained in
the course of our audit we are required to report if we have identified material misstatements in the
Business Report. We have nothing to report in this regard.
Responsibilities of Management and Those Charged with Governance for the Separate and
Consolidated Financial Statements
Management is responsible for the preparation of the separate and consolidated financial statements
that give a true and fair view in accordance with IFRS EU, and for such internal control as
management determines is necessary to enable the preparation of separate and consolidated
financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the separate and consolidated financial statements, management is responsible for
assessing the Bank’s and the Group's ability to continue as a going concern, disclosing, as applicable,
matters related to going concern and using the going concern basis of accounting unless management
either intends to liquidate the Bank or the Group or to cease operations, or has no realistic alternative
but to do so.
Those charged with governance are responsible for overseeing the Bank’s and the Group’s financial
reporting process.
Auditor's Responsibilities for the Audit of the Separate and Consolidated Financial
Statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated
financial statements as a whole are free from material misstatement, whether due to fraud or error,
and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of
assurance, but is not a guarantee that an audit conducted in accordance with ISAs and EU Regulation
(EU) No 537/2014 will always detect a material misstatement when it exists. Misstatements can arise
from fraud or error and are considered material if, individually or in the aggregate, they could
reasonably be expected to influence the economic decisions of users taken on the basis of these
separate and consolidated financial statements.
As part of an audit in accordance with ISAs and EU Regulation (EU) No 537/2014, we exercise
professional judgment and maintain professional scepticism throughout the audit. We also:
•
Identify and assess the risks of material misstatement of the separate and consolidated financial
statements, whether due to fraud or error, design and perform audit procedures responsive to
those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our
opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for
one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control;
•
Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Bank’s and the Group's internal control;
•
Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management;
•
Conclude on the appropriateness of management’s use of the going concern basis of accounting
and, based on the audit evidence obtained, whether a material uncertainty exists related to events
or conditions that may cast significant doubt on the Bank’s and the Group’s ability to continue as
a going concern. If we conclude that a material uncertainty exists, we are required to draw
attention in our auditor’s report to the related disclosures in the separate and consolidated

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions
are based on the audit evidence obtained up to the date of our auditor’s report. However, future
events or conditions may cause the Bank or the Group to cease to continue as a going concern;
•
Evaluate the overall presentation, structure and content of the separate and consolidated financial
statements, including the disclosures, and whether the separate and consolidated financial
statements represent the underlying transactions and events in a manner that achieves fair
presentation;
•
plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the
financial information of the entities or business units within the Group as a basis for forming an
opinion on the Group financial statements. We are responsible for the direction, supervision and
review of the audit work performed for purposes of the group audit. We remain solely responsible
for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned
scope and timing of the audit and significant audit findings, including any significant deficiencies in
internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant
ethical requirements regarding independence, and communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, actions
taken to eliminate threats or safeguards applied.
From the matters communicated with those charged with governance, we determine those matters
that were of most significance in the audit of the separate and consolidated financial statements of the
current period and are therefore the key audit matters. We describe these matters in our auditor’s
report unless law or regulation precludes public disclosure about the matter or when, in extremely rare
circumstances, we determine that a matter should not be communicated in our report because the
adverse consequences of doing so would reasonably be expected to outweigh the public interest
benefits of such communication.
Report on Other Legal and Regulatory Requirements
We were appointed by the shareholders of the Bank on the shareholders meeting dated 20 June 2022
to audit the Bank’s and the Group’s respective separate and consolidated financial statements for the
year ended 31 December 2024. Our total uninterrupted period of engagement is 2 years.
We confirm that:
•
our audit opinion is consistent with the additional report presented to the Audit Committee of the
Bank dated 9 April 2025;
•
we have not provided any prohibited non-audit services (NASs) referred in Article 5 of EU
Regulation (EU) No 537/2014. We also remained independent of the Bank and the Group in
conducting the audit.
For the period to which our statutory audit relates, we and other KPMG network firms have not
provided any other services to the Bank and its controlled related entities which are not disclosed in
the Business Report or in the separate and consolidated financial statements.
Independent Auditor's Report on the Compliance of the Electronic Separate and
Consolidated Financial Statements with the Delegated Regulation 2019/815 on a Single
Electronic Reporting Format
We have conducted an engagement to provide reasonable assurance as to whether the audited
separate and consolidated financial statements of the Bank and the Group for the financial year ended
31 December 2024 (respectively, “Audited Separate Financial Statements” and “Audited Consolidated
Financial Statements” and, collectively, “Audited Separate and Consolidated Financial Statements”)

have been prepared in accordance with requirements of the Commission Delegated Regulation (EU)
2019/815 of 17 December 2018 on supplementing the Directive 2004/109/EC of the European
Parliament and the Council with regard to regulatory technical standards for establishing a single
electronic reporting format applicable for the year 2024 (»Delegated Regulation«).
Responsibilities of Management and Those Charged with Governance
Management is responsible for the preparation and presentation of the Audited Separate and
Consolidated Financial Statements in accordance with the Delegated Regulation, and for such internal
control as management determines is necessary to enable the preparation of the Audited Separate
and Consolidated Financial Statements that are free from material misstatement, whether due to fraud
or error.
Those charged with governance are responsible for overseeing the preparation of the Audited
Separate and Consolidated Financial Statements in compliance with requirements of the Delegated
Regulation.
Auditor’s Responsibilities
Our responsibility is to express an opinion on whether the Audited Separate and Consolidated
Financial Statements are prepared in accordance with requirements of the Delegated Regulation. We
conducted our assurance engagement in accordance with the International Standard on Assurance
Engagements (ISAE) 3000 Revised, Assurance Engagements Other than Audits or Reviews of
Historical Financial Information issued by the International Auditing and Assurance Standards Board.
That standard requires that we plan and perform our procedures to obtain reasonable assurance
about whether the separate and consolidated financial statements in the ESEF format are properly
prepared and presented in accordance with the requirements of the Delegated Regulation, in all
material respects.
We have acted in accordance with the independence and ethical requirements of the EU Regulation
537/2014 and the International Code of Ethics for Professional Accountants (including International
Independence Standards) issued by the International Ethics Standards Board of Accountants (IESBA
Code), together with the ethical requirements that are relevant to our assurance engagements in
Slovenia. The Code is based on the fundamental principles of integrity, objectivity, professional
competence and due care, confidentiality and professional conduct.
Our firm applies International Standard on Quality Management (ISQM) 1, Quality Management for
Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related
Services Engagements, issued by the IAASB, which requires the firm to design, implement and
operate a system of quality management including policies or procedures regarding compliance with
ethical requirements, professional standards and applicable legal and regulatory requirements.
Summary of Work Performed
Within the scope of our work, we performed the following audit procedures:
•
identified and assessed the risks of material non-compliance of the Audited Separate and
Consolidated Financial Statements with the requirements of the Delegated Regulation, whether
due to error or fraud;
•
obtained an understanding of internal control relevant to the engagement in order to provide
reasonable assurance for designing procedures that are appropriate in the circumstances, but not
for the purpose of expressing an opinion on the effectiveness of internal control;
•
assessed whether the Audited Separate Financial Statements are prepared in a correct XHTML
format.
•
assessed whether the Audited Consolidated Financial Statements comply with the requirements of
the Delegated Regulation applicable as of the reporting date;
•
obtained reasonable assurance that the Audited Consolidated Financial Statements of the issuer
are presented in a correct XHTML electronic format;

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report

•
obtained reasonable assurance that the values and disclosures in the Audited Consolidated
Financial Statements in XHTML format are correctly marked and in Inline XBRL (iXBRL)
technology and that their machine reading provides complete and accurate information contained
in the Audited Consolidated Financial Statements; and
•
obtained reasonable assurance that notes to the consolidated financial statements are correctly
block-tagged.
We believe that the evidence obtained provides a sufficient and appropriate basis for our opinion.
Opinion
Based on the procedures performed and the evidence obtained, the Audited Separate and
Consolidated Financial Statements of the Bank and the Group for the financial year ended 31
December 2024 are in our opinion prepared, in all material respects, in accordance with the
requirements of the Delegated Regulation.
On behalf of audit firm

KPMG SLOVENIJA,
podjetje za revidiranje, d.o.o.

Domagoj Vuković, FCCA
Certified Auditor
Partner
Ljubljana, 9 April 2025

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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement of Management’s Responsibility
The Management Board hereby confirms its
responsibility for preparing the consolidated financial
statements of NLB Group and the financial statements of
NLB for the year ending on 31 December 2024, and for
the accompanying accounting policies and notes to the
financial statements.
The Management Board is responsible for the
preparation and fair presentation of these financial
statements in accordance with the International
Financial Reporting Standards as adopted by the
European Union, and with the requirements of the
Slovenian Companies Act and the Banking Act so as
to give a true and fair view of the financial position of
NLB Group and NLB as at 31 December 2024, and their
financial results and cash flows for the year then ended.
The Management Board also confirms that the
appropriate accounting policies were consistently
applied, and that the accounting estimates were
prepared according to the principles of prudence and
good management. The Management Board further
confirms that the financial statements of NLB Group
and NLB, together with the accompanying notes, have
been prepared on a going-concern basis for NLB Group
and NLB, and in line with valid legislation and the
International Financial Reporting Standards as adopted
by the European Union.
The Management Board is also responsible for
appropriate accounting practices, the adoption of
appropriate measures for safeguarding assets, and
the prevention and identification of fraud and other
irregularities or illegal acts.
Management Board of NLB
Hedvika Usenik
Andrej Lasič
Archibald Kremser
Peter Andreas Burkhardt
Antonio Argir
Blaž Brodnjak
Member
Member
Member
Member
Member
Chief Executive Officer

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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Income Statement for the Annual Period ended 31 December
in EUR thousands
NLB Group
NLB
Notes
2024
2023
2024
2023
Interest income calculated using the effective interest method
1,112,288
952,875
602,004
477,154
Other interest and similar income
95,350
40,530
44,926
21,184
Interest and similar income
4.1.
1,207,638
993,405
646,930
498,338
Interest expenses calculated using the effective interest method
(232,863)
(148,034)
(174,429)
(115,779)
Other interest and similar expenses
(40,614)
(12,037)
(40,621)
(9,993)
Interest and similar expenses
4.1.
(273,477)
(160,071)
(215,050)
(125,772)
Net interest income
934,161
833,334
431,880
372,566
Dividend income
4.2.
116
169
223,579
145,258
Fee and commission income
4.3.
435,284
398,741
191,911
170,981
Fee and commission expenses
4.3.
(122,360)
(120,780)
(47,222)
(42,432)
Net fee and commission income
312,924
277,961
144,689
128,549
Gains less losses from financial assets and liabilities not
measured at fair value through profit or loss
4.4.
(160)
(742)
2,503
(834)
Gains less losses from financial assets and liabilities held for trading
4.5.
33,229
32,187
9,979
(408)
Gains less losses from non-trading financial assets mandatorily at fair value through profit or loss
4.6.
3,263
1,784
3,848
2,445
Gains less losses from financial liabilities measured at fair value through profit or loss
(2,903)
(799)
(1,572)
(382)
Fair value adjustments in hedge accounting
5.5.a)
(1,411)
3,899
(1,403)
3,588
Foreign exchange translation gains less losses
4.7.
(3,644)
(2,778)
(3,547)
3,003
Net gains or losses on derecognition of investments in subsidiaries, associates and joint ventures
5.12.d,e)
-
(766)
-
(105)
Gains less losses on derecognition of non-financial assets
3,032
3,200
(213)
49
Other operating income
4.8.
21,849
17,408
14,574
10,376
Other operating expenses
4.8.
(11,829)
(22,100)
(3,908)
(14,382)
Administrative expenses
4.9.
(543,995)
(452,623)
(288,442)
(218,407)
Cash contributions to resolution funds and deposit guarantee schemes
4.10.
(40,213)
(39,093)
(10,793)
(11,383)
Depreciation and amortisation
4.11.
(58,217)
(49,232)
(24,016)
(19,457)
Gains less losses from modification of financial assets
4.12.
(4,280)
(16,271)
-
-
Provisions for credit losses
4.13.
10,728
5,055
8,701
3,074
Provisions for other liabilities and charges
4.13.
(12,847)
(25,925)
(7,149)
(14,422)
Impairment of financial assets
4.14.
(31,306)
6,717
(40,690)
(7,668)
Impairment of non-financial assets
4.14.
(4,014)
53
53,524
97,114
Share of profit from investments in associates and joint ventures
(accounted for using the equity method)
5.12.h)
2,990
1,072
-
-
Gains less losses from non-current assets held for sale
676
5,903
446
172
Profit before income tax
608,149
578,413
511,990
478,746
Income tax
4.15.
(77,916)
(15,090)
(33,829)
35,541
Profit for the year
530,233
563,323
478,161
514,287
Attributable to owners of the parent
514,552
550,700
478,161
514,287
Attributable to non-controlling interests
15,681
12,623
-
-
Earnings per share (in EUR per share)
4.16.
25.7
27.5
23.9
25.7
Diluted earnings per share (in EUR per share)
4.16.
25.7
27.5
23.9
25.7
The notes are an integral part of these financial statements.

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement of Other Comprehensive Income for the Annual Period ended 31 December
in EUR thousands
NLB Group
NLB
Notes
2024
2023
2024
2023
Net profit for the year after tax
530,233
563,323
478,161
514,287
Other comprehensive income after tax
56,704
84,952
25,968
48,078
Items that will not be reclassified to income statement
Actuarial gains/(losses) on defined benefit pensions plans
5.16.c)
(1,307)
(444)
(860)
588
Fair value changes of equity instruments measured at fair
value through other comprehensive income
5.4.c)
9,423
6,796
2,162
2,284
Share of other comprehensive income/(losses) of entities accounted for using the equity method
18
45
-
-
Income tax relating to components of other comprehensive income
5.18.
(1,433)
(973)
(476)
(465)
Items that have been or may be reclassified subsequently to income statement
Foreign currency translation
3,178
1,884
-
-
Translation gains/(losses) taken to equity
3,178
1,884
-
-
Debt instruments measured at fair value through other comprehensive income
57,414
70,926
32,233
33,822
Valuation gains/(losses) taken to equity
5.4.c)
55,781
77,238
31,825
38,046
Transferred to income statement
4.4., 4.14.
1,633
(6,312)
408
(4,224)
Income tax relating to components of other comprehensive income
5.18.
(10,589)
6,718
(7,091)
11,849
Total comprehensive income for the year after tax
586,937
648,275
504,129
562,365
Attributable to owners of the parent
571,081
635,233
504,129
562,365
Attributable to non-controlling interests
15,856
13,042
-
-
The notes are an integral part of these financial statements.

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Annual Report 2024
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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement of Financial Position as at 31 December
in EUR thousands
NLB Group
NLB
Notes
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Cash, cash balances at central banks, and other demand deposits at banks
5.1.
4,039,581
6,103,561
1,973,113
4,318,032
Financial assets held for trading
5.2.a)
18,338
15,718
21,073
17,957
Non-trading financial assets mandatorily at fair value through profit or loss
5.3.a)
17,429
14,175
19,135
16,643
Financial assets measured at fair value through other comprehensive income
5.4.
2,563,516
2,251,556
1,665,019
1,023,012
Financial assets measured at amortised cost
- debt securities
5.6.a)
3,725,195
2,522,229
2,846,779
1,966,169
- loans and advances to banks
5.6.b)
458,921
547,640
193,172
149,011
- loans and advances to customers
5.6.c)
16,363,649
13,734,601
8,653,348
7,148,283
- other financial assets
5.6.d)
136,854
165,962
81,518
101,596
Derivatives - hedge accounting
5.5.b)
77,771
47,614
77,771
47,614
Fair value changes of the hedged items in portfolio hedge of interest rate risk
5.5.c)
(6,353)
(10,207)
(8,761)
(12,514)
Investments in subsidiaries
5.12.a)
-
-
1,179,757
975,757
Investments in associates and joint ventures
5.12.g)
14,661
12,519
4,823
4,823
Tangible assets
Property and equipment
5.8.
310,017
278,034
91,320
85,970
Investment property
5.9.
26,132
31,116
5,599
7,640
Intangible assets
5.10.
100,496
62,117
44,424
37,379
Current income tax assets
604
42
-
-
Deferred income tax assets
5.17.
120,701
111,305
106,327
109,449
Other assets
5.13.
56,819
49,154
17,825
13,907
Non-current assets held for sale
5.7.
11,036
4,849
2,849
4,048
Total assets
28,035,367
25,941,985
16,975,091
16,014,776
Financial liabilities held for trading
5.2.b)
6,995
13,217
9,977
17,510
Financial liabilities measured at fair value through profit or loss
5.3.b)
9,633
4,482
5,597
3,210
Financial liabilities measured at amortised cost
- deposits from banks and central banks
5.15.a)
136,000
95,283
220,120
147,002
- borrowings from banks and central banks
5.15.b)
120,612
140,419
51,106
82,797
- due to customers
5.15.a)
22,206,310
20,732,722
12,293,708
11,881,563
- borrowings from other customers
5.15.b)
104,519
99,718
-
-
- debt securities issued
5.15.c)
1,608,939
1,338,235
1,608,939
1,338,235
- other financial liabilities
5.15.d)
296,725
357,116
145,802
198,020
Derivatives - hedge accounting
5.5.b)
3,592
3,540
1,261
1,420
Provisions
5.16.
104,388
113,305
41,646
48,456
Current income tax liabilities
18,026
35,879
4,328
14,762
Deferred income tax liabilities
5.17.
17,694
1,426
-
-
Other liabilities
5.19.
103,889
58,653
66,998
32,350
Total liabilities
24,737,322
22,993,995
14,449,482
13,765,325
Equity and reserves attributable to owners of the parent
Share capital
5.20.
200,000
200,000
200,000
200,000
Share premium
5.22.a)
871,378
871,378
871,378
871,378
Other equity instruments
5.21.
84,184
84,178
84,184
84,178
Accumulated other comprehensive income
5.22.b)
(19,642)
(76,118)
(10,348)
(36,316)
Profit reserves
5.22.a)
186,332
13,522
186,332
13,522
Retained earnings
1,903,708
1,789,890
1,194,063
1,116,689
3,225,960
2,882,850
2,525,609
2,249,451
Non-controlling interests
72,085
65,140
-
-
Total equity
3,298,045
2,947,990
2,525,609
2,249,451
Total liabilities and equity
28,035,367
25,941,985
16,975,091
16,014,776
The notes are an integral part of these financial statements.

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
The Management Board of NLB has authorised
for issue the financial statements and the
accompanying notes.

Management Board of NLB
Hedvika Usenik
Andrej Lasič
Archibald Kremser
Peter Andreas Burkhardt
Antonio Argir
Blaž Brodnjak
Member
Member
Member
Member
Member
Chief Executive Officer

Ljubljana, 9 April 2025

NLB Group
Annual Report 2024
382
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement of Changes in Equity for the Annual Period ended 31 December
in EUR thousands
Accumulated other
comprehensive income
NLB Group
Share
capital
Share
premium
Other equity
instruments
Fair value
reserve of
financial
assets
measured at
FVOCI
Foreign
currency
translation
reserve
Other
Profit
reserves
Retained
earnings
Equity
attributable
to owners of
the parent
Equity
attributable
to non-
controlling
interests
Total
equity
Notes
5.20.
5.22.a)
5.21.
5.22.b)
5.22.b)
5.22.b)
5.22.a)
Balance as at 1
January 2024
200,000
871,378
84,178
(60,019)
(14,588)
(1,511)
13,522
1,789,890
2,882,850
65,140
2,947,990
- Net profit for the year
-
-
-
-
-
-
-
514,552
514,552
15,681
530,233
- Other comprehensive
income
-
-
-
54,541
3,222
(1,234)
-
-
56,529
175
56,704
Total comprehensive
income after tax
-
-
-
54,541
3,222
(1,234)
-
514,552
571,081
15,856
586,937
Dividends
-
-
-
-
-
-
-
(220,000)
(220,000)
(8,911)
(228,911)
Transfer to profit
reserves
-
-
-
-
-
-
172,810
(172,810)
-
-
-
Transfer of fair
values reserve
-
-
-
(58)
-
5
-
53
-
-
-
Other
-
-
6
-
-
-
-
(7,977)
(7,971)
-
(7,971)
Balance as at 31
December 2024
200,000
871,378
84,184
(5,536)
(11,366)
(2,740)
186,332
1,903,708
3,225,960
72,085
3,298,045
in EUR thousands
Accumulated other
comprehensive income
NLB Group
Share
capital
Share
premium
Other equity
instruments
Fair value
reserve of
financial
assets
measured at
FVOCI
Foreign
currency
translation
reserve
Other
Profit
reserves
Retained
earnings
Equity
attributable
to owners of
the parent
Equity
attributable
to non-
controlling
interests
Total
equity
Notes
5.20.
5.22.a)
5.21.
5.22.b)
5.22.b)
5.22.b)
5.22.a)
Balance as at 1
January 2023
200,000
871,378
84,184
(142,909)
(16,485)
(1,194)
13,522
1,357,089
2,365,585
56,740
2,422,325
- Net profit for the year
-
-
-
-
-
-
-
550,700
550,700
12,623
563,323
- Other comprehensive
income
-
-
-
82,953
1,897
(317)
-
-
84,533
419
84,952
Total comprehensive
income after tax
-
-
-
82,953
1,897
(317)
-
550,700
635,233
13,042
648,275
Dividends
-
-
-
-
-
-
-
(110,000)
(110,000)
(4,634)
(114,634)
Transactions with
non-controlling
interests (note 3.)
-
-
-
-
-
-
-
8
8
(8)
-
Transfer of fair
values reserve
-
-
-
(63)
-
-
-
63
-
-
-
Other
-
-
(6)
-
-
-
-
(7,970)
(7,976)
-
(7,976)
Balance as at 31
December 2023
200,000
871,378
84,178
(60,019)
(14,588)
(1,511)
13,522
1,789,890
2,882,850
65,140
2,947,990

NLB Group
Annual Report 2024
383
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
Accumulated other
comprehensive income
NLB
Share
capital
Share
premium
Other equity
instruments
Fair value
reserve of
financial assets
measured at
FVOCI
Other
Profit
reserves
Retained
earnings
Total
equity
Notes
5.20.
5.22.a)
5.21.
5.22.b)
5.22.b)
5.22.a)
5.20.
Balance as at 1 January 2024
200,000
871,378
84,178
(35,111)
(1,205)
13,522
1,116,689
2,249,451
- Net profit for the year
-
-
-
-
-
-
478,161
478,161
- Other comprehensive income
-
-
-
26,828
(860)
-
-
25,968
Total comprehensive income after tax
-
-
-
26,828
(860)
-
478,161
504,129
Dividends
-
-
-
-
-
-
(220,000)
(220,000)
Transfer to profit reserves
-
-
-
-
-
172,810
(172,810)
-
Other
-
-
6
-
-
-
(7,977)
(7,971)
Balance as at 31 December 2024
200,000
871,378
84,184
(8,283)
(2,065)
186,332
1,194,063
2,525,609
in EUR thousands
Accumulated other
comprehensive income
NLB
Share
capital
Share
premium
Other equity
instruments
Fair value
reserve of
financial assets
measured at
FVOCI
Other
Profit
reserves
Retained
earnings
Total
equity
Notes
5.20.
5.22.a)
5.21.
5.22.b)
5.22.b)
5.22.a)
5.20.
Balance as at 1 January 2023
200,000
871,378
84,184
(79,743)
(1,934)
13,522
515,463
1,602,870
- Net profit for the year
-
-
-
-
-
-
514,287
514,287
- Other comprehensive income
-
-
-
47,521
557
-
-
48,078
Total comprehensive income after tax
-
-
-
47,521
557
-
514,287
562,365
Dividends
-
-
-
-
-
-
(110,000)
(110,000)
Merger of subsidiary
-
-
-
(2,889)
172
-
204,904
202,187
Other
-
-
(6)
-
-
-
(7,965)
(7,971)
Balance as at 31 December 2023
200,000
871,378
84,178
(35,111)
(1,205)
13,522
1,116,689
2,249,451
The notes are an integral part of these financial statements.

NLB Group
Annual Report 2024
384
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Statement of Cash Flows for the Annual Period ended 31 December
in EUR thousands
NLB Group
NLB
Notes
2024
2023
2024
2023
CASH FLOWS FROM OPERATING ACTIVITIES
Interest received
1,176,909
997,912
625,877
494,577
Interest paid
(237,651)
(135,715)
(197,468)
(110,439)
Dividends received
963
417
213,425
138,327
Fee and commission receipts
434,272
397,366
186,775
164,611
Fee and commission payments
(123,432)
(120,892)
(47,382)
(41,809)
Realised gains from financial assets and financial liabilities not at fair value through profit or loss
455
94
-
2
Net gains/(losses) from financial assets and liabilities held for trading
33,491
29,374
8,783
4,287
Payments to employees and suppliers
(502,249)
(467,937)
(243,299)
(216,407)
Other receipts
17,878
16,913
12,295
11,141
Other payments
(63,387)
(63,413)
(15,448)
(24,090)
Income tax (paid)/received
(88,128)
(33,404)
(36,790)
(7,750)
Cash flows from operating activities before changes in operating assets and liabilities
649,121
620,715
506,768
412,450
(Increases)/decreases in operating assets
(2,824,264)
(74,575)
(2,148,023)
(14,214)
Net (increase)/decrease in trading assets
(9,138)
200
(9,138)
200
Net (increase)/decrease in non-trading financial assets mandatorily at fair value through profit or loss
1,191
6,416
998
648
Net (increase)/decrease in financial assets measured at fair value through other comprehensive income
(240,602)
733,788
(595,088)
400,123
Net (increase)/decrease in loans and receivables measured at amortised cost
(2,562,328)
(818,626)
(1,542,445)
(414,239)
Net (increase)/decrease in other assets
(13,387)
3,647
(2,350)
(946)
Increases/(decreases) in operating liabilities
1,380,011
854,231
373,482
280,488
Net increase/(decrease) in deposits and borrowings measured at amortised cost
1,378,653
847,289
371,637
274,363
Net increase/(decrease) in other liabilities
1,358
6,942
1,845
6,125
Net cash flows from operating activities
(795,132)
1,400,371
(1,267,773)
678,724
CASH FLOWS FROM INVESTING ACTIVITIES
Receipts from investing activities
739,185
445,345
159,890
196,331
Proceeds from sale of property, equipment, and investment property
16,310
11,314
2,510
224
Proceeds from sale of subsidiaries, net of cash and cash equivalents
5.12.d, e)
-
12,776
-
20,068
Proceeds from non-current assets held for sale
2,045
16,786
1,893
944
Proceeds from maturity/disposals of debt securities measured at amortised cost
720,830
404,469
155,487
175,095
Payments from investing activities
(2,077,402)
(1,083,639)
(1,184,301)
(551,632)
Purchase of property, equipment, and investment property
(43,452)
(42,681)
(14,920)
(10,152)
Purchase of intangible assets
(29,122)
(19,305)
(19,620)
(12,587)
Purchase of subsidiaries, net of cash acquired and increase in subsidiaries‘ equity
3., 5.12.b, c)
(103,926)
-
(130,545)
-
Purchase of debt securities measured at amortised cost
(1,900,902)
(1,021,653)
(1,019,216)
(528,893)
Net cash flows from investing activities
(1,338,217)
(638,294)
(1,024,411)
(355,301)
CASH FLOWS FROM FINANCING ACTIVITIES
Proceeds from financing activities
795,958
497,708
795,958
497,708
Issuance of subordinated bonds
5.15.c)
298,611
-
298,611
-
Issuance of senior preferred notes
5.15.c)
497,347
497,708
497,347
497,708
Payments from financing activities
(807,886)
(122,273)
(812,061)
(111,264)
Dividends paid
(228,679)
(114,749)
(220,000)
(110,000)
Repayments of subordinated debt
5.15.c)
(270,659)
-
(270,659)
-
Repayment of senior preferred notes
5.15.c)
(300,000)
-
(300,000)
-
Other payments related to financing activities
-
-
(19,930)
-
Lease payments
(8,548)
(7,524)
(1,472)
(1,264)
Net cash flows from financing activities
(11,928)
375,435
(16,103)
386,444
Effects of exchange rate changes on cash and cash equivalents
6,788
(595)
(1,904)
1,039
Net increase/(decrease) in cash and cash equivalents
(2,145,277)
1,137,512
(2,308,287)
709,867
Cash and cash equivalents at beginning of year
6,637,139
5,500,222
4,323,499
3,494,435
Cash and cash equivalents of merged bank at the date of the merger
-
-
-
118,158
Cash and cash equivalents at end of year
4,498,650
6,637,139
2,013,308
4,323,499
The notes are an integral part of these financial statements.

NLB Group
Annual Report 2024
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Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB Group
NLB
Notes
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Cash and cash equivalents comprise:
Cash, cash balances at central banks, and other demand deposits at banks
5.1.
4,040,816
6,104,851
1,973,308
4,318,499
Loans and advances to banks with original maturity up to three months
431,997
506,266
40,000
5,000
Debt securities measured at fair value through other comprehensive
income with original maturity up to three months
25,837
26,022
-
-
Total
4,498,650
6,637,139
2,013,308
4,323,499

NLB Group
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Performance Overview
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NLB Group Key Members
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Financial
Report
Notes to the Financial
Statements
1. General Information on
Reporting Entity
Nova Ljubljanska banka d.d. Ljubljana (hereinafter:
‘NLB’ or ‘the Bank’) is a Slovenian joint-stock entity
providing universal banking services. NLB Group
consists of NLB and its subsidiaries located in nine
countries, mainly in Slovenia and the SEE market.
Information on NLB Group’s structure is disclosed
in note 5.12. Information on other related party
relationships of NLB Group is provided in note 8.
NLB is incorporated and domiciled in Slovenia. The
address of its registered office is Trg Republike 2, 1000
Ljubljana. NLB’s shares are listed on the Ljubljana Stock
Exchange, and the global depositary receipts (‘GDR’)
representing ordinary shares of NLB, are listed on
the London Stock Exchange. Five GDRs represent one
share of NLB.
As at 31 December 2024 and as at 31 December
2023, the largest shareholder of NLB with significant
influence is the Republic of Slovenia, owning 25.00%
plus one share.
2. Summary of Material
Accounting Policy
Information
The material accounting policy information adopted
for the preparation of the separate and consolidated
financial statements are set out below. The policies
have been consistently applied to all the years
presented, except for changes in accounting policies
resulting from the application of new standards or
changes to standards.
2. 1. Statement of compliance
The principal accounting policies applied in the
preparation of the separate and consolidated
financial statements were prepared in accordance
with the International Financial Accounting Standards
(hereinafter: ‘the IFRS’) as adopted by the European
Union (hereinafter: ‘EU’). Additional requirements under
the national legislation are included where appropriate.
The separate and consolidated financial statements
are comprised of the income statement and statement
of other comprehensive income, the statement of
financial position, the statement of changes in equity,
the statement of cash flows, material accounting policy
information, and the notes.
2. 2. Basis for preparation the
financial statements
The financial statements have been prepared on
a going-concern basis, under the historical cost
convention, except for the following items, which are
measured at fair value: financial assets measured
at fair value through other comprehensive income,
financial assets, and financial liabilities at fair
value through profit or loss, including all derivative
contracts, hedged items in fair value hedge accounting
relationships, non-current assets held for sale, liabilities
for cash-settled share-based payment arrangements,
and investment property.
The preparation of financial statements in accordance
with the IFRS requires the use of estimates and
assumptions that affect the reported amounts of assets
and liabilities, the disclosure of contingent assets and
liabilities on the date of the financial statements, and
the reported amounts of revenue and expenses during
the reporting period. Although these estimates are
based on management’s best knowledge of current
events and activities, actual results may ultimately
differ from those estimates. Accounting estimates and
underlying assumptions are reviewed on an ongoing
basis. Revisions of accounting estimates are recognised
in the period in which the estimate is revised. Critical
accounting estimates and judgements in applying
accounting policies are disclosed in note 2.35.
This document contains both the separate financial
statements of NLB, and the consolidated financial
statements of NLB Group. The presented accounting
policies apply to both sets of financial statements,
with the exception of policies described in notes
2.5. and 2.6., which only apply to the consolidated
financial statements and policies described in note
2.7., where differences in the accounting treatment for
investments in subsidiaries, and associates, and joint
ventures between separate and consolidated financial
statements are described. Data relating to separate
financial statements is marked ‘NLB,’ while data
relating to consolidated financial statements is marked
‘NLB Group.’
2. 3. Functional and
presentation currency
These consolidated financial statements are presented
in euro, which is Bank’s functional currency. All amounts
have been rounded to the nearest thousand, except
when otherwise indicated.
2. 4. Comparative amounts
Except when a standard or an interpretation
permits or requires otherwise, all amounts are
reported or disclosed with comparative amounts.
Where IAS 8 applies, comparative figures have been
adjusted to conform to the changes in presentation in
the current year.

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2. 5. Consolidation
In the consolidated financial statements (NLB Group),
subsidiaries which are directly or indirectly controlled
by NLB have been fully consolidated. Subsidiaries are
consolidated from the date on which effective control is
transferred to NLB Group.
NLB controls an entity when all three elements of
control are met:
- it has power over the entity;
- it is exposed or has rights to variable returns from its
involvement with the entity; and
- it has the ability to use its power over the entity to
affect the amount of the entity’s returns.
NLB reassesses whether it controls an entity if facts
and circumstances indicate there are changes to one
or more of the three elements of control. If the loss of
control of a subsidiary occurs, the subsidiary is no longer
consolidated from the date that the control ceases.
Where necessary, the accounting policies of subsidiaries
have been amended to ensure consistency with the
policies adopted by NLB. The financial statements of
consolidated subsidiaries are prepared as at the parent
entity’s reporting date. Non-controlling interests are
disclosed in the consolidated statement of changes in
equity. Non-controlling interest is that part of the net
results, and of the equity of a subsidiary, attributable
to interests which NLB does not own, either directly or
indirectly. NLB Group measures non-controlling interest
on a transaction-by-transaction basis, either at fair
value, or by the non-controlling interest’s proportionate
share of net assets of the acquiree.
Inter-company transactions, balances, and unrealised
gains on transactions between NLB Group entities are
eliminated. Unrealised losses are also eliminated unless
the transaction provides evidence of impairment of the
asset transferred.
NLB Group treats transactions with non-controlling
interests as transactions with equity owners of NLB
Group. For purchases of subsidiaries from non-
controlling interests, the difference between any
consideration paid and the relevant share acquired
of the carrying value of net assets of the subsidiary is
deducted from the equity. For sales to non-controlling
interests, the differences between any proceeds
received and the relevant share of non-controlling
interests are also recorded in the equity. All effects are
presented in the line item ‘Equity Attributable to Non-
controlling Interest.’
2. 6. Business combinations,
goodwill, and bargain purchases
NLB Group accounts for business combinations using
the acquisition method when the acquired set of
activities and assets meets the definition of a business,
and control is transferred to the Group. In determining
whether a particular set of activities and assets is a
business, the Group assesses whether the set of assets
and activities acquired includes, at a minimum, an input
and substantive process, and whether the acquired
set has the ability to produce outputs. The acquired
process is considered substantive if it is critical to the
ability to continue producing outputs; and the inputs
acquired include an organised workforce with the
necessary skills, knowledge, or experience to perform
that process or it significantly contributes to the ability
to continue producing outputs and is considered
unique or scarce or cannot be replaced without
significant cost, effort, or delay in the ability to continue
producing outputs.
The consideration transferred is measured at the
fair value of the assets transferred, equity interest
issued, liabilities incurred or assumed, including
the fair value of assets or liabilities from contingent
consideration arrangements and fair value of any
pre-existing equity interest in the subsidiary. However,
this excludes amounts related to the settlement of pre-
existing relationships which are recognised in profit
or loss. Acquisition-related costs such as advisory,
legal, valuation, and similar professional services are
recognised in profit or loss as well. Transaction costs
incurred for issuing equity instruments are deducted
from the equity, and all other transaction costs
associated with the acquisition are expensed.
Identifiable assets acquired and liabilities assumed in
a business combination are, with limited exceptions,
measured initially at their fair values at the acquisition
date.
A contingent consideration classified as equity is not re-
measured and its subsequent settlement is accounted
for within equity. A contingent consideration classified
as an asset or liability that is a financial instrument
and within the scope of IFRS 9 Financial Instruments
is measured at fair value at each reporting date, and
changes in fair value are recognised in the statement
of profit or loss in accordance with IFRS 9. Other
contingent considerations that are not within the scope
of IFRS 9 are measured at fair value at each reporting
date, and changes in fair value are recognised in profit
or loss.
For each business combination, NLB Group elects
whether to measure the non-controlling interests in
the acquiree at fair value or at the present ownership
instruments’ proportionate share in the recognised
amounts of the acquiree’s identifiable net assets
at the date of acquisition. All other components
of non‑controlling interests are measured at
their acquisition‑date fair values, unless another
measurement basis is required by IFRSs.
Goodwill is measured as the excess of the aggregate
of the consideration transferred measured at fair
value, the amount of any non-controlling interest in
the acquiree, and the fair value of an interest in the
acquiree held immediately before the acquisition date
over the net amounts of the identifiable assets acquired,
as well as the liabilities assumed less any accumulated
impairment losses. Any negative amount, a gain on a
bargain purchase, is recognised in profit or loss after
management reassesses whether it has identified all
the assets acquired and all the liabilities and contingent
liabilities assumed, and reviews the appropriateness of
their measurement.
Goodwill is tested annually for impairment. For the
purpose of impairment testing, goodwill arising from
a business combination is, from the acquisition date,
allocated to the Group’s cash-generating units (CGUs)
or groups of CGUs that are expected to benefit from
the synergies of the combination. Where goodwill has
been allocated to a cash-generating unit (CGU) and
part of the operation within that unit is disposed of,
the goodwill associated with the disposed operation
is included in the carrying amount of the operation
when determining the gain or loss on disposal. Goodwill

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disposed in these circumstances is measured based on
the relative values of the disposed operation and the
portion of the cash-generating unit retained.
The goodwill of associates and joint ventures is
included in the carrying value of investments.
In a business combination achieved in stages, NLB Group
remeasures its previously held equity interest in the
acquiree at its acquisition-date fair value, and recognises
the resulting gain or loss, if any, in profit or loss.
2. 7. Investments in subsidiaries,
associates, and joint ventures
In the separate financial statements (NLB), investments
in subsidiaries, associates, and joint ventures are
accounted for with the cost method. Dividends
from subsidiaries, joint ventures, or associates are
recognised in the income statement when NLB’s right to
receive the dividend has been established.
In the consolidated financial statements, investments in
associates are accounted for using the equity method
of accounting. These are generally undertakings in
which NLB Group holds between 20% and 50% of the
voting rights, and over which NLB Group exercises
significant influence, but does not have control.
Joint ventures are entities over whose activities NLB
Group has joint control, established by contractual
agreement. In the consolidated financial statements,
investments in joint ventures are accounted for using
the equity method of accounting.
NLB Group’s share of its associates and joint ventures
post-acquisition profits or losses is recognised in
the consolidated income statement, and its share
of other comprehensive income is recognised in
other comprehensive income. The cumulative post-
acquisition movements are adjusted against the
carrying amount of the investment. When NLB Group’s
share of losses in an associate and joint venture
equals or exceeds its interest in the associate and joint
venture, including any other unsecured receivables,
NLB Group does not recognise further losses unless it
has incurred obligations or made payments on behalf
of the associate and joint venture. NLB Group resumes
recognising its share of those profits only after its share
of the profits equals the share of losses not recognised
(note 5.12.g).
NLB Group’s subsidiaries, associates, and joint ventures
are presented in note 5.12.
2. 8. A combination of entities
or businesses under
common control
A merger of entities within NLB Group is a business
combination involving entities under common control.
For such mergers, members of NLB Group apply
merger accounting principles, and use the book value
accounting at the date of merger of merged entities as
reported in the consolidated financial statements.
Mergers of entities within NLB Group do not affect the
consolidated financial statements.
When accounting for a merger in separate financial
statements (the merger of a parent company and its
subsidiary) if a surviving entity is the parent company,
NLB applies an accounting policy to recognise the
difference between: (1) the amounts assigned to the
assets and liabilities in the parent’s separate financial
statements after the merger; and (2) the carrying
amounts of the investments in the merged subsidiary
before the merger, directly in equity. In such a case, the
acquired assets and assumed liabilities are recognised
at the carrying amounts from the consolidated financial
statements of merged subsidiary as at the date of
the merger, including any recognised goodwill and
fair value adjustments related to merged subsidiary’s
assets and liabilities. The comparative amounts in
separate financial statements are not restated.
2. 9. Foreign currency translation
Functional and presentation currency
The items included in the financial statements of
each of NLB Group’s entities are measured using the
currency of the primary economic environment in
which the entity operates (i.e., the functional currency).
The financial statements are presented in euros, which
is NLB Group’s presentation currency.
Transactions and balances
Foreign currency transactions are translated into the
functional currency at the exchange rates prevailing
on the dates of the transactions. Foreign exchange
gains and losses resulting from the settlement of such
transactions and from the translation of monetary
assets and liabilities denominated in foreign currencies
are recognised in the income statement, except when
deferred in other comprehensive income as qualifying
cash flow hedges.
Translation differences resulting from changes in the
amortised cost of monetary items denominated in
a foreign currency and classified as financial assets
measured at fair value through other comprehensive
income are recognised in the income statement.
Translation differences on non-monetary items, such
as equity instruments at fair value through profit or
loss, are reported as part of the fair value gain or
loss in the income statement. Translation differences
on non-monetary items, such as equity instruments
classified as financial assets measured at fair value
through other comprehensive income, are included
together with valuation reserves in the valuation
(losses)/gains taken to other comprehensive income
and accumulated in the equity.
Gains and losses resulting from foreign currency
purchases and sales for trading purposes are included
in the income statement as gains less losses from
financial assets and liabilities held for trading.
NLB Group entities
The financial statements of all NLB Group entities
that have a functional currency different from
the presentation currency are translated into the
presentation currency as follows:
- assets and liabilities for each statement of financial
position presented are translated at the closing rate at
the date of statement of financial position;
- income and expenses for each income statement are
translated at average annual exchange rates; and
- components of equity are translated at the historical
rate.
Goodwill and fair value adjustments arising from the
acquisition of a foreign entity are treated as assets

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and liabilities of the foreign entity and translated at the
closing rate.
In the consolidated financial statements, exchange
differences arising from the translation of the net
investment in foreign operations are recognised in
other comprehensive income. When control over a
foreign operation is lost, the previously recognised
exchange differences on translations to a different
presentation currency are reclassified from other
comprehensive income to profit and loss for the year.
On the partial disposal of a subsidiary without loss of
control, the related portion of accumulated currency
translation differences is reclassified as a non-
controlling interest within the equity.
2. 10. Interest income and expenses
Interest income and expenses for all financial
instruments measured at amortised cost, and
financial assets measured at fair value through other
comprehensive income are recognised in the income
statement for all interest-bearing instruments on an
accrual basis using the effective interest method.
Interest income on all trading assets and financial
assets mandatorily required to be measured at fair
value through profit or loss is recognised using the
contractual interest rate. The effective interest method
is used to calculate the amortised cost of a financial
asset or financial liability, and to allocate the interest
income or interest expenses over the relevant period.
The effective interest rate is the rate that exactly
discounts estimated future cash payments or receipts
over the expected life of the financial instrument, or a
shorter period (when appropriate) to the gross carrying
amount of the financial asset, or to the amortised
cost of a financial liability. Interest income includes
coupons earned on fixed-yield investments and trading
securities, and accrued discounts and premiums on
securities. The calculation of the effective interest rate
includes all fees and points paid or received by parties
to the contract and all transaction costs, but excludes
future credit risk losses.
Interest income is calculated by applying the effective
interest rate to the gross carrying amount of financial
assets other than credit-impaired assets.
When a financial asset becomes credit-impaired and
is, therefore, classified in Stage 3, interest income is
calculated by applying the effective interest rate to the
net amortised cost of the financial asset. If the financial
asset cures and is no longer credit-impaired, interest
income is again calculated on a gross basis.
In the case of purchased or originated credit-impaired
financial assets (POCI), the credit-adjusted effective
interest rate is applied to the amortised cost of the
financial asset from initial recognition. The credit-
adjusted effective interest rate is the interest rate that,
at initial recognition, discounts the estimated future
cash flows (including credit losses) to the amortised cost
of the purchased or originated credit-impaired financial
asset. At the NLB Group level, most POCI exposures
relate to the initial recognition of non-performing
exposures in the case of a business combination.
2. 11. Fee and commission income
and expenses
Fees and commission income and expenses mainly
include those related to credit cards and ATMs,
customer transaction accounts, payment services,
investment funds, and commissions from guarantees.
Fee and commission income are recognised at an
amount that reflects the consideration to which the
NLB Group expects to be entitled, in exchange for
providing the services. The performance obligations,
as well as the timing of their satisfaction, are identified
and determined at the inception of the contract. The
Group’s revenue contracts do not include multiple
performance obligations.
When the NLB Group provides a service to its
customers, the consideration is invoiced and generally
due immediately upon satisfaction of a service
provided at a point in time. When the service is
provided over time, the consideration is invoiced and
due in line with the contractual provisions. NLB Group
has generally concluded that it is the principal in its
revenue arrangements because it typically controls the
services before transferring them to the customer.
Fees and commissions that are integral to the effective
interest rate of financial assets and liabilities are
presented within interest income or expenses.
2. 12. Dividend income
Dividends are recognised in the income statement
within the line item ‘Dividend income’ when NLB
Group’s right to receive payment has been established
and an inflow of economic benefits is probable. In the
consolidated financial statements, dividends received
from associates, and joint ventures reduce the carrying
value of the investment.
2. 13. Financial instruments
a) Classification and measurement
Financial instruments are initially measured at
fair value plus or minus, in the case of a financial
instrument not measured at fair value through
profit or loss, transaction costs that are directly
attributable to the acquisition or issue of the financial
instrument. Subsequent measurement depends on the
classification of the instrument.
Financial assets
All debt financial assets need to be assessed based
on a combination of the Group’s business model for
managing the assets and the instruments’ contractual
cash flow characteristics. The measurement categories
of financial assets are as follows:
- Financial assets, measured at amortised costs (AC);
- Financial assets at fair value through other
comprehensive income (FVOCI);
- Financial assets held for trading (FVTPL); and
- Non-trading financial assets, mandatorily at fair value
through profit or loss (FVTPL).
Financial assets are measured at AC if they are held
within a business model for the purpose of collecting
contractual cash flows (‘held to collect’), and if cash
flows are solely payments of principal and interest
on the principal amount outstanding. After initial
recognition, they are measured at the amortised cost
using the effective interest method and are subject
to impairment. Interest income calculated using the
effective interest method, foreign exchange gains and
losses, and impairment are recognised in profit or loss.
Each of them is presented as a separate line item in the
income statement. Any gain or loss on derecognition is
recognised in profit or loss in line item ‘Gains less losses

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from financial assets and liabilities not measured at fair
value through profit or loss.’
Debt financial instruments are measured at FVOCI if
they are held within a business model for the purpose of
both collecting contractual cash flows and selling (‘held
to collect and sell’), and if cash flows are solely payments
of principal and interest on the principal amount
outstanding. FVOCI results in the debt instruments
being recognised at fair value in the statement of
financial position and at the AC in the income statement.
Interest income is calculated using the effective interest
method, foreign exchange gains and losses, and
impairments are recognised separately in the income
statement. Other net gains and losses are recognised
in other comprehensive income, until the instrument is
derecognised. At derecognition of the debt financial
instrument, the cumulative gains and losses previously
recognised in other comprehensive income are
reclassified to the income statement under the line item
‘Gains less losses from financial assets and liabilities not
classified at fair value through profit or loss.’
Equity instruments that are not held for trading may be
irrevocably designated as FVOCI, with no subsequent
reclassification of gains or losses to the income
statement. Dividends are recognised as income in
profit or loss unless the dividend clearly represents a
recovery of part of the cost of the investment, in which
case, such gains are recorded in other comprehensive
income. Other net gains and losses are recognised
in other comprehensive income and are never
reclassified to profit or loss. In NLB Group, the most
material equity instrument irrevocably designated as
FVOCI is the investment in the National Resolution Fund
(note 5.4.a). NLB Group decided to use this presentation
alternative because the fund was established based
on the law, and it has a highly regulated investment
strategy in order to ensure safety, low risk, and the high
liquidity of the fund.
All other financial assets are mandatorily measured at
FVTPL, including financial assets within other business
models such as financial assets managed at fair value
or those held for trading and financial assets with
contractual cash flows that are not solely payments
of principal and interest on the principal amount
outstanding. Net gains and losses, including any interest
or dividend income, are recognised in profit or loss.
Financial liabilities
Financial liabilities are subsequently measured at the
amortised cost or at fair value through profit or loss,
when they are held for trading, derivative instruments,
or the fair value designation is applied.
Upon initial recognition, financial liability may be
irrevocably designated as measured at fair value
through profit or loss if that eliminates or significantly
reduces a measurement or recognition inconsistency
that would otherwise arise from measuring assets or
liabilities or recognising the gains or losses on them on
different bases, or if the liabilities are part of a group
of financial instruments which are managed and
their performance evaluated on a fair value basis in
accordance with a documented risk management or
investment strategy.
Changes in the fair value of financial liabilities
designated as measured at fair value through profit or
loss are recognised in profit or loss, with the exception
of movement in the fair value due to changes of NLB
Group’s own credit risk. Such changes are presented
in other comprehensive income with no subsequent
reclassification to the income statement.
Other financial liabilities are subsequently measured
at amortised cost using the effective interest method.
Interest expenses and foreign exchange gains and
losses are recognised in profit or loss. Any gain or loss
on the derecognition of a financial liability is recognised
in profit or loss. In the event of derecognition of a
financial liability measured at amortised cost, the gains
and losses are recognised in the line item ‘Gains less
losses from financial assets and liabilities not measured
at fair value through profit or loss.’ Gains and losses on
disposals of financial liabilities designated as measured
at fair value through profit or loss are also presented
separately from those held for trading.
Assessment of NLB Group’s business model
NLB Group has determined its business model
separately for each reporting unit within NLB Group,
and is based on observable factors for different
portfolios that best reflect how the Group manages
groups of financial assets to achieve its business
objective, such as:
- how the performance of the business model and
the financial assets held within that business model
are evaluated and reported to key management
personnel;
- the risks that affect the performance of the business
model and, in particular, the way those risks are
managed;
- how the managers of the business are compensated
(e.g., whether the compensation is based on the fair
value of the assets or on collection of contractual cash
flows); and
- the expected frequency, value, and timing of sales.
The business model assessment is based on
reasonably expected scenarios without taking worst-
case and stress case scenarios into consideration. In
general, the business model assessment of the Group
can be summarised as follows:
- Loans and deposits given are included in a business
model ‘held to collect’ since the primary objective
of NLB Group for the loan portfolio is to collect the
contractual cash flows;
- Debt securities are divided into three business models:
• the first group of debt securities presents the ‘held
for trading’ category;
• debt securities in the second group are held under
a business model ‘held to collect and sell’ with the
intention of collecting the contractual cash flows
and sale of financial assets, and forms part of the
Group’s liquidity reserves;
• the third part of debt securities is held within the
business model for holding them with the objective
to collect contractual cash flows.
With regard to debt securities within the ‘held to collect’
business model, the sales which are related to the
increase of the issuers’ credit risk, sales made close to
the final maturity, or sales in order to meet liquidity needs
in a stress case scenario are permitted. Other sales,
which are not due to an increase in credit risk may still be
consistent with a held to collect business model if such
sales are incidental to the overall business model, and:
- are insignificant in value both individually and in
aggregate, even when such sales are frequent;
- are infrequent even when they are significant in value.

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A review of instruments’ contractual cash flow
characteristics (the SPPI test – solely payment of
principal and interest on the principal amount
outstanding)
The second step in the classification of the financial
assets in portfolios being ‘held to collect’ and ‘held to
collect and sell’ relates to the assessment of whether
the contractual cash flows are consistent with the SPPI
test. The principal amount reflects the fair value at
initial recognition less any subsequent changes, e.g.
due to repayment. The interest must represent only the
consideration for the time value of money, credit risk,
other basic lending risks, and a profit margin consistent
with basic lending features. If the cash flows introduce
more than de minimis exposure to risk or volatility
that is not consistent with basic lending features, the
financial asset is mandatorily measured at fair value
through profit or loss.
NLB Group reviews the portfolio within ‘held to collect’
and ‘held to collect and sell’ for standardised products
on a level of a product and for non-standardised
products on a single exposure level. The Group has
established a procedure for SPPI identification as
part of regular investment process with defined
responsibilities for primary and secondary controls.
Special emphasis is put on new and non-standardised
characteristics of loan agreements.
Accounting policy for modified financial assets
When contractual cash flows of a financial asset are
modified, NLB Group assesses whether the cash flows
of modified asset are substantialy different to the extent
that it becomes a new financial asset. The following
factors are, amongst others, considered when making
such assessment:
- reason for modification of cash flows;
- change in currency of the loan;
- introduction of an equity feature;
- replacement of initially agreed debtor with a new
debtor that is not related party to initial debtor; and
- if the modification changes the result of the SPPI test.
If the modification results in derecognition of a
financial asset, the new financial asset is initially
recognised at fair value, with the difference recognised
as a derecognition gain or loss, to the extent that an
impairment loss has not already been recorded. If
the modification does not result in cash flows that are
substantially different, the modification does not result
in derecognition. In such cases, NLB Group recalculates
the gross carrying amount of the financial asset and
recognises modification gain or loss in the income
statement. The gross carrying amount is recalculated
as the present value of the renegotiated or modified
contractual cash flows that are discounted at the
financial asset’s original effective interest rate (or
credit-adjusted effective interest rate for purchased or
originated credit-impaired financial assets).
b) Reclassification
Financial assets can be reclassified when and only
when NLB Group’s business model for managing those
assets changes. The reclassification takes place from
the start of the reporting period following the change.
Such changes are expected to be very infrequent, and
none occurred during the presented periods. Financial
liabilities shall not be reclassified.
c) Day one gains or losses
The best evidence of fair value at initial recognition
is the transaction price (i.e., the fair value of the
consideration given or received), unless the fair value
of that instrument is evidenced by a comparison
with other observable current market transactions
in the same instrument (i.e., without modification or
repackaging), or based on a valuation technique whose
variables only include data from observable markets.
If the transaction price on a non-active market is
different than the fair value from other observable
current market transactions in the same instrument, or
is based on a valuation technique whose variables only
include data from observable markets, the difference
between the transaction price and fair value is
recognised immediately in the income statement (‘day
one gains or losses’).
In cases where the data used for valuation are not
fully observable in financial markets, day one gains or
losses are not recognised immediately in the income
statement. The timing of recognition of deferred
day one gains or losses is determined individually.
It is either amortised over the life of the transaction,
deferred until the instrument’s fair value can be
determined using market observable inputs, or realised
through settlement.
d) Derecognition
A financial asset is derecognised when the contractual
rights to the cash flows from the financial asset expire,
or when the financial asset is transferred, and the
transfer qualifies for derecognition. A financial liability
is derecognised only when it is extinguished, i.e., when
the obligation specified in the contract is discharged,
cancelled, or expires.
e) Write-offs
NLB Group writes off financial assets in their entirety
or a portion thereof when it has no reasonable
expectations of recovery. Criteria indicating that there
is no reasonable expectation of recovery include
default period, quality of collateral, and different
stages of enforcement procedures. NLB Group may
write off financial assets that are still subject to
enforcement activities, but this does not affect its
rights in the enforcement procedures. NLB Group still
seeks to recover all amounts it is legally entitled to in
full. A write-off reduces the gross carrying amount of
a financial asset and allowance for the impairment.
Any subsequent recoveries are credited to credit loss
expenses. Write-offs and recoveries are disclosed in
note 5.14.a and b).
f) Fair value measurement principles
The fair value of financial instruments traded on active
markets is based on the price that would be received to
sell the assets or transfer liability (the exit price) being
measured at the reporting date, excluding transaction
costs. If there is no active market, the fair value of the
instruments is estimated using discounted cash flow
techniques or pricing models.
If discounted cash flow techniques are used, estimated
future cash flows are based on management’s best
estimates; and the discount rate is a market-based
rate at the reporting date for an instrument with similar
terms and conditions. If pricing models are used, inputs
are based on market-based measurements at the
reporting date.

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g) Derivative financial instruments and
hedge accounting
Derivative financial instruments – including forward
and futures contracts, swaps, and options – are
initially recognised in the statement of financial
position at fair value. Derivative financial instruments
are subsequently re-measured at their fair value.
Fair values are obtained from quoted market prices,
discounted cash flow models, or pricing models, as
appropriate. All derivatives are carried at their fair
value within assets when the derivative position is
favourable to NLB Group, and within liabilities when the
derivative position is unfavourable to NLB Group.
The method of recognising the resulting fair value gain
or loss depends on whether the derivative is designated
as a hedging instrument and, if so, the nature of the
item being hedged. NLB Group designates certain
derivatives as either:
- hedges of the fair value of recognised assets or
liabilities or firm commitments (fair value hedge);
- hedges of highly probable future cash flows
attributable to a recognised asset or liability, or a
highly probable forecasted transaction (cash flow
hedge); or
- hedges of a net investment in a foreign operation (net
investment hedge).
Hedge accounting is used when certain criteria are
met. NLB Group and NLB have exercised the option to
continue applying the existing IAS 39 hedge accounting
requirements in accordance with the policy choice
permitted under IFRS 9. However, disclosures that are
required by the IFRS 9-related amendments to IFRS 7
‘Financial Instruments: Disclosures’ are implemented.
At the inception of the transaction, NLB Group
documents the relationship between hedged items and
hedging instruments, as well as its risk management
objective, valuation methodology, and strategy for
undertaking various hedge transactions. NLB Group
also documents its assessment, both at the hedge
inception and on an ongoing basis, of whether the
derivatives used in hedging transactions are highly
effective in offsetting changes in fair values or cash
flows of hedged items. The actual results of a hedge
must always fall within a range of 80–125%.
Fair value hedge
Changes in the fair value of derivatives that are
designated and qualify as fair value hedges are
recognised in the income statement together with
any changes in the fair value of the hedged asset
or liability that are attributable to the hedged
risk. Effective changes in the fair value of hedging
instruments and related hedged items are reflected
in ‘Fair Value Adjustments in Hedge Accounting’
in the income statement. Any ineffectiveness from
derivatives is recognised immediately in the income
statement, recorded in the same line as change in fair
value of hedging instruments and hedged item if they
are different.
If a hedge no longer meets the hedge accounting
criteria, the adjustment to the carrying amount of the
hedged item for which the effective interest method is
used is amortised to profit or loss over the remaining
period to maturity. The adjustment to the carrying
amount of a hedged equity security is included in the
income statement upon disposal of the equity security.
Cash flow hedge
The effective portion of changes in the fair value of
derivatives that are designated and qualify as cash flow
hedges is recognised in other comprehensive income.
The gain or loss relating to the ineffective portion is
immediately recognised in the income statement.
Amounts accumulated in equity are recycled as a
reclassification from other comprehensive income
to the income statement in the periods when the
hedged item affects the profit or loss. When a hedging
instrument expires or is sold, or when a hedge no
longer meets hedge accounting criteria, any cumulative
gain or loss existing in other comprehensive income
and previously accumulated in equity at that time
remains in other comprehensive income and in equity,
and is recognised in profit or loss only when the
forecasted transaction is ultimately recognised in the
income statement. When a forecasted transaction is no
longer expected to occur, the cumulative gain or loss
that was reported in other comprehensive income is
immediately transferred to the income statement.
Hedge of a net investment in a foreign operation
Hedges of net investments in foreign operations are
accounted for in consolidated financial statements
similar to cash flow hedges. Any gain or loss on the
hedging instrument relating to the effective portion
of the hedge is recognised directly in equity. The gain
or loss relating to the ineffective portion is recognised
immediately in the consolidated income statement in
‘Gains Less Losses on Financial Assets and Liabilities
Held for Trading.’ Gains and losses accumulated in
other comprehensive income are included in the
consolidated income statement when the foreign
operation is disposed of as part of the gain or loss on
the disposal.
2. 14. Allowances for financial assets
a) Expected credit losses for collective allowances
IFRS 9 applies an expected loss model that provides an
unbiased and probability-weighted estimate of credit
losses by evaluating a range of possible outcomes that
incorporates forecasts of future economic conditions.
The expected loss model requires NLB Group to
recognise not only credit losses that have already
occurred, but also losses that are expected to occur
in the future. An allowance for expected credit losses
(ECL) is required for all loans and other debt financial
assets not measured at FVTPL, together with loan
commitments and financial guarantee contracts.
In the general model, the allowance is based on the
expected credit losses associated with the probability
of default in the next 12 months unless there has
been a significant increase in credit risk since initial
recognition, in which case, the allowance is based on
the probability of default over the life of the financial
asset (LECL). When determining whether the risk
of default has increased significantly since initial
recognition, the Group considers reasonable and
supportable information that is relevant and available
without undue cost or effort. This includes both
quantitative and qualitative information and analysis,
based on the Group’s historical data, experience, expert
credit assessment, and incorporation of forward-
looking information.

