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TBC Bank Group

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FY2019 Annual Report · TBC Bank Group
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Make Life 
Easier

ANNUAL REPORT 2019

20
19

TBC BANK1 is the largest 

banking group in Georgia –

serving around 90% of the 

country’s adult population. 

TBC Bank is listed on the 

premium segment of London 

Stock Exchange and is a FTSE 

250 constituent.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

CONTENTS

STRATEGIC REPORT2

At a glance 

2019 highlights 

Chairman’s statement 

CEO letter 

Implications of COVID-19  

Georgia 

Business model and strategy 

Key performance indicators 

Divisional overview 

Stakeholder engagement 

Doing business responsibly 

Material existing and emerging risks 

Risk management 

Financial review 

GOVERNANCE2

Directors’ governance statement 

Directors’ report 

Board biographies 

The Bank’s Management Board biographies 

Corporate governance and

Nomination committee report 

Risk committee report 

Remuneration committee report 

Audit committee report 

2

3

4

6

9

10

12

18

20

52

56

84

93

108

124

131

136

140

143

147

151

180

FINANCIAL STATEMENTS

Independent auditors’ report 

Consolidated statement of financial position 

Consolidated statement of profit or loss and

other comprehensive income 

Consolidated statement of changes in equity 

Consolidated statement of cash flows 

Separate statement of financial position 

Separate statement of changes in equity 

Separate statement of cash flows 

Notes to the financial statements 

ADDITIONAL INFORMATION

Shareholder information 

Glossary 

Abbreviations 

191

198

199

200

201

202

203

204

205

319

320

321

For more information visit our website 
www.tbcbankgroup.com

1  TBC Bank Group PLC (the company), the UK-incorporated 

parent company of JSC TBC Bank (the Bank) and its subsidiaries 
(together TBC Bank or the Group)

2  The figures in the strategic report and governance sections are 

unaudited, except where explicitly indicated as audited

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

1

AT A GLANCE

WHO WE ARE ?
We  are  the  leading  universal  financial  group  in  Georgia,  holding  39.5%  and  39.0%  market  shares1 
in total loans and total deposits respectively.  We hold a dominant position in all our major business 
lines  comprised  of  retail,  corporate  and  micro,  small  and  medium  enterprises  (MSME).  Our  fully-
fledged financial services include traditional banking offerings as well as the industry’s cutting-edge 
solutions. We are pioneers in the region2 in launching the first fully digital bank, Space and the first 
customer focused digital ecosystems, creating a whole new world of opportunities for our customers.  

COMPLETE SUIT OF TRADITIONAL FINANCIAL SERVICES

FULLY DIGITAL BANK

CUSTOMER FOCUSED DIGITAL ECOSYSTEMS

For more information
please refer to
 20-32, 36-41 pages

For more information
please refer to 34-35 pages

For more information
please refer to 43-51 pages

OUR MISSION > Make Life Easier

OUR VISION

We  are  TBC,  a  technology  driven  company,  that 
exists for its users, knows them and cares for them.

We have the best team, which is innovative and is 
not afraid of mistakes.

TBC is an important part of people’s daily lives and 
serves them digitally.

1 
2 

  Based on data published by National Bank of Georgia as of 31 December 2019
  Region in this context comprises: Armenia, Azerbaijan and Georgia

TBC CULTURE IS BASED ON 
OUR TEAM, WHICH IS
 ` Winner by nature;
 ` Happy;
 ` Curious;
 ` Goal-oriented;
 ` Open for new opportunities;
 ` Honest;
 ` And always delivers on its promises.

2019 HIGHLIGHTS

STRONG FINANCIAL PERFORMANCE

  545.1 mln
+ 19.8% YoY
UNDERLYING NET PROFIT 1(APM)

 540.3 mln
+ 23.5% YoY
REPORTED NET PROFIT 

22.6%
- 0.2pp YoY
UNDERLYING RETURN
ON AVERAGE EQUITY 1(APM)

22.4%
+ 0.4pp YoY
REPORTED RETURN
ON AVERAGE EQUITY 

 12,662.0mln
+ 22.1% YoY
TOTAL LOANS

 10,049.3 mln
+ 7.5% YoY
TOTAL DEPOSITS

BEST-IN-CLASS DIGITAL CAPABILITIES

 ` World’s best in mobile banking 20192 
 ` 93% retail offloading ratio

SUPERIOR CUSTOMER EXPERIENCE

 ` Best service company in Georgia3

HIGH EMPLOYEE SATISFACTION LEVELS

 ` 1.76 Employee happiness index4

STRONG BRAND

 ` 100% Aided brand awareness among Georgian population5
 ` 41% Top of mind in banking sector5

1  More information about underlying figures (APMs) is given in Annex 1 on pages 122-123
2  Named by Global Finance Magazine
3  Based on survey conducted by independent research company IPM among the retail segment in December 2019
4  The index is measured on a scale from -3 to +3 (with +3 meaning very happy) based on internal survey, created in collaboration with the world’s 

leading consulting firm, conducted among employees who are part of the agile structure in December 2019

5  Based on survey conducted by the independent research company, TNS in October 2019

CHAIRMAN’S STATEMENT

Dear shareholders,
This is my first letter to you in the capacity of the Chairman 
of TBC Bank Group PLC. I was appointed as Chairman of 
TBC  Bank  Group  PLC  on  25  July  2019  following  the 
resignation  of  Mamuka  Khazaradze  and  Badri  Japaridze 
as Chairman and Deputy Chairman. 

Mamuka Khazaradze founded the bank back in 1992 and 
together  with  his  friend  and  business  partner  Badri 
Japaridze  led  TBC  Bank  to  the  position  of  the  leading 
financial institution in the region. On behalf of the entire 
TBC team I would like to thank Mamuka and Badri for their 
vision,  leadership  and  tremendous  contribution  to  the 
success of this company and Georgia as a whole. 

KEY ACHIEVEMENTS AND STRATEGY

The  Group  once  more  delivered  strong  financial 
performance  in  2019,  however  the  Board  decided  not 
to  recommend  dividend  at  the    upcoming  AGM  due  to 
uncertainties related to COVID-19 outbreak.

The Group made significant progress towards our mission 
of  making  the  lives  of  our  customers  easier  in  today’s 
digital world by continuing to transform into a technology-
driven  company  and  expanding  our  value  proposition 
beyond  traditional  banking.  Naturally,  it  is  disappointing 
to see that our good financial performance and strategic 
achievements have not been reflected in our share price 
due  to  external  factors.  However,  the  Board  is  confident 
that  the  Group  is  on  the  right  track  and  will  continue  to 
focus  on  its  strategic  priorities,  which  are  expected  to 
generate long-term sustainable value for all stakeholders.  

4

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

As part of our digital transformation, we took a big stride 
in  2019  in  the  development  of  our  customer-centric 
digital  ecosystems,  which  will  allow  us  to  create  deeper 
and broader relationships with our customers by offering 
them  innovative  services  in  various  areas  of  their  lives 
and to generate new revenue streams for the Group. This 
year,  we  launched  the  first  Georgian  housing  (Livo)  and 
e-commerce  (Vendoo)  ecosystems  and  also  acquired 
a  leading  e-commerce  player  in  the  Georgian  market, 
My  Group,  which  operates  in  three  online  marketplace 
verticals: automotive & automotive spare parts, consumer-
to-consumer  goods,  and  housing.    This  acquisition  has 
dramatically increased our digital presence and has given 
us access to a large customer base of around 1.7 million 
unique  monthly  visitors.  In  the  coming  year,  we  plan 
to  significantly  enhance  our  ecosystems  and  generate 
synergies between them as well as the wider Group. 

As  digital  transformation  cannot  occur  without  strong 
support  and  commitment  from  our  employees,  we 
launched  a  company-wide,  agile  transformation  project 
that  will  help  us  create  a  more  dynamic  and  flexible 
corporate  culture,  leading  to  faster  time-to-market, 
more  creativity  and  higher  employee  satisfaction.  Over 
the course of 2019, this agile structure was successfully 
implemented  in  several  departments  and  has  already 
demonstrated very promising results. We plan to continue 
to roll it out across other departments in the next year.  

I  am  also  delighted  with  our  progress  in  relation  to 
international expansion.  As a result of the diligent work of 
our team working on the Uzbekistan project, we received 
a banking licence in April 2020, which allows us to launch 
our banking operations in the country in the near future. 
As  announced  earlier,  our  strategy  is  to  build  a  next 
generation  bank  for  retail  and  MSME  customers  with  a 
strong focus on digital offerings in partnership with EBRD, 
IFC  and  a  local  Uzbek-Oman  investment  company.  In 
parallel, we are actively developing our payments business 
in  Uzbekistan,  through  our  recently  acquired  subsidiary, 
Payme,  which  is  the  leading  payments  company  in  the 
country,  already  serving  around  2  million  customers  by 
March 2020.

The CEO letter describes our strategic initiatives in more detail.

OPERATING ENVIRONMENT  

2019  has  been  a  challenging  year  from  the  macro 
perspective.  After  the  negative  spillover  from  Turkey  in 
2018, the Russian flight ban came in as an external shock 
leading to a slowdown in tourism inflows, exchange rate 
depreciation and elevated inflation pressures. 

Nevertheless,  thanks  to  the  diversification  of  tourism 
inflows  and  the  sector’s  abundant  untapped  potential, 
the tourism industry recovered fast on the back of strong 
growth  from  the  EU,  Georgia’s  neighbours,  including  a 
recovery  from  Turkey,  as  well  as  growth  from  Central 
Asia, Israel and Middle Eastern countries. It is important 
to  highlight,  that  starting  from  September  2019,  the  EU 
share  of  tourism  inflows  has  surpassed  the  one  from 
Russia, akin to remittances from the beginning of 2018. 

Moreover, the central bank has managed to address the 
undervalued GEL by turning more hawkish on the GEL on 
the one hand, and more dovish on the US$ and the EUR 
on  the  other,  ensuring  the  continuation  of  credit  flow  to 
the  economy.  Besides,  GDP  growth  was  also  supported 
by  a  solid  performance  in  net  exports  as  well  as  an 
expansionary, though still prudent, fiscal stance. 

Following some retreat in the first half of 2019, FDI inflows 
recovered strongly in the second half of 2019 and came in 
at 7.1% of GDP, almost unchanged from the previous year. 
FDIs at around these levels are considered high from the 
international perspective.

increased  by  5.1% 

Overall,  GDP 
in  2019,  which 
demonstrates  the  economy’s  solid  growth  potential  and 
resilience.  Similarly,  Uzbekistan,  which  has  even  higher 
growth potential, stands out in the broader region as being 
relatively unaffected by the latest slowing cycle. 

While COVID-19 is certainly a challenge for the global as 
well as Georgia’s tourism dependent economy, assuming 
the  shock 
is  predominantly  temporary,  rather  than 
permanent, the economy and most of the sectors should 
be back to the normal growth trajectory in a reasonable 
time-frame.  Meanwhile,  it  will  be  a  challenging  period, 
however, the Group’s advanced risk management practices 
including stress testing and risk mitigation should pay-off.

GOVERNANCE  

The Board is committed to ensuring excellent governance 
and  the  highest  ethical  standards  within  the  Group. 
Therefore,  we  review  the  Board’s  composition  with 
regularity  and  are  committed  to  maintaining  a  diverse 
and wide-ranging set of skills and experience within the 
Board. During the year, we announced a number of board 
changes, as outlined below.

As mentioned above, on 25 July 2019 Mamuka Khazaradze 
and Badri Japaridze stepped down from their respective 
positions  of  Chairman  and  Deputy  Chairman  of  the 
Board.  They  both  arrived  at  this  decision  after  careful 
consideration in order to ensure that the allegations made 
against them by the Georgian office of Public Prosecution 
do not affect the Group, and to be able to concentrate on 
refuting those allegations.

In  August  2019,  Arne  Berggren  joined  the  Board  as  an 
Independent  non-executive  Director,  and  in  September 
2019,  Eric  Rajendra  was  re-appointed  as  an  Independent 
non-executive Director following the recovery in his health.

In August 2019, the Group reintroduced a “Mirror Boards” 
governance structure whereby all non-executive members 
of  the  Board  and  the  supervisory  board  of  the  Bank  are 
the  same;  the  Chairman  of  TBC  Bank  Goup  PLC  (“TBC 
PLC”) also serves as the Chairman of the Bank and Senior 
Independent Director (“SID”) of TBC PLC also serve as the 
SID  of  the  Bank.  Board  committees  of  TBC  PLC  and  the 
Bank  are  also  “mirrored”  and  have  the  same  members 
and  chairmen.  In  September  2019,  we  also  reviewed 
membership of our board committees to make them more 
balanced and efficient.

As  the  result  of  these  changes,  the  Group  has  complied 
with  all  relevant  provisions  set  out  in  the  UK  Corporate 
  We  are  very  pleased  that  our 
Governance  Code. 
ISS  corporate  governance  score1  reflected 
these 
improvements and increased from “5” in July 2019  to “2” 
in October 2019. There have been no changes since then.

Further details can be found in Corporate Governance and 
Nomination Committee Report  on pages 143-146. 

TRANSPARENCY AND DISCLOSURE

This  year,  we  have  significantly  enhanced  our  disclosure 
in relation to social and environmental matters to enable 
our  stakeholders  to  better  assess  our  non-financial 
performance.  As  the  largest  financial  institution  in  the 
country,  we  take  seriously  our  responsibility  towards 
our  community  and  environment  and  are  committed  to 
conducting  business  with  integrity  and  accountability 
towards all our stakeholders, as well as ensuring that our 
customers  and  suppliers  also  fulfill  their  environmental 
and social responsibilities. For more insight please refer 
to pages 72-83. 

I am also delighted that JSC TBC Bank received the Best 
Annual  Report  and  Transparency  Award  2019  from  the 
National  Reforms  Support  Foundation  for  Accounting, 
Reporting  and  Auditing  under  the  auspices  of  a  joint 
European Union–World Bank project on financial inclusion 
and  accountability.  This  award  underlines  our  high 
standards  of  reporting  of  financial  and  non-financial 
information  and  sets  an  example  for  other  Georgian 
companies. 

OUTLOOK

Looking  forward,  I  feel  confident  that  TBC  Bank  has 
the  right  people,  resources  and  capabilities  to  tackle 
challenges  presented  by  the  COVID-19  pandemic  and 
establish  itself  as  a  leading  technology-driven  company 
not only in Georgia but in the wider region and to create 
the best opportunities for future success. 

In  conclusion,  on  behalf  of  the  Board,  I  would  like  to 
express  my  sincere  gratitude  to  the  management  team 
and  all  employees  for  their  dedication  and  hard  work  in 
delivering such impressive results last year and answering 
the recent challenges presented to us by COVID-19.

Nikoloz Enukidze
Chairman
28 April 2020

1  The ISS scores indicate decile ranking relative to index or region. A 
decile score of 1 indicates low governance risk, while a 10 indicates 
higher governance risk

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

5

CEO LETTER 

Dear shareholders,
I  am  delighted  to  report  that  we  have  had  another 
successful  year  in  2019.  Our  disciplined  approach  and 
relentless efforts have translated into strong financial and 
operating results.

FINANCIAL PERFORMANCE
Our reported net profit amounted to GEL 540.3 million, up 
by 23.5% year-on-year, and our earnings per share stood 
at GEL 9.8, which is 21.0% higher than in 2018.  Over the 
same period, our underlying net profit reached GEL 545.1 
million,  up  by  19.8%  compared  to  2018,  reflecting  the 
growth  in  net  fee  and  commission  income  and  interest 
income.  The  growth  in  net  profit  was  also  strongly 
supported  by  a  decrease  in  credit  loss  allowance,  which 
was driven by improved performance across all segments 
as  well  as  by  a  change  in  the  product  mix.  We  continue 
to  maintain  a  close  focus  on  cost  efficiency  and  strictly 
control  operating  expenses  across  the  Group,  including 
our  new  strategic 
investments.  Consequently,  our 
reported cost-to-income ratio stood at 39.9%, or at 39.5% 
on an underlying basis. Over the same period, the Bank’s 
standalone cost-to-income ratio remained broadly stable 
year-on-year at 35.9%.1 As a result, our reported return on 
equity stood at 22.4% and our reported return on assets 
stood at 3.2%, while our underlying return on equity was 
22.6% and our underlying return on assets stood at 3.3%. 

In terms of balance sheet growth, we maintain a leadership 
position in loan and deposit market shares, holding 39.5% 
and  39.0%  respectively  as  of  31.12.2019.  Our  capital 

6

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

position  and  liquidity  levels  continue  to  be  strong.  As  of 
31 December 2019, our regulatory CET 1, tier 1 and total 
capital  adequacy  ratios  per  Basel  III  guidelines  stood  at 
12.0%,  14.6%  and  19.1%  respectively,  while  minimum 
requirements  amounted  to  10.4%,  12.5%  and  17.5% 
respectively. Our regulatory liquidity coverage ratio stood 
at 110% compared to the minimum requirement of 100%, 
while  the  regulatory  net  stable  funding  ratio  (NSFR)  per 
Basel  III  guidelines  stood  at  127%,  above  the  minimum 
requirement of 100%. 

STRATEGIC PROGRESS
This year was a transformational year for us, as we have 
successfully  established  our  presence  in  the  Georgian 
digital  marketplace  by  launching  the  first  customer-
centric  digital  ecosystems  in  the  country,  which  already 
comprise payments, housing, e-commerce and auto. 

 ` Payments:  our  payments  ecosystem  includes  both 
traditional  payment  channels  such  as  e-commerce, 
POS and self-service terminals as well as innovative 
payment  methods  comprising  Apple  Pay,  ATM  QR 
withdrawal and TBC bracelets. In addition, it includes 
a  leading  Georgian  payments  platform,  TKT.ge, 
which allows people to buy tickets for various events 
and  transportation,  as  well  as  a  leading  payments 
platform in Uzbekistan, Payme, which facilitates utility 
payments, P2P transfers, loan repayments, mPOS for 
QR-based payments and ecommerce purchases. Our 
strategy  for  2020  is  to  further  diversify  our  payment 
options and grow the number and volume of payments 
transactions. 

 ` E-commerce: our e-commerce business is comprised 
of  two  digital  platforms:  Vendoo  and  Mymarket. 
Vendoo  is  an  online  marketplace,  while  Mymarket  is 
a classified listing platform each having a respective, 
estimated  24%  and  80%  of  total  digital  traffic  in 
comparable  e-commerce  in  Georgia.  The  number 
of  unique  visitors  amounted  to  337,000  and  900,000 
respectively  in  December  2019.  Our  strategy  for 
the  coming  year  is  to  further  increase  the  product 
offerings  and  enhance  our  customer  experience  in 
order to increase the gross merchandize value. 

 ` Housing: our housing ecosystems, Livo and Myhome, 
together have an estimated 55% of total digital traffic 
in  housing  in  Georgia  and  served  around  630,000 
unique visitors in December 2019. Livo is a data driven 
company mainly focused on generating effective leads 
to customers based on accurate analysis of user data, 
while Myhome is a classified platform, which primarily 
generates  revenue  from  advertisements.  In  2020, 
we will continue to harness the existing strengths of 
these platforms to develop innovative solutions for our 
customers. 

 ` Auto: Myauto and Myparts are the leading players in 
the  automotive  and  spare  parts  markets  in  Georgia, 
with  the total digital traffic of 80% in each segment. 
In  December  2019,  both  platforms  attracted  around 
1,500,000  unique  visitors.  Our  strategy  for  2020  is  to 
add  new  services  as  well  as  to  launch  new  market-
disrupting  sub-platforms  by  leveraging  the  existing 
consumer base and digital traffic.

More information about our ecosystems is given on pages 43-51. 

Another significant development was obtaining a banking 
licence  in  Uzbekistan  in  April  2020.  Our  strategy  is  to 
develop a greenfield, next-generation banking ecosystem 
for retail and MSME customers in Uzbekistan. The primary 
focus will be on digital and partnership-driven channels. 
Given the current operating environment and impact from 
Covid-19, we have further optimised our business model 
with  the  enhanced  emphasis  on  asset-light  and  cost-
efficient operations.

Last  year,  we  launched  several  important  preparatory 
work-streams,  including  implementation  of  the  core 
banking system in co-operation with a local IT company. 
We  also  set  up  a  pilot  branch  in  Tashkent  for  proof  of 
concept and built a core team for the bank. Thus, we are 
well advanced in the process and expect to start banking 
operations in  June 2020.

In  terms  of  our  product  offerings,  we  plan  to  start  with 
сash loans, salary backed loans and car loan as well as 
savings and current accounts,  cards, mobile application 
and transactional capabilities including (but not limited to) 
P2P  transactions,  money  transfers  and  utility  payments. 
These  products  will  be  offered  through  our  digital 
platform, Space; however, we also plan to open branches 
for advising and consulting purposes. 

The bank will be run by an experienced management board 
headed by Chief Executive Officer Sandro Rtveladze, who 
previously held the role of Group Head of Retail Banking 
at Bayport Financial Services and prior to that was Deputy 
CEO at Liberty Bank in Georgia.

We has already invested US$ 12.6 million into the charter 
capital of the Bank and expects to invest an additional US$ 
9.4 million by the end of 2020.  Additional capital increase 
is planned for later this year. Potential new shareholders, 
including  the  European  Bank  for  Reconstruction  and 
Development,  the  International  Finance  Corporation  and 
the  Uzbek-Oman  Investment  Company,  have  expressed 
their  interest  to  participate  subject  to  their  internal 
approvals. TBC PLC will remain the majority shareholder 
with 51% interest.

I am also pleased with the results of our recently acquired 
subsidiary, Payme, which is the leading payments company 
in  Uzbekistan,  serving  around  2    million  customers  by 
the  end  of  March  2020.  The  company  is  growing  rapidly, 
and  in  2019,  its  revenue  went  up  by  84%  and  amounted 
to  GEL  8.6  million,  while  its  EBITDA  reached  GEL  4.5 
million, up by 77% year-on-year.  Payme will continue to 
operate separately from the bank but the two entities will 
co-operate closely. In addition, the bank will also run the 
point-of-sale consumer finance operations.

CHANGES IN THE MANAGEMENT BOARD
In 2019, we had certain changes to the composition of the 
Management Board. David Chkonia, our Chief Risk Officer, 
left the Bank at the end of his contractual term in order 
to pursue other career opportunities. Consequently, Nino 
Masurashvili, deputy CEO, who was previously in charge 

of retail banking development, has been appointed as the 
new Chief Risk Officer and Tornike Gogichaishvili, Deputy 
CEO and Chief Operations Officer (COO) of the Bank has 
been  appointed  to  lead  the  retail  banking  business.  The 
functions that were previously carried out by the COO have 
been re-allocated to be the responsibility of the CFO and 
the Deputy CEO, SME & Micro Banking. 

I  would  like  to  thank  David  Chkonia  for  his  significant 
contribution  to  enhancing  our  risk  management  system 
and to wish him success in his future career. Also, I would 
like to wish Nino Masurashvili and Tornike Gogichaishvili 
success in their new roles.

MACROECONOMIC OVERVIEW
Structural reforms and diversified sources of inflows once 
again paid off in 2019. Alongside its high growth potential, 
resilience has become another hallmark of the Georgian 
economy  in  recent  years,  as  reflected  in  continuous 
upgrades to the country’s sovereign credit ratings. In 2019, 
exports of goods, tourism and remittances inflows in US$ 
terms  increased  by  12.4%,  1.4%  and  9.7%  year-on-year 
respectively,  while  import  of  goods  declined  slightly  by 
0.8% year-on-year. Despite the Russian flight ban imposed 
in June and subsequent weak growth of tourism inflows, 
the  current  account  deficit  improved  and  stood  at  5.1% 
of GDP in 2019 compared to 6.8% in 2018 on the back of 
stronger  balance  of  trade  in  goods  as  well  as  improved 
remittance inflows. CA deficit was fully balanced with FDI 
inflows which on a net basis stood at 5.6% of GDP, up by 0.3 
pp YoY. The growth was supported by the fiscal stimulus, 
taking  into  account  the  size  of  the  deficit  adjusted  for 
advance payments and large capital spending with a high 
multiplier. This provided balancing for the weakness in the 
tourism industry. 

Despite  a  challenging  year,  banking  system  credit  growth 
was  solid  and  increased  by  16.1%  year-on-year  on  a 
constant  currency  basis.  This  growth  was  mainly  driven 
by the business segment, while the retail segment slowed 
down  due  to  the  responsible  lending  regulation  effective 
from January 2019. This regulation, however, is seen as a 
rating  positive  and,  together  with  country’s  proven  track 
record  of  sound  macro  and  micro  risk  management, 
strengthens the financial system’s resilience. 

Our  initial  projection  for  2020  growth  was  around  5.0%. 
The economy was expected to expand at this rate without 
large  scale  infrastructure  projects  entering  more  active 
phase and assuming that the flight ban with Russia is not 
lifted. Due to the COVID-19 crises, we expect the economy 
to contract in 2020, though the growth should turn positive 
in 2021. While the shock is severe and the uncertainties are 
high, the support from the international financial institutions 
is  an  important  mitigation.  Also,  there  were  no  signs  of 
overheating in the economy or housing market before the 
distress. Therefore, the impact of the shock on the economy 
and financial sector should be rather manageable. 

1  For the ratio calculation all relevant group recurring costs are 

allocated to the bank

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

7

CEO LETTER CONTINUED

OUR RESPONSE TO COVID-19
We have implemented a number of important actions to protect our customers and staff members and to minimize disruption 
to the Group’s operations during the COVID-19 outbreak. In developing our response, we have looked at best practices from 
major global companies as well as organizations like the World Health Organization.  We are also coordinating closely with 
the Government of Georgia, the NBG and the other banks in the country.

Our first priority is the health, safety and well-being of our staff and our customers. We have introduced a number of additional 
security and infection prevention measures in our branch network. We have also introduced remote working practices for 
most of our head office and back office units. Today, 95% of our head office and back office staff (including those in our call 
center) are working from home and our market-leading digital banking platform allows our customers to continue with 
almost all of their banking transactions from the safety of their own homes.

In order to support our customers during the coming difficult months, we have introduced a three-month grace period on 
principal and interest payments for all our individual and MSME customers as well as those corporate customers whose 
business is the most exposed in the current situation.

The NBG has implemented counter-cyclical measures to support the financial stability of the banking system and to ensure 
the provision of financial support to sectors of the economy affected by the current turmoil.  The measures include a significant 
reduction in capital adequacy requirements and standby liquidity support incentives. In addition, the NBG coordinated the 
creation of respective loan loss provisions across the system. Further details are given in the risk management section of 
the report.

In  terms  of  our  financial  position,  our  liquidity  and  capital  positions  remains  strong.  After  the  impact  of  the  currency 
devaluation and additional provisions related to the potential impact of COVID 19, which resulted in  about 3.1% of our loan 
book per local regulatory standard, our CET1, Tier 1 and Total CAR stood at 9.1%, 12.0% and 16.7% respectively as of 31 
March 2020, above the corresponding eased minimum regulatory requirements of 6.9%, 8.8% and 13.3%. At the same time, 
our net stable funding (NSFR) and liquidity coverage ratios (LCR) stood at 124.7% and 107.6% respectively.  

On the other hand, we are focusing on optimising our cost structure, re-arranging many processes and prioritising expenses. 
We are targeting the Bank’s cost to income ratio for the full year ending 31 December 2020 to be broadly the same as it was 
in 2019.

OUTLOOK
In 2019, we recorded strong financial results and made significant progress against our strategic priorities, including the 
development of customer focused ecosystems and international expansion in Uzbekistan. This lays a solid foundation for the 
further development of these initiatives in the coming years. I would like to thank the whole TBC team for their outstanding 
effort and commitment and congratulate them on our accomplishments in 2019. I am also thankful to the team for being able 
to quickly adapt to  the current situation caused by COVID-19 and continue their work with minimal disruption. 

Our leading digital capabilities, outstanding customer experience and advanced data analytical capabilities, coupled with 
our strong team spirit, make me confident that we are well positioned to achieve sustainable growth and to deliver superior 
results to our shareholders in the medium-term and withstand the short-term negative impacts caused by COVID-19.

Therefore, I would like to reiterate our medium-term targets: ROE of above 20%, cost to income ratio below 35%, dividend 
pay-out ratio of 25-35% and loan book growth of around 10-15%.

The strategic report, as detailed on pages 2 to 123, was approved by the Board and signed on behalf of the Board by:

Vakhtang Butskhrikidze 
CEO
28 April 2020

8

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

IMPLICATIONS OF COVID-19 

IMPLICATIONS OF COVID-19 
The outbreak of the COVID-19 virus has created serious challenges to economies and businesses throughout the world and 
Georgia is no exception. However, so far our country has managed to fight COVID-19 more effectively than other countries, 
thanks to the timely, strict measures taken by the government, which have resulted in a relatively low number of cases. 

From an economic perspective, the COVID-19 pandemic has resulted in decreased economic growth in Georgia, increased 
unemployment,  depreciation  of  the  GEL,  decreased  commodity  and  real  estate  prices,  and  impaired  creditworthiness  of 
the private sector. As the contribution of tourism to the Georgian economy was significant, the impact should be sizable. 
Per IMF projections, as of 14th April, the Georgian economy is expected to contract by 4.0% in 2020, while in 2021 growth is 
expected to recover to 3.0%. According to the TBC Research projection for the Georgian economy, while the GDP drop in 2020 
might be slightly stronger than 4.0%, the recovery in 2021 is expected to be well above 3.0%. While the shock is severe and 
uncertainties are high, support from the international financial institutions is an important mitigation factor. Also, there were 
no signs of overheating in the economy or housing market before the pandemic. Therefore, the impact of the shock on the 
economy and the financial sector should be manageable.

According to the government’s announcement as of 15 March, around US$ 1.7 billion, or 10% of GDP in 2019, will be mobilized 
to support the government’s financing needs and partially support the central bank’s international reserves. In addition, 
around US$ 1.5 billion will be used to support the private sector.

The  NBG  is  also  implementing  countercyclical  measures  to  support  the  financial  stability  of  the  banking  system  and  to 
ensure the provision of financial support to sectors of the economy affected by the current turmoil.

In relation to capital adequacy requirements, this means:

 ` Postponing the phasing in of the additional capital requirements planned in March 2020, with a 0.44pp effect on TBC’s CET 1;
 ` Allowing banks to use the conservation buffer (currently at 2.5pp on CET1) and 2/3 of the CICR buffer resulted in the 

release of 1.0-2.0% of capital across our CET1, Tier 1 and Total CAR;

 ` Leaving open the possibility of releasing all pillar 2 buffers (remaining 1/3 CICR, HHI and Net Grape buffers) in the range 

of 1.0-4.0% of capital across our CET1, Tier 1 and Total CAR.