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Classification into stages
NLB Group prepared a methodology for ECL defining the
criteria for classification into stages, transition criteria
between stages, models for risk indicators calculation,
forward-looking scenarios, and the validation of
models. The Group classifies financial instruments into
Stage 1, Stage 2, and Stage 3, based on the applied ECL
allowance methodology as described below:
- Stage 1 – A performing portfolio: no significant
increase of credit risk since initial recognition, NLB
Group recognises an allowance based on 12-month
period;
- Stage 2 – An underperforming portfolio: significant
increase in credit risk (SICR) since initial recognition,
NLB Group recognises an allowance for lifetime
period; and
- Stage 3 – An impaired portfolio: NLB Group recognises
lifetime allowances for these defaulted financial
assets.
The Bank has aligned its definition of credit impaired
assets under IFRS 9 to the European Banking Authority
(EBA) definition of non-performing loans (NPLs). The
Bank uses a unified definition of past due and default
exposures; defaulted clients are rated D, DF, or E based
on the internal rating system and contain the clients
with material delays over 90 days, as well as the clients
that were assessed as unlikely to pay. All facilities of
retail clients obtain a unified credit rating.
A significant increase in credit risk is assumed:
- when a credit rating significantly deteriorates at the
reporting date in comparison to the credit rating
at initial recognition a significant deterioration is a
3-notch rating decrease taking into consideration the
NLB Group’s long rating scale (with nine performing
rating classes) or deterioration from invest/invest
with care to speculative investment rating grade on
the short rating scale (with only three performing
rating groups),
- when a threefold increase of LPD since initial
recognition is detected (comparing the LPD assessed
using the PD curve calculated at instrument
origination and the last available PD curve),
- when a financial asset has material delays over
30 days with a healing period of three months and
the materiality limit aligned with the one used as a
default trigger (the materiality limit is aligned with
the regulatory limit for default definition, the holding
period of three months is applied),
- if NLB Group grants a forbearance to the borrower
where the rules of forbearance expiry are aligned
with the ECB Guidelines,
- if the legal entity is placed on the watch list or
intensive care list,
- if a retail client is placed on the watch list based on
features which lead to increased credit risk (such as
spending habits, decreased employment security,
political risk, etc.).
The methodology of credit rating for banks and
sovereign classification depends on the existence or
non-existence of a rating from international credit
rating agencies – Fitch, Moody’s, or the S&P. Ratings
are set on a basis of the average international credit
rating. If there are no international credit ratings
available, the credit rating classification is based on the
internal Methodology Rating Classification for Financial
Markets clients’ segments in NLB d.d. and NLB Group.
For banks without an international credit rating, we
obtain information from Bureau van Dijk, a Moody’s
Analytics Company, using the modules BankScore and
BankFocus. Additionally, information is obtained by an
analyst from the annual reports with the assistance of
the central relationship manager.
The classification into stages is based on the facility
level. Nevertheless, occurring delays on one facility may
trigger the stage deterioration of other facilities of the
same client. When the SICR criteria no longer exist, the
facility may be transferred to a more favourable stage
subject to the prescribed cure period of three months.
The ECL for Stage 1 financial assets is calculated based
on 12-month PDs or shorter period PDs, if the remaining
maturity of the financial asset is shorter than one year.
The 12-month PD already includes the macroeconomic
impact effect. Allowances in Stage 1 are designed to
reflect expected credit losses that had been incurred in
the performing portfolio but have not been identified.
The ECL for Stage 2 financial assets is calculated based
on lifetime PDs (LPD) because their credit risk has
increased significantly since their initial recognition.
This calculation is also based on a forward-looking
assessment that considers several economic scenarios
in order to recognise the probability of losses associated
with the predicted macro-economic forecasts.
For financial instruments in Stage 3, the same treatment
is applied as for those considered to be credit impaired.
Exposures below the materiality threshold obtain
collective allowances using a PD of 100%. Financial
instruments will be transferred out of Stage 3 if they
no longer meet the criteria of being credit-impaired
after a probation period. Special treatment applies
for purchased or originated credit-impaired financial
instruments (POCI), where only the cumulative changes
in lifetime expected losses since the initial recognition
are recognised as a loss allowance.
The calculation of collective allowances is performed
by multiplying the EAD (exposure at default) at the
end of each month with an appropriate PD and LGD
(loss-given default). The obtained result for each
month is discounted to the present time using the
original effective interest rate of the facility. For Stage
1 exposures, the ECL only takes a 12-month period into
account, while for Stage 2 or 3 all potential losses until
the maturity date are included. Risk parameters are
calculated separately for each of the three possible
scenarios. The final ECL for each facility is calculated as
a weighted average ECL for each scenario.
The EAD represents the anticipated outstanding
amount owed by the obligor, which is determined as
the sum of on-balance exposure and expected future
drawings of the off-balance exposure. The drawings
are assessed by applying the CCF (credit conversion
factor) based on the Bank’s historic experience with
similar types of facilities.
The PD is the estimation of the likelihood of default
over a given time horizon. The estimation is performed
separately for each unique segment (corporate
clients by size, institutions, or central government), or
by product group (mortgage, consumer loans, and
other retail products). Through the cycle, the PD is
supplemented with the forward-looking aspect using
three possible scenarios.
Risk parameter calculations are based on the data
from each subsidiary, while the calculations and
modelling are performed centrally. In the case where

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the data samples are not sufficiently large, hurdle
rates are applied based on the regulatory or other
benchmarks.
Expected Life
When measuring ECL, NLB Group must consider the
maximum contractual period over which the Group
is exposed to credit risk. For certain revolving credit
facilities that do not have a fixed maturity, the expected
life is estimated based on the period over which the NLB
Group is exposed to credit risk and where the credit
losses would not be mitigated by management actions.
Forward-looking information
During 2024, NLB Group reviewed the IFRS 9
provisioning by testing the relevant macroeconomic
scenarios to accurately reflect the current
circumstances and their future impacts.
NLB Group established multiple scenarios (i.e., baseline,
optimistic, and severe) for the ECL calculation, aiming
to create a unified projection of macroeconomic and
financial variables for the Group, aligned with the
Bank’s consolidated view of the future of economic
development in the SEE. The Group formed three
probable scenarios with an associated probability of
occurrence for forward-looking assessment of risk
provisioning in the context of the IFRS 9. These IFRS 9
macroeconomic scenarios incorporate the forward-
looking and probability-weighted aspects of the ECL
impairment calculation. Both features may change
when material changes in the future development of
the economy are recognised and not embedded in
previous forecasts.
The baseline scenario presents an expected forecast
macroeconomic view for all the countries of the
Group. This scenario is based on recent official and
professional forecasts, with specific adjustments for
individual countries of the Group. Key characteristics
include decreasing inflation as an energy-related
impact on goods and services prices abate, a slightly
less tight labour market, GDP growth supported by
declining interest rates and strong private consumption
due to real wage growth, resilient labour market and
positive expectations, industry and export activity
pick-up, and limited spillover effects of financial system
issues/major trading partners growth slowdown on the
real economy.
The alternative scenarios are based on plausible
drivers of economic development for the next three
years. The optimistic alternative scenario demonstrates
supply-driven positive developments. Supply chains
adapt swiftly and support optimistic economic stance
– this keeps a lid on inflation pressures. Labour skill
mismatches are addressed through targeted training
programs. Automation and technology adoption create
new job opportunities, offsetting any displacement. In
the short-term, financing conditions ease, and business
confidence rebounds. Consumer spending picks up,
contributing to overall growth. The ECB considers both
demand and supply factors when setting interest rates.
In this scenario, the ECB maintains a dovish stance,
easing aggressively until the inflation rebound towards
the ECB target.
The severe alternative scenario paints a picture
of bleak economic developments, where supply
constraints, geopolitical tensions, technological
shifts, and labour market disruption hinder economic
recovery. Moreover, high public debt diverts funds from
productive investments. Policymakers must navigate
these challenges to ensure stability and sustainable
growth. This adverse scenario results in a prolonged
global recession, with growth falling well below the
levels needed to achieve sustainable development
goals in the mid-term. The ECB carefully considers both
supply and demand factors when setting interest rates
to prevent abrupt economy shifts.
All of the above scenarios are included in the calculation
of expected credit losses in accordance with IFRS 9.

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Macroeconomic scenarios for explanatory variables,
developed for each country in the NLB Group used in
2024 (in %):
Optimistic scenario
Baseline scenario
Severe scenario
2024
2025
2026
2024
2025
2026
2024
2025
2026
Slovenia
Real GDP
2.9
3.3
3.8
1.9
2.5
3.0
0.8
0.4
2.4
Unemployment rate
4.0
3.8
3.6
4.2
4.2
4.0
4.7
6.2
6.6
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7
Bosnia and Herzegovina
Real GDP
3.1
3.5
3.5
2.5
3.0
3.0
1.8
1.6
2.6
Unemployment rate
12.0
10.6
10.1
12.5
12.0
11.5
13.2
14.5
14.6
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7
Montenegro
Real GDP
5.4
4.9
5.0
3.3
3.2
3.3
1.5
(0.7)
2.5
Unemployment rate
12.5
11.3
11.1
13.0
12.7
12.5
13.7
15.2
15.6
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7
North Macedonia
Real GDP
3.8
4.2
4.2
2.6
3.2
3.2
1.4
0.7
2.6
Unemployment rate
12.2
10.9
10.7
12.7
12.4
12.2
14.4
18.2
19.2
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7
Serbia
Real GDP
3.8
4.1
4.1
2.9
3.4
3.4
2.1
1.7
3.0
Unemployment rate
8.7
7.9
7.7
9.0
8.8
8.6
9.7
12.2
13.0
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7
Kosovo
Real GDP
4.6
4.7
4.7
3.7
4.0
4.0
2.8
2.1
3.5
Unemployment rate
10.0
8.6
8.1
10.5
10.0
9.5
11.2
12.5
12.6
EURIBOR (6 months)
1.7
1.5
1.8
2.9
2.6
2.6
3.9
3.6
3.7

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Macroeconomic scenarios for explanatory variables,
developed for each country in the NLB Group used in
2023 (in %):
Optimistic scenario
Baseline scenario
Severe scenario
2023
2024
2025
2023
2024
2025
2023
2024
2025
Slovenia
Real GDP
2.4
3.4
2.5
0.6
2.2
2.5
(0.6)
0.4
0.7
Unemployment rate
3.9
4.0
4.1
4.0
4.2
4.2
4.5
5.0
5.3
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
Bosnia and Herzegovina
Real GDP
2.3
2.9
2.4
1.0
2.0
2.3
0.3
0.9
1.2
Unemployment rate
15.0
14.0
14.2
15.2
15.1
14.8
15.9
16.2
16.2
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
Montenegro
Real GDP
6.0
5.5
3.4
2.6
3.2
3.2
0.6
0.1
0.1
Unemployment rate
13.5
12.2
12.3
13.7
13.3
12.9
14.4
14.4
14.3
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
North Macedonia
Real GDP
3.6
4.3
3.3
1.6
3.0
3.3
0.3
1.1
1.4
Unemployment rate
13.7
12.7
12.8
13.9
13.7
13.4
15.3
16.0
16.3
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
Serbia
Real GDP
3.3
4.2
3.6
1.8
3.1
3.4
1.1
2.0
2.3
Unemployment rate
9.4
8.6
8.7
9.5
9.2
9.0
10.2
10.4
10.6
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
Kosovo
Real GDP
4.1
4.6
3.8
2.4
3.5
3.8
1.4
2.0
2.3
Unemployment rate
16.3
14.9
14.6
16.5
16.0
15.2
17.2
17.1
16.6
EURIBOR (6 months)
2.4
2.1
2.2
2.7
2.3
2.3
4.6
4.5
4.6
NLB Group formed three probable scenarios with an
associated probability of occurrence for forward-
looking assessment of risk provisioning in the context
of IFRS 9. IFRS 9 macroeconomic scenarios incorporate
the forward-looking and probability-weighted
aspects of ECL impairment calculation. Both features
may change when material changes in the future
development of the economy are recognised and not
embedded in previous forecasts. On this basis, for the
year 2024, NLB Group assigned weights of 20%–60%–
20% (alternative scenarios receiving 20% each, and the
baseline scenario 60%).
Effects of changed risk parameters
The effects of the changed risk parameters on the
amount of expected credit losses are disclosed in notes
5.14. and 5.16.b).
b) Individual assessment of allowances for impaired
financial assets
NLB Group assesses impairments of financial assets
separately for all individually significant assets
classified in Stage 3. The materiality threshold is set at
a EUR 0.5 million exposure for legal entities, and EUR
0.1 million for private persons on the level of NLB, while
the Group members apply lower thresholds applicable
to their portfolio size. All other financial assets obtain
collective allowances.
The amount of loss is measured as the difference
between the asset’s carrying amount and the
present value of estimated future cash flows, which
are discounted to the estimation date. The scenario
of expected cash flows can be based on the ‘going
concern’ assumption, where the cash flow from
operations is considered along with the sale of collateral
that is not crucial for future business. In the case of the
‘gone concern’ principle, the repayments are based
on expected cash flows from the sale of collateral. The
expected payment from the collateral is calculated
from the appraised market value of the collateral, the
haircut is used as defined in the Haircut Methodology,
and discounted. Off-balance sheet liabilities are also
assessed individually and, where necessary, related
allowances are recognised as liabilities.
The carrying amount of financial assets measured
at amortised cost is reduced through an allowance
account and the loss is recognised in the income
statement line item ‘Impairment of financial assets.’
If the number of allowances for ECL decreases
subsequently due to an event occurring after the

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impairment was recognised (e.g., repayment in the
collection process exceeds the assessed expected
payment from collateral), the reversal of the loss is
recognised as a reduction in the allowance account,
and the gain is recognised in the same income
statement item. For off-balance exposures, the amount
of ECL is recognised in the statement of financial
position in the line item ‘Provisions’ and in the income
statement in the line item ‘Provisions for credit losses.’
The ECLs for debt instruments measured at fair
value through other comprehensive income do
not reduce the carrying amount of these financial
assets in the statement of financial position, which
remains at fair value. Instead, an amount equal to
the allowance that would arise if the assets were
measured at amortised cost is recognised in other
comprehensive income as an accumulated impairment
amount, with a corresponding charge to profit or
loss. The accumulated loss recognised in other
comprehensive income is recycled to the profit or loss
upon derecognition of the assets, or when the amount
of allowances for ECL decreases due to an event
occurring after the impairment was recognised.
2. 15. Forborne loans
A forborne loan (or restructured financial asset) arises
as a result of a debtor’s inability to repay a debt under
the originally agreed terms, either by modifying the
terms of the original contract (via an annex) or by
signing a new contract under which the contracting
parties agree the partial or total repayment of the
original debt. When receivables from the client receive
restructuring status, the debtor must be classified in the
rating grade C or lower.
The definitions of forborne loans closely follow
definitions that were developed by the European
Banking Authority (EBA). These definitions aim to
achieve comprehensive coverage of exposures to which
forbearance measures have been extended.
The accounting treatment of forborne loans depends
on the type of restructuring. When NLB Group embarks
on a forborne loan via the modified terms of repayment
proceeding from extending the deadline for the
repayment of the principal and/or interest, and/or a
forbearance of the repayment of the principal, and/
or interest or a reduction in the interest rate, and/or
other expenses, it adjusts the carrying amount of the
forborne loan on the basis of the discounted value of
the estimated future cash flows under the modified
terms, and recognises the resulting effect in profit or
loss. In the event of the reduction of a claim against the
debtor via the reduction in the amount of the claims
as a result of a contractually agreed debt waiver and
ownership restructuring or debt to equity swap, NLB
Group derecognises the claim in the part relating to
the write-down or the contractually agreed upon debt
waiver. The new estimate of the future cash flows for
the residual claim, not yet written down, is based on an
updated estimate of the probability of loss. NLB Group
considers the debtor’s modified position, the economic
expectations, and the collateral of the forborne loan.
When NLB Group is embarking on the forborne loan by
taking possession of other assets (i.e., property, plant,
and equipment; securities; and other financial assets),
including investments in the equity of debtors obtained
via debt-to-equity swaps, it recognises the acquired
assets in the statement of financial position at fair
value, recognising the difference between the fair value
of the asset and the carrying amount of the eliminated
claim in profit or loss.
Forborne exposures may be identified in both the
performing and non-performing parts of the portfolio.
Where the forborne loan is classified in the non-
performing part of the portfolio, it can be reclassified
to the performing part when exposure is no longer
considered as impaired or defaulted, when determined
amounts were repaid, when one year has passed
from the latest of the events defined (introduction of
forbearance, classification in the non-performing part,
repayment of the last overdue amount, end of the grace
period), and after the introduction of forbearance there
have been no overdue amounts or doubts concerning
the repayment of the entire exposure, under the terms
and conditions after the forbearance. The absence of
doubt is confirmed by analysis of the financial situation
of the debtor. The forborne status is withdrawn when:
- at least a 2-year probation period has passed since
the latest of:
• the moment of extending the restructuring
measures, or
• the forborne exposure was deemed performing;
- regular payments of the principal or interest were
made, in a substantial total amount, during at least
half the probation period;
- no exposure, in the probation period, is more than 30
days in default of more than EUR 100;
- the client fulfils determined financial indicators.
In the case of a deferral of payment approved due to
the COVID-19 crisis, the probation period is extended
for the period of deferral.
2. 16. Repossessed assets
In certain circumstances, assets are repossessed
following the foreclosure on loans that are in default.
Repossessed assets are initially recognised in the
financial statements at their fair value and classified in
the appropriate category according to their purpose
and are sold as soon as it is feasible in order to reduce
exposure (note 6.1.l). After initial recognition, the
repossessed assets are measured and accounted for in
accordance with the policies applicable to the relevant
asset categories. Non-financial repossessed assets
mainly represent items of real estate that NLB Group
classifies within investment properties measured in
accordance with an IAS 40 Investment property (note
2.21.), and other assets measured in accordance with
IAS 2 Inventories.
Real estate obtained as collateral from the foreclosure
of loans and receivables, classified as other assets
are initially recognised at fair value less costs to sell
(realisable value), wherein only the direct costs of
sales can be considered, but up to the amount of gross
carrying amount of foreclosed loan. At subsequent
measurement, the realisable value is verified at least
annually. Valuations of the fair value of real estate are
performed by certified real estate appraisers. The real
estate is impaired when the carrying value exceeds the
realisable value. The effect of impairment is recognised
as the impairment of other assets, and the reversal
of impairment as income from the reversal of the
impairment of other assets.
2. 17. Offsetting
Financial assets and liabilities are offset, and the net
amount reported in the statement of financial position

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when there is a legally enforceable right to offset the
recognised amounts, and there is an intention to settle
on a net basis, or to realise the asset and settle the
liability simultaneously.
2. 18. Sale and repurchase
agreements
Securities sold under sale and repurchase agreements
(repos) are retained in the financial statements, and the
counterparty liability is recognised in financial liabilities
measured at an amortised cost. Securities sold subject
to sale and repurchase agreements are reclassified in
the financial statements as pledged assets when the
transferee has the right by contract or custom to sell or
re-pledge the collateral. Securities purchased under
agreements to resell (reverse repos) are presented as
loans to other banks or customers, as appropriate.
In financial statements, the difference between the sale
and repurchase price is treated as interest and accrued
over the life of the repo agreements using the effective
interest method.
2. 19. Property and equipment
All items of property and equipment are initially
recognised at cost. They are subsequently measured
at cost less any accumulated depreciation and any
accumulated impairment loss.
Each year, NLB Group assesses whether there are
indications that property and equipment may be
impaired. If any such indication exists, the recoverable
amounts are estimated. The recoverable amount
is the higher of the fair value less costs to sell and
value in use. If the recoverable amount exceeds the
carrying value, the assets are not impaired. If the
carrying amount exceeds the recoverable amount, the
difference is recognised as an impairment loss in the
income statement.
Items of a largely independent property and
equipment which do not generate cash flows are
included in the cash-generating unit and later tested
for possible impairment.
Depreciation is calculated on a straight-line basis over
the assets’ estimated useful lives. The following annual
depreciation rates were applied:
NLB Group and NLB
in %
Buildings
2 – 5
Leasehold improvements
5 – 25
Computers
12.5 – 50
Furniture and equipment
10 – 33.3
Motor vehicles
10 – 25
Depreciation does not begin until the assets are
available for use.
The assets’ residual values and useful lives are reviewed
and adjusted if appropriate on each reporting date.
Gains and losses on the disposal of items of property
and equipment are determined as the difference
between the sale proceeds and their carrying amount,
and are recognised in the income statement.
Maintenance and repairs are charged to the income
statement during the financial period in which they
are incurred. Subsequent costs that increase future
economic benefits are recognised in the carrying amount
of an asset, and the replaced part, if any, is derecognised.
2. 20. Intangible assets
Intangible assets include software licenses, goodwill
(note 2.6.), and identifiable intangible assets acquired
in a business combination. Intangible assets other than
goodwill, have a finite useful life and are in the statement
of financial position stated at cost, less accumulated
amortisation and impairment losses. Amortisation is
calculated on a straight-line basis at rates designed
to write-down the cost of an intangible asset over
its estimated useful life. The core banking system is
amortised over a period of 10 years, and other software
over a period of three to five years. Amortisation does
not begin until the assets are available for use.
The identifiable intangible assets acquired in a
business combination and recognised separately from
goodwill, are recorded at fair value on the acquisition
date if the intangible asset is separable or arises
from contractual or other legal rights. After initial
recognition, intangible assets acquired in a business
combination are measured in accordance with IAS 38
Intangible Assets. Other intangible assets acquired in a
business combination (note 5.10.) relate to core deposits
and trade name. Their useful life is assessed to be five
years. Amortisation of a trade name is calculated on a
straight-line basis, while for core deposits accelerated
amortisation is applied, since it better reflects the
pattern of the asset’s consumption.
2. 21. Investment properties
Investment properties include properties held to
earn rentals, or to increase the value of a long-term
investment, rather than to be used by NLB Group.
Investment properties are carried at fair value
determined by a certified appraiser. Fair value is
based on current market prices. Any gain or loss
arising from a change in the fair value is recognised in
the income statement.
2. 22. Non-current assets and
disposal groups classified as
held for sale
Non-current assets and disposal groups are classified
as held for sale if their carrying amount will be
recovered through a sale transaction rather than
through continuing use. This condition is deemed to
be met only when the sale is highly probable, and the
asset is available for immediate sale in its present
condition. Management must be committed to the sale,
which should be expected to qualify for recognition
as a completed sale within one year from the date of
classification. Non-current assets and disposal groups
classified as held for sale are measured at the lower of
the assets’ previous carrying amount and fair value less
costs to sell.
In the case of business combinations, NLB Group
measures an acquired non‑current asset (or disposal
group) that is classified as held for sale at the
acquisition date in accordance with IFRS 5 Non‑current
Assets Held for Sale and Discontinued Operations at
fair value less costs to sell.
During subsequent measurement, certain assets and
liabilities of a disposal group that are outside the scope
of IFRS 5 measurement requirements are measured
in accordance with the applicable standards (e.g.,

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deferred tax assets, assets arising from employee
benefits, financial instruments, investment property
measured at fair value, and contractual rights under
insurance contracts). Tangible and intangible assets
are not depreciated. The effects of sale and valuation
are included in the income statement as a gain or loss
from non-current assets held for sale.
Liabilities directly associated with disposal groups are
reclassified and presented separately in the statement
of financial position.
2. 23. Accounting for leases
A lease is a contract, or part of a contract which creates
enforceable rights and obligations and conveys the
right to control the use of an identified asset for a
period of time in exchange for a consideration. Thus,
IFRS 16 requires determination whether a contract is, or
contains, a lease.
NLB Group as a lessee
NLB Group recognises a liability to make lease
payments and an asset representing the right to use the
underlying asset (i.e., the right-of-use asset) during the
lease term for all leases, except for short-term leases
and leases of low-value. Short-term leases are defined
as those which at the commencement date have a lease
term of 12 months or less without the option to purchase
the underlying asset. Leases of underlying assets with a
value, when new, lower, or equal to EUR 5 thousand are
defined as low value leases, and are thus recognised as
expenses on a straight-line basis over the lease term.
Right-of-use assets
At the commencement date, NLB Group measures
the right-of-use asset at cost. The cost of right-of-
use assets consists of the amount of lease liabilities
recognised, the initial direct costs incurred, an
estimate of costs to be incurred by the lessee in
dismantling and removing the underlying asset to
the condition required by the terms and conditions of
the lease and lease payments made at or before the
commencement date less any lease incentives received.
After the commencement date, NLB Group measures
the right-of-use asset using a cost model (the asset
is measured at cost, reduced by any accumulated
depreciation and impairment losses, and adjusted for
any remeasurement of lease liabilities) and recognises
depreciation of the right-of-use assets on a straight-
line basis over the lease term, and (separately) interest
on the lease liabilities. In the statement of financial
position, right-of-use assets are presented in the line
item ‘Property and equipment.’
Lease liabilities
At the commencement date, NLB Group measures
the lease liability at the present value of the lease
payments that are not paid at that date. The lease
payments consist of fixed payments, variable lease
payments that depend on an index or a rate, amounts
expected to be paid under residual value guarantees,
the exercise price of a purchase option if there exists
a reasonable certainty for it to be exercised, and
payments of penalties for terminating the lease if the
lease term suggests reflects exercising the option to
terminate. Subsequently (after the commencement
date), NLB Group measures the lease liability by:
- increasing the carrying amount to reflect interest on
the lease liability;
- reducing the carrying amount to reflect the lease
payments made;
- remeasuring the carrying amount to reflect any
reassessment or lease modifications.
In the statement of financial position, lease liabilities
are presented in the line item ‘Other financial liabilities.’
NLB Group as a lessor
Payments under operating leases are recognised
as income on a straight-line basis over the period of
the lease. Assets leased under operating leases are
presented in the statement of financial position as
investment property or as property and equipment.
NLB Group classifies a lease as a finance lease when
the risks and rewards incidental to ownership of a
leased asset lie with the lessee. When assets are leased
under a finance lease, the present value of the lease
payments is recognised as a receivable. Income from
finance lease transactions is amortised over the lifetime
of the lease using the interest rate implicit in the lease.
Finance lease receivables are recognised at an amount
equal to the net investment in the lease, /including the
unguaranteed residual value and any initial direct costs
of the lessor.
Sale-and-leaseback transactions
NLB Group also enters into sale-and-leaseback
transactions (in which NLB Group is primarily a
lessor) under which the leased assets are purchased
from, and then leased back to the lessee. These
contracts are classified as finance leases or
operating leases, depending on the contractual terms
of the leaseback agreement.
Leases recognised in a business combination
In most leases acquired in business combinations,
the acquiree is the lessee. For such leases, NLB Group
applies the IFRS 16 initial measurement provisions
(with exceptions for leases with remaining term of 12
months or less and low value leases), and recognises
the acquired lease liability as if the lease contract was a
new lease at the acquisition date. The right-of-use asset
is measured at an amount equal to the recognised
liability. There are no favourable or unfavourable terms
of the leases relative to market terms, which would
require the adjustment of the right-of-use assets.
2. 24. Cash and cash equivalents
For the purpose of the statement of cash flows, cash
and cash equivalents comprise cash and balances
with central banks, and other demand deposits at
banks, loans to banks, and debt securities not held for
trading with an original maturity of up to three months.
Cash and cash equivalents are disclosed under the
cash flow statement.
2. 25. Borrowings, deposits, and
issued debt securities with
characteristics of debt
Loans and deposits received and issued debt securities
are initially recognised at fair value. Borrowings are
subsequently measured at the amortised cost. The
difference between the value at initial recognition and
the final value is recognised in the income statement as
interest expenses, applying the effective interest rate.
Repurchased own debt is disclosed as a reduction of
liabilities in the statement of financial position. The
difference between the book value and the price at
which own debt was repurchased is disclosed in the
income statement.

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2. 26. Other issued financial
instruments with
characteristics of equity
Upon initial recognition, other issued financial
instruments are classified in part or in full as equity
instruments if the contractual characteristics of the
instruments are such that NLB Group must classify
them as equity instruments in accordance with IAS 32
Financial Instruments: Presentation. An issued financial
instrument is only considered an equity instrument
if that instrument does not represent a contractual
obligation for payment.
Issued financial instruments with characteristics of
equity are recognised in equity in the statement of
financial position. Transaction costs incurred for issuing
such instruments are deducted from retained earnings.
The corresponding interest is recognised directly in
retained earnings.
The carrying value of an issued financial instrument
with characteristics of equity is presented in the
statement of changes in equity in the line item ‘Other
Equity Instruments.’
2. 27. Provisions
Provisions are recognised when NLB Group has a
present legal or constructive obligation as a result
of past events, and it is probable that an outflow
of resources embodying economic benefits will be
required to settle the obligation, and a reliable estimate
of the amount of the obligation can be made. They
are recognised in the amount that is the best estimate
of the expenditure required to settle the present
obligation at the end of the reporting period. The
provision assessment considers:
- the likelihood of demonstrating compliance with
information duties,
- the potential outcomes of ongoing court cases,
- the uncertainty surrounding the final resolution and
timing of disputes,
- the estimation of legal costs, and the statute of
limitations on claims.
When the effect of the time value of money is material,
NLB Group determines the level of provisions by
discounting the expected cash flows at a pre-tax rate
reflecting the current rates specific to the liability.
2. 28. Contingent liabilities and
commitments
Financial and non-financial guarantees
Financial guarantees are contracts that require the
issuer to make specific payments to reimburse the
holder for a loss it incurs because a specific debtor fails
to make payments when due, in accordance with the
terms of debt instruments. Such financial guarantees
are given to banks, financial institutions, and other
bodies on behalf of the customer to secure loans,
overdrafts, and other banking facilities.
The issued guarantees covering non-financial
obligations of the clients represent the obligation of
the Bank (guarantor) to pay if the client fails to perform
certain works in accordance with the terms of the
commercial contract. Financial and non-financial
guarantees are initially recognised at fair value,
which is usually evidenced by the fees received. The
fees are amortised to the income statement over the
contract term using the straight-line method. NLB
Group’s liabilities under guarantees are subsequently
measured at the greater of:
- the initial measurement, less amortisation calculated
to recognise fee income over the period of guarantee;
or
- ECL provisions as set out in note 2.14.
Documentary letters of credit
Documentary (and standby) letters of credit constitute
a written and irrevocable commitment of the issuing
(opening) bank on behalf of the issuer (importer) to
pay the beneficiary (exporter) the value set out in the
documents by a defined deadline:
- if the letter of credit is payable on sight; and
- if the letter of credit is payable for deferred payment,
the bank will pay according to the contractual
agreement when and if the beneficiary (exporter)
presents the bank with documents that are in line
with the conditions and deadlines set out in the letter
of credit.
A commitment may also take the form of a letter
of credit confirmation, which is usually done at the
request or authorisation of the issuing (opening)
bank and constitutes a firm commitment by the
confirming bank, in addition to that of the issuing bank,
which independently assumes a commitment to the
beneficiary under certain conditions.
Other contingent liabilities and commitments
Other contingent liabilities and commitments
represent undrawn loan commitments to extend credit,
uncovered letters of credit, and other commitments.
The nominal contractual values of guarantees, letters
of credit, and undrawn loan commitments where the
loan agreed to be provided is on market terms, are not
recognised in the statement of financial position.
Contingent liabilities recognised in a
business combination
A contingent liability recognised in a business
combination is initially measured at its fair value and
is recognised in the statement of financial position in
the line item ‘Provisions.’ After initial recognition, it is
measured at the higher of:
- the amount that would be recognised in accordance
with IAS 37 Provisions, Contingent Liabilities, and
Contingent Assets; or
- the amount initially recognised less, if appropriate,
the cumulative amount of income recognised in
accordance with the principles of IFRS 15 Revenue
from Contracts with Customers. This requirement does
not apply to contracts accounted for in accordance
with IFRS 9.
2. 29. Taxes
Income tax expenses are comprised of current and
deferred income tax.
Current corporate income tax in NLB Group is
calculated on taxable profits at the applicable tax
rate in the respective jurisdiction. Income tax rates
within NLB Group ranges from 9 to 32%. The corporate
income tax rate for 2024 in Slovenia was 22% (2023:
19%). According to the Reconstruction, Development
and Provision of the Financial Resources Act, the
corporate income tax rate is increased to 22% from
2024 to 2028.

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Current and deferred taxes are recognised in profit or
loss, except to the extent that they relate to a business
combination or taxes related to effects recognised
directly in equity (deferred tax related to the fair value
re-measurement of financial assets measured at fair
value through other comprehensive income, cash flow
hedges, and actuarial gains and losses on defined
benefit pension plans is charged or credited directly to
other comprehensive income).
Deferred income tax is calculated using the balance
sheet liability method for temporary differences arising
between the tax bases of assets and liabilities, and their
carrying amounts for financial reporting purposes.
Deferred tax assets are recognised if it is probable
that future taxable profit will be available in the
foreseeable future against which the temporary
differences can be utilised.
Deferred tax assets and liabilities are measured at
tax rates enacted or substantively enacted at the end
of the reporting period that are expected to apply to
the period when the asset is realised, or the liability is
settled. At each reporting date, NLB Group reviews the
carrying amount of deferred tax assets and assesses
future taxable profits against which temporary taxable
differences can be utilised.
Deferred tax assets for temporary differences arising
from impairments of investments in subsidiaries,
associates and joint ventures are recognised only to the
extent that it is probable that:
- the temporary differences will be reversed in the
foreseeable future; and
- taxable profit will be available.
NLB Group recognises a deferred tax liability for
all taxable temporary differences associated with
investments in subsidiaries to the extent that NLB is
able to control the timing of reversal of the temporary
differences, and that it is probable that the
temporary differences will reverse in the foreseeable
future. As NLB controls the dividend policy of its
subsidiaries, NLB Group recognised the deferred tax
liability on withholding tax payable on future planned
dividend pay-out.
In the case of business combination, deferred tax
balances are recognised if related to temporary
differences and carry-forwards of an acquiree that
exist at the acquisition date, or if they arise as a result
of the acquisition. Income taxes are measured in
accordance with IAS 12 Income Taxes.
In accordance with the amendment to Slovenian
corporate income tax law effective from January 1,
2025, tax losses can be carried forward to subsequent
periods for a maximum of five years after the period
in which they occurred. Based on the transitional
provision, accumulated unused old tax losses, incurred
before the entry into force, expire in the in five years
(until 2029). Prior to 2025, Slovenian legislation did not
set deadlines by which uncovered tax losses expire.
A tax on financial services is a tax on fees, paid for
prescribed financial services rendered (financial
services, exempt from value-added tax (with the
exception of securities transactions) and the services
of insurance brokers and agents), paid in Slovenia.
The tax rate is 8.5% (2023: 8.5%) and the tax is paid
monthly. Given that the tax on financial services is
classified as a sales tax, it reduces accrued revenues in
the financial statements.
For the years 2024-2028 tax on banks’ balance sheets
was introduced in Slovenia. The tax is recognised in
other general and administrative expenses.
2. 30. Fiduciary activities
NLB Group provides asset management services to
its clients. Assets held in a fiduciary capacity are not
reported in NLB Group’s financial statements as they do
not represent assets of NLB Group. Fee and commission
income and expenses relating to fiduciary activities are
generally recognised in the income statement when the
service has been provided (see also note 2.11.). Fee and
commission income charged for this type of service is
broken down by items in note 4.3.b). Further details on
transactions managed on behalf of third parties are
disclosed in note 5.25.
Based on the requirements of Slovenian legislation,
NLB Group has, in note 5.25., additionally disclosed
the assets and liabilities on accounts used to
manage financial assets from fiduciary activities, i.e.,
information related to the receipt, processing, and
execution of orders and related custody activities.
2. 31. Employee benefits
Employee benefits include:
- short-term employee benefits (such as salary,
compensations, annual holiday allowance, separation
allowance, and non-monetary benefits);
- reimbursement of commuting costs, meal allowance,
compensation for use of own resources;
- retirement indemnity bonuses (post-employment
benefits);
- other employment benefits (jubilee long-service
benefits, voluntary supplementary pension insurance);
- variable remuneration.
Short-term employee benefits are recognised in the
period to which they relate and included in the income
statement line item ‘Administrative expenses.’ Among
others, they include the payment of contributions for
pension and disability insurance, which according to
Slovenian local legislation (for employer) amount to
8.85% of the gross salaries.
According to legislation, employees retire after they
fulfil certain conditions and are entitled to a lump-sum
severance payment. Employees are also entitled to a
long-service bonus for every 10 years of continuous
service in NLB and its predecessor companies.
These obligations are measured at the present value
of future cash outflows considering future salary
increases and other conditions, and then apportioned
to past and future employee service based on the
benefit plan’s terms and conditions.
Service costs are included in the income statement
in the line item ‘Administrative expenses’ as defined
benefit costs, while interest expenses on the defined
benefit liability are recognised in the line item ‘Interest
and similar expenses.’ These interest expenses
represent the change during the period in the defined
benefit liability that arises from the passage of time. For
post-employment benefits, actuarial gains and losses
from the effect of changes in actuarial assumptions
and experience adjustments (differences between

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the realised and expected payments) are recognised
in other comprehensive income under the line item
‘Actuarial Gains/(Losses) on Defined Benefit Pensions
Plans,’ and will not be recycled to the income statement.
Actuarial gains and losses that relate to other
employment benefits are recognised in the income
statement as defined benefit costs. In the statement of
financial position, liabilities for short-term employee
benefits are included in the line item ‘Other liabilities,’
while liabilities for post-employment benefits and other
employment benefits (jubilee long-service benefits) are
included in the line item ‘Provisions.’
In the case of a business combination, employee
benefits are recognised and measured in accordance
with IAS 19 Employee Benefits, i.e., not at fair value.
2. 32. Share-based
payment transactions
Cash-settled share-based payment transactions
If certain conditions are met, members of the
Management Board and employees performing special
work (i.e., those who can significantly impact the risk
profile of the Group in the scope of their tasks and
activities) receive part of their variable remuneration in
the form of financial instruments, whose value is linked
to the value of NLB share. Upon expiration of the legally
prescribed period (up to five years), beneficiaries
receive cash payments depending on the value of a
NLB share. The first contracts, including share-based
payment transactions, were concluded in the second
quarter of 2022.
In the statement of financial position, a liability
is recognised in the line item ‘Financial liabilities
measured at fair value through profit or loss.’ Its fair
value is measured initially and at each reporting date
up to and including the settlement date, with changes in
fair value recognised in the income statement line item
‘Gains less losses from financial liabilities measured at
fair value through profit or loss.’
Equity-settled share-based payment transactions
NLB Group does not have any equity-settled share-
based payment transactions.
2. 33. Share capital
Dividends on ordinary shares
Dividends on ordinary shares are recognised in
equity in the period in which they are approved by
NLB’s shareholders.
Treasury shares
If NLB or another member of NLB Group purchases
NLB shares, the consideration paid is deducted from
the total shareholders’ equity as treasury shares. If
such shares are subsequently sold, any consideration
received is included in equity. If NLB shares are
purchased by NLB itself or other NLB Group entities,
NLB creates reserves for treasury shares in equity.
Share issue costs
Costs directly attributable to the issue of new shares
are recognised in equity as a reduction in the share
premium account.
2. 34. Segment reporting
Operating segments are reported in a manner
consistent with internal reporting to the Management
Board of the Bank, which is the executive body that
makes decisions regarding the allocation of resources
and assesses the performance of a specific segment.
Transactions between organisational units (OUs) are
managed under normal operating conditions. Interest
income among individual OUs in the parent bank (NLB)
is allocated using a fund transfer pricing method and
shown within the net interest income of each OU. Net
non-interest income is allocated to the OU that actually
provides the service that generates income. Direct costs
are attributed to the segment that is directly related to
the provided service, and indirect costs (costs which
service centres provide for profit centres) are attributed
to the segment for which the service is provided,
whereas overhead costs are allocated according to
general keys. External net income is the net income of
NLB Group from the consolidated income statement.
Income tax is not allocated between segments. Analysis
by segment for NLB Group is presented in note 7.
In accordance with IFRS 8, NLB Group has the following
reportable segments: Retail Banking in Slovenia,
Corporate and Investment Banking in Slovenia,
Strategic Foreign Markets, Financial Markets in
Slovenia, Non-core members, and Other Activities.
2. 35. Critical accounting estimates
and judgments in applying
accounting policies
NLB Group’s financial statements are influenced by
accounting policies, assumptions, estimates, and
management’s judgment. NLB Group makes estimates
and assumptions that affect the reported amounts of
assets and liabilities within the next financial year. All
estimates and assumptions required in conformity with
the IFRS are best estimates undertaken in accordance
with the applicable standard. Estimates and judgments
are evaluated on a continuing basis, and are based
on past experience and other factors, including
expectations with regard to future events.
a) Allowances for expected credit losses on loans
and advances
NLB Group monitors and checks the quality of the
loan portfolio at the individual and portfolio levels
to continuously estimate the necessary allowances
for ECL. NLB Group creates individual allowances for
individually significant financial assets attributed to
Stage 3. Such an assignment is based on information
regarding the fulfilment of contractual obligations
or other financial difficulties of the debtor, and other
important facts. Individual assessments are based on
the expected discounted cash flows from operations
and/or the assessed expected payment from collateral.
Allowances are assessed collectively for financial
assets assigned to Stage 1 or 2, or for financial assets in
Stage 3 with exposure below the materiality threshold.
Disclosure regarding allowances by stages are
disclosed in notes 5.14., 5.16. and 6.1.j). The ECL in this
group of assets are estimated based on expected value
of risk parameters combining the historic movements
with the future macroeconomic predictions for three
separate scenarios. The models used to estimate future
risk parameters are validated and back-tested on a
regular basis to make the loss estimations as realistic
as possible.

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NLB Group applies three different macroeconomic
scenarios to collectively assess the allowances for
credit risk: optimistic, baseline, and severe scenario.
The key features of each scenario are described in
note 2.14.a) Forward-looking information. Recognised
allowances represent a weighted average of the results
of the three scenarios.
In terms of credit risk parameters, the scenarios differ
in the level of default rates (transfer of assets from
performing to non-performing status) and loss rates
(the % of exposure that will not be repaid in case of
default occurrence). Applying a 100% probability on
each of the scenario provides an overview of severity or
optimism reflected in the two remaining scenarios.
The results for NLB Group show the following deviations
of the severe and optimistic scenario from the baseline
as at 31 December 2024 and 31 December 2023:
NLB Group
in EUR thousands
31 Dec 2024
31 Dec 2023
Gross
Loans
Of which
Gross
Loans with
collective
allowances
Collective allowances
Individual
allowances
Gross
Loans
Of which
Gross
Loans with
collective
allowances
Collective allowances
Individual
allowances
Optimistic
scenario
Baseline
scenario
Severe
scenario
Weighted
average
Optimistic
scenario
Baseline
scenario
Severe
scenario
Weighted
average
Companies
7,320,791
7,183,783
(70,386)
(79,386)
(103,604)
(82,439)
(92,667)
6,343,920
6,198,141
(59,740)
(72,321)
(109,972)
(80,209)
(93,739)
Individuals
8,734,989
8,713,898
(154,935)
(164,266)
(185,229)
(166,654)
(10,630)
7,235,314
7,212,398
(121,473)
(130,512)
(159,304)
(137,304)
(11,195)
The result shows that for collective allowances, the
optimistic scenario would result in 92% of the baseline
provisions (89% as at 31.12.2023), while the severe
scenario and its conservative assumptions lead to an
increase of 119% compared to the baseline (133% as at
31.12.2023).
b) Fair value of financial instruments
The fair values of financial investments traded on the
active market are based on current bid prices (financial
assets) or offer prices (financial liabilities).
The fair values of financial instruments that are not
traded on the active market are determined by using
valuation models. These include a comparison with
recent transaction prices, the use of a discounted cash
flow model, valuation based on comparable entities,
and other frequently used valuation models. These
valuation models at their best estimate reflect current
market conditions at the measurement date, which
may not be representative of market conditions either
before or after the measurement date. Management
reviewed all applied models as at the reporting date
to ensure they appropriately reflect current market
conditions, including the relative liquidity of the market
and the applied credit spread. Changes in assumptions
regarding these factors could affect the reported fair
values of financial instruments held for trading, and
financial assets measured at fair value through other
comprehensive income.
The fair values of derivative financial instruments are
determined on the basis of market data (mark-to-
market), in accordance with NLB Group’s methodology
for the valuation of financial instruments. The market
exchange rates, interest rates, yield, and volatility curves
used in valuations are based on the market snapshot
principle. Market data are saved daily at 4 p.m., and
later used for the calculation of the fair values (market
value, NPV) of financial instruments. NLB Group applies
market yield curves for valuation, and fair values are
additionally adjusted for credit risk of the counterparty.
The fair value hierarchy of financial instruments is
disclosed in note 6.5.
c) Impairment of investments in subsidiaries,
associates, and joint ventures
The process of identifying and assessing the
impairment of investments in subsidiaries, associates,
and joint ventures is inherently uncertain, as the
forecasting of cash flows requires the significant
use of estimates, which themselves are sensitive to
the assumptions used. The review of impairment
represents management’s best estimate of the facts
and assumptions such as:
- Future cash flows from individual investments present
the estimated cash flow for periods for which adopted
business plans are available. For core members,
estimated cash flows are based on a five-year
business plan. For non-core members, estimated cash
flows are based on a period in line with the strategy
of divestment. The business plans of individual entities
are based on an assessment of future economic
conditions that will impact an individual member’s
business and the quality of the credit portfolio;
- The growth rate for cash flows in perpetuity, following
the period of the adopted business plan, ranges
between 2.5 and 3.7%;
- The target capital adequacy ratio of an individual
bank is between 15 and 18%;
- The discount rate derived from the capital asset
pricing model that is used to discount future cash
flows is based on the cost of equity allocated to an
individual investment. The discount rate reflects
the impact of a range of financial and economic
variables, including the risk-free rate and risk
premium. The value of variables used is subject to
fluctuations outside management’s control. The
pre-tax discount rate is between 10.6 and 18.35% (31
December 2023: between 10.2 and 20.25%).

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d) Employee benefits
Liabilities for certain employee benefits are calculated
by an independent actuary. The main assumptions
included in the actuarial calculation are as follows:
NLB Group
NLB
2024
2023
2024
2023
Actuarial assumptions
Discount factor
3.0% - 6.4%
3.6% - 8.0%
3.0%
4.0%
Wage growth based on inflation, promotions, and wage growth based on past years of service
2.4% - 5.7%
2.4% - 13.4%
2.5% - 3.7%
2.4% - 8.0%
Other assumptions
Number of employees eligible for benefits
7,306
7,177
2,475
2,519
A sensitivity analysis of significant actuarial
assumptions for post-employment benefit:
31 Dec 2024
NLB Group
NLB
Discount rate
Future salary increases
Discount rate
Future salary increases
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
Impact on provisions for employee benefits
- post-employment benefits (in %)
(4.6)
4.9
5.0
(4.6)
(4.2)
4.5
4.5
(4.2)
31 Dec 2023
NLB Group
NLB
Discount rate
Future salary increases
Discount rate
Future salary increases
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
+0.5 p.p.
-0.5 p.p.
Impact on provisions for employee benefits
- post-employment benefits (in %)
(4.4)
4.8
4.8
(4.5)
(4.2)
4.5
4.5
(4.2)
Individual analysis is done by changing one assumption
for +/- 0.5 percentage points, while all other
assumptions stay the same.
The breakdown of actuarial gains and losses for post-
employment benefit by causes:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Actuarial gains and losses due to changed financial assumptions
(1,765)
(470)
(973)
614
Actuarial gains and losses due to changes in demographic assumptions
834
141
832
-
Actuarial gains and losses due to experience
(376)
(115)
(719)
(26)
Total actuarial gains and losses for the year
(1,307)
(444)
(860)
588
The weighted average duration of liabilities in years:
NLB Group
NLB
2024
2023
2024
2023
Post-employment benefit
9.4 - 20.5
9.6 - 20.9
10.2
10.9

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e) Taxes
NLB Group operates in countries governed by different
laws. The deferred tax assets recognised as at 31
December 2024 are based on profit forecasts and
take the expected manner of recovery of the assets
into account. Changes in assumptions regarding the
likely manner of recovering assets or changes in profit
forecasts can lead to the recognition of currently
unrecognised deferred tax assets or derecognition
of previously created deferred tax assets. If profit
projections used for estimation of the amount of
deferred tax assets which are expected to be reversed
in the foreseeable future (i.e., within five years) change
by 10%, the estimated amount of deferred tax assets
would change by approximately EUR 11 million (notes
4.15. and 5.17.).
2. 36. Implementation of the new
and revised International
Financial Reporting Standards
During the current year, NLB Group adopted all new
and revised standards and interpretations issued
by the International Accounting Standards Board
(hereinafter: ‘the IASB’) and the International Financial
Reporting Interpretations Committee (hereinafter:
‘the IFRIC’), and that are endorsed by the EU that are
effective for annual accounting periods beginning on
1 January 2024.
Accounting standards and amendments to existing
standards effective for annual periods beginning on
1 January 2024 that were endorsed by the EU and
adopted by NLB Group
- IAS 1 (amendment and deferral of effective date) –
Presentation of Financial Statements: Classification
of Liabilities as Current or Non-current is effective for
annual periods beginning on or after 1 January 2024.
The amendments clarify that liabilities are classified
as either current or non-current, depending on the
rights that exist at the end of the reporting period.
Classification is unaffected by the expectations of
the entity or events after the reporting date. The
amendment also clarifies what IAS 1 means when it
refers to the ‘settlement’ of a liability. The changes
had no impact on the financial statements.
- IAS 1 (amendment) – Presentation of Financial
Statements: Non-current Liabilities with Covenants
is effective for annual periods beginning on or
after 1 January 2024. The amendments improved
the information an entity provides when its right
to defer settlement of a liability for at least 12
months is subject to compliance with covenants.
The amendments also responded to stakeholders’
concerns about the classification of such a liability as
current or non-current. The changes had no impact
on the financial statements.
- IFRS 16 (amendment) – Leases: Lease Liability
in a Sale and Leaseback is effective for annual
periods beginning on or after 1 January 2024. The
amendments affect only the subsequent measurement
of lease liabilities arising from a sale and leaseback
transaction with variable lease payments, which
occurred from the date of initial application of IFRS
16 and for which the seller-lessee’s accounting policy
differs from the requirements specified in these
amendments. The changes had no impact on the
financial statements.
- IAS 7 (amendment) – Statement of Cash Flows and IFRS
7 (amendment) – Financial Instruments: Disclosures:
Supplier Finance Arrangements is effective for
annual periods beginning on or after 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, and the entity’s exposure
to liquidity risk. Supplier finance arrangements are
characterised by one or more finance providers
offering to pay amounts an entity owes its suppliers
and the entity agreeing to pay according to the
terms and conditions of the arrangements at the
same date as, or a date later than, suppliers are
paid. The amendments note that arrangements
that are solely credit enhancements for the entity or
instruments used by the entity to settle directly with a
supplier the amounts owed are not supplier finance
arrangements. Meanwhile, the amendments to IFRS
7 require from an entity to disclose a description
of how it manages the liquidity risk resulting from
financial liabilities. The amendments include as an
additional factor whether the entity has accessed,
or has access to, supplier finance arrangements that
provide the entity with extended payment terms or
the entity’s suppliers with early payment terms. The
changes had no impact on the financial statements.
Accounting standards and amendments to existing
standards that were endorsed by the EU, but not
adopted early by NLB Group
New and revised accounting standards and
interpretations endorsed by the EU that are not
mandatory for annual accounting periods beginning on
1 January 2024, were not adopted early by NLB Group.
These standards and amendments are not expected to
have a material impact on the consolidated financial
statements of NLB Group in the future reporting
periods and on foreseeable future transactions.
NLB Group plans to adopt the accounting standards
and amendments listed below for reporting periods
commencing on or after the effective date.
- IAS 21 (amendment) – The Effects of Changes in
Foreign Exchange Rates: Lack of Exchangeability
is effective for annual periods beginning on or
after 1 January 2025. The amendments clarify
how an entity should assess whether a currency is
exchangeable, and how it should determine a spot
exchange rate when exchangeability is lacking. A
currency is exchangeable when an entity is able
to exchange that currency for another currency
through market or exchange mechanisms that create
enforceable rights and obligations without undue
delay at the measurement date and for a specified
purpose. If a currency is not exchangeable at the
measurement date, the entity is required to estimate
the spot exchange rate as the rate that would have
applied to an orderly exchange transaction between
market participants at the measurement date
under prevailing economic conditions, and disclose
expected affects to the entity’s financial statements.
NLB Group does not expect there to be an impact on
the financial statements.
Accounting standards and amendments to existing
standards, but not endorsed by the EU
- IFRS 9 and IFRS 7 (amendment) – Amendments to
the Classification and Measurement of Financial
Instruments is effective for annual periods beginning
on or after 1 January 2026. The Amendments mainly
respond to a request from stakeholders to clarify
some aspects of the application guidance for
assessing the contractual cash flow characteristics

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of financial assets and accounting for the settlement
of financial liabilities through electronic payment
systems. NLB Group does not expect there to be an
impact on the financial statements.
- IFRS 18 (new standard) – Presentation and Disclosure
in Financial Statements is effective for annual
periods beginning on or after 1 January 2027. IFRS
18 replaces IAS 1, carrying forward many of the
requirements in IAS 1 unchanged and complementing
them with new requirements.
IFRS 18 introduces new requirements to:
• present specified categories and defined subtotals
in the statement of profit or loss;
• provide disclosures on management-defined
performance measures (MPMs) in the notes to the
financial statements;
• improve aggregation and disaggregation.
NLB Group expects an impact only on the presentation
of financial statements.
- IFRS 19 (new standard) – Subsidiaries without Public
Accountability: Disclosures is effective for annual
periods beginning on or after 1 January 2027.
IFRS 19 permits an eligible subsidiary to provide
reduced disclosures when applying IFRS Accounting
Standards in its financial statements. A subsidiary
is eligible for the reduced disclosures if it does not
have public accountability, and its ultimate or any
intermediate parent produces consolidated financial
statements available for public use that comply
with IFRS Accounting Standards. IFRS 19 is optional
for subsidiaries that are eligible and sets out the
disclosure requirements for subsidiaries that elect to
apply it. NLB Group does not expect there to be an
impact on the financial statements.
- Annual Improvements Volume 11 (amendment)
– amendments are effective for annual periods
beginning on or after 1 January 2026. The
amendments bring small improvements to existing
standards. NLB Group does not expect there to be an
impact on the financial statements.
- IFRS 9 and IFRS 7 (amendment) - Contracts
Referencing Nature-dependent Electricity.
Amendments are effective for annual periods
beginning on or after 1 January 2026. Amendments
help companies to better report the financial effects
of nature-dependent electricity contracts, which are
often structured as power purchase agreements
(PPAs). The amount of electricity generated under
these contracts can vary based on uncontrollable
factors such as weather conditions. To allow
companies to better reflect these contracts in the
financial statements, the amendments include:
• clarifying the application of the ‘own-use’
requirements;
• permitting hedge accounting if these contracts are
used as hedging instruments; and
• adding new disclosure requirements to enable
investors to understand the effect of these
contracts on a company’s financial performance
and cash flows.
NLB Group does not expect there to be an impact on
the financial statements.
3. Changes in the
Composition of the
NLB Group
Changes in 2024
Capital changes:
- In May 2024, NLB Skladi d.o.o., Ljubljana became
an owner of 100% of financial company Generali
Investments a.d. Skopje. The purchase price for the
company was EUR 2,515 thousand and was fully paid
in cash (note 5.12.b). In August 2024, the company was
renamed ‘NLB Fondovi a.d. Skopje’.
- In September 2024, NLB d.d., Ljubljana completed
the acquisition of a 100% stake in the company SLS
HOLDCO d.o.o., the parent company of Summit Leasing
Slovenija d.o.o., Ljubljana and its subsidiary Mobil
Leasing d.o.o., Zagreb. The purchase price was EUR
127,216 thousand and was fully paid in cash (note 5.12.c).
- In October 2024, NLB d.d. Ljubljana increased
share capital in the form of a cash contribution in
the amount of EUR 3,329 thousand in company NLB
Lease&Go, leasing, d.o.o., Ljubljana.
- In October 2024, NLB Komercijalna banka a.d.
Beograd and NLB Lease&Go, leasing, d.o.o., Ljubljana
increased share capital in the form of a cash
contribution in the company NLB Lease&Go Leasing
d.o.o. Beograd in the total amount of EUR 5,831
thousand. After that, NLB Lease&Go, leasing, d.o.o.,
Ljubljana ownership of NLB Lease&Go leasing d.o.o.
Beograd increased to 50.89%, and NLB Komercijalna
banka a.d. Beograd to 48.91%.
- In December 2024, NLB Lease&Go, leasing, d.o.o.,
Ljubljana and NLB Banka a.d., Skopje increased share
capital in the form of a cash contribution in the total
amount of EUR 684 thousand in the company NLB
Lease&Go, d.o.o. Skopje.
Other changes:
- In January 2024, according to the new NLB Group
Governance Policy, three real estate companies
S-REAM d.o.o., Ljubljana, REAM d.o.o., Beograd and
REAM d.o.o., Podgorica were transferred from non-
core members to core members.
- In May 2024, company S-REAM d.o.o., Ljubljana
was renamed ‘NLB Real Estate d.o.o., Ljubljana,’
company REAM d.o.o., Podgorica was renamed ‘NLB
Real Estate d.o.o., Podgorica,’ and company REAM
d.o.o., Beograd was renamed ‘NLB Real Estate d.o.o.,
Beograd.’
- On 1 July 2024, after merging with NLB Lease&Go,
leasing, d.o.o., Ljubljana, subsidiary NLB Leasing d.o.o.
Ljubljana – v likvidaciji ceased to exist. All its assets
and liabilities were transferred to NLB Lease&Go,
leasing, d.o.o., Ljubljana which became its universal
legal successor after the merger.
- On 1 July 2024, after merging with NLB Real Estate
d.o.o., Ljubljana, subsidiary Privatinvest d.o.o.,
Ljubljana ceased to exist. All its assets and liabilities
were transferred to NLB Real Estate d.o.o., Ljubljana
which became after merger its universal legal
successor after the merger.
- In September 2024, NLB Komercijalna banka
a.d. Beograd completed the sale of its subsidiary
KomBank Invest a.d. Beograd to NLB Skladi,
upravljanje premoženja, d.o.o. Ljubljana. In October
2024, the company KomBank Invest a.d. Beograd was
renamed ‘NLB Fondovi a.d. Beograd.’
- In October 2024, NLB Lease&Go, leasing, d.o.o.,
Ljubljana established a new non-financial company
for digital business NLB Car&Go, upravljanje spletnih
platform, d.o.o.
- In November 2024, NLB Zavod za upravljanje kulturne
dediščine was renamed ‘NLB MUZA Zavod za
upravljanje kulturne dediščine, Ljubljana.’
Changes in 2023
Capital changes:
- In January 2023, NLB Lease&Go, leasing, d.o.o.,
Ljubljana increased its share capital in the form

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of a cash contribution in the amount of EUR 2,100
thousand in the company Zastava Istrabenz Lizing,
d.o.o., Beograd. The ownership interest increased
from 95.20% to 99%. In January 2023, the company
was renamed to ‘NLB Lease&Go leasing d.o.o.
Beograd.’
- In June 2023, NLB Lease&Go, leasing, d.o.o., Ljubljana
increased its share capital in the form of a cash
contribution in the amount of EUR 1,195 thousand in
the company NLB Lease&Go leasing d.o.o. Beograd.
Ownership interest increased from 99% to 99.30%.
- In September 2023, NLB Komercijalna banka a.d.
Beograd increased its share capital in the form of a
cash contribution in the amount of EUR 767 thousand
in the company KomBank Invest a.d. Beograd.
- In September 2023, NLB Lease&Go, leasing, d.o.o.,
Ljubljana and NLB Banka a.d., Skopje increased its
share capital in the form of a cash contribution in the
total amount of EUR 1,571 thousand in the company
NLB Lease&Go, d.o.o. Skopje.
- In December 2023, NLB Komercijalna banka a.d.
Beograd increased its share capital in the form
of a cash contribution in the amount of EUR 3,804
thousand in the company NLB Lease&Go leasing
d.o.o. Beograd. After that, NLB Lease&Go, leasing,
d.o.o., Ljubljana ownership of NLB Lease&Go
leasing d.o.o. Beograd is 50.73%, meanwhile, NLB
Komercijalna banka a.d. Beograd ownership of NLB
Lease&Go leasing d.o.o. Beograd is 48.91%.
Other changes:
- In April 2023, after merging with REAM d.o.o.,
Beograd, subsidiary SPV 2 d.o.o., Beograd ceased to
exist. All of its assets and liabilities were transferred
to REAM d.o.o., Beograd, which became its universal
legal successor after the merger.
- In May 2023, NLB Group sold its subsidiary Tara Hotel
d.o.o. Budva (note 5.12.e).
- In July 2023, a purchase agreement was signed for the
sale of NLB Group’s subsidiary Optima Leasing d.o.o.,
Zagreb – u likvidaciji. The transfer of the ownership
was entered into the Register of Companies on 13
September 2023 (note 5.12.d).
- In August 2023, NLB received an authorisation of the
ECB for the merger of the N Banka. On 1 September
2023, with entry of the merger in the Register of
Companies, the process of the legal merger of N
Banka with NLB was closed. As at the date of the
merger, N Banka ceased to exist as an independent
legal entity, and NLB as a universal successor, took
over all of its rights and obligations (note 5.12.f).
- In September 2023, NLB Leasing d.o.o., Beograd – u
likvidaciji was liquidated. In accordance with the
court order, the company was removed from the court
register.
- In September 2023, after cross-border merging with
S-REAM d.o.o., Ljubljana, subsidiary REAM d.o.o,
Zagreb ceased to exist. All its assets and liabilities
were transferred to S-REAM d.o.o., Ljubljana, which
became its universal legal successor after the merger.
- On 30 November 2023, NLB concluded a purchase
agreement for the acquisition of a 100% stake in the
company SLS HOLDCO d.o.o., the parent company of
Summit Leasing Slovenija d.o.o. and its subsidiaries
from funds managed by affiliates of Apollo Global
Management, Inc. and the European Bank for
Reconstruction and Development. The purchase
price for the mentioned deal is equal to the book
value of Summit Leasing with an additional small
mark-up. Completion of the transaction depends on
obtaining regulatory approvals and approvals from
competent authorities/institutions for the protection of
competition and is expected in the second half of 2024.