In relation to liquidity requirements, the NBG has introduced a swap program for US$ 200 million, with an annual spread of 
9%. If necessary, it will also utilize additional measures:

 ` Decreasing LCR limits;
 ` Decreasing FX mandatory reserve requirements;
 ` Updating criteria for security or repo pledging to support GEL liquidity.

In terms of our actions, we have taken a number of measures that allowed the bank to alter its day-to-day operations in order 
to adapt to the current, unprecedented operating environment, while maintaining the health, safety and well-being of our 
staff and customers as the number one priority:

 ` We  introduced  additional  security  and  infection  prevention  measures  in  our  branches,  including  glass  barriers  and 

antiseptic solutions for employees and customers;

 ` We promptly changed our operational model so that 95% of head and back office employees, over 2,200 people, including 

call center staff, are already working from home;

 ` We  provided  additional  incentives  to  our  customers  to  use  our  market-leading  digital  banking  platform.  Since  our 

offloading ratio is as high as 93%, this proved very useful during this difficult time; 

 ` We also work closely with the NBG, government and other businesses; 
 ` We decided to provide a three-month grace period on principal and interest payments for individual and MSME customers 

and those corporate customers who are affected by the current situation;  

 ` In addition, as part of the stress testing exercise, we have analysed multiple scenarios to ensure that the Group has 

sufficient liquidity and capital to meet updated regulatory capital and liquidity requirements; and

 ` To optimize costs, top management has decided to forgo their entire annual bonuses for 2020 and LTIP grants for the 

2020 cycle;

 ` The provision charges to be set aside for the first quarter 2020 is expected to be in the range of 1.7%- 2.0% of the average 

loan book mainly attributable to Covid-19;

 ` Finally, the Board decided not to recommend dividends at the upcoming AGM.

In 2020, our priorities will be prudent management of our capital and liquidity positions, leveraging our robust risk management 
system to closely monitor and proactively manage asset quality. In parallel, we will be focusing on cost optimization with a 
target to keep the Bank’s cost to income flat for 2020 compared to 2019 despite of pressure in revenue, currency depreciation, 
and increased number of transactions.

At  the  same  time,  the  crisis  has  provided  a  strong  validation  of  our  digital  strategy  and  has  also  revealed  a  number  of 
opportunities that we will be perusing to further enhance our operational model.  

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9

GEORGIA

ECONOMIC GROWTH AND THE EXTERNAL SECTOR
GDP growth came in at 5.1% YoY in 2019. The growth was broad-based across different sectors of the economy with trade and 
repairs (+8.8% YoY), real estate (+6.1% YoY), information and communication (+15.2% YoY) and transport and logistics (+7.4% 
YoY) contributing most to the economic growth.   

REAL GDP GROWTH

6.4%

3.6%

4.4%

3.0%

2.9%

4.8%

4.8%

 5.1%

2012

2013

2014

2015

2016

2017

2018

2019

Source: GeoStat

Despite the negative impact stemming from Russia’s flight ban, the growth of inflows proved resilient in 2019. Following the 
restriction of flights from Russia in July, tourism inflows retreated; however, growth quickly got back on track as solid growth 
in the number of visitors from the EU, neighbouring countries, the Middle East including Israel, and Central Asian countries 
compensated for the decline in the number of visitors from Russia. For the full year 2019, tourism inflows growth remained 
positive and amounted to 1.4% YoY in US$ terms. Over the same period, exports of goods showed solid 12.4% YoY growth, 
while remittances increased by 9.7% YoY, again, mostly on the back of remittances from the EU. 

Overall, the dynamics of the external balance remained healthy. Following lower growth in tourism inflows, the balance of 
trade in services declined slightly from 12.7% of GDP in 2018 to 12.2% of GDP in 2019 which was counteracted by the lower 
deficit in trade in goods (down by 2.3% of GDP). As a result, the CA balance to GDP ratio improved to its historic low of 5.1% 
in 2019, compared to 6.8% in 2018. The CA deficit continued to be fully financed with FDI inflows, coming in at 5.6% on a net 
basis, up by 0.3 pp compared to 2018. Although somewhat below the average amount in the past couple of years, FDI inflows at 
current levels are still quite high compared to peer countries in the neighbourhood as well as in Central and Eastern Europe. 

CA DEFICIT AND NET FDI (% OF GDP)

YOY GROWTH OF VISITORS BY COUNTRIES/REGIONS (%)

9.5

8.1

8.2

10.4

6.0

6.5

5.3

4.6

5.3

5.6

-5.6

-5.1

-6.8

-8.1

-9.8

-11.4

-12.2

-10.2

-11.8

-12.4

   60

   40

   20

0

   -20

   -40

   -60

   -80

2010

2011

2012 2013 2014 2015 2016 2017 2018

2019

2018

2019 Q1

2019 Q2

2019 Q3

2019 Q4

CA Deficit to GDP

Net FDI to GDP

Russia

Turkey

EU

Iran

Other Countries

Total Visitors

Source: NBG, GeoStat

Source: GNTA

EXCHANGE RATE, MONETARY POLICY AND CREDIT
The depreciation in the GEL exchange rate since June 2019 has been the major factor behind the rise in inflation to 7.0% as 
of the end of 2019. In response to higher inflation pressures, the NBG tightened the monetary policy rate from 6.5% by the 
beginning of September to 9.0% as of the end of 2019. The tighter monetary policy stance in GEL, coupled with a stronger 
external sector, contributed to the appreciation in the GEL. At the end of 2019, US$/GEL stood at 2.87, strengthening from 
the high of 2.98 at the end of September. 

10

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Despite tighter monetary policy in GEL, lending growth remained solid, mostly on the back of accelerated FX credit by the end 
of 2019, supported by the lower reserve requirements and ample bank liquidity in FX. At the end of 2019, the bank loan portfolio 
went up by 16.1% YoY, excluding the exchange rate effect, mostly on the back of business lending (+23.3% YoY excluding FX 
effect), supporting economic growth. At the same time, retail growth was relatively slow (+6.0% YoY excluding FX effect), owing 
to tighter prudential regulations. Despite some acceleration of FX lending, the de-dollarization of the financial sector remains a 
priority for the central bank; however, in the future, relatively more attention is expected to be devoted to liabilities. 

CPI INFLATION AND  MONETARY POLICY RATE (%, YOY)

9     

8

7

6

5

4

3

2

1

0

-1

Jan 14

A pr 14

Jul 14

Oct 14

Jan 15

A pr 15

Jul 15

Oct 15

Jan 16

A pr 16

Jul 16

Oct 16

Jan 17

A pr 17

Jul 17

Oct 17

Jan 18

A pr 18

Jul 18

Oct 18

Jan 19

A pr 19

Jul 19

Oct 19

CPI Inflation

Monetary policy rate

Source: GeoStat, NBG

FISCAL SPENDING
Fiscal spending significantly supported growth in 2019, with the budget deficit coming in at an estimated 2.4%1 of GDP in 
2019. The actual impact of the fiscal sector on growth was even higher: taking into consideration the advance payments 
made at the end of 2018 and high multiplier of capital spending. 

Public debt levels remained stable, with the composition of debt switching gradually towards domestic financing. At the end 
of 2019, estimated public debt to GDP stood at 41.1% as opposed to 40.4% a year ago, mostly on the back of higher domestic 
debt (up from 8.8% of GDP in 2018 to 9.7% of GDP), while the level of external debt went down slightly by 0.1% of GDP to 
31.5%, despite the GEL depreciation throughout the year.

GOING FORWARD
Above 5.0% economic growth for the full year 2019 once more underlines the resilience and high growth potential of the 
Georgian economy. This growth is particularly encouraging given the challenges that the economy faced in 2019, the most 
important being Russia’s flight ban. Per IMF projections, as of 14th April2, Georgian economy is expected to contract by 4.0% 
in 2020, while in 2021 the growth is expected to recover to 3.0%. According to the same source, the economy of Azerbaijan 
is expected to decline by 2.2% in 2020 with 0.7% recovery a year after. As for the Uzbekistan, the growth is expected to be 
positive for both 2020 and 2021 with 1.8% and 7.0% respectively.

According to the TBC Research projection for Georgian economy, while the GDP drop in 2020 might be slightly stronger than 
4.0%, the recovery in 2021 is expected to be well above 3.0%.

More information on the Georgian economy and financial sector can be found at www.tbcresearch.ge. 

1  Modified deficit based on IMF methodology
IMF World Economic Outlook, April 2020
2 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

11

BUSINESS MODEL AND STRATEGY

OUR BUSINESS MODEL 
We  have  a  customer-centric  business  model  focused  on  providing 
the  best  customer  experience  in  servicing  everyday  needs  of  our 
clients. Our strategy is centered on the core principles of sustainable 
development, innovation and efficiency and is designed to create value 
for all our stakeholders.

Our distinctive competitive advantages ...

 ` Best-in-class digital capabilities
 ` Advanced data analytical capabilities
 ` Superior customer experience
 ` Strong brand and reputation
 ` First Neobank in Georgia - Space
 ` First digital ecosystems in the country
 ` Strong corporate culture 
 ` Experienced management team and high quality of corporate governance
 ` Effective risk management 

... translate into strong financial and operating results ... 

 ` Robust profitability
 ` High efficiency 
 ` Sustainable business growth
 ` Sound asset quality
 ` Strong liquidity level
 ` Prudent capital position
 ` High digitalization levels
 ` High customer satisfaction levels
 ` Increasing number of active users
 ` Highly motivated and engaged team

... enabling us to deliver for all our stakeholders

 ` Generate robust and long-term sustainable returns for our shareholders 
 ` Provide well-suited solutions and superior customer experience for our customers
 ` Offer challenging and rewarding careers for our colleagues
 ` Support community through a wide range of CSR activities
 ` Preserve Georgia’s cultural heritage and environment
 ` Support economic growth and employment

1  Based on survey conducted by independent research companies IPM and ACT
2  Based on survey conducted by the independent research company, TNS in October 2019
3  The Banker, EMEA finance, Euromoney, Global Finance
4  The ISS scores indicate decile ranking relative to index or region. A decile score of 1 indicates low governance risk, while a 10 indicates higher governance risk

12

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

OUR DISTINCTIVE COMPETITIVE ADVANTAGES

BEST-IN-CLASS DIGITAL CAPABILITIES
 ` Our digital solutions, offering an unrivaled customer experience, represent the core of our distribution platform 

accounting for 93% of all transactions in 2019;

 ` We have industry-leading internet and mobile bank applications, having won the world’s “Best in Mobile Banking 

Award 2019” together with multiple regional and country digital awards from Global Finance Magazine. 

ADVANCED DATA ANALYTICAL CAPABILITIES 
 ` 4 data analytical projects implemented and scaled up, 5 underway;
 ` GEL 8.9 million extra profit generated in 2019;
 ` Institutionalizing capability building by setting up a data analytics academy called Avalanche.

SUPERIOR CUSTOMER EXPERIENCE  
 ` “The customer comes first” approach – we place our clients at the center of all our activities and services;
 ` Striving for continuous improvement through innovation, investment in digital channels and infrastructure with 

cutting edge technologies;

 ` Maintaining the highest satisfaction scores1 in Georgia’s banking sector for many years in a row.

STRONG BRAND AND REPUTATION 
TBC is a well-established brand in Georgia, known for its credibility, excellence, innovation and community service.
 ` Our aided brand awareness stands as high as 100%2 among the Georgian population;
 ` The highest top of mind rating in the banking sector of 41%2;
 ` Recipient of 38 awards for “Best Bank in Georgia” since 2002 from the world’s leading financial magazines3 

FIRST NEOBANK IN GEORGIA, SPACE 
 ` Launched in May 2018, Space is a cutting-edge mobile application for managing daily finances, which challenges 
and re-defines the traditional banking experience by offering a unique customer experience through simple 
procedures and products, intuitive design and instant delivery. 

FIRST DIGITAL ECOSYSTEMS IN THE COUNTRY
 ` This year, we started to develop the first customer focused digital ecosystems in the country, offering a complete 

suite of interconnected services as one integrated experience;

 ` We have already launched payments, housing, e-commerce ecosystems and are actively developing auto ecosystems. 

STRONG CORPORATE CULTURE 
 ` Corporate culture centered on collaboration and commitment;   
 ` Continuous investment in our employees, focusing on their professional development, satisfaction and wellbeing.

EXPERIENCED MANAGEMENT TEAM AND HIGH QUALITY OF CORPORATE GOVERNANCE
 ` We have a highly qualified and diverse board of directors with a strong commitment to the highest standards of 

corporate governance and business transparency;

 ` Excellent ISS corporate governance score4, which stood at 2.0 as of 31.12.2019; 
 ` Listing on the premium segment of London Stock Exchange, in full compliance with the UK Corporate Governance Code.

EFFECTIVE RISK MANAGEMENT 
 ` A sophisticated risk management system which ensures the Group’s sustainability and resilience; 
 ` Our prudent approach translates into low cost of risk, sound asset quality and strong capital and liquidity positions.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

13

BUSINESS MODEL AND STRATEGY CONTINUED

OUR STRATEGY 

In line with our mission to make the lives of our customers easier, last year we introduced a new strategic initiative to expand 
our value proposition beyond financial services and develop customer-centric digital ecosystems. This will enable our clients 
to access a variety of related products and services, including banking services, on one of our platforms instead of having to 
switch to a third-party provider. By increasing the touchpoints with our customers, we will be able to accumulate knowledge 
about customer preferences and behavior, which will provide significant opportunities for relevant cross-selling. At the same 
time, it will help us to enhance our customer experience by developing highly personalized solutions. In the medium-to-long 
term, these ecosystems will also generate substantial fee and commission  income as well as other operating income for 
TBC Group. 

In parallel, we are actively developing our core financial products and services for our corporate, MSME and retail customers 
as well as striving to further strengthen our superior customer experience and leading digital capabilities.

We also continue to roll out an agile transformation project across the organization and invest in our employees by focusing 
on their learning and development. 

In addition, we are expanding our presence beyond Georgia and aspire to create the next generation banking abroad by 
harnessing our extensive banking experience and advanced digital capabilities.

OUR STRATEGIC PRIORITIES 
OUR STRATEGIC PRIORITIES 

PROGRESS IN 2019

Payments
 ` Number of transactions up by 36.9% YoY
 ` Volume of payments up by 34.1% YoY

Housing  
Livo
 ` GEL 2.5 mln revenue1  
 ` 274,000 unique visitors
 ` 24,000 listings

Myhome
 ` GEL 1.4 mln revenue  
 ` 360,000 unique visitors
 ` 140,000 listings

E-commerce
Vendoo
 ` GEL 2.4 mln revenue  
 ` 337,000 unique visitors
 ` 27,000 different items (SKU)

Mymarket
 ` GEL 1.2 mln revenue  
 ` 900,000 unique visitors
 ` 45,000 sellers 

Auto and auto parts
Myauto & Myparts
 ` GEL 2.5 mln revenue  
 ` 1,550 000 unique visitors
 ` 400,000 listings

More information can be viewed at pages 43-51

1. BUILDING CUSTOMER FOCUSED
DIGITAL ECOSYSTEMS

As we strive to create maximum value for our customers, we have 
decided  to  better  integrate  with  them  by  focusing  on  the  major 
areas of their lives and creating additional services in those areas 
aimed at building strong, long-lasting relationships. This year, we 
have  made  significant  progress  in  this  regard  and  launched  the 
first payments, housing, e-commerce and actively developing auto 
ecosystems in Georgia. 

14

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

OUR STRATEGIC PRIORITIES 

PROGRESS IN 2019

2. LEVERAGING OUR CORE FINANCIAL
PRODUCTS AND SERVICES

Being the largest bank in the country, we aim to retain our market 
leadership  position  and  grow  together  with  the  market  in  all  our 
core segments and products by constantly fine-tuning our financial 
offerings  (for  more  information  please  refer  to  the  divisional 
overview on pages 20-51). Interest income remains our key revenue 
generation  stream  and  we  will  be  focusing  on  maintaining  sound 
levels  of  net  interest  margin  (NIM)  through  proper  customer 
segmentation  and  pricing.    In  parallel,  we  will  be  increasing  our 
commission-based  services  such  as  insurance,  cards  business, 
trade finance and brokerage and investment banking. 

Strong growth
 ` Loan book up by 22.1% YoY
 ` 39.5% market share in loans up by 0.7 

pp

Robust profitability
 ` 22.6% underlying ROE decreased 

by 0.2pp YoY (reported ROE stood at 
22.4%  up by 0.4 pp YoY)

 ` 3.3% underlying ROA remained stable 
YoY (reported ROA stood at 3.2%  
stable YoY)

3. FURTHER STRENGTHENING OUR
DIGITAL CAPABILITIES

In  line  with  our  aspiration  to  turn  ourselves  into  a  technological 
company,  we  are  continuously  fine-tuning  our  advanced  digital 
capabilities and developing ever more innovative solutions for our 
customers by utilizing big data analytics and artificial intelligence. 
This  year,  we  launched  a  number  of  innovations  including  voice 
payment in mobile banking, Apple Pay and QR payments.  

In  parallel,  we  are  actively  developing  our  Neobank  Space,  which 
was  launched  last  year  in  Georgia,  offering  a  completely  unique 
banking  experience  for  digitally  savvy  customers  and  challenging 
the  Georgian  banking  sector.  With  Space,  we  are  creating  an 
important knowledge bank that will help us easily introduce Space 
in other markets and support our international expansion plans. 

4. FURTHER IMPROVE  SUPERIOR
CUSTOMER EXPERIENCE 

Our aspiration is to be the best service provider in Georgia across 
all  major  industries.  To  achieve  this,  we  dedicate  significant  time 
and  effort  to  explore  our  customers’  needs  and  preferences  and 
constantly transform our products and services in order to deliver 
an  outstanding  customer  experience  across  all  our  channels.    In 
doing  so,  we  leverage  our  advanced  digital  capabilities,  which 
creates a huge opportunity for taking our customer experience to 
the next level by allowing us not only to meet, but also to anticipate, 
our customers’ wishes. 

Offloading ratio
 ` 92.7% up by 2.1 pp YoY

Mobile banking
penetration ratio
 ` 40.0% up by 3.0 pp YoY

Space
 ` 508,000 downloads
 ` 181,000 registered customers

Named the best
service provider in Georgia2 

1 
2 

 TBC’s  contribution from real estate evaluation is GEL 2.2 mln
 Based on survey conducted by independent research company IPM among the retail segment in December 2019

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

15

BUSINESS MODEL AND STRATEGY CONTINUED

OUR STRATEGIC PRIORITIES 

PROGRESS IN 2019

5. TRANSFORMING INTO AGILE COMPANY 

We realise the importance of a flexible organisational structure in 
today’s fast changing market environment, where companies need 
to be able to quickly adapt and respond to evolving business needs. 
For  this  purpose,  we  have  decided  to  start  an  enterprise-wide 
agile transformation process, which will help us to increase cross-
company collaboration, achieve operational excellence and reduce 
time-to-market.  It will also support the creation of an exceptional 
working  environment,  in  which  employees  feel  more  empowered 
and  motivated.  During  2019,  we  successfully  implemented  agile 
transformation in the retail, MSME and IT departments and plan to 
roll it out across other departments during 2020.  

Time to market
for majority of systems1
 ` Up by 2.3 times 

Employee happiness1
 ` Up by 16.0%

FTE productivity
 ` Up by 10.0%

Organizational agility score1
 ` Up by 4.3% 

6. INVESTING IN HUMAN CAPITAL

As  we  believe  that  people  are  our  key  competitive  advantage,  we 
are increasing our focus on learning and development. This year, in 
addition to expanding TBC academy’s capacity, which offers general 
courses in different fields, we have set up several new educational 
programs to support our new business initiatives:

 ` Business school – tailored learning program for corporate, 

finance and risk professionals which is comprised of 8 models 
and lasts for 2 months;

 ` Agile academy – general training in agile and scrum 

methodology;

 ` Data analytics – a general data management course, as well as 

advanced training in data science and engineering;

 ` IT academy – attracts and trains the most talented young 

developers in Front-end and Back-end bootcamp courses. 
It also organises meetups and hackathons to promote 
information technology.

We  plan  to  further  develop  these  programs  and  add  more  online 
courses next year. 

Business School
 ` 80 people trained

Agile Academy
 ` 545 people trained

Data Analytics
 ` 500  people trained

IT Academy
 ` 117 new people trained and 25 

recruited

16

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

7. INTERNATIONAL EXPANSION 
Our strategy in international markets is to follow a cautious, asset-light, limited capital investment approach with a strong 
focus on digital channels. Furthermore, we aim to invest further capital, subject to achieving milestones, in stages to ensure 
that we are comfortable with the results and the operating environment before committing additional investment. If and 
where relevant, we will engage with our partner IFI institutions.

Our progress in Uzbekistan
In April 2020, our subsidiary, TBC Bank in Uzbekistan has obtained a banking licence and is planning to launch banking 
operations in the country in June 2020.  Our  strategy  is to  develop a  greenfield, next-generation banking ecosystem  for 
retail and MSME customers in Uzbekistan. The primary focus will be on digital and partnership-driven channels. Given the 
current operating environment and impact from Covid-19, we have further optimised our business model with the enhanced 
emphasis on asset-light and cost-efficient operations.

While awaiting the license, during 2019, we launched several important preparatory work-streams including implementation 
of the core banking system in co-operation with a local IT company.  We also set up a pilot branch in Tashkent for proof 
of concept and built a core team for the bank. Thus, we are well advanced in the process and  are ready to  start banking 
operations in  June 2020.

Our business model envisages serving  customers through our digital platform, Space. However, we also plan to open up 
smart, self-service branches in order to provide advising and consulting to our customers. The range of products offered 
by the Bank at launch will include: сurrent and savings accounts,  сash loans, salary backed loans and car loans as well as  
cards, mobile application and transactional capabilities including (but not limited to) P2P transactions, money transfers and 
utility payments. Our aspiration is to break-even starting from 2022 and achieve ROE in the range of TBC Group’s target in 
the medium-term, while loan book mid-term target is to reach up to US$ 700 million.

The  bank  will  be  run  by  an  experienced  management  board  headed  by  Chief  Executive  Officer  Sandro  Rtveladze,  who 
previously held the role of Group Head of Retail Banking at Bayport Financial Services and prior to that was Deputy CEO at 
Liberty Bank in Georgia.

We has already invested US$ 12.6 million into the charter capital of the Bank and expects to invest an additional US$ 9.4 
million by the end of 2020.  Additional capital increase is planned for later this year. Potential new shareholders, including 
the  European  Bank  for  Reconstruction  and  Development,  the  International  Finance  Corporation  and  the  Uzbek-Oman 
Investment Company, have expressed their interest to participate subject to their internal approvals. TBC PLC will remain 
the majority shareholder with 51% interest.

In parallel, we have been actively developing our payments business in the country, through our recently acquired subsidiary, 
Payme.  Payme  is  a  fast  growing,  profitable  payment  service  provider  in  Uzbekistan  that  supplies  high-quality  payment 
solutions. It facilitates utility payments, P2P transfers, loan repayments, mPOS for QR-based payments and e-commerce 
purchases.  It  also  provides  a  marketplace  platform  for  loans  from  certain  Uzbek  banks.  The  company  recorded  strong 
results during 2019: its revenue increased by 84.0% and reached GEL 8.6 million, while the number of registered customers 
and the number of transactions grew by 56.4% and 24.5%, respectively and stood at 1,772,000 and 40.1 million accordingly 
in December 2019.  Payme will continue to operate separately from the bank but the two entities will co-operate closely. In 
addition, the bank will also run the point-of-sale consumer finance operations.

Our progress in Azerbaijan
During the year, our partner bank, Yelo Bank2 (previously known under the brand name Nikoil Bank) enhanced its operations, 
including core banking and data warehouse as well as improved risk management in terms of operational risk, credit risk 
and  compliance.  Also,  a  new  management  team  was  recruited.  In  addition,  in  December  2019  it  launched  a  rebranding 
process and introduced a new name, logo and slogan. The new name of Yelo Bank is a stylized spelling of the English word 
Yellow, symbolizing a bright, vibrant, new approach to banking services. The transition to a new name and the introduction 
of a new corporate identity will occur gradually and expected to be completed in April 2020. This will be followed by the 
introduction of a new banking service model in the branches and their transition to a completely new design.

1  Based on the internal survey
2  TBC Bank and Nikoil Bank agreed on shareholders’ agreement in late December 2018 and signed it in early January 2019. According to which our 

shareholding in the joint entity will be 8.3%.  The transaction is subject to regulatory approval

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

17

BUSINESS MODEL AND STRATEGY CONTINUED

KEY PERFORMANCE INDICATORS  
We closely monitor progress against our strategy and have developed key 
performance indicators (KPIs) that measure our financial and operational 
performance. These KPIs are closely aligned with our strategy and ensure 
that we deliver on our goals and achieve sustainable growth.

In 2019, our underlying net profit reached GEL 545.1 million (reported net profit amounted to GEL 540.3 million), up by 19.8% 
YoY, while our underlying return on equity was 22.6% and our underlying return on assets stood at 3.3% (the reported return 
on equity stood at 22.4% and our reported return on assets stood at 3.2%). 

In 2019, our operating income amounted GEL 1,128.2, up by 3.7% year-on-year, which was supported by increase in net fee 
and commission income and net interest income. The growth in net interest income was related to re-classification of net 
gains on currency swaps in the amount of GEL 28.6 million from other operating income, which offset by the decline in net 
interest income related to the introduction of the responsible lending regulation from 1 January 2019, limiting the Bank’s 
ability to lend money to higher-yield retail customers and change in product mix. Consequently, the net interest margin 
decreased by 1.3 pp year-on-year and stood at 5.6% in 2019 and 5.3% in the fourth quarter of 2019. The growth in net profit 
was also strongly supported by a decrease in credit loss allowance, which was driven by improved performance across all 
segments. As a result, our cost of risk stood at 0.7% in 2019 compared to 1.6% in 2018.  In 2019, our operating expenses 
increased by 9.7% year-on-year or 8.3% on an underlying basis, resulting in an underlying cost-to-income ratio of 39.5% (the 
reported cost-to-income ratio stood at 39.9%), up by 1.7 pp year-on-year. The increase in the cost-to-income ratio was mainly 
related to investments in our new ecosystems.  Over the same period, the bank’s standalone cost-to-income ratio remained 
strong and stood at 35.9%1.

In terms of balance sheet growth, our loan book expanded by 22.1% year-on-year, or by 17.9% on constant currency basis, 
mainly supported by growth in the corporate and MSME segments. As a result, as of 31 December 2019, our loan book market 
share stood at 39.5% up by 0.7 pp year-on-year. Our capital positions remain solid. As of 31 December 2019, our regulatory tier 
1 and total capital adequacy ratios per Basel III guidelines stood at 14.6% and 19.1% respectively, while minimum requirements 
amounted to 12.5% and 17.5% respectively.

We continue to generate strong results in digitalization. Our retail transactions offloading ratio continues to grow mainly 
driven by mobile banking transactions. We also remain leaders among the major retail industries in Georgia in terms of 
providing the best customer experience. Equally important for us is caring about our colleagues and this year we introduced 
an employee happiness index, which will be closely monitored going forward.

FINANCIAL KPIS  

REPORTED NET PROFIT
(IN MLN GEL)

growth 23.5%

2019 

2018 

2017 

540.3

437.4

359.9

REPORTED RETURN
ON AVERAGE EQUITY

growth 0.4pp

2019

2018 

2017 

22.4%

22.0%

20.9%

18

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

UNDERLYING NET PROFIT
(IN MLN GEL)2 (APM)

BASIC EARNING
PER SHARE (IN GEL)

growth 19.8%

growth 21.0%

2019 

2018 

2017 

545.1

454.9

369.2

2019 

2018 

2017 

9.8

8.1

6.7

UNDERLYING RETURN
ON AVERAGE EQUITY2 (APM)

reduction 0.2pp

2019 

2018

2017 

22.6%

22.8%

21.4%

NET INTEREST MARGIN

reduction 1.3pp

2019 

2018 

2017 

5.6%

6.9%

6.5%

REPORTED COST TO INCOME

growth 2.1pp

STANDALONE COST
TO INCOME1 

growth 0.3pp

2019 

2018 

2017 

39.9%

37.8%

41.7%

2019 

2018 

2017 

35.9%

35.6%

39.7%

COST OF RISK

reduction 0.9pp

2019  0.7%

2018 

2017 

1.6%

1.2%

LOAN BOOK MARKET SHARE3

TIER 1 CAR (BASEL III)

TOTAL CAR (BASEL III)

growth 0.7pp

growth 1.8pp

growth 1.2pp

2019 

2018 

2017 

39.5%

38.8%

38.2%

2019 

2018 

2017 

14.6%

12.8%

13.4%

2019 

2018 

2017 

19.1%

17.9%

17.5%

NON-FINANCIAL KPIS  

EMPLOYEE SATISFACTION4

growth 15.8%

CUSTOMER EXPERIENCE
The best service provider in Georgia 
(gap with peer bank)5

growth 0.4pp

2019 

2018 

2017 

1.76

1.52

N/A

2019 

2018 

2017 

2.7

2.3

N/A

MOBILE BANKING
PENETRATION RATIO
growth 3.0pp

RETAIL TRANSACTIONS
OFFLOADING RATIO

growth 2.1pp

2019 

2018 

2017 

40.0%

37.0%

24.2%

2019 

2018 

2017 

92.7%

90.6%

88.3%

1  For the ratio calculation all relevant group recurring costs are allocated to the bank
2  More information about underlying figures (APMs) is given in Annex 1 on pages 122-123
3  Based on data published by National Bank of Georgia
4  The index is measured on a scale from -3 to +3 (with +3 meaning very happy) based on internal survey, created in collaboration with the world’s

leading consulting firm, conducted among employees who are part of the agile structure
5  Based on survey conducted by independent research company IPM among retail segment

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

19

 
DIVISIONAL OVERVIEW

RETAIL BANKING 

2019 HIGHLIGHTS

40.0%
Retail loan market share1 

37.9%
Retail deposits market share1

39.9%
Retail loan share in total portfolio 

56.5%
Retail deposit share in total portfolio

c.2.5 mln
Number of customers

93%
Offloading ratio

OVERVIEW
TBC Bank is a leader in the retail banking segment in Georgia, serving 2.5 million clients, which is 90% of adult population of 
the country. We offer our clients a full range of financial products and services tailored to their needs through our advanced 
omni-channel,  with  a  strong  focus  on  digital  channels.  We  pride  ourselves  on  having  the  highest  customer  satisfaction 
scores2 in the Georgian banking industry, and we hold the leading position among all major retail companies. 

In 2019, our retail loan book increased by 7.5% YoY to GEL 5,053 million, mainly driven by an increase in mortgages, which 
grew by 17.0%. Over the same period, retail deposits increased by 11.2% to GEL 5,674 million. More information about the 
financial performance of the retail segment is provided in the financial review section on pages 108 to 123.