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4. Notes to the Income Statement
4. 1. Interest income and expenses
Analysis by type of assets and liabilities
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Interest and similar income
Interest income calculated using the effective interest method
1,112,288
952,875
602,004
477,154
Financial assets measured at fair value through
other comprehensive income
54,463
38,645
25,289
9,184
Securities measured at amortised cost
85,320
36,886
54,016
24,237
Deposits with banks and central banks
121,456
130,829
115,927
122,807
Loans and advances to banks measured at amortised cost
17,271
21,616
11,142
9,584
Loans and advances to customers measured at amortised cost
833,778
724,899
395,630
311,342
Other interest and similar income
95,350
40,530
44,926
21,184
Financial assets held for trading
5,939
6,213
6,444
6,459
Non-trading financial assets mandatorily
at fair value through profit or loss
19
48
412
417
Derivatives - hedge accounting
38,474
14,529
38,070
14,308
Finance leases
50,913
18,959
-
-
Other
5
781
-
-
Total
1,207,638
993,405
646,930
498,338
Interest and similar expenses
Interest expenses calculated using the effective interest method
232,863
148,034
174,429
115,779
Deposits from banks and central banks
3,543
3,372
9,068
6,914
Borrowings from banks and central banks
3,871
1,880
2,220
712
Due to customers
115,578
68,784
56,353
36,266
Borrowings from other customers
2,187
1,515
-
-
Subordinated liabilities
46,302
35,155
46,302
35,155
Debt securities issued
60,306
36,579
60,306
36,579
Lease liabilities (note 5.11.a)
1,076
728
180
132
Negative interest
-
21
-
21
Other interest and similar expenses
40,614
12,037
40,621
9,993
Derivatives - hedge accounting
34,164
4,470
34,164
4,444
Financial liabilities held for trading
5,546
5,595
6,020
5,191
Interest expenses on defined employee benefits (note 2.31., 5.16.c)
768
668
409
330
Other
136
1,304
28
28
Total
273,477
160,071
215,050
125,772
Net interest income
934,161
833,334
431,880
372,566

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4. 2. Dividend income
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Financial assets measured at fair value through
other comprehensive income
55
116
-
-
- related to investments held at the end of reporting period
55
116
-
-
Investments in subsidiaries
-
-
222,652
144,930
Investments in associates and joint ventures
-
-
866
275
Non-trading financial assets mandatorily at fair value through profit or loss
61
53
61
53
Total
116
169
223,579
145,258
4. 3. Fee and commission income and expenses
a) Fee and commission income and expenses relating to activities of NLB Group and NLB
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Fee and commission income
Fee and commission income relating to financial
instruments not at fair value through profit or loss
Credit cards and ATMs
138,680
130,460
56,164
50,094
Customer transaction accounts
100,204
93,527
57,184
53,355
Other fee and commission income
Payments
90,399
88,334
25,992
24,977
Investment funds
42,812
32,994
14,104
9,916
Agency of insurance products
18,621
13,425
11,880
9,679
Other services
10,505
10,381
3,862
3,816
Total fee and commission income from contracts with customers
401,221
369,121
169,186
151,837
Guarantees
19,141
17,954
11,048
9,577
Total
420,362
387,075
180,234
161,414
Fee and commission expenses
Fee and commission expenses relating to financial
instruments not at fair value through profit or loss
Credit cards and ATMs
90,454
91,543
36,654
33,387
Other fee and commission expenses
Payments
13,168
13,169
1,678
1,351
Insurance for holders of personal accounts and gold cards
1,412
1,516
1,039
888
Investment banking
6,287
4,627
820
679
Guarantees
1,685
1,691
1,643
1,598
Other services
4,873
4,314
904
606
Total
117,879
116,860
42,738
38,509
Net fee and commission income related to banking activities
302,483
270,215
137,496
122,905

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b) Fee and commission income and expenses relating to fiduciary activities
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Fee and commission income related to fiduciary activities
Receipt, processing, and execution of orders
2,695
1,661
2,244
1,546
Management of financial instruments portfolio
2,439
1,724
-
-
Initial or subsequent underwriting and/or placing of financial
instruments without a firm commitment basis
579
228
579
228
Custody and similar services
6,640
6,027
6,498
5,842
Management of clients‘ account of non-materialised securities
2,291
1,942
2,291
1,942
Safe-keeping of clients‘ financial instruments
213
75
-
-
Advice to companies on capital structure, business
strategy, and related matters and advice, and services
relating to mergers and acquisitions of companies
65
9
65
9
Total
14,922
11,666
11,677
9,567
Fee and commission expenses related to fiduciary activities
Fee and commission related to Central Securities
Clearing Corporation and similar organisations
4,379
3,844
4,382
3,847
Fee and commission related to stock exchange and similar organisations
102
76
102
76
Total
4,481
3,920
4,484
3,923
Net fee income related to fiduciary activities
10,441
7,746
7,193
5,644
Total fee and commission income a) and b)
435,284
398,741
191,911
170,981
Total fee and commission expenses a) and b)
122,360
120,780
47,222
42,432
Total net fee and commission a) and b)
312,924
277,961
144,689
128,549

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c) Analysis of fee and commission income and expenses by type and by segments
in EUR thousands
NLB Group
2024
Retail Banking
in Slovenia
Corporate and
Investment
Banking in
Slovenia
Strategic
Foreign
Markets
Financial
Markets in
Slovenia
Non-Core
Members
Other
activities
Intercompany
relations
Total
Fee and commission income
Fee and commission income relating to financial
instruments not at fair value through profit or loss
89,681
23,602
125,601
63
-
2
(65)
238,884
Credit cards and ATMs
35,051
21,104
82,521
8
-
1
(5)
138,680
Customer transaction accounts
54,630
2,498
43,080
55
-
1
(60)
100,204
Other fee and commission
87,587
25,011
78,701
514
39
2,980
(17,573)
177,259
Payments
13,919
11,711
64,326
76
-
2,957
(2,590)
90,399
Investment funds
55,994
44
993
-
-
-
(14,219)
42,812
Agency of insurance products
11,877
2
6,741
-
-
1
-
18,621
Other services
5,797
13,254
6,641
438
39
22
(764)
25,427
Total fee and commission income from contracts with customers
Guarantees
110
10,893
8,423
45
-
-
(330)
19,141
Total
177,378
59,506
212,725
622
39
2,982
(17,968)
435,284
Fee and commission expenses
(47,296)
(18,421)
(70,670)
(2,666)
(41)
(1,234)
17,968
(122,360)
Total
(47,296)
(18,421)
(70,670)
(2,666)
(41)
(1,234)
17,968
(122,360)
Net fee and commission income
130,082
41,085
142,055
(2,044)
(2)
1,748
-
312,924

in EUR thousands
NLB Group
2023
Retail Banking
in Slovenia
Corporate and
Investment
Banking in
Slovenia
Strategic
Foreign
Markets
Financial
Markets in
Slovenia
Non-Core
Members
Other
activities
Intercompany
relations
Total
Fee and commission income
Fee and commission income relating to financial
instruments not at fair value through profit or loss
84,170
22,043
117,756
125
-
14
(121)
223,987
Credit cards and ATMs
31,771
19,679
79,002
5
-
8
(5)
130,460
Customer transaction accounts
52,399
2,364
38,754
120
-
6
(116)
93,527
Other fee and commission
71,260
23,400
71,358
493
46
2,763
(12,520)
156,800
Payments
13,704
11,146
62,574
152
-
2,748
(1,990)
88,334
Investment funds
42,663
47
233
-
-
-
(9,949)
32,994
Agency of insurance products
10,124
1
3,294
4
-
2
-
13,425
Other services
4,769
12,206
5,257
337
46
13
(581)
22,047
Total fee and commission income from contracts with customers
Guarantees
120
10,361
7,545
35
-
13
(120)
17,954
Total
155,550
55,804
196,659
653
46
2,790
(12,761)
398,741
Fee and commission expenses
(41,434)
(15,593)
(72,547)
(2,727)
(122)
(1,118)
12,761
(120,780)
Total
(41,434)
(15,593)
(72,547)
(2,727)
(122)
(1,118)
12,761
(120,780)
Net fee and commission income
114,116
40,211
124,112
(2,074)
(76)
1,672
-
277,961

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Risk Factors & Outlook
Performance Overview
Segment Analysis
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Risk Management
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Financial
Report
4. 4. Gains less losses from financial assets and liabilities not measured at fair value through profit or loss
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Debt instruments measured at fair value through
other comprehensive income
- gains
160
94
-
2
- losses
(3,328)
(836)
(210)
(836)
Financial assets measured at amortised cost
- gains
169
-
-
-
Financial liabilities measured at amortised cost
- gains
2,839
-
2,713
-
Total
(160)
(742)
2,503
(834)

4. 5. Gains less losses from financial assets and liabilities held for trading
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Foreign exchange trading
- gains
40,675
35,774
14,037
12,308
- losses
(8,833)
(7,394)
(7,792)
(7,299)
Debt instruments
- gains
583
188
580
134
- losses
(340)
(28)
(340)
(28)
Derivatives
- currency
1,192
2,462
3,567
(1,512)
- interest rate
(51)
1,182
(76)
(4,014)
- securities
3
3
3
3
Total
33,229
32,187
9,979
(408)
Interest income from financial assets held for trading is
included in the income statement line item ‘Interest and
similar income’ and interest expenses from financial
liabilities held for trading in line item ‘Interest and
similar expenses’ (note 4.1.).

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Financial
Report
4. 6. Gains less losses from non-trading financial assets mandatorily at fair value through profit or loss
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Equity securities
- gains
4,076
2,667
4,045
1,901
- losses
(863)
(985)
(855)
(712)
Debt securities
- gains
54
122
-
-
- losses
(4)
(44)
-
-
Loans and advances to customers
- gains
-
24
658
1,256
Total
3,263
1,784
3,848
2,445
Interest income from non-trading financial assets
mandatorily at fair value through profit or loss is
included in the income statement line item ‘Interest and
similar income’ (note 4.1.).
4. 7. Foreign exchange translation gains less losses
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Financial assets and liabilities not measured as
at fair value through profit or loss
(3,867)
(2,549)
(3,770)
3,232
Financial assets measured at fair value through profit or loss
167
(7)
167
(7)
Other
56
(222)
56
(222)
Total
(3,644)
(2,778)
(3,547)
3,003

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Financial
Report
4. 8. Other operating income and expenses
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Other operating income
Income from non-banking services
8,360
7,933
7,029
6,862
- cash transportation
3,279
3,455
3,279
3,481
- operating leases of movable property
2,491
2,133
527
485
- IT services
316
221
1,486
1,249
- other
2,274
2,124
1,737
1,647
Rental income from investment property
1,348
1,755
293
359
Revaluation of investment property to fair value (note 5.9.)
1,714
617
221
223
Sale of investment property
816
427
258
17
Other operating income
9,611
6,676
6,773
2,915
Total
21,849
17,408
14,574
10,376
Other operating expenses
Donations
2,187
12,008
1,541
11,564
Expenses related to issued service guarantees
3
545
3
545
Revaluation of investment property to fair value (note 5.9.)
1,228
1,734
35
41
Other operating expenses
8,411
7,813
2,329
2,232
Total
11,829
22,100
3,908
14,382
The line item ‘Donations,’ classified under the ‘Other
operating expenses’ in year 2023 also include
donations of NLB for floods mitigation in Slovenia
to municipalities in the total amount of EUR 4,000
thousand, and to the Budget of the Republic of Slovenia
to a particular budget line to raise funds to recover the
consequences of the August floods in the amount of
EUR 5,000 thousand.
Other operating expenses mainly include expenses
associated with the changes in proportional deduction
of VAT, licences, penalties, and damages.
Other operating income mainly include reimbursement
of costs and taxes and income from sale of gold.

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Report
4. 9. Administrative expenses
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Employee costs
Gross salaries, compensations, and other short-term benefits
288,583
252,731
144,109
118,962
Defined contribution scheme
18,591
17,424
9,055
8,225
Social security contributions
14,198
12,612
7,544
6,864
Defined benefit expenses (note 5.16.c)
780
(602)
501
(279)
Post-employment benefits
(26)
(1,134)
(187)
(452)
Other employee benefits
806
532
688
173
Total
322,152
282,165
161,209
133,772
Other general and administrative expenses
Material
6,994
6,672
1,746
1,624
Services
58,476
46,735
33,146
26,824
Intellectual services
22,218
18,385
12,810
9,768
Costs of supervision
7,136
4,942
4,384
2,806
Costs of other services
29,122
23,408
15,952
14,250
Tax expenses
37,915
4,454
34,507
1,040
Tax on balance sheet
33,204
-
33,204
-
Other tax expenses
4,711
4,454
1,303
1,040
Membership fees and similar
994
903
363
359
Business travel
2,172
1,684
787
561
Marketing
20,502
17,373
10,439
9,213
Buildings and equipment
32,591
32,680
16,091
15,290
Electricity
7,481
8,285
3,714
4,307
Rents and leases
2,423
3,012
400
526
Maintenance costs
10,135
9,370
5,333
4,977
Costs of security
6,371
5,952
2,582
2,203
Insurance for tangible assets
810
656
293
152
Other costs related to buildings and equipment
5,371
5,405
3,769
3,125
Technology
43,558
43,093
22,692
23,100
Maintenance of software and hardware
21,695
22,527
8,996
10,232
Licences
13,959
12,612
9,707
8,829
Data assets and subscription costs
3,359
3,267
2,342
2,157
Other technology costs
4,545
4,687
1,647
1,882
Communications
12,150
12,490
4,498
4,567
Postal services
4,697
4,868
2,828
2,814
Telecommunication and internet
4,996
5,141
521
558
Other communication costs
2,457
2,481
1,149
1,195
Other general and administrative costs
6,491
4,374
2,964
2,057
Total
221,843
170,458
127,233
84,635
Total administrative expenses
543,995
452,623
288,442
218,407
Number of employees
8,322
7,982
2,523
2,554
Costs of other services include insurance costs, costs for
cash transport, archiving costs, costs for certification
agency and e-business, meeting fees of members of the
Supervisory Board.

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Performance Overview
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Financial
Report
In the table below are presented expenses related to
the services of the statutory auditor:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Statutory audit fees
Cost of statutory audit
1,307
944
526
333
Audit overruns due to additional scope
90
-
53
-
Total
1,397
944
579
333
Other audit fees
Other assurance services
225
28
210
28
Non assurance services
34
-
15
-
Total
259
28
225
28
Total audit fees
1,656
972
804
361
The contractual amount of the auditor’s remuneration
for auditing the annual report (excluding VAT,
predefined costs and inflation, if it exceeds 3% in an
individual member state of the NLB Group) amounted
to EUR 915 thousand in 2024 at the NLB Group (2023:
EUR 757 thousand), and EUR 302 thousand at NLB
(2023: EUR 341 thousand).
For other audit assurance services, the contractual
values (excluding VAT and additional costs) for the
NLB Group amount to EUR 180 thousand (2023:
EUR 17 thousand), and EUR 163 thousand at NLB (2023:
EUR 8 thousand), and relate to the sustainability
report and other audit services. For other audit
services, excluding assurance, the contractual values
for the NLB Group amount to EUR 24 thousand
(2023: EUR 15 thousand), and in NLB amounted to
EUR 7 thousand (2023: EUR 7 thousand).
In addition to the services included in the paragraph
above, the statutory auditor also performed certain
non-audit services in 2024 in the amount of EUR 159
thousand (2023: EUR 75 thousand) and other assurance
services in 2023 in the amount of EUR 260 thousand,
both related to the issuance of bonds. Amounts are
presented without VAT. The payment was included
in the calculation of the effective interest rate on the
instrument issued.
4. 10. Cash contributions to resolution funds and deposit guarantee schemes
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Cash contributions to deposit guarantee schemes
39,968
36,946
10,793
9,686
Cash contributions to resolution funds
245
2,147
-
1,697
Total
40,213
39,093
10,793
11,383
In February 2024, Bank of Slovenia announced Single
Resolution Board decision that no regular annual
contributions to Single Resolution Fund will be collected
in 2024 since the target level of at least 1% of covered
deposits held in the member states participating in the
Single Resolution Mechanism was reached. Accordingly,
NLB was not obligated to contribute its regular
contribution to resolution funds for the year 2024.

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Annual Report 2024
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Risk Factors & Outlook
Performance Overview
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Financial
Report
4. 11. Depreciation and amortisation
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Amortisation of intangible assets (note 5.10.)
20,775
16,402
11,625
7,528
Depreciation of property and equipment:
- own property and equipment (note 5.8.b)
29,561
24,832
10,838
10,508
- right-of-use assets (note 5.11.a)
7,881
7,998
1,553
1,421
Total
58,217
49,232
24,016
19,457

4. 12. Gains less losses from modification of financial assets
in EUR thousands
2024
2023
NLB Group
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Financial assets modified during the period
Amortised cost before modification
515,034
16,401
2,083
533,518
510,682
4,141
4,145
518,968
Net modification gains/(losses)
(4,113)
(143)
(24)
(4,280)
(16,043)
(123)
(105)
(16,271)
The majority of modification loss of financial assets
in 2024 and 2023 refers to the Decision on temporary
measures for banks in relation to housing loans
to natural persons, which limited the interest rates
of housing loans in Serbia. The loss represents the
difference between the balance of the loan on the
modification date and the discounted value of the
cash flows of the modified repayment plans using the
original effective interest rate.
in EUR thousands
NLB Group
31 Dec 2024
31 Dec 2023
Financial assets modified since initial recognition
Gross carrying amount of financial assets for which loss allowance has
changed to 12-month measurement during the period
-
775
4. 13. Provisions
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Provision for credit losses
(10,728)
(5,055)
(8,701)
(3,074)
Guarantees and commitments (note 5.16.b)
(10,728)
(5,055)
(8,701)
(3,074)
Provision for other liabilities and charges
12,847
25,925
7,149
14,422
Restructuring provisions (note 5.16.d)
3,919
3,654
2,500
3,800
Provisions for legal risks (note 5.16.e)
8,928
7,280
4,649
(2,678)
Other provisions (note 5.16.f)
-
14,991
-
13,300
Total
2,119
20,870
(1,552)
11,348

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Financial
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4. 14. Impairment charge
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Impairment of financial assets
Cash balances at central banks, and other demand deposits at banks
(53)
(504)
(272)
110
Loans and advances to banks measured at amortised cost (note 5.14.a)
(79)
23
36
(80)
Loans and advances to individuals measured at amortised cost (note 5.14.a)
39,711
37,632
23,535
15,689
Loans and advances to other customers measured
at amortised cost (note 5.14.a)
(8,280)
(41,396)
17,813
(4,254)
Debt securities measured at fair value through
other comprehensive income (note 5.14.b)
(1,535)
(7,054)
198
(5,058)
Debt securities measured at amortised cost (note 5.14.b)
1,923
1,749
723
672
Other financial assets measured at amortised cost (note 5.14.a)
(381)
2,833
(1,343)
589
Total impairment of financial assets
31,306
(6,717)
40,690
7,668
Impairment of investments in subsidiaries, associates and joint ventures
Investments in subsidiaries
-
-
(53,525)
(96,876)
Investments in associates and joint ventures
-
-
-
(241)
Total
-
-
(53,525)
(97,117)
Impairment of other assets
Property and equipment (note 5.8.b)
3,667
47
-
-
Other assets
347
(100)
1
3
Total
4,014
(53)
1
3
Total impairment of non-financial assets
4,014
(53)
(53,524)
(97,114)
Total impairment
35,320
(6,770)
(12,834)
(89,446)
In 2024, NLB released impairments related to equity
investments in subsidiaries in total amount of EUR
53,705 thousand (2023: EUR 97,847 thousand). Release
of impartments in subsidiaries was due to increase in
their estimated recoverable amounts. The recoverable
amounts have been calculated based on value in
use, determined by discounting the future cash flows
expected to be generated from holding the investments.
The values assigned to the key assumptions represent
management’s assessment of future trends in the
relevant sectors and have been based on historical
data from both internal and external sources (discount
rate from 10.6% to 18.35%; growth rate from 2.5% to
3.7%; target capital adequacy ratio between 15% and
18%). Details of the assumptions used in the estimates
are presented in note 2.35.c).
In 2024, NLB impaired equity investment in non-core
subsidiary in amount of EUR 180 thousand (2023:
EUR 730 thousand), which is included in the amount in
the line item ‘Investments in subsidiaries.’
In 2024, impairment of financial assets includes EUR
1,661 thousand of 12-month expected credit losses for
Stage 1 financial assets measured at amortised cost,
acquired through a business combination (note 5.12.c).

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Financial
Report
4. 15. Income tax
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Current income tax
76,432
66,072
34,423
25,210
Global minimum tax
6,037
-
3,851
-
Deferred income tax (note 5.17.)
(4,553)
(50,982)
(4,445)
(60,751)
Total
77,916
15,090
33,829
(35,541)

Reconciliations of differences from the amount of tax
determined by applying the Slovenian statutory tax
rate and reconciliation of effects:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Profit before tax
608,149
578,413
511,990
478,746
Tax calculated at prescribed rate of 22% (in 2023: 19%)
133,793
22.0%
109,898
19.0%
112,638
22.0%
90,962
19.0%
Tax effect of:
Income not subject to tax
(14,855)
-2.4%
(13,180)
-2.2%
(58,988)
-11.5%
(45,966)
-9.6%
Non-deductible expenses
10,385
1.7%
10,572
1.7%
1,239
0.2%
3,130
0.7%
Utilization of previously non-deductible expenses
-
-
(16,034)
-2.6%
-
-
(2,578)
-0.5%
Tax reliefs
(4,840)
-0.8%
(3,324)
-0.5%
(3,273)
-0.6%
(3,301)
-0.7%
Use of previously unrecognised tax losses
(27,689)
-4.6%
(22,266)
-3.7%
(27,079)
-5.3%
(21,898)
-4.6%
Unrecognised deferred tax assets on current period tax losses
1,107
0.1%
14,218
2.3%
-
-
-
-
Recognition of previously unrecognised deferred tax on tax losses
(6,920)
-1.1%
(46,697)
-7.7%
(5,501)
-1.1%
(46,697)
-9.8%
Recognition of previously unrecognised deferred
tax on deductible temporary differences
-
-
(1,918)
-0.3%
-
-
(1,918)
-0.4%
Changes in deferred taxes due to the increase of tax rate
-
-
(13,491)
-2.2%
-
-
(13,544)
-2.8%
Effect of different tax rates in other countries
(29,794)
-4.9%
(18,636)
-3.1%
-
-
-
-
Withholding tax for which no tax credit was available
10,197
1.7%
6,920
1.1%
10,197
2.0%
6,920
1.4%
Deferred tax liability on undistributed profits
840
0.1%
9,626
1.6%
-
-
-
-
Adjustment to tax in respect of prior years
(670)
-0.1%
50
-
420
-
(3)
-
Global minimum tax
6,037
1.0%
-
-
3,851
0.8%
-
-
Other
325
0.1%
(648)
-0.1%
325
0.1%
(648)
-0.1%
Total
77,916
12.8%
15,090
2.6%
33,829
6.6%
(35,541)
-7.4%
Each member of NLB Group (disclosed in note 5.12.a) is
taxable as required by local tax legislation. Income tax
rates within NLB Group ranges from 9 to 32%.
A tax rate of 22% was applied in Slovenia in 2024
(2023: 19%). For the years 2024 – 2028, the rate in
Slovenia will be 22%.
The effect of income not subject to tax of NLB in 2024,
related to:
- dividends in 2024 amounted EUR 46,728
thousand (2023: EUR 26,219 thousand). They are
based on non-taxable dividend income in 2024 which
amounts to EUR 212,400 thousand (2023: EUR 137,994
thousand);
- release of impairments of equity investments
in 2024 amounted to EUR 11,815 thousand
(2023: EUR 18,591 thousand). They are based on
non-taxable income from release of impairments
of equity investments in 2024 in amount of
EUR 53,705 thousand (2023: EUR 97,847 thousand).
NLB recognised deferred tax assets accrued on the
basis of temporary differences in an amount that, given
future profit estimates, is expected to be reversed in the
foreseeable future (i.e., within five years). Due to some
uncertainties regarding external factors (regulatory
environment, market situation, etc.), a lower range of

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expected outcomes was considered for the purposes of
deferred tax assets calculation.
NLB recognised deferred tax assets on all temporary
differences. The deferred tax assets for tax losses are
recognised in the amount that takes into account other
deferred tax assets, reaches the total amount of deferred
tax assets, for which a reversal is expected within five
years. The deferred tax assets with respect to which
simultaneously deferred tax liabilities are recognised are
excluded from this calculation (e.g., deferred tax assets
for temporary non-deductible expenses for impairment
of debt securities measured at fair value through other
comprehensive income and deferred tax assets related
to fair value hedge accounting).
NLB Group members did not recognise deferred tax
assets for tax losses if there was uncertainty about
whether the tax losses could be utilised, because it is
not probable that future taxable profits will be available
against which the deferred tax assets can be utilised.
The majority of the impact of unrecognised deferred
tax assets on current period tax losses for 2023 relates
to the tax loss of a subsidiary that realised tax loss
due to the utilisation of previously tax non-deductible
expenses for impairments in the subsidiary, which was
divested in 2023.
Deferred tax liability related to undistributed profits
includes withholding tax which shall be paid in the year
2025 on projected dividends.
The tax authorities may audit operations of NLB Group
entities. In general, tax inspection, which may result
in the emergence of additional tax liability, default
interest, and penalties, may be initiated at any time
within four to six years from the date of tax statement or
from the year in which tax should have been assessed.
NLB is not aware of any circumstances that could give
rise to a potential material tax liability in this respect.
NLB has a special tax status at the Financial
Administration of the Republic of Slovenia (FURS).
The purpose of the status is to establish cooperation
between FURS and the taxpayers, with the aim of
encouraging voluntary compliance and reduce
administrative burdens on financial supervision. FURS
cooperates with NLB and responds quickly to resolve
NLB’s tax compliance issues, which reduces NLB’s tax
risks and uncertain tax positions.
Global minimum tax
NLB Group became subject to global minimum top-up
tax from 1 January 2024 and is liable to pay the top-up-
tax for the group members in the jurisdictions, where
effective tax rate, calculated by the rules related to
global minimum top-up-tax, is below 15%. NLB as the
parent company recognised the global minimum top-
up-tax in the amount of EUR 3,851 thousand related to
subsidiaries in Bosnia and Herzegovina and Kosovo,
where the statutory corporate income tax rate is 10%.
North Macedonia, where a 10% statutory corporate
income tax also applies, introduced a domestic top-
up-tax, therefore NLB Banka Skopje recognised a EUR
2,186 thousand top-up-tax.
The NLB Group applied a mandatory temporary
exception from the requirements of IAS 12, according
to which information on deferred tax assets and
liabilities related to Global minimum tax are not
recognised or disclosed.

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4. 16. Earnings per share
Earnings per share are calculated by dividing the net
profit by the weighted average number of ordinary
shares in issue, less treasury shares.
Diluted earnings per share are the same as basic
earnings per share for NLB Group and NLB, since
subordinated bonds and other issued debt securities
have no future conversion options, and consequently
there are no dilutive potential ordinary shares.
NLB Group
NLB
2024
2023
2024
2023
Net profit attributable to the owners of
the parent (in EUR thousands)
514,552
550,700
478,161
514,287
Weighted average number of ordinary shares (in thousands)
20,000
20,000
20,000
20,000
Basic earnings per share (in EUR per share)
25.7
27.5
23.9
25.7
Diluted earnings per share (in EUR per share)
25.7
27.5
23.9
25.7
5. Notes to the Statement of Financial Position
5. 1. Cash, cash balances at central banks, and other demand deposits at banks
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Balances and obligatory reserves with central banks
3,322,029
5,435,460
1,708,488
4,077,399
Cash
540,283
470,902
214,637
181,735
Demand deposits at banks
178,504
198,489
50,183
59,365
4,040,816
6,104,851
1,973,308
4,318,499
Allowance for impairment
(1,235)
(1,290)
(195)
(467)
Total
4,039,581
6,103,561
1,973,113
4,318,032
Slovenian banks are required to maintain a
compulsory reserve with the Bank of Slovenia relative
to the volume and structure of their customer deposits.
Other banks in NLB Group maintain a compulsory
reserve in accordance with local legislation. NLB
and other banks in NLB Group fulfil their compulsory
reserve deposit requirements.

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5. 2. Financial instruments held for trading
a) Financial assets held for trading
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Derivatives, excluding hedging instruments
Swap contracts
7,649
13,867
10,393
16,135
- currency swaps
1,598
3,687
1,919
3,712
- interest rate swaps
6,051
10,180
8,474
12,423
Options
486
1,249
486
1,249
- interest rate options
463
1,229
463
1,229
- securities options
23
20
23
20
Forward contracts
779
602
770
573
- currency forward
779
602
770
573
Total derivatives
8,914
15,718
11,649
17,957
Securities
Bonds
9,424
-
9,424
-
- other EU members
2,036
-
2,036
-
- other non-EU members
7,388
-
7,388
-
Total securities
9,424
-
9,424
-
Total
18,338
15,718
21,073
17,957
- quoted securities
9,424
-
9,424
-
of these debt instruments
9,424
-
9,424
-
The notional amounts of derivative financial
instruments are disclosed in note 5.24.b).
b) Financial liabilities held for trading
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Derivatives, excluding hedging instruments
Swap contracts
5,496
11,139
8,478
15,440
- currency swaps
660
2,035
1,311
4,216
- interest rate swaps
4,836
9,104
7,167
11,224
Options
595
1,573
595
1,573
- interest rate options
595
1,573
595
1,573
Forward contracts
904
505
904
497
- currency forward
904
505
904
497
Total
6,995
13,217
9,977
17,510
The notional amounts of derivative financial
instruments are disclosed in note 5.24.b).

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5. 3. Non-trading financial instruments measured at fair value through profit or loss
a) Financial assets mandatorily at fair value through profit or loss
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Assets
Shares
8,650
6,300
8,650
6,300
Investment funds
7,779
2,658
6,521
2,558
Bonds
1,000
5,217
-
-
Loans and advances to companies
-
-
3,964
7,785
Total
17,429
14,175
19,135
16,643
- quoted securities
1,000
5,217
-
-
of these debt instruments
1,000
5,217
-
-
- unquoted securities
16,429
8,958
15,171
8,858
of these equity instruments
16,429
8,958
15,171
8,858
As at 31 December 2024 and 2023, NLB Group and
NLB did not have any assets received by taking
possession of collateral and included in financial assets
mandatorily at fair value through profit or loss.
b) Financial liabilities measured at fair value through profit or loss
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Liabilities
Loans and advances to companies
-
-
637
1,234
Other financial liabilities (note 2.32.)
9,633
4,482
4,960
1,976
Total
9,633
4,482
5,597
3,210

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5. 4. Financial assets measured at fair value through other comprehensive income
a) Analysis by type of financial assets measured at fair value through other comprehensive income
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Bonds
2,262,669
1,836,604
1,601,875
962,084
- governments
1,707,776
1,398,036
1,046,982
523,516
- Republic of Slovenia
385,768
246,155
365,517
210,509
- other EU members
636,688
200,914
564,737
194,599
- Republic of Serbia
347,103
579,333
4,701
4,482
- other non-EU members
338,217
371,634
112,027
113,926
- banks
459,750
413,926
459,750
413,926
- other issuers
95,143
24,642
95,143
24,642
Shares
33,819
26,467
370
303
National Resolution Fund
62,774
60,625
62,774
60,625
Treasury bills
173,614
301,838
-
-
- Republic of Slovenia
-
19,902
-
-
- other EU members
140,774
247,827
-
-
- other non-EU members
32,840
34,109
-
-
Commercial bills
30,640
26,022
-
-
Total
2,563,516
2,251,556
1,665,019
1,023,012
of these debt securities
2,466,923
2,164,464
1,601,875
962,084
of these equity securities
96,593
87,092
63,144
60,928
Allowance for impairment (note 5.14.b)
(5,793)
(7,329)
(2,647)
(2,448)
- quoted securities
2,392,486
1,997,126
1,601,875
962,084
of these debt instruments
2,363,268
1,992,263
1,601,875
962,084
of these equity instruments
29,218
4,863
-
-
- unquoted securities
171,030
254,430
63,144
60,928
of these debt instruments
103,655
172,201
-
-
of these equity instruments
67,375
82,229
63,144
60,928
The credit quality analysis for financial assets and
contingent liabilities is disclosed in note 6.1.j) and
movements in allowance for the impairment of debt
securities in note 5.14.b).

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b) Movements of financial assets measured at fair value through other comprehensive income
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Debt securities
Equity
securities Debt securities
Equity
securities
Debt securities
Equity
securities Debt securities
Equity
securities
Balance as at 1 January
2,164,464
87,092
2,838,796
80,407
962,084
60,928
1,291,277
42,784
Effects of translation of foreign operations
to presentation currency
2,433
103
(293)
(34)
-
-
-
-
Additions
2,433,207
54
1,446,746
-
836,368
54
59,345
-
Derecognition
(2,253,476)
(87)
(2,249,943)
(82)
(260,979)
-
(479,962)
-
Net interest income
54,462
-
38,624
-
25,289
-
9,163
-
Exchange differences on monetary assets
4,177
-
1,901
-
1,427
-
(766)
-
Changes in fair values
61,656
9,431
88,633
6,801
37,686
2,162
49,410
2,284
Merger of subsidiary (note 5.12.f)
-
-
-
-
-
-
33,617
15,860
Balance as at 31 December
2,466,923
96,593
2,164,464
87,092
1,601,875
63,144
962,084
60,928
As at 31 December 2024, and as at 31 December 2023,
NLB Group and NLB do not have any equity instruments
measured at fair value through other comprehensive
income obtained by taking possession of collateral in
the statement of financial position (note 6.1.l).
c) Accumulated other comprehensive income related to financial assets measured at fair value through other comprehensive income
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Debt securities
Equity
securities Debt securities
Equity
securities
Debt securities
Equity
securities Debt securities
Equity
securities
Balance as at 1 January
(66,934)
7,011
(144,578)
1,332
(35,255)
144
(78,283)
(1,460)
Effects of translation of foreign operations
to presentation currency
(14)
(8)
(31)
(5)
-
-
-
-
Net gains/(losses) from changes in fair value
55,795
9,431
77,269
6,801
31,825
2,162
38,046
2,284
Gains/losses transferred to net profit on disposal (note 4.4.)
3,168
-
742
-
210
-
834
-
Impairment (note 4.14.)
(1,535)
-
(7,054)
-
198
-
(5,058)
-
Transfer of gains/losses to retained earnings
-
(58)
-
(63)
-
-
-
-
Deferred income tax (note 5.17.)
(10,589)
(1,484)
6,718
(1,054)
(7,091)
(476)
11,849
(434)
Merger of subsidiary
-
-
-
-
-
-
(2,643)
(246)
Balance as at 31 December
(20,109)
14,892
(66,934)
7,011
(10,113)
1,830
(35,255)
144

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5. 5. Derivatives for hedging purposes
NLB Group entities measure exposure to interest rate
risk using repricing gap analysis and by calculating
the sensitivity of the statement of financial position
and off-balance-sheet items in terms of the economic
value of equity. The portfolio duration is used as a
measure of risk in the management of securities in the
banking book.
NLB Group entities use interest rate swaps (IRS) to
close open positions in an individual maturity bucket.
Micro and macro fair value hedges are used for that
purpose, i.e., the swapping of a fixed interest rate on a
hedged item for a variable interest rate. Micro cash flow
hedges are also occasionally used, i.e. the swapping
of a variable interest rate on a hedged item for a fixed
interest rate. All fair value hedges are made on assets
and liability items.
Hedge accounting principles (i.e., fair value and cash
flow hedging) were applied in the hedging of interest
rate risk using interest rate swaps. These hedge
relationships are designated in such a way that the
characteristics of the hedging instrument and those of
the hedged item match (i.e., the principal terms match),
while the dollar-offset method is used to regularly
measure hedge effectiveness retrospectively. Efficiency
is considered when total difference is within range
80%–125% or within materiality threshold defined at
origination of hedge. Prospective testing of hedge
effectiveness is carried out regularly for macro hedges
where the characteristics of both items in the hedge
relationship do not fully match by comparing the
change in the fair value of both items to the shift in the
yield curve.
Sources of hedge ineffectiveness may arise from
the difference of discount rates used for valuation of
hedged and hedging instruments, notional and timing
differences, as well differences in the amortisation plan
between hedged items and the hedging instrument.
Hedge effectiveness is assessed monthly, by comparing
changes in the fair value of the hedged item that are
attributable to a hedged risk with changes in the fair
value of the hedging instrument.
a) Fair value adjustment in hedge accounting recognised in profit or loss
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Fair value hedge from assets items
(231)
2,735
(223)
2,424
Net effects from hedging instruments
(10,840)
(24,799)
(10,731)
(22,803)
- interest rate swap for micro hedge
(7,098)
(15,677)
(6,989)
(13,681)
- interest rate swap for macro hedge
(3,742)
(9,122)
(3,742)
(9,122)
Net effects from hedged items
10,609
27,534
10,508
25,227
- loans measured at amortised cost - micro hedge
-
(3)
-
(3)
- bonds measured at amortised cost - micro hedge
894
2,684
894
2,684
- bonds measured at fair value through OCI - micro hedge
5,861
11,293
5,861
11,293
- loans measured at amortised cost- macro hedge
3,854
13,560
3,753
11,253
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Fair value hedge from liability items
(1,180)
1,164
(1,180)
1,164
Net effects from hedging instruments
25,204
6,505
25,204
6,505
- interest rate swap for micro hedge
25,204
6,505
25,204
6,505
Net effects from hedged items
(26,384)
(5,341)
(26,384)
(5,341)
- debt securities issued
(26,384)
(5,341)
(26,384)
(5,341)
In both years presented, all fair value hedges were
effective, with actual results of the hedge ratio within a
range of 80–125% (or within the materiality of change),
therefore, no discontinuation of the hedge accounting
was required.
As at 31 December 2024 and 2023, NLB Group and
NLB had no relationships designated for cash flow
hedge accounting or for hedge of a net investment in a
foreign operation. NLB Group applied a hedge of a net
investment in a foreign operation in years 2011 and 2012,
and at that time recognised a EUR 754 thousand gain on
the hedging instrument in other comprehensive income
(note 5.22.b). This gain will be included in the consolidated
income statement when the foreign operation is disposed
of as a part of the gain or loss on the disposal.

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b) Notional amounts of interest rate swaps
in EUR thousands
NLB Group
NLB
Fair value hedge of assets items
Notional
amount
Fair value
Change in fair value
of hedging instrument
used for calculating
hedge ineffectiveness
Notional
amount
Fair value
Change in fair value
of hedging instrument
used for calculating
hedge ineffectiveness
Asset
Liability
Asset
Liability
31 Dec 2024
589,141
26,815
3,592
(10,802)
529,141
26,815
1,261
(10,583)
31 Dec 2023
633,798
38,738
3,540
19,708
573,798
38,738
1,420
17,843
in EUR thousands
NLB Group
NLB
Fair value hedge of liability items
Notional
amount
Fair value
Change in fair value
of hedging instrument
used for calculating
hedge ineffectiveness
Notional
amount
Fair value
Change in fair value
of hedging instrument
used for calculating
hedge ineffectiveness
Asset
Liability
Asset
Liability
31 Dec 2024
1,520,000
50,956
-
41,997
1,520,000
50,956
-
41,997
31 Dec 2023
450,000
8,876
-
8,774
450,000
8,876
-
8,774
The hedging instrument is included in the statement
of financial position in the line item ‘Derivatives –
hedge accounting.’

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c) Accumulated fair value adjustments arising from the
corresponding continuing hedge relationships
The table below presents accumulated fair value
adjustments arising from the corresponding continuing
hedge relationships, irrespective of whether there
has been a change in the hedge designation during
the year. The accumulated fair value adjustment is
presented in the same line of statement of financial
position as a hedged item, except for macro fair
value hedges. In such relationships, hedged items are
presented in the line item ‘Financial assets measured
at amortised cost,’ while the accumulated fair value
adjustment is presented in a separate line item ‘Fair
value changes of the hedged items in portfolio hedge of
interest rate risk.’
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Carrying
amount of
hedged items
Accumulated
amount of FV
adjustments
on the hedged
item
Carrying
amount of
hedged items
Accumulated
amount of FV
adjustments
on the hedged
item
Carrying
amount of
hedged items
Accumulated
amount of FV
adjustments
on the hedged
item
Carrying
amount of
hedged items
Accumulated
amount of FV
adjustments
on the hedged
item
Micro fair value hedges
Fixed rate bonds measured at AC
114,743
(3,768)
108,494
(4,349)
114,743
(3,768)
108,494
(4,349)
Fixed rate bonds measured at FVOCI
213,207
(9,980)
242,347
(15,841)
213,207
(9,980)
242,347
(15,841)
Fixed rate issued bonds
1,096,577
31,725
464,393
5,341
1,096,577
31,725
464,393
5,341
Macro fair value hedges
Fixed rate retail loans
257,465
(6,353)
267,908
(10,207)
194,962
(8,761)
205,601
(12,514)
The change in fair value of the hedge item used as the
basis for recognising hedge ineffectiveness:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Micro fair value hedges
(38,270)
3,591
(38,270)
3,591
Macro fair value hedges
3,560
10,577
3,364
8,540
d) IBOR reform
NLB Group continuously monitors the development
of Benchmark Interest Rate Reform and is actively
preparing for the changes imposed by the regulation.
In 2018, NLB formed a special working group which
deals with the preparation for the discontinuation of
some important reference interest rates and reports on
this to the NLB Group ALCO.
NLB Group no longer offers new products that would
be tied to reference rates in termination. With regard to
the reference rates, the NLB Group offers only products
related to EURIBOR, which is not scheduled for
discontinuation. Therefore, NLB Group’s attention in the
past few years has been focused on the modification of
new contractual relationships with customers in which
EURIBOR occurs.
EURIBOR’s possible discontinuation
Due to the timely transition to the new hybrid EURIBOR
methodology which meet the BMR requirements,
EURIBOR can continue to be used in new and legacy
contracts for the foreseeable future.
EU-supervised entities are bound to include robust
fallback clauses into contractual documentation
with the clients. In November 2019, the Euro risk-
free rates (RFR) Working Group published high level
recommendations for fallback provisions for products
referencing EURIBOR. The inclusion of robust fallback
language is a requirement in contracts subject to
the EU Benchmark Regulation. The Bank already
incorporated the generic fallback clause into all new
EURIBOR (both retail and corporate) contracts.
In May 2021, the Euro RFR Working Group produced
its recommendations on EURIBOR fallback trigger
events and €STR-based EURIBOR fallback rates. NLB's
mid-term activities are expected to undertake on the
implementation of more precise fallback provisioning,
based on these recommendations. NLB identified
potential €STR-based fallbacks for EURIBOR, in line
with the current market consensus on those fallbacks
and intends to proceed with the activities for inclusion
on EURIBOR fallbacks into all new EURIBOR-based

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contracts. In the next step, the Bank is also expected
to include fallback provisions in legacy contracts.
The exact timing depends on the regulatory/market
development and best practice.
NLB as a supervised entity, is required to comply
with the Benchmark regulation and, as a user of
benchmarks, must produce and maintain a robust
written plan setting out the actions NLB would take
in the event that a benchmark materially changes or
ceases to be provided. NLB has prepared a plan, which
sets out an inexhaustive/summary action list, and will
continue to closely follow market standards to identify
alternative benchmarks that could be referenced in
substitute of existing benchmarks.
LIBOR discontinuation
Since many LIBOR settings ceased to exist at the
beginning of 2022, the Bank finished the process of
winding-down the exposures in a most efficient way.
Incremental LIBOR transactions were not allowed
unconditionally.
NLB Group activities for implementation of LIBOR
transition were as follows:
- review of outstanding LIBOR referencing loans,
- identification of alternative reference rate to be used
for loan portfolio,
- analysis of how the alternative reference rate will
be calculated and how to calculate any economic
difference between LIBORs and the selected
alternative reference rates,
- consideration of IT system accommodation with
alternative reference rates,
- documentation of the transition of the loans.
The tables indicate the notional amount and weighted
average maturity of derivatives on the NLB Group level
and separately NLB d.d. sole in hedging relationships
that will be affected by the IBOR reform, analysed
on an interest rate basis. The derivative hedging
instruments provide a close approximation to the
extent of the risk exposure NLB Group manages
through hedging relationships.
in EUR thousands
2024
2023
NLB Group
Notional amount
(in EUR
thousands)
Weighted
average
maturity (years)
Notional amount
(in EUR
thousands)
Weighted
average
maturity (years)
Interest rate swaps (assets)
EURIBOR (3 months)
310,250
8.05
318,509
8.94
EURIBOR (6 months)
272,189
5.47
315,289
5.68
USD LIBOR (6 months)
6,702
8.93
-
-
Interest rate swaps (liabilities)
EURIBOR (3 months)
800,000
2.53
350,000
2.49
EURIBOR (6 months)
720,000
3.87
100,000
2.49
in EUR thousands
2024
2023
NLB
Notional amount
(in EUR
thousands)
Weighted
average
maturity (years)
Notional amount
(in EUR
thousands)
Weighted
average
maturity (years)
Interest rate swaps (assets)
EURIBOR (3 months)
250,250
8.88
258,509
9.72
EURIBOR (6 months)
272,189
5.47
315,289
5.68
USD LIBOR (6 months)
6,702
8.93
-
-
Interest rate swaps (liabilities)
EURIBOR (3 months)
800,000
2.53
350,000
2.49
EURIBOR (6 months)
720,000
3.87
100,000
2.49
As can be seen from the table, the majority of long-
term derivatives in hedging relationships are exposed
to EURIBOR, therefore, the uncertainty arising from
interest rate benchmark reform derives mainly from
derivatives with longer maturities, when a change of
EURIBOR could be expected. As at 31 December 2024,
derivatives with remaining maturity of five or more years
amount to EUR 242,830 thousand (31 December 2023:
EUR 285,280 thousand).

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NLB Group Key Members
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Financial
Report
5. 6. Financial assets measured at amortised cost
Analysis by type
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Debt securities
3,725,195
2,522,229
2,846,779
1,966,169
Loans and advances to banks
458,921
547,640
193,172
149,011
Loans and advances to customers
16,363,649
13,734,601
8,653,348
7,148,283
Other financial assets
136,854
165,962
81,518
101,596
Total
20,684,619
16,970,432
11,774,817
9,365,059
The credit quality analysis for financial assets and
contingent liabilities is disclosed in note 6.1.j).
a) Debt securities
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Governments
2,707,448
1,898,725
1,832,344
1,347,161
Companies
75,923
79,679
68,674
72,458
Banks
882,616
536,096
882,616
536,096
Financial organisations
66,675
13,251
66,675
13,251
3,732,662
2,527,751
2,850,309
1,968,966
Allowance for impairment (note 5.14.b)
(7,467)
(5,522)
(3,530)
(2,797)
Total
3,725,195
2,522,229
2,846,779
1,966,169
b) Loans and advances to banks
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Loans
456
623
131,794
119,914
Time deposits
229,591
249,765
61,684
25,865
Reverse sale and repurchase agreements
229,049
294,069
-
-
Purchased receivables
-
3,482
-
3,482
Finance lease receivables (note 5.11.b)
65
-
-
-
459,161
547,939
193,478
149,261
Allowance for impairment (note 5.14.a)
(240)
(299)
(306)
(250)
Total
458,921
547,640
193,172
149,011
c) Loans and advances to customers
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Loans
14,817,888
13,117,311
8,440,471
6,946,199
Overdrafts
507,933
449,145
276,421
236,792
Finance lease receivables (note 5.11.b)
1,227,783
337,610
-
-
Credit card business
158,702
154,664
87,211
82,457
Called guarantees
9,104
4,498
6,958
2,403
16,721,410
14,063,228
8,811,061
7,267,851
Allowance for impairment (note 5.14.a)
(357,761)
(328,627)
(157,713)
(119,568)
Total
16,363,649
13,734,601
8,653,348
7,148,283

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Analysis of loans and advances to customers by sector
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Governments
511,129
386,291
209,228
118,220
Financial organisations
149,132
91,523
1,326,073
384,995
Companies
7,145,683
6,169,972
3,235,837
3,101,465
Individuals
8,557,705
7,086,815
3,882,210
3,543,603
Total
16,363,649
13,734,601
8,653,348
7,148,283
d) Other financial assets
Analysis by type of other financial assets
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Receivables in the course of settlement
and other temporary accounts
43,265
43,608
25,701
20,207
Credit card receivables
26,108
54,748
13,881
42,753
Debtors
14,181
9,265
3,437
2,013
Fees and commissions
7,974
9,734
3,405
2,924
Accrued income
15,081
7,171
7,451
6,247
Prepayments
5,183
2,176
-
-
Other financial assets
34,055
50,065
28,856
29,066
145,847
176,767
82,731
103,210
Allowance for impairment (note 5.14.a)
(8,993)
(10,805)
(1,213)
(1,614)
Total
136,854
165,962
81,518
101,596
Receivables in the course of settlement are temporary
balances which will be transferred to the appropriate
item in the days following their occurrence.
Other financial assets in the amount of EUR 23,975
thousand (31 December 2023: EUR 22,745 thousand)
relate to a receivable recognised in accordance with
the ‘Act for Value Protection of Republic of Slovenia’s
Capital Investment in Nova Ljubljanska banka d.d.,
Ljubljana’ (note 5.16.a). The remaining balance includes
claims for fees and legal costs, and claims from refunds.

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Report
Analysis of other financial assets by sector
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Banks
42,218
51,020
10,114
19,779
Government
26,315
44,233
26,000
25,756
Financial organisations
21,126
30,715
11,932
23,554
Companies
9,385
5,062
824
723
Individuals
37,810
34,932
32,648
31,784
Total
136,854
165,962
81,518
101,596
e) Movement of called non-financial guarantees
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
984
397
60
90
Effects of translation of foreign
operations to presentation currency
-
(1)
-
-
Called guarantees
1,599
1,184
1,300
-
Paid guarantees
(1,722)
(534)
(1,144)
-
Merger of subsidiary
-
-
-
32
Write-offs
(357)
(62)
(176)
(62)
Balance as at 31 December
504
984
40
60
5. 7. Non-current assets held for sale
The line item ‘Non-current assets held for sale’ includes
business premises and assets received as collateral
that are in the process of being sold. As at 31 December
2024, the value of assets received by taking possession
of collateral and included in non-current assets held for
sale by NLB Group amounted to EUR 7,191 thousand
(31 December 2023: EUR 474 thousand). As at
31 December 2024, and as at 31 December 2023, NLB
did not have any non-current assets obtained by taking
possession of collateral and included in non-current
assets held for sale (note 6.1.l).
Analysis of movements of non-current assets held for sale
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
4,849
15,436
4,048
4,235
Effects of translation of foreign
operations to presentation currency
6
11
-
-
Transfer from/(to) property and
equipment (note 5.8.)
7,681
584
240
584
Transfer from/(to) other assets
8
-
8
-
Transfer from/(to) investment property (note 5.9.)
81
-
-
-
Disposals
(1,286)
(10,861)
(1,136)
(655)
Valuation
(303)
(321)
(311)
(116)
Balance as at 31 December
11,036
4,849
2,849
4,048

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5. 8. Property and equipment
a) Analysis by type
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Own property and equipment
274,683
249,920
85,677
80,240
Right-of-use assets (note 5.11.)
35,334
28,114
5,643
5,730
Total
310,017
278,034
91,320
85,970
b) Movement wof own property and equipment
in EUR thousands
NLB Group
NLB
Land &
Buildings
Computers
Other equipment
Total
Land &
Buildings
Computers
Other equipment
Total
for own use
in
operating
lease
for own use
in
operating
lease
Cost
Balance as at 1 January 2024
357,527
93,968
104,612
15,004
571,111
202,080
46,552
44,866
4,202
297,700
Effects of translation of foreign operations
to presentation currency
233
66
61
1
361
-
-
-
-
-
Acquisition of subsidiary (note 5.12.b, c)
-
302
627
20,777
21,706
-
-
-
-
-
Additions
14,155
11,067
16,355
20,791
62,368
7,825
5,962
2,439
395
16,621
Disposals
(1,529)
(9,358)
(8,830)
(10,596)
(30,313)
(93)
(2,312)
(3,007)
(1)
(5,413)
Transfer from/to property and equipment
385
-
(547)
162
-
385
-
(385)
-
-
Transfer to/from investment property (note 5.9.)
1,106
-
-
-
1,106
-
-
-
-
-
Transfer to/from non-current assets held for sale (note 5.7.)
(10,436)
-
-
-
(10,436)
(2,123)
-
-
-
(2,123)
Other
-
-
-
(7,793)
(7,793)
-
-
-
-
-
Balance as at 31 December 2024
361,441
96,045
112,278
38,346
608,110
208,074
50,202
43,913
4,596
306,785
Depreciation and impairment
Balance as at 1 January 2024
183,334
58,823
73,838
5,196
321,191
141,780
33,419
38,690
3,571
217,460
Effects of translation of foreign operations
to presentation currency
34
20
16
1
71
-
-
-
-
-
Disposals
(664)
(8,808)
(7,513)
(123)
(17,108)
-
(2,307)
(2,999)
(1)
(5,307)
Depreciation (note 4.11.)
9,665
9,348
7,710
2,838
29,561
3,880
4,710
2,004
244
10,838
Impairment (note 4.14.)
3,667
-
-
-
3,667
-
-
-
-
-
Transfer from/to property and equipment
47
-
(88)
41
-
47
-
(47)
-
-
Transfer to/from investment property (note 5.9.)
(8)
-
-
-
(8)
-
-
-
-
-
Transfer to/from non-current assets held for sale (note 5.7.)
(2,755)
-
-
-
(2,755)
(1,883)
-
-
-
(1,883)
Other
-
-
-
(1,192)
(1,192)
-
-
-
-
-
Balance as at 31 December 2024
193,320
59,383
73,963
6,761
333,427
143,824
35,822
37,648
3,814
221,108
Net carrying value
Balance as at 31 December 2024
168,121
36,662
38,315
31,585
274,683
64,250
14,380
6,265
782
85,677
Balance as at 1 January 2024
174,193
35,145
30,774
9,808
249,920
60,300
13,133
6,176
631
80,240
As at 31 December 2024, the value of assets received by
taking possession of collateral and included in property
and equipment by NLB Group amounted to EUR 1,644
thousand (31 December 2023: EUR 11,641 thousand). As
at 31 December 2024 and as at 31 December 2023, NLB
did not have any assets received by taking possession
of collateral and included in property and equipment
(note 6.1.l).

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Performance Overview
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Statement
Financial
Report
in EUR thousands
NLB Group
NLB
Land &
Buildings
Computers
Other equipment
Total
Land &
Buildings
Computers
Other equipment
Total
for own use
in
operating
lease
for own use
in
operating
lease
Cost
Balance as at 1 January 2023
347,252
84,875
95,075
9,304
536,506
195,685
42,180
43,783
3,722
285,370
Effects of translation of foreign operations
to presentation currency
(68)
(20)
(3)
-
(91)
-
-
-
-
-
Additions
16,827
14,104
15,217
7,604
53,752
3,527
4,737
2,829
482
11,575
Disposals
(5,519)
(4,969)
(5,627)
(1,904)
(18,019)
-
(1,357)
(2,403)
(2)
(3,762)
Transfer to/from investment property (note 5.9.)
86
-
-
-
86
-
-
-
-
-
Transfer to/from non-current assets held for sale (note 5.7.)
(1,051)
-
-
-
(1,051)
(1,051)
-
-
-
(1,051)
Merger of subsidiary (note 5.12.f)
-
-
-
-
-
3,919
992
657
-
5,568
Disposal of subsidiaries (note 5.12.d, e)
-
(22)
(50)
-
(72)
-
-
-
-
-
Balance as at 31 December 2023
357,527
93,968
104,612
15,004
571,111
202,080
46,552
44,866
4,202
297,700
Depreciation and impairment
Balance as at 1 January 2023
177,896
53,340
72,310
4,016
307,562
138,264
29,619
38,891
3,334
210,108
Effects of translation of foreign operations
to presentation currency
(10)
(3)
11
-
(2)
-
-
-
-
-
Disposals
(914)
(4,615)
(4,845)
(335)
(10,709)
-
(1,350)
(2,359)
(2)
(3,711)
Depreciation (note 4.11.)
6,782
10,123
6,412
1,515
24,832
3,750
4,635
1,884
239
10,508
Impairment (note 4.14.)
47
-
-
-
47
-
-
-
-
-
Transfer to/from non-current assets held for sale (note 5.7.)
(467)
-
-
-
(467)
(467)
-
-
-
(467)
Merger of subsidiary (note 5.12.f)
-
-
-
-
-
233
515
274
-
1,022
Disposal of subsidiaries (note 5.12.d, e)
-
(22)
(50)
-
(72)
-
-
-
-
-
Balance as at 31 December 2023
183,334
58,823
73,838
5,196
321,191
141,780
33,419
38,690
3,571
217,460
Net carrying value
Balance as at 31 December 2023
174,193
35,145
30,774
9,808
249,920
60,300
13,133
6,176
631
80,240
Balance as at 1 January 2023
169,356
31,535
22,765
5,288
228,944
57,421
12,561
4,892
388
75,262

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5. 9. Investment property
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
31,116
35,639
7,640
6,753
Effects of translation of foreign operations
to presentation currency
65
(14)
-
-
Disposals
(4,340)
(3,392)
(2,227)
(79)
Transfer from/(to) property and equipment (note 5.8.)
(1,114)
(86)
-
-
Transfer from/(to) non-current assets held for sale (note 5.7.)
(81)
-
-
-
Transfer from/(to) other assets
-
86
-
-
Net valuation to fair value (note 4.8.)
486
(1,117)
186
182
Merger of subsidiary (note 5.12.f)
-
-
-
784
Balance as at 31 December
26,132
31,116
5,599
7,640
As at 31 December 2024, the value of assets received
by taking possession of collateral and included in
investment property by NLB Group amounted to
EUR 17,844 thousand (31 December 2023: EUR 21,253
thousand), and in NLB amounted to EUR 619 thousand
(31 December 2023: EUR 2,263 thousand) (note 6.1.l).
Operating expenses arising from investment properties:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Leased to others
529
1,986
333
373
Not leased to others
476
459
342
298
Total
1,005
2,445
675
671

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5. 10. Intangible assets
in EUR thousands
NLB Group
NLB
Software licenses
Other
intangible assets
Goodwill
Total
Software licenses
Cost
Balance as at 1 January 2024
272,445
13,214
32,336
317,995
218,179
Effects of translation of foreign operations
to presentation currency
68
51
(1)
118
-
Acquisition of subsidiaries (note 5.12.b, c)
1,590
21,959
4,541
28,090
-
Additions
31,023
-
-
31,023
18,670
Write-offs
(3,946)
-
-
(3,946)
(3,250)
Balance as at 31 December 2024
301,180
35,224
36,876
373,280
233,599
Amortisation and impairment
Balance as at 1 January 2024
217,335
9,736
28,807
255,878
180,800
Effects of translation of foreign operations
to presentation currency
39
38
-
77
-
Amortisation (note 4.11.)
18,147
2,628
-
20,775
11,625
Write-offs
(3,946)
-
-
(3,946)
(3,250)
Balance as at 31 December 2024
231,575
12,402
28,807
272,784
189,175
Net carrying value
Balance as at 31 December 2024
69,605
22,822
8,069
100,496
44,424
Balance as at 1 January 2024
55,110
3,478
3,529
62,117
37,379
Other intangible assets represent additionally identified
intangible assets in a business combination, namely
core deposits, trade name and intangible assets related
to the distribution agreements. The newly identified
intangible assets related to the distribution agreements
recognised at the acquisition date were measured by
referring to the fair value which amounted to EUR 21,959
thousand. Useful life is assessed to be 10 years. This fair
value was estimated by applying an income approach.

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Statement
Financial
Report
in EUR thousands
NLB Group
NLB
Software licenses
Other
intangible assets
Goodwill
Total
Software licenses
Cost
Balance as at 1 January 2023
259,684
13,227
32,336
305,247
207,769
Effects of translation of foreign operations
to presentation currency
(25)
(13)
-
(38)
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
979
Additions
20,697
-
-
20,697
13,797
Disposals
(4)
-
-
(4)
-
Write-offs
(7,740)
-
-
(7,740)
(4,366)
Disposal of subsidiary (note 5.12.d)
(167)
-
-
(167)
-
Balance as at 31 December 2023
272,445
13,214
32,336
317,995
218,179
Amortisation and impairment
Balance as at 1 January 2023
210,821
7,384
28,807
247,012
177,344
Effects of translation of foreign operations
to presentation currency
(16)
(13)
-
(29)
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
294
Disposals
(4)
-
-
(4)
-
Amortisation (note 4.11.)
14,037
2,365
-
16,402
7,528
Write-offs
(7,336)
-
-
(7,336)
(4,366)
Disposal of subsidiary (note 5.12.d)
(167)
-
-
(167)
-
Balance as at 31 December 2023
217,335
9,736
28,807
255,878
180,800
Net carrying value
Balance as at 31 December 2023
55,110
3,478
3,529
62,117
37,379
Balance as at 1 January 2023
48,863
5,843
3,529
58,235
30,425
5. 11. Leases
a) NLB Group as a lessee
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Right-of-use assets
Land and buildings
31,802
24,541
3,103
2,794
Vehicles
85
92
2,377
2,681
Computers
375
395
163
255
Furniture and equipment
3,072
3,086
-
-
Total
35,334
28,114
5,643
5,730
Lease liabilities
35,935
28,944
5,775
5,793
In the statement of financial position, right-of-use
assets are included in the line item ‘Property and
equipment’ and lease liabilities are included in the line
item ‘Other financial liabilities.’
Additions to the right-of-use assets during 2024 in
NLB Group amounted to EUR 17,305 thousand (2023:
EUR 19,149 thousand), and in NLB EUR 2,675 thousand
(2023: EUR 4,656 thousand). Due to the acquisition of
subsidiaries in 2024, the right-of-use assets in NLB
Group increased by EUR 1,894 thousand (note 5.12.c).

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Financial
Report
The income statement shows the following amounts relating to leases:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Depreciation of right-of-use assets (note 4.11.)
Land and buildings
6,653
6,519
684
692
Vehicles
81
160
821
705
Computers
91
61
48
24
Furniture and equipment
1,056
1,258
-
-
Total
7,881
7,998
1,553
1,421
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Interest expenses on lease liabilities (note 4.1.)
(1,076)
(728)
(180)
(132)
Expenses relating to short-term leases
(included in administrative expenses)
(929)
(1,554)
(269)
(403)
Expenses relating to leases of low-value assets
that are not shown above as short-term leases
(included in administrative expenses)
(1,393)
(1,237)
(138)
(182)
Income from sub-leasing right-of-use assets
(included in other operating income)
112
140
-
-
The total cash outflow for leases in 2024 in NLB Group
was EUR 9,433 thousand (2023: EUR 8,242 thousand), and
in NLB EUR 1,646 thousand (2023: EUR 1,386 thousand).
NLB Group leases various offices, branches, vehicles,
and other equipment used in its business. Rental
contracts for offices and branches generally have lease
terms between 5 to 20 years, while some contracts are
made for indefinite periods. Contracts for indefinite
periods are included in the measurement of the liability
in accordance with planning projections. Normally, a
lease term of five years is assumed, with the exemption
of business premises on strategic locations where
management assesses a different (longer) lease term.
Vehicles and other equipment generally have lease
terms between 1 and 5 years. There are several lease
contracts that include extension and termination options.
These options are negotiated by management to align
with the Group’s business needs. Lease payments to be
made under reasonably certain extension options are
included in measurement of the liability.
Lease terms are negotiated on an individual basis and
contain a range of different terms and conditions. The
lease agreements do not impose any covenants other
than the security interests in the leased assets that are
held by the lessor. Leased assets may not be used as
security for borrowing purposes.
NLB Group also has certain leases of other equipment
with a lease term of 12 months or less, and equipment
with low value. For these leases, NLB Group applies
the short-term lease and the lease of low-value assets
recognition exemptions. Lease payments on short-term
leases and leases of low-value assets are recognised
as expenses on a straight-line basis over the lease term.
For calculation of the net present value of the future
lease payments, NLB Group applies the internal
transfer price as a discount rate.
NLB Group and NLB do not have expenses relating to
variable payments and gains or losses arising from a
sale and leaseback transactions.

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The following table sets out a maturity analysis of undiscounted lease liabilities.
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Up to 1 Month
641
518
143
163
1 Month to 3 Months
1,291
1,016
283
285
3 Months to 1 Year
5,732
3,952
1,245
1,298
1 Year to 5 Years
24,005
18,155
3,734
3,835
Over 5 Years
8,607
7,719
794
640
Total
40,276
31,359
6,199
6,221
b) NLB Group as a lessor
Finance and operating leases of motor vehicles and
operating leases of business premises and POS
terminals represent the majority of agreements in
which NLB Group acts as a lessor.
Most of the lease agreements entered into by
NLB Group as lessor contracts are finance lease
agreements. Most of the finance lease agreements are
concluded for a non-cancellable period of between 48
and 60 months. By paying the last instalment at the end
of the contract, the leasing object becomes the lessee’s
property. The financial leasing receivables are secured
by the object of financing. NLB Group does not have
finance lease contracts with variable payments not
included in the measurement of the net investment in
the lease.
The investment properties are leased to the lessee
under operating leases with rentals payable monthly.
There are no variable lease payments that depend on
an index or a rate. The investment properties generally
have lease terms between 2 and 10 years. Some
contracts are made for an indefinite period.
Finance leases
Loans and advances to customers in NLB Group
include finance lease receivables.
The following table sets out a maturity analysis of lease
receivables, showing the undiscounted lease payments
to be received after the reporting date.
in EUR thousands
NLB Group
2024
2023
Less than 1 year
242,013
115,449
1 to 2 years
191,168
89,047
2 to 3 years
204,981
76,876
3 to 4 years
198,055
62,091
4 to 5 years
184,840
31,172
More than 5 years
397,203
20,787
Total undiscounted
lease receivable
1,418,260
395,422
Unearned finance income
(190,412)
(57,812)
Net investment in the lease
1,227,848
337,610
During 2024, NLB Group recognised interest income on
lease receivables in the amount of EUR 50,913 thousand
(2023: EUR 18,959 thousand).
Operating lease
A maturity analysis of lease payments, showing the
undiscounted lease payments to be received after the
reporting date.
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Less than
1 year
7,376
5,590
910
899
1 to 2 years
2,778
3,516
907
893
2 to 3 years
2,674
2,271
861
864
3 to 4 years
2,382
2,005
793
825
4 to 5 years
1,494
1,573
723
749
More than
5 years
3,838
3,490
3,616
3,393
Total
20,542
18,445
7,810
7,623
NLB Group realised rental income arising from:
investment properties in the amount of EUR 1,348
thousand (2023: EUR 1,755 thousand); and movable
property in the amount of EUR 2,491 thousand (2023:
EUR 2,133 thousand). NLB realised rental income arising
from: investment properties in the amount of EUR 293
thousand (2023: EUR 359 thousand); and movable
property in the amount of EUR 527 thousand (2023: EUR
485 thousand) (note 4.8.).