158
Branches

3,671
Self service 
terminals

22,414
POS terminals

c.1,350
ATMs3

c.560,000
Internet or mobile  
banking users

The first voice
biometrics recognition 
system in call center 

40%
Mobile banking
penetration ratio

The first Georgian 
Speaking chat-bot, Ti-
Bot available through 
Facebook Messenger

RETAIL SUB-SEGMENTS
Our retail banking is divided into mass retail and private banking business lines. This allows us to better customize our 
offerings and provide our products and services in the most convenient way. 

Our private banking is comprised of affluent clients-TBC Status and High Net Worth Individuals, providing them with best-
in-class  financial  and  wealth  management  solutions  coupled  with  sophisticated  lifestyle  offerings.  In  recognition  of  our 
distinguished efforts, we have received the country’s Best Private Bank 2019 award from The Banker and Professional Wealth 
Management (PWM) magazine and have won Global Finance’s Best Private Bank Award in Georgia 2020. These prestigious 
awards acknowledge our leading position in delivering exceptional private banking services and the highest standards of 
client satisfaction.

1  Based on data published by the National Bank of Georgia as of 31 December 2019; in this context retail refers to individual customers
2  Based on survey conducted by independent research company IPM among retail segment in December 2019
3  TBC Bank ATMs including partner banks

20

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Number of clients
Loan book share
Deposit share

Mass Retail Private Banking

c.2.5 mln
37%
32%

 c.85,000
63%
68%

TBC Status 
TBC  Status  serves  around  82,540  affluent  customers, 
while  our  Status  deposits  and  loans  stood  at  GEL  2,086 
million and GEL 2,975 million as of 31 December 2019, up 
by 31.4% and, 37.3% respectively. 

We offer dedicated multichannel services for our affluent 
customers with a special focus on digital channels, which 
include  internet  and  mobile  banking  with  enhanced 
functionality as well as a separate call center with extended 
capabilities. This allows our customers to conduct most of 
their  transactions  remotely.  As  a  result,  the  mobile  and 
internet banking penetration level stood as high as 87.0% 
as  of  31  December  2019  versus  45.0%  in  mass  retail. 
Should customers need a personal consultation with their 
banker, they are attended to in a comfortable service space 
designed  especially  for  them.  We  have  around  70  TBC 
Status areas in 24 branches.

We are constantly fine-tuning our private banking offerings 
to  stay  ahead  of  the  curve  and  put  together  innovative 
solutions  for  our  clients.  In  2019,  we  unified  credit  and 
operational functions so that our private customers could 
be served by a single universal banker, who will be able to 
assist him/her with all queries. We also launched the first 
digital personal banking services in the region, allowing our 
customers to self-manage their daily banking operations 

and  get  financial  advice  online.  This  service  proved  to 
be very successful and the number of digital clients has 
grown substantially. Overall, the number of Status Clients 
doubled YoY and reached 82,540 by the end of 2019.

Furthermore, we have significantly enriched our lifestyle 
services, the most popular among which proved to be the 
regular  special  meetings  with  leading  international  and 
local  speakers  from  different  fields  such  as  literature, 
psychology  management,  marketing, 
emotional 
intelligence  and  art.  We  also  have  a  dedicated  platform 
for this initiative (www.statusevents.ge), where our status 
clients  can  register  for  the  meetings  and  watch  short 
videos from previous meetings. 

High-Net-Worth Individuals 
This segment is comprised of around 2,500 resident and 
non-resident  HNW  individuals,  who  have  close  ties  with 
Georgia.  We  also  have  a  representative  office  in  Israel, 
TBC  Invest,  which  acts  as  an  intermediary  with  clients 
from  Israel,  offering  information  regarding  TBC  Bank’s 
products. 

We serve our high-net-worth clients in VIP service areas, 
which  combine  luxury,  comfort  and  privacy.  Our  highly 
qualified personal bankers act as consultants and wealth 
planners, who provide a wide range of customized services 
including  traditional  banking  and  lifestyle  solutions.  We 
actively engage with our clients to better understand their 
goals and aspirations and assist them in taking full benefit 
of  our  sophisticated  offerings.  We  also  provide  brokerage 
and  wealth  management  services  through  our  wholly-
owned subsidiary, TBC Capital. In 2019, our HNW individuals 
acquired around US$ 44 million bonds via TBC Capital. 

STATUS EVENTS

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

21

DIVISIONAL OVERVIEW CONTINUED

OUR STRATEGIC DIRECTIONS IN 2019

We  aspire  to  become  a  truly 
customer-centric  company  and 
provide personalized and seamless 
customer  experience  across 
our  omni-channel  platform  by 
leveraging  our  advanced  digital 
capabilities and big data analytics

Becoming a customer centric company
This year, we have completely reshuffled our structure in 
the  retail  business  by  building  teams  around  customers 
versus products. As a result, our focus shifted from selling 
products  and  services  towards  understanding  customer 
needs  and  striving  to  fulfil  their  needs  by  developing 
various  projects  and  ecosystems  (more  details  about 
customer  focused  digital  ecosystems  are  provided  on 
pages  43-51).  This  will  significantly  enhance  our  value 
proposition beyond banking and enable our customers to 
receive additional products and services.

During  2019,  we  launched  several  retail  projects,  the 
most significant of which is the dedicated online platform 
“Dgesve”,  which  means  “Today”  (www.dgesve.ge).  This 
user-friendly  platform  aims  to  help  people  fulfil  their 
wishes instantly and offers not only loans, but also a full 
package of complementary services that they might need 
for different purposes. For example, if a customer needs 
a car loan, he or she will also get a special discount for 
car  insurance  and  various  automobile  related  gifts  and 
offerings  from  partner  companies.  This  platform  offers 
nine  different  types  of  loans,  including  travel,  auto, 
education  etc.  The  initial  results  were  rather  promising, 
since  launch  in  November,  1,128  loans  were  disbursed 
with  outstanding  amount  of  GEL  2.7  million  as  of  31 
December 2019.  

The young generation continues to be one of the strategic 
directions  for  the  retail  business.  Our  aspiration  is  to 
become  the  #1  choice  and  most  loved  mark  brand  for 
this  segment,  by  focusing  on  educational  and  lifestyle 
offerings.

22

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 ` In 2019, we launched a youth platform for school children 
(www.TBCkids.ge),  giving  an  opportunity  to  parents  to 
order debit cards for their children remotely. The card is 
free of any banking charges, including annual service fees 
and ATM withdrawals from TBC Bank ATMs. Parents can 
set  maximum  daily  limits  for  their  children’s  spending 
and  withdrawals,  while  children  can  collect  and  spend 
loyalty  points.  In  addition,  this  platform  offers  various 
discounts  and  activities  to  the  cardholders  tailored  to 
their interests. This year, TBC also acted as a sponsor for 
educational events including Kings Olympics, Book Fair 
and Tbilisi Kids Fest. 

 ` We  also  have  many  interesting  offerings  to  university 
students, 
including  educational  and  entertainment 
programmes.  In  cooperation  with  Georgia’s  leading 
universities,  we  held  a  series  of  lectures  on  different 
subjects  based  on  students’  interests.  We  also  offer 
YourCard, a special card with distinctive benefits tailored 
to  students’  interests.  Card  holders  are  able  to  benefit 
from discounts in more than 50 partner companies. In 
2020, we plan to launch a platform for students that will 
provide  an  ecosystem  for  young  professionals,  uniting 
educational, employment and many other offerings. 

As a result, the number of youth customers1 increased by 
10.0% YoY and reached 144,260 by the end of 2019.

Since  2017,  we  have  operated  a  wide-scale  loyalty 
programme,  Ertguli,  which  helps  us  to  strengthen 
their 
relationships  with  our  clients  and 
engagement  with  us.  We  conduct  regular  campaigns 
and  partner  with  over  270  organizations  to  develop  the 
best offers for our customers. As a result, the number of 
Ertguli card holders reached 1.5 million by the end of 2019, 
while the number of POS transactions reached 85 million 
in 2019 compared to 60 million in 2018 and 40 million in 
2017. 

increase 

Transformation into a data driven organization
We aspire to maintain our leading position in the country 
and  become  a  customer-centric  organization  through 
enhancing  our  advanced  analytical  capabilities.  This  will 
help  us  to  build  a  non-replicable  competitive  advantage 
in Georgia and the wider region as well as reveal hidden 
opportunities. 

Last  year,  with  the  support  of  the  world’s  leading 
consultant,  we  developed  a  3-year  analytical  roadmap, 
which  is  comprised  of  23  data  analytical  projects  across 
the  bank.  The  target  is  to  generate  an  extra  GEL  100 
million annual net profit by 2023.

By  the  end  of  2019,  we  have  launched  and  scaled  the 
following  data  analytical  projects,  which  gained  an  extra 
GEL 8.9 million in profit:

1  Customers between 6-23 years

 ` Consumer loan pricing optimisation – This project was initiated in 2018 and the target clients were payroll customers. 
Based on the detailed analysis of their spending behavior and other characteristics, we determined price sensitivity for each 
customer and developed tailored offerings for each individual client.

 ` Affluent value proposition – In April 2019, we introduced the first digital personal banking service in Georgia, which 
allows customers full digital onboarding and self-management of digital banking operations as well as receiving TBC 
Status benefits. This project proved to be very successful, and by the end of 2019, the number of Status clients more than 
doubled, significantly outperforming our main competitor.

 ` Subscriptions for business owners – In June 2019, we launched B-COM, an innovative service model for the business 
community, which is a subscription based banking solution, offering customers a set of products and services as well as 
various trainings for a fixed monthly or annual fee. Since the launch, we have already attracted over 9,000 subscribers. 
 ` Deposit pricing in retail – This project was launched in October 2019 with the aim of effectively managing our retail 
deposits via tailored offerings to clients. When opening a term deposit, every single customer receives an alternative offer 
which is the best possible proposition for him/her under the given conditions. In December 2019, 50% of all newly opened 
or renewed term deposits were placed with alternative terms.

In addition, we have established an analytics academy, called Avalanche School of Analytics, in order to attract, train and 
retain the best talent in data science and data engineering, as well as to raise general awareness about the importance of 
data analytics across the bank. In 2019, we trained more than 500 people in data analytics principles.

Advanced digital capabilities 
We started our digital journey back in 2012 by investing in cutting-edge technology and introducing best-in-class digital 
solutions for our customers, including our award winning internet and mobile banking applications. We are also leading the 
market in terms of innovations, having pioneered the introduction of the following in Georgia: P2P payments, a Georgian-
speaking chatbot available via Facebook messenger, personal finance manager in internet and mobile banking, and a voice 
biometric  recognition  system  in  our  call  center.  As  a  result,  93%  of  all  transactions  are  conducted  digitally,  with  mobile 
banking being the most preferred channel of communication for our customers. 

We are extremely proud that, TBC Bank was named the Best in Mobile Banking 2019 globally by Global Finance Magazine 
and stands next to the world’s leading banks such as DBS, Citi and Sberbank. The award is a tribute to our advanced digital 
capabilities and continual development of cutting-edge technologies. In addition, we have won multiple regional and country 
awards from Global Finance Magazine in various digital categories, such as: The Best Consumer Digital Bank in Georgia 
2019, The Best in Consumer Mobile Banking and The Best Consumer Mobile Banking App in Central & Eastern Europe 2019. 

We do not rest on our laurels and continue to fine-tune our best-in-class internet and mobile banking applications, based 
on our customers’ feedback. This year, we added several useful features including voice assistant, which enables our clients 
to conduct simple banking transactions. We have also integrated QR payments into our mobile application, which enables 
our customers to use various payment options through a single application. In addition, we have enriched our internet and 
mobile banking offering with third party data and added information regarding our clients’ state pension fund contributions. 
Furthermore, we are using our data analytical capabilities to develop personalized offerings which are offered via our mobile 
& internet banking applications. 

First Internet and
Mobile Bank verison

First P2P payment
product in Georgia

First Financial
ChatBot in Georgia

Voice and
QR Payments

2012

2014

2015

2016

2017

2018

2019

Renewed version
of Mobile Bank

Renewed version
of Internet Bank

Digital Wallet

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

23

DIVISIONAL OVERVIEW CONTINUED

D G E S V E . G E

PLATFORM DGESVE

It is an innovative online platform, 
which allows retail customers to fulfil 
their wishes by getting consumer 
loans instantly. 

24

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DIVISIONAL OVERVIEW CONTINUED

CORPORATE INVESTMENT BANKING

2019 HIGHLIGHTS

38.9%
Corporate loan market share1 

36.8%
Corporate loan share in total gross portfolio

40.6%
Corporate deposits market share1

31.7%
Corporate deposit share in total portfolio

50.2%
Corporate guarantee and
letter of credits market share1 

3,232
Number of customers

OVERVIEW
TBC Bank is the leading corporate and investment bank in Georgia, holding the number one position by all key metrics. We 
operate an advisory focused business model and strive to become the trusted partner for our clients in all their business 
undertakings. Our clients are served by highly experienced corporate bankers, with strong expertise in all major economic 
sectors,  who  help  them  to  optimize  their  financial  structure.  We  also  have  strong  trade  finance  capabilities  supporting 
international trade relationships for Georgian companies. As the demand for sophisticated investment banking solutions is 
increasing among large corporations, we are actively developing our corporate advisory, brokerage and research services 
through our wholly owned subsidiary TBC Capital.

DIVERSIFIED PORTFOLIO WITH STRONG PRESENCE IN EVERY SECTOR OF GEORGIAN ECONOMY

Energy &Utilities

Real Estate

Food Industry

Oil & Gas

Automotive

Metals & Mining

Hospitality & Leisure

Finantial Services

Construction

Trade

Healthcare

Agriculture

Other

1%

2%

2%

7%

3%

4%

5%

7%

12%

13%

23%

20%

CORPORATE BANKING
We have a well-diversified loan portfolio, serving 3,232 corporate clients across all major sectors of the economy. 2019 was 
a strong year in terms of client acquisition and portfolio growth, especially in the mid-corporate sub-segment. As of 31 
December 2019, our total corporate loan book amounted to GEL 4,660 million, up by 46.7% YoY driven by acquisitions of both 
large and mid-corporate clients as well as re-segmentation of certain clients from the MSME segment in first quarter 2019. 
Consequently, the share of our mid-corporate segment increased to 41.0% of the total corporate portfolio as of 31 December 

1  Based on data published by the National Bank of Georgia as of 31 December 2019; in this context corporate refers to legal entities

26

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2019 compared to 27.0% a year ago. More information about 
the  financial  performance  of  the  corporate  segment  is 
provided in the financial review section on pages 108 -123.

We  maintain  the  leading  position  in  Georgia  in  terms  of 
trade  finance  operations  by  providing  diversified  product 
offerings as well as advisory services. We also have well-
established  partnerships  with  major  counterparty  banks 
and international financial institutions. Our guarantees and 
letter of credit portfolio amounted to GEL 1,702 million, up 
by 39.0% YoY. In recognition of our outstanding efforts, we 
have won several prestigious international awards: “Trade 
Finance  Award  for  Excellent  Partnership  2019”  from 
Commerzbank,  “Best  Trade  Finance  Provider  in  Georgia 
2020” from Global Finance as well as “The Market Leader 
in Georgia 2020” and “The Best Service Provider in Georgia 
2020” from Euromoney. 

Furthermore,  our  corporate  banking  drives  strong 
cross-selling  of  various  operational  products  including 
payments1 , payroll accounts and FX transactions. In 2019, 
the number of corporate clients’ payroll accounts reached 
161,953, remained broadly stable on YoY basis, while the 
payroll fund grew by 23.0% YoY, amounting to GEL 302.7 
million. Corporate banking also had solid results in terms 
of number of payments transactions, totaling 94.5 million, 
up  by  52.4%  YoY,  and  volume  of  transactions  amounting 
to GEL 4,058 million, up by 54.6% YoY. The volume of FX 
transactions in 2019 amounted to GEL 12,095 million, up 
by 38.7% YoY, while the number of FX transactions grew by 
51.4%, amounting 130,397.

As a long-standing partner and advisor, we strive to create 
additional value for our customers by sharing the world’s 
best practices with them.  For this purpose, this year, we 
provided  a  unique  opportunity  for  our  large  corporate 
clients  to  attend  a  full  2  day  customized  “TBC  Bank 
Strategic Leadership Executive Education Programme“ at 
INSEAD, one of the leading business schools in the world. 
The programme was specially designed for our partners 
and  covered  the  following  topics:  cultural  agility,  deep 
partnering,  assessing  the  long-term  profit  potential  of 
market opportunities, competing in markets with platform 
and ecosystems dynamics.

INVESTMENT BANKING
This year, TBC Capital acted as the sole lead arranger for 
bonds of Tegeta Motors2  and Nikora Trade3  in the amount 
of GEL 30 million and GEL 28 million, respectively as well 
as  for  one  private  placement  in  the  amount  of  US$  2.2 
million. In addition, TBC Capital, together with a number 
of  leading  international  investment  banks,  acted  as  joint 
lead arranger for the Eurobonds of Silknet4  and TBC Bank 
in  the  amount  of  US$  200  million  and  US$  425  million 
respectively, which were dual-listed on the Georgian Stock 
Exchange and the Irish Stock Exchange. Silknet’s Eurobond 
was the first issuance from the private sector non-financial 
institution in Georgia, while TBC Bank achieved the lowest 
ever  interest  yield  on  its  senior  bonds  and  the  lowest 
coupon  on  the  additional  Tier  1  bonds  in  Georgia.  As  a 

result, the bonds issued publicly and listed5  by TBC Capital 
during  this  year  amounted  to  GEL  1,805  million,  holding 
76.0%6  of total bonds issued and listed on Georgian Stock 
Exchange in 2019. 

TBC  Bank  continues  to  provide  the  most  convenient 
brokerage solutions to its clients by offering sophisticated 
services.  This  year,  we  achieved  a  significant  milestone 
by starting cooperation with Clearstream, which is one of 
the  largest  Central  Securities  Depositories  in  the  world, 
and  we  successfully  settled  the  first  Georgian  corporate 
bond  of  Lisi  Lake  Development7    through  this  platform. 
This  will  allow  Georgian  companies  to  get  access  to  a 
large international investor base and attract capital more 
effectively.  Furthermore,  we  continue  our  partnership 
with Interactive Brokers, the largest online broker in the 
USA,  which  enables  us  to  offer  advanced  online  trading 
capabilities  to  our  clients  through  direct  access  to  more 
than 120 markets, 30 countries and 22 currencies.

TBC Capital is actively developing its sectoral research arm. 
During  2019,  we  produced  a  number  of  comprehensive 
reports  including  Tbilisi  and  Batumi  Residential  Markets, 
Tourism,  Fixed  Income  Securities,  Fast  Moving  Consumer 
Goods  (FMCG)  and  Energy.  The  reports  are  available  at 
www.tbcresearch.ge.  This  year,  TBC  Capital  also  organized 
six  public  events,  presenting  TBC  Capital  sectoral  insights 
to  major  stakeholders.  Our  reports  were  well  received  by 
both  the  private  sector  and  the  state,  sparking  numerous 
discussions  in  the  media  and  being  referred  to  by  industry 
professionals. Going forward, our target is to fully cover the 
Georgian  economy  through  in-depth  sector  research  and 
regular updates.

Nikorassuu pp ee rrmm aarrkkee tt

GEL 30 mln 3-year Bond
Public Placement
NBG + 4.25%
Placement Agent

GEL 28 mln 3-year Bond
Public Placement
TIBR3M + 4.00%
Placement Agent

US$ 200 mln 5-year Eurobond
Public Placement
11%
Co-Lead Manager

1  Payments include e-commerse and POS terminal transactions
2  Tegeta Motors is a leading automotive products and service 

provider company in Georgia

3  Nikora Trade is a leading food producer company in Georgia
4  Silknet is a leading telecommunication company in Georgia
5  Excluding IFI bonds
6  Excluding IFI bonds and dual listed bonds and Bank of Georgia AT1 

bond, which is not listed on Georgia Stock Exchange

7  Lisi Lake Development is a leading developer company in Georgia

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

27

DIVISIONAL OVERVIEW CONTINUED

SECTORAL RESEARCH

TBC  Capital  regularly  organizes 
public  discussions  on  various 
sectors including Tbilisi and Batumi 
Residential Markets, Tourism, Fixed 
Income  Securities,  Fast  Moving 
Consumer Goods (FMCG) and Energy.

28

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DIVISIONAL OVERVIEW CONTINUED

MSME

2019 HIGHLIGHTS

62%1
of newly registered legal entities
chose TBC Bank

c.147,418  
customers

11.8%  
MSME share in total deposit portfolio

93%2 
offloading ratio of MSME

23.3%  
MSME share in total loan book

75%3 
NPS

OVERVIEW
TBC Bank is the number one partner bank for micro, small and medium enterprises (MSMEs) in the country, with 62%1 of all 
newly registered legal entities in Georgia choosing TBC Bank. We differentiate ourselves through an exceptional customer 
experience,  best-in-class  financial  products  and  services,  an  extensive  business  support  programme  and  strong  digital 
capabilities.  

This year, we introduced an agile structure in MSME, that is better tailored to business needs and attuned to market demands. 
Segment-focused squads (agile teams) have been created that enable us to create added value for our clients and become 
ever more customer-centric when developing our products and services. The process-oriented squads help us to streamline 
the processes, while digital squads, which are allocated directly to businesses are designed to improve digital channels and  
to ensure that all our products are digitally accessible.

In 2019, our MSME loan book increased by 18.1% YoY to GEL 2,948 million, mainly driven by an increase in the hospitality and 
leisure, agriculture, construction and trade sectors. Over the same period, MSME deposits increased by 16.8% to GEL 1,188 
million. More information about the financial performance of the MSME segment is provided in the financial review section 
on pages 108 to 123.

DIVERSIFIED MSME PORTFOLIO WITH STRONG PRESENCE IN AGRICULTURE, HOSPITALITY&LEISURE AND TRADE SECTORS

1%

13%

15%

2%

2%

3%

4%

5%

5%

6%

7%

9%

30

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

14%

12%

Agriculture

Healthcare

Hospitality & Leisure

Transportation

Trade

Construction

Food Industry

Pawn Shops

Services

Real Estate

Automotive

Manufacturing

Individual

Oil and Gas

Finantial Services

Other

OUR STRATEGIC DIRECTIONS IN 2019

We  aspire  to  deliver  the  best 
customer  experience  to  MSME 
clients through our best-in-class 
distribution channels, innovative 
and affordable offerings, efficient 
and lean operational processes and 
wide-ranging non-financial services.

Best-in-class distribution channels
In  an  era  of  constant  technological  development,  it  is 
crucial for us to provide market leading digital offerings and 
engage digitally with our customers. We are proud to have 
the best-in-class internet and mobile banking applications, 
with  around  84%  of  our  active  MSME  customers  using 
internet  banking  and  37%  using  only  the  mobile  bank 
application as of 31 December 2019. As internet banking  
is  the  most  popular  channel  of  communication  with  our 
customers, we are constantly fine-tuning it based on our 
customer feedback. This year, we have added several new 
features and redesigned certain screens to make it more 
intuitive and easy to use. 

Next  year,  we  also  plan  to  develop  a  dedicated  in-house 
mobile banking application for businesses, which will be 
tailored for businesses needs and allow our customers to 
manage their businesses easily on the go.  The in-house 
development will enable us to be more agile and prompt 
in  responding  to  our  customer  needs  and  will  make  the 
interaction with the app engaging.

In  addition,  we  have  a  dedicated  call  center    for  MSMEs 
available 24/7, which is a strong channel both for sales and 
customer enquiries. Around 53% of all sales are conducted 
though our call center. 

We  are  the  only  bank  in  the  region4  offering  fully 
digital  on-boarding,  which  enables  legal  entities  to 
become  our  customers  by  registering  online  at  www.
businessregistration.ge. The registration process only takes 
a  few  minutes,  after  which  the  company  becomes  TBC’s 
customer with access to all basic products. In 2019, 22% of 
newly registered customers were on-boarded digitally. 

Innovative and affordable offerings
In line with our mission of making the lives of our customers 
easier,  we constantly fine-tune our offerings in order to 
create maximum value for our customers. In addition to 
the  full  range  of  lending  and  operational  products  that 
we offer to our MSME clients, we also provide innovative 
solutions  as  well  as  tailor-made  offerings  for  start-ups 
and micro and small businesses. 

Since  2017,  we  have  run  “Startaperi”,  an  innovative 
programme that aims to support early-stage businesses 
by providing them with accessible financial resources as 
well  as  extensive  non-financial  services.  Currently,  we 
offer four types of loans for start-ups: a general loan and 
special loans for restaurants, hotels and agro businesses. 
The  Startaperi  programme  has  gained  tremendous 
popularity  and  attracted  around  34,800  companies  since 
its launch.  As of 31 December 2019, the total outstanding 
portfolio of such loans stood at GEL 120 million, while the 
number of loans amounted to 550. 

In order to foster business growth in rural areas and help 
to create new job opportunities, we are actively supporting 
local  businesses  by  providing  affordable  finance.  In 
partnership  with  government  programmes:  “Produce  in 
Georgia” and “Agriculture Project”,   which aim to support 
agriculture,  manufacturing  and  hospitality  industries, 
we  have  been  providing  the  necessary  financing  to  local 
businesses.  Within  these  programmes,  borrowers  can 
apply  for  a  subsidy  from  the  government  to  lower  their 
interest  expense.  During  2019  we  disbursed  46  loans 
amounting to GEL 29 million. Overall, as of 31 December 
2019,  34%  of  our  total  MSME  loan  book  was  used  to 
finance rural areas, the largest sectors being agriculture, 
hospitality  &  leisure  and  trade  with  respective  shares 
of  39%,  10%  and  9%.  As  a  result,  we  have  helped  more 
than  29,000  borrowers  in  rural  areas  to  develop  their 
businesses. 

In  May  2019,  we  launched  B-COM,  an 
innovative, 
subscription  based  banking  service  that  offers  MSME 
customers  a  set  of  products  and  services  as  well  as 
various trainings for a fixed monthly or annual fee. Since its 
launch, we have already attracted over 9,000 subscribers, 
with around 34% choosing annual subscription. The new 
service packages are well tailored to fit the various needs 
of  businesses  and  enable  cost  optimization  on  frequent 
transactions.

In  2019,  we  launched  TPay  application,  a  universal 
payment  system  that  combines  point  of  sale  and  online 
payments with QR technology and also allows innovative 
online checkout. This is a faster, cheaper and more secure 
payment method, which enables cashless transactions in 
micro merchants, mainly in rural areas, where currently 
only  cash  is  accepted.  Merchants  can  use  a  printed  QR 
stand, a sticker, or choose the TPay application to accept 
QR  payments,  while  retail  customers  can  conduct  QR 
payment via our mobile banking application, as well as the 
TPay application for non-TBC customers. Currently there 
are about 2,267 online and offline merchants already using 
TPay system.

1  Data is for FY 2019, source: www.napr.gov.ge, the national Agency 

of Public Registry

2  Excluding cash transactions
3  Based on survey conducted by independent research company IPM 

among MSME segment in October 2019

4  The region in this context comprises Azerbaijan, Armenia and Georgia

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

31

DIVISIONAL OVERVIEW CONTINUED

In  October  2019,  we  introduced  an  innovative  new  cash 
terminal  ,  a  combination  of  a  cash  register  and  a  POS 
terminal,  to  minimize  our  MSME  customers’  monthly 
costs.  This  terminal  enables  merchants  to  offer  their 
customers  the  same  services  in  a  more  convenient  and 
affordable way. Since its launch, more than 483 merchants 
have either replaced their old terminals with a new one, or 
started using our cash terminals as their first choice. 

Next year, we plan to enhance our online lending platform, 
which  will  significantly  simplify  and  speed  up  the  loan 
application  process  for  business  customers  and 
is 
expected to decrease the bank’s decision making process 
to minimum.

Operational process optimisation
In 2019, we optimized our structure in the MSME business 
by  eliminating  unnecessary  processes  and  enhancing 
certain  functions 
in  order  to  speed  up  customer 
registration,  overall  service  time  as  well  as  product 
development time-to-market. 

The most remarkable initiative this year was the complete 
transformation  of  our  registration  platform  for  MSME 
clients. The new platform is integrated with the National 
Agency of Public Registry (NAPR) and the Public Service 
Development  Agency,  which  allows  the  majority  of 
information  to  be  filled  automatically,  thus  enabling 
our  employees  to  register  new  customers  with  all  basic 
products  within  10-15  minutes,  with  no  involvement 
needed from the back office in more than 70% of cases. 
In the past, it took more than 40 minutes to register a new 
customer and 24 hours for a new account to be activated, 
with back office involvement needed in almost all cases.   

Another  important  project  was  the  simplification  of  the 
loan approval process, which shortened the time between 
application submission and loan approval from 2 days to 
30 minutes:

 ` Starting  from  March,  mini  business  and  mini  agro 
loans up to GEL 20,000 could be issued using tablets. 
Loan officers visit the clients at their locations, approve 
loans based on scoring model and register clients on 
the spot.  As of December 2019, more than 85% of this 
type of loans were disbursed using tablets. 

 ` In addition, starting from November 2019, we launched 
the  automotive  loan  approval  system  for  business 
loans  up  to  GEL  100,000  based  on  scoring  model. 
At  the  end  of  the  year,  40%  of  all  such  loans  were 
approved automatically. 

Extensive non-financial services 
We  are  the  only  bank  in  Georgia  offering  a  full-scale 
business support programme, which includes educational 
resources,  a  business  blog,  business  support  tools,  an 

32

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

annual  business  award  and  a  start-up  programme.  All 
these  services  are  united  on  a  single  platform:  www.
tbcbusiness.ge.

In  partnership  with  the  Asian  Development  Bank  (ADB) 
and the European Fund for Southeast Europe (EFSE), we 
conduct trainings, run conferences, and organise individual 
consultations as well as agro forums across the country. 
All these services are provided free of charge. The aim is to 
help entrepreneurs to improve their skills in areas such as 
management, marketing, finance and taxation, which will 
support them in developing their businesses. In 2019, we 
have trained more than 4,000 business representatives in 
different  fields  and  organised  four  business  forums  with 
around  800  participants  in  different  regions  of  Georgia. 
During the year, we have also held a number of six-week 
intensive  courses  for  our  SME  clients,  “IFRS  for  SMEs”, 
training around 160 participants in total.

Support of early-stage businesses remains our top priority 
and  we  continue  to  develop  new  services  within  our 
innovative  programme  “Startaperi”.  Startaperi  aims  to 
create more successful startups in Georgia by supporting 
them with easily accessible capital, a digital platform for 
advertising  campaigns,  as  well  as  various  educational 
programmes  and  conferences.  During  the  year,  700 
start-ups were trained in different fields. In 2019, we also 
launched  “Startup  discussions”,  a  monthly  knowledge 
sharing platform for startup founders to learn from other 
successful  startups.  This  initiative  proved  to  be  very 
successful, attracting around 100 participants each month. 