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Financial
Report
5. 12. Investments in subsidiaries, associates, and joint ventures
a) Analysis by type of investment in subsidiaries
in EUR thousands
NLB
31 Dec 2024
31 Dec 2023
Banks
975,400
901,765
Other financial organisations
160,952
30,407
Enterprises
43,405
43,585
Total
1,179,757
975,757
Data of subsidiaries as included in the consolidated financial statements of NLB Group as at 31 December 2024:
Nature of
Business
Country of
Incorporation
Equity as at
31 Dec 2024
(in EUR
thousands)
Profit/(loss)
for 2024
(in EUR
thousands)
NLB Group
NLB
Shareholding
(in %)
Voting rights
(in %)
Shareholding
(in %)
Voting rights
(in %)
Core members
NLB Banka a.d., Skopje
Banking
North Macedonia
322,944
67,838
86.97
86.97
86.97
86.97
NLB Banka a.d., Podgorica
Banking
Montenegro
119,729
27,714
99.87
99.87
99.87
99.87
NLB Banka a.d., Banja Luka
Banking
Bosnia and
Herzegovina
130,314
29,510
99.85
99.85
99.85
99.85
NLB Banka sh.a., Prishtina
Banking
Kosovo
173,827
37,028
82.38
82.38
82.38
82.38
NLB Banka d.d., Sarajevo
Banking
Bosnia and
Herzegovina
107,662
14,384
97.34
97.35
97.34
97.35
NLB Komercijalna banka a.d. Beograd
Banking
Serbia
865,365
140,482
100
100
100
100
NLB Skladi d.o.o., Ljubljana
Finance
Slovenia
22,971
12,113
100
100
100
100
NLB Fondovi a.d., Beograd
Finance
Serbia
401
(355)
100
100
-
-
NLB Fondovi a.d. Skopje
Finance
North Macedonia
1,130
17
100
100
-
-
NLB Lease&Go, leasing, d.o.o., Ljubljana
Finance
Slovenia
29,551
3,251
100
100
100
100
NLB Lease&Go, d.o.o. Skopje(i)
Finance
North Macedonia
1,497
(677)
100
100
-
-
NLB Lease&Go leasing d.o.o. Beograd(ii)
Finance
Serbia
13,204
226
99.80
99.80
-
-
NLB Car&Go, upravljanje spletnih platform, d.o.o.
Web portal
Slovenia
(26)
(33)
100
100
-
-
Summit Leasing Slovenija d.o.o., Ljubljana(iii)
Finance
Slovenia
102,906
(1,009)
100
100
-
-
Mobil Leasing d.o.o., Zagreb
Finance
Croatia
24,659
(2)
100
100
-
-
NLB MUZA Zavod za upravljanje
kulturne dediščine, Ljubljana
Cultural heritage
management
Slovenia
3,613
113
100
100
100
100
NLB DigIT d.o.o., Beograd
IT services
Serbia
2,823
243
100
100
100
100
NLB Real Estate d.o.o., Podgorica
Real estate
Montenegro
2,642
486
100
100
100
100
NLB Real Estate d.o.o., Beograd
Real estate
Serbia
1,085
(964)
100
100
100
100
NLB Real Estate d.o.o., Ljubljana
Real estate
Slovenia
22,675
113
100
100
100
100
Non-core members
NLB Crna Gora d.o.o., Podgorica
Finance
Montenegro
4,011
368
100
100
100
100
NLB InterFinanz AG, Zürich in Liquidation
Finance
Switzerland
10,483
895
100
100
100
100
NLB InterFinanz d.o.o., Beograd - u likvidaciji
Finance
Serbia
3
2
100
100
-
-
LHB AG, Frankfurt
Finance
Germany
524
(160)
100
100
100
100
PRO-REM d.o.o., Ljubljana - v likvidaciji (iv)
Real estate
Slovenia
19,984
175
100
100
-
-
OL Nekretnine d.o.o., Zagreb - u likvidaciji
Real estate
Croatia
567
(73)
100
100
-
-
NLB Srbija d.o.o., Beograd
Real estate
Serbia
18,768
444
100
100
100
100
SLS HOLDCO, holdinška družba, d.o.o. Ljubljana
Finance
Slovenia
104,150
(2,113)
100
100
100
100
(i)51% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana and 49% ownership of NLB Banka a.d., Skopje.
(ii)50.89% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana and 48.91% NLB Komercijalna banka a.d. Beograd.
(iii)100% ownership of SLS HOLDCO, holdinška družba, d.o.o. Ljubljana.
(iv)100% ownership of NLB Real Estate d.o.o., Ljubljana.

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Financial
Report
Data of subsidiaries as included in the consolidated financial statements of NLB Group as at 31 December 2023:
Nature of
Business
Country of
Incorporation
Equity as at
31 Dec 2023
(in EUR
thousands)
Profit/(loss)
for 2023
(in EUR
thousands)
NLB Group
NLB
Shareholding
(in %)
Voting rights
(in %)
Shareholding
(in %)
Voting rights
(in %)
Core members
NLB Banka a.d., Skopje
Banking
North Macedonia
279,987
44,517
86.97
86.97
86.97
86.97
NLB Banka a.d., Podgorica
Banking
Montenegro
120,390
26,658
99.87
99.87
99.87
99.87
NLB Banka a.d., Banja Luka
Banking
Bosnia and
Herzegovina
107,270
24,269
99.85
99.85
99.85
99.85
NLB Banka sh.a., Prishtina
Banking
Kosovo
149,669
35,968
82.38
82.38
82.38
82.38
NLB Banka d.d., Sarajevo
Banking
Bosnia and
Herzegovina
95,980
12,819
97.34
97.35
97.34
97.35
NLB Komercijalna banka a.d. Beograd
Banking
Serbia
827,575
132,313
100
100
100
100
KomBank Invest a.d. Beograd
Finance
Serbia
769
(1,201)
100
100
-
-
NLB Skladi d.o.o., Ljubljana
Finance
Slovenia
13,707
9,498
100
100
100
100
NLB Lease&Go, leasing, d.o.o., Ljubljana
Finance
Slovenia
21,251
1,664
100
100
100
100
NLB Lease&Go, d.o.o. Skopje(ii)
Finance
North Macedonia
1,493
(605)
100
100
-
-
NLB Lease&Go leasing d.o.o. Beograd(iii)
Finance
Serbia
7,115
(736)
99.64
99.64
-
-
NLB Zavod za upravljanje
kulturne dediščine, Ljubljana
Cultural
heritage
management
Slovenia
3,500
86
100
100
100
100
NLB DigIT d.o.o., Beograd
IT services
Serbia
2,569
204
100
100
100
100
Non-core members
NLB Leasing d.o.o., Ljubljana - v likvidaciji(i)
Finance
Slovenia
2,021
1,487
100
100
-
-
NLB Crna Gora d.o.o., Podgorica
Finance
Montenegro
3,643
348
100
100
100
100
NLB InterFinanz AG, Zürich in Liquidation
Finance
Switzerland
9,762
(2,321)
100
100
100
100
NLB InterFinanz d.o.o., Beograd - u likvidaciji
Finance
Serbia
3
1
100
100
-
-
LHB AG, Frankfurt
Finance
Germany
684
(402)
100
100
100
100
REAM d.o.o., Podgorica
Real estate
Montenegro
2,156
389
100
100
100
100
REAM d.o.o., Beograd - Novi Beograd
Real estate
Serbia
2,042
(576)
100
100
100
100
S-REAM d.o.o., Ljubljana
Real estate
Slovenia
22,452
(384)
100
100
100
100
PRO-REM d.o.o., Ljubljana - v likvidaciji
Real estate
Slovenia
20,447
635
100
100
-
-
OL Nekretnine d.o.o., Zagreb - u likvidaciji
Real estate
Croatia
1,153
(314)
100
100
-
-
NLB Srbija d.o.o., Beograd
Real estate
Serbia
18,252
(603)
100
100
100
100
Privatinvest d.o.o., Ljubljana
Real estate
Slovenia
110
(11)
100
100
100
100
(i)100% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana.
(ii)51% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana and 49% ownership of NLB Banka a.d., Skopje.
(iii)50.73% ownership of NLB Lease&Go, leasing, d.o.o., Ljubljana and 48.91% NLB Komercijalna banka a.d. Beograd.
Changes in ownership interest in the subsidiaries of NLB Group in 2024 and 2023 are presented in note 3.

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Data of subsidiaries with significant non-controlling interests, before intercompany eliminations:
in EUR thousands
NLB Banka,
Skopje
NLB Banka,
Prishtina
2024
2023
2024
2023
Non-controlling interest in equity (in %)
13.03
13.03
17.62
17.62
Non-controlling interest‘s voting rights (in %)
13.03
13.03
17.62
17.62
Income statement and statement of comprehensive income
Revenues
125,449
111,640
78,654
68,468
Profit/(loss) for the year
67,838
44,517
37,028
35,968
Attributable to non-controlling interest
8,839
5,801
6,525
6,339
Other comprehensive income
1,768
3,363
(154)
(141)
Total comprehensive income
69,606
47,880
36,874
35,827
Attributable to non-controlling interest
9,070
6,239
6,498
6,314
Paid dividends to non-controlling interest
4,765
4,391
3,997
-
Statement of financial position
Current assets
991,343
867,333
713,084
716,000
Non-current assets
1,167,424
1,034,922
713,778
513,757
Current liabilities
1,568,345
1,393,480
963,407
856,340
Non-current liabilities
267,478
228,788
289,628
223,748
Equity
322,944
279,987
173,827
149,669
Attributable to non-controlling interest
42,080
36,482
30,634
26,376

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b) Acquisition of Generali Investment, Skopje
In May 2024, NLB Skladi d.o.o., Ljubljana become
an owner of 100% of financial company Generali
Investments a.d. Skopje. Generali Investments a.d.
Skopje is the third largest asset manager on the
Macedonian market with an 18% market share. As at 30
June 2024, the company managed approximately EUR
53 million of client assets in different investment funds
and portfolios.
In August 2024, Generali Investments a.d. Skopje was
renamed to NLB Fondovi a.d. Skopje.
The purchase price for the company was EUR 2,515
thousand and was fully paid in cash. There are no
contingent consideration arrangements. At the
acquisition date, cash in acquired entities amounted to
EUR 173 thousand. The net outflow of cash amounted to
EUR 2,342 thousand (included in the statement of cash
flows within payments from investing activities).
The assets and liabilities recognised in the NLB Group
financial statements as a result of the acquisition are
as follows:
in EUR thousands
Cash, cash balances at central banks and other demand deposits at banks
173
Non-trading financial assets mandatorily at fair value through profit or loss
857
Financial assets measured at amortised cost
- other financial assets
2
Tangible assets
Property and equipment
4
Intangible assets
34
Current income tax assets
15
Other assets
83
Total assets
1,168
Financial liabilities measured at amortised cost
- other financial liabilities
39
Other liabilities
17
Total liabilities
56
Net identifiable assets acquired
1,112
Consideration given
2,515
Goodwill
1,403
The acquisition of NLB Fondovi a.d. Skopje, resulted in a
goodwill in the amount of EUR 1,403 thousand, which is
recognised in the statement of financial position under
the line, ‘Intangible assets.’ The main factors that make
up the goodwill are the synergies within the NLB Group,
the existing distribution channels and the presence on
the strategically important market of the NLB Group.
Acquisition-related costs were immaterial.

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c) Acquisition of SLS HOLDCO d. o. o. , Ljubljana
On 11 September 2024, NLB completed the acquisition
of a 100% stake in the company SLS HOLDCO d.o.o.,
Ljubljana, the parent company of Summit Leasing
Slovenija d.o.o., Ljubljana, and its subsidiary Mobil
Leasing d.o.o., Zagreb.
The purchase price for the company was EUR 127,216
thousand and was fully paid in cash. There are no
contingent consideration arrangements. At the
acquisition date, cash in acquired entities amounted
to EUR 25,632 thousand. The net outflow of cash
amounted to EUR 101,584 thousand (included in
the statement of cash flows within payments from
investing activities).
The assets and liabilities recognised in the NLB Group
financial statements as a result of the acquisition are
as follows:
in EUR thousands
Cash, cash balances at central banks and other demand deposits at banks
25,632
Financial assets measured at amortised cost
- loans and advances to banks
69
- loans and advances to customers
874,816
- other financial assets
3,877
Tangible assets
Property and equipment
23,596
Intangible assets
23,515
Current income tax assets
522
Deferred income tax assets
3,726
Other assets
8,406
Total assets
964,159
Financial liabilities measured at amortised cost
- borrowings from banks and central banks
809,939
- other financial liabilities
16,036
Provisions
2,002
Deferred income tax liabilities
3,155
Other liabilities
8,949
Total liabilities
840,081
Net identifiable assets acquired
124,078
Consideration given
127,216
Goodwill
3,138
The acquisition of SLS HOLDCO d.o.o., Ljubljana,
resulted in a goodwill in the amount of EUR 3,138
thousand, which is recognised in the statement of
financial position under the line, ‘Intangible assets.
Goodwill consists of the fair value of expected synergies
and other benefits from combining the acquirer and
acquiree’s net assets and businesses. The goodwill
will not be deductible for income tax purposes. In
2024, acquisition-related costs amounted to EUR
1,900 thousand and are included within administrative
expenses (2023: EUR 1,100 thousand).
As a result of the acquisition, NLB Group’s off-balance
sheet liabilities increased by EUR 1,868 thousand.

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The valuation techniques used for measuring the fair
value of material assets and liabilities acquired were
as follows:
Assets acquired
Valuation technique
Performing loans
For the performing loans portfolio, fair value was determined by using the discounted cash
flow method, whereby future cash flows were discounted to their present value at current
market interest rates. Contractual cash flows were adjusted for historical prepayment
rate. In the absence of publicly available market interest rate for financial leases, market
interest rates were estimated based on the weighted average interest rate of the financial
leases issued in the last three months by Summit Leasing Slovenija and Mobil Leasing.
Non-performing loans
The market value of non-performing loans was determined on the market value of the
underlying collateral. Financial leases are secured by the assets under lease. The market value is
recovered as profit for sale as underlying assets on average reduced for the appropriate haircut.
Consumer loans are secured by insurance, and 100% of the exposure can be recovered.
Distribution agreements
For valuation of distribution agreements multi-period excess earnings method (MEEM) under the
income approach was applied. This method is based on the principle that the value of intangible
assets is equal to the present value of the excess earnings attributable only to the subject intangible
asset after deducting contributory assets charges like fixed assets and assembled workforce.
The fair value of acquired loans and advances to
customers is EUR 874,816 thousand, of which EUR
848,638 thousand relates to performing portfolio and
EUR 26,178 thousand to non-performing portfolio. The
latter was recognised as purchased or originated
credit impaired financial assets (POCI). The gross
contractual amount for performing loans and
advances to customers is EUR 857,488 thousand, and
for this exposure 12-month expected credit losses in
the amount of EUR 1,596 thousand were recognised
through the income statement. The gross contractual
amount for non-performing loans and advances to
customers is EUR 38,952 thousand, and it is expected
that approximately EUR 6 million of the contractual
cash flows will not be collected.
Since the transaction was completed on 11 September
2024, a loss of EUR 1,821 thousand was included in
the income statement for 2024, 12-month expected
credit losses for financial assets in Group 1 of EUR
1,661 thousand, and related deferred taxes of EUR
358 thousand were recognized. If the acquisition had
occurred on 1 January 2024, management estimates
that consolidated revenues would have been
approximately EUR 53 million, higher. Consolidated
profit for the period would not have changed materially.
NLB obtained all the necessary information for
measuring fair values, therefore no amounts were
measured and recognised on a provisional basis.

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d) Disposal of subsidiary Optima Leasing d. o. o. , Zagreb – u likvidaciji
In September 2023, NLB Group sold its subsidiary
Optima Leasing d.o.o., Zagreb – u likvidaciji.
The assets and liabilities derecognised from NLB Group
financial statements as a result of disposal are
as follows:
in EUR thousands
Cash, cash balances at central banks and other demand deposits at banks
713
Financial assets measured at amortised cost
- other financial assets
4
Other assets
104
Total assets
821
Provisions
30
Other liabilities
22
Total liabilities
52
Net assets of subsidiary
769
Total disposal consideration
470
Cash and cash equivalents in subsidiary sold
(713)
Cash outflow on disposal
(243)
Consideration for disposal of the subsidiary
470
Carrying amount of net assets disposed of
769
Loss from disposal of subsidiary in consolidated financial statements
(299)
At sale of subsidiary Optima Leasing d.o.o., Zagreb – u
likvidaciji, NLB Group realised a loss in the amount of
EUR 299 thousand.
e) Disposal of subsidiary Tara Hotel d. o. o. , Budva
In May 2023, NLB Group sold its subsidiary
Tara Hotel d.o.o., Budva.
The assets and liabilities derecognised from NLB Group
financial statements as a result of disposal are as follows:
in EUR thousands
Cash, cash balances at central banks and other demand deposits at banks
2
Financial assets measured at amortised cost
- other financial assets
19
Other assets
13,938
Total assets
13,959
Financial liabilities measured at amortised cost
- borrowings from banks and central banks
178
- other financial liabilities
20
Deferred income tax liabilities
193
Other liabilities
82
Total liabilities
473
Net assets of subsidiary
13,486
Total disposal consideration
13,019
Cash inflow on disposal
13,019
Consideration for disposal of the subsidiary
13,019
Carrying amount of net assets disposed of
13,486
Loss from disposal of subsidiary in consolidated financial statements
(467)
At sale of Tara Hotel d.o.o., Budva NLB Group realised a
loss in the amount of EUR 467 thousand and NLB in the
amount of EUR 105 thousand.

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f) Merger of N Banka d. d. , Ljubljana
On 1 September 2023, with entry of the merger in the
Register of Companies, the process of the legal merger
of N Banka d.d. with NLB d.d. was closed. As at the
date of the merger, N Banka ceased to exist as an
independent legal entity, and NLB, as a universal legal
successor, took over all of its rights and obligations.
The merger was accounted for using merger
accounting principles, due to the fact that such a
merger is considered to be a business combination
involving entities under common control. NLB has
applied for the merger the following accounting policy:
- As at 1 September 2023, all assets, liabilities, and off-
balance sheet items of N Banka were recognised as
they were reported for the purposes of NLB Group
financial statements as at 31 August 2023 in relevant
line items of assets, liabilities, and off-balance sheet
items of merged bank; and
- As at 1 September 2023, all income and expenses of N
Banka were recognised as they were reported for the
purposes of NLB Group financial statements as at 31
August 2023 directly into retained earnings. Therefore,
only income and expenses from 1 September 2023
onwards were recognised in the income statement of
the merged bank.
As at the day of the merger, NLB also took over control
of the company Privatinvest d.o.o., which was 100%
owned by N Banka and whose assets consist only
of repossessed real estate. N Banka also had an
investment in Bankart d.o.o., Ljubljana, which was on
the day of the merger transferred to NLB.
Items of the statement of financial position at the day of
the merger were as follows:
in EUR thousands
Cash, cash balances at central banks and other demand deposits at banks
118,158
Financial assets measured at fair value through other comprehensive income
49,477
Financial assets measured at amortised cost
- debt securities
13,044
- loans and advances to banks
3
- loans and advances to customers
765,552
- other financial assets
2,664
Investments in associates and joint ventures
134
Tangible assets
Property and equipment
4,884
- own property and equipment
4,546
- right-of-use assets
338
Investment property
784
Intangible assets
685
Deferred income tax assets
2,426
Other assets
68
Total assets
957,879
Financial liabilities held for trading
189
Financial liabilities measured at amortised cost
- deposits from banks and central banks
131,070
- borrowings from banks and central banks
40,084
- due to customers
574,747
- other financial liabilities
2,193
Provisions
7,881
Current income tax liabilities
1,026
Other liabilities
943
Total liabilities
758,133
Equity
199,746
Total liabilities and equity
957,879

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As a result of the merger, NLB’s off-balance sheet liabilities increased by EUR 200,933 thousand:
in EUR thousands
Guarantees
108,673
Commitments to extend credit
92,260
Total
200,933
Items of the N Banka income statement for the period
1 January – 31 August 2023 as they were reported for the
purposes of NLB Group financial statements:
in EUR thousands
Net interest income
27,822
Net fee and commission income
6,016
Profit for the year
13,389
g) Analysis by type of investment in associates, and joint ventures
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Carrying amount of the NLB Group‘s interest
Other financial organisations
14,661
12,519
4,293
4,293
Enterprises
-
-
530
530
Total
14,661
12,519
4,823
4,823
NLB Group’s associates
in %
2024
2023
Nature of
Business
Country of
Incorporation
Shareholding
Voting rights
Shareholding
Voting rights
Bankart d.o.o., Ljubljana
Card
processing
Slovenia
46.03
46.03
46.03
46.03
ARG - Nepremičnine d.o.o.,
Horjul
Real estate
Slovenia
75.00
75.00
75.00
75.00
By contractual agreement between the shareholders,
NLB does not control ARG-Nepremičnine, Horjul, but
does have a significant influence. Therefore, the entity is
accounted as an associate.

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The carrying amount of interests in associates included in the consolidated financial statements of NLB Group:
in EUR thousands
2024
2023
Carrying amount of the NLB Group‘s interest
14,661
12,519
NLB Group‘s share of:
- Profit for the year
2,990
1,072
- Other comprehensive income
18
45
- Total comprehensive income
3,008
1,117
In previous years, NLB Group’s interest in an associate
was reduced to zero. Consequently, NLB Group did
not recognise a share of profit in the amount of
EUR 37 thousand in 2024 (2023: EUR 347 thousand).
The cumulative unrecognised share of losses of an
associate as at 31 December 2024 amounted to EUR
1,705 thousand (31 December 2023: EUR 1,742 thousand).
NLB Group’s joint ventures
in %
2024
2023
Nature of
Business
Country of
Incorporation
Voting rights
Voting rights
Prvi Faktor Group, Ljubljana
Finance
Slovenia
50
50
In previous years, NLB Group’s interest in a joint venture
was reduced to zero. Consequently, NLB Group did
not recognise a share of profit in the amount of EUR
485 thousand in 2024 (2023: EUR 751 thousand). The
cumulative unrecognised share of losses of a joint
venture as at 31 December 2024 amounted to EUR 13,160
thousand (31 December 2023: EUR 13,645 thousand).
h) Movements of investments in associates
in EUR thousands
NLB Group
2024
2023
Balance as at 1 January
12,519
11,677
Share of result before tax
3,408
1,394
Share of tax
(418)
(322)
Net gains/(losses) recognised in other comprehensive income
18
45
Dividends received
(866)
(275)
Balance as at 31 December
14,661
12,519

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5. 13. Other assets
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Assets, received as collateral (note 6.1.l)
20,598
27,637
1,468
3,129
Deferred expenses
17,131
12,313
10,383
6,915
Inventories
11,938
5,825
4,807
2,943
Claim for taxes and other dues
5,180
1,599
586
531
Prepayments
1,972
1,780
581
389
Total
56,819
49,154
17,825
13,907
Assets, received as collateral on NLB Group in the
amount of EUR 18,976 thousand (31 December 2023:
EUR 27,122 thousand), and on NLB in the amount of
EUR 1,468 thousand (31 December 2023: EUR 3,129
thousand) consist of real estate (note 6.1.l).
5. 14. Movements in allowance for the impairment of financial assets
a) Movements in allowance for the impairment of loans and receivables measured at amortised cost
in EUR thousands
NLB Group
Balance as at
1 Jan 2024
Effects of
translation
of foreign
operations to
presentation
currency
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2024
Repayments
of written-off
receivables
Notes
4.14.
4.14.
5.6.b, c, d)
4.14.
12-month expected credit losses
Loans and advances to banks
213
2
-
(108)
-
(1)
(2)
104
-
Loans and advances to individuals
39,668
31
37,441
(20,732)
(120)
(11,206)
1
45,083
-
Loans and advances to other customers
51,087
61
4,088
6,013
(2)
(17,737)
(6)
43,504
-
Other financial assets
624
(1)
(56)
135
(55)
(85)
10
572
-
Lifetime ECL not credit-impaired
Loans and advances to individuals
25,051
4
(30,636)
35,412
(26)
5,165
(11)
34,959
-
Loans and advances to other customers
19,778
17
(6,647)
10,534
(31)
5,283
(6)
28,928
-
Other financial assets
40
1
(22)
56
(17)
(2)
(2)
54
-
Lifetime ECL credit-impaired
Loans and advances to banks
86
-
-
2
-
28
20
136
-
Loans and advances to individuals
83,780
32
(6,805)
36,596
(28,683)
7,923
4,399
97,242
13,447
Loans and advances to other customers
109,263
(142)
2,559
(2,604)
(21,203)
729
19,443
108,045
10,498
Other financial assets
10,141
10
78
305
(5,527)
129
3,231
8,367
919
Of which: Purchased or
originated credit-impaired
Loans and advances to individuals
1,024
(2)
-
1,443
(506)
(197)
1,147
2,909
493
Loans and advances to other customers
5,985
-
-
(12,719)
(607)
7
11,700
4,366
927
Other financial assets
1,231
4
-
(831)
(1,165)
-
777
16
-
Column Increases/(Decreases) for year 2024 also
includes 12-month expected credit losses recognised at
the acquisition of SLS HOLDCO in the amount of EUR
472 thousand for Loans and advances to individuals,
in the amount of EUR 1,124 thousand for Loans and
advances to other customers, and in the amount of EUR
65 thousand for Other financial assets (notes 4.14. and
5.12.c).

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in EUR thousands
NLB Group
Balance as at
1 Jan 2023
Effects of
translation
of foreign
operations to
presentation
currency
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Foreign
exchange
differences
and other
movements
Disposal of
subsidiary
Balance as at
31 Dec 2023
Repayments
of written-off
receivables
Notes
4.14.
4.14.
5.12.d, e)
5.6.b, c, d)
4.14.
12-month expected credit losses
Loans and advances to banks
161
-
-
49
-
-
3
-
213
-
Loans and advances to individuals
31,385
(13)
31,614
(22,681)
(221)
(419)
3
-
39,668
-
Loans and advances to other customers
59,840
(17)
(1,229)
5,634
-
(13,134)
(7)
-
51,087
-
Other financial assets
1,246
-
(17)
(201)
(42)
(117)
(225)
(20)
624
-
Lifetime ECL not credit-impaired
Loans and advances to individuals
14,582
(5)
(28,704)
34,051
(18)
5,121
24
-
25,051
-
Loans and advances to other customers
31,230
1
(1,988)
(9,837)
(8)
156
224
-
19,778
-
Other financial assets
38
-
(36)
82
(17)
(26)
(1)
-
40
-
Lifetime ECL credit-impaired
Loans and advances to banks
108
-
-
(26)
-
-
4
-
86
-
Loans and advances to individuals
75,807
(5)
(2,910)
29,543
(23,445)
720
4,070
-
83,780
8,703
Loans and advances to other customers
111,154
645
3,217
(8,614)
(19,399)
(364)
22,624
-
109,263
15,237
Other financial assets
7,750
-
53
3,374
(764)
(18)
17
(271)
10,141
261
Of which: Purchased or
originated credit-impaired
Loans and advances to individuals
(499)
-
-
(414)
(456)
-
2,393
-
1,024
1,377
Loans and advances to other customers
(3,134)
(6)
-
(4,817)
(1,026)
-
14,968
-
5,985
2,012
Other financial assets
185
(2)
-
185
-
-
863
-
1,231
-
in EUR thousands
NLB
Balance as at
1 Jan 2024
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2024
Repayments
of written-off
receivables
Notes
4.14.
4.14.
5.6.b, c, d)
4.14.
12-month expected credit losses
Loans and advances to banks
164
-
6
-
-
-
170
-
Loans and advances to individuals
8,073
19,915
(15,710)
(115)
(2,733)
-
9,430
-
Loans and advances to other customers
13,482
(569)
772
(2)
(1,423)
(6)
12,254
-
Other financial assets
98
8
32
(8)
(16)
1
115
-
Lifetime ECL not credit-impaired
Loans and advances to individuals
11,489
(13,058)
16,507
(22)
3,393
(12)
18,297
-
Loans and advances to other customers
2,553
1,733
6,912
(31)
2,871
-
14,038
-
Other financial assets
2
14
(12)
(1)
(1)
-
2
-
Lifetime ECL credit-impaired
Loans and advances to banks
86
-
2
-
28
20
136
-
Loans and advances to individuals
45,663
(6,857)
18,562
(10,029)
6,720
1,193
55,252
3,204
Loans and advances to other customers
38,308
(1,164)
9,947
(4,040)
213
5,178
48,442
1,479
Other financial assets
1,514
(22)
(926)
(332)
(7)
869
1,096
413
Of which: Purchased or
originated credit-impaired
Loans and advances to individuals
1,755
-
(123)
(501)
(196)
184
1,119
154
Loans and advances to other customers
5,678
-
(2,757)
(524)
-
4,075
6,472
200
Other financial assets
2
-
(842)
-
-
858
18
-

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in EUR thousands
NLB
Balance as at
1 Jan 2023
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Foreign
exchange
differences
and other
movements
Merger of
subsidiary
Balance as at
31 Dec 2023
Repayments
of written-off
receivables
Notes
4.14.
4.14.
5.12.f)
5.6.b, c, d)
4.14.
12-month expected credit losses
Loans and advances to banks
216
-
(54)
-
2
-
-
164
-
Loans and advances to individuals
6,161
15,744
(14,192)
(189)
(603)
1
1,151
8,073
-
Loans and advances to other customers
14,880
(1,199)
(2,541)
-
(3,622)
25
5,939
13,482
-
Other financial assets
203
(193)
(92)
(7)
(34)
(1)
222
98
-
Lifetime ECL not credit-impaired
Loans and advances to individuals
7,385
(14,921)
15,949
(10)
2,127
24
935
11,489
-
Loans and advances to other customers
800
1,344
(2,647)
(1)
(444)
-
3,501
2,553
-
Other financial assets
2
(6)
7
(1)
-
-
-
2
-
Lifetime ECL credit-impaired
Loans and advances to banks
-
-
(28)
-
-
4
110
86
-
Loans and advances to individuals
34,286
(823)
15,358
(5,797)
17
819
1,803
45,663
2,967
Loans and advances to other customers
29,900
(145)
11,822
(7,292)
(29)
1,677
2,375
38,308
6,793
Other financial assets
808
199
785
(296)
-
(8)
26
1,514
77
Of which: Purchased or
originated credit-impaired
Loans and advances to individuals
-
-
1,672
(20)
-
88
15
1,755
-
Loans and advances to other customers
638
-
4,661
(247)
-
626
-
5,678
-
Other financial assets
1
-
-
-
-
1
-
2
-
Other movements relate mainly to expenses due to initial
recognition of non-performing exposure at fair value.
The contractual amount outstanding on financial
assets that were written off during the year ending
31 December 2024 and that are still subject to
enforcement activity for NLB Group amounted to
EUR 39,408 thousand (31 December 2023: EUR 43,080
thousand), and for NLB amounted to EUR 11,576
thousand (31 December 2023: EUR 15,715 thousand), of
which EUR 2,590 thousand in NLB Group (31 December
2023: EUR 2,962 thousand) and EUR 1,122 thousand in
NLB (31 December 2023: EUR 1,904 thousand) represent
interest receivables that have not been recognised in
the income statement prior to the write-off.

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b) Movements in allowance for the impairment of debt securities
in EUR thousands
NLB Group
Balance as at
1 Jan 2024
Effects of
translation
of foreign
operations to
presentation
currency
Transfers
Increases/
(Decreases)
Changes in models/
risk parameters
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2024
Notes
4.14.
4.14.
5.4.a), 5.6.a)
12-month expected credit losses
Debt securities measured
at amortised cost
4,946
2
(4)
2,047
(92)
14
6,913
Debt securities measured at fair value
through other comprehensive income
6,475
-
-
(1,273)
(243)
-
4,959
Lifetime ECL not credit-impaired
Debt securities measured
at amortised cost
576
2
4
153
(185)
4
554
Debt securities measured at fair value
through other comprehensive income
56
-
-
(11)
(8)
(1)
36
Lifetime ECL credit-impaired
Debt securities measured at fair value
through other comprehensive income
798
-
-
-
-
-
798
in EUR thousands
NLB Group
Balance as at
1 Jan 2023
Effects of
translation
of foreign
operations to
presentation
currency
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2023
Notes
4.14.
4.14.
5.4.a), 5.6.a)
12-month expected credit losses
Debt securities measured
at amortised cost
3,519
2
(52)
1,478
-
9
(10)
4,946
Debt securities measured at fair value
through other comprehensive income
9,029
4
-
(2,470)
-
(87)
(1)
6,475
Lifetime ECL not credit-impaired
Debt securities measured
at amortised cost
265
(1)
52
(253)
-
515
(2)
576
Debt securities measured at fair value
through other comprehensive income
70
-
-
(13)
-
(1)
-
56
Lifetime ECL credit-impaired
Debt securities measured at fair value
through other comprehensive income
6,777
-
-
(4,483)
(1,537)
-
41
798
Release of lifetime ECL credit-impaired debt securities
measured at fair value through other comprehensive
income relates to impairment of Russian sovereign
debt, which was sold in February 2023.

NLB Group
Annual Report 2024
454
Overview
MB Statement
SB Statement
Key Highlights
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Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
Balance as at
1 Jan 2024
Transfers
Increases/
(Decreases)
Changes in models/
risk parameters
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2024
Notes
4.14.
4.14.
5.4.a), 5.6.a)
12-month expected credit losses
Debt securities measured
at amortised cost
2,624
(4)
858
(34)
6
3,450
Debt securities measured at fair value
through other comprehensive income
1,650
-
206
(8)
1
1,849
Lifetime ECL not credit-impaired
Debt securities measured
at amortised cost
173
4
(101)
-
4
80
Lifetime ECL credit-impaired
Debt securities measured at fair value
through other comprehensive income
798
-
-
-
-
798
in EUR thousands
NLB
Balance as at
1 Jan 2023
Transfers
Increases/
(Decreases)
Write-offs
Changes in
models/risk
parameters
Merger of
subsidiary
Foreign
exchange
differences
and other
movements
Balance as at
31 Dec 2023
Notes
4.14.
4.14.
5.12.f)
5.4.a), 5.6.a)
12-month expected credit losses
Debt securities measured
at amortised cost
1,990
(52)
585
-
(36)
140
(3)
2,624
Debt securities measured at fair value
through other comprehensive income
2,022
-
(554)
-
(21)
204
(1)
1,650
Lifetime ECL not credit-impaired
Debt securities measured
at amortised cost
-
52
123
-
-
(2)
173
Lifetime ECL credit-impaired
Debt securities measured at fair value
through other comprehensive income
6,777
-
(4,483)
(1,537)
-
41
798
Release of lifetime ECL credit-impaired debt securities
measured at fair value through other comprehensive
income relates to impairment of Russian sovereign
debt, which was sold in February 2023.

NLB Group
Annual Report 2024
455
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
c) Explanation of how significant changes in the gross carrying amount of financial instruments contributed to changes in the loss allowance
Movement of gross carrying amount of loans to banks
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
12-month
expected
credit losses
Lifetime
ECL credit-
impaired
12-month
expected
credit losses
Lifetime
ECL credit-
impaired
12-month
expected
credit losses
Lifetime
ECL credit-
impaired
12-month
expected
credit losses
Lifetime
ECL credit-
impaired
Balance as at 1 January
547,826
113
223,126
108
149,148
113
350,841
-
Effects of translation of foreign operations
to presentation currency
1,003
-
(105)
-
-
-
-
-
Acquisition of subsidiaries (note 5.12.c)
69
-
-
-
-
-
-
-
Increases/(Decreases)
(91,570)
23
322,034
5
44,176
23
(202,175)
-
Exchange differences on monetary assets
1,697
-
2,771
-
18
-
482
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
-
-
-
113
Balance as at 31 December
459,025
136
547,826
113
193,342
136
149,148
113

NLB Group
Annual Report 2024
456
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Movement of gross carrying amount of loans and advances to individuals
in EUR thousands
NLB Group
NLB
Individuals
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2024
6,854,725
248,424
132,165
7,235,314
3,379,513
152,261
77,054
3,608,828
Effects of translation of foreign operations
to presentation currency
5,063
81
62
5,206
-
-
-
-
Acquisition of subsidiaries (note 5.12.c)
549,397
-
25,902
575,299
-
-
-
-
Transfers
(220,285)
185,613
34,672
-
(112,291)
101,857
10,434
-
Increases/(Decreases)
992,732
(24,689)
(15,525)
952,518
366,370
(3,516)
4,536
367,390
Write-offs
(120)
(26)
(28,683)
(28,829)
(115)
(22)
(10,029)
(10,166)
Exchange differences on monetary assets
293
(21)
(868)
(596)
-
-
(863)
(863)
Modification losses (note 4.12.)
(3,793)
(106)
(24)
(3,923)
-
-
-
-
Balance as at 31 December 2024
8,178,012
409,276
147,701
8,734,989
3,633,477
250,580
81,132
3,965,189
in EUR thousands
NLB Group
NLB
Individuals
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2023
6,422,877
190,121
130,446
6,743,444
2,922,907
101,744
59,680
3,084,331
Effects of translation of foreign operations
to presentation currency
(1,606)
(24)
(12)
(1,642)
-
-
-
-
Transfers
(103,434)
70,870
32,564
-
(48,707)
34,682
14,025
-
Increases/(Decreases)
551,995
(12,564)
(7,469)
531,962
204,972
5,439
(346)
210,065
Write-offs
(221)
(18)
(23,445)
(23,684)
(189)
(10)
(5,797)
(5,996)
Exchange differences on monetary assets
783
124
186
1,093
1,914
127
189
2,230
Modification losses (note 4.12.)
(15,669)
(85)
(105)
(15,859)
-
-
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
298,616
10,279
9,303
318,198
Balance as at 31 December 2023
6,854,725
248,424
132,165
7,235,314
3,379,513
152,261
77,054
3,608,828
In year 2024, the loss allowance for loans and advances
to individuals increased by EUR 28,785 thousand at the
NLB Group level, while at the NLB level it increased by
EUR 17,754 thousand. At the NLB Group level, the gross
carrying amount increased by EUR 1,499,675 thousand,
mainly due to increased exposure and the acquisition
of subsidiaries, while at the NLB level it increased by
EUR 356,361 thousand.
In year 2023, the loss allowance for loans and advances
to individuals increased by EUR 26,725 thousand at the
NLB Group level, while at the NLB level it increased by
EUR 17,393 thousand. The reasons for increases are
also changed risk parameters, which increased the loss
allowance by EUR 5,422 thousand at the NLB Group
level, and by EUR 1,541 thousand at NLB level.
At the NLB level, it also increased due to the merger
of N Banka by EUR 3,889 thousand. At the NLB Group
level, the gross carrying amount increased by EUR
491,870 thousand, mainly due to increased exposure,
while at the NLB level it increased by EUR 524,497
thousand due to increased exposure and the merger of
N Banka (EUR 318,198 thousand).

NLB Group
Annual Report 2024
457
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Movement of gross carrying amount of loans and advances to other customers
in EUR thousands
NLB Group
NLB
Other customers
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2024
6,207,653
451,154
169,107
6,827,914
3,434,833
162,976
61,214
3,659,023
Effects of translation of foreign operations
to presentation currency
6,100
525
(217)
6,408
-
-
-
-
Acquisition of subsidiaries (note 5.12.c)
287,202
-
12,315
299,517
-
-
-
-
Transfers
(245,302)
198,802
46,500
-
(162,091)
147,783
14,308
-
Increases/(Decreases)
922,294
(27,899)
(20,310)
874,085
1,180,061
14,321
(4,840)
1,189,542
Write-offs
(2)
(31)
(21,203)
(21,236)
(2)
(31)
(4,040)
(4,073)
Exchange differences on monetary assets
(1,330)
(151)
1,571
90
(139)
-
1,519
1,380
Modification losses (note 4.12.)
(320)
(37)
-
(357)
-
-
-
-
Balance as at 31 December 2024
7,176,295
622,363
187,763
7,986,421
4,452,662
325,049
68,161
4,845,872
in EUR thousands
NLB Group
NLB
Other customers
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2023
6,028,285
423,671
201,584
6,653,540
2,960,455
51,906
51,133
3,063,494
Effects of translation of foreign operations
to presentation currency
(1,887)
(128)
960
(1,055)
-
-
-
-
Transfers
(94,306)
80,889
13,417
-
(41,456)
36,860
4,596
-
Increases/(Decreases)
277,557
(53,135)
(27,449)
196,973
115,612
26,546
(2,303)
139,855
Write-offs
-
(8)
(19,399)
(19,407)
-
(1)
(7,292)
(7,293)
Exchange differences on monetary assets
(1,622)
(97)
(6)
(1,725)
(91)
-
-
(91)
Modification losses (note 4.12.)
(374)
(38)
-
(412)
-
-
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
400,313
47,665
15,080
463,058
Balance as at 31 December 2023
6,207,653
451,154
169,107
6,827,914
3,434,833
162,976
61,214
3,659,023
In 2024, the gross carrying amount of loans and
advances to other customers increased by EUR
1,158,507 thousand at the NLB Group level and EUR
1,186,849 thousand at the NLB level, mostly in Stage 1
due to the acquisition of subsidiaries and the increased
exposure. The loss allowance increased by EUR 349
thousand at the NLB Group level and EUR 20,391
thousand at the NLB level. The main reason for the
small increase in allowance compared to the increased
exposure were write-offs in the amount of EUR 21,236
thousand at the NLB Group level and EUR 4,073
thousand at the NLB level.
In 2023, the gross carrying amount of loans and
advances to other customers increased by EUR 174,374
thousand at the NLB Group level mostly in Stage 1 due
to the increased exposure. Irrespective of that, the
loss allowance decreased by EUR 22,096 thousand.
The main reason for the decrease were write-offs in
the amount of EUR 19,407 thousand. Also, in 2023, the
gross carrying amount of loans and advances to other
customers increased by EUR 595,529 thousand at the
NLB level, mostly due to merger of N Bank (EUR 463,058
thousand). The loss allowance increased by EUR 8,925
thousand, the main reason was the merger of N Banka
(EUR 11,815 thousand).

NLB Group
Annual Report 2024
458
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Movement of gross carrying amount of other financial assets
The gross carrying amount of other financial assets
in 2024 decreased (by EUR 30,920 thousand at the
NLB Group level and EUR 20,479 thousand at the NLB
level), with the majority of these decreases relating
to receivables for credit cards. As these receivables
are by their nature short-term, they did not contribute
significantly to the decrease of the loss allowance. The
loss allowance for other financial assets in year 2024 on
the NLB Group level decreased by EUR 1,812 thousand,
while at the NLB level by EUR 401 thousand. The main
reason for these decreases are write-offs (EUR 5,599
thousand at the NLB Group level and EUR 341 thousand
at the NLB level).
The gross carrying amount of other financial assets
in 2023 decreased (by EUR 10,090 thousand at the
NLB Group level and EUR 12,202 thousand at the NLB
level), with the majority of these decreases relating
to receivables for the sale of securities. As these
receivables are by their nature short-term, they did
not contribute significantly to the decrease of the loss
allowance. Therefore, the loss allowance for other
financial assets in year 2023 on the NLB Group level
increased only by EUR 1,771 thousand, while at the NLB
level by EUR 601 thousand. The main reason for this
moderate increase at the NLB Group level and on the
NLB level are write-offs (EUR 823 thousand at the NLB
Group level and EUR 304 thousand at the NLB level).
Movement of gross carrying amount of debt securities measured at amortised cost
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Balance as at 1 January
2,515,430
12,321
1,914,170
7,229
1,963,866
5,100
1,599,438
-
Effects of translation of foreign operations
to presentation currency
746
28
(344)
(8)
-
-
-
-
Additions
1,881,834
-
1,023,233
-
1,024,531
-
531,650
-
Derecognition
(762,104)
(8,415)
(453,836)
(24)
(194,214)
(8,415)
(200,534)
(24)
Net interest income
85,111
210
36,750
136
53,806
210
24,101
136
Exchange differences on monetary assets
6,581
25
(2,234)
(5)
4,505
25
(1,664)
(5)
Other
895
-
2,684
-
895
-
2,684
-
Merger of subsidiary (note 5.12.f)
-
-
-
-
-
-
13,184
-
Transfers
(8,198)
8,198
(4,993)
4,993
(8,198)
8,198
(4,993)
4,993
Balance as at 31 December
3,720,295
12,367
2,515,430
12,321
2,845,191
5,118
1,963,866
5,100

NLB Group
Annual Report 2024
459
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Movement of gross carrying amount of debt securities measured at fair value through other comprehensive income
in EUR thousands
NLB Group
NLB
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2024
2,252,797
144
798
2,253,739
1,008,933
-
798
1,009,731
Effects of translation of foreign operations
to presentation currency
2,447
-
-
2,447
-
-
-
-
Additions
2,433,207
-
-
2,433,207
836,368
-
-
836,368
Derecognition
(2,250,764)
(21)
-
(2,250,785)
(255,327)
-
-
(255,327)
Net interest income
54,462
-
-
54,462
25,289
-
-
25,289
Exchange differences on monetary assets
4,177
-
-
4,177
1,427
-
-
1,427
Balance as at 31 December 2024
2,496,326
123
798
2,497,247
1,616,690
-
798
1,617,488
in EUR thousands
NLB Group
NLB
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
12-month
expected
credit losses
Lifetime ECL
not credit -
impaired
Lifetime
ECL credit-
impaired
Total
Balance as at 1 January 2023
2,999,030
165
8,337
3,007,532
1,367,496
-
8,337
1,375,833
Effects of translation of foreign operations
to presentation currency
(262)
-
-
(262)
-
-
-
-
Additions
1,446,746
-
-
1,446,746
59,345
-
-
59,345
Derecognition
(2,233,255)
(21)
(7,526)
(2,240,802)
(463,403)
-
(7,526)
(470,929)
Net interest income
38,624
-
-
38,624
9,163
-
-
9,163
Exchange differences on monetary assets
1,914
-
(13)
1,901
(753)
-
(13)
(766)
Merger of subsidiary (note 5.12.f)
-
-
-
-
37,085
-
-
37,085
Balance as at 31 December 2023
2,252,797
144
798
2,253,739
1,008,933
-
798
1,009,731

NLB Group
Annual Report 2024
460
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
5. 15. Financial liabilities, measured at amortised cost
Analysis by type of financial liabilities, measured at the amortised cost
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Deposits from banks and central banks
136,000
95,283
220,120
147,002
Borrowings from banks and central banks
120,612
140,419
51,106
82,797
Due to customers
22,206,310
20,732,722
12,293,708
11,881,563
Borrowings from other customers
104,519
99,718
-
-
Debt securities issued
1,608,939
1,338,235
1,608,939
1,338,235
Other financial liabilities
296,725
357,116
145,802
198,020
Total
24,473,105
22,763,493
14,319,675
13,647,617
a) Deposits from banks and central banks and amounts due to customers
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Deposit on demand
- banks and central banks
115,897
75,756
210,872
127,726
- other customers
18,260,144
17,454,515
10,927,307
10,674,541
- governments
339,454
351,313
38,803
64,406
- financial organisations
212,487
285,540
187,123
225,295
- companies
4,922,384
4,639,997
2,601,847
2,543,280
- individuals
12,785,819
12,177,665
8,099,534
7,841,560
Other deposits
- banks and central banks
20,103
19,527
9,248
19,276
- other customers
3,946,166
3,278,207
1,366,401
1,207,022
- governments
50,245
61,880
31,520
35,813
- financial organisations
279,888
215,457
56,119
90,590
- companies
889,837
718,230
412,897
378,340
- individuals
2,726,196
2,282,640
865,865
702,279
Total
22,342,310
20,828,005
12,513,828
12,028,565
b) Borrowings from banks and central banks and other customers
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Loans
- banks and central banks
120,612
140,419
51,106
82,797
- other customers
104,519
99,718
-
-
- governments
17,911
20,357
-
-
- financial organisations
86,608
79,361
-
-
Total
225,131
240,137
51,106
82,797
As at 31 December 2024, NLB Group and NLB had EUR
97,874 thousand in undrawn borrowings (31 December
2023: EUR 95,249 thousand).

NLB Group
Annual Report 2024
461
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
c) Debt securities issued
in EUR thousands
NLB Group and NLB
31 Dec 2024
31 Dec 2023
Currency
Due date
Interest rate
Carrying
amount
Nominal
value
Carrying
amount
Nominal
value
Subordinated bonds
EUR
06.05.2029(ii)
4.20% to 06.05.2024, thereafter 5Y MS + 4.159% p.a.
-
-
45,980
45,000
EUR
19.11.2029(i)
3.65% to 19.11.2024, thereafter 5Y MS + 3.833% p.a.
-
-
119,781
120,000
EUR
05.02.2030(i)
3.40% to 05.02.2025, thereafter 5Y MS + 3.658% p.a.
10,785
10,500
123,176
120,000
EUR
28.11.2032
10.75% to 28.11.2027, thereafter 5Y MS + 8.298% p.a.
224,960
225,000
220,458
225,000
EUR
24.01.2034
6.875% to 24.01.2029, thereafter 5Y MS + 4.230% p.a.
324,398
300,000
-
-
Total Subordinated bonds
560,143
535,500
509,395
510,000
Senior Preferred notes
EUR
19.07.2025(iii)
6% to 19.07.2024, thereafter 1Y MS + 4.835% p.a.
-
-
307,507
300,000
EUR
27.06.2027
7.125% to 27.07.2026, thereafter 1Y MS + 3.606% p.a.
524,638
500,000
521,333
500,000
EUR
29.05.2030
4.50% to 29.05.2029, thereafter 1Y MS + 1.650% p.a
524,158
500,000
-
-
Total Senior Preferred notes
1,048,796
1,000,000
828,840
800,000
Total Debt securities issued
1,608,939
1,535,500
1,338,235
1,310,000
(i)In January 2024, NLB conducted a liability management exercise where it repurchased its two outstanding subordinated Tier 2 notes in the total nominal value EUR 219,600 thousand with approaching call dates (ISIN code
XS2080776607 and XS2113139195).
(ii)NLB has, based on the obtained permission of the European Central Bank, redeem its subordinated notes in the aggregate nominal amount of EUR 45,000 thousand, issued on 6 May 2019 and with maturity on 6 May 2029 (ISIN code
SI0022103855), before their maturity. Pursuant to the terms and condition of the notes the early repayment of principal and accrued and unpaid interest was made on the fifth anniversary from the issuance, 6 May 2024.
(iii)NLB has, based on the obtained permission of the Single Resolution Board, redeem its senior preferred notes in the aggregate nominal amount of EUR 300,000 thousand, issued on 19 July 2022 and with maturity on 19 July 2025 (ISIN
code XS2498964209), before their maturity. Pursuant to the terms and condition of the notes the early repayment of principal and accrued and unpaid interest was made on the second anniversary of the issuance, being 19 July 2024.
All of the above-mentioned subordinated bonds
represent non-convertible Tier 2 instruments (note 5.23.).
In the event of bankruptcy or liquidation of the issuer,
claims arising from Tier 2 instruments shall be repaid:
a) after repayment of all unsubordinated claims of the
Issuer, as well as at all other subordinated claims (if
any), except claims arising from Tier 2 instruments
and Additional Tier 1 instruments;
b) with the same priority (pari passu) as, and
proportionally with the claims arising from other
instruments which qualify as Tier 2 instruments;
c) in priority to the claims arising from shares or
other instruments which qualify as Additional Tier 1
instruments and claims arising from Common Equity
Tier 1 capital instruments.

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Overview
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Performance Overview
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Statement
Financial
Report
Movement of debt securities issued
in EUR thousands
NLB Group and NLB
Subordinated bonds
Senior Preferred notes
2024
2023
2024
2023
Balance as at 1 January
509,395
508,778
828,840
307,212
Cash flow items:
(3,211)
(34,538)
143,722
479,708
- new issued
298,611
-
497,347
497,708
- repayment
(270,659)
-
(300,000)
-
- repayments of interest
(31,163)
(34,538)
(53,625)
(18,000)
Non-Cash flow items:
53,959
35,155
76,234
41,920
- accrued interest
46,322
35,155
60,201
36,579
- other
7,637
-
16,033
5,341
Balance as at 31 December
560,143
509,395
1,048,796
828,840
d) Other financial liabilities
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Items in the course of settlement
78,192
93,425
13,878
17,957
Debit or credit card payables
37,169
113,398
33,874
90,495
Suppliers
30,470
22,872
18,208
16,614
Lease liabilities (note 5.11.a)
35,935
28,944
5,775
5,793
Accrued expenses
54,337
35,628
29,631
17,065
Fees and commissions
935
1,242
800
1,133
Liabilities to brokerage firms and others for
securities purchase and custody services
228
288
224
268
Other financial liabilities
59,459
61,319
43,412
48,695
Total
296,725
357,116
145,802
198,020
Other financial liabilities in the amount of EUR 25,255
thousand (31 December 2023: EUR 24,025 thousand)
relate to a liability recognised in accordance with
the ‘Act for Value Protection of Republic of Slovenia’s
Capital Investment in Nova Ljubljanska banka d.d.,
Ljubljana’ (note 5.16.a). The remaining balance also
includes liabilities to insurance companies, liabilities for
received EIB financial initiatives, that can be used for
specified purposes, and received warranties.

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5. 16. Provisions
a) Analysis by type of provisions
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Provisions for guarantees and commitments (note 5.24.a)
21,850
32,548
9,240
17,941
Stage 1
11,953
18,429
3,851
7,653
Stage 2
2,306
1,655
834
319
Stage 3
7,591
12,464
4,555
9,969
Employee benefit provisions
20,903
17,892
13,296
11,795
Restructuring provisions
10,366
12,592
5,309
7,198
Provisions for legal risks
46,913
44,833
10,125
6,219
Other provisions
4,356
5,440
3,676
5,303
Total
104,388
113,305
41,646
48,456
Provisions for guarantees and commitments represent
expected credit losses in accordance with IFRS 9,
employee benefits are recognised in accordance
with IAS 19, while all other provisions are recognised
according to IAS 37.
Legal risks
Provisions for legal risks are formed based on
expectations regarding the probable outcome of legal
disputes. As at 31 December 2024, NLB Group was
involved in 40 (31 December 2023: 41) legal disputes with
material claims against Group members in the total
amount of EUR 463,087 thousand, excluding accrued
interest (31 December 2023: EUR 463,122 thousand). As at
31 December 2024, NLB was involved in 23 (31 December
2023: 21) legal disputes with material monetary
claims against NLB. The total amount of these claims,
excluding accrued interest, was EUR 243,599 thousand
(31 December 2023: EUR 236,727 thousand).
In connection with legal risks, the largest amount
of material monetary claims relates to civil claims
filed by Privredna banka Zagreb (the PBZ) and
Zagrebačka banka (the ZaBa) against NLB, referring
to the old savings of LB Branch Zagreb savers, which
were transferred to these two banks in a principal
amount of approximately EUR 174.75 million (as per
31 December 2024). Due to the fact the proceedings
had been pending for such a long time, the penalty
interest already exceeds the principal amount. As NLB
is not liable for the old foreign currency savings, based
on numerous process and content-related reasons,
NLB has all along objected to these claims. Two key
reasons NLB is not liable for the old foreign currency
savings are that it was only founded on the basis of
the Constitutional Act on 27 July 1994 (at the time the
savings were deposited with LB Branch Zagreb, NLB
did not yet exist), and NLB did not assume any such
obligations. Moreover, this is a former Yugoslavia
succession matter, as the governments of the Republic
of Slovenia and the Republic of Croatia agreed in a
Memorandum of Understanding signed in 2013 whose
intent was to find a solution to the transferred foreign
currency savings of Ljubljanska banka in Croatia (LB)
on the basis of the Agreement on Succession Issues.
The Memorandum also said that the Republic of
Croatia would ensure the stay of all the proceedings
commenced by the PBZ and the ZaBa in relation to the
transferred foreign currency savings until the issue was
finally resolved.
Despite the agreement in the Memorandum of
Understanding to stay all of the proceedings
commenced, the Court of Appeal, the County Court
of Zagreb, ruled in six claims (as explained below in
detail) in favour of the plaintiff. In six of those cases, NLB
filed a constitutional suit after an extraordinary legal
measure of NLB with the Supreme Court of the Republic
of Croatia was not successful. In two of the six cases
mentioned, the plaintiff was fully repaid and therefore
there are no further liabilities for NLB in this regard.
Contrary to the decisions of the court described above
in another case, a claim filed by the PBZ was refused
and the judgment became final in favour of NLB. The
extraordinary legal measure with the Supreme Court
of the Republic of Croatia, filed by the plaintiff, was
dismissed by the Supreme Court on 16 June 2015.
In the other cases, with respect to which court
procedures described above are pending, final court
decisions have not yet been issued.

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The table below summarises the amounts according to final court decisions (not including penalty interest) and which have not yet been recovered from NLB:
Date of the ruling
Plaintiff
Principal amount
in thousands of currency
Costs of the proceedings
in thousands of currency
Measures taken by NLB
April 2018
PBZ
EUR 222
EUR 34
Constitutional suit against the court decisions (including the decision of the Supreme Court of
the Republic of Croatia in the revision proceeding), as NLB found the court decision contrary to
the legislation in force and constitutional principles, and as well contrary to the Memorandum
concluded between the Republic of Slovenia and the Republic of Croatia. Constitutional Court
of the Republic of Croatia rejected the constitutional appeal of NLB d.d. on 5 October 2021.
November 2017
PBZ
EUR 220
EUR 91
NLB challenged the judgments with the extraordinary legal measure (revision) on the Supreme
Count of the Republic of Croatia, which rejected NLB‘s revision on 22 November 2023 (judgment
received on 5 January 2024). NLB challenged the judgment in question with a constitutional
lawsuit before the Constitutional Court of the Republic of Croatia on 2 February 2024.
December 2018
PBZ
SEK 3,855
EUR 90
Constitutional suit against the court decisions (including the decision of the Supreme Court of
the Republic of Croatia in the revision proceeding), as NLB found the court decision contrary to
the legislation in force and constitutional principles and as well contrary to the Memorandum
concluded between the Republic of Slovenia and the Republic of Croatia. Constitutional Court
of the Republic of Croatia rejected the constitutional appeal of NLB d.d. on 3 October 2023
March 2019
PBZ
USD 9,185
EUR 425
NLB challenged the judgment with the extraordinary legal measure (revision) on the Supreme
Count of the Republic of Croatia which rejected NLB‘s revision. NLB challenged the judgment in
question with a constitutional lawsuit before the Constitutional Court of the Republic of Croatia
The NLB Shareholders’ Meeting provided the
Management Board of NLB with instructions how to act
in the event of existing or potential new final decisions
by Croatian courts against LB and NLB regarding the
transferred foreign currency deposits, especially not
to voluntarily settle the adjudicated amounts, and also
gave some additional instructions on the usage of
legal remedies and regarding the management of the
property from that perspective.
On 19 July 2018, the National Assembly of the Republic
of Slovenia passed the ‘Act for Value Protection of
Republic of Slovenia’s Capital Investment in Nova
Ljubljanska banka d.d., Ljubljana’ (Zakon za zaščito
vrednosti kapitalske naložbe Republike Slovenije v
Novi Ljubljanski banki d.d., Ljubljana, hereinafter: ‘the
ZVKNNLB’) which entered into force on 14 August 2018.
In accordance with the ZVKNNLB, the Succession Fund
of the Republic of Slovenia (Sklad Republike Slovenije
za nasledstvo, javni sklad, hereinafter: ‘the Fund’),
shall compensate NLB for the sums recovered from
NLB by enforcement of final judgements delivered by
Croatian courts with regard to the transferred foreign
currency deposits, that is the principle amount, accrued
interest, expenses of court, attorney’s expenses, and
other expenses of the plaintiff, and expenses related
to enforcement with the accrued interest, and shall
not compensate NLB for its own costs or for the
difference between the book value of its assets sold
in enforcement proceedings and the price obtained
for such assets in enforcement proceedings. There
shall be no compensation for any voluntarily made
payments by NLB. In accordance with the ZVKNNLB
and pursuant to the agreement between NLB and
the Fund, as envisaged by the ZVKNNLB (which was
concluded on 14 August 2018), NLB has to contest the
claims made against it in court proceedings in relation
to transferred foreign currency deposits, and use
against court decisions that are disadvantageous for
NLB, all reasonable legal remedies and to continue to
actively challenge the judicial decisions of the courts of
the Republic of Croatia in relation to transferred foreign
currency deposits on the basis of which enforcement
took place, leading, on the basis of ZVKNNLB, to the
compensation of the sums recovered from NLB by
enforcement. In the aforementioned case from May
2015, the Succession Fund of the Republic of Slovenia
has already compensated the sums recovered from
NLB by enforcement.
Provisions for legal risks for existing claims filed by
PBZ and ZaBa are not formed, since NLB believes that
based on the factual and legal evaluation there are
greater prospects for the court proceedings to end in
favour of NLB than the opposite.
Regardless of the negative outcomes for claims for
which the final ruling was issued, in the financial
statements NLB Group did not recognise the negative
impact on profit and loss due to protection provided
by the ZVKNNLB. For final judgements, NLB Group
recognised the liabilities and related assets, which are
included within other financial assets (note 5.6.d) and
other financial liabilities (note 5.15.d).

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b) Provisions for guarantees and commitments
Movements in provisions for guarantees and commitments
in EUR thousands
NLB Group
Balance as at
1 Jan 2024
Effects of
translation of
foreign operations
to presentation
currency
Acquisition of
subsidiaries
Transfers
Increases/
(Decreases)
Changes in
models/risk
parameters
Foreign exchange
differences and
other movements
Balance as at
31 Dec 2024
Notes
5.12.c)
4.13.
4.13.
5.16.a)
12-month expected credit losses
18,429
9
1
1,417
(834)
(7,089)
20
11,953
Lifetime ECL not credit-impaired
1,655
2
-
489
(9)
168
1
2,306
Lifetime ECL credit-impaired
12,464
4
-
(1,906)
(3,521)
557
(7)
7,591
Of which: Purchased or
originated credit-impaired
3,095
1
-
-
(2,674)
-
(160)
262
in EUR thousands
NLB Group
Balance as at
1 Jan 2023
Effects of
translation of
foreign operations
to presentation
currency
Transfers
Increases/
(Decreases)
Changes in
models/risk
parameters
Foreign exchange
differences and
other movements
Balance as at
31 Dec 2023
Notes
4.13.
4.13.
5.16.a)
12-month expected credit losses
18,826
(3)
583
2,609
(3,587)
1
18,429
Lifetime ECL not credit-impaired
1,953
-
(263)
(873)
837
1
1,655
Lifetime ECL credit-impaired
16,830
-
(320)
(4,039)
(2)
(5)
12,464
Of which: Purchased or
originated credit-impaired
4,095
1
-
(1,015)
-
14
3,095
in EUR thousands
NLB
Balance as at
1 Jan 2024
Transfers
Increases/
(Decreases)
Changes in models/
risk parameters
Foreign exchange
differences and
other movements
Balance as at
31 Dec 2024
Notes
4.13.
4.13.
5.16.a)
12-month expected credit losses
7,653
646
(1,608)
(2,841)
1
3,851
Lifetime ECL not credit-impaired
319
1,146
(806)
175
-
834
Lifetime ECL credit-impaired
9,969
(1,792)
(4,014)
393
(1)
4,555
Of which: Purchased or
originated credit-impaired
2,935
-
(2,673)
-
-
262
in EUR thousands
NLB
Balance as at
1 Jan 2023
Transfers
Increases/
(Decreases)
Changes in models/
risk parameters
Merger of
subsidiary
Balance as at
31 Dec 2023
Notes
4.13.
4.13.
5.12.f)
5.16.a)
12-month expected credit losses
8,156
158
(146)
(1,142)
627
7,653
Lifetime ECL not credit-impaired
378
147
(616)
387
23
319
Lifetime ECL credit-impaired
11,765
(305)
(1,589)
32
66
9,969
Of which: Purchased or
originated credit-impaired
2,876
-
(3)
-
62
2,935

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Movement of contractual amounts of guarantees and commitments in off-balance sheet
in EUR thousands
NLB Group
NLB
12-month
expected
credit losses
Lifetime ECL not
credit - impaired
Lifetime ECL
credit-impaired
Total
12-month
expected
credit losses
Lifetime ECL not
credit - impaired
Lifetime ECL
credit-impaired
Total
Balance as at 1 January 2024
4,032,559
106,616
20,917
4,160,092
2,783,977
66,619
13,978
2,864,574
Effects of translation of foreign
operations to presentation currency
2,539
110
13
2,662
-
-
-
-
Acquisition of subsidiaries (note 5.12.c)
1,868
-
-
1,868
-
-
-
-
Increases/(Decreases)
333,795
14,058
(9,522)
338,331
232,852
(9,697)
(7,463)
215,692
Foreign exchange differences
417
-
-
417
33
-
-
33
Transfers
(14,379)
13,601
778
-
(15,703)
15,244
459
-
Balance as at 31 December 2024
4,356,799
134,385
12,186
4,503,370
3,001,159
72,166
6,974
3,080,299
in EUR thousands
NLB Group
NLB
12-month
expected
credit losses
Lifetime ECL not
credit - impaired
Lifetime ECL
credit-impaired
Total
12-month
expected
credit losses
Lifetime ECL not
credit - impaired
Lifetime ECL
credit-impaired
Total
Balance as at 1 January 2023
3,843,293
83,270
26,897
3,953,460
2,397,742
35,243
15,019
2,448,004
Effects of translation of foreign
operations to presentation currency
(837)
(28)
(2)
(867)
-
-
-
-
Increases/(Decreases)
224,499
(9,271)
(7,960)
207,268
216,455
1,071
(2,041)
215,485
Foreign exchange differences
231
-
-
231
152
-
-
152
Transfers
(34,627)
32,645
1,982
-
(28,955)
28,362
593
-
Disposal of subsidiary
-
-
-
-
198,583
1,943
407
200,933
Balance as at 31 December 2023
4,032,559
106,616
20,917
4,160,092
2,783,977
66,619
13,978
2,864,574

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Financial
Report
c) Movements in employee benefit provisions
Post-employment benefits
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
15,468
16,021
10,369
10,672
Effects of translation of foreign
operations to presentation currency
16
(3)
-
-
Acquisition of subsidiaries (note 5.12.c)
623
-
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
531
Additional provisions (note 4.9.)
934
227
641
587
Provisions released (note 4.9.)
(960)
(1,361)
(828)
(1,039)
Interest expenses (note 4.1.)
660
587
355
297
Utilised during year (payments)
(329)
(447)
(138)
(91)
Actuarial gains and losses
1,307
444
860
(588)
Balance as at 31 December
17,719
15,468
11,259
10,369
Other employee benefits
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
2,424
2,005
1,426
1,204
Effects of translation of foreign
operations to presentation currency
4
(1)
-
-
Acquisition of subsidiary (note 5.12.c)
73
-
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
79
Additional provisions (note 4.9.)
885
636
688
173
Provisions released (note 4.9.)
(79)
(104)
-
-
Interest expenses (note 4.1.)
108
81
54
33
Utilised during year
(231)
(193)
(131)
(63)
Balance as at 31 December
3,184
2,424
2,037
1,426
Other employee benefits include NLB Group’s obligations for jubilee long-service benefits.
d) Movements in restructuring provisions
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
12,592
21,036
7,198
7,288
Effects of translation of foreign
operations to presentation currency
18
(1)
-
-
Additional provisions (note 4.13.)
3,919
4,006
2,500
3,800
Provisions released (note 4.13.)
-
(352)
-
-
Utilised during year
(6,163)
(12,097)
(4,389)
(3,890)
Balance as at 31 December
10,366
12,592
5,309
7,198
Additional restructuring provisions recognised during
the year 2024 and 2023 relate mainly to NLB for the
purpose of continuing the reorganisation, optimisation
of work processes/business in individual segments,
and HR restructuring (restructuring of workforce in
accordance with business demands) and the related
reduction in the number of employees.

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e) Movements in provisions for legal risks
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
44,833
43,209
6,219
3,584
Effects of translation of foreign
operations to presentation currency
98
8
-
-
Acquisition of subsidiary (note 5.12.c)
761
-
-
-
Disposal of subsidiaries (note 5.12.d)
-
(30)
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
5,382
Additional provisions (note 4.13.)
11,730
16,354
4,660
899
Provisions released (note 4.13.)
(2,802)
(9,074)
(11)
(3,577)
Utilised during year
(7,707)
(5,634)
(743)
(69)
Balance as at 31 December
46,913
44,833
10,125
6,219
f) Movements in other provisions
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Balance as at 1 January
5,440
2,772
5,303
2,169
Effects of translation of foreign
operations to presentation currency
-
1
-
-
Acquisition of subsidiary (note 5.12.c)
544
-
-
-
Merger of subsidiary (note 5.12.f)
-
-
-
1,173
Additional provisions (note 4.13.)
-
15,019
-
13,300
Provisions released (note 4.13.)
-
(28)
-
-
Utilised during year
(1,628)
(12,324)
(1,627)
(11,339)
Balance as at 31 December
4,356
5,440
3,676
5,303
Other provisions in the NLB Group and NLB relate
mainly to liability in relation to reimbursement of fees in
case of early loan repayment.

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5. 17. Deferred income tax
a) Analysis by type of deferred income taxes
in EUR thousands
NLB Group
NLB
31 Dec 2024
2024
31 Dec 2024
2024
Deferred income
tax assets
Deferred income
tax liabilities
Included
in the
income
statement
Included
in other
comprehensive
income
Deferred income
tax assets
Deferred income
tax liabilities
Included
in the
income
statement
Included
in other
comprehensive
income
Valuation of financial instruments
and capital investments
50,852
10,345
279
(12,192)
48,892
5,219
(346)
(7,523)
Impairment of financial assets
15,182
5,159
336
119
1,358
582
205
(44)
Provisions for liabilities and charges
8,559
-
(743)
51
1,529
-
(327)
-
Depreciation and valuation
of non-financial assets
3,720
1,206
(336)
-
129
139
35
-
Fair value adjustments of financial
assets measured at amortised cost
3,116
8,004
(1,722)
-
788
-
(624)
-
Tax losses
60,989
-
6,920
-
59,571
-
5,502
-
Undistributed profit of subsidiaries
-
10,466
(840)
-
-
-
-
-
Other
576
4,807
659
-
-
-
-
-
Total
142,994
39,987
4,553
(12,022)
112,267
5,940
4,445
(7,567)
in EUR thousands
NLB Group
NLB
31 Dec 2023
2023
31 Dec 2023
2023
Deferred income
tax assets
Deferred income
tax liabilities
Included
in the
income
statement
Included
in other
comprehensive
income
Deferred income
tax assets
Deferred income
tax liabilities
Included
in the
income
statement
Included
in other
comprehensive
income
Valuation of financial instruments
and capital investments
59,640
7,218
8,055
4,322
55,098
3,556
7,517
10,244
Impairment of financial assets
9,704
3,589
801
1,342
1,153
538
(961)
1,171
Provisions for liabilities and charges
9,047
-
(928)
81
1,856
-
23
(31)
Depreciation and valuation
of non-financial assets
4,141
1,304
(452)
-
123
168
9
-
Fair value adjustments of financial
assets measured at amortised cost
1,940
6,651
(1,398)
-
1,412
-
94
-
Tax losses
54,069
-
54,069
-
54,069
-
54,069
-
Undistributed profit of subsidiaries
-
9,626
(9,626)
-
-
-
-
-
Other
248
522
461
-
-
-
-
-
Total
138,789
28,910
50,982
5,745
113,711
4,262
60,751
11,384
The table above does not include the effects of the merger of N Banka.
The tax loss on which NLB did not recognise deferred
tax assets, as at 31 December 2024 amounts to EUR
430,086 thousand (31 December 2023: EUR 580,388
thousand). In accordance with the amendment to
Slovenian corporate income tax law effective from
January 1, 2025, tax losses can be carried forward
to subsequent periods for a maximum of five years
after the period in which they occurred. Based on the
transitional provision, accumulated unused old tax
losses, incurred before the entry into force, can be
claimed in the five years (until 2029). By Slovenian tax
law, use of tax loss is limited to 50% of the actual tax
base. Other banking members have no tax losses.
NLB did not recognise deferred tax assets on
temporary differences arising from the impairments of
investments in subsidiaries and associates where it is
not probable that the temporary difference will reverse
in the foreseeable future. These temporary differences
amount to EUR 137,277 thousand as at 31 December
2024 (31 December 2023: EUR 189,311 thousand).

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Report
b) Movements in deferred income taxes
Deferred income tax assets
in EUR thousands
NLB Group
Provisions for
liabilities and
charges
Valuation
of financial
instruments
and capital
investments
Depreciation
and valuation
of non-financial
assets
Impairment of
financial assets
Tax losses
Fair value
adjustments of
financial assets
measured at
amortised cost
Other
Total
Balance as at 1 January 2023
9,899
48,415
4,737
9,480
-
2,046
141
74,718
Effects of translation of
foreign operations to
presentation currency
(5)
1
-
(8)
-
2
-
(10)
(Charged)/credited to
profit and loss
(928)
7,490
(596)
232
54,069
(108)
107
60,266
(Charged)/credited to other
comprehensive income
81
3,734
-
-
-
-
-
3,815
Balance as at 31 December 2023
9,047
59,640
4,141
9,704
54,069
1,940
248
138,789
Effects of translation of
foreign operations to
presentation currency
18
12
14
27
-
-
-
71
(Charged)/credited to
profit and loss
(743)
(346)
(435)
2,023
6,920
(394)
216
7,241
(Charged)/credited to other
comprehensive income
51
(8,454)
-
-
-
-
-
(8,403)
Acquisition of subsidiaries
(note 5.12.c)
186
-
-
3,428
-
1,570
112
5,296
Balance as at 31 December 2024
8,559
50,852
3,720
15,182
60,989
3,116
576
142,994
in EUR thousands
NLB
Provisions for
liabilities and
charges
Valuation
of financial
instruments
and capital
investments
Depreciation
and valuation
of non-financial
assets
Impairment of
financial assets
Tax losses
Fair value
adjustments of
financial assets
measured at
amortised cost
Total
Balance as at 1 January 2023
1,819
38,028
109
2,050
-
-
42,006
(Charged)/credited to
profit and loss
23
7,517
14
(961)
54,069
94
60,756
(Charged)/credited to other
comprehensive income
(31)
8,517
-
-
-
-
8,486
Merger of subsidiary (note 5.12.f)
45
1,036
-
64
-
1,318
2,463
Balance as at 31 December 2023
1,856
55,098
123
1,153
54,069
1,412
113,711
(Charged)/credited to
profit and loss
(327)
(346)
6
205
5,502
(624)
4,416
(Charged)/credited to other
comprehensive income
-
(5,860)
-
-
-
-
(5,860)
Balance as at 31 December 2024
1,529
48,892
129
1,358
59,571
788
112,267

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Deferred income tax liabilities
in EUR thousands
NLB Group
Impairment of
financial assets
Valuation
of financial
instruments
and capital
investments
Depreciation and
valuation of
non-financial
assets
Undistributed
profit of
subsidiaries
Fair value
adjustments of
financial assets
measured at
amortised cost
Other
Total
Balance as at 1 January 2023
5,501
8,375
1,641
-
5,366
877
21,760
Effects of translation of foreign operations
to presentation currency
(1)
(4)
-
-
(5)
(1)
(11)
Charged/(credited) to profit and loss
(569)
(565)
(144)
9,626
1,290
(354)
9,284
Charged/(credited) to other comprehensive income
(1,342)
(588)
-
-
-
-
(1,930)
Disposal of subsidiaries
-
-
(193)
-
-
-
(193)
Balance as at 31 December 2023
3,589
7,218
1,304
9,626
6,651
522
28,910
Effects of translation of foreign operations
to presentation currency
2
14
1
-
25
3
45
Charged/(credited) to profit and loss
1,687
(625)
(99)
840
1,328
(443)
2,688
Charged/(credited)to other comprehensive income
(119)
3,738
-
-
-
-
3,619
Acquisition of subsidiaries (note 5.12.c)
-
-
-
-
-
4,725
4,725
Balance as at 31 December 2024
5,159
10,345
1,206
10,466
8,004
4,807
39,987
in EUR thousands
NLB
Impairment of
financial assets
Valuation
of financial
instruments
and capital
investments
Depreciation and
valuation of
non-financial
assets
Total
Balance as at 1 January 2023
1,672
5,283
163
7,118
Charged/(credited) to profit and loss
-
-
5
5
Charged/(credited) to other comprehensive income
(1,171)
(1,727)
-
(2,898)
Merger of subsidiary (note 5.12.f)
37
-
-
37
Balance as at 31 December 2023
538
3,556
168
4,262
Charged/(credited) to profit and loss
-
-
(29)
(29)
Charged/(credited) to other comprehensive income
44
1,663
-
1,707
Balance as at 31 December 2024
582
5,219
139
5,940

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5. 18. Income tax relating to components of other comprehensive income
in EUR thousands
2024
NLB Group
NLB
Before tax
Tax expense
Net of tax
Before tax
Tax expense
Net of tax
Actuarial gains and losses
(1,307)
51
(1,256)
(860)
-
(860)
Financial assets measured at fair value through other comprehensive income
66,837
(12,073)
54,764
34,395
(7,567)
26,828
Share of associates and joint ventures
18
-
18
-
-
-
Total
65,548
(12,022)
53,526
33,535
(7,567)
25,968
in EUR thousands
2023
NLB Group
NLB
Before tax
Tax expense
Net of tax
Before tax
Tax expense
Net of tax
Actuarial gains and losses
(444)
81
(363)
588
(31)
557
Financial assets measured at fair value through other comprehensive income
77,722
5,664
83,386
36,106
11,415
47,521
Share of associates and joint ventures
45
-
45
-
-
-
Total
77,323
5,745
83,068
36,694
11,384
48,078
5. 19. Other liabilities
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Accrued salaries
34,445
28,228
24,388
19,461
Unused annual leave
8,362
7,657
3,106
2,761
Deferred income
8,941
11,376
734
4,376
Taxes payable
41,350
7,015
38,367
4,895
Payments received in advance
10,791
4,377
403
857
Total
103,889
58,653
66,998
32,350

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5. 20. Share capital
The share capital of NLB amounts to EUR 200,000
thousand and did not change in 2024. It is comprised of
20,000,000 no-par-value ordinary registered shares,
with the corresponding value of EUR 10.0 for one share.
All issued shares are fully paid and there are no un-
issued authorised shares. As at 31 December 2024, the
major shareholder of NLB with significant influence is the
Republic of Slovenia, who owns 25.00% plus one share.
The book value of a NLB share on a consolidated level
as at 31 December 2024 was EUR 157.1 (31 December
2023: EUR 139.9), and on a solo level was EUR 122.1
(31 December 2023: EUR 108.3). It is calculated as the
ratio of net assets’ book value excluding other equity
instruments issued and the number of shares.
Distributable profit as at 31 December 2024 amounts
to EUR 1,194,063 thousand (31 December 2023: EUR
1,116,689 thousand) and consists of NLB net profit for
2024 in the amount of EUR 478,161 thousand (2023: EUR
514,287 thousand), and retained earnings from previous
years in the amount of EUR 1,116,689 thousand, reduced
for the transfer of profit to reserves in the amount of
EUR 172,810 thousand, for the payment of dividends
in the amount of EUR 220,000 thousand, and for the
interests of subordinated bonds, which are considered
instruments of additional basic capital in the amount
of EUR 7,977 thousand. Its allocation will be subject to a
decision by the Bank’s General Assembly. The proposal
for the General Assembly will be prepared by the
Management and the Supervisory Board, considering
restrictions imposed by the regulators, the Group’s risk
appetite, the target capital adequacy at the Group’s
level, and actual prevailing capital position at the time
of the proposal.
The shares give to their holders the right to vote at the
NLB’s meeting of shareholders where, as a rule, each
share entitles its holder to one vote. Nevertheless, a
shareholder who acquires shares which, together with
the shares already held by such shareholder or by a
third person on behalf of such shareholder, represent
more than 25% of the NLB’s share capital, may only
exercise its voting rights under such shares if NLB’s
Supervisory Board approves such an acquisition. The
Supervisory Board’s approval may only be rejected
if, following such an acquisition, such a person would
hold shares representing more than 25% of NLB’s
issued share capital plus one share. The approval
shall be considered given if not expressly rejected in
20 days. No such approval is necessary with respect
to the shares acquired by a person on behalf of third
persons provided that such a person is not entitled to
exercise the voting rights arising out of such shares at
its own discretion, and undertakes to NLB that it will not
exercise the voting rights based on voting instructions
unless such voting instructions are accompanied with
a confirmation that the person giving such instructions
is the beneficial owner of the shares with respect to
which votes are to be exercised and does not hold in
the aggregate, directly or indirectly 25% or more NLB
shares with voting rights.
The shares also give their holders the right to be
informed, as well as the pre-emptive right to subscribe
for new shares on a pro rata basis in the case of a
share capital increase, the right to a pro-rata share
of remaining assets in the case of bankruptcy or
liquidation or NLB, and the right to receive a dividend.
In 2024, NLB paid dividends for the previous year in
the amount of EUR 11.00 per share (2023: EUR 5.5 per
share), which decreased retained earnings by EUR
220,000 thousand (2023: EUR 110,000 thousand).
As at 31 December 2024 and 31 December 2023,
NLB holds no own shares. In June 2019, the General
Assembly of NLB authorised the Management Board
that in the period of 36 months from the adoption of
the shareholders’ resolution, it can buy own shares of
the Bank for the payment of variable remuneration to
certain employees as required by the Banking Act and
other relevant regulations. NLB did not buy any own
shares based on this authorisation.
5. 21. Other equity instruments issued
On 23 September 2022, NLB issued subordinated notes
intended to qualify as Additional Tier 1 Instruments in
the aggregate nominal amount of EUR 82 million. The
notes have no scheduled maturity date. The issuer
has the option for early redemption of the notes in the
period between 23 September 2027 and 23 March 2028,
and on each distribution payment date after 23 March
2028. Until 23 March 2028, the interest on the principal
of the notes will accrue at the interest rate of 9.721% per
annum, and for each subsequent 5-year period, will
accrue at the applicable interest rate, which shall be
reset prior to the commencement of each such period
(5Y MS + 7.20% per annum). The coupon payments are
discretionary and non-cumulative. The notes terms
provide for a temporary write-down in the event that
the Common Equity Tier 1 ratio of NLB Group and/or
NLB drop(s) below 5.125%. The issue price was equal to
100% of the nominal amount of the notes. The ISIN code
of the notes is SI0022104275. The carrying amount as at
31 December 2024 is EUR 84,184 thousand (31 December
2023: EUR 84,178 thousand).

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5. 22. Accumulated other
comprehensive income
and reserves
a) Reserves
The share premium account as at 31 December 2024
and 31 December 2023 comprises paid-up premiums
in the amount of EUR 822,173 thousand and the
revaluation of share capital from previous years in the
amount of EUR 49,205 thousand.
Profit reserves as of 31 December 2024 amount to EUR
186,332 thousand and consist of EUR 13,522 thousand
of legal reserves and EUR 172,810 thousand of other
reserves, which were formed based on the Resolution
of the Bank’s General Meeting. As at 31 December 2023,
profit reserves in the amount of EUR 13,522 thousand
relate entirely to legal reserves in accordance with the
Companies Act.
In 2024, NLB recorded a net profit in the amount of EUR
478,161 thousand (2023: net profit EUR 514,287 thousand)
which is included in the retained earnings as at 31
December 2024.
b) Accumulated other comprehensive income
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Financial assets measured at fair value through
other comprehensive income - debt securities
(19,978)
(66,666)
(10,113)
(35,255)
Financial assets measured at fair value through
other comprehensive income - equity securities
14,442
6,647
1,830
144
Actuarial defined benefit pension plans
(3,494)
(2,265)
(2,065)
(1,205)
Foreign currency translation
(11,366)
(14,588)
-
-
Hedge of a net investment in a foreign operation
754
754
-
-
Total
(19,642)
(76,118)
(10,348)
(36,316)

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5. 23. Capital adequacy ratios
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Paid up capital instruments
200,000
200,000
200,000
200,000
Share premium
871,378
871,378
871,378
871,378
Retained earnings - from previous years
1,385,040
1,235,363
715,902
602,402
Profit eligible - from current year
256,973
327,398
220,905
159,833
Accumulated other comprehensive income
(19,197)
(75,662)
(10,348)
(36,316)
Other reserves
186,332
13,522
186,332
13,522
Minority interest
38,480
28,798
-
-
Prudential filters: Additional Valuation Adjustments (AVA)
(2,606)
(2,295)
(1,711)
(1,067)
(-) Goodwill
(8,069)
(3,529)
-
-
(-) Other intangible assets
(65,420)
(37,153)
(23,959)
(20,846)
(-) Deferred tax assets
(51,667)
(47,002)
(56,419)
(54,069)
(-) Insufficient coverage for non-performing exposures
(5,426)
(907)
(706)
(246)
COMMON EQUITY TIER 1 CAPITAL (CET1)
2,785,818
2,509,911
2,101,374
1,734,591
Capital instruments eligible as AT1 Capital
82,000
82,000
82,000
82,000
Minority interest
4,534
5,907
-
-
Additional Tier 1 capital
86,534
87,907
82,000
82,000
TIER 1 CAPITAL
2,872,352
2,597,818
2,183,374
1,816,591
Capital instruments and subordinated loans eligible as Tier 2 capital
533,421
507,516
533,421
507,516
Minority interest
5,485
3,874
-
-
TIER 2 CAPITAL
538,906
511,390
533,421
507,516
TOTAL CAPITAL
3,411,258
3,109,208
2,716,795
2,324,107
RWA for credit risk
14,508,398
12,168,121
9,105,028
7,449,829
RWA for market risks
1,505,108
1,447,713
859,088
818,113
RWA for credit valuation adjustment risk
16,613
14,200
17,425
15,613
RWA for operational risk
2,185,986
1,707,128
1,171,163
923,943
TOTAL RISK EXPOSURE AMOUNT (RWA)
18,216,105
15,337,162
11,152,704
9,207,498
Common Equity Tier 1 Ratio
15.3%
16.4%
18.8%
18.8%
Tier 1 Ratio
15.8%
16.9%
19.6%
19.7%
Total Capital Ratio
18.7%
20.3%
24.4%
25.2%

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Overall capital requirements of NLB Group on consolidated level:
SREP requirement
2024
2023
2022
CET1
4.5%
4.5%
4.5%
Pillar 1 (P1R)
AT1
1.5%
1.5%
1.5%
T2
2.0%
2.0%
2.0%
CET1
1.19%
1.35%
1.46%
Pillar 2 (P2R)
Tier 1
1.59%
1.80%
1.95%
Total Capital
2.12%
2.40%
2.60%
CET1
5.69%
5.85%
5.96%
Total SREP Capital Requirement (TSCR)
Tier 1
7.59%
7.80%
7.95%
Total Capital
10.12%
10.40%
10.60%
Capital Conservation buffer
CET1
2.50%
2.50%
2.50%
O-SII buffer
CET1
1.25%
1.25%
1.00%
Systemic risk buffer
CET1
0.11%
0.10%
0.00%
Countercyclical buffer
CET1
0.52%
0.26%
0.00%
Combined buffer requirement (CBR)
CET1
4.38%
4.11%
3.50%
CET1
10.07%
9.96%
9.46%
Overall capital requirement (OCR) = MDA threshold
Tier 1
11.97%
11.91%
11.45%
Total Capital
14.50%
14.51%
14.10%
Pillar 2 Guidance (P2G)
CET1
1.0%
1.0%
1.0%
CET1
11.07%
10.96%
10.46%
OCR + P2G
Tier 1
12.97%
12.91%
12.45%
Total Capital
15.50%
15.51%
15.10%
As at 31 December 2024, the Group’s Overall Capital
Requirement (OCR) on a consolidated basis was
14.50%, which is slightly lower (by 0.01 percentage
point, hereinafter: p.p.) than at the end of 2023.
However, the reduction in the SREP requirement by 0.28
p.p. was offset by an increase in the Countercyclical
buffer by 0.26 p.p. The OCR comprises:
- The Total SREP Capital Requirement (TSCR) is
10.12%, including 8.00% Pillar 1 and 2.12% Pillar 2
Requirements. As at 1 January 2024, the Pillar 2
Requirement decreased by 0.28 p.p. to 2.12% due to a
better overall SREP assessment.
- The second component is the Combined Buffer
Requirement (CBR), which is 4.38%, and includes a
2.50% Capital Conservation Buffer, a 1.25% O-SII
Buffer, a 0.52% Countercyclical Buffer, and a 0.11%
Systemic risk buffer.
In addition to the above requirements, the Pillar 2
Guidance (P2G) is 1.0% of Common Equity Tier 1 (CET1).
Effective 1 January 2025, changes to capital buffer rates
in Slovenia will be implemented:
- The CCYB rate for exposures in Slovenia will increase
from 0.5% to 1.0%.
- The sectoral systemic risk buffer for retail exposures
to natural persons secured by residential real estate
will be reduced from 1.0% to 0.5%.
In addition, the CCYB for the Group is expected to
be higher due to the introduced CCYB in the Group
members (NLB Banka, Skopje, NLB Banka, Podgorica).
The Bank and NLB Group’s capital covers all the current
and announced regulatory capital requirements,
including capital buffers and other currently known
requirements, as well as the P2G.
As at 31 December 2024, NLB Group capital ratios on a
consolidated basis stand at:
- 15.3% CET1 ratio,
- 15.8% Tier 1 ratio,
- 18.7% Total Capital ratio.
In the scope of regulatory risks, which include credit
risk, operational risk, and market risk, NLB Group
uses a standardised approach for credit and market
risks, while the calculation of capital requirement
for operational risks is made according to a basic
indicator approach. The same approaches are used
for calculating the capital requirements for NLB on
a standalone basis, except for the calculation of the
capital requirement for operational risks where the
standardised approach is used.
As at 31 December 2024, the Group’s TCR stood at 18.7%
(or 1.5 p.p. decrease YoY), and the CET1 ratio stood at
15.3% (or 1.1 p.p. decrease YoY), which is well above
requirements. The lower total capital adequacy derives
from higher RWA (EUR 2,878.9 million YoY), although
capital increased by EUR 302.1 million YoY. The Group
increased its capital by partially including 2024 profit
(EUR 257.3 million) and revaluation adjustments (EUR
56.5 million).
In 2024 (YoY), the Group’s RWA for credit risk increased
by EUR 2,340.3 million due to lending activity in the

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corporate and retail segments, of which the acquisition
of Summit Leasing companies contributed to a higher
RWA by EUR 698.0 million. The RWA for high-risk
exposures increased due to new project financing loans
and the withdrawal of previously approved project
finance loans. Furthermore, higher RWA for liquidity
assets resulted from EUR-denominated placements
with central banks and liquidity surpluses placed at
commercial banks.
The increase in the Group’s RWAs for market risks and
Credit Value Adjustments (CVA) by EUR 59.8 million
YoY was driven by a higher RWA for FX risk of EUR
58.6 million (mainly the result of more open positions
in domestic currencies of non-euro subsidiary banks
– mostly RSD), and a slightly higher RWA for CVA risk
of EUR 2.4 million (calculating exposure value for
derivative transactions subject to CRR risk based on the
OEM method).
The increase in the Group’s RWA for operational risks
(EUR 478.9 million YoY) derived from the higher net
interest and net fee and commission income, mainly
from the NLB, NLB Komercijalna banka, Beograd, and
Summit Leasing. This resulted in a higher three-year
average of relevant income. The other components
used in the calculations did not significantly differ from
previous years.
The most important goal of internal capital adequacy
assessment process (ICAAP) in NLB Group, set up in
accordance with ECB Guidelines, is ensuring adequate
capital and sustainability on an ongoing basis. The
purpose of this process is to have in place sound,
effective, and comprehensive strategies and processes
to assess and maintain capital on an ongoing basis,
as well as the adequate distribution of internal capital
for covering the nature and level of the risks to which
NLB Group is or might be exposed. In addition, NLB
Group places strong emphasis on its integration into
the overall risk management system in order to ensure
proactive support for informed decision-making.
From an economic perspective, NLB Group manages
its capital adequacy by ensuring that all its risks are
adequately covered by internal capital. A normative
perspective is a multiyear forward-looking assessment
of NLB Group which shows its ability to fulfil all of its
capital-related regulatory and supervisory requirements
and risk appetite of NLB Group. Within these capital
constraints, NLB Group defines its management
buffers in the Risk appetite above the regulatory and
supervisory requirements, and the internal capital needs
that allow it to sustainably follow its business strategy. A
normative perspective includes several stress scenarios
which are integrated into NLB Group’s annual business
plan review and budgeting process.

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5. 24. Off-balance sheet liabilities
a) Contractual amounts of off-balance sheet financial instruments
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Short-term guarantees
349,733
369,849
197,356
205,731
- financial
159,847
154,769
84,865
88,373
- non-financial
189,886
215,080
112,491
117,358
Long-term guarantees
1,455,838
1,261,764
925,219
817,646
- financial
534,861
513,523
299,008
309,909
- non-financial
920,977
748,241
626,211
507,737
Loan commitments
2,640,323
2,469,800
1,940,563
1,822,847
Letters of credit
34,577
41,026
670
10,446
Other
22,899
17,653
16,491
7,904
4,503,370
4,160,092
3,080,299
2,864,574
Provisions (note 5.16.b)
(21,850)
(32,548)
(9,240)
(17,941)
Total
4,481,520
4,127,544
3,071,059
2,846,633
Fee income from issued non-financial guarantees
amounted to EUR 10,239 thousand (2023: EUR 8,628
thousand) in NLB Group, and to EUR 6,743 thousand
(2023: EUR 5,552 thousand) in NLB.
In addition to the instruments presented in the table
above, NLB Group and NLB have also some low-
risk off-balance sheet items, for which a 0% credit
conversion factor is applied in accordance with the
Capital Requirements Regulation (credit and other lines
which can be irrevocably cancelled by a bank). As at
31 December 2024, these items at the NLB Group level
amount to EUR 1,097,316 thousand (31 December 2023:
EUR 915,450 thousand), and at the NLB level EUR 433,363
thousand (31 December 2023: EUR 412,330 thousand).

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b) Analysis of derivative financial instruments by notional amounts
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Short-term
Long-term
Short-term
Long-term
Short-term
Long-term
Short-term
Long-term
Swaps
419,642
2,330,260
486,874
1,526,962
556,373
2,390,260
715,173
1,586,962
- currency swaps
328,259
-
482,463
10,799
464,990
-
710,762
10,799
- interest rate swaps
91,383
2,330,260
4,411
1,516,163
91,383
2,390,260
4,411
1,576,163
Options
-
37,382
-
45,924
-
37,382
-
45,924
- interest rate options
-
16,696
-
30,189
-
16,696
-
30,189
- securities options
-
20,686
-
15,735
-
20,686
-
15,735
Forward contracts
44,783
241
74,351
6,640
43,367
241
72,120
6,640
- currency forward
44,783
241
74,351
6,640
43,367
241
72,120
6,640
Total
464,425
2,367,883
561,225
1,579,526
599,740
2,427,883
787,293
1,639,526
2,832,308
2,140,751
3,027,623
2,426,819
As at 31 December 2024, the NLB Group held interest
rate swaps intended as fair value hedges of assets
with a total nominal value of EUR 589,141 thousand (31
December 2023: EUR 633,798 thousand) and intended
to hedge the fair value of bonds issued in 2024 with
a total nominal value of EUR 1,520,000 thousand (31
December 2023: EUR 450,000 thousand) (note 5.5.b).
As at 31 December 2024, the NLB held interest rate
swaps intended as fair value hedges of assets with
a total nominal value of EUR 529,141 thousand (31
December 2023: EUR 573,798 thousand) and intended
to hedge the fair value of bonds issued in 2024 with a
total contractual value of EUR 1,520,000 thousand (31
December 2023: EUR 450,000 thousand) (note 5.5.b).
Derivatives that qualify for hedge accounting are used
to hedge interest rate risk.
The fair values of derivative financial instruments are
disclosed in notes 5.2. and 5.5.
c) Capital commitments
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Capital commitments for purchase of:
- property and equipment
7,733
3,131
7,189
3,022
- intangible assets
3,278
2,901
3,066
2,470
Total
11,011
6,032
10,255
5,492

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5. 25. Funds managed on behalf of third parties
Funds managed on behalf of third parties are
accounted separately from NLB Group’s funds. Income
and expenses arising with respect to these funds are
charged to the respective fund, and no liability falls on
NLB Group in connection with these transactions. NLB
Group charges fees for its services.
Funds managed on behalf of third parties
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Fiduciary activities
26,083,756
30,241,726
23,873,013
28,278,498
Settlement and other services
1,043,073
1,085,213
943,592
1,010,624
Total
27,126,829
31,326,939
24,816,605
29,289,122
Fiduciary activities
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Assets
Clearing or transaction account claims for client assets
26,032,877
30,196,860
23,830,528
28,243,725
From financial instruments
26,030,300
30,196,322
23,827,995
28,243,237
- receipt, processing, and execution of orders
12,426,559
11,217,662
11,593,690
10,407,489
- management of financial instruments portfolio
654,510
573,177
-
-
- custody services
12,949,231
18,405,483
12,234,305
17,835,748
To Central Securities Clearing Corporation or bank settlement account for sold financial instrument
130
128
86
78
To other settlement systems and institutions for bought financial instrument (debtors)
2,447
410
2,447
410
Clients‘ money
50,879
44,866
42,485
34,773
- at settlement account for client assets
28,073
27,082
28,059
16,989
- at bank transaction accounts
22,806
17,784
14,426
17,784
Liabilities
Clearing or transaction liabilities for client assets
26,083,756
30,241,726
23,873,013
28,278,498
To clients from cash and financial instruments
26,077,151
30,238,652
23,867,594
28,275,954
- receipt, processing, and execution of orders
12,450,080
11,233,595
11,617,211
10,423,422
- management of financial instruments portfolio
661,762
582,790
-
-
- custody services
12,965,309
18,422,267
12,250,383
17,852,532
To Central Securities Clearing Corporation or bank settlement account for bought financial instrument
225
138
225
138
To other settlement systems and institutions for bought financial instrument (creditors)
6,038
2,532
4,852
2,002
To bank or settlement bank account for fees and costs, etc.
342
404
342
404
Fee income for funds managed on behalf of third parties
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Fiduciary activities (note 4.3.b)
14,922
11,666
11,677
9,567
Settlement and other services
641
912
638
806
Total
15,563
12,578
12,315
10,373

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6. Risk Management
Risk management in NLB Group is implemented in
accordance with the set strategic guidelines, established
internal policies, and procedures which take into
account European banking regulations, the regulations
adopted by the Bank of Slovenia, current EBA guidelines,
and relevant good banking practices. In addition, the
Group is constantly enhancing and complementing the
existing approaches, methodologies, and processes
in all risk management segments with the aim to
proactively support decision-making.
Managing risks and capital efficiently is crucial
for NLB Group sustained long-term profitable
operations. A robust Risk Management framework
is comprehensively integrated into decision-making,
steering, and mitigation processes within the Group.
NLB Group gives high importance to the risk culture and
awareness of all relevant risks within the entire Group.
NLB Group’s Risk management framework supports
business decision-making on strategic and operating
levels, comprehensive steering, proactive risk
management, and mitigation by incorporating:
- risk appetite statement and risk strategy orientations;
- yearly review of strategic business goals, budgeting,
and the capital planning process;
- internal capital adequacy assessment process (ICAAP)
and internal liquidity adequacy assessment process
(ILAAP);
- recovery plan activities;
- other internal stress-testing capabilities, early
warning systems, and regular risk analysis;
- regulatory and internal management reporting.
NLB Group uses the ‘three lines of defence framework’
as an important element of its internal governance,
whereby the Risk management function acts as a
second line of defence. Set governance and different
risk management tools enable adequate oversight
of the Group’s risk profile. Moreover, they support
business operations and enable efficient risk
management by incorporating escalation procedures
and different mitigation measures when necessary.
a) Risk management strategies and processes
The key goal of NLB Group’s Risk Management is to
proactively manage, assess, and monitor risks within
the Group. Sound and holistic understanding of risk
management is embedded into the entire organisation,
focusing on risk identification at a very early stage,
efficient risk management, and mitigation of them with
the aim of ensuring the prudent use of its capital and
adequate liquidity structure to support the financial
resilience of the Group.
Key strategic risk management principles of NLB
Group are defined by its Risk Appetite and Risk
Strategy, designed in accordance with the Group’s
business model, integrating a forward-looking
perspective. The Strategy of NLB Group, the
Risk Appetite, Risk Strategy, and the key internal
policies of NLB Group – which are approved by the
Management and Supervisory Boards – specify the
strategic goals, risk appetite guidelines, approaches,
and methodologies for monitoring, measuring, and
managing all types of risk in order to meet internal
strategic objectives and fulfil all external requirements.
The main strategic risk guidelines are comprehensively
integrated into decision-making, including the
business plan review and budgeting process.
NLB Group plans a prudent risk profile and optimal
capital usage, representing an important element of
its business strategy and related mid-term financial
targets. The management of credit risk, which is
the most important risk category in NLB Group,
concentrates on taking moderate risks – a diversified
credit portfolio, adequate credit portfolio quality, the
sustainable costs of risk, and ensuring an optimal
return considering the risks assumed. As regards
liquidity risk, the tolerance is low, while the activities are
geared towards ensuring an adequate liquidity position
on an ongoing basis. The Group limited exposure to
credit spread risk, arising from the valuation risk of
debt securities portfolio servicing as liquidity reserves,
to a medium level. The fundamental orientation in the
management of interest rate risk is to limit unexpected
negative effects on revenues and capital, therefore, a
medium tolerance for this risk is stated. When assuming
operational risk, the Group pursues the orientation that
such a risk must not significantly impact its operations.
On this basis, changes of control activities, processes,
and/or organisation are performed when necessary.
Besides, the Group also focuses on proactive mitigation,
prevention, and minimisation of potential damage. The
conclusion of transactions with derivative financial
instruments at NLB is primarily limited to servicing
customers and hedging Bank’s own positions. In the
area of currency risk, NLB Group pursues the goals of
low to moderate exposure. The tolerance for other risk
types is low and focuses on minimising their possible
impacts on NLB Group’s entire operations.
Risk management focuses on managing and mitigating
risks in line with the Group’s Risk Appetite and Risk
Strategy. Within these frameworks, the Group monitors
a range of risk metrics, including internal capital
allocation in order to assure the Group’s risk profile
is in line with its risk appetite. The usage of risk limits
and potential deviations from limits and target values
are regularly reported to the respective committees
and/or the Management Board of the Bank and the
Supervisory Board. The banking subsidiaries within
NLB Group adapted a corresponding approach to
monitor and manage their target risk profiles.
NLB Group established a comprehensive stress-
testing framework and other early warning systems
in different risk areas with the intention to strengthen
the existing internal controls and timely response
when necessary. A robust and uniform stress-testing
programme includes all material types of risk and
relevant stress scenario analysis, according to the
vulnerability of the Group’s business model. The Group
established an internal ESG stress-testing concept
to identify the most relevant financial vulnerabilities
stemming from climate risk, which is constantly further
enhanced by considering disposable ESG-related
data. Stress testing is integrated into the risk appetite,
ICAAP, ILAAP, Recovery Plan, and budgeting process
to support proactive management of the Group’s risk
profile, namely the capital and liquidity positions in a
forward-looking perspective. In addition, the Group
also performs reverse stress tests with the aim to test
its maximum recovery capacity. Other partial risk
assessments are covered by other risk analysis, based
on relevant risk parameters, and integrated into the
process of setting a risk management limit system.

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For the purpose of an efficient risk mitigation process,
NLB Group applies a single set of standards to
retail and corporate loan collateral, representing
a secondary source of repayment with the aim of
efficient credit risk management and optimal capital
consumption. The Group has a system for monitoring
and reporting collateral at fair (market) value in
accordance with the International Valuation Standards
(IVS). The eligibility of collateral, by types and ratios
referring to prudent lending criteria, is set within
internal lending guidelines. Credit risk mitigation
principles and rules in NLB Group are described
in more relevant details in the section ‘Credit risk
management.’ When hedging market risks, namely
interest rate risk and foreign exchange risk, in line with
the set risk appetite, NLB Group follows the principle of
natural hedge or using derivatives in line with hedge
accounting principles.
b) Risk management structure and organisation
NLB Group’s corporate governance framework is based
on the principles of sound and responsible governance,
in accordance with the applicable legislation of the
Republic of Slovenia, particularly the provisions of the
Companies Act (ZGD-1M) and the Banking Act (ZBan-3),
the Regulation on Internal Governance Arrangements,
the Management Body, and the Internal Capital
Adequacy Assessment Process for Banks and Savings
Banks, the EBA Guidelines on internal governance, the
EBA Guidelines on the assessment of the suitability of
members of the management body, and key function
holders, as well as the EBA Guidelines on remuneration
practices. Several layers of management provide
cohesive risk management governance in NLB Group.
NLB Group established the three lines of a defence
framework with the aim of managing risks effectively.
The three lines of defence concept provides a
clear division of activities and defines roles and
responsibilities for risk management at different levels
within the Group. Risk management in the Group
acts as a second line of defence, accountable for
appropriate managing, assessing, monitoring, and
reporting of risks in the Bank as the main entity in
Slovenia, and as the competence centre in charge of
group banking and leasing members, and other non-
core subsidiaries which are in a controlled wind-out.
Overall, the organisation and delineation of
competencies in NLB Group’s risk management
structure is designed to prevent conflicts of interest
and ensure a transparent and documented decision-
making process, subject to an appropriate upward
and downward flow of information. Risk management
in NLB Group is managed within the Risk management
competence line, which is a specialised competence
line encompassing several professional areas for which
the Global Risk Department, the Credit Risk – Corporate
Department, the Credit Risk – Retail Department and
the Evaluation and Control Department are responsible
within NLB, and which reports to the Management
Board, Assets and Liabilities Committee (ALCO),
Risk Committee (RICO) and Credit Committee of the
Management Board and the Risk Committee of the
Supervisory Board. The risk management competence
line is in charge of formulating and controlling the
risk management policies of NLB Group, setting
limits, establishing methodologies, overseeing the
harmonisation of risk management policies within the
NLB Group, monitoring NLB Group’s risk exposures,
and preparing external and internal reports.
All members of NLB Group that are included in the
financial statements of NLB Group, report their
exposure to risks to the competent organisational
units within the Risk management competence line.
These organisational units then report all relevant
risk information to the Management Board and its
respective Committees and the Supervisory Board
and its respective Committees, where the appropriate
measures are adopted.
The credit ratings of clients that are materially
important to NLB Group and the issuing of credit risk
opinions are centralised via the Credit Committee of
NLB. The process follows the co-decision principle, in
which the credit committee of the respective Group
member first approves their decision, following which
the Credit Committee of NLB gives their opinion. The
resolution of the Credit Committee of NLB is made on
the basis of all available documentation, including
a non-binding rating opinion prepared by the
underwriting department of NLB.
Risk monitoring in NLB Group members is operating
within an independent and/or separate organisational
unit. This enables uniform risk monitoring on
standardised risk management approaches. Such
monitoring provides a comprehensive overview of
the Group’s and of each member’s risk profile. In
compliance with the risk appetite, risk management
strategy, and policies of NLB Group, risk monitoring
in each NLB Group member is separated from its
management and/or business function to maintain the
objectivity required when assessing business decisions
(three lines of defence concept). The organisational unit
for managing risks directly reports to the Management
Board and its committees (Credit Committee, ALCO,
RICO and the Operational Risk Committee) and to the
Supervisory Board.
c) Risk measurement and reporting systems
As a systemic banking group, NLB Group is subject
to the Single Supervisory Mechanism (SSM), which is
supervised by the Joint Supervisory Team (JST) of the
ECB and the Bank of Slovenia. The Group member
complies with the ECB regulation, while NLB Group
subsidiaries operating outside Slovenia are also
compliant with the rules set by the local regulators. A
third-party equivalent was approved in Serbia, Bosnia
and Herzegovina, and North Macedonia, resulting
in alignment of local regulation with CRR rules. With
regards to capital adequacy, based on the provisions of
the Directive (CRD), Decision (CRR), NLB Group applies a
standardised approach to credit and market risk, and
the basic approach (a simplified approach with less
data granularity) to operational risks, with the exception
of NLB which applies the standardised approach.
Across the Group, risks are assessed, monitored,
managed, or mitigated in a uniform manner, as
defined in the Group’s Risk management standards,
and consider also the specifics of the markets in which
individual NLB Group members operate. For the
purposes of measuring exposure to credit risk, liquidity
risk, interest rate, and credit spread risk in the banking
book, operational risk, market risk, ESG, and non-
financial risks, in addition to the prescribed regulations,
NLB Group uses internal methodologies and
approaches that enable more detailed monitoring and
management of risks. These internal methodologies
are aligned with ECB, EBA, and Basel guidelines, as well
as best practices in banking methodologies.

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As for risk reporting, NLB Group’s internal guidelines
reflect, in addition to internal requirements, the
substance and frequency of reporting required
by the Bank of Slovenia and the ECB. In addition,
each member of NLB Group also complies with the
requirements of its local regulations. Risk reporting
is carried out in the form of standardised reports,
pursuant to risk management policies based on
common methodologies for measuring exposure
to risks, a uniform database structure within Data
Warehouse (DWH), comprehensive data quality
assurance, and automated report preparation,
which ensures the quality of reports and reduces the
possibility of errors.
d) Data and IT system
Risk data are calculated and stored in NLB Group DWH
and collected from NLB and other Group member’s
DWH. The established process provides an integrated
information in common reference structure where
business users can access in a consistent and subject-
oriented format. Data are regularly checked and
validated. Data used for internal risk assessment,
management, and reporting are the same as data
which NLB Group uses for regulatory reporting.
The Group has established a strong and robust data
governance program that aligns with the goals and
objectives of the Group’s risk management function.
NLB Group data governance and data quality
framework consists of identifying risks, developing
policies and controls on data confidentiality, integrity,
accuracy, and availability, and by executing the second
line of defence controls by an independent validation
unit under the responsibility of Group Data Governance
Officer. This framework covers the agreed upon service
level standards for both in-house and outsourced data-
related processes. By that, the Group complies with
BCBS 239 principles and ECB Guide on effective risk
data aggregation and risk reporting.
e) Main emphasis of risk management in 2024
Efficient managing of risks and capital remains
crucial for NLB Group to sustain long-term profitable
operations. The Group further enhanced the robustness
of its risk management system in all respective risk
categories in order to manage them proactively,
comprehensively, and prudently. Risk identification
in a very early stage, its efficient managing, and the
corresponding mitigation processes represent essential
steps in such a system. The business and operating
environment relevant for NLB Group operations is
changing with trends, such as sustainability, social
responsibility, governance, changing customer
behaviours, emerging new technologies and
competitors, as well as increasing new regulatory
requirements. Respectfully, the risk management
framework is regularly adapted with the aim of
detecting and managing new potential emerging risks.
The NLB Group gives special focus on the inclusion
of risk analysis into the decision-making process on
strategic and operating levels, diversification in order to
avoid a large concentration, optimal usage of internal
capital, appropriate risk-adjusted pricing, regular
education/trainings at all levels of management, and
the assurance of overall compliance with internal
policies/rules and relevant regulations.
During 2024, the Group’s credit portfolio remained
high-quality and well-diversified, with a stable rating
structure and lower NPLs level. There was no large
concentration in any selected industry sector. The
latter is particularly important as geopolitical tensions,
a green transition, and other macro developments
could materially impact on specific industry sectors.
The Group monitored the macroeconomic and
geopolitical circumstances closely, remaining very
prudent in identifying any increase in credit risk at a
very early stage, and proactive in NPL management.
Furthermore, unfavourable trends in the German
automotive industry did not severely influence the
Slovenian export-oriented industry. With that in mind,
the bank downgraded some selected clients in stage
2 and formed additional impairments. The cost of
risk remained at relatively low level. The established
impairments derive from portfolio development,
new financing and any portfolio deterioration. In
contrast, the successful collection of previously written-
off receivables and changes in risk parameters
contributed positively to a low total net impact.
The Group stayed well capitalised and above the risk
appetite at both the Group and banking member levels.
The liquidity position of the Group also remained solid,
with liquidity indicators high above the regulatory
requirements, indicating its low tolerance for this
risk. Even if a highly unfavourable liquidity scenario
would materialise, the Group holds a sufficient level
of high-quality liquidity reserves. Significant attention
was put into the structure and concentration of
liquidity reserves, while at the same time considering
the potential adverse negative market movements.
Investment activity continued with a balanced
approach to finding attractive market opportunities
while pursuing well-managed credit spread and
interest rate risk, as well as capital consumption.
Interest rate risk exposure remained moderate and
stayed well within the risk appetite tolerance.
The management of ESG risks follows ECB and EBA
guidelines, focusing on their comprehensive integration
into all relevant processes. It addresses the Group’s
overall credit approval process, collateral management
and related credit portfolio management. Sustainable
ESG financing in accordance with Environmental and
Social Management System is integrated into the
Group’s Risk Appetite Statement. Additionally, publicly
disclosed its Net-Zero commitments are addressed in
the Group’s Risk appetite. In its initial round of NZBA
targets, NLB Group has focused on fossil fuel-based
and highly energy-intensive sectors, such as power
generation and iron and steel, and other sectors
where the Bank has substantial emissions and/or
exposure and available data. These include residential
mortgages and commercial real estate. Defined Net
Zero targets are regularly followed. Activities for setting
second round of NZBA targets, for sectors such as
transport and agriculture, are underway. Moreover,
NLB’s ESG Risk Rating assigned by Morningstar
Sustainalytics further improved in 2024, reflecting a low
risk of material financial impacts from ESG factors.
As a systemically important institution, the Group
is included in the EBA EU-wide and ECB SSM Stress
Test exercise.
This EU-wide stress test is designed to assess the
resilience of the European banking sector in the current
uncertain and changing macroeconomic environment,
namely the aggravation of geopolitical tensions leading
to a severe decline in GDP. The exercise results are
expected to be published at the beginning of August
2025. Besides, in 2024, the Group was also included in

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two ECB Stress test exercises: the 2024 EBA Fit-for-55
climate risk scenario analysis and the 2024 ECB Cyber
Resilience Stress Test Exercise. By performing these
exercises, the ECB assessed how banks are prepared to
deal with financial and economic shocks from climate
and cyber risk.
Starting on 1.1.2025 the calculation of Risk weighted
assets for credit risk is based on CRR3 regulation.
NLB Group is using Standardized approach, therefore
no materially significant changes in the calculated
volumes are expected. Nevertheless, the cumulative
result of the new regulation will lead to the increase
of RWA, primarily due to increased credit conversion
factor (CCF) for unused credit lines and introduction of
foreign exchange (FX) lending multiplier for lending to
private individuals in non-domestic currency. Partially
the increases will be compensated by more favourable
risk weights for residential real-estate collateral.
6. 1. Credit risk management
a) Introduction
In its operations, NLB Group is exposed to credit risk,
or the risk of losses due to the failure of a debtor to
settle its liabilities to NLB Group. For that reason,
it proactively and comprehensively monitors and
assesses the aforementioned risk. In that process, NLB
Group follows the International Financial Reporting
Standards, regulations issued by the European Central
Bank or Bank of Slovenia, and the EBA guidelines.
This area is governed in greater detail by the internal
methodologies and procedures set out in internal acts.
Through regular reviews of the business practices and
the credit portfolios of NLB entities, NLB ensures that
the credit risk management of those entities function
in accordance with NLB Group’s risk management
standards to enable meaningfully uniform procedures
at the consolidated level.
NLB Group manages credit risk using different
approaches:
- Risk Assessment and Monitoring:
At the level of the individual customer/group of
customers, appropriate procedures are followed in
various phases of the relationship with a customer
prior to, during, and after the conclusion of an
agreement. Prior to concluding an agreement, a
customer’s performance, financial position, and past
cooperation with NLB are assessed. To objectively
assess a client’s operation, internal scoring models for
particular client segments or product types have been
developed. It is also important to secure high-quality
collateral even though it does not affect a customer’s
credit rating. This is followed by various forms of
monitoring a customer, in particular an assessment
of its ability to generate sufficient cash flows for the
regular settlement of its liabilities and contractual
obligations. In this part of the credit process, regular
monitoring of clients within the Early Warning System
(EWS) is important. In the case of client default,
restructuring or work-out is initiated depending on
the severity of the client’s position.
- Performance Measurement and Reporting:
The quality and trends in the credit portfolio, including
on-balance and off-balance sheet exposures, are
actively monitored and analysed at the level of the
overall portfolio of NLB Group and single banking
entities. Comprehensive analyses are regularly
performed to assure monitoring of the portfolio
quality through time and to identify any breach of
limits or targets. Great emphasis is placed on the
evolution of portfolio structure in terms of client
segmentation, credit rating structure, structure by
stages (based on IFRS 9), and NPL ratios. Furthermore,
the coverage of NPL is an important indicator of
potential future losses that is closely monitored.
- Stress-testing and Scenario Analysis:
Regular stress-testing and scenario analyses are
conducted to assess the resilience of credit portfolio
under different economic conditions. These exercises
help in identifying vulnerabilities and formulating
contingency plans.
Beside default risk, portfolio management is also
focused on monitoring single name and industry
concentration, migration, FX lending, and the
Environmental and climate risks of the credit portfolio.
Capital requirements for credit risk at NLB Group
level within the first pillar are calculated according to
the Standardised approach, while within the second
pillar an internal IRB approach is used to estimate
the RWA for default, migration, and FX lending risk. In
addition, a single name concentration add-on is based
on the Granularity adjustment methodology, and an
industry concentration add-on is estimated based on
the HHI concentration indexes. NLB and other NLB
Group members assess the level of credit risk losses
on an individual basis for material claims, and at the
collective level for the rest of the portfolio.
An individual review is performed for material Stage
3 financial assets which have been rated as non-
performing based on the information regarding
significant financial problems encountered by a
customer, actual breaches of contractual obligations
such as arrears in the settlement of liabilities, whether
financial assets will be restructured for economic
or legal reasons, and the likelihood that a customer
will enter bankruptcy or a financial reorganisation.
Expected future cash flows (from ordinary operations
and possible redemption of collateral) are assessed
following an individual review. If their discounted value
differs from the book value of the financial asset in
question, impairment must be recognised.
Collective ECL allowances are made for the remainder
of the portfolio, which is not assessed on an individual
basis. Based on IFRS 9 requirements, financial assets
measured at amortised cost or at fair value through
other comprehensive income are attributed to the
appropriate stage based on the estimated increase of
credit risk of a single exposure since initial recognition.
The stage of financial assets determines whether a
12-month or lifetime ECL must be considered. The ECL
calculation is based on the forward-looking probability
of default (PD) and loss given default (LGD), which are
calculated using historic data and statistical modelling,
as well as predicted macroeconomic parameters for
different scenarios. For off-balance financial assets,
the probability of the redemption of guarantees is
considered when creating collective provisions. The
models used to estimate future risk parameters are
validated and backtested on a regular basis to make
loss estimations as realistic as possible.

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The management of ESG risks is incorporated in the
Group’s overall credit approval process and related
credit portfolio management. Sustainable financing is
addressed in the basic documentary framework:
- Lending Policy for Non-Financial Companies in
NLB d.d. and NLB Group where in the special sub-
chapter Environmental, Social and Governance
Framework three categories are defined (prohibited,
restricted, normal activities);
- The Environmental and Social Transaction Policy
Framework in NLB d.d. and NLB Group applies to
certain transactions with the greatest potential for
significant E&S impact (exclusion list, regulatory and
performance standards compliance check, project
categorisation);
- The Environmental and Social Transaction
Categorisation Methodology Framework in NLB d.d.
and NLB Group provides a guide to the typical level of
inherent environmental and social risk according to
NACE codes.
Beside addressing ESG risks in all relevant stages of
the credit-granting process, relevant ESG criteria were
also considered in the collateral evaluation process. On
the portfolio level, the Group does not face any large
concentration towards specific NACE industrial sectors
exposed to climate risk, whereby the role of transitional
risk is more prevailing. The availability of ESG data in
the region where NLB Group operates is still lacking,
nevertheless the Group has made material progress
in this respect in 2024 and has ambitious plans for the
following year.
b) Main emphasis in 2024
In the process of constantly complementing and
enhancing credit risk management, NLB Group focuses
on taking moderate risks, and at the same time ensuring
an optimal return considering the risks assumed.
Preserving high credit portfolio quality represents the
most important key aim, with a focus on the quality of
new placements leading to a diversified portfolio of
customers. The Group is actively present on the market
in the region, financing existing and new creditworthy
clients. To further enhance existing risk management
tools, the Group is constantly developing a wide range
of advanced approaches supported by mathematical
and statistical models in credit risk assessment in line
with best banking practises, while at the same time
enabling faster responsiveness towards clients.
Lending growth, which was modest in 2023 due to
increasing interest rate trends, picked up in 2024. In the
retail segment, the lending in fixed interest rates was
prevailing, especially in the housing loan market. In the
Corporate segment, the Bank seized opportunities to
finance some of the top corporate clients in the region
while keeping the focus on SME as its key segment.
The credit portfolio remains well-diversified, and there
is no large concentration in any specific industry or
client segment. The share of retail portfolio in the whole
credit portfolio is quite substantial, with still prevailing
segment of mortgage loans.
In 2024, the Group’s credit portfolio quality remained
solid with a stable rating structure and diversified
portfolio. Great emphasis was placed on intensive
and proactive handling of problematic customers and
customers active in the industries that are less stable
under the current economic circumstances. The bank
established an early warning system for detecting
increased credit risk at a very early stage. The stock
of NPE volume increased, primarily as a result of SLS
Group acquisition. As at 31 December 2024, the share
of non-performing exposure by EBA methodology in
NLB Group was 1.1% (the same as at the end of 2023).
Moreover, the coverage ratio remains high at 62.7%,
which is above the EU average published by the EBA
(41.6% in 3Q 2024).

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c) Maximum exposure to credit risk
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Cash, cash balances at central banks, and other demand deposits at banks
4,039,581
6,103,561
1,973,113
4,318,032
Financial assets held for trading
18,338
15,718
21,073
17,957
Non-trading financial assets mandatorily at fair value through profit or loss
1,000
5,217
3,964
7,785
Financial assets at fair value through other comprehensive income
2,466,923
2,164,464
1,601,875
962,084
Financial assets at amortised cost
Debt securities
3,725,195
2,522,229
2,846,779
1,966,169
Loans to governments
511,129
386,291
209,228
118,220
Loans to banks
458,921
547,640
193,172
149,011
Loans to financial organisations
149,132
91,523
1,326,073
384,995
Loans to individuals
8,557,705
7,086,815
3,882,210
3,543,603
Loans to companies
7,145,683
6,169,972
3,235,837
3,101,465
Other financial assets
136,854
165,962
81,518
101,596
Derivatives - hedge accounting
77,771
47,614
77,771
47,614
Total net financial assets
27,288,232
25,307,006
15,452,613
14,718,531
Guarantees
1,805,571
1,631,613
1,122,575
1,023,377
Financial guarantees
694,708
668,292
383,873
398,282
Non-financial guarantees
1,110,863
963,321
738,702
625,095
Loan commitments
2,640,323
2,469,800
1,940,563
1,822,847
Other potential liabilities
57,476
58,679
17,161
18,350
Total contingent liabilities
4,503,370
4,160,092
3,080,299
2,864,574
Total maximum exposure to credit risk
31,791,602
29,467,098
18,532,912
17,583,105
Maximum exposure to credit risk is a presentation
of NLB Group’s exposure to credit risk separately by
individual types of financial assets and contingent
liabilities. Exposures stated in the above table are
shown for the balance sheet items in their net book
value as reported in the statement of financial position,
and for off-balance sheet items in the amount of their
nominal value.