Since  2016,  in  partnership  with  EFSE,  we  have  been 
organising an Annual Business Awards ceremony in order 
to  support  entrepreneurship  in  Georgia.  This  ceremony 
has  become  the  major  business  event  of  the  year  in  the 
country, attracting more than 2,000 community members. 
This year, over 350 business participated in the Business 
Award ceremony and five winners were announced in the 
following categories:

 ` Product/service of the year;
 ` Employer of the year;
 ` Exceptional corporate social responsibility;
 ` Innovation of the year; and
 ` Startup of the year.

The  event  attracted  a  reach  of  25  million  in  press  and 
social media while a survey conducted by the independent 
research agency, ACT, showed that top-of mind awareness 
of the project reached 72% in 2019.

Yevgen Lisnyak, Senior Director and Head of Strategic 
Partnerships,  Fintech  &  Ventures  (Visa,  CISSEE), 
commented:  “At  Visa  we  believe  in  the  power  of 
partnership  to  bring  our  profound  experience  and 
innovative solutions to emerging payment players like 
Space. Being in the center of Fintech ecosystem, we aim 
to share our knowledge, best practices and network of 
technological partners with Space to achieve mutual 
goals in expanding the reach of digital financial services. 
Today, we are witnessing a rapid transformation of the 
financial banking sector, where new players are playing 
a significant role. Neobanks are agile, consumer-centric, 
flexible and innovative, offering modern consumers 
completely new financial solutions and a new digital 
banking experience. We are excited to be able to support 
fintechs to navigate the payments landscape in the 
Caucasus region to achieve their business growth and 
international expansion ambitions.”

SPACE

2019 HIGHLIGHTS

508k downloads
2.6 mln transactions during 2019
GEL 27 mln loan portfolio
121k total cards attached
4.9 stars of Apple store with 5.9k reviews

Partnership agreement with Visa

OVERVIEW
Space is the first Georgian neobank, a mobile app without 
traditional branches or a physical presence. Structured as 
an  autonomous  business,  Space  is  a  trailblazing  mobile 
application  for  managing  daily  finances,  which  challenges 
and redefines the traditional banking experience and strives 
to make banking simple, friendly and fun. In all operational 
aspects,  it  is  a  fintech  startup  project:  from  people  to 
processes to corporate culture.

Space  is  a  fully  cloud  solution  that  was  built  in  order  to 
resolve the complexity of integration with traditional legacy 
systems.  Its  flexible  IT  architecture  makes  it  possible  to 
launch new products much faster than in traditional banking. 

Space  will  play  an  important  role  in  our  international 
expansion strategy and will allow us to expand our presence 
in new markets in the most efficient way, using a capital-
light model. 

Space was launched in May 2018 in Georgia and has already 
attracted around 181 thousand customers, out of whom 46% 
were previously inactive TBC customers. As of 31 December 
2019, the Space loan book amounted to GEL 27 million and 
the number of borrowers reached 10 thousand. Also, during 
2019 the number of transactions stood at 2.6 million, while 
the volume of transactions amounted to GEL 154 million. 

PRODUCT DESCRIPTION AND
ITS MAJOR BENEFITS

Space differentiates itself through its simple and intuitive 
design,  unique  customer  experience,  price  transparency 
and instant service delivery. 

Currently  Space  is  offering  the  following  products  and 
capabilities: 

 ` remote account opening in under 5 minutes;
 ` instant consumer loans 24/7 up to 50,000 GEL;
 ` Savings pot;
 ` instant money transfers to any bank 24/7;
 ` mobile top and bill payments; 
 ` debit cards, 

181k total registered customers

GEL 154 mln transactions volume during 2019
10k borrowers
65k Space cards issued
4.8 stars of Google play with 6.0k reviews

 ` Wallet with the possibility to attach other bank cards;
 ` Apple pay; 
 ` QR installments for e-commerce and offline stores. 

Saving  pots,  which  was  launched  in  December  2019,  is 
a  modern  alternative  to  traditional  saving  and  deposit 
products. It will enable customers to save money more easily 
with the help of features such as goal setting, automatic 
saving rules and flexible access options. Customers will be 
able to choose from three main automatic saving rules that 
are attached to everyday transactions. In addition, pots will 
allow customers to access their money at any time without 
restrictions.  Customers  will  also  be  able  to  share  their 
pots  with  friends  to  save  money  collectively  for  different 
occasions such as birthdays, presents, etc.

In July 2019, Space introduced a unique cash-back program, 
offering  cash-back  in  every  food  chain  worldwide.    A  5% 
cashback is issued to customers who pay with Space cards 
in  cafes,  restaurants,  fast  food  restaurants  or  when  they 
order food via delivery applications such as Glovo or Wolt. 
During  2019,  around  13  thousand  customers  benefited 
from this service. 

In addition, in response to our customers’ wishes, in July 
2019, we introduced a weekly gamification contest, which is 
a different take on a traditional loyalty program.  Customers 
compete  with  each  other  to  gain  rewards.  Points,  which 
are called “stars”, are given for making transactions with 
a  Space  card,  inviting  others  to  join  Space,  making  bill 
payments and even by playing Space game that are built 
into  the  app.  Each  Friday,  the  top  300  customers  receive 
cash rewards ranging from GEL 5 to GEL 150. More than 
28% of total Space customers are actively involved in this 
contest and 2,705 customers received cash rewards by 31 
December 2019.

One  achievement  that  particularly  stands  out  in  2019 
was  the  signature  of  a  partnership  agreement  with  Visa 
to  jointly  develop  an  innovative  banking  service  and  to 
introduce  cutting-edge,  user-centric  and  secure  banking 
solutions,  which  will  help  us  in  our  ambitions  to  expand 
our digital banking footprints beyond Georgia. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

35

DIVISIONAL OVERVIEW CONTINUED

MAJOR SUBSIDIARIES

TBC Insurance is a rapidly growing, wholly owned subsidiary of TBC Bank and is the main bancassurance partner of the 
Bank. The company was acquired by the Group in October 2016, and since then it has worked hard to strengthen its position, 
becoming the largest retail player in the non-health insurance market in Georgia, with a market share1 of 36.6% and serving 
more than 260,000 customers. 

TBC Insurance serves both individual and legal entities and it provides a broad range of insurance products covering motor, 
travel,  personal  accident,  credit  life  and  property,  business  property,  liability,  cargo  and  agro  products.  TBC  Insurance 
differentiates itself by advanced digital channels, which includes TBC Bank’s award winning Internet and mobile banking 
applications, a wide network of self-service terminals, a web channel, as well as B Bot, a Georgian-speaking chat bot that is 
available through Facebook messenger.

Starting from the second quarter of 2019, TBC Insurance entered the health insurance market with a focus on the premium 
segment. Our strategy is to capture the affluent market by leveraging our strong brand name, leading digital capabilities and 
cross selling opportunities with payroll customers. 

The bancassurance business2 represents 41.2% of the total gross written premium (GWP) as of 31 December 2019, while the 
breakdown of total GPW by segments and products is given on the below pie charts. 

TOTAL GWP IN 2019 BY SEGMENTS

TOTAL GWP IN 2019 BY PRODUCTS

35%

Retail

Business

4%

7%

16%

65%

43%

30%

Motor

Life & Personal Accident

Property

Health

Other

MARKET OVERVIEW
The insurance business in Georgia is regulated by an independent body, the Insurance State Supervision Service of Georgia, 
which  closely  monitors  insurance  companies  and  sets  the  minimum  and  solvency  capital  requirements.  There  are  17 
insurance companies in the Georgian insurance market. The Georgian insurance market has a high growth potential as it is 
under-penetrated with gross written premium to GDP standing at around 1.3%3 as of September 2019, which is one of the 
lowest among CEE countries. The density, which is measured as gross written premium per capita, is also low compared to 
peer countries, standing at US$ 56.4 as of December 2019.

36

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

In 2019, the non-health insurance market grew by 19.9%, 
or 12.7% on a constant currency basis and reached GEL 
378  million.  The  compulsory  motor  third  party  liability 
insurance  (MTPL),  which  is  expected  to  come  into  force 
in 2021, will further increase the market by an estimated 
GEL 150 million. The largest products on the market are 
motor  and  property  insurance,  which  combined  account 
for 66.3% of the total market. Aldagi and TBC insurance 
are the two largest players with market shares4 of 29.1% 
and 21.5% respectively, as of 31 December 2019, followed 
by GPIH with 14.2%. 

In 2019, the health insurance market grew by 7.9% on a 
constant currency basis and amounted to GEL 224 million. 
We  expect  accelerated  market  growth  in  the  coming 
years  driven  by  the  increasing  trend  in  average  monthly 
premium.  The  largest  players  in  the  health  insurance 
market are Imedi L and GPIH with market shares  of 31.9% 
and  24.0%  respectively,  followed  by  Ardi  insurance  with 
12.5% as of 31 December 2019.

GWP OF GEORGIAN INSURANCE MARKET
BY PRODUCTS IN 2019

6%

7%

9%

MAIN ACHIEVEMENTS AND STRATEGY 
In 2019, our main focus in the retail non-health business 
was increasing the sales offloading ratio5 and the motor 
claims offloading ratio6. As a result, the number of policies 
sold  via  digital  channels  increased  by  146.0%  YoY  and 
reached  51,160  in  2019,  leading  to  an  offloading  ratio 
of  48.3%  compared  to  29.3%  a  year  ago.  Over  the  same 
period,  the  number  of  motor  claims  handled  distantly 
also increased sharply, with the motor claims offloading 
ratio  reaching  51.2%  in  December  2019,  up  by  16.1pp 
YoY.  Furthermore,  in  July  2019,  we  introduced  a  digital 
motor policy renewal process, which will result in reduced 
acquisition costs and increased operational effectiveness 
over the medium-term. By the end of the year, 26.5% of all 
renewed motor policies were renewed digitally.  

On the MSME side, we have standardized certain insurance 
products  and  processes  in  order  to  provide  simplified 
solutions  to  our  customers.  In  parallel,  we  continue  to 
actively  utilize  our  MSME  bancassurance  web  portal, 
which  helps  us  to  increase  our  foothold  in  the  severely 
underpenetrated  MSME  market.  In  terms  of  corporate 
clients,  we  continue  to  leverage  the  bank’s  strong 
corporate client base in order to attract new customers. 
As a result, our market share of non-health legal entities 
reached 11.4% in 2019, compared to 10.4% in 2018.

Regarding the health business, from November 2019 TBC 
Insurance  offered  individuals  the  opportunity  to  receive 
claim  reimbursements  via  chat  bot  messenger.  This 
initiative is unique in the market and will greatly improve 
the claim regulation process on the client side.

14%

37%

27%

Health

Motor

Property

Life & Personal Accident

Liability

Other

1  Market  share  without  mandatory  border  MTPL.  With  mandatory 
border MTPL market share was 30.2%. Starting from March 1, 2018 
border  MTPL  has  been  introduced  and  GWP  was  divided  evenly 
between  17  insurance  companies,  therefore  it  has  decreased  our 
market share. Source: insurance.gov.ge

2  The  selling  of  credit  linked  and  voluntary  insurance  products  and 

services by JSC TBC Bank

3  Source: Geostat and insurance.gov.ge
4  Market shares are without mandatory border MTPL. With mandatory 
border  MTPL  market  shares  of  Aldagi,  TBC  Insurance  and  GPIH 
stood at 27.3%, 20.0% and 13.4% respectively. Starting from March 
1,  2018  border  MTPL  has  been  introduced  and  GWP  was  divided 
evenly between 17 insurance companies, therefore it has decreased 
our market share. Source: insurance.gov.ge

5  The number of policies sold via digital channels divided by the total 

number of voluntary retail policies

6  The  number  of  motor  claims  regulated  distantly  (by  web  &  call 

center) divided by the total number of motor claims

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

37

DIVISIONAL OVERVIEW CONTINUED

Overall, TBC Insurance recorded strong growth in 2019 with gross written premium increasing by 31.5% to reach GEL 79.0 
million, leading to a market share1 of 21.5%, up by 1.1pp YoY. Over the same period, our net earned premium increased by 
48.3% and amounted to GEL 52.9 million, while our net combined ratio grew by 3.5pp and stood at 82.8%, driven by increased 
operating expenses in health insurance. As a result, our net profit went up by 12.5% and reached GEL 8.5 million. Looking 
forward, we will continue to grow and expand our insurance business and become the number one player in Georgia in the 
medium-term, with the highest net promoter score (NPS) among the industry players in the country.

Strategic priorities  Non-health Insurance
Market Share
Net Combined Ratio
Offloading ratio in voluntary retail sales2
NPS3

Strategic priorities Health Insurance
# of Insured Premium Staff 
Net Combined Ratio
Loss Ratio
NPS3

Mid-term target
30% +
< = 85%
70% +
The best in industry

Mid-term target
50,000
< = 95%
< = 85%
The best in industry

Our mid-term target for net combined ratio increased from below 80% in 2018 to below 85% in 2019, due to the strong 
competition on the market and reduced margins. We also plan to increase the corporate share in our portfolio, which will in 
turn increase the need for reinsurance. 

We also raised our offloading ratio target from above 50% in 2018 to above 70% in 2019, as the trend towards digitization is 
more positive than expected. Moreover, the digital renewal process also enhanced our capabilities to increase digitalization 
at a faster pace.

1  Without mandatory border MTPL. Market share with mandatory border MTPL stood at 20.0%, up by 0.9 pp YoY. Starting from March 1, 2018 border 

MTPL has been introduced and GWP was divided evenly between 17 insurance companies, therefore it has decreased our market share
 Number of sales conducted in digital sales divided by total number of retail voluntary sales 
 Based on the internal survey

2 
3 

38

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DIVISIONAL OVERVIEW CONTINUED

TBC  Leasing  is  a  wholly  owned  subsidiary  of  TBC  Bank 
and is the leading leasing company in Georgia, with 68.0% 
market  share1  as  of  31  December  2019.  It  was  founded 
in 2003 by TBC Bank and, since then, it has considerably 
strengthened  its  position  on  Georgian  market,  serving 
around  4,000  customers  with  a  total  leasing  portfolio  of 
GEL 258.3 million as of 31 December 2019. 

TBC Leasing serves both individuals and legal entities and 
provides  comprehensive  leasing  solutions  and  advisory 
services,  including  financial  leasing,  operating  leasing, 
sales and leasebacks tailored to customers’ needs. Legal 
entities  account  for  around  84.6%  of  our  portfolio  with 
services,  construction,  health  care  and  production  being 
the  largest  sectors.  Our  retail  portfolio  is  comprised  of 
new and used cars, with respective shares of 43.8% and 
56.2%  in  total.  Our  retail  customers  are  served  at  our 
service centers, while we use the bank’s channels to sell 
our products to MSME and corporate customers.

The company actively cooperates with two governmental 
projects,  “Produce  in  Georgia”  and  “Agriculture  Projects 
Management Agency” (APMA), which aim to support the 
development  of  manufacturing,  service  and  agriculture 
industries  by  subsidizing  companies’  interest  expenses. 
During 2019, we issued GEL 34 million leases within these 
programs and our portfolio grew by 80.8% YoY to GEL 53 
million.  We  also  strive  to  increase  awareness  of  leasing 
solutions  to  startup  companies  for  whom  leasing  is  an 
affordable and particularity convenient option to obtain the 
necessary equipment.  

In  addition,  TBC  Leasing  actively  cooperates  with  the 
largest vendors of Georgia to facilitate sales and financing 
of  new  vehicles  and  equipment  used  in  transportation, 
construction  and  manufacturing.  During  2019,  together 
with  Tegeta  Motors,  its  long-run  strategic  partner  and  a 
leader in  the automotive products and services industry, 
TBC Leasing ran active joint campaigns for the promotion 
of sales of new vehicles and equipment. 