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d) Collaterals from financial assets measured at amortised cost
Collaterals from credit impaired financial assets measured at amortised cost
in EUR thousands
31 Dec 2024
NLB Group
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Financial assets at amortised cost
Loans to banks
-
-
-
136
-
-
Loans to individuals
47,477
27,871
128,687
99,187
21,244
7,319
Loans to other customers
97,394
48,781
308,698
86,255
25,333
31,754
Other financial assets
65
30
3,503
8,847
515
53
Total
144,936
76,682
440,888
194,425
47,092
39,126
in EUR thousands
31 Dec 2023
NLB Group
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Financial assets at amortised cost
Loans to banks
-
-
-
113
27
-
Loans to individuals
47,586
28,634
133,472
83,423
17,964
4,511
Loans to other customers
102,763
47,238
343,157
66,332
12,606
20,506
Other financial assets
119
57
4,507
10,484
405
54
Total
150,468
75,929
481,136
160,352
31,002
25,071

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Report
in EUR thousands
31 Dec 2024
NLB
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Financial assets at amortised cost
Loans to banks
-
-
-
136
-
-
Loans to individuals
29,840
15,986
73,399
50,299
8,594
2,489
Loans to other customers
27,961
10,648
98,625
39,882
8,591
11,609
Other financial assets
2
1
5
1,144
49
5
Total
57,803
26,635
172,029
91,461
17,234
14,103
in EUR thousands
31 Dec 2023
NLB
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Financial assets at amortised cost
Loans to banks
-
-
-
113
27
-
Loans to individuals
32,400
20,097
76,149
43,943
10,579
3,189
Loans to other customers
41,759
18,968
145,806
19,456
3,938
4,028
Other financial assets
7
2
355
1,655
146
10
Total
74,166
39,067
222,310
65,167
14,690
7,227

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Collaterals from financial assets measured at amortised cost classified into Stage 1 and 2
in EUR thousands
31 Dec 2024
NLB Group
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Financial assets at amortised cost
Debt securities
156,568
156,493
156,355
3,576,094
3,568,702
-
Loans to banks
194
194
195
458,831
458,727
37
Loans to individuals
3,999,354
3,981,774
8,539,514
4,588,971
4,526,816
418,328
Loans to other customers
2,968,522
2,944,379
7,647,688
4,834,250
4,787,451
843,348
Other financial assets
1,851
1,845
4,891
135,084
134,464
723
Total
7,126,489
7,084,685
16,348,643
13,593,230
13,476,160
1,262,436
in EUR thousands
31 Dec 2023
NLB Group
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Financial assets at amortised cost
Debt securities
113,822
113,724
113,161
2,413,929
2,408,505
-
Loans to banks
216
216
1,037
547,610
547,397
-
Loans to individuals
3,358,508
3,351,490
7,084,152
3,745,797
3,688,727
184,220
Loans to other customers
2,489,620
2,466,593
5,645,989
4,169,199
4,121,349
620,595
Other financial assets
1,440
1,436
3,296
164,724
164,064
487
Total
5,963,606
5,933,459
12,847,635
11,041,259
10,930,042
805,302

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Report
in EUR thousands
31 Dec 2024
NLB
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Financial assets at amortised cost
Debt securities
156,568
156,493
156,355
2,693,741
2,690,286
-
Loans to banks
-
-
-
193,342
193,172
-
Loans to individuals
2,059,295
2,051,482
4,411,879
1,825,755
1,806,148
31,114
Loans to other customers
1,062,028
1,059,346
2,390,689
3,716,001
3,692,553
361,951
Other financial assets
20
20
77
81,565
81,448
15
Total
3,277,911
3,267,341
6,959,000
8,510,404
8,463,607
393,080
in EUR thousands
31 Dec 2023
NLB
Fully/over collateralised financial assets
Financial assets not or not fully covered with collateral
Gross value of
financial assets
Net value of
financial assets
Fair value
of collateral
Gross value of
financial assets
Net value of
financial assets
Fair value of
collateral
Financial assets at amortised cost
Debt securities
113,822
113,724
113,161
1,855,144
1,852,445
-
Loans to banks
-
-
-
149,148
148,984
-
Loans to individuals
1,902,110
1,900,201
4,027,602
1,630,374
1,612,726
38,207
Loans to other customers
1,024,057
1,025,532
2,437,145
2,573,752
2,556,242
311,166
Other financial assets
44
44
130
101,504
101,404
18
Total
3,040,033
3,039,501
6,578,038
6,309,922
6,271,801
349,391
e) Collateral from loans mandatorily at fair value through profit or loss
in EUR thousands
31 Dec 2024
31 Dec 2023
NLB
Fully/over collateralised loans
Loans not or not fully covered with
collateral
Fully/over collateralised loans
Loans not or not fully covered with
collateral
Fair value
of loans
Fair value
of collateral
Fair value
of loans
Fair value of
collateral
Fair value
of loans
Fair value of
collateral
Fair value
of loans
Fair value of
collateral
Loans mandatorily at fair value
through profit or loss
76
149
3,888
2,030
70
149
7,715
5,800

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f) Credit protection policy
NLB Group applies a single set of standards to retail
and corporate loan collateral, as developed by NLB
Group members in accordance with regulatory
requirements. The master document regulating loan
collateral in the NLB Group is the Loan Collateral
Policy in NLB d.d. and NLB Group. The Policy has been
adopted by the Management Board of NLB Group. The
Policy represents the basic principles that NLB Group’s
employees must take into account when signing,
evaluating, monitoring, and reporting collateral, with
the aim of reducing credit risk.
In line with the policy, the primary source of loan
repayment is the debtor’s solvency, and the accepted
collateral is a secondary source of repayment in case
the debtor ceases to repay the contractual obligations.
NLB Group primarily accepts collateral complying with
the Basel II requirements with the aim of improving
credit risk management and consuming capital
economically. In accordance with Basel II, collateral may
consist of pledged deposits, government guarantees,
bank guarantees, debt securities issued by central
governments and central banks, bank debt securities,
and real-estate mortgages (the real estate must be,
beside other criteria, located in the European Economic
Area or in country recognised in EBA’s third party
equivalent list for the effect on capital to be recognised).
Loans made to companies and sole proprietors may
be secured by other forms of collateral, as well (e.g., a
lien on movable property, a pledge of an equity stake,
investment coupons, collateral by pledged/assigned
receivables, etc.) if it is assessed that the collateral could
generate a cash flow if it were needed as a secondary
source of payment. If there is a lower probability that
this type of collateral would generate a cash flow, NLB
Group takes a conservative approach and accepts the
collateral while reporting its value as zero.
From spring 2024 onwards, NLB Group has been
intensively preparing for the introduction of the
amended Basel III standards. The amended regulation
came into force on 1 January 2025 and brings changes
in particular in the area of mortgaged real estate. The
aim of the NLB Group’s adaptation is to establish such
collateral and monitoring in the application support
in order to be able to fully exploit the regulatory
opportunities to realise capital savings.
g) The processes for valuing collateral
In compliance with relevant regulations, NLB Group
has established a system for monitoring and reporting
collateral at fair (market) value.
The market value of real estate used as collateral is
obtained from valuation reports of licensed appraisers.
The market value of movable property is obtained
from valuation reports of licensed appraisers or from
sales agreements. Both, valuation reports and sales
agreements must not be older than one year. In NLB
and members of NLB Group, most reports of external
real estate appraisers are controlled. The controls
are performed by internal appraisers. The subject of
control is the content, value, scope, and format of the
report, its compliance with international valuation
standards, and the estimated value. If they notice
deviations, they estimate the needed correction of the
value of the external valuation (in %) and correct the
value of the external valuation. The value adjustment
can only be negative and can be applied only in a
limited range. For the purposes of business decisions
and the calculation of the necessary impairments and
provisions, additional deductions (haircuts) are applied
to the eventual adjusted market value, depending on
the type of collateral. These haircuts for purpose of
liquidation value are for real estate in the range of 30 to
70%, depending on the type of real estate and location,
and for movables they range between 50 and 100%,
depending on the type of movable.
The market value of financial instruments held by NLB
Group is obtained from the organised market – such
as the stock exchange, for listed financial instruments
or determined in accordance with the internal
methodology for unlisted financial instruments (such
collateral is used exceptionally and on a small scale in
loans granted to companies and sole proprietors).
NLB has compiled a reference list of licensed real
estate appraisers for real estate. All appraisals must
be made for the purpose of secured lending and in
accordance with the international valuation standards
(IVS, EVS, and RICS). Appraisals related to retail loans
are generally ordered only from appraisers with whom
the NLB has a contract for real-estate valuations. For
corporate loans, appraisals are usually submitted by
clients. If a client submits an appraisal that is not made
by an appraiser included on NLB’s reference list, NLB’s
expert department which employs certified real estate
appraisers in construction with licences granted by the
Slovenian Ministry of Justice, and certified real-estate
value appraisers with licences granted by the Slovenian
Institute of Auditors, will verify the appraisal. The expert
department is also responsible for reviewing valuations
of real estate serving as collateral for large loans.
Other NLB Group members obtain valuations from
in-house appraisers and outsourced appraisers,
all possessing the necessary licences. NLB Group
has compiled a reference list of appraisers for
valuations of real estate located outside the Republic
of Slovenia. Appraisals must be made in accordance
with the international valuation standards, and for
larger exposures, real-estate evaluations must also
be reviewed by an internal licensed appraiser with
knowledge of the local real-estate market. If the
appraisal does not correspond to the international
valuation standards or if the value adjustment is
greater than certain limit, the appraisal is rejected
as inadequate.
When assuring collateral, NLB Group follows the
internal regulations which define the minimum security
or pledge ratios. NLB Group strives to obtain collateral
with a higher value than the underlying exposure
(depending on the borrower’s rating, loan maturity,
etc.) with the aim of reducing negative consequences
resulting from any major swings in market prices of
the assets used as collateral. If real estate, movable
property, and financial instruments serve as collateral,
NLB Group’s lien on such assets should be top ranking.
Exceptionally, where the value of the mortgaged real
estate is large enough, the lien can have a different
priority order.
NLB Group monitors the value of collateral during
the loan repayment period in accordance with the
mandatory periods and internal instructions. For
example, the value of collateral using mortgaged
real estate is monitored annually, either by preparing
individual assessments or by using the internal
methodology for preparing an own value appraisal

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of real estate, based either on public records and
indexes of real-estate value published by the relevant
government authorities (the Surveying and Mapping
Authority in the Republic of Slovenia) or on analyses
carried out. The value of pledged movable property
is monitored once a year (in NLB automated, with
a straight-line depreciation over the period of the
remaining useful life).
h) The main types of collateral taken by the NLB Group
NLB Group accepts different forms of material and
personal security as loan collateral.
Material loan collateral gives the right in the case of
a debtor (borrower) defaulting on their contractual
obligations to sell a specific property to recover
claims, keep specific non-cash property or cash, or
reduce or offset the amount of exposure against the
counterparty’s debt to the Bank.
NLB Group accepts the following material types of
loan collateral:
- Collateral in the form of business and residential
real estate: land, buildings, and individual parts of
buildings in a storeyed property intended for living
in or performing a business activity, such as land
in the area foreseen for construction, apartments,
residential buildings, garages and holiday homes,
business premises, industrial buildings, offices, shops,
hotels, branches and warehouses, forests, parking
spaces, etc. The objects can be completed or under
construction. Priority is given to property where the
pledge right of the Bank is entered in the first place
and real estate is already owned by the debtor and/
or the pledger. For real estate, there must be a market,
and it must be redeemable within a reasonable time;
- Collateral in the form of movable property: priority
is given to the types of movable property, that are
highly likely to be sold in the event of execution, and
the funds received are used to repay the collateralised
claims (their market value must be estimated with
considerable reliability). Among the appropriate
types of movable property, the Bank includes motor
vehicles, agricultural machinery, construction
machinery, production lines, and series-produced
machines, and some custom-made production
machines;
- Collateral by a pledge of financial assets (bank
deposits or cash-like instruments, debt securities
of different issuers, investment fund units, equity
securities, or convertible bonds):
• Cash receivable collateral: bank deposits and
savings with Bank are appropriate in domestic
and foreign currency;
• Debt and equity securities: bonds and shares
which, according to the Bank’s assessment, are
suitable for securing investments and are traded
on a regulated market (marketable securities of
higher-quality Slovenian and foreign issuers);
• The pledge of investment coupons of mutual
funds managed by management companies (a
priority company NLB Skladi) and are, according
to the Bank’s assessment, suitable for insurance
of investments.
- A pledge of an equity stake: non-marketable capital
shares with a credit rating of at least B are adequate;
- A pledge or assignment of receivables as collateral:
cash receivables must have longer maturities than the
maturity of the investment and they must not be due
and not be paid;
- Other material forms of loan collateral (e.g., life
insurance policies pledged to NLB): The Bank accepts
products of Vita, life insurance company d.d. Ljubljana
– a pledge of an investment life insurance policy and
a life insurance policy with a guaranteed return that
includes saving, in addition to insurance.
Personal loan collateral is a method for reducing credit
risk whereby a third party undertakes to pay the debt
in case of the primary debtor (borrower) defaulting.
NLB Group accepts the following types of personal
loan collateral:
- Joint and several guarantees by retail and corporate
clients: for the collateralisation of private individuals’
loans, employees, or pensioners are adequate
guarantors. They must not be in the process of
personal bankruptcy. They are responsible for
fulfilling the debtor’s obligations for loans with a
repayment period not exceeding 60 months. For
the collateralisation of legal entities investments,
legal entities, individuals, or private individuals are
adequate guarantors;
- Bank guarantees;
- Government guarantees (e.g., of the Republic of
Slovenia);
- Guarantees by national and regional development
agencies with which the Bank has a contract on
the acceptance of guarantees (e.g. the Slovenian
Enterprise Fund);
- Other types of personal loan collateral.
Loans are very often secured by a combination of
collateral types. The general recommendations on loan
collateral are specified in the internal instructions and
include the elements specified below. The decision on the
type of collateral and the coverage of loan by collateral
depends on the client’s creditworthiness (credit rating),
loan maturity, and varies depending on whether the
loan is granted to retail or a corporate client.
NLB has also created, in the area of real-estate loan
collateral, an ‘online’ connection with the Surveying
and Mapping Authority in the Republic of Slovenia,
which allows direct and immediate verification of the
existence of property.
NLB Group strives to ensure the best possible
collateral for long-term loans, in particular mortgages
where possible. As a result, the mortgaging of real
estate is the most frequent form of loan collateral of
corporate and retail clients. In corporate exposures,
the next most frequent forms of collateral are
government and corporate guarantees, while in retail
loans, it is guarantors.
i) Risks, deriving from valuation of received collateral
Client/counterparty credit risk is the key decision
parameter when approving exposures. Collateral
is a secondary source of repayment, and therefore
decisions on the approvals of exposures should not
primarily be based on the provided collateral. However,
collateral is an important comfort element in the
approval process and, depending on the credit rating
of the client, a prerequisite. NLB Group has prescribed
the minimum ratios between the value of collateral and
the loan amount, depending on the type of collateral,
loan maturity, and the client rating. The ratios are
based on experience and regulatory guidelines.

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NLB Group pays particular attention to closely
monitoring the fair value of collateral, and to receiving
regular and independent revaluations by applying the
International Valuation Standards. Through a detailed
examination of all collateral received, NLB has ensured
that only collateral from which payment can be
realistically expected if it is liquidated, is considered.
NLB Group has the largest concentration of collaterals
arising from mortgages on real-estate, which is a
relatively reliable and quality type of collateral. Due to
the possible decrease of real-estate market prices, the
Group closely monitors the real-estate collateral values
and, where required, establishes higher amounts of
impairments and provisions for non-performing loans
secured by real-estate, based on estimated discounts
of the real-estate value, which are expected to be
achieved in a sale (expected payment from collateral).
Priority is given to property where the pledge right
of the Group is entered in the first place and the real-
estate is already owned by the debtor and/or the
pledger. For real-estate, there must be a market, and it
must be redeemable within a reasonable time.
Collateral consisting of securities entails market risk,
specifically the risk of changes in the prices of securities
on capital markets. To limit such risks and restrict
the possibility of the value of instruments received
as collateral falling below approved limits, the Rules
determine minimum pledge ratios for securing loans
based on pledged securities and equity shares in
NLB. Deviations from the Rules are subject to the prior
approval of the respective decision bodies of the Bank.
The ratio between the loan amount and the securities’
value is determined regarding the rating of the issuer,
the securities’ liquidity, maturity, and correlation with
changes in market indexes, i.e., by considering the key
features reflecting the level of volatility of market prices,
and the ability to sell the securities at the market price.
Collateral consisting of the sureties of corporate clients,
sureties of private individuals, and bank guarantees
entail the credit risk of the provider of the collateral.
NLB Group includes the amount of the guarantees
received in the exposure of the guarantor, and
guarantees are only taken into account as collateral if
the guarantor has sufficient overall creditworthiness.
Loan Collateral Policy in NLB d.d. and NLB Group
regulate which forms of collateral are acceptable, and
which preconditions a type of collateral needs to fulfil to
be able to be considered.

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j) Credit quality analysis for financial assets and contingent liabilities
in EUR thousands
NLB Group
NLB
31 Dec 2024
12-month
expected
credit
losses
Lifetime
ECL not
credit -
impaired
Lifetime
ECL credit-
impaired
Purchased
credit-
impaired
financial
assets
Total
12-month
expected
credit
losses
Lifetime
ECL not
credit -
impaired
Lifetime
ECL credit-
impaired
Purchased
credit-
impaired
financial
assets
Total
Debt securities at amortised cost
A
2,714,402
-
-
-
2,714,402
2,419,414
-
-
-
2,419,414
B
1,005,893
-
-
-
1,005,893
425,777
-
-
-
425,777
C
-
12,367
-
-
12,367
-
5,118
-
-
5,118
Loss allowance
(6,913)
(554)
-
-
(7,467)
(3,450)
(80)
-
-
(3,530)
Carrying amount
3,713,382
11,813
-
-
3,725,195
2,841,741
5,038
-
-
2,846,779
Loans and advances to banks at amortised cost
A
161,030
-
-
-
161,030
193,342
-
-
-
193,342
B
297,995
-
-
-
297,995
-
-
-
-
-
D and E
-
-
136
-
136
-
-
136
-
136
Loss allowance
(104)
-
(136)
-
(240)
(170)
-
(136)
-
(306)
Carrying amount
458,921
-
-
-
458,921
193,172
-
-
-
193,172
Loans and advances to individuals at amortised cost
A
7,213,612
113,659
-
567
7,327,838
2,762,800
37,680
-
553
2,801,033
B
901,722
131,949
-
186
1,033,857
810,920
99,668
-
186
910,774
C
62,678
163,668
-
284
226,630
59,757
113,232
-
254
173,243
D and E
-
-
135,383
11,281
146,664
-
-
78,441
1,698
80,139
Loss allowance
(45,083)
(34,959)
(94,333)
(2,909)
(177,284)
(9,430)
(18,297)
(54,133)
(1,119)
(82,979)
Carrying amount
8,132,929
374,317
41,050
9,409
8,557,705
3,624,047
232,283
24,308
1,572
3,882,210
Loans and advances to other customers at amortised cost
A
1,577,298
2,304
-
122
1,579,724
2,162,169
555
-
-
2,162,724
B
5,384,507
204,865
-
1,284
5,590,656
2,225,505
73,908
-
138
2,299,551
C
214,490
415,194
-
2,708
632,392
64,988
250,586
-
180
315,754
D and E
-
-
161,660
21,989
183,649
-
-
57,690
10,153
67,843
Loss allowance
(43,504)
(28,928)
(103,679)
(4,366)
(180,477)
(12,254)
(14,038)
(41,970)
(6,472)
(74,734)
Carrying amount
7,132,791
593,435
57,981
21,737
7,805,944
4,440,408
311,011
15,720
3,999
4,771,138
Other financial assets at amortised cost
A
124,420
127
-
-
124,547
76,951
1
-
-
76,952
B
10,022
224
-
-
10,246
4,271
50
-
-
4,321
C
1,120
1,022
-
-
2,142
200
112
-
-
312
D and E
-
-
8,863
49
8,912
-
-
1,127
19
1,146
Loss allowance
(572)
(54)
(8,351)
(16)
(8,993)
(115)
(2)
(1,078)
(18)
(1,213)
Carrying amount
134,990
1,319
512
33
136,854
81,307
161
49
1
81,518
Debt instruments at fair value through other comprehensive income
A
1,795,347
-
-
-
1,795,347
1,489,490
-
-
-
1,489,490
B
700,979
-
-
-
700,979
127,200
-
-
-
127,200
C
-
123
-
-
123
-
-
-
-
-
D and E
-
-
798
-
798
-
-
798
-
798
Loss allowance
(4,959)
(36)
(798)
-
(5,793)
(1,849)
-
(798)
-
(2,647)
Contingent liabilities
A
1,920,809
4,505
-
3
1,925,317
1,518,483
2,518
-
3
1,521,004
B
2,390,472
49,399
-
255
2,440,126
1,454,857
13,252
-
255
1,468,364
C
45,518
80,481
-
7
126,006
27,819
56,396
-
7
84,222
D and E
-
-
11,642
279
11,921
-
-
6,430
279
6,709
Loss allowance
(11,953)
(2,306)
(7,329)
(262)
(21,850)
(3,851)
(834)
(4,293)
(262)
(9,240)
Carrying amount
4,344,846
132,079
4,313
282
4,481,520
2,997,308
71,332
2,137
282
3,071,059

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in EUR thousands
NLB Group
NLB
31 Dec 2023
12-month
expected
credit
losses
Lifetime
ECL not
credit -
impaired
Lifetime
ECL credit-
impaired
Purchased
credit-
impaired
financial
assets
Total
12-month
expected
credit
losses
Lifetime
ECL not
credit -
impaired
Lifetime
ECL credit-
impaired
Purchased
credit-
impaired
financial
assets
Total
Debt securities at amortised cost
A
1,779,525
-
-
-
1,779,525
1,590,676
-
-
-
1,590,676
B
735,905
-
-
-
735,905
373,190
-
-
-
373,190
C
-
12,321
-
-
12,321
-
5,100
-
-
5,100
Loss allowance
(4,946)
(576)
-
-
(5,522)
(2,624)
(173)
-
-
(2,797)
Carrying amount
2,510,484
11,745
-
-
2,522,229
1,961,242
4,927
-
-
1,966,169
Loans and advances to banks at amortised cost
A
166,615
-
-
-
166,615
145,666
-
-
-
145,666
B
381,211
-
-
-
381,211
3,482
-
-
-
3,482
D and E
-
-
113
-
113
-
-
113
-
113
Loss allowance
(213)
-
(86)
-
(299)
(164)
-
(86)
-
(250)
Carrying amount
547,613
-
27
-
547,640
148,984
-
27
-
149,011
Loans and advances to individuals at amortised cost
A
6,787,523
111,211
-
632
6,899,366
3,373,404
77,225
-
313
3,450,942
B
64,863
55,590
-
10
120,463
6,109
31,221
-
8
37,338
C
2,339
81,623
-
514
84,476
-
43,815
-
389
44,204
D and E
-
-
126,743
4,266
131,009
-
-
72,822
3,521
76,343
Loss allowance
(39,668)
(25,051)
(82,756)
(1,024)
(148,499)
(8,072)
(11,489)
(43,908)
(1,755)
(65,224)
Carrying amount
6,815,057
223,373
43,987
4,398
7,086,815
3,371,441
140,772
28,914
2,476
3,543,603
Loans and advances to other customers at amortised cost
A
1,344,256
3,758
-
-
1,348,014
1,167,563
1,961
-
-
1,169,524
B
4,724,560
158,829
-
12
4,883,401
2,182,739
59,001
-
-
2,241,740
C
138,837
288,567
-
-
427,404
84,531
102,014
-
-
186,545
D and E
-
-
152,759
16,336
169,095
-
-
49,049
12,166
61,215
Loss allowance
(51,087)
(19,778)
(103,278)
(5,985)
(180,128)
(13,482)
(2,553)
(32,631)
(5,678)
(54,344)
Carrying amount
6,156,566
431,376
49,481
10,363
6,647,786
3,421,351
160,423
16,418
6,488
3,604,680
Other financial assets at amortised cost
A
125,514
77
-
-
125,591
83,727
25
-
-
83,752
B
39,042
156
-
-
39,198
17,580
50
-
-
17,630
C
819
556
-
-
1,375
122
44
-
-
166
D and E
-
-
9,346
1,257
10,603
-
-
1,658
4
1,662
Loss allowance
(624)
(40)
(8,910)
(1,231)
(10,805)
(98)
(2)
(1,512)
(2)
(1,614)
Carrying amount
164,751
749
436
26
165,962
101,331
117
146
2
101,596
Debt instruments at fair value through other comprehensive income
A
1,221,592
-
-
-
1,221,592
854,472
-
-
-
854,472
B
1,031,205
-
-
-
1,031,205
154,461
-
-
-
154,461
C
-
144
-
-
144
-
-
-
-
-
D and E
-
-
798
-
798
-
-
-
798
798
Loss allowance
(6,475)
(56)
(798)
-
(7,329)
(1,650)
-
-
(798)
(2,448)
Contingent liabilities
A
1,691,834
26,522
-
37
1,718,393
1,358,079
25,286
-
10
1,383,375
B
2,286,997
33,489
-
11
2,320,497
1,383,937
25,497
-
1
1,409,435
C
53,728
46,605
-
170
100,503
41,961
15,836
-
56
57,853
D and E
-
-
17,221
3,478
20,699
-
-
10,613
3,298
13,911
Loss allowance
(18,429)
(1,655)
(9,369)
(3,095)
(32,548)
(7,653)
(319)
(7,034)
(2,935)
(17,941)
Carrying amount
4,014,130
104,961
7,852
601
4,127,544
2,776,324
66,300
3,579
430
2,846,633

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Sustainability
Statement
Financial
Report
NLB Group’s client credit rating classification is based
on an internally developed methodologies, drawing
from internal statistical analyses, good banking
practices, as well as Bank of Slovenia regulations, and
ECB and EBA guidelines and requirements. The rating
methodologies are used across the entire NLB Group.
They include a uniform credit grade scale of 12 rating
classes, out of which nine represent performing clients
and three non-performing clients.
Rating Group A (AAA to A rating classes) includes the
best clients with a low degree of default probability,
characterised by high coverage of financial liabilities
with free cash flow. The Rating Group A is considered as
investment grade classification.
Rating Group B (BBB to B rating classes) includes
clients with a low credit risk, starting one notch higher
than at ‘A’ rating group clients. These clients show
stable performance, acceptable financial ratios, and
qualitative elements, and have sufficient cash flow to
settle their obligations, but may be more sensitive to
changes in the industry or the economy. The Rating
Group B classification is an investment grade for BBB,
and an ‘invest with care’ for BB and B rating classes.
Rating Group C (CCC to C rating classes) includes clients
who are exposed to a higher and above-average level
of credit risk. CCC-rated clients are financed by the
Bank only in the case when such support brings more
positive effects for the Bank; however, Rating Group C
is overall considered as a substantial risk. The Bank
reasonably restricts cooperation with such clients and
decreases its exposure to them.
Rating Groups D (D and DF rating classes) and E
represent non-performing clients that are treated
as defaulted. D, DF, and E rating classified clients
are ordinarily transferred to the specialised units for
restructuring (which performs business and financial
restructuring with a goal of minimising losses and
restoring the client to a performing status) or workout
and legal support (with the goal of minimising losses
due to default).
The NLB Group ratings in the master scale are mapped
to the following PD structure:
Rating class
Average PD in %
AAA
0.05
AA
0.15
A
0.30
BBB
0.60
BB
1.20
B
2.40
CCC
4.80
CC
9.60
C
19.20
D
100
DF
100
E
100
NLB Group applies the default definition based on the
EBA guidelines, where the materiality threshold for
delays is determined in absolute and relative terms
(EUR 100 for retail and EUR 500 for the non-retail
segment and 1% of the total on-balance exposure on
the client level). In 2023, a scoring model for private
individual clients came into effect in NLB d.d., while
the models in banking subsidiaries were deployed in
2024, which will enable higher degree of differentiation
among the clients as it introduces nine performing
rating classes (instead of the previous three).
A general corporate rating methodology, with
the prescribed set of parameters (qualitative and
quantitative) applies to all the NLB Group entities.
Groups of connected clients are treated as materially
important for the NLB Group whenever exposure
exceeds EUR 7 million for NLB Group members with
total assets lower than EUR 1.5 billion, EUR 15 million
for NLB Group members with total assets between
EUR 1.5 billion and EUR 4.0 billion, or EUR 20 million for
NLB Group members with total assets above EUR 4.0
billion. Materially important clients are ordinary under
authority of the NLB Credit Committee.
NLB regularly reviews the business practices and credit
portfolios of NLB Group entities to make sure they
are operating in accordance with the minimum risk
management standards of NLB Group. This ensures
appropriate standard processes for managing and
reporting credit risks at the consolidated level.

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
k) Forborne loans and advances
in EUR thousands
31 Dec 2024
NLB Group
All forborne exposures
Impairment, provisions and value
adjustments
Collateral
and financial
guarantees
received on
forborne
exposures
Gross
carrying
amount
Performing
Non - performing
Performing
forborne
exposures
Non-performing
forborne
exposures
Impaired
Defaulted
Loans and advances (including at
amortised cost and fair value)
220,566
104,419
116,147
116,147
(10,089)
(79,861)
98,496
Governments
544
247
297
297
(7)
(297)
-
Other financial organisations
457
-
457
457
-
(457)
-
Non-financial organisations
128,446
54,637
73,809
73,809
(2,062)
(52,107)
67,158
Households
91,119
49,535
41,584
41,584
(8,020)
(27,000)
31,338
Loan commitments given
1,018
866
152
152
(2)
(47)
906
Total exposures with forbearance measures
221,584
105,285
116,299
116,299
(10,091)
(79,908)
99,402
in EUR thousands
31 Dec 2023
NLB Group
All forborne exposures
Impairment, provisions and value
adjustments
Collateral
and financial
guarantees
received on
forborne
exposures
Gross
carrying
amount
Performing
Non - performing
Performing
forborne
exposures
Non-performing
forborne
exposures
Impaired
Defaulted
Loans and advances (including at
amortised cost and fair value)
246,402
116,477
129,874
129,925
(7,883)
(81,121)
92,352
Governments
624
419
205
205
(22)
(205)
-
Other financial organisations
1,388
-
1,388
1,388
-
(1,388)
-
Non-financial organisations
168,726
77,709
90,966
91,017
(3,857)
(59,606)
58,611
Households
75,664
38,349
37,315
37,315
(4,004)
(19,922)
33,741
Loan commitments given
434
84
350
350
(1)
(27)
352
Total exposures with forbearance measures
246,836
116,561
130,224
130,275
(7,884)
(81,148)
92,704

NLB Group
Annual Report 2024
498
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
31 Dec 2024
NLB
All forborne exposures
Impairment, provisions and value
adjustments
Collateral
and financial
guarantees
received on
forborne
exposures
Gross
carrying
amount
Performing
Non - performing
Performing
forborne
exposures
Non-performing
forborne
exposures
Impaired
Defaulted
Loans and advances (including at
amortised cost and fair value)
129,624
67,114
62,510
62,510
(7,997)
(46,847)
51,358
Governments
125
-
125
125
-
(125)
-
Other financial organisations
457
-
457
457
-
(457)
-
Non-financial organisations
51,956
25,233
26,723
26,723
(502)
(22,733)
26,650
Households
77,086
41,881
35,205
35,205
(7,495)
(23,532)
24,708
Loan commitments given
313
169
144
144
(2)
(42)
209
Total exposures with forbearance measures
129,937
67,283
62,654
62,654
(7,999)
(46,889)
51,567
in EUR thousands
31 Dec 2023
NLB
All forborne exposures
Impairment, provisions and value
adjustments
Collateral
and financial
guarantees
received on
forborne
exposures
Gross
carrying
amount
Performing
Non - performing
Performing
forborne
exposures
Non-performing
forborne
exposures
Impaired
Defaulted
Loans and advances (including at
amortised cost and fair value)
110,905
42,584
68,270
68,321
(3,718)
(41,050)
53,937
Other financial organisations
1,388
-
1,388
1,388
-
(1,388)
-
Non-financial organisations
50,979
15,166
35,762
35,813
(70)
(23,142)
27,232
Households
58,538
27,418
31,120
31,120
(3,648)
(16,520)
26,705
Loan commitments given
434
84
350
350
(1)
(27)
352
Total exposures with forbearance measures
111,339
42,668
68,620
68,671
(3,719)
(41,077)
54,289

NLB Group
Annual Report 2024
499
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Forborne exposures of loans and advances by periods of forbearance
in EUR thousands
NLB Group
31 Dec 2024
Up to 3 months
3 to 6 months
6 to 12 months
Over 12 months
Performing exposures
28,990
5,151
16,141
44,048
Non-performing exposures
3,210
1,891
3,515
27,669
Total exposures with forbearance measures
32,200
7,042
19,656
71,717
31 Dec 2023
Performing exposures
7,519
1,813
8,140
91,122
Non-performing exposures
1,569
6,838
5,071
35,275
Total exposures with forbearance measures
9,088
8,651
13,211
126,397

in EUR thousands
NLB
31 Dec 2024
Up to 3 months
3 to 6 months
6 to 12 months
Over 12 months
Performing exposures
14,634
4,078
14,046
26,359
Non-performing exposures
2,038
1,522
2,155
9,948
Total exposures with forbearance measures
16,672
5,600
16,201
36,307
31 Dec 2023
Performing exposures
7,059
1,690
2,880
27,237
Non-performing exposures
1,312
6,634
2,455
16,819
Total exposures with forbearance measures
8,371
8,324
5,335
44,056

The main forbearance measurements used by
NLB Group and NLB are: deferral of payment,
reduction of interest rates, acquisition of collateral
for partial repayment of claims, and others, either as
a single forbearance measurement or as a
combination of those.
l) Repossessed assets
NLB Group and NLB received the following assets by
taking possession of collateral held as security and
held them at the reporting date:
in EUR thousands
NLB Group
NLB
Net value
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Nature of assets
Investment property (note 5.9.)
17,844
21,253
619
2,263
Property and equipment (note 5.8.)
1,644
11,641
-
-
Investments in subsidiaries and associates
-
-
530
530
Real estates (note 5.13.)
18,976
27,122
1,468
3,129
Other assets (note 5.13.)
1,622
515
-
-
Non-current assets held for sale (note 5.7.)
7,191
474
-
-
Total
47,277
61,005
2,617
5,922

NLB Group
Annual Report 2024
500
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
m) Analysis of loans and advances by industry sectors
in EUR thousands
NLB Group
31 Dec 2024
31 Dec 2023
Industry sector
Gross loans
Impairment
provisions
Net loans
(%)
Gross loans
Impairment
provisions
Net loans
(%)
Banks
459,161
(240)
458,921
2.71
547,939
(299)
547,640
3.79
Finance
228,729
(1,759)
226,970
1.34
154,385
(2,321)
152,064
1.05
Electricity, gas, and water
682,054
(6,781)
675,273
3.98
599,988
(9,284)
590,704
4.09
Construction industry
731,917
(18,724)
713,193
4.21
535,444
(23,798)
511,646
3.54
Heavy industry
1,719,369
(44,177)
1,675,192
9.88
1,487,769
(29,619)
1,458,150
10.09
Education
22,247
(564)
21,683
0.13
14,278
(481)
13,797
0.10
Agriculture, forestry, and fishing
132,097
(3,973)
128,124
0.76
108,204
(3,536)
104,668
0.72
Public sector
429,321
(3,558)
425,763
2.51
390,522
(4,234)
386,288
2.67
Individuals
8,734,987
(177,282)
8,557,705
50.46
7,235,314
(148,499)
7,086,815
49.05
Mining
42,036
(842)
41,194
0.24
45,801
(1,733)
44,068
0.31
Entrepreneurs
485,774
(7,785)
477,989
2.82
388,668
(7,604)
381,064
2.64
Services
1,180,787
(34,029)
1,146,758
6.76
929,438
(34,385)
895,053
6.19
Transport and communications
826,287
(21,530)
804,757
4.75
884,162
(20,676)
863,486
5.98
Trade industry
1,462,654
(36,306)
1,426,348
8.41
1,254,749
(41,550)
1,213,199
8.40
Health care and social security
43,151
(451)
42,700
0.25
34,506
(907)
33,599
0.23
Other financial assets
145,847
(8,993)
136,854
0.81
176,767
(10,805)
165,962
1.15
Total
17,326,418
(366,994)
16,959,424
100.00
14,787,934
(339,731)
14,448,203
100.00
in EUR thousands
NLB
31 Dec 2024
31 Dec 2023
Industry sector
Gross loans
Impairment
provisions
Net loans
(%)
Gross loans
Impairment
provisions
Net loans
(%)
Banks
193,478
(306)
193,172
2.16
149,261
(250)
149,011
2.01
Finance
1,397,781
(4,142)
1,393,639
15.60
440,080
(2,914)
437,166
5.90
Electricity, gas, and water
466,900
(2,863)
464,037
5.20
429,569
(2,577)
426,992
5.76
Construction industry
191,539
(8,229)
183,310
2.05
131,462
(8,652)
122,810
1.66
Heavy industry
936,494
(23,615)
912,879
10.22
847,052
(11,135)
835,917
11.29
Education
8,671
(423)
8,248
0.09
3,509
(63)
3,446
0.05
Agriculture, forestry, and fishing
18,775
(111)
18,664
0.21
14,566
(65)
14,501
0.20
Public sector
125,747
(485)
125,262
1.40
116,388
(824)
115,564
1.56
Individuals
3,965,189
(82,979)
3,882,210
43.46
3,608,827
(65,224)
3,543,603
47.84
Mining
18,475
(16)
18,459
0.21
19,996
(71)
19,925
0.27
Entrepreneurs
89,796
(2,848)
86,948
0.97
83,802
(2,753)
81,049
1.09
Services
700,644
(17,287)
683,357
7.65
607,989
(15,368)
592,621
8.00
Transport and communications
489,078
(3,608)
485,470
5.44
580,244
(3,814)
576,430
7.78
Trade industry
379,557
(10,957)
368,600
4.13
370,514
(5,521)
364,993
4.93
Health care and social security
26,379
(150)
26,229
0.29
21,638
(587)
21,051
0.28
Other financial assets
82,731
(1,213)
81,518
0.91
103,210
(1,614)
101,596
1.37
Total
9,091,234
(159,232)
8,932,002
100.00
7,528,107
(121,432)
7,406,675
100.00

NLB Group
Annual Report 2024
501
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
n) Analysis of net loans and advances by geographical sectors
in EUR thousands
NLB Group
NLB
Country
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Slovenia
7,969,478
6,705,660
8,006,737
6,701,924
Other European Union members
720,158
414,732
375,666
222,556
Serbia
3,755,300
3,306,766
225,207
193,376
Other countries
4,514,488
4,021,045
324,392
288,819
Total
16,959,424
14,448,203
8,932,002
7,406,675

NLB Group
Annual Report 2024
502
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
o) Analysis of debt securities and derivative financial instruments by geographical sectors
in EUR thousands
31 Dec 2024
NLB Group
NLB
Country
Financial assets
measured at
amortised cost
Financial
assets held
for trading
Financial assets
measured
at fair value
through OCI
Non-trading
financial assets
mandatorily at
FV through
profit or loss
Derivative
financial
instruments
Financial assets
measured at
amortised cost
Financial
assets held
for trading
Financial assets
measured
at fair value
through OCI
Derivative
financial
instruments
Slovenia
525,678
-
402,577
107
390
511,251
-
377,523
390
Other members of European Union
2,342,901
2,036
1,267,941
893
85,264
2,125,674
2,036
1,055,216
85,264
- Austria
168,320
-
103,179
-
-
137,890
-
61,437
-
- Belgium
328,701
-
308,327
-
13,311
256,430
-
265,469
13,311
- Bulgaria
46,205
-
-
-
-
46,205
-
-
-
- Cyprus
23,191
-
1,529
-
-
23,191
-
1,529
-
- Denmark
36,232
-
4,369
-
-
36,232
-
4,369
-
- Estonia
13,834
-
-
-
-
13,834
-
-
-
- Finland
115,999
-
99,633
-
-
86,118
-
87,227
-
- France
360,058
-
213,353
-
18,437
323,246
-
152,646
18,437
- Germany
204,034
2,036
166,371
893
34,374
180,109
2,036
131,702
34,374
- Hungary
49,125
-
5,769
-
-
49,125
-
5,769
-
- Ireland
73,921
-
18,630
-
17,387
73,921
-
18,630
17,387
- Italy
70,985
-
9,231
-
-
70,985
-
9,231
-
- Latvia
30,324
-
-
-
-
30,324
-
-
-
- Lithuania
27,701
-
-
-
-
27,701
-
-
-
- Luxembourg
153,457
-
124,075
-
-
153,457
-
124,075
-
- Malta
41,281
-
-
-
-
41,281
-
-
-
- Netherlands
168,307
-
79,593
-
1,755
144,399
-
59,250
1,755
- Poland
58,091
-
4,073
-
-
58,091
-
4,073
-
- Portugal
47,147
-
16,470
-
-
47,147
-
16,470
-
- Romania
60,950
-
5,066
-
-
60,950
-
5,066
-
- Slovakia
91,839
-
4,950
-
-
91,839
-
4,950
-
- Spain
120,383
-
65,491
-
-
120,383
-
65,491
-
- Sweden
50,784
-
37,832
-
-
50,784
-
37,832
-
- Other
2,032
-
-
-
-
2,032
-
-
-
United States of America
84,268
7,388
77,416
-
-
28,204
7,388
13,608
-
Other countries
772,348
-
718,989
-
1,031
181,650
-
155,528
3,766
- Bosnia and Herzegovina
90,442
-
108,057
-
-
4,074
-
3,095
-
- Kosovo
-
-
30,355
-
23
-
-
-
23
- Montenegro
25,942
-
19,203
-
-
6,787
-
3,057
2,423
- North Macedonia
206,379
-
116,933
-
9
13,107
-
47,339
-
- Serbia
299,661
-
347,105
-
989
14,941
-
4,701
1,310
- Albania
-
-
28,339
-
-
-
-
28,339
-
- Canada
55,418
-
7,557
-
-
55,418
-
7,557
-
- Great Britain
21,239
-
35,875
-
10
14,056
-
35,875
10
- Iceland
10,669
-
8,497
-
-
10,669
-
8,497
-
- Israel
7,839
-
9,392
-
-
7,839
-
9,392
-
- Kazakhstan
-
-
7,676
-
-
-
-
7,676
-
- Mexico
10,505
-
-
-
-
10,505
-
-
-
- Norway
21,264
-
-
-
-
21,264
-
-
-
- Other
22,990
-
-
-
-
22,990
-
-
-
Total
3,725,195
9,424
2,466,923
1,000
86,685
2,846,779
9,424
1,601,875
89,420
Other members of the European Union included in the line item ‘Other’ is Greece.
Other members of the ‘Other countries’ in the line item ‘Other’ are Chile, South Korea, Egypt, Brazil, and Oman.

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
31 Dec 2023
NLB Group
NLB
Country
Financial assets
measured at
amortised cost
Financial assets
measured at fair
value through OCI
Non-trading
financial assets
mandatorily at
FV through
profit or loss
Derivative
financial
instruments
Financial assets
measured at
amortised cost
Financial assets
measured at fair
value through OCI
Derivative
financial
instruments
Slovenia
428,163
274,855
-
1,092
416,679
219,307
1,092
Other members of European Union
1,567,873
805,334
5,217
35,121
1,440,075
551,192
35,121
- Austria
113,531
77,472
707
-
105,552
46,541
-
- Belgium
173,326
84,471
706
7,819
156,407
34,407
7,819
- Bulgaria
34,226
1,002
-
-
34,226
1,002
-
- Czech Republic
12,975
-
-
-
12,975
-
-
- Cyprus
18,172
1,550
-
-
18,172
1,550
-
- Denmark
16,662
8,187
-
-
16,662
8,187
-
- Estonia
5,640
-
-
-
5,640
-
-
- Finland
67,257
90,419
707
-
59,293
57,919
-
- France
239,395
136,115
-
9,227
211,895
92,483
9,227
- Germany
167,538
107,278
505
12,301
136,969
54,500
12,301
- Hungary
45,211
5,639
-
-
45,211
5,639
-
- Ireland
58,793
31,191
-
2,677
52,634
29,141
2,677
- Italy
51,566
5,989
100
-
51,566
5,989
-
- Latvia
23,276
-
-
-
23,276
-
-
- Lithuania
20,596
-
-
-
20,596
-
-
- Luxembourg
69,567
7,337
-
-
69,567
7,337
-
- Malta
27,442
-
-
-
27,442
-
-
- Netherlands
117,309
112,840
2,492
3,097
91,519
70,653
3,097
- Poland
35,024
7,126
-
-
35,024
7,126
-
- Portugal
42,677
16,574
-
-
42,677
16,574
-
- Romania
53,190
5,013
-
-
53,190
5,013
-
- Slovakia
63,406
18,900
-
-
58,488
18,900
-
- Spain
67,471
40,190
-
-
67,471
40,190
-
- Sweden
41,597
48,041
-
-
41,597
48,041
-
- Other
2,026
-
-
-
2,026
-
-
United States of America
37,158
58,889
-
-
6,831
7,427
-
Other countries
489,035
1,025,385
-
27,119
102,584
184,158
29,358
- Bosnia and Herzegovina
59,073
132,027
-
-
4,064
2,917
-
- Kosovo
-
48,614
-
20
-
-
20
- Montenegro
60,109
22,665
-
-
6,760
3,008
2,243
- North Macedonia
154,398
115,535
-
29
13,129
46,539
7
- Serbia
140,796
579,332
-
821
3,972
4,482
839
- Albania
-
27,819
-
-
-
27,819
-
- Canada
26,681
12,133
-
-
26,681
12,133
-
- Great Britain
1,638
51,436
-
26,249
1,638
51,436
26,249
- Iceland
7,737
8,205
-
-
7,737
8,205
-
- Israel
7,408
9,062
-
-
7,408
9,062
-
- Kazakhstan
-
7,507
-
-
-
7,507
-
- Norway
19,303
6,465
-
-
19,303
6,465
-
- Other
11,892
4,585
-
-
11,892
4,585
-
Total
2,522,229
2,164,463
5,217
63,332
1,966,169
962,084
65,571
Other members of the European Union included in the line item ‘Other’ is Greece.
Other members of the ‘Other countries’ in the line item ‘Other’ are Egypt, Uzbekistan, South Korea, and Oman.

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Performance Overview
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Statement
Financial
Report
p) Internal rating of derivatives counterparties
in %
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
A
94.34
92.94
94.72
93.80
B
5.58
6.91
5.20
6.06
C
0.04
0.08
0.04
0.07
D and E
0.04
0.08
0.04
0.07
Total
100.00
100.00
100.00
100.00
All derivatives in the banking book are entered into with
counterparties with an external investment-grade rating.
When derivatives are entered into on behalf of NLB
Group’s customers, such customers usually do not
have an external rating, but all such transactions are
covered through back-to-back transactions involving
third parties with an external investment-grade rating.
r) Debt financial instruments in NLB Group’s and NLB’s portfolio that represent subordinated liabilities for the issuer
in EUR thousands
31 Dec 2024
NLB Group
NLB
Internal rating
A
B
C
D
Total
A
B
C
D
Total
Financial assets measured at fair value
through other comprehensive income
25,162
2,491
-
-
27,653
25,162
2,491
-
-
27,653
Financial assets measured at amortised cost
- debt securities
34,494
5,927
-
-
40,421
34,494
5,927
-
-
40,421
- loans and advances to banks
-
-
-
-
-
114,702
-
-
-
114,702
- loans and advances to customers
-
-
-
-
-
-
-
7,124
-
7,124
Total
59,656
8,418
-
-
68,074
174,358
8,418
7,124
-
189,900
in EUR thousands
31 Dec 2023
NLB Group
NLB
Internal rating
A
B
C
D
Total
A
B
C
D
Total
Financial assets measured at fair value
through other comprehensive income
28,421
-
-
-
28,421
28,421
-
-
-
28,421
Financial assets measured at amortised cost
- debt securities
9,484
-
-
-
9,484
9,484
-
-
-
9,484
- loans and advances to banks
-
-
-
-
-
90,153
-
-
-
90,153
- loans and advances to customers
-
-
-
-
-
-
-
7,050
-
7,050
Total
37,905
-
-
-
37,905
128,058
-
7,050
-
135,108

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Financial
Report
s) Presentation of net financial instruments by measurement category
in EUR thousands
NLB Group
31 Dec 2024
Financial assets
held for trading
Non-trading financial
assets mandatorily
at FV through P&L
Financial assets
measured at FV
through OCI
Financial assets
measured at
amortised cost
Financial
leases
Derivatives for
hedge accounting
Total
Cash and obligatory reserves
with central banks, and other
demand deposits at banks
-
-
-
4,039,581
-
-
4,039,581
Securities
9,424
17,429
2,563,516
3,725,195
-
-
6,315,564
- Bonds
9,424
1,000
2,262,669
3,725,195
-
-
5,998,288
- Shares
-
8,650
96,593
-
-
-
105,243
- Commercial bills
-
-
30,640
-
-
-
30,640
- Treasury bills
-
-
173,614
-
-
-
173,614
- Investment funds
-
7,779
-
-
-
-
7,779
Derivatives
8,914
-
-
-
-
77,771
86,685
Loans and receivables
-
-
-
15,603,331
1,219,239
-
16,822,570
- Loans to governments
-
-
-
510,872
257
-
511,129
- Loans to banks
-
-
-
458,856
65
-
458,921
- Loans to financial organisations
-
-
-
148,364
768
-
149,132
- Loans to individuals
-
-
-
7,942,741
614,964
-
8,557,705
- Loans to other customers
-
-
-
6,542,499
603,184
-
7,145,683
Other financial assets
-
-
-
136,854
-
-
136,854
Total financial assets
18,338
17,429
2,563,516
23,504,961
1,219,239
77,771
27,401,254
in EUR thousands
NLB Group
31 Dec 2023
Financial assets
held for trading
Non-trading financial
assets mandatorily
at FV through P&L
Financial assets
measured at FV
through OCI
Financial assets
measured at
amortised cost
Financial
leases
Derivatives for
hedge accounting
Total
Cash and obligatory reserves
with central banks, and other
demand deposits at banks
-
-
-
6,103,561
-
-
6,103,561
Securities
-
14,175
2,251,556
2,522,229
-
-
4,787,960
- Bonds
-
5,217
1,836,604
2,522,229
-
-
4,364,050
- Shares
-
6,300
87,092
-
-
-
93,392
- Commercial bills
-
-
26,022
-
-
-
26,022
- Treasury bills
-
-
301,838
-
-
-
301,838
- Investment funds
-
2,658
-
-
-
-
2,658
Derivatives
15,718
-
-
-
-
47,614
63,332
Loans and receivables
-
-
-
13,945,973
336,268
-
14,282,241
- Loans to governments
-
-
-
386,059
232
-
386,291
- Loans to banks
-
-
-
547,640
-
-
547,640
- Loans to financial organisations
-
-
-
91,460
63
-
91,523
- Loans to individuals
-
-
-
6,986,045
100,770
-
7,086,815
- Loans to other customers
-
-
-
5,934,769
235,203
-
6,169,972
Other financial assets
-
-
-
165,962
-
-
165,962
Total financial assets
15,718
14,175
2,251,556
22,737,725
336,268
47,614
25,403,056

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Strategy
Risk Factors & Outlook
Performance Overview
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Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2024
Financial assets
held for trading
Non-trading financial
assets mandatorily
at FV through P&L
Financial assets
measured at FV
through OCI
Financial assets
measured at
amortised cost
Derivatives for
hedge accounting
Total
Cash and obligatory reserves with central banks,
and other demand deposits at banks
-
-
-
1,973,113
-
1,973,113
Securities
9,424
15,171
1,665,019
2,846,779
-
4,536,393
- Bonds
9,424
-
1,601,875
2,846,779
-
4,458,078
- Shares
-
8,650
63,144
-
-
71,794
- Investment funds
-
6,521
-
-
-
6,521
Derivatives
11,649
-
-
-
77,771
89,420
Loans and receivables
-
3,964
-
8,846,520
-
8,850,484
- Loans to governments
-
-
-
209,228
-
209,228
- Loans to banks
-
-
-
193,172
-
193,172
- Loans to financial organisations
-
-
-
1,326,073
-
1,326,073
- Loans to individuals
-
-
-
3,882,210
-
3,882,210
- Loans to other customers
-
3,964
-
3,235,837
-
3,239,801
Other financial assets
-
-
-
81,518
-
81,518
Total financial assets
21,073
19,135
1,665,019
13,747,930
77,771
15,530,928
in EUR thousands
NLB
31 Dec 2023
Financial assets
held for trading
Non-trading financial
assets mandatorily
at FV through P&L
Financial assets
measured at FV
through OCI
Financial assets
measured at
amortised cost
Derivatives for
hedge accounting
Total
Cash and obligatory reserves with central banks,
and other demand deposits at banks
-
-
-
4,318,032
-
4,318,032
Securities
-
8,858
1,023,012
1,966,169
-
2,998,039
- Bonds
-
-
962,084
1,966,169
-
2,928,253
- Shares
-
6,300
60,928
-
-
67,228
- Investment funds
-
2,558
-
-
-
2,558
Derivatives
17,957
-
-
-
47,614
65,571
Loans and receivables
-
7,785
-
7,297,294
-
7,305,079
- Loans to governments
-
-
-
118,220
-
118,220
- Loans to banks
-
-
-
149,011
-
149,011
- Loans to financial organisations
-
-
-
384,995
-
384,995
- Loans to individuals
-
-
-
3,543,603
-
3,543,603
- Loans to other customers
-
7,785
-
3,101,465
-
3,109,250
Other financial assets
-
-
-
101,596
-
101,596
Total financial assets
17,957
16,643
1,023,012
13,683,091
47,614
14,788,317
As at 31 December 2024 and 31 December 2023, all of
NLB Group’s financial liabilities, except for derivatives
designated as hedging instruments, trading liabilities,
and financial liabilities measured at fair value through
profit or loss, were carried at amortised cost.

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Financial
Report
6. 2. Market risk
NLB Group defines market risk as the risk of potential
financial losses due to changes in rates and/or market
prices (exchange rates, credit spreads, and equity
prices), or in parameters that affect prices (volatilities
and correlations). Losses may impact profit or loss
directly, for example in the case of trading book
positions. However, for the banking book positions they
are reflected in the revaluation reserve. The exposure
to market risk is to a certain degree integrated into the
banking industry and offers an opportunity to create
financial results and value.
The Global Risk Department of NLB is independent
from the trading activities and reports to the Bank’s
Assets and Liabilities Committee (ALCO). Global Risk
also monitors and manages exposure to market
risks separately for the banking and trading books.
Exposures and limits are monitored daily and reported
to the ALCO committee on a regular basis.
The Bank uses a wide selection of quantitative and
qualitative tools for measuring, managing, and reporting
market risks such as value-at-risk (VaR), sensitivity
analysis, stress-testing, backtesting, scenarios, other
market risk mitigants (concentration of exposures, gap
limits, stop-loss limits, etc.), net interest income sensitivity,
economic value of equity, and economic capital. Stress-
testing provides an indication of the potential losses that
could occur in severe market conditions.
In the area of currency risk, NLB Group pursues the
goal of low to medium exposure. NLB monitors the
open position of NLB Group on an ongoing basis.
The orientation of NLB Group in interest rate risk
management is to prevent negative effects on the net
interest income and economic value of equity arising
from changed market interest rates. The conclusion of
transactions involving derivatives at NLB is limited to
the servicing of the clients’ and hedging of the Group’s
own open positions. In accordance with the provisions
of the Strategy on trading with financial instruments in
NLB Group, the trading activities in other NLB Group
members are very restricted.
For monitoring and managing NLB Group’s exposure
to market risks, uniform guidelines and exposure limits
for each type of risk are set for individual NLB Group
entities. The methodologies are in line with regulatory
requirements on individual and consolidated levels,
while reporting to the regulator on the consolidated
level is carried out using the standardised approach.
Pursuant to the relevant policies, NLB Group entities
must monitor and manage exposure to market risks
and report to NLB accordingly. The exposure of an
individual NLB Group entity is regularly monitored and
reported to the Assets and Liabilities Committee of NLB
Group (NLB Group ALCO).
6.2.1. Currency risk (FX)
Foreign currency risk (FX) is a risk of the potential
losses from the open FX positions due to the changes
of the foreign currency rates. The exposures of NLB
to the movement of the FX rates have an impact on
the financial position and cash flows of the Bank. The
Bank measures and manages the FX risk by using a of
combination of sensitivity analysis, VaR, scenarios, and
stress-testing.
In the trading book, similar to the other market risks,
risk is managed on the basis of VaR limits that are
approved by the Management Board of the Bank and in
accordance with the adopted policy of managing market
risk in the trading book of NLB. The trading FX risk is
managed on an integrated basis at a portfolio level.
NLB monitors and manages FX risk in the banking book
according to the policy of managing FX risk in NLB. The
policy is primarily composed to protect Common Equity
Tier 1 against the negative effects of the volatility of
the FX rates, whilst limiting the volatility in the income
statement. FX exposures in banking book result from
core banking business activities.
Each member is responsible for its own currency risk
policy, which also includes a limit system and is in line
with the parent Bank’s guidelines and standards, as
well as local regulatory requirements. Policies are
confirmed by either the local Management Board or
Supervisory Board. NLB monitors and manages NLB
Group currency risk exposure on a monthly basis for
each member and on the consolidated level.
NLB Group banks follow the guidelines for managing
FX lending in NLB Group. The guidelines’ goal is to
address risks stemming from the potential excessive
growth of FX lending, to identify hidden risks, and
tail-event risks related to FX lending, to mitigate the
respective risk, to internalise the respective costs, and
to hold adequate capital with respect to FX lending.
The positions of all currencies in the statement of
financial position of NLB, for which a daily limit is set,
are monitored daily. FX positions are managed at the
currency level so that they are always within the limits.
Regarding structural FX positions on a consolidation
level, assets, and liabilities held in foreign operations
are translated into euro at the closing FX rate on
the reporting date. Foreign exchange differences of
non-euro assets and liabilities against the euro are
recognised in OCI, and therefore affect shareholder’s
equity and CET1 capital. NLB Group ALM employs
strategies to manage this foreign currency exposure,
including matched funding of assets and liabilities.
Exposure to currency risks is discussed at daily
liquidity meetings and monthly meetings of the ALCO
committee of the NLB Group, and quarterly on the
consolidated level.

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Financial
Report
a) Analysis of financial instruments by currency exposure
in EUR thousands
NLB Group
31 Dec 2024
EUR
RSD
USD
CHF
Other
Total
Financial assets
Cash, cash balances at central banks, and other demand deposits at banks
2,862,691
577,522
30,194
36,606
532,568
4,039,581
Financial assets held for trading
10,950
-
7,388
-
-
18,338
Non-trading financial assets mandatorily at fair value through profit or loss
7,931
-
8,650
-
848
17,429
Financial assets measured at fair value through other comprehensive income
2,133,137
241,315
119,170
-
69,894
2,563,516
Financial assets measured at amortised cost
- debt securities
3,037,241
265,376
137,879
5,383
279,316
3,725,195
- loans and advances to banks
166,871
229,524
36,524
17,313
8,689
458,921
- loans and advances to customers
13,152,456
1,401,937
37,987
73,186
1,698,083
16,363,649
- other financial assets
86,171
16,195
24,494
45
9,949
136,854
Derivatives - hedge accounting
77,771
-
-
-
-
77,771
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(6,353)
-
-
-
-
(6,353)
Total financial assets
21,528,866
2,731,869
402,286
132,533
2,599,347
27,394,901
Financial liabilities
Financial liabilities held for trading
6,992
3
-
-
-
6,995
Financial liabilities measured at fair value through profit or loss
6,670
1,129
-
-
1,834
9,633
Derivatives - hedge accounting
3,592
-
-
-
-
3,592
Financial liabilities measured at amortised cost
- deposits from banks and central banks
97,980
1,150
15,351
10,480
11,039
136,000
- borrowings from banks and central banks
106,632
-
13,980
-
-
120,612
- due to customers
17,720,288
1,816,332
360,291
203,175
2,106,224
22,206,310
- borrowings from other customers
104,519
-
-
-
-
104,519
- debt securities issued
1,608,939
-
-
-
-
1,608,939
- other financial liabilities
199,241
42,028
27,155
3,364
24,937
296,725
Total financial liabilities
19,854,853
1,860,642
416,777
217,019
2,144,034
24,493,325
Net on-balance sheet financial position
1,674,013
871,227
(14,491)
(84,486)
455,313
2,901,576
Derivative financial instruments
(188,260)
12,828
17,817
93,905
41,523
(22,187)
Net financial position
1,485,753
884,055
3,326
9,419
496,836
2,879,389
31 Dec 2023
Total financial assets
20,405,012
2,338,709
362,174
114,750
2,172,204
25,392,849
Total financial liabilities
18,858,907
1,474,262
414,604
220,268
1,816,691
22,784,732
Net on-balance sheet financial position
1,546,105
864,447
(52,430)
(105,518)
355,513
2,608,117
Derivative financial instruments
(233,578)
(25,498)
55,204
123,650
59,879
(20,343)
Net financial position
1,312,527
838,949
2,774
18,132
415,392
2,587,774
‘Other’ mostly relates to exposures in currency MKD and BAM.

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Annual Report 2024
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Strategy
Risk Factors & Outlook
Performance Overview
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NLB Group Key Members
Risk Management
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Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2024
EUR
RSD
USD
CHF
Other
Total
Financial assets
Cash, cash balances at central banks, and other demand deposits at banks
1,945,093
342
4,403
6,603
16,672
1,973,113
Financial assets held for trading
13,685
-
7,388
-
-
21,073
Non-trading financial assets mandatorily at fair value through profit or loss
10,485
-
8,650
-
-
19,135
Financial assets measured at fair value through other comprehensive income
1,640,292
-
23,386
-
1,341
1,665,019
Financial assets measured at amortised cost
- debt securities
2,741,307
-
81,816
5,383
18,273
2,846,779
- loans and advances to banks
193,172
-
-
-
-
193,172
- loans and advances to customers
8,547,034
-
30,565
75,749
-
8,653,348
- other financial assets
57,071
3
24,412
1
31
81,518
Derivatives - hedge accounting
77,771
-
-
-
-
77,771
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(8,761)
-
-
-
-
(8,761)
Total financial assets
15,217,149
345
180,620
87,736
36,317
15,522,167
Financial liabilities
Financial liabilities held for trading
9,977
-
-
-
-
9,977
Financial liabilities measured at fair value through profit or loss
5,597
-
-
-
-
5,597
Derivatives - hedge accounting
1,261
-
-
-
-
1,261
Financial liabilities measured at amortised cost
- deposits from banks and central banks
170,798
52
13,985
18,834
16,451
220,120
- borrowings from banks and central banks
37,126
-
13,980
-
-
51,106
- due to customers
12,037,455
11
131,979
75,831
48,432
12,293,708
- debt securities issued
1,608,939
-
-
-
-
1,608,939
- other financial liabilities
121,744
3
23,367
175
513
145,802
Total financial liabilities
13,992,897
66
183,311
94,840
65,396
14,336,510
Net on-balance sheet financial position
1,224,252
279
(2,691)
(7,104)
(29,079)
1,185,657
Derivative financial instruments
(64,061)
-
3,208
6,677
32,605
(21,571)
Net financial position
1,160,191
279
517
(427)
3,526
1,164,086
31 Dec 2023
Total financial assets
14,542,589
547
137,918
57,960
36,789
14,775,803
Total financial liabilities
13,310,922
103
192,177
96,385
70,170
13,669,757
Net on-balance sheet financial position
1,231,667
444
(54,259)
(38,425)
(33,381)
1,106,046
Derivative financial instruments
(157,517)
5
55,204
39,957
40,143
(22,208)
Net financial position
1,074,150
449
945
1,532
6,762
1,083,838
‘Other’ mostly relates to exposures in currency GBP, CAD, and JPY.

NLB Group
Annual Report 2024
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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
b) FX sensitivity analysis
in %
NLB Group and NLB
Scenarios
31 Dec 2024
31 Dec 2023
USD
+/-6.49
+/-13.32
CHF
+/-8.93
+/-9.67
CZK
+/-6.14
+/-7.10
RSD
+/-0.43
+/-0.55
MKD
+/-2.50
+/-1.82
JPY
+/-23.19
+/-19.69
AUD
+/-10.02
+/-9.20
HUF
+/-7.48
+/-20.39
BAM
+/-6.49
+/-0
in EUR thousands
31 Dec 2024
31 Dec 2023
NLB Group
NLB
NLB Group
NLB
Effects on income
statement
Effects on other
comprehensive
income
Effects on income
statement
Effects on other
comprehensive
income
Effects on income
statement
Effects on other
comprehensive
income
Effects on income
statement
Effects on other
comprehensive
income
Appreciation of
USD
(22)
-
(15)
53
(342)
-
(294)
248
CHF
(746)
1,127
(14)
-
(730)
1,330
53
-
CZK
40
-
40
-
-
-
-
-
RSD
68
3,845
1
-
(125)
4,775
2
-
MKD
5
8,051
5
-
4
5,234
4
-
Other
99
176
91
-
100
93
102
-
Effects on comprehensive income
(556)
13,199
108
53
(1,093)
11,432
(133)
248
Depreciation of
USD
20
-
13
(47)
262
-
225
(190)
CHF
624
(942)
12
-
601
(1,096)
(44)
-
CZK
(35)
-
(36)
-
-
-
-
-
RSD
(68)
(3,813)
(1)
-
124
(4,724)
(2)
-
MKD
(5)
(7,659)
(5)
-
(4)
(5,047)
(4)
-
Other
(83)
(176)
(76)
-
(70)
(93)
(71)
-
Effects on comprehensive income
453
(12,590)
(93)
(47)
913
(10,960)
104
(190)
The effect on the other comprehensive income
statement of NLB Group has increased due to the
higher translation positions in MKD currency, and
because of the higher volatility growths’ scenario for
MKD currency.

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Report
6.2.2. Managing market risks in the trading book
Market risk exposure in the trading book arises mostly
as a result of the changes in interest rates, credit
spreads, FX rates, and equity prices.
The Management Board determines low total risk
appetite and limits by the risk type. The limits are
monitored daily by the Global Risk Department.
NLB uses an internal VaR model based on the variance-
covariance method for other market risks. The daily
calculation of the VAR value is adjusted to Basel
standards (99% confidence interval, a monitored period
of 250 business days, a 10-day holding position period).
6.2.3. Interest rate risk
Interest rate risk is the risk to NLB Group’s capital and
profit or loss arising from changes in market interest
rates. Interest rate risk management of NLB Group
includes all interest rate-sensitive on- and off-balance
sheet assets and liabilities which are divided into the
trading and banking book according to regulatory
standards. It takes into account the positions in each
currency. Interest rate risk management in NLB Group
is adopted in accordance with the risk appetite and
risk strategy, based on general Basel standards on
interest rate management in the banking book (IRRBB;
hereinafter: ‘Standards’) and European Banking
Authority guidelines.
In the trading book, interest rate risk is measured
on the basis of the VaR method and BPV method, in
accordance with the adopted policy for managing
market risk in the trading book of NLB.
The interest rate risk in the banking book is measured
and monitored within a framework of interest rate
risk management policy that establishes consistent
methodologies, models, and limit systems. NLB
Group manages interest rate risk exposure through
application of two main measures:
- Economic value sensitivity – using BPV method (Basis
Point Value), which measures the extent to which the
economic value of the banking book would change if
interest rates change according to the scenario;
- Sensitivity of net interest income – which measures
the impact of the interest rate change on future net
interest income over a one-year period, assuming
constant balance sheet volume and structure.
NLB Group regularly measures interest rate risk
exposure in the banking book under various
standardised and additional scenarios of changes
in the level and shape of interest rate yield curve,
including all significant sources of risk, taking into
account behavioural and modelling assumptions. Part
of non-maturing deposits, which is considered as a
core part is allocated long-term by using a replicating
portfolio approach. Optionality risk is mainly
derived from behavioural options, and is reflected
in prepayments and withdrawals, and embedded
options such as caps and floors. Moreover, considering
expected cash flows, non-performing exposures, as
well as off-balance sheet items are considered when
measuring interest rate risk exposure.
The interest rate risk is closely measured, monitored,
and managed within approved risk limits and controls.
The Group manages interest rate positions and
stabilises its interest rate margin primarily with the
pricing policy and a fund transfer pricing policy. An
important part of the interest rate risk management
is presented by the banking book securities portfolio,
whose primary purpose is to maintain adequate
liquidity reserves, while it also contributes to the
stability of the interest rate margin.
NLB Group also manages interest rates risk by using
plain vanilla derivative financial instruments (interest
rate swaps, overnight index swaps, cross currency
swaps, and forward rate agreements), most of which
are treated according to hedge accounting rules.
Each member of NLB Group is responsible for its
own interest rate risk policy, which includes the limit
system and is in line with the parent Bank’s guidelines
and standards, as well as with the local regulatory
requirements. NLB regularly monitors the interest rate
risk exposure of each individual member of NLB Group
in accordance with the Standards for Risk Management
in NLB Group. The document comprises guidelines for
uniform and effective interest rate risk management
within individual NLB Group members.
Interest rate risk in the banking book is measured,
monitored, and reported by the Global Risk
Department (weekly in the case of NLB and monthly on
Group level), while positions are managed by Financial
Markets. Exposure to interest rate risk is discussed on
ALCO monthly on NLB’s individual level and quarterly
on the consolidated level.

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a) Analysis of financial instruments according to the
exposure to interest rate risk
The following table presents open net interest rate
risk positions by the most important currencies of
NLB Group.
Financial instruments without maturity such as sight
deposits are presented in the first gap irrespective
of their behavioural characteristics and the NLB
Group’s expectations.
in EUR thousands
31 Dec 2024
NLB Group
Currency
1 - 3 years
3 - 5 years
5 - 10 years
Over 10 Years
EUR
(3,828,183)
2,408,757
2,706,607
1,548,118
RSD
285,895
280,810
275,857
(33)
MKD
198,485
110,367
16,844
(20,024)
Other
(316,582)
195,638
140,147
14,937
in EUR thousands
31 Dec 2023
NLB Group
Currency
1 - 3 years
3 - 5 years
5 - 10 years
Over 10 Years
EUR
(2,109,587)
1,278,722
1,519,103
756,545
RSD
573,943
195,097
69,386
5
MKD
253,734
25,929
(5,110)
5,960
Other
(206,743)
130,171
87,324
3,970
in EUR thousands
31 Dec 2024
NLB
Currency
1 - 3 years
3 - 5 years
5 - 10 years
Over 10 Years
EUR
(3,233,482)
1,883,525
2,183,790
1,462,043
Other
(100,720)
21,856
33,753
7,337
in EUR thousands
31 Dec 2023
NLB
Currency
1 - 3 years
3 - 5 years
5 - 10 years
Over 10 Years
EUR
(1,772,291)
1,004,157
1,436,836
645,084
Other
(176,222)
19,729
20,418
-

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b) Net interest income sensitivity analysis and
an economic view of interest rate risk in the
banking book
The analysis of interest income sensitivity for the horizon
of the next 12 months assumes a sudden parallel interest
rate shock down by 50 basis points for EUR or 100 basis
points for other currencies. The analysis assumes that
the positions used remain unchanged.
The assessment of the impact of a change in interest
rates of 50/100 basis points on the amount of net
interest income of the banking book position:
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Net interest income sensitivity
38,643
57,595
19,626
33,281
Net interest income sensitivity - as % of Equity
1.35%
2.22%
0.90%
1.84%
The ‘EVE’ (Economic Value of Equity) method is a
measure of the sensitivity of changes in market interest
rates on the economic value of financial instruments.
The EVE represents the present value of net future
cash flows and provides a comprehensive view of the
possible long-term effects of changing interest rates
at least under the six prescribed standardised interest
rate shock scenarios or more if necessary, according
to the situation on financial markets. Calculations are
considering behavioural and automatic options, as well
as the allocation of non-maturing deposits.
The assessment of the impact of a change in interest
rates of 200 basis points on the economic value of the
banking book position:
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Interest risk in banking book - EVE
144,400
108,489
97,643
60,747
Interest risk in banking book - EVE as % of Equity
5.04%
4.19%
4.47%
3.36%
The applied sudden parallel interest rate shock up is
by 200 basis points, which represents a "worst case"
scenario for NLB Group. The calculation takes into the
account allocation of the core part of non-maturing
deposits and other behavioural assumptions.

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6. 3. Liquidity risk
Liquidity risk is the risk of the NLB Group being unable
to fulfil current or future expected and unexpected
cash requirements, across all time horizons. The risk
may stem from the reduction in funding sources or a
reduction in the liquidity of certain assets.
Liquidity risk is related to funding liquidity risk (the
NLB Group’s liquidity on the liabilities-side) and market
liquidity risk (counterbalancing capacity on the assets-
side). From a liabilities perspective, liquidity risk can
result in a loss if the Bank is unable to settle all its
liabilities or when the Bank, because of its incapacity
to provide sufficient funds to settle its obligations, is
forced to raise the necessary funds at a cost which
significantly exceeds the normal cost. From an assets
perspective, the liquidity risk is related to the market
value of counterbalancing capacity and arises in case
of significant reduction of market value of an individual
financial instrument and may result in insufficient value
of counterbalancing capacity to cover the NLB Group’s
liquidity needs.
Intraday liquidity risk is the capacity required during
the business day to enable financial institutions to make
payments and settle obligations.
In the risk identification process, first the reasons
for the realisation of each identified material risk
are analysed and grouped together in short risk
descriptions. Material risks are then classified into
three groups based on what part of liquidity is affected
by the realisation of the material risks: liabilities,
assets, and intraday liquidity risk. The origin of each
risk is determined as being internal, external, or a
combination of internal and external (internal shock,
meaning it originates within the Bank, or external
shock; meaning it comes from outside the Bank – e.g.,
a major macroeconomic event, physical or transition
event, ESG rating downgrade). Based on the identified
material risks, key liquidity risk drivers are defined. Key
risk drivers of the liquidity position are factors that are
expected to trigger a substantial deterioration of the
Group’s liquidity position. This deterioration may take
place in the form of an increase in outflows, a decrease
in inflows, or a decrease in the liquidity value of the
counterbalancing capacity.
Liquidity risk is defined as an important risk type
for NLB Group, and one which must be managed
carefully. NLB Group has a liquidity risk management
framework in place that enables maintaining a low risk
tolerance for liquidity risk. NLB Group formulated a set
of liquidity risk metrics and limits to manage liquidity
position within the requirements set by the regulator.
By maintaining a smooth long-term maturity profile,
limiting dependence on wholesale funding, and holding
a solid liquidity reserve, the NLB Group maintains a
sound and robust liquidity position, even under severely
adverse conditions.
The Management Board approves the Liquidity Risk
Management Policy, which outlines the key principles
for the Bank’s liquidity management. ALCO receives
a regular report on the liquidity position and the
performance against approved limits and targets.
ALCO oversees the development of the Bank’s funding
and liquidity position and decides on liquidity risk-
related issues in NLB Group.
Risk tolerance for liquidity risk is low, therefore NLB
Group must be able to provide sufficient funds for
settling its liabilities at all times, even if a specific
stress scenario is realised. NLB Group measures and
manages its liquidity in two stages:
- Static view (current exposure),
- Forward-looking and stress-testing.
The objectives of monitoring and managing liquidity
risk in NLB Group are as follows:
- ensuring a sufficient amount of liquidity for the
settlement of all NLB Group’s liabilities;
- minimising the costs of maintaining liquidity;
- determining an adequate amount of
counterbalancing capacity and optimal liquidity
management;
- ensuring adequate control environment;
- ensuring an appropriate level of liquidity for different
situations and stress scenarios;
- anticipating emergencies or crisis conditions, and
implementing contingency plans in the event of
extraordinary circumstances;
- ensuring regular projections of future cash flows and
stress-testing of liquidity risk;
- preparing proposals for establishing additional
financial assets as collateral for sources of funding;
- to ensure that climate-related and environmental
risks which could have a material impact on net cash
outflows or liquidity reserves, are incorporate into
liquidity risk management and liquidity reserves
calibration.
Overall assessment of the liquidity position of NLB
Group is assessed in the Internal Liquidity Adequacy
Assessment Process (ILAAP) at least once per year for
NLB Group, and it includes a clear formal statement
on liquidity adequacy, supported by an analysis of
ILAAP outcomes. The ILAAP process is integral to risk
management frameworks and is aligned with the
NLB Group’s risk appetite which is consistent with the
business model and approved by the management
board. Based on the Risk Appetite, the NLB Group
prepares a business plan and financial forecasts which
are crucial for defining internal capital needs (the
ICAAP process) and an internal liquidity assessment
(ILAAP process). Both processes are conducted
from the normative and economic perspectives and
supplemented by the stress-testing programme.
NLB Group performs stress tests on a regular basis
for a variety of bank-specific and market-wide stress
scenarios (individually and in combination) to identify
sources of potential liquidity strain and to ensure
that current exposures remain in accordance with
the NLB Group’s established liquidity risk tolerance.
Stress test outcomes are used to adjust its liquidity risk
management strategies, policies, and positions, define
minimum amount of counterbalancing capacity, and to
develop effective contingency plans.
NLB Group has a formal liquidity contingency
plan (LCP) that clearly sets out the procedures for
addressing liquidity shortfalls in stressed situations. The
plan outlines procedures to manage a range of stress
environments, establish clear lines of responsibility,
include clear invocation and escalation procedures,
and is regularly tested and updated to ensure that it is
operationally robust.
NLB Group maintains a sufficient amount of liquidity
reserves in the form of high credit quality debt
securities that are eligible for refinancing via the
ECB/central bank or on the market. In the current
situation, NLB Group also strives to follow as closely

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as possible the long-term trend of diversification on
both the liability and asset sides of the balance sheet.
NLB Group regularly performs stress tests with the
aim of testing the liquidity stability and the availability
of liquidity reserves in various stress situations. In
addition, special attention is given to the fulfilment of
the liquidity regulation (CRR/CRD), with monitoring and
reporting of the liquidity coverage ratio (LCR) according
to the Delegated Act and net stable funding ratio
(NSFR). This also includes monitoring and reporting
of Additional Liquidity Monitoring Metrics (ALMM) on
solo and consolidated levels. In accordance with the
Commission Implementing Regulation (EU), NLB Group
regularly monitors and issues quarterly reports on
asset encumbrance.
The Group manages its liquidity position (liquidity
within one day) daily, for a period of several days
or weeks in advance, based on the planning and
monitoring of cash flows. Each NLB Group member is
responsible for its own liquidity position and carries out
the following activities:
- managing intraday liquidity;
- planning and monitoring cash flows;
- monitoring and complying with the liquidity
regulations of the central bank;
- adopting business decisions;
- forming and managing liquidity reserves; and
- performing a liquidity stress test to define the liquidity
reserves for smooth functioning of the payment
system in stressed circumstances.
NLB Group members actively manage liquidity over the
course of a day, taking into account the characteristics
of payment settlements to ensure the timely settlement
of liabilities in normal and stressed circumstances.
Liquidity risk management in NLB Group is under strict
monitoring by NLB as a parent bank. Reporting to NLB
by all Group members is performed daily. Global Risk
gives guidelines and defines minimal standards for
Group members regarding liquidity risk management
in NLB Group Risk Management Standards. Each
Group member is responsible for ensuring adequate
liquidity via the necessary sources of funding and
their appropriate diversification and maturity, and
by managing liquidity reserves and fulfilling the
requirements of regulations governing liquidity. The
exposure of an individual NLB Group member towards
liquidity risk is regularly monitored and reported to
ALCO, and to local Assets and Liabilities Committees.
a) Managing NLB Group’s liquidity reserves
NLB Group has liquidity reserves available to cover
liabilities that fall or may become due. Liquidity
reserves must become available on short notice.
Liquidity reserves are comprised of cash, the
settlement account at the central bank above reserve
requirement, debt securities valued at market value,
and loans eligible as collateral for the Eurosystem’s
liquidity providing operations on the basis of which the
Bank may generate the requisite liquidity at any time.
The available liquidity reserves are liquidity reserves
decreased by the required balances for the continuous
performance of payment transactions, encumbered
securities, and/or credit claims for different purposes
(secured funding).
The structure of liquidity reserves is shown in the
following table.
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Liquidity reserves
Cash, cash balances at central banks(i)
2,764,196
4,958,969
1,801,602
4,142,013
Trading book securities(ii)
9,424
-
9,424
-
Banking book securities(ii)
6,133,196
4,569,721
4,368,400
2,810,064
ECB eligible loans
380,678
678,445
380,678
678,445
Total available liquidity reserves
9,287,494
10,207,135
6,560,104
7,630,522
Encumbered liquidity reserves
41,685
41,502
41,685
41,502
(i) above reserve requirement
(ii) market value
As at 31 December 2024, 72.0% (31 December 2023: 79.5%)
of debt securities in the banking book of NLB Group
were government securities (including government
guaranteed bonds – GGB), and 11.3% (31 December 2023:
11.9%) were bank senior unsecured bonds.
The purpose of banking book securities is to provide
liquidity, along with stabilisation of the interest margin
and the interest rate risk management, simultaneously.
When managing the portfolio, NLB Group uses
conservative principles, particularly with respect to
the portfolio’s structure in terms of issuers’ ratings
and asset class. The general rules and principles for
managing the banking book securities are laid in the
NLB Group Investment Strategy: Investment Portfolio
Plan – definition and monitoring and Trading and
Treasury Framework for Managing Debt Securities.
The ECB-eligible credit claims comprise loans which
fulfil the high eligibility criteria set by the ECB itself and
for domestic loans are specified in the General terms
about execution of monetary policy framework (Part
4) adopted by the Bank of Slovenia. NLB is the only
member of NLB Group that classifies as an eligible
counterparty to the Eurosystem. As such, these ECB
credit claims are included among liquidity reserves.
Members of NLB Group manage their liquid assets
on a decentralised basis in compliance with the local
liquidity regulation and valid policies and standards of
NLB Group.

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b) Encumbered/unencumbered assets
in EUR thousands
NLB Group
NLB
31 Dec 2024
Carrying amount
of encumbered
assets
Fair value of
encumbered
securities
Carrying amount
of unencumbered
assets
Fair value of
unencumbered
securities
Carrying amount
of encumbered
assets
Fair value of
encumbered
securities
Carrying amount
of unencumbered
assets
Fair value of
unencumbered
securities
Loans on demand
1,330,862
-
2,168,436
-
126,192
-
1,632,284
-
Equity instruments
1,210
1,210
111,812
111,812
-
-
78,315
78,315
Debt securities
42,357
41,685
6,160,185
6,142,628
42,357
41,685
4,415,721
4,377,825
Loans and advances other
than loans on demand
8,254
-
16,951,170
-
104
-
8,931,898
-
Other assets
-
-
1,261,081
-
-
-
1,748,220
-
Total
1,382,683
26,652,684
168,653
16,806,438
in EUR thousands
NLB Group
NLB
31 Dec 2023
Carrying amount
of encumbered
assets
Fair value of
encumbered
securities
Carrying amount
of unencumbered
assets
Fair value of
unencumbered
securities
Carrying amount
of encumbered
assets
Fair value of
encumbered
securities
Carrying amount
of unencumbered
assets
Fair value of
unencumbered
securities
Loans on demand
1,241,906
-
4,390,753
-
118,356
-
4,017,941
-
Equity instruments
1,002
1,002
95,048
95,048
-
-
69,786
69,786
Debt securities
42,739
41,502
4,649,171
4,568,776
42,739
41,502
2,885,514
2,810,064
Loans and advances other
than loans on demand
15,171
-
14,433,032
-
8,067
-
7,398,608
-
Other assets
-
-
1,073,163
-
-
-
1,473,765
-
Total
1,300,818
24,641,167
169,162
15,845,614
c) Collateral received – unencumbered
The table below shows the nominal value of collateral
received and own debt securities issued not available
for encumbrance.
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Equity instruments
267,819
293,343
197,925
265,757
Loans and advances other
than loans on demand
163,534
175,307
44,352
51,190
Other assets
17,670,493
13,599,848
6,877,572
6,408,890
Total
18,101,846
14,068,498
7,119,849
6,725,837

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d) Sources of encumbrance
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Collateralised
liability
Assets given as
collateral
Collateralised
liability
Assets given as
collateral
Collateralised
liability
Assets given as
collateral
Collateralised
liability
Assets given as
collateral
Derivatives
1,119
4,862
2,486
9,638
1,119
4,862
2,486
9,638
Other sources of encumbrance
3,435
1,377,821
2,861
1,291,179
-
163,791
-
159,523
Total
4,554
1,382,683
5,347
1,300,817
1,119
168,653
2,486
169,161
As at 31 December 2024, NLB Group and NLB had a
large share of unencumbered assets. Other sources of
encumbrance mostly relate to the obligatory reserve.
On the NLB Group level, the amount of encumbered
assets equalled EUR 1,383 million (31 December 2023:
EUR 1,301 million).

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e) Non-derivative cash flows
The tables below illustrate the cash flows from non-
derivative financial instruments by residual maturities
at the end of the year. The amounts disclosed in the
table are the undiscounted contractual cash flows
determined on the basis of spot rates at the end of the
reporting period.
in EUR thousands
NLB Group
31 Dec 2024
Carrying amount
Total
Up to
1 Month
1 Month
to 3 Months
3 Months
to 1 Year
1 Year
to 5 Years
Over
5 Years
Cash, cash balances at central banks, and
other demand deposits at banks
4,039,581
4,039,581
4,039,581
-
-
-
-
Financial assets held for trading
9,424
13,141
-
40
174
1,395
11,532
Non-trading financial assets mandatorily
at fair value through profit or loss
17,429
17,429
847
-
16,475
107
-
Financial assets measured at fair value
through other comprehensive income
2,563,516
2,725,607
134,287
125,895
540,803
1,726,575
198,047
Financial assets measured at amortised cost
- debt securities
3,725,195
4,459,687
174,388
107,314
332,185
1,892,931
1,952,869
- loans and advances to banks
458,921
458,929
448,107
8,769
1,979
74
-
- loans and advances to customers
16,363,649
19,736,359
768,137
854,857
3,520,519
8,571,720
6,021,126
- other financial assets
136,854
136,854
75,114
607
28,313
7,119
25,701
Total financial assets
27,314,569
31,587,587
5,640,461
1,097,482
4,440,448
12,199,921
8,209,275
Financial liabilities measured at fair
value through profit or loss
9,633
9,633
-
-
2,850
6,028
755
Financial liabilities measured at amortised cost
- deposits from banks and central banks
136,000
136,259
131,570
-
4,470
218
1
- borrowings from banks and central banks
120,612
126,208
1,732
2,079
18,731
51,342
52,324
- due to customers
22,206,310
22,328,118
18,830,640
544,091
1,930,638
970,629
52,120
- borrowings from other customers
104,519
118,640
994
1,645
6,909
51,035
58,057
- debt securities issued
1,608,939
2,231,966
20,629
357
82,220
849,107
1,279,653
- other financial liabilities
296,725
301,066
204,928
9,133
13,551
32,251
41,203
Credit risk related commitments
3,392,507
3,392,507
3,392,507
-
-
-
-
Non-financial guarantees
1,110,863
1,110,863
62,646
113,859
317,075
538,658
78,625
Total financial liabilities and credit-related commitments
28,986,108
29,755,260
22,645,646
671,164
2,376,444
2,499,268
1,562,738

NLB Group
Annual Report 2024
519
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB Group
31 Dec 2023
Carrying amount
Total
Up to
1 Month
1 Month
to 3 Months
3 Months
to 1 Year
1 Year
to 5 Years
Over
5 Years
Cash, cash balances at central banks, and
other demand deposits at banks
6,103,561
6,103,561
6,103,561
-
-
-
-
Non-trading financial assets mandatorily
at fair value through profit or loss
14,175
14,175
1,009
707
11,586
873
-
Financial assets measured at fair value
through other comprehensive income
2,251,556
2,408,707
283,269
222,258
434,430
1,212,748
256,002
Financial assets measured at amortised cost
- debt securities
2,522,229
2,825,397
64,238
115,969
273,677
1,310,387
1,061,126
- loans and advances to banks
547,640
547,646
500,739
43,829
1,572
1,502
4
- loans and advances to customers
13,734,601
16,818,381
691,501
622,566
3,068,830
7,109,179
5,326,305
- other financial assets
165,962
165,962
132,368
1,150
1,732
6,705
24,007
Total financial assets
25,339,724
28,883,829
7,776,685
1,006,479
3,791,827
9,641,394
6,667,444
Financial liabilities measured at fair
value through profit or loss
4,482
4,482
-
-
-
4,144
338
Financial liabilities measured at amortised cost
- deposits from banks and central banks
95,283
95,726
75,818
-
15,330
4,332
246
- borrowings from banks and central banks
140,419
147,519
1,198
1,417
11,311
16,181
117,412
- due to customers
20,732,722
20,857,070
17,921,304
258,812
1,661,298
928,654
87,002
- borrowings from other customers
99,718
114,387
1,101
1,835
8,261
9,021
94,169
- debt securities issued
1,338,235
1,852,163
-
4,079
84,166
871,459
892,459
- other financial liabilities
357,116
357,116
274,348
6,915
9,111
26,557
40,185
Credit risk related commitments
3,196,771
3,196,771
3,196,771
-
-
-
-
Non-financial guarantees
963,321
963,321
76,594
97,262
338,287
380,994
70,184
Total financial liabilities and credit-related commitments
26,928,067
27,588,555
21,547,134
370,320
2,127,764
2,241,342
1,301,995

NLB Group
Annual Report 2024
520
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2024
Carrying amount
Total
Up to
1 Month
1 Month
to 3 Months
3 Months
to 1 Year
1 Year
to 5 Years
Over
5 Years
Cash, cash balances at central banks, and
other demand deposits at banks
1,973,113
1,973,113
1,973,113
-
-
-
-
Financial assets held for trading
9,424
13,141
-
40
174
1,395
11,532
Non-trading financial assets mandatorily
at fair value through profit or loss
19,135
19,529
-
11
15,364
4,154
-
Financial assets measured at fair value
through other comprehensive income
1,665,019
1,778,178
26,960
34,083
211,135
1,378,866
127,134
Financial assets measured at amortised cost
- debt securities
2,846,779
3,436,842
16,043
36,398
271,024
1,411,754
1,701,623
- loans and advances to banks
193,172
276,377
40,930
2,641
16,175
91,930
124,701
- loans and advances to customers
8,653,348
10,113,955
430,462
327,451
1,511,475
4,603,080
3,241,487
- other financial assets
81,518
81,518
23,598
504
27,720
5,368
24,328
Total financial assets
15,441,508
17,692,653
2,511,106
401,128
2,053,067
7,496,547
5,230,805
Financial liabilities measured at fair
value through profit or loss
5,597
5,597
637
-
1,699
3,261
-
Financial liabilities measured at amortised cost
- deposits from banks and central banks
220,120
220,389
215,921
-
4,468
-
-
- borrowings from banks and central banks
51,106
51,258
-
-
1,473
5,816
43,969
- due to customers
12,293,708
12,326,162
11,253,264
226,523
612,041
227,619
6,715
- debt securities issued
1,608,939
2,231,966
20,629
357
82,220
849,107
1,279,653
- other financial liabilities
145,802
146,226
97,353
7,131
7,882
6,258
27,602
Credit risk related commitments
2,341,597
2,341,597
2,341,597
-
-
-
-
Non-financial guarantees
738,702
738,702
35,939
74,545
184,329
373,653
70,236
Total financial liabilities and credit-related commitments
17,405,571
18,061,897
13,965,340
308,556
894,112
1,465,714
1,428,175

NLB Group
Annual Report 2024
521
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2023
Carrying amount
Total
Up to
1 Month
1 Month
to 3 Months
3 Months
to 1 Year
1 Year
to 5 Years
Over
5 Years
Cash, cash balances at central banks, and
other demand deposits at banks
4,318,032
4,318,032
4,318,032
-
-
-
-
Non-trading financial assets mandatorily
at fair value through profit or loss
16,643
17,515
4
43
12,714
154
4,600
Financial assets measured at fair value
through other comprehensive income
1,023,012
1,063,468
11,640
38,854
241,365
632,002
139,607
Financial assets measured at amortised cost
- debt securities
1,966,169
2,202,821
6,764
30,167
154,110
1,057,182
954,598
- loans and advances to banks
149,011
201,826
5,933
6,719
15,928
42,789
130,457
- loans and advances to customers
7,148,283
8,487,918
405,580
212,509
1,284,363
3,621,788
2,963,678
- other financial assets
101,596
101,597
70,972
1,131
1,583
5,035
22,876
Total financial assets
14,722,746
16,393,177
4,818,925
289,423
1,710,063
5,358,950
4,215,816
Financial liabilities measured at fair
value through profit or loss
3,210
3,210
1,234
-
-
1,976
-
Financial liabilities measured at amortised cost
- deposits from banks and central banks
147,002
147,442
127,726
-
15,330
4,142
244
- borrowings from banks and central banks
82,797
83,851
-
-
1,654
1,967
80,230
- due to customers
11,881,563
11,919,187
10,985,068
97,176
540,607
278,051
18,285
- debt securities issued
1,338,235
1,852,163
-
4,079
84,166
871,459
892,459
- other financial liabilities
198,020
198,020
149,601
6,481
6,871
9,902
25,165
Credit risk related commitments
2,239,479
2,239,479
2,239,479
-
-
-
-
Non-financial guarantees
625,095
625,095
29,712
68,768
196,286
265,632
64,697
Total financial liabilities and credit-related commitments
16,515,401
17,068,447
13,532,820
176,504
844,914
1,433,129
1,081,080
When determining the gap between the financial
liabilities and financial assets in the maturity bucket of
up to one month, it is necessary to be aware of the fact
that financial liabilities include total demand deposits,
although from an economic perspective, they are stable
and present long term funding source.

NLB Group
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522
Overview
MB Statement
SB Statement
Key Highlights
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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
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Sustainability
Statement
Financial
Report
f) An analysis of the statement of financial position by residual contractual maturity
in EUR thousands
NLB Group
31 Dec 2024
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Cash, cash balances at central banks, and other demand deposits at banks
4,039,581
-
-
-
-
4,039,581
Financial assets held for trading
8,914
-
-
-
9,424
18,338
Non-trading financial assets mandatorily at fair value through profit or loss
847
-
16,475
107
-
17,429
Financial assets measured at fair value through other comprehensive income
128,419
110,383
512,080
1,632,016
180,618
2,563,516
Financial assets measured at amortised cost
- debt securities
165,058
86,544
259,565
1,550,966
1,663,062
3,725,195
- loans and advances to banks
448,106
8,768
1,976
71
-
458,921
- loans and advances to customers
714,525
734,669
3,003,291
7,045,144
4,866,020
16,363,649
- other financial assets
75,114
607
28,313
7,119
25,701
136,854
Derivatives - hedge accounting
77,771
-
-
-
-
77,771
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(6,353)
-
-
-
-
(6,353)
Total financial assets
5,651,982
940,971
3,821,700
10,235,423
6,744,825
27,394,901
Financial liabilities held for trading
6,995
-
-
-
-
6,995
Financial liabilities measured at fair value through profit or loss
-
-
2,850
6,028
755
9,633
Financial liabilities measured at amortised cost
- deposits from banks and central banks
131,555
-
4,226
218
1
136,000
- borrowings from banks and central banks
1,688
1,857
16,663
48,258
52,146
120,612
- due to customers
18,821,506
530,206
1,874,878
931,456
48,264
22,206,310
- borrowings from other customers
917
1,468
6,016
43,185
52,933
104,519
- debt securities issued
-
-
-
524,638
1,084,301
1,608,939
- other financial liabilities
204,834
8,949
12,726
29,561
40,655
296,725
Derivatives - hedge accounting
3,592
-
-
-
-
3,592
Credit risk related commitments
3,392,507
-
-
-
-
3,392,507
Non-financial guarantees
62,646
113,859
317,075
538,658
78,625
1,110,863
Total financial liabilities and credit-related commitments
22,626,240
656,339
2,234,434
2,122,002
1,357,680
28,996,695

NLB Group
Annual Report 2024
523
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB Group
31 Dec 2023
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Cash, cash balances at central banks, and other demand deposits at banks
6,103,561
-
-
-
-
6,103,561
Financial assets held for trading
15,718
-
-
-
-
15,718
Non-trading financial assets mandatorily at fair value through profit or loss
1,009
707
11,586
873
-
14,175
Financial assets measured at fair value through other comprehensive income
273,593
213,671
416,536
1,202,599
145,157
2,251,556
Financial assets measured at amortised cost
- debt securities
61,505
108,615
236,639
1,279,633
835,837
2,522,229
- loans and advances to banks
500,738
43,828
1,568
1,502
4
547,640
- loans and advances to customers
646,236
537,884
2,594,804
6,883,875
3,071,802
13,734,601
- other financial assets
132,368
1,150
1,732
6,705
24,007
165,962
Derivatives - hedge accounting
47,614
-
-
-
-
47,614
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(10,207)
-
-
-
-
(10,207)
Total financial assets
7,772,135
905,855
3,262,865
9,375,187
4,076,807
25,392,849
Financial liabilities held for trading
13,217
-
-
-
-
13,217
Financial liabilities measured at fair value through profit or loss
-
-
-
4,144
338
4,482
Financial liabilities measured at amortised cost
- deposits from banks and central banks
75,815
-
15,134
4,332
2
95,283
- borrowings from banks and central banks
1,065
1,210
9,820
15,602
112,722
140,419
- due to customers
17,916,339
252,769
1,602,706
926,396
34,512
20,732,722
- borrowings from other customers
940
1,456
6,229
8,260
82,833
99,718
- debt securities issued
-
-
-
828,840
509,395
1,338,235
- other financial liabilities
280,669
6,498
7,318
21,482
41,149
357,116
Derivatives - hedge accounting
3,540
-
-
-
-
3,540
Credit risk related commitments
3,196,771
-
-
-
-
3,196,771
Non-financial guarantees
76,594
97,262
338,287
380,994
70,184
963,321
Total financial liabilities and credit-related commitments
21,564,950
359,195
1,979,494
2,190,050
851,135
26,944,824

NLB Group
Annual Report 2024
524
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2024
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Cash, cash balances at central banks, and other demand deposits at banks
1,973,113
-
-
-
-
1,973,113
Financial assets held for trading
11,649
-
-
-
9,424
21,073
Non-trading financial assets mandatorily at fair value through profit or loss
-
-
15,247
3,888
-
19,135
Financial assets measured at fair value through other comprehensive income
25,238
21,639
194,082
1,308,678
115,382
1,665,019
Financial assets measured at amortised cost
- debt securities
10,091
21,104
218,825
1,154,075
1,442,685
2,846,779
- loans and advances to banks
40,908
2,386
7,252
52,747
89,879
193,172
- loans and advances to customers
411,030
283,321
1,295,486
3,942,796
2,720,715
8,653,348
- other financial assets
23,598
504
27,720
5,368
24,328
81,518
Derivatives - hedge accounting
77,771
-
-
-
-
77,771
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(8,761)
-
-
-
-
(8,761)
Total financial assets
2,564,637
328,954
1,758,612
6,467,552
4,402,413
15,522,167
Financial liabilities held for trading
9,977
-
-
-
-
9,977
Financial liabilities measured at fair value through profit or loss
637
-
1,699
3,261
-
5,597
Financial liabilities measured at amortised cost
- deposits from banks and central banks
215,896
-
4,224
-
-
220,120
- borrowings from banks and central banks
-
-
1,429
5,714
43,963
51,106
- due to customers
11,250,468
220,898
596,360
220,960
5,022
12,293,708
- debt securities issued
-
-
-
524,638
1,084,301
1,608,939
- other financial liabilities
97,210
6,855
6,660
5,873
29,204
145,802
Derivatives - hedge accounting
1,261
-
-
-
-
1,261
Credit risk related commitments
2,341,597
-
-
-
-
2,341,597
Non-financial guarantees
35,939
74,545
184,329
373,653
70,236
738,702
Total financial liabilities and credit-related commitments
13,952,985
302,298
794,701
1,134,099
1,232,726
17,416,809

NLB Group
Annual Report 2024
525
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2023
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Cash, cash balances at central banks, and other demand deposits at banks
4,318,032
-
-
-
-
4,318,032
Financial assets held for trading
17,957
-
-
-
-
17,957
Non-trading financial assets mandatorily at fair value through profit or loss
-
-
3,579
138
12,926
16,643
Financial assets measured at fair value through other comprehensive income
11,142
36,942
235,185
630,105
109,638
1,023,012
Financial assets measured at amortised cost
- debt securities
5,003
24,216
125,394
1,033,656
777,900
1,966,169
- loans and advances to banks
5,912
6,409
8,999
35,329
92,362
149,011
- loans and advances to customers
389,935
185,727
1,076,136
3,519,655
1,976,830
7,148,283
- other financial assets
70,971
1,131
1,583
5,035
22,876
101,596
Derivatives - hedge accounting
47,614
-
-
-
-
47,614
Fair value changes of the hedged items in portfolio hedge of interest rate risk
(12,514)
-
-
-
-
(12,514)
Total financial assets
4,854,052
254,425
1,450,876
5,223,918
2,992,532
14,775,803
Financial liabilities held for trading
17,510
-
-
-
-
17,510
Financial liabilities measured at fair value through profit or loss
1,234
-
-
1,976
-
3,210
Financial liabilities measured at amortised cost
- deposits from banks and central banks
127,726
-
15,134
4,142
-
147,002
- borrowings from banks and central banks
-
-
1,430
1,945
79,422
82,797
- due to customers
10,983,368
95,065
521,103
277,829
4,198
11,881,563
- debt securities issued
-
-
-
828,840
509,395
1,338,235
- other financial liabilities
149,456
6,224
5,736
10,078
26,526
198,020
Derivatives - hedge accounting
1,420
-
-
-
-
1,420
Credit risk related commitments
2,239,479
-
-
-
-
2,239,479
Non-financial guarantees
29,712
68,768
196,286
265,632
64,697
625,095
Total financial liabilities and credit-related commitments
13,549,905
170,057
739,689
1,390,442
684,238
16,534,331

NLB Group
Annual Report 2024
526
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
g) Derivative cash flows
The table below illustrates cash flows from derivatives,
broken down into the relevant maturity buckets based
on residual maturities. The amounts disclosed in the
table are the contractual undiscounted cash flows
prepared on the basis of spot rates on the
reporting date.
in EUR thousands
NLB Group
31 Dec 2024
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Foreign exchange derivatives
- Forwards
- Outflow
(16,067)
(16,933)
(11,967)
-
-
(44,967)
- Inflow
16,083
16,951
11,991
-
-
45,025
- Swaps
- Outflow
(205,990)
(61,926)
(40,455)
-
-
(308,371)
- Inflow
226,748
61,369
40,136
-
-
328,253
Interest rate derivatives
- Interest rate swaps and cross-currency swaps
- Outflow
(3,671)
(6,379)
(40,775)
(103,678)
(20,035)
(174,538)
- Inflow
9,411
3,741
49,102
161,730
31,048
255,032
- Caps and floors
- Outflow
(84)
(35)
(195)
(296)
(2)
(612)
- Inflow
97
17
172
185
2
473
Total outflow
(225,812)
(85,273)
(93,392)
(103,974)
(20,037)
(528,488)
Total inflow
252,339
82,078
101,401
161,915
31,050
628,783
in EUR thousands
NLB Group
31 Dec 2023
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Foreign exchange derivatives
- Forwards
- Outflow
(52,767)
(12,024)
(15,874)
(250)
-
(80,915)
- Inflow
52,821
12,035
15,890
250
-
80,996
- Swaps
- Outflow
(264,488)
(150,003)
(77,229)
-
-
(491,720)
- Inflow
264,597
150,432
78,250
-
-
493,279
Interest rate derivatives
- Interest rate swaps and cross-currency swaps
- Outflow
(1,000)
(5,613)
(27,240)
(51,905)
(22,798)
(108,556)
- Inflow
3,250
4,043
34,172
79,633
37,296
158,394
- Caps and floors
- Outflow
(211)
(51)
(768)
(586)
(6)
(1,622)
- Inflow
179
37
629
416
3
1,264
Total outflow
(318,466)
(167,691)
(121,111)
(52,741)
(22,804)
(682,813)
Total inflow
320,847
166,547
128,941
80,299
37,299
733,933

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Performance Overview
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Statement
Financial
Report
in EUR thousands
NLB
31 Dec 2024
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Foreign exchange derivatives
- Forwards
- Outflow
(15,131)
(16,840)
(11,583)
-
-
(43,554)
- Inflow
15,147
16,857
11,604
-
-
43,608
- Swaps
- Outflow
(293,177)
(102,241)
(69,072)
-
-
(464,490)
- Inflow
293,653
102,183
69,154
-
-
464,990
Interest rate derivatives
- Interest rate swaps and cross-currency swaps
- Outflow
(3,749)
(6,724)
(41,751)
(107,834)
(20,606)
(180,664)
- Inflow
9,486
4,133
50,525
167,836
31,725
263,705
- Caps and floors
- Outflow
(84)
(35)
(195)
(296)
(2)
(612)
- Inflow
97
17
172
185
2
473
Total outflow
(312,141)
(125,840)
(122,601)
(108,130)
(20,608)
(689,320)
Total inflow
318,383
123,190
131,455
168,021
31,727
772,776
in EUR thousands
NLB
31 Dec 2023
Up to
1 Month
1 Month to
3 Months
3 Months to
1 Year
1 Year to
5 Years
Over
5 Years
Total
Foreign exchange derivatives
- Forwards
- Outflow
(50,861)
(11,715)
(15,874)
(250)
-
(78,700)
- Inflow
50,894
11,726
15,890
250
-
78,760
- Swaps
- Outflow
(310,781)
(279,104)
(131,949)
-
-
(721,834)
- Inflow
310,647
278,819
132,095
-
-
721,561
Interest rate derivatives
- Interest rate swaps and cross-currency swaps
- Outflow
(1,455)
(5,763)
(29,050)
(57,044)
(23,651)
(116,963)
- Inflow
3,605
4,162
35,869
87,326
38,276
169,238
- Caps and floors
- Outflow
(211)
(51)
(768)
(586)
(6)
(1,622)
- Inflow
179
37
629
416
3
1,264
Total outflow
(363,308)
(296,633)
(177,641)
(57,880)
(23,657)
(919,119)
Total inflow
365,325
294,744
184,483
87,992
38,279
970,823

NLB Group
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
6. 4. Management of
non-financial risks
a) Operational risk
When assuming operational risks, NLB Group follows
the guideline that such risks may not materially impact
its operations and, therefore, the risk appetite for
operational risks is low to moderate. The risk is also
gradually decreasing due to the reduced complexity
of operations in NLB Group, with the disinvestment
process of non-core activities and optimisation of
internal processes. NLB Group has set up a system of
collecting loss events, identification, assessment, and
management of operational risks, all with the aim of
ensuring quality management of operational risks. This
is particularly valid in strategic banking members.
All NLB Group banking members monitor risk appetite
limits for operational risk. The upper tolerance limit is
defined as the limit amount of net loss that an individual
member still allows in its operations. If the sum of net
loss exceeds the tolerance limit, a special treatment of
major loss events is required and, if necessary, takes
additional measures for the prevention or mitigation of
the same or similar loss events are taken. The warning
and critical limit of loss events are also defined, which
in case of exceeding require escalation procedures an
acceptance of possible additional risk management
measures. In addition, the Bank does not allow
certain risks in its business – for them a so-called ‘zero
tolerance’ was defined. For monitoring, some specific
more important key risk indicators that could show
a possible increase of an operational risk, the Bank
developed a specific methodology as an early warning
system. Such risks are periodically monitored in
different business areas, and the results are discussed
at the Operational Risk Committee. The latter was
named as the highest decision-making authority in
the area of operational risk management. Relevant
operational risk committees were also appointed
at other NLB Group banks. The Management Board
serves in this role at other subsidiaries. The main task
of the aforementioned bodies is to discuss the most
significant operational risks and loss events, and to
monitor and support the effective management of
operational risks including their mitigation within an
individual entity. All NLB Group entities, which are
included in the consolidation, have adopted relevant
documents that are in line with NLB Group standards.
In banking members, these documents are in line with
the development of operational risk management and
regularly updated. The whole NLB Group uses uniform
software support, which is also regularly upgraded.
In NLB Group, the reported incurred net loss arising
from loss events in 2024 was lower than in the previous
year and remained within the set tolerance limits
for operational risk. Certain litigation costs mainly
occurred due to systemic issues such as litigation risk
(e.g., cases related to loan processing fees and loan
insurance premiums in Serbia). For other realised
operational losses, banking members of the Group
performed a comprehensive analysis and defined
adequate mitigation measures to prevent or minimise
such events in the future.
In general, considerable attention is paid to reporting
loss events, their mitigation measures, and defining
operational risks in all segments. To treat major loss
events appropriately and as soon as possible, the Bank
introduced an escalation scale for reporting bigger or
more important loss events to the top levels of decision-
making at NLB and the Supervisory Board of NLB.
Additional attention is paid to the reporting of potential
loss events in order to improve the internal controls, and
thus minimise those and similar events. Furthermore, the
methodology to monitor, analyse, and report key risk
indicators is established, servicing as an early warning
system. The aim is to improve business and supporting
processes, as well enabling prompt response.
Through comprehensive identification of operational
risks, possible future losses are identified, estimated,
and appropriately managed. Each year, special
emphasis is placed on current risks as a result of the
risk identification process, including ESG risks. For
the later key risk indicators (KRIs) have been also
addressed for ESG risks, serving as an early warning
system. The major operational risks are actively
managed with the measures taken to reduce them.
An operational risk profile is prepared once a year
based on the operational risk identification. Special
emphasis is put on the most topical risks, among
which in particular are those with a low probability
of occurrence and very high potential financial
influence. For this purpose, the Bank has developed
the methodology of stress-testing for operational risk.
The methodology is a combination of modelling loss
event data and scenario analysis for exceptional, but
plausible events. Scenario analyses are made based
on experience and knowledge of experts from various
critical areas. The most significant loss could be derived
from the following potential events: possible difficulties
operating electronic banking channels, anti-money
laundering, cyber-attacks, and legal risks. For these
scenarios, existent controls were additionally revised,
while for identifying potential deficiencies, mitigation
measures were defined.
The capital requirement for operational risk is
calculated using the basic indicator approach at the
NLB Group level and using the standardised approach
at the NLB level.
b) Business Continuity Management (BCM)
In NLB Group, business continuity management is
carried out to protect lives, goods, and reputation.
Business continuity plans are prepared to be
used in the event of natural disasters, IT disasters,
epidemic/pandemic, and the undesired effects of the
environment to mitigate their consequences.
The concept of the action plan that is prepared
each year is such that the activities contribute to the
upgrading or improvement of the Business Continuity
Management System. In 2024, Business Continuity
Management was upgraded and optimised –
implementation of DORA (Digital Operational Resilience
Act) requirements in the Business Impact Analysis
(hereinafter: ‘BIA’).
The basis for modernising the business continuity plans
is the regular annual Business Impact Analysis (BIA). On
its basis, the adequacy of the plans for Organisational
Unit Plans (merged office buildings and HR plans)
and IT plans are checked. The best indicator of the
adequacy of the business continuity plans is testing. In
2024, NLB tested Manual Procedures, backup locations,
and the IT Disaster Recovery Plan and external. No
major deviations were identified.
In NLB Group, know-how and methodologies are
transferred to its members. The members have
adopted appropriate documents which are in line with

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Financial
Report
the standards of NLB and revised in accordance with
the development of business continuity management.
The activity of the members is monitored throughout
the year, and expert assistance is provided if necessary.
For more efficient functioning of the business continuity
management system in NLB Group, training courses
and visits to individual banking members are also
provided. All preventive and response measures with
regard to business continuity are regularly sent to
the members with the purpose to help and act in the
uniform way.
With regards to natural disasters (floods) and IT
failures, the Bank successfully used the business
continuity plans and instructions for manual
procedures, and thus also ensured business operations
in emergency situations.
c) Management of other types of non-financial risks –
strategic risks, reputation risk, and profitability risk
Risks not included in the regulatory capital
requirements (standardised approach) but have or
might have an important influence on the risk profile
of NLB Group, are regularly assessed, monitored, and
managed. In addition, they are integrated into the
internal capital adequacy assessment process (ICAAP).
NLB Group established internal methodologies for
identifying and assessing specific types of risk, referring
to the Group’s business model or arising from other
external circumstances. If a certain risk is assessed
as a materially important risk, relevant disposable
preventive and mitigation measures are applied,
including regular monitoring of their effectiveness.
On this basis, internal capital is considered, and its
consumption regularly monitored.
6. 5. Fair value hierarchy of financial
and non-financial assets and
liabilities
Fair value is the price that would be received when
selling an asset or paid to transfer a liability in an
orderly transaction between market participants
at the measurement date. NLB Group uses various
valuation techniques to determine fair value. IFRS
13 specifies a fair value hierarchy with respect to the
inputs and assumptions used to measure financial
and non-financial assets and liabilities at fair value.
Observable inputs reflect market data obtained from
independent sources, while unobservable inputs reflect
the assumptions of NLB Group. This hierarchy gives
the highest priority to observable market data when
available, and the lowest priority to unobservable
market data. NLB Group considers relevant and
observable market prices in its valuations, where
possible. The fair value hierarchy comprises the
following levels:
- Level 1 – Quoted prices (unadjusted) on active
markets. This level includes listed equities, debt
instruments, gold, derivatives, units of investment
funds, and other unadjusted market prices of assets
and liabilities. When an asset or liability may be
exchanged in multiple active markets, the principal
market for the asset or liability must be determined.
In the absence of a principal market, the most
advantageous market for the asset or liability must be
determined.
- Level 2 – A valuation technique where inputs are
observable, either directly (i.e., prices) or indirectly (i.e.,
derived from prices). Level 2 includes prices quoted for
similar assets or liabilities in active markets and prices
quoted for identical or similar assets, and liabilities
in markets that are not active. The sources of input
parameters for financial instruments, such as yield
curves, credit spreads, foreign exchange rates, and
the volatility of interest rates and foreign exchange
rates, is Bloomberg.
- Level 3 – A valuation technique where inputs are not
based on observable market data. Unobservable
inputs are used to the extent that relevant observable
inputs are not available. Unobservable inputs must
reflect the assumptions that market participants
would use when pricing an asset or liability. This
level includes non-tradable shares and bonds, and
derivatives associated with these investments and
other assets and liabilities for which fair value cannot
be determined with observable market inputs.
Wherever possible, fair value is determined as an
observable market price in an active market for
an identical asset or liability. An active market is a
market in which transactions for an asset or liability
are executed with sufficient frequency and volume
to provide pricing information on an ongoing basis.
Assets and liabilities measured at fair value in active
markets are determined as the market price of a unit
(e.g., a share) at the measurement date, multiplied by
the quantity of units owned by NLB Group. The fair
value of assets and liabilities whose market is not
active is determined using valuation techniques. These
techniques bear a different intensity level of estimates
and assumptions, depending on the availability
of observable market inputs associated with the
asset or liability that is the subject of the valuation.
Unobservable inputs shall reflect the estimates and
assumptions that other market participants would use
when pricing the asset or liability.
For non-financial assets measured at fair value and
not classified at Level 1, fair value is determined based
on valuation reports provided by certified valuators.
Valuations are prepared in accordance with the
International Valuation Standards (IVS).

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Performance Overview
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Financial
Report
a) Financial and non-financial assets and liabilities measured at fair value in the financial statements
in EUR thousands
31 Dec 2024
NLB Group
NLB
Level 1
Level 2
Level 3
Total
fair value
Level 1
Level 2
Level 3
Total
fair value
Financial assets
Financial instruments held for trading
9,424
8,891
23
18,338
9,424
11,626
23
21,073
Debt instruments
9,424
-
-
9,424
9,424
-
-
9,424
Derivatives
-
8,891
23
8,914
-
11,626
23
11,649
Derivatives - hedge accounting
-
77,771
-
77,771
-
77,771
-
77,771
Financial assets measured at fair value
through other comprehensive income
2,004,786
557,464
1,266
2,563,516
1,598,780
65,869
370
1,665,019
Debt instruments
2,004,463
462,460
-
2,466,923
1,598,780
3,095
-
1,601,875
Equity instruments
323
95,004
1,266
96,593
-
62,774
370
63,144
Non-trading financial assets mandatorily at
fair value through profit and loss
2,258
-
15,171
17,429
-
-
19,135
19,135
Debt instruments
1,000
-
-
1,000
-
-
-
-
Equity instruments
1,258
-
15,171
16,429
-
-
15,171
15,171
Loans
-
-
-
-
-
-
3,964
3,964
Financial liabilities
Financial instruments held for trading
-
6,995
-
6,995
-
9,977
-
9,977
Derivatives
-
6,995
-
6,995
-
9,977
-
9,977
Derivatives - hedge accounting
-
3,592
-
3,592
-
1,261
-
1,261
Financial liabilities measured at fair value through profit or loss
-
9,633
-
9,633
-
4,960
637
5,597
Non-financial assets
Investment properties
-
6,918
19,214
26,132
-
5,599
-
5,599
Non-current assets held for sale
-
2,849
8,187
11,036
-
2,849
-
2,849
Non-financial assets impaired during the year
Recoverable amount of property and equipment
-
-
10,491
10,491
-
-
-
-
Recoverable amount of investments in
subsidiaries, associates and joint ventures
-
-
-
-
-
-
1,466
1,466

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Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
31 Dec 2023
NLB Group
NLB
Level 1
Level 2
Level 3
Total
fair value
Level 1
Level 2
Level 3
Total
fair value
Financial assets
Financial instruments held for trading
-
15,698
20
15,718
-
17,937
20
17,957
Derivatives
-
15,698
20
15,718
-
17,937
20
17,957
Derivatives - hedge accounting
-
47,614
-
47,614
-
47,614
-
47,614
Financial assets measured at fair value
through other comprehensive income
1,452,046
798,154
1,356
2,251,556
955,638
67,071
303
1,023,012
Debt instruments
1,451,824
712,570
70
2,164,464
955,638
6,446
-
962,084
Equity instruments
222
85,584
1,286
87,092
-
60,625
303
60,928
Non-trading financial assets mandatorily at
fair value through profit and loss
5,317
-
8,858
14,175
-
-
16,643
16,643
Debt instruments
5,217
-
-
5,217
-
-
-
-
Equity instruments
100
-
8,858
8,958
-
-
8,858
8,858
Loans
-
-
-
-
-
-
7,785
7,785
Financial liabilities
Financial instruments held for trading
-
13,217
-
13,217
-
17,510
-
17,510
Derivatives
-
13,217
-
13,217
-
17,510
-
17,510
Derivatives - hedge accounting
-
3,540
-
3,540
-
1,420
-
1,420
Financial liabilities measured at fair value through profit or loss
-
4,482
-
4,482
-
1,976
1,234
3,210
Non-financial assets
Investment properties
-
10,927
20,189
31,116
-
7,640
-
7,640
Non-current assets held for sale
-
4,048
801
4,849
-
4,048
-
4,048
Non-financial assets impaired during the year
Recoverable amount of property and equipment
-
-
89
89
-
-
-
-
Recoverable amount of investments in
subsidiaries, associates and joint ventures
-
-
-
-
-
-
1,646
1,646

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b) Significant transfers of financial instruments
between levels of valuation
NLB Group’s policy of transfers of financial instruments
between levels of valuation is illustrated in the table
below.
Fair value
hierarchy
Equities
Equity stake
Gold
Funds
Debt securities
Loans
Derivatives
Equities
Currency
Interest
1
market value from
exchange market
market value from
spot market
official price by
fund management
company
market value from
exchange market
2
valuation model
valuation model
(underlying
in level 1)
valuation model
valuation model
3
valuation model
valuation model
valuation model
valuation model/
purchase price
valuation model
valuation model
(underlying
instrument
in level 3)
Transfers
from level 1 to 3
from level 1 to 3
from level 1 to 2
from level 2 to 3
equity excluded
from exchange
market
fund management
company stops
publishing regular
valuation
debt securities
excluded from
exchange market
underlying
instrument
excluded from
exchange market
from level 1 to 3
from level 3 to 1
from level 1 to 2
from level 3 to 2
companies
in insolvency
proceedings
fund management
company starts
publishing regular
valuation
debt securities not
liquid (not trading
for 6 months)
underlying
instrument
included in
exchange market
from level 1 to 3
from level 1 to 3
and from 2 to 3
equity not liquid
(not trading for
2 months)
companies
in insolvency
proceedings
from level 3 to 1
from level 2 to 1
and from 3 to 1
equity included in
exchange market
start trading with
debt securities on
exchange market
from level 3 to 2
until valuation
parameters are
confirmed on
ALCO (at least on
quarterly basis)
Transfers between levels of valuation of financial
instruments measured at fair value in financial
statements:
in EUR thousands
31 Dec 2024
NLB Group
NLB
From 1. level
To 2. level
From 1. level
To 2. level
Transfer of assets and liabilities between levels of valuation
Financial assets measured at fair value
through other comprehensive income
Debt instruments
(43,080)
43,080
(3,091)
3,091

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c) Financial and non-financial assets and liabilities at
Level 2 regarding the fair value hierarchy
Financial instruments on Level 2 of the fair value
hierarchy at NLB Group and NLB include:
- debt securities: mostly bonds not quoted on active
markets and valuated by a valuation model;
- derivatives: derivatives except forward derivatives
and options on equity instruments that are not quoted
on active markets; and
- the National Resolution Fund.
Non-financial assets on Level 2 of the fair value
hierarchy at NLB Group and NLB include investment
properties and non-current assets held for sale.
When valuing bonds classified on Level 2, NLB Group
primarily uses the income approach based on an
estimation of future cash flows discounted to the
present value. The input parameters used in the income
approach are the risk-free yield curve and the spread
over the yield curve (i.e., credit, liquidity, country).
Fair values for derivatives are determined using a
discounted cash flow model based on the risk-free
yield curve. Fair values for options are determined
using valuation models for options (the Garman and
Kohlhagen model, the binomial model, and the Black-
Scholes model).
At least one of the three valuation methods are used
for the valuation of investment property. The majority
of investment property is valued using the income
approach where the present value of future expected
returns is assessed.
When valuing an investment property, average rents
at similar locations and capitalisation ratios such as:
the risk-free yield, risk premium, and the risk premium
to account for capital preservation are used. Rents at
similar locations are generated from various sources,
like data from lessors and lessees, web databases, and
own databases. NLB Group has observable data for all
investment property at its disposal. If observable data
for similar locations are not available, NLB Group uses
data from wider locations and adjusts it appropriately.
d) Financial and non-financial assets and liabilities at
Level 3 of the fair value hierarchy
Financial instruments on Level 3 of the fair value
hierarchy in NLB Group and NLB include:
- equities: mainly financial equities that are not quoted
on active markets;
- debt instruments: bonds not quoted on active markets
and valuated by valuation model with inputs which
are not based on observable market data;
- derivative financial instruments: forward derivatives
and options on equity instruments that are not
quoted on an active organised market. Fair values
for forward derivatives are determined using the
discounted cash flow model. Fair values for equity
options are determined using valuation models
for options (the Garman and Kohlhagen model,
the binomial model, and Black-Scholes model).
Unobservable inputs include the fair values of
underlying instruments determined using valuation
models. The source of observable market inputs is the
Bloomberg information system;
- loans measured at fair value, which according to IFRS
9 do not pass the SPPI test. Fair value is calculated
on the basis of the discounted expected future cash
flows with the required rate of return. In defining the
expected cash flows for loans, the value of collateral
and other pay off estimates can be used.
Non-financial assets on Level 3 of the fair value
hierarchy at NLB Group include investment properties
and non-current assets held for sale.
NLB Group uses three valuation methods for the
valuation of equity financial assets mentioned in the
first bullet: income, market, and cost approaches.
NLB Group selects valuation model and values of
unobservable input data within a reasonable possible
range, but uses model and input data that other market
participants would use.
At least one of the three valuation methods are used
for the valuation of investment property. The majority
of investment property is valued using the income
approach where the present value of future expected
returns is assessed.
When valuing an investment property, average rents
at similar locations and capitalisation ratios such as:
the risk-free yield, risk premium, and the risk premium
to account for capital preservation are used. Rents at
similar locations are generated from various sources,
like data from lessors and lessees, web databases, and
own databases. NLB Group has observable data for all
investment property at its disposal. If observable data
for similar locations are not available, NLB Group uses
data from wider locations and adjusts it appropriately.

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Report
Movements of financial assets and liabilities at Level 3
in EUR thousands
Financial instruments
held for trading
Financial assets
measured at fair value
through OCI
Non-trading
financial assets
mandatorily at fair value
through profit or loss
Total financial
assets
NLB Group
Derivatives
Debt instruments
Equity instruments
Equity instruments
Balance as at 1 January 2023
17
2,236
1,256
7,519
11,028
Valuation:
- through profit or loss
3
-
-
1,362
1,365
- recognised in other comprehensive income
-
5,768
49
-
5,817
Foreign exchange differences
-
21
-
(173)
(152)
Increases
-
-
-
150
150
Decreases
-
(6,418)
(19)
-
(6,437)
Write-offs
-
(1,537)
-
-
(1,537)
Balance as at 31 December 2023
20
70
1,286
8,858
10,234
Valuation:
- through profit or loss
3
-
-
3,043
3,046
- recognised in other comprehensive income
-
-
(45)
-
(45)
Increases
-
-
54
3,270
3,324
Decreases
-
(70)
(29)
-
(99)
Balance as at 31 December 2024
23
-
1,266
15,171
16,460
in EUR thousands
Financial
instruments
held for trading
Financial assets
measured at fair value
through OCI
Non-trading financial assets
mandatorily at fair value through profit
or loss
Total financial
assets
Financial liabilities
measured at fair
value through
profit or loss
NLB
Derivatives
Debt instruments
Equity instruments
Equity instruments
Loans and other
financial assets
Loans and other
financial liabilities
Balance as at 1 January 2023
17
2,026
269
7,519
7,892
17,723
1,786
Valuation:
- through profit or loss
3
-
-
1,362
705
2,070
(552)
- recognised in other comprehensive income
-
5,768
19
-
-
5,787
-
Foreign exchange differences
-
21
-
(173)
-
(152)
-
Increases
-
-
-
150
492
642
-
Decreases
-
(6,278)
-
-
(1,304)
(7,582)
-
Write-offs
-
(1,537)
-
-
-
(1,537)
-
Merger of subsidiary
-
-
15
-
-
15
-
Balance as at 31 December 2023
20
-
303
8,858
7,785
16,966
1,234
Valuation:
- through profit or loss
3
-
-
3,043
60
3,106
(597)
- recognised in other comprehensive income
-
-
13
-
-
13
-
Increases
-
-
54
3,270
423
3,747
-
Decreases
-
-
-
-
(4,304)
(4,304)
-
Balance as at 31 December 2024
23
-
370
15,171
3,964
19,528
637

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Performance Overview
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Statement
Financial
Report
NLB Group and NLB recognise the effects from valuation
of trading instruments in income statement line item
‘Gains less losses from financial assets and liabilities held
for trading,’ the effects from valuation of non-trading
equity instruments and loans mandatorily measured at
fair value through profit or loss in the income statement
line item ‘Gains less losses from non-trading financial
assets mandatorily at fair value through profit or
loss,’ and the effects from valuation of financial assets
measured at fair value through other comprehensive
income in the accumulated other comprehensive
income line item ‘Financial assets measured at fair value
through other comprehensive income.’
In 2024 and in 2023, NLB Group and NLB recognised
the following unrealised gains or losses for financial
instruments that were at Level 3 as at 31 December:
in EUR thousands
NLB Group
Financial assets
held for trading
Financial assets measured at fair
value through OCI
Non-trading financial assets
mandatorily at fair value through
profit or loss
2024
Derivatives
Equity instruments
Equity instruments
Items of Income statement
Gains less losses from financial assets and liabilities held for trading
3
-
-
Gains less losses from non-trading assets mandatorily at fair value through profit or loss
-
-
3,043
Item of Other comprehensive income
Financial assets measured at fair value through other comprehensive income
-
21
-
in EUR thousands
NLB Group
Financial assets
held for trading
Financial assets measured at fair
value through OCI
Non-trading financial assets
mandatorily at fair value through
profit or loss
2023
Derivatives
Equity instruments
Equity instruments
Items of Income statement
Gains less losses from financial assets and liabilities held for trading
3
-
-
Gains less losses from non-trading assets mandatorily at fair value through profit or loss
-
-
1,362
Foreign exchange translation gains less losses
-
-
(173)
Item of Other comprehensive income
Financial assets measured at fair value through other comprehensive income
-
49
-

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Performance Overview
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Financial
Report
in EUR thousands
NLB
Financial assets held for
trading
Financial assets
measured at fair value
through OCI
Non-trading financial assets mandatorily at fair
value through profit or loss
Financial liabilities
measured at fair value
through profit or loss
2024
Derivatives
Equity instruments
Equity instruments
Loans and other
financial assets
Loans and other
financial liabilities
Items of Income statement
Gains less losses from financial assets
and liabilities held for trading
3
-
-
-
-
Gains less losses from non-trading assets
mandatorily at fair value through profit or loss
-
-
3,043
60
597
Item of Other comprehensive income
Financial assets measured at fair value
through other comprehensive income
-
13
-
-
-
in EUR thousands
NLB
Financial assets held for
trading
Financial assets
measured at fair value
through OCI
Non-trading financial assets mandatorily at fair
value through profit or loss
Financial liabilities
measured at fair value
through profit or loss
2023
Derivatives
Equity instruments
Equity instruments
Loans and other
financial assets
Loans and other
financial liabilities
Items of Income statement
Gains less losses from financial assets
and liabilities held for trading
3
-
-
-
-
Gains less losses from non-trading assets
mandatorily at fair value through profit or loss
-
-
1,362
705
552
Foreign exchange translation gains less losses
-
-
(173)
-
-
Item of Other comprehensive income
Financial assets measured at fair value
through other comprehensive income
-
19
-
-
-
Movements of non-financial assets at Level 3
in EUR thousands
Investment property
Non-current assets
held for sale
NLB Group
2024
2023
2024
2023
Balance as at 1 January
20,189
23,447
801
11,201
Effects of translation of foreign operations to presentation currency
65
(14)
6
11
Disposals
(1,329)
(1,954)
(150)
(10,206)
Transfer from/(to) property and equipment
70
(86)
7,441
-
Transfer from/(to) non-current assets held for sale
(81)
-
-
-
Transfer from/(to) other assets
-
86
-
-
Transfer from/(to) investment property
-
-
81
-
Net valuation to fair value
300
(1,290)
8
(205)
Balance as at 31 December
19,214
20,189
8,187
801

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Strategy
Risk Factors & Outlook
Performance Overview
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Financial
Report
e) Fair value of financial instruments not measured at
fair value in financial statements
Financial instruments not measured at fair value in
financial statements are not managed on a fair value
basis. For respective instruments, fair values are
calculated for disclosure purposes only and do not
impact NLB Group statement of financial position or
income statement.
The table below shows estimated fair values of financial
instruments not measured at fair value in the statement
of financial position.
in EUR thousands
NLB Group
NLB
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Carrying value
Fair value
Carrying value
Fair value
Carrying value
Fair value
Carrying value
Fair value
Financial assets measured
at amortised cost
- debt securities
3,725,195
3,706,958
2,522,229
2,440,596
2,846,779
2,808,210
1,966,169
1,889,481
- loans and advances to banks
458,921
458,651
547,640
547,555
193,172
185,768
149,011
149,011
- loans and advances to customers
16,363,649
15,697,133
13,734,601
13,256,192
8,653,348
8,242,067
7,148,283
6,895,232
- other financial assets
136,854
136,854
165,962
165,962
81,518
81,518
101,596
101,596
Financial liabilities measured
at amortised cost
- deposits from banks
and central banks
136,000
135,957
95,283
95,657
220,120
220,096
147,002
147,379
- borrowings from banks
and central banks
120,612
120,065
140,419
134,020
51,106
50,813
82,797
75,152
- due to customers
22,206,310
22,194,577
20,732,722
20,746,603
12,293,708
12,292,632
11,881,563
11,892,641
- borrowings from other customers
104,519
106,912
99,718
101,649
-
-
-
-
- debt securities issued
1,608,939
1,699,477
1,338,235
1,363,301
1,608,939
1,699,477
1,338,235
1,363,301
- other financial liabilities
296,725
296,725
357,116
357,116
145,802
145,802
198,020
198,020
Loans and advances to banks
The estimated fair value of deposits is based on
discounted cash flows using prevailing market interest
rates for instruments with similar credit risk and
residual maturities. The fair value of overnight deposits
equals their carrying value.
Loans and advances to customers
The estimated fair value of loans and advances
represents the discounted amount of estimated future
cash flows expected to be received. Expected cash
flows are discounted at current market rates for debts
with similar credit risk and residual maturities to
determine their fair value.
Deposits and borrowings
The fair value of sight deposits and overnight deposits
equals their carrying value. However, their actual value
for NLB Group depends on the timing and amounts of
cash flows, current market rates, and the credit risk
of the depository institution itself. A portion of sight
deposits is stable, similar to term deposits. Therefore,
their economic value for NLB Group differs from the
carrying amount.
The estimated fair value of other deposits and
borrowings from customers is based on discounted
cash flows using interest rates for new deposits with
similar residual maturities.
Debt securities measured at amortised cost and debt
securities issued
The fair value of debt securities measured at amortised
cost and debt securities issued is based on their quoted
market price or value calculated by using a discounted
cash flow method and the prevailing money market
interest rates.
Loan commitments
For credit facilities that are drawn soon after the NLB
Group grants loans (drawn at market rates) and loan
commitments to those clients that are not impaired,
the fair value is close to zero. For loan commitments
to clients that are impaired, fair value represents the
amount of the recognised provisions.
Other financial assets and liabilities
The carrying amount of other financial assets and
liabilities is a reasonable approximation of their fair
value as they mainly relate to short-term receivables
and payables.

NLB Group
Annual Report 2024
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Risk Factors & Outlook
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Statement
Financial
Report
Fair value hierarchy of financial instruments not measured at fair value in financial statements
in EUR thousands
31 Dec 2024
NLB Group
NLB
Level 1
Level 2
Level 3
Total fair value
Level 1
Level 2
Level 3
Total fair value
Financial assets measured
at amortised cost
- debt securities
3,067,440
632,269
7,249
3,706,958
2,692,742
115,468
-
2,808,210
- loans and advances to banks
-
458,651
-
458,651
-
185,768
-
185,768
- loans and advances to customers
-
-
15,697,133
15,697,133
-
-
8,242,067
8,242,067
- other financial assets
-
-
136,854
136,854
-
-
81,518
81,518
Financial liabilities measured
at amortised cost
- deposits from banks
and central banks
-
135,957
-
135,957
-
220,096
-
220,096
- borrowings from banks
and central banks
-
120,065
-
120,065
-
50,813
-
50,813
- due to customers
-
22,194,577
-
22,194,577
-
12,292,632
-
12,292,632
- borrowings from other customers
-
-
106,912
106,912
-
-
-
-
- debt securities issued
1,699,477
-
-
1,699,477
1,699,477
-
-
1,699,477
- other financial liabilities
-
-
296,725
296,725
-
-
145,802
145,802
in EUR thousands
31 Dec 2023
NLB Group
NLB
Level 1
Level 2
Level 3
Total fair value
Level 1
Level 2
Level 3
Total fair value
Financial assets measured
at amortised cost
- debt securities
2,030,120
403,255
7,221
2,440,596
1,779,995
109,486
-
1,889,481
- loans and advances to banks
-
547,555
-
547,555
-
149,011
-
149,011
- loans and advances to customers
-
-
13,256,192
13,256,192
-
-
6,895,232
6,895,232
- other financial assets
-
-
165,962
165,962
-
-
101,596
101,596
Financial liabilities measured
at amortised cost
- deposits from banks
and central banks
-
95,657
-
95,657
-
147,379
-
147,379
- borrowings from banks
and central banks
-
134,020
-
134,020
-
75,152
-
75,152
- due to customers
-
20,746,603
-
20,746,603
-
11,892,641
-
11,892,641
- borrowings from other customers
-
-
101,649
101,649
-
-
-
-
- debt securities issued
1,363,301
-
-
1,363,301
1,363,301
-
-
1,363,301
- other financial liabilities
-
-
357,116
357,116
-
-
198,020
198,020

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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
6. 6. Environmental and
climate-related risks
The NLB Group is engaged in contributing to
sustainable finance by incorporating environmental,
social, and governance (ESG) risks into its business
strategies, risk management framework, and internal
governance arrangements. With the adoption of the
NLB Group Sustainability programme, NLB Group
implemented sustainability elements into its business
model. Thus, sustainable finance integrates ESG criteria
into the Group’s business and investment decisions for
the lasting benefit of the Group’s clients and society.
The NLB Group Sustainability Committee oversees
the integration of the ESG factors to the NLB Group
business model.
ESG risks represent one of the risk drivers of the
existing type of risks. The Group integrates and
manages them within the established risk management
framework in the areas of credit, liquidity, market, and
operational risk. The management of ESG risks follows
ECB and EBA guidelines, following the tendency of their
comprehensive integration into all relevant processes.
The management of ESG risks is incorporated into
the Group’s overall credit approval process, collateral
management and the related credit portfolio
management. Sustainable financing is implemented in
accordance with the Group’s Environmental and Social
Management System (ESMS). In addition to addressing
ESG risks in all relevant stages of the credit-granting
process, relevant ESG criteria were also considered in
the collateral evaluation process.
NLB Group conducts a materiality assessment as part
of its overall risk identification process to determine
the level of transitional and physical risk to which the
Group is exposed. In this process, the identification
of environmental risk factors, relevant transmission
channels, and their materiality and impact on the
Group’s financial performance in short-, mid- and
long-term periods are assessed. From the perspective
of physical risk, the most relevant natural disasters
are floods, landslides, and drought, while hail and
windstorms are also frequent, but less material. Despite
this, the Group can expect its impact to increase
in the long run if no adequate policy changes are
implemented in a timely manner. Chronic risk is not
determined as a material risk.
On the portfolio level, the Group does not face
any large concentration towards specific NACE
industrial sectors exposed to climate risk, with the
role of transitional risk being more prevalent. Based
on the industry segmentation of the portfolio and
corresponding emissions, the Group has a relatively
low exposure to emission-intensive sectors in its
corporate clients’ businesses. The Group does not
finance companies that extract fossil fuels or operate
coal-fired power plants as part of its strategy.
Moreover, as a UN Net-Zero Banking Alliance member,
the Bank pledged to align its lending and investment
portfolio with net-zero emissions by 2050. In its initial
round of NZBA targets, NLB Group has focused on fossil
fuel-based and highly energy-intensive sectors (power
generation and iron and steel) and other sectors
where the Bank has substantial emissions and/or
exposure and available data. These include residential
mortgages and commercial real estate. Activities for
setting a second round of NZBA targets for sectors such
as transport and agriculture are underway.
An internal ESG stress-testing concept to identify the
most relevant financial vulnerabilities stemming from
transitional and physical climate risks was established,
which was further revised and enhanced by
considering disposable ESG-related data. The results of
the climate stress tests showed no material impacts on
the Group’s capital and liquidity positions. Besides, in
2024, the Group was also included in the ECB Stress test
exercise – the 2024 EBA Fit-for-55 climate risk scenario
analysis. By performing this exercise, the ECB assessed
how banks are prepared to deal with financial and
economic shocks from climate risk.
6. 7. Offsetting financial assets and
financial liabilities
NLB Group has entered into bilateral foreign exchange
netting arrangements with certain banks and
corporates. Cash flows from such transactions that are
due on the same day in the same currency, are settled
on a net basis, i.e., a single cash flow for each currency.
The settlement of all interest rates derivatives is also
carried out by netting of both legs of transaction. Assets
and liabilities related to these netting arrangements
are not presented in a net amount in the statement of
financial position because netting rules apply to cash
flows and not to the entire financial instrument.
NLB Group also holds certain standardised derivatives
(some interest rate swaps) with a clearing house or
central counterparty. A system of daily margins assures
the mitigation and collateralisation of exposures, as well
as the daily settlement of cash flows for each currency.
All derivatives are conducted under the conditions of
signed Master Agreements (MA), with international
banks. The ISDA MA is in place along with CSA annex
and for corporates domestic MA is in place, which
enable daily evaluation and exchange of margining.

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB Group
31 Dec 2024
Amounts not set off in the statement of financial position
Financial assets/liabilities
Gross amounts
of recognised
financial assets/
liabilities
Impact of
master netting
agreements
Financial
instruments
collateral
Net amount
Derivatives - assets
86,653
5,359
79,335
1,958
Derivatives - liabilities
10,583
5,014
518
5,051
in EUR thousands
NLB Group
31 Dec 2023
Amounts not set off in the statement of financial position
Financial assets/liabilities
Gross amounts
of recognised
financial assets/
liabilities
Impact of
master netting
agreements
Financial
instruments
collateral
Net amount
Derivatives - assets
63,283
4,992
52,103
6,188
Derivatives - liabilities
16,714
4,992
1,563
10,159
in EUR thousands
NLB
31 Dec 2024
Amounts not set off in the statement of financial position
Financial assets/liabilities
Gross amounts
of recognised
financial assets/
liabilities
Impact of
master netting
agreements
Financial
instruments
collateral
Net amount
Derivatives - assets
89,397
5,681
79,335
4,381
Derivatives - liabilities
11,238
5,336
518
5,384
in EUR thousands
NLB
31 Dec 2023
Amounts not set off in the statement of financial position
Financial assets/liabilities
Gross amounts
of recognised
financial assets/
liabilities
Impact of
master netting
agreements
Financial
instruments
collateral
Net amount
Derivatives - assets
65,551
5,013
54,346
6,192
Derivatives - liabilities
18,929
5,013
1,563
12,353
NLB Group and NLB have no financial assets/liabilities
set off in the statement of financial position.

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Annual Report 2024
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Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
7. Analysis by Segment for NLB Group
a) Segments
in EUR thousands
NLB Group
2024
Retail Banking
in Slovenia
Corporate and
Investment Banking
in Slovenia
Strategic
Foreign
Markets
Financial
Markets in
Slovenia
Non-Core
Members
Other
activities
Unallocated
Total
Total net income
448,318
178,806
619,035
(823)
1,282
10,917
-
1,257,535
Net income from external customers
275,938
222,584
627,179
105,582
565
12,962
-
1,244,810
Intersegment net income
172,380
(43,778)
(8,144)
(106,405)
717
(2,045)
-
12,725
Net interest income
325,249
131,729
483,131
(4,064)
924
(2,808)
-
934,161
Net interest income from external customers
157,483
180,490
492,294
104,083
407
(596)
-
934,161
Intersegment net interest income
167,766
(48,761)
(9,163)
(108,147)
517
(2,212)
-
-
Administrative expenses
(160,250)
(69,651)
(252,733)
(12,043)
(7,355)
(53,417)
-
(555,449)
Depreciation and amortisation
(15,600)
(6,397)
(32,417)
(818)
(237)
(4,019)
-
(59,488)
Reportable segment profit/(loss) before
impairment and provision charge
272,468
102,758
333,885
(13,684)
(6,310)
(46,519)
-
642,598
Other net gains/(losses) from equity
investments in associates and joint ventures
2,990
-
-
-
-
-
2,990
Impairment and provisions charge
(28,118)
(7,576)
4,073
(706)
2,174
(7,286)
-
(37,439)
Profit/(loss) before income tax
247,340
95,182
337,958
(14,390)
(4,136)
(53,805)
-
608,149
Owners of the parent
247,340
95,182
322,277
(14,390)
(4,136)
(53,805)
-
592,468
Non-controlling interests
-
-
15,681
-
-
-
-
15,681
Income tax
(77,916)
(77,916)
Profit for the year
514,552
Reportable segment assets
4,748,021
3,911,138
12,454,973
6,390,862
28,658
487,054
-
28,020,706
Investments in associates and joint ventures
14,661
-
-
-
-
-
-
14,661
Reportable segment liabilities
9,879,695
2,428,556
10,407,559
1,789,151
2,312
230,049
-
24,737,322
Additions to non-current assets
35,099
11,939
41,496
807
2
4,048
-
93,391

NLB Group
Annual Report 2024
542
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB Group
2023
Retail Banking
in Slovenia
Corporate and
Investment Banking
in Slovenia
Strategic
Foreign
Markets
Financial
Markets in
Slovenia
Non-Core
Members
Other
activities
Unallocated
Total
Total net income
366,988
149,184
541,624
40,437
(131)
5,574
-
1,103,676
Net income from external customers
246,811
204,868
541,098
95,748
(578)
5,349
-
1,093,296
Intersegment net income
120,177
(55,684)
526
(55,311)
447
225
-
10,380
Net interest income
264,707
106,462
423,249
37,752
1,540
(376)
-
833,334
Net interest income from external customers
147,803
161,103
429,464
94,023
1,444
(503)
-
833,334
Intersegment net interest income
116,904
(54,641)
(6,215)
(56,271)
96
127
-
-
Administrative expenses
(141,132)
(63,955)
(223,239)
(9,202)
(13,230)
(12,740)
-
(463,498)
Depreciation and amortisation
(12,675)
(6,240)
(27,990)
(689)
(508)
(635)
-
(48,737)
Reportable segment profit/(loss) before
impairment and provision charge
213,181
78,989
290,395
30,546
(13,869)
(7,801)
-
591,441
Other net gains/(losses) from equity
investments in associates and joint ventures
1,072
-
-
-
-
-
1,072
Impairment and provisions charge
(32,592)
7,909
1,124
4,757
3,729
973
-
(14,100)
Profit/(loss) before income tax
181,661
86,898
291,519
35,303
(10,140)
(6,828)
-
578,413
Owners of the parent
181,661
86,898
278,896
35,303
(10,140)
(6,828)
-
565,790
Non-controlling interests
-
-
12,623
-
-
-
-
12,623
Income tax
(15,090)
(15,090)
Profit for the year
550,700
Reportable segment assets
3,778,767
3,376,370
11,058,835
7,232,457
47,097
435,940
-
25,929,466
Investments in associates and joint ventures
12,519
-
-
-
-
-
-
12,519
Reportable segment liabilities
9,381,016
2,512,801
9,329,079
1,540,000
3,419
227,680
-
22,993,995
Additions to non-current assets
19,775
9,826
40,239
505
4
4,099
-
74,448
Segment reporting is presented in accordance with the
strategy on the basis of the organisational structure
used in management reporting of NLB Group’s results.
NLB Group’s segments are business units that focus on
different customers and markets. They are managed
separately because each business unit requires
different strategies and service levels.
The business activities of the parent bank (NLB) are
divided into several segments. Interest income and
expenses are reallocated between segments on the basis
of fund transfer prices (FTP). Other NLB Group members
are, based on their business activity, included in only one
segment except NLB Lease&Go, leasing, Ljubljana and
Summit Leasing Slovenija, which are according to their
business activities divided into two segments.
N Banka is included as an independent legal entity in
segment analysis for the year 2023 until 1 September
2023, when the legal and operational merger between
N Banka and NLB was successfully completed.
The segments of NLB Group are divided into core and
non-core segments.
The core segments are the following:
• Retail Banking in Slovenia covers individuals and micro
companies, asset management (NLB Skladi, Ljubljana),
and the part of NLB Lease&Go, leasing, Ljubljana and
Summit Leasing Slovenija, Ljubljana operating with
retail clients, as well as the part of the result of the
associated company Bankart.
• Corporate and Investment Banking in Slovenia covers
Key Corporate Clients, SMEs, Cross-Border Corporate
Financing, Investment Banking and Custody, Trade
finance, Restructuring and Workout, and the part of
NLB Lease&Go, leasing, Ljubljana, and Summit Leasing
Slovenija, Ljubljana operating with corporate clients.
• Strategic Foreign Markets consist of strategic banks in
the Group operating in the strategic markets (Serbia,
North Macedonia, Bosnia and Herzegovina, Kosovo,
and Montenegro), as well as the investment companies
NLB Fondovi, Skopje and NLB Fondovi, Beograd, NLB
DigIT, Beograd, and leasing companies NLB Lease&Go
Skopje, NLB Lease&Go leasing Beograd, and Mobil
Leasing, Zagreb.
• Financial Markets in Slovenia include treasury
activities and trading with financial instruments,
while also presenting the results of asset and liability
management (ALM).
• Other activities include categories whose operating
results cannot be allocated to specific segments,
as well as NLB Cultural Heritage Management
Institute, Real Estate entities from 2024 (the latter
were previously in the non-core segment) and newly
established company NLB Car&Go, Ljubljana.
Non-Core Members include the operations of non-core
NLB Group members, i.e. entities in liquidation, LHB, NLB
Srbija, NLB Crna Gora, and SLS HOLDCO, Ljubljana.
NLB Group is primarily a financial group, and net
interest income represents the majority of its net
revenues. NLB Group’s main indicator of a segment’s
efficiency is net profit before tax. No revenues were
generated from transactions with a single external
customer that would amount to 10% or more of NLB
Group’s revenues.

NLB Group
Annual Report 2024
543
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
b) Geographical information
Geographical analysis includes a breakdown of items
with respect to the country in which individual NLB
Group entities are located.
in EUR thousands
Revenues
Net income
Profit/(loss) before income tax
Income tax
NLB Group
2024
2023
2024
2023
2024
2023
2024
2023
Slovenia
872,734
729,170
617,297
556,854
250,734
275,533
(35,689)
19,447
South East Europe
770,095
663,042
626,954
538,752
356,653
305,507
(42,196)
(34,525)
Bosnia and Herzegovina
119,925
104,460
100,789
85,158
47,928
40,677
(3,913)
(3,467)
Croatia
2,914
-
3,039
(557)
189
(527)
(336)
-
Kosovo
78,396
68,279
61,730
56,374
40,786
39,797
(3,924)
(3,995)
Montenegro
68,936
62,625
56,720
51,658
33,562
32,032
(4,989)
(5,502)
North Macedonia
126,627
111,599
105,436
90,233
76,479
49,895
(9,903)
(4,910)
Serbia
373,297
316,079
299,240
255,886
157,709
143,633
(19,131)
(16,651)
Western Europe
209
103
559
(2,310)
762
(2,627)
(31)
(12)
Germany
-
-
29
51
(160)
(402)
-
-
Switzerland
209
103
530
(2,361)
922
(2,225)
(31)
(12)
Total
1,643,038
1,392,315
1,244,810
1,093,296
608,149
578,413
(77,916)
(15,090)
The column ‘Revenues’ includes interest and similar
income, dividend income, and fee and commission
income.
The column ‘Net Income’ includes net interest income,
dividend income, net fee and commission income, the
net effect of financial instruments, foreign exchange
translation, the effect on the derecognition of assets,
net operating income, cash contribution to resolution
funds and deposit guarantee schemes, gains less losses
from modification of financial assets, and gain less
losses from non-current assets held for sale.
in EUR thousands
Non-current assets
Total assets
Number of employees
NLB Group
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Slovenia
212,961
160,574
15,554,251
14,851,067
2,856
2,689
South East Europe
238,335
223,185
12,462,052
11,072,317
5,464
5,291
Bosnia and Herzegovina
40,195
38,861
2,156,231
1,934,891
1,025
990
Croatia
4,490
-
125,708
1,194
41
1
Kosovo
13,571
13,810
1,426,811
1,229,426
478
468
Montenegro
24,522
23,163
956,080
928,913
410
390
North Macedonia
36,567
34,276
2,168,629
1,895,297
995
962
Serbia
118,990
113,075
5,628,593
5,082,596
2,515
2,480
Western Europe
10
27
19,064
18,601
2
2
Germany
10
27
516
552
-
-
Switzerland
-
-
18,548
18,049
2
2
Total
451,306
383,786
28,035,367
25,941,985
8,322
7,982

NLB Group
Annual Report 2024
544
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
The table below presents data on NLB Group
members before intercompany eliminations and
consolidation journals:
in EUR thousands
Revenues
Net income
Profit/(loss) before
income tax
Income tax
NLB Group
2024
2023
2024
2023
2024
2023
2024
2023
Slovenia
1,155,998
909,550
860,643
704,971
525,573
511,693
(34,802)
28,958
South East Europe
780,300
670,510
621,072
542,776
359,168
308,129
(42,497)
(34,879)
Bosnia and Herzegovina
121,307
105,503
98,514
83,567
47,807
40,555
(3,913)
(3,467)
Croatia
2,914
-
1,672
(385)
277
(366)
(352)
-
Kosovo
78,654
68,468
59,608
55,182
40,952
39,963
(3,924)
(3,995)
Montenegro
71,505
64,729
56,360
50,465
33,557
32,836
(4,989)
(5,502)
North Macedonia
127,080
111,933
102,660
86,612
77,081
48,822
(9,903)
(4,910)
Serbia
378,840
319,877
302,258
267,335
159,494
146,319
(19,416)
(17,005)
Western Europe
216
118
490
(2,467)
766
(2,711)
(31)
(12)
Germany
-
-
29
51
(160)
(402)
-
-
Switzerland
216
118
461
(2,518)
926
(2,309)
(31)
(12)
Total
1,936,514
1,580,178
1,482,205
1,245,280
885,507
817,111
(77,330)
(5,933)

NLB Group
Annual Report 2024
545
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
8. Related-Party
Transactions
A related party is a person or entity that is related to
NLB Group in such a manner that it has control or joint
control, has a significant influence, or is a member of
the key management personnel of the reporting entity.
Related parties of NLB Group and NLB include: key
management personnel (Management Board, other
key management personnel and their family members);
the Supervisory Board; companies in which members of
the Management Board, key management personnel,
or their family members have control, joint control, or
a significant influence; or a major shareholder of NLB
with significant influence, subsidiaries, associates, and
joint ventures.
Related-party transactions with Management Board
and other key management personnel, their family
members and companies these related parties have
control, joint control, or significant influence
A number of banking transactions are entered into
with related parties within regular course of business.
The volume of related-party transactions and the
outstanding balances are as follows:
in EUR thousands
NLB Group
Management Board and other
Key management personnel
Family members of the
Management Board and other
key management personnel
Companies in which members
of the Management Board, key
management personnel or their
family members have control, joint
control, or a significant influence
Supervisory Board
2024
2023
2024
2023
2024
2023
2024
2023
Loans issued
Balance at 1 January
1,855
2,173
444
469
-
-
24
54
Increase
1,663
1,214
326
307
-
-
88
46
Decrease
(1,456)
(1,532)
(273)
(332)
-
-
(83)
(76)
Balance at 31 December
2,062
1,855
497
444
-
-
29
24
Interest income
65
57
18
17
-
-
1
1
Deposits received
Balance at 1 January
2,367
2,556
1,153
926
272
218
417
348
Increase
4,742
2,617
1,036
1,440
539
496
1,081
407
Decrease
(4,476)
(2,806)
(1,132)
(1,213)
(335)
(442)
(1,232)
(338)
Balance at 31 December
2,633
2,367
1,057
1,153
476
272
266
417
Interest expenses
(33)
(33)
(7)
(6)
-
-
(4)
(5)
Other financial assets
1
-
-
-
-
-
-
-
Other financial liabilities
1
1
-
-
6
12
-
-
Other financial liabilities
measured at fair value through
profit or loss (note 2.32.)
4,960
2,075
-
-
-
-
-
-
Other operating liabilities
15,028
11,066
-
-
-
-
-
-
Guarantees issued and
loan commitments
302
287
79
64
-
-
23
14
Fee income
22
19
9
8
3
3
1
1
Other income
21
16
-
-
-
-
-
-
Other expenses
-
-
-
-
(122)
(94)
(1)
(1)

NLB Group
Annual Report 2024
546
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
Management Board and other Key
management personnel
Family members of the Management
Board and other key management
personnel
Companies in which members
of the Management Board, key
management personnel or their
family members have control, joint
control or a significant influence
Supervisory Board
2024
2023
2024
2023
2024
2023
2024
2023
Loans issued
Balance at 1 January
1,854
2,172
444
469
-
-
24
54
Increase
1,648
1,203
326
307
-
-
88
46
Decrease
(1,440)
(1,521)
(273)
(332)
-
-
(83)
(76)
Balance at 31 December
2,062
1,854
497
444
-
-
29
24
Interest income
65
57
18
17
-
-
1
1
Deposits received
Balance at 1 January
2,357
2,536
1,153
926
272
218
417
348
Increase
4,672
2,555
1,036
1,440
539
496
1,081
407
Decrease
(4,396)
(2,734)
(1,132)
(1,213)
(335)
(442)
(1,232)
(338)
Balance at 31 December
2,633
2,357
1,057
1,153
476
272
266
417
Interest expenses
(33)
(33)
(7)
(6)
-
-
(4)
(5)
Other financial assets
1
-
-
-
-
-
-
-
Other financial liabilities
1
1
-
-
6
12
-
-
Other financial liabilities
measured at fair value through
profit or loss (note 2.32.)
4,960
1,975
-
-
-
-
-
-
Other operating liabilities
15,014
11,080
-
-
-
-
-
-
Guarantees issued and
loan commitments
295
279
79
64
-
-
23
14
Fee income
22
19
9
8
3
3
1
1
Other income
21
16
-
-
-
-
-
-
Other expenses
-
-
-
-
(122)
(94)
(1)
(1)
Key management compensation
The remuneration for the 2024 for the members of the
Supervisory Board of NLB d.d. and the Management
Board of NLB d.d. is regulated in Remuneration Policy
for the Members of the Supervisory Board of NLB d.d.
and the Members of the Management Board of NLB
d.d. The remuneration for the identified employees and
other employees is regulated in Remuneration Policy for
employees of NLB d.d. and NLB Group.
In the Remuneration Policy and based thereon and in
accordance with Commission Delegated regulation (EU)
2021/923, the Bank designates identified employees.
In designating identified employees, the internal
organisation and the nature, scope, and complexity
of the Bank’s activities are taken into account. The
criteria fully take into account the risks that the Bank
or the NLB Group is or could be exposed to its given
risk profile and risk appetite. As identified employees
under the Remuneration Policy are identified members
of the Bank’s Supervisory Board, members of the Bank’s
Management Board, senior management, and other
identified employees identified as identified employees
on the basis of the Bank’s annual self-assessment.
Members of the Supervisory Board may, in relation to
their function of a member of the Supervisory Board,
receive only remuneration that is compliant with the
relevant resolutions of the Bank’s General Meeting.
The Supervisory Board members are entitled to a
remuneration for performing their function for their
membership in the Supervisory Board of the Bank and
the committees of the Supervisory Board of the Bank,
which are determined in accordance with respective
applicable resolution by the General Meeting of the
Bank, and to reimbursement of travel expenses and
accommodation costs up to the amount provided by the
regulations governing reimbursement of costs related to
work and other income not included in the tax base.
The Bank’s General Meeting may determine and change
the remuneration of the members of the Supervisory
Board independently from the Remuneration Policy, and
may change, repeal, or replace any of its resolutions in
relation to the remuneration of the Supervisory Board
members at any time, or adopt a new resolution in
relation to the remuneration of the Supervisory Board
members. The last changes of the remuneration of
members of the Supervisory Board were adopted at the
General Meeting of NLB d.d. 19 June 2023.
The performance of Management Board Members
is defined by financial and non-financial criteria. In
addition to the salary determined in their employment
contract, other income and reimbursement of
costs and other benefits, they are also entitled to a
Performance Bonus which is divided into a short-term
incentive (hereinafter: ‘STI’) and a long-term incentive
(hereinafter: ‘LTI’). The Short-term Performance Criteria
for STI and LTI consists of the financial goals of NLB

NLB Group
Annual Report 2024
547
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Group, the goals in the areas covered by the individual
Management Board Member, and the personal goals. To
determine the performance of and individual member
of the Management Board during the Subsequent
Performance Period (LTI), the following targets are used:
a) relative total shareholder return (RTSR); and b) goals
that derive from the Bank’s long term strategy and that
are related to the sustainability and development of the
Bank and are linked to the promotion of organisational
culture, employee development and customer relations
(only for the chief risk officer the cost of risk are included
in the targets).
The objectives and performance assessment criteria
for STI and LTI of each member of the Management
Board shall be determined each year by the
Supervisory Board NLB d.d. at the time of adoption of
the Bank’s annual business plan. Also, the Supervisory
Board of NLB d.d. confirms the objectives of the heads
of control or supervisory functions and financial
targets of NLB d.d. The objectives and performance
assessment criteria for the identified employees are
determined by the Management Board.
Management Board members are entitled to a STI
in the amount of a maximum of nine average gross
monthly salaries of each member of the Management
Board, and LTI for a single accrual period, which can
amount to a maximum of three average gross monthly
salaries of each member of the Management Board.
Other identified employees are entitled to a variable
part of remuneration according to the category
of employee in the maximum amount of three to
six salaries. Key management shall be entitled to
a variable part of the performance benefit only in
proportional part to the actual period of employment
(duration of the term of office) of the Bank during the
period to which the variable part of the performance
benefit relates.
The non-deferred part of variable remuneration is
paid no later than three months after the adoption
of the Annual Report of NLB Group for the business
year to which the variable remuneration relates.
Variable remuneration part of payment of an identified
employee is awarded and paid in cash without deferral,
provided that the amount does not exceed EUR 50
thousand or/and is higher than one-third of his/her
total remuneration for each financial year, and if this is
permissible in accordance with the relevant regulation.
If the variable remuneration part of payment of an
identified employee exceeds EUR 50 thousand or/and
is higher than one-third of his/her total remuneration
for each financial year and if this is permissible in
accordance with the relevant regulation, then at least
50% of the variable remuneration must consist of
instruments. The part of the variable remuneration of
an identified employee consisting of instruments shall
be awarded and paid under the terms and conditions
in the valid Remuneration Policy in instruments whose
value is based on the value of the share of NLB d.d. The
instrument gives its holder yields equal to the dividends
the NLB d.d.’s share gives its holder.
The deferred part of the variable part of the salary must
be deferred for a period of at least five years of the
day on which the non-deferred part of such variable
remuneration is paid, and it is paid in proportional
shares (in fifths), according to the relevant legislation.
The table below shows payments in presented periods:
in EUR thousands
NLB Group and NLB
Management Board
Other key management
personnel
Supervisory Board
2024
2023
2024
2023
2024
2023
Short-term benefits
3,678
3,076
7,550
6,604
775
728
Cost refunds
9
9
115
112
89
104
Long-term bonuses:
- severance pay
-
-
189
120
-
-
- other benefits
17
53
178
163
-
-
- variable part of payments
901
299
2,346
1,252
-
-
Total
4,605
3,437
10,378
8,251
864
832
Short-term benefits include:
- monetary benefits (gross salaries, supplementary
insurance, holiday allowances, and other bonuses);
- non-monetary benefits (company cars, health care,
residential facilities, etc.).
The reimbursement of cost comprises food allowances,
travel expenses, and use of own resources.

NLB Group
Annual Report 2024
548
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Payments to individual members of the Management Board
in EUR
Member/Mandate
2024
2023
Blaž Brodnjak
Short-term benefits:
01.12.2012
- gross salary and holiday allowance
753,098
662,159
- benefits and other short-term bonuses
14,405
9,040
Costs refunds
1,452
1,490
Long-term bonuses:
- other benefits
2,904
2,904
- variable part of payments
241,055
92,854
Total
1,012,914
768,447
Peter Andreas Burkhardt
Short-term benefits:
18.09.2013
- gross salary and holiday allowance
678,405
552,167
- benefits and other short-term bonuses
48,283
46,318
Costs refunds
1,504
1,540
Long-term bonuses:
- other benefits
2,904
3,364
- variable part of payments
210,292
83,480
Total
941,387
686,869
Archibald Kremser
Short-term benefits:
31.07.2013
- gross salary and holiday allowance
718,973
632,159
- benefits and other short-term bonuses
35,699
33,364
Costs refunds
1,434
1,324
Long-term bonuses:
- other benefits
2,904
3,364
- variable part of payments
229,865
88,539
Total
988,875
758,750
Antonio Argir
Short-term benefits:
28.04.2022
- gross salary and holiday allowance
453,128
352,909
- benefits and other short-term bonuses
56,206
64,854
Costs refunds
1,431
1,515
Long-term bonuses:
- other benefits
2,904
37,140
- variable part of payments
73,114
34,047
Total
586,783
490,465
Andrej Lasič
Short-term benefits:
28.04.2022
- gross salary and holiday allowance
453,128
352,909
- benefits and other short-term bonuses
1,364
3,756
Costs refunds
1,387
1,469
Long-term bonuses:
- other benefits
2,904
3,364
- variable part of payments
73,114
34,047
Total
531,897
395,545
Hedvika Usenik
Short-term benefits:
28.04.2022
- gross salary and holiday allowance
453,128
352,909
- benefits and other short-term bonuses
12,336
13,234
Costs refunds
1,325
1,507
Long-term bonuses:
- other benefits
2,904
2,904
- variable part of payments
73,114
34,047
Total
542,807
404,601

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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Payments to individual members of the Supervisory Board
in EUR
Member/Mandate
2024
2023
Primož Karpe
Annual compensation
110,400
103,680
11.02.2016
Other bonuses - benefit
292
279
Costs refunds
12,364
9,300
David Eric Simon
Annual compensation
43,211
87,480
04.08.2016 - 17.06.2024
Other bonuses - benefit
-
279
Costs refunds
9,534
13,162
Shrenik Dhirajlal Davda
Annual compensation
103,500
83,683
10.06.2019
Other bonuses - benefit
292
279
Costs refunds
13,300
19,444
Mark William Lane Richards
Annual compensation
93,150
87,480
10.06.2019
Other bonuses - benefit
292
279
Costs refunds
11,984
18,141
Verica Trstenjak
Annual compensation
38,410
73,254
15.06.2020 - 17.06.2024
Other bonuses - benefit
-
279
Costs refunds
1,048
3,490
Sergeja Kočar
Annual compensation
34,572
23,659
17.06.2020
Other bonuses - benefit
292
279
Costs refunds
4,115
1,017
Islam Osama Bahgat Zekry
Annual compensation
82,800
77,760
14.06.2021
Other bonuses - benefit
292
279
Costs refunds
10,621
17,656
Tadeja Žbontar Rems
Annual compensation
54,265
44,774
22.01.2021
Other bonuses - benefit
292
279
Costs refunds
1,292
309
Cvetka Selšek
Annual compensation
86,020
30,102
15.08.2023
Other bonuses - benefit
292
279
Costs refunds
2,431
2,580
André Marc Richard
Prudent Toccanier
Annual compensation
93,150
33,063
15.08.2023
Other bonuses - benefit
292
279
Costs refunds
11,126
6,773
Luka Vesnaver
Annual compensation
20,930
-
30.09.2024
Other bonuses - benefit
292
-
Costs refunds
1,463
-
Natalia Olegovna Ansell
Annual compensation
12,190
-
08.11.2024
Other bonuses - benefit
-
-
Costs refunds
9,660
-
Gregor Rok Kastelic
Annual compensation
-
38,025
10.06.2019 - 19.06.2023
Other bonuses - benefit
-
-
Costs refunds
-
4,527
Andreas Klingen
Annual compensation
-
42,250
22.06.2015 - 19.06.2023
Other bonuses - benefit
-
-
Costs refunds
-
7,917

NLB Group
Annual Report 2024
550
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Related-party transactions with subsidiaries, associates, and joint ventures
in EUR thousands
NLB Group
Associates
Joint ventures
2024
2023
2024
2023
Loans issued
Balance at 1 January
10
1,057
-
201
Increase
119
1,161
-
2
Decrease
(117)
(2,208)
-
(203)
Balance at 31 December
12
10
-
-
Interest income
-
63
-
1
Impairment
-
825
-
6
Deposits received
Balance at 1 January
6,168
5,375
1,451
3,071
Effects of translation of foreign operations to presentation currency
-
-
4
(3)
Increase
6,753
10,378
3,338
6,902
Decrease
(2,588)
(9,585)
(3,197)
(8,519)
Balance at 31 December
10,333
6,168
1,596
1,451
Interest expenses
-
-
(48)
(36)
Other financial assets
7
7
-
1
Other financial liabilities
1,642
1,460
-
-
Guarantees issued and loan commitments
28
30
-
-
Income/(expenses) provisions for guaranties and commitments
-
2
-
-
Fee income
8
8
-
-
Fee expenses
(18,891)
(16,167)
-
-
Other income
42
53
5
5
Other expenses
(827)
(1,174)
-
-

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Annual Report 2024
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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
in EUR thousands
NLB
Subsidiaries
Associates
Joint ventures
2024
2023
2024
2023
2024
2023
Loans issued
Balance at 1 January
458,684
337,900
10
982
-
201
Increase
1,466,812
660,088
119
1,161
-
2
Decrease
(575,225)
(539,304)
(117)
(2,133)
-
(203)
Balance at 31 December
1,350,271
458,684
12
10
-
-
of which at amortised cost
1,345,680
450,213
12
10
-
-
of which at fair value through profit or loss
4,591
8,471
-
-
-
-
Interest income
38,472
19,938
-
63
-
1
Impairment
(1,651)
11
-
861
-
6
Valuation
658
1,231
-
-
-
-
Deposits
Balance at 1 January
21,762
223,492
-
-
-
-
Increase
1,646,007
1,120,256
-
-
-
-
Decrease
(1,605,441)
(1,321,986)
-
-
-
-
Balance at 31 December
62,328
21,762
-
-
-
-
Interest income
1,337
985
-
-
-
-
Impairment
-
43
-
-
-
-
Other equity instruments
Balance at 1 January
-
-
-
-
-
-
Increase
19,930
-
-
-
-
-
Balance at 31 December
19,930
-
-
-
-
-
Loans received
Balance at 1 January
-
13,001
-
-
-
-
Increase
330,057
36,887
-
-
-
-
Decrease
(330,057)
(49,888)
-
-
-
-
Balance at 31 December
-
-
-
-
-
-
Interest expenses
(1,924)
(24)
-
-
-
-
Deposits received
Balance at 1 January
104,949
165,778
6,168
5,375
395
40
Increase
93,033,722
87,107,211
6,753
10,378
94
418
Decrease
(92,978,089)
(87,168,040)
(2,588)
(9,585)
(56)
(63)
Balance at 31 December
160,582
104,949
10,333
6,168
433
395
Interest expenses
(6,136)
(5,205)
-
-
-
-
Derivatives
Fair value
2,090
54
-
-
-
-
Contractual amount
206,739
298,290
-
-
-
-
Interest income
101
25
-
-
-
-
Interest expenses
(474)
(208)
-
-
-
-
Other financial assets
3,092
2,058
7
7
-
-
Impairment
-
3
-
-
-
-
Other financial liabilities
4,545
4,615
1,394
1,340
-
-
Guarantees issued and loan commitments
100,348
87,094
28
30
-
-
Income/(expenses) provisions for guaranties and commitments
120
(76)
-
2
-
-
Received loan commitments and financial guarantees
11,103
10,741
-
-
-
-
Fee income
15,309
10,632
8
8
-
-
Fee expenses
(4)
(5)
(15,240)
(12,698)
-
-
Other income
2,366
1,959
42
43
2
2
Other expenses
(6,352)
(5,087)
(820)
(1,137)
-
-
Gains less losses from financial assets and liabilities held for trading
2,811
(1,898)
-
-
-
-

NLB Group
Annual Report 2024
552
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Related-party transactions with major shareholder with significant influence
The volumes of related party transactions with major shareholder are as follows:
in EUR thousands
NLB Group
NLB
2024
2023
2024
2023
Loans issued
Balance at 1 January
13,384
17,595
13,384
17,595
Increase
2,670
2,731
2,670
2,731
Decrease
(1,941)
(6,942)
(1,941)
(6,942)
Balance at 31 December
14,113
13,384
14,113
13,384
Interest income
-
713
-
713
Investments in securities
Balance at 1 January
577,529
564,287
516,926
473,389
Exchange difference on opening balance
103
(27)
-
-
Acquisition of subsidiaries
-
-
-
33,617
Increase
448,959
550,561
393,686
409,682
Decrease
(287,713)
(548,065)
(209,996)
(410,346)
Valuation
9,583
10,773
8,341
10,584
Balance at 31 December
748,456
577,529
708,957
516,926
Interest income
12,825
7,131
11,543
5,692
Interest expenses
-
(21)
-
(21)
Other financial assets
113
65
113
65
Other financial liabilities
60
20
60
20
Guarantees issued and loan commitments
1,681
1,466
1,681
1,466
Fee income
1,174
574
1,174
574
Fee expenses
(27)
(28)
(27)
(28)
Other income
250
272
250
272
Other expenses
(5)
(5,009)
(5)
(5,009)
Gains less losses from financial assets and liabilities not measured at fair value through profit or loss
-
(656)
-
(656)
Gains less losses from financial assets and liabilities held for trading
19
-
19
-

NLB Group
Annual Report 2024
553
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group and NLB disclose all transactions with
the major shareholder with significant influence.
For transactions with other government-related
entities, NLB Group discloses individually significant
transactions with exposure above EUR 40 million and
their business accounts balances.
in EUR thousands
NLB Group and NLB
Amount of significant transactions
concluded during the year
Number of significant transactions
concluded during the year
2024
2023
2024
2023
Guarantees issued and loan commitments
-
50,000
-
1
in EUR thousands
NLB Group and NLB
Year-end balance of all
significant transactions
Number of significant transactions
at year-end
2024
2023
2024
2023
Loans
386,762
406,005
6
10
Debt securities measured at amortised cost
63,912
64,132
1
1
Borrowings, deposits and business accounts
40,159
30,399
1
3
Guarantees issued and loan commitments
105,546
152,500
3
2
in EUR thousands
NLB Group and NLB
Effects in income statement
during the year
2024
2023
Interest income from loans
16,364
18,489
Fees and commissions income
55
51
Interest income from debt securities measured at amortised cost and net valuation effects from hedge accounting
2,151
2,411

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
9. Events After the
Reporting Date
Senior Preferred Bonds
On January 21, 2025, NLB issued senior preferred bonds
in a total nominal value of EUR 500 million, 4NC3 tenor,
and ISIN code XS2972971399.
Subordinated Bonds
On February 5, 2025, NLB conducted a tender offer
for the repurchase of outstanding Tier 2 subordinated
bonds, with approaching call dates and ISIN code
XS2113139195, in the amount of EUR 10.5 million.

NLB Group
Annual Report 2024
555
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Group Directory
Nova Ljubljanska banka d. d. , Ljubljana
Trg republike 2
1000 Ljubljana, Slovenia
Tel: +386 1 476 39 00, +386 1 477 20 00
E-mail: info@nlb.si
www.nlb.si
Slovenian network
Area Branch Ljubljana
Trg republike 2
1000 Ljubljana, Slovenia
Area Branch Northwest and Central Slovenia
Ljubljanska cesta 62
1230 Domžale, Slovenia
Area Branch East Slovenia
Titova cesta 2
2000 Maribor, Slovenia
Area Branch Northeast Slovenia
Rudarska cesta 3
3320 Velenje, Slovenia
Area Branch Southeast Slovenia
Seidlova cesta 3
8000 Novo mesto, Slovenia
Area Branch Southwest Slovenia
Cesta Zore Perello - Godina 7
6000 Koper, Slovenia
Private Banking
Trg republike 2
1000 Ljubljana, Slovenia
Micro Enterprises
Trg republike 2
1000 Ljubljana, Slovenia
Mobile Banking
Trg republike 2
1000 Ljubljana, Slovenia
Small and Mid-Corporates
Central Slovenia
Trg republike 2
1000 Ljubljana, Slovenia
Northwest region
Ljubljanska cesta 62
1230 Domžale, Slovenia
Primorsko-Goriška region
Cesta Zore Perello - Godina 7
6000 Koper, Slovenia
Podravsko-Pomurska region
Titova cesta 2
2000 Maribor, Slovenia
Savinjsko-Koroška region
Kocenova 1
3000 Celje, Slovenia
Dolenjsko-Posavska region
Seidlova cesta 3
8000 Novo mesto, Slovenia
CSA & Cross-Border
Financing
Trg republike 2
1000 Ljubljana, Slovenia
Large Corporates
Institutional Investors
Trg republike 2
1000 Ljubljana, Slovenia
Large Corporates
Trg republike 2
1000 Ljubljana, Slovenia
Investment Banking
and Custody
Trg republike 2
1000 Ljubljana, Slovenia
Trade Finance Services
Trg republike 2
1000 Ljubljana, Slovenia
Members of NLB Group
NLB Komercijalna Banka AD Beograd
Bulevar Mihajla Pupina 165v
11070 New Belgrade, Serbia
E-mail: kontakt.centar@nlbkb.rs
www. nlbkb.rs
NLB Banka AD Skopje
Vodnjanska 1
1000 Skopje, North Macedonia
E-mail: info@nlb.mk
www.nlb.mk
NLB Banka a. d. Banja Luka
Milana Tepića 4
78000 Banja Luka, Republic of Srpska,
Bosnia and Herzegovina
E-mail: nlbinfo@nlb-rs.ba
www.nlb-rs.ba

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SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB Banka d. d. , Sarajevo
Ul. Koševo br. 3
71000 Sarajevo, Bosnia and Herzegovina
E-mail: info@nlb.ba
www.nlb.ba
NLB Banka sh. a. , Prishtina
Rr. Ukshin Hoti nr. 124
10000 Prishtina, Kosovo
E-mail: qendrakontaktuese@nlb-kos.com
www.nlb-kos.com
NLB Banka a. d. , Podgorica
Bulevar Ivana Crnojevića 171
81000 Podgorica, Montenegro
E-mail: info@nlb.me
www.nlb.me
NLB DigIT d. o. o. , Beograd
Omladinskih brigada 90b
11070 New Belgrade, Serbia
E-mail: office@nlbdigit.rs
www.nlbdigit.rs
NLB Lease&Go, leasing, d. o. o. , Ljubljana
Šlandrova ulica 2
1231 Ljubljana - Črnuče, Slovenia
E-mail: info@nlbleasego.si
www.nlbleasego.si
NLB Lease&Go, d. o. o. , Skopje
Vodnjanska 1
1000 Skopje, North Macedonia
E-mail: info@nlbleasego.mk
www.nlbleasego.mk
NLB Lease&Go Leasing d. o. o. Beograd
Mihajla Pupina 165v (prvi sprat)
11070 New Belgrade, Serbia
E-mail: office@nlbleasego.rs
www.nlbleasego.rs
NLB Car&Go d. o. o. , Ljubljana
Šlandrova ulica 2
1231 Ljubljana - Črnuče, Slovenia
SLS HOLDCO, d. o. o. , Ljubljana
Flajšmanova ulica 3
1000 Ljubljana, Slovenia
Summit Leasing Slovenija d. o. o. , Ljubljana
Flajšmanova ulica 3
1000 Ljubljana, Slovenia
E-mail: info@summit-leasing.si
www.summit-leasing.si
Mobil Leasing d. o. o.
Kovinska ulica 5
10000 Zagreb, Croatia
E-mail: info@mobil-leasing.hr
www.mobil-leasing.hr
NLB MUZA Cultural Heritage Management Institute,
Ljubljana
Čopova ulica 3
1000 Ljubljana, Slovenia
www.nlb-muza.si
Prvi faktor d. o. o. , v likvidaciji, Ljubljana
Slovenska cesta 17
1000 Ljubljana, Slovenia
Prvi faktor – faktoring d. o. o. , Beograd – u likvidaciji
Bulevar Mihajla Pupina 165v
11070 New Belgrade, Serbia
Prvi faktor d. o. o. u likvidaciji, Zagreb
Miramarska cesta 24
10000 Zagreb, Croatia
E-mail: info@prvifaktor.hr
NLB InterFinanz AG in Liquidation, Zürich
Beethovenstrasse 48
8002 Zürich, Switzerland
E-mail: info@nlbinterfinanz.ch
NLB InterFinanz d. o. o. , Beograd – u likvidaciji
Bulevar Mihajla Pupina 165v
11070 New Belgrade, Serbia
NLB Skladi, upravljanje premoženja, d. o. o. , Ljubljana
Tivolska cesta 48
1000 Ljubljana, Slovenia
E-mail: info@nlbskladi.si
www.nlbskladi.si
NLB Fondovi a. d. , Beograd
Svetogorska 42
11000 Belgrade, Serbia
E-mail: info@nlbfondovi.rs
www.nlbfondovi.rs
NLB Fondovi AD Skopje
Blvd. Partizanski odredi 14A-1/2
1000 Skopje, North Macedonia
E-mail: info@nlbfondovi.mk
www.nlbfondovi.mk
Bankart d. o. o. , Ljubljana
Celovška cesta 150
1000 Ljubljana, Slovenia
E-mail: info@bankart.si
www.bankart.si
LHB Aktiengesellschaft, Frankfurt am Main
Silberbornstrasse 14
D-60320 Frankfurt, Germany
PRO-REM d. o. o. , Ljubljana – v likvidaciji
Čopova 3
1000 Ljubljana, Slovenia
E-mail: info@prorem.si
www.nlbrealestate.com
NLB REAL ESTATE d. o. o. , Podgorica
Bul. Džordža Vašingtona br. 102, I. sprat/20
81000 Podgorica, Montenegro
E-mail: info@nlb-re.com
www.nlbrealestate.com
OL Nekretnine d. o. o. u likvidaciji, Zagreb
Miramarska 24/6
10000 Zagreb, Croatia

NLB Group
Annual Report 2024
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MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB REAL ESTATE d. o. o. , Beograd
Bulevar Mihajla Pupina 165v
11070 New Belgrade, Serbia
E-mail: office@nlbre.rs
www.nlbrealestate.com
NLB Srbija d. o. o. , Beograd
Bulevar Mihajla Pupina 165v
11070 New Belgrade, Serbia
E-mail: office@nlbsrbija.co.rs
www.nlbsrbija.co.rs
NLB Crna Gora d. o. o. , Podgorica
Bulevar Džordža Vašingtona 102,
II sprat/38
81000 Podgorica, Montenegro
NLB REAL ESTATE d. o. o. , Ljubljana
Čopova 3
1000 Ljubljana, Slovenia
E-mail: info@nlb-re.com
www.nlbrealestate.com
ARG – Nepremičnine d. o. o.
Vrhniška cesta 30
1354 Horjul, Slovenia
Branches and
Representative Offices
of NLB Group members
outside their country of
residence
NLB InterFinanz AG in Liquidation
Ljubljana Branch in liquidation
Puharjeva ulica 3
1000 Ljubljana, Slovenia

NLB Group
Annual Report 2024
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Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
Definitions and Glossary of Selected Terms
AC

Amortised Costs
AIB

Associations of Issuing Bodies
AJPES
Agency of the Republic of Slovenia for Public Legal
Records and Related Services
ALCO
Asset and Liability Committee
ALM

Asset and Liability Management
ALMM
Additional Liquidity Monitoring Metrics
AML/CTF

Anti-Money Laundering and Counter-Terrorism
Financing
AMLD
Anti-Money Laundering Directive
Articles of Association
Articles of Association of the NLB d.d.
ARSO
Slovenian Environmental Agency
AT1

Additional Tier 1 capital
AuM

Assets under Management
AVA

Additional Valuation Adjustments
BAM

Bosnian Convertible Mark
BCM

Business Continuity Management
BCP

Business Continuity Plans
BEV

Battery electric vehicles
BIA

Business Impact Analysis
BiH

Bosnia and Herzegovina
BMR

Benchmarks Regulation
BoS

Bank of Slovenia
bps

Basis Points
BPV

Basis Point Value
BSCC

British-Slovenian Chamber of Commerce
CAPEX
Capital Expenditure
CB

Central Bank
CBA

Collective bargaining agreements
CBCR
Country-by-Country Reporting
CBR

Combined Buffer Requirement
CCF

Credit Conversion Factor
CCYB
Countercyclical Capital Buffer
CEE

Central Eastern Europe
CEO

Chief Executive Officer
CER

Sustainable Business Network of Slovenia
CET1

Common Equity Tier 1 capital
CEU

Energy efficiency centre
CFO

Chief Financial Officer
CGU

Cash-Generating Units
CGPO
Chief Group Governance, Payments and Innovations
Officer
CIR

Cost-to-Income Ratio
CISO

Chief Information Security Officer
CMO

Chief Marketing Officer
CoR

Cost of Risk

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Annual Report 2024
559
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
CRD

Capital Requirements Directive
CRE

Commercial Real Estate
CRM

Customer Relationship Management
CRO

Chief Risk Officer
CRR

Capital Requirements Regulation
CSA

Credit Support Annex
DSCR
Debt Service Coverage Ratio
CSD

Central Security Depository
CSR

Corporate Social Responsibility
CSRD
Corporate Sustainable Reporting Directive
CTO

Chief Transformation Officer
CVA

Credit Value Adjustments
DAC 6
EU Council Directive 2011/16
DEFRA
Department for Environment, Food & Rural Affairs - UK
DEI

Diversity, equity and inclusion
DGS

Deposit Guarantee Scheme
DMA

Double Materiality Assessment
DORA
Digital Operational Resilience Act
DPO

Data Protection Officer
DT

Deferred Tax
DTA

Deferred Tax Asset
DWH

Data Warehouse
EAD

Exposure at Default
EAF

Electric Arc Furnaces
EaR

Earnings at Risk
EBA

European Banking Authority
EBRD
European Bank for Reconstruction and Development
ECB

European Central Bank
ECL

Expected Credit Losses
ECRA
Enterprise Compliance Risk Assessment
eDMS
electronic Document Management System
EEA

European Economic Area
EF

Emission factor
EFRAG
European Financial Reporting Advisory Group
EIB

European Investment Bank
EPC

Energy Performance Certificate
EPS

Earnings Per Share
ESEF

European Single Electronic Format
E&S

Environmental and Social
ESG

Environmental, Social and Governance
ESMS
Environmental and Social Management System
ESRS

European Sustainability Reporting Standards
EU

European Union
EURIBOR

Euro Interbank Offered Rate
EU Taxonomy
Regulation (EU) 2020/852
EV

Electric vehicle
EVE

Economic Value of Equity
EVS

European Valuation Standards

NLB Group
Annual Report 2024
560
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
EWS

Early Warning System
EYKA
Education Camp for Financial Literacy
FATCA
Foreign Account Tax Compliance Act
FCA

Financial Conduct Authority
FDI

Foreign Direct Investment
FTE

Full Time Equivalent
FTP

Fund Transfer Pricing
FURS

Financial Administration of the Republic of Slovenia
FVOCI
Fair Value Through Other Comprehensive Income
FVTPL
Fair Value Through Profit or Loss
FX

Foreign Exchange
FY
Financial Year
GAR

Green Asset Ratio
GBF

Green Bond Framework
GDP

Gross Domestic Product
GDPR
General Data Protection Regulation
GDR

Global Depositary Receipts
GenAI
Generative Artificial Intelligence
General Meeting

General Meeting of Shareholders of NLB d.d.
GFANZ
Glasgow Financial Alliance for Net Zero
GGB

Government Guaranteed Bonds
GHG

Greenhouse gases
GLWF
Green Light World Flight
GPA

General Provisions of the Agreement
GRI

Global Reporting Initiative – Sustainability Reporting
Standards
GWP AR5

Global warming potential – Fifth Assessment Report
HEV

Hybrid electric vehicles
HHI

Herfindahl-Hirschman Index
HR

Human Resources
HQ

Headquarters
HQLA
High-quality liquid assets
HVAC
Heating, ventilation and airconditioning
IAS

International Accounting Standard
IASB

International Accounting Standards Board
IBOR

Interbank Offered Rate
ICAAP
Internal Capital Adequacy Assessment Process
ICAO

The International Civil Aviation Organization
ICE

Internal Combustion Engine Vehicle
ICMA
International Capital Market Association
ICT

Information and Communication Technology
IEA

International Energy Agency
IFRIC

International Financial Reporting Interpretations
Committee
IFRS

International Financial Reporting Standard
IJS

Institute Jožef Stefan
ILAAP
Internal Liquidity Adequacy Assessment Process
ILO

International Labour Organization
IPCC

The Intergovnmental Panel on Climante Change
IRB

Internal ratings-based

NLB Group
Annual Report 2024
561
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
IRRBB
Interest Rate Risks for Banking Book
IRO

Impacts, risks and opportunities
IRS

Interest Rate Swaps
ISDA

International Swaps and Derivatives Association
ISIN

International Securities Identification Number
IVS

International Valuation Standards
JST

Joint Supervisory Team
KB

Komercijalna Banka
KDD

Central Securities Clearing Corporation
KPI

Key Performance Indicator
KRI

Key Risk Indicators
KYC

Know Your Client
LCP

Liquidity Contingency Plan
LCR

Liquidity Coverage Ratio
LECL

Lifetime Expected Credit Losses
LGD

Loss Given Default
LIBOR
London Interbank Offered Rate
LJSE

Ljubljana Stock Exchange
LPD

Lifetime Probability of a Default
LRE

Leverage Ratio Exposure
LSE

London Stock Exchange
LTD

Loan-to-Deposit Ratio
LTI

Long-Term Incentive
LTV

Loan-to-Value
LULUCF

The Regulation on land, land use change and forestry
(EU) 2018/841
M&A

Mergers and Acquisitions
MA

Master Agreements
Management Board or MB

Management Body of NLB d.d.
MDA

Maximum Distributable Amount
MEEM
Multi-Period Excess Earnings Method
MiFID II

Markets in Financial Instruments Directive
MIGA
Multilateral Investment Guarantee Agency
MPM

Management-Defined Performance Measures
MREL
Minimum Requirement of Own Funds and Eligible
Liabilities
MS

Mid-swap
NACE
Statistical Classification of Economic Activities in the
European Community
NBRNM

National Bank of the Republic of North Macedonia
NCV

Net caloric value
NFC

Non-Financial Corporation
NFRD
Non-Financial Reporting Directive (2014/95/EU)
NGW

Negative Goodwill, i.e. Gains from Bargain Purchase
NII

Net Interest Income
NLB or the Bank

NLB d.d.
NLB Group
The Group or Group
NPE

Non-Performing Exposures
NPL

Non-Performing Loans
NPS

Net Promoter Score

NLB Group
Annual Report 2024
562
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NPV

Net Present Value
NSFR
Net stable funding ratio
NZBA
Net-Zero Banking Alliance
NZE

Net zero emissions
OBM

Operational Business Margin
OCI

Other Comprehensive Income
OCR

Overall Capital Requirement
OECD
Organisation for Economic Co-operation and
Development
OECD CRS

OECD Common Reporting Standards
OEM

Original Exposure Method
OHS

Occupational health and safety management system
OPEX
Operational Expenditure
O-SII

Other Systemically Important Institutions
OU

Organisational Units
PACI

Partnering Against Corruption Inititave
PCAF
Partnership for Carbon Accounting Financials
PHEV
Plug-in hybrid electric vehicle
p. p.

Percentage Point(s)
PPA

Power Purchase Agreement
PPP

Purchase Power Parity
P1R

Pillar 1 Requirement
P2G

Pillar 2 Guidance
P2R

Pillar 2 Requirements
PD

Probability of Default
PeP

Politically Exposed Person
PPA

Power Purchase Agreement
POCI

Purchased or Originated Credit-Impaired
POS

Point of Sale
PSD2

Payments Services Directive
RCP

Representative Concentration Pathway
RE

Real Estate
REAM
Real Estate Asset Management
RES

Renewable Energy Sources
RFP

Request for proposal
RFR

Risk-Free Rates
RICO

Risk Committee
RICS

Royal Institution of Chartered Surveyors
ROA

Return on Assets
ROE

Return on Equity
RORAC
Return On Risk-Adjusted Capital
RoS

Republic of Slovenia
RRE

Residential Real Estate
RSD

Serbian dinar
RTSR

Relative Total Shareholder Return
RWA

Risk Weighted Assets
SASB
Renewable Energy Sources
SBITOP

Slovenian Blue-chip Index
SBTi

Science-based targets

NLB Group
Annual Report 2024
563
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
SDA

Slovenian Directors’ Association
SDK

Standardna klasifikacija dejavnosti (Standard
Classification of Activities – Slovenia)
SEE

South-Eastern Europe
SEPA

Single Euro Payment Area
SFRD
Sustainable Finance Disclosure Regulation Regulation
(EU) 2019/2088
SICR

Significant Increase of Credit Risk
SMA

Security Market Agency
SME

Small and Medium-sized Enterprises
SPPI

Solely Payment of Principal and Interest
SREP

Supervisory Review and Evaluation Process
SSH

Slovenian Sovereign Holding
STI

Short-Term Incentive
SSM

Single Supervisory Mechanism
Supervisory Board or SB

Supervisory Board of NLB d.d.
T1

Tier 1
TCR

Total Capital Ratio
tCO2eq
tonnes of CO2 equivalent
TCFD
Task force on Climate-Related Financial Disclosures
TNFD
Taskforce on Nature-related Financial Disclosures
tNPS

transactional Net Promoter Score
TRC

Total Rental Costs
TREA
Total Risk exposure Amount
TSCR

Total SREP Capital Requirement
UN

United Nations
UNEP FI

United Nations Environment Programme Finance
Initiative
UN PRB

United Nations Principles for Responsible Banking
UN PRI
United Nations Principles for Responsible Investment
UN SDG

United Nations Sustainable Development Goals
VaR

Value-at-Risk
VAT

Value Added Tax
WEF

World Economic Forum
WEO 22

World Energy Outlook 2022
Workers’ Council

Workers’ Council of NLB d.d.
WTT

Well-to-tank emissions
ZBan-3
Slovenian Banking Act
ZEO

Zero-energy building
ZGD-1
Companies Act (Zakon o gospodarskih družbah)
ZGD-1M

Companies Act (Zakon o gospodarskih družbah) -
Amendment M
ZTFI-1
Financial Instruments Market Act
ZVKNNLB

Slovenian Act for Value Protection of Republic of
Slovenia’s Capital Investment in Nova Ljubljanska banka
d.d., Ljubljana

NLB Group
Annual Report 2024
564
Overview
MB Statement
SB Statement
Key Highlights
Business Report
Strategy
Risk Factors & Outlook
Performance Overview
Segment Analysis
NLB Group Key Members
Risk Management
Sustainability
Statement
Financial
Report
NLB d.d., Ljubljana
nlb.si
NLB d.d.
Production:
Saatchi & Saatchi Ljubljana
Photographs:
Barbara Zajc, Iztok Lazar, Matko Mioč, iStock
Archive of NLB and Archives of Sports Associations and Clubs
All rights reserved: NLB d. d., Ljubljana
Ljubljana, April 2025
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