Furthermore, TBC Leasing is actively engaged in financing 
green  and  energy  efficient  assets.  During  2019,  in 
cooperation with SOCAR Georgia Petroleum and SCANIA 
Georgia, the company provided financing in the amount of 
GEL 4.5 million for fuel transporting heavy vehicles, which 
are manufactured by SCANIA in accordance with the Euro 

6  emission  standard  and  therefore  are  ecofriendly  and 
energy efficient. In addition, in 2019, TBC Leasing obtained 
a multicurrency credit facility in amount of GEL 30 million 
from FMO with 30.0% of the amount to be utilized in energy 
efficient projects.

Our  focus  for  2020  remains  to  further  grow  the  leasing 
business in Georgia, as well as to develop supplementary 
services for our clients “to make their lives easier” in line 
with the group’s mission.

TBC PAY

TBC Pay is one of Georgia’s leading payment companies. 
It was founded in 2008 by TBC Bank and is a wholly owned 
subsidiary of the bank. TBC Pay operates a wide network 
of self-service terminals all over the country, which allow 
individuals to perform payments for various daily services 
instantly  in  an  interactive  mode  on  a  24-hour  basis. 
Payments can be made in cash or using a debit or credit 
card. The company also operates an online web-platform 
(www.tbcpay.ge), which has the same functionality as self-
service terminals.

TBC  Pay  also  offers  cash  management  services  to 
companies  with  a  large  volume  of  cash  operations, 
allowing customers to deposit money directly to their bank 
account,  which  will  appear  instantly  on  their  electronic 
statement.

In 2019, the company significantly expanded its operations 
in  the  payment  business  as  well  as  cash  management.  
The  number  of  transactions  in  self-service  terminals 
increased by 7.9% YoY to 46.7 million, while the volume of 
these transactions went up 37.3% YoY to reach GEL 3,194.7 
million  accounting  for  around  88%  of  total  number  and 
volume of transactions.  This was driven by the increase 
in number of self-service terminals, as well as by careful 
analysis of suitable locations for the installation of these 
terminals.    Currently,  TBC  Pay  has  3,671  self-service 
terminals  in  operation  compared  to  3,281  a  year  ago.  
Over  the  same  period,  the  volume  of  cash  management 
transactions  amounted  to  GEL  990.4  million  in  2019, 
up  by  around  114%  year  on-year,  while  the  number  of 
such  terminals  increased  from  to  454  from  131  a  year 
ago.  Among  our  large  clients  are  the  leading  petroleum 
companies,  pharmacy  retailers  and  food  producers  in 
Georgia. As a result, in 2019, our net revenue reached GEL 
35.1  million,  up  by  14%  year-on-year,  while  our  EBITDA 
amounted to GEL 18.3 million, up by 14.0% year-on-year. 

40

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

We continue to enhance our digital offerings and in 2019, 
we  enriched  our  web-platform  with  new  features  and 
functionalities  making  bill  payments  easier  and  faster. 
We also introduced an e-wallet enabling TBC Pay clients 
to  conduct  their  electronic  transactions  without  the  use 
of  credit  cards.  The  customer  just  needs  to  top-up  the 
e-wallet balance periodically.  Furthermore, we launched 
the TBC Pay mobile app for both iOS and Android users, 
which  is  the  first  mobile  payments  application,  allowing 
clients  to  use  its  services  without  any  additional  mobile 
internet charge. 

Our main priorities for 2020 remain fine-tuning our digital 
offerings,  with  a  special  focus  on  mobile  application,  as 
well as enhancing customer satisfaction in order to provide 
the  most  comfortable  and  effective  payment  services  to 
the Georgian population and businesses. 

TBC  Capital  is  TBC  Bank’s  wholly  owned  investment 
banking  subsidiary  and  is  a  licensed  broker-dealer  in 
Georgia. It is an integral part of TBC Bank’s corporate and 
investment banking franchise. Its main lines of business 
include corporate advisory services, debt and equity capital 
markets,  brokerage  services  and  investment  research. 
TBC Capital is also a shareholder of the Georgian Stock 
Exchange and plays an active role in the development of its 
infrastructure and the integration of the domestic capital 
market into international markets.

The  launch  of  the  Government’s  pension  fund  at  the 
beginning  of  the  year  was  an  important  step  forward 
in  supporting  the  development  of  capital  markets  in 
Georgia. The pension fund’s active involvement in capital 
markets  should  especially  help  new  equity  issuances, 
which  are  still  hard  to  come  by,  while  bonds  issuances 
have  significantly  increased  in  recent  years.    As  of  31 
December of 2019, the pension fund accumulated around 
GEL 506.8 million or 1.0% of GDP. 

Another important achievement was popularizing the Tbilisi 
Inter Bank Rate (TIBR) by placing the first corporate bond2 
linked to TIBR, rather than on the National Bank of Georgia’s 
(NBG)  refinancing  rate.  This  initiative  further  strengthens 
Georgian  Capital  markets,  as  a  more  stable  benchmark 
gets  established  as  a  reference  rate,  more  accurately 
depicting current market conditions and providing a fairer 
pricing option than the monetary policy rate from NBG.

Furthermore,  TBC  Capital  actively  assisted  Silknet3 
and  JSC  TBC  Bank  to  dual-list  their  Eurobonds  on  the 
Georgian  Stock  Exchange  together  with  the  Irish  Stock 
Exchange.  This  supports  the  development  of  the  local 
exchange market, as local investors with no direct reach 
to  international  markets  can  invest  in  Eurobonds  issued 
by local companies (more information about Eurobonds is 
given in the corporate and investment banking section on 
pages 26 to 29).

In  2020,  our  main  focus  remains  to  support  the 
development  of  local  capital  markets,  as  well  as  to 
enhance our brokerage and research business units. We 
also see large potential in M&A transactions on the local 
market. There are a number of players in several sectors 
actively seeking consolidation opportunities, which we see 
as a good base to start educating the market. Apart from 
sector  champions,  we  anticipate  consolidation  moves 
to  be  made  by  medium  sized  companies  as  well,  which 
increases  the  player  base  substantially  and  gives  us  an 
opportunity to capture the rising market.

More information about TBC Capital can be found in the 
corporate and investment banking section on pages 26 to 29.

1  Based on internal estimates
2  This bond was issued by JSC Nikora, a leading meat products 

producer and retailer in Georgia

3  Silknet is a leading telecommunication service provider in Georgia

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

41

ECOSYSTEMS

In order to deepen our relationship with our customers and expand our range of digital touchpoints, we added a new strategic 
priority in 2019: to develop customer-focused ecosystems that are closely linked to our core financial products and services.

Our ambitions are to:

 ` Establish new standards of customer experience;
 ` Facilitate digital sales and engagement;
 ` Create new revenue streams; and
 ` Collect valuable customer data.

In this regard, we have already launched payments, housing and e-commerce ecosystems and are also actively developing 
an auto ecosystems.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

43

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DIVISIONAL OVERVIEW CONTINUED

PAYMENTS ECOSYSTEMS

As our customers conduct a broad range of payment transactions daily, we aspire to provide frictionless payment solutions 
for all their existing and anticipated needs. For this purpose, we have created a dedicated payments ecosystem with a holistic 
view of all payment solutions. Our payments ecosystem comprises traditional payment channels such as POS terminals, 
e-commerce and self-service terminals, as well innovative payment methods. We are number 1 in e-commerce and POS 
terminal transactions volume, with a market share of above 53%1 by the end of 2019. We are also among the world’s best 
in terms of the number of contactless payments, which stood around 86%2 of total card payments as of 31 December 2019.

Our aspiration is to become a regional payments provider, with annual growth rate in payments commission income of 20% 
and also to reduce cash payments in Georgia. This year we launched several innovative payment solutions including Apple 
Pay, TPay, which is the first QR Payment and online checkout system in the region3, ATM QR withdrawals and TBC Bracelets:

 ` In September 2019, we were among the first movers to launch Apple Pay, enabling our customers to conduct payments 
through Apple devices not only in Georgia, but also internationally. Apple Pay is easy to set up and users will continue to 
receive all the rewards and benefits offered through our credit and debit cards. Furthermore, we have a mobile wallet 
application for Android that allows customers to pay directly using near-field communication (NFC) technology. 

 ` TPay was launched in July 2019 and it gives opportunity to our micro clients to offer cashless payments to its customers in 
a convenient and cost-efficient way at the counter. TPay has a dedicated application with simple interface, which enables 
users to add any bank card. Moreover, TBC customers can conduct QR payments through their mobile bank application. 
In addition, while shopping online, customers no longer need to enter card details. Instead, they can check out with 
their TBC online banking account or just scan a QR code displayed on the checkout page with their TBC mobile banking 
application or TPay application. The new checkout process is twice as fast as the standard one and is also more secure. 
 ` By the end of the year, we also launched ATM withdrawals using QR codes and Apple Pay, enabling our customers to 

conduct cardless money withdrawals through their mobile banking application and Apple devices, respectively.

 ` In December 2019, we launched a new payments solution, TBC Bracelet, which can be added to any TBC debit account 
and allows our customers to make payments without cards or eWallets. The bracelet has an appealing visual, is eco-
friendly and water, freeze and heat resistant. 

In addition, to enhance our value proposition beyond banking and offer an improved customer experience in lifestyle offerings, 
we increased our share in our associated company TKT.ge to 55% from 26% in May 2019. TKT.ge is a leading online platform 
in Georgia that allows people to buy tickets for various events such as the cinema, the theatre or concerts as well as airplane 
and train tickets.

Our payments ecosystem also includes our Uzbek subsidiary, Payme, which is a leading payments platform in the country 
with around 1.8 million users. More information about this business is given on page 17.

We achieved outstanding results in our payments ecosystem over the course of 2019. The number of payments transactions4 
went up by 36.9% YoY and reached 236.4 million, while the volume of payment transactions amounted to GEL 11.8 bln, up by 
34.1% YoY.

1  Source: NBG
2  Data from Business Insider Intelligence was used for comparison purposes
3  The region in this context comprises Armenia, Azerbaijan and Georgia
4 

Includes both retail & business payments

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

45

DIVISIONAL OVERVIEW CONTINUED

HOUSING ECOSYSTEM

LIVO.GE

In January 2019, we acquired a 90% share of the real estate platform Allproperty.ge, a local real estate listing company, 
for US$ 225,000. We used this platform to launch Livo.ge, the first housing digital ecosystem in Georgia, which will bring 
together various real estate services into one, smooth holistic digital platform that creates value for all stakeholders.

Launched  in  May  2019,  Livo.ge  has  an  asset  light  business  model.  It  is  an  open  platform  that  partners  with  third  party 
providers for provision of various services. Our main focus is to generate effective leads for our customers based on accurate 
analysis of user data. 

Livo.ge boasts an enhanced user interface and offers a wide range of traditional and innovative services:

 ` Traditional services: personal profiles, advertisements and 3D tours & photographers. 
 ` Innovative services: mortgage loans, insurance, lead generation, the first real-estate valuation service in Georgia within 

24 hours, premier agent service for brokers and information about air pollution.

We  have  ambitious  plans  to  introduce  new  cutting-edges  solutions  in  the  coming  years  including  Live  auction  and  Livo 
artificial intelligence tools, which will empower our customers to make the most optimal decisions. 

TBC Bank invested around US$ 755,000 in the development of the company in 2019 and plans to invest an additional US$ 
700,000 in 2020. 

Our housing ecosystem gained popularity quickly and attracted 274,000 unique visitors by December 2019, while the number 
of listings amounted to 24,000.  As a result, Livo.ge’s estimated total digital traffic reached around 20% in housing market in 
Georgia, based on the number of visitors. In terms of financial results, Livo.ge’s revenue stood at GEL 2.5 million for the full 
year 2019 (out of which GEL 2.2 million was TBC’s contribution from real estate valuation)and the company plans to break 
even in the third quarter 2020. In terms of operational targets, our main priority for 2020 will be increasing the number of 
unique visitors and the number of listings. 

MYHOME.GE

In August 2019, for a consideration of GEL 19.45 million, TBC Bank acquired a 65% stake in LLC My.ge, the leading classified 
e-commerce  player  in  Georgia,  trading  under  the  My.ge  Group  (“My  Group”)  name.  My  Group  operates  in  three  online 
marketplace verticals: automotive & automotive spare parts, consumer-to-consumer goods and housing.   

Myhome.ge,  the  housing  digital  platform,  is  a  leading  classified  digital  platform  in  Georgia  for  real  estate  purchase  and 
renting  with  an  estimated  total  digital  traffic  of  35%  in  housing  market  in  Georgia,  based  on  the  number  of  visitors.  In 
December 2019, the number of unique visitors reached 360,000, while the number of listings stood at 140,000. In the current 
year, the company generated revenues of GEL 1.4 million, while its EBITDA amounted to GEL 0.4 million. Our strategy for 
2020 is to diversify service offerings and increase the company’s revenue streams. In addition, we plan to launch new market-
disrupting sub-platforms by leveraging the existing consumer base and digital traffic.

46
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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019
TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

48

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

E-COMMERCE ECOSYSTEMS

VENDOO.GE

In  August  2018,  we  acquired  Swoop,  a  well-known  Georgian  online  discount  and  sales  company,  for  a  consideration  of 
US$ 70,000, as the first step in developing an e-commerce market place in Georgia, through our innovative digital trading 
platform, Vendoo. 

We are developing Vendoo into an asset light platform that will be the key intermediary between buyers and sellers, modelled 
on industry peers such as Alibaba and Rakuten. 

The platform, www.vendoo.ge, was launched in May 2019 and allows customers to purchase various products online, access 
consumer finance and benefit from prompt delivery and a flexible refund policy. Local businesses will benefit from Vendoo’s 
large customer base and online marketing possibilities.

Vendoo is growing fast: by the end of 2019, it already had a diverse product offering comprised of electronics, personal care 
products, gardening & housing, toys, household chemicals, books & stationery and beverages. As of 31 December 2019, the 
company partnered with over 230 merchants and had around 27,000 stock keeping units (SKUs), while the number of unique 
visitors reached 337,000 in December 2019 and gross merchandise volume (GMV) amounted to GEL 2.9 million for the full 
year 2019. As a result, Vendoo’s estimated total digital traffic reached around 24% in comparable e-commerce in Georgia, 
based on the number of visitors. Our major priority for 2020 will be increasing the number of SKUs and the number of unique 
visitors as well as growing GMV. The introduction of the new merchant portal will also enable faster onboarding of SMEs on 
the platform, enabling them to scale up sales across the country. 

The e-commerce business has significant potential given that the e-commerce market in Georgia is underpenetrated and 
there are no big players on the market. In addition, a lot of Georgians shop online abroad, which also creates additional 
growth potential for the local market. The total addressable market was estimated to be around GEL 200 million1 in 2019, and 
we expect it to grow by around 30% in 2020. 

In addition to the initial investment of US$ 70,000 in 2018, TBC Bank invested around US$ 2.5 million in the development of 
the company in 2018-2019.

MYMARKET.GE & MYSHOP.GE2

Mymarket and Myshop are the number one classified players in C2C and B2C e-commerce in Georgia. Myshop is an online 
outlet  platform  offering  a  wide  range  of  products,  while  Mymarket  offers  both  new  and  secondary  products  as  well  as 
various household services. Together, both business lines have an estimated total digital traffic of around 80% in comparable 
e-commerce in Georgia, based on the number of visitors. In 2019, Mymarket completely renovated its platform with a more 
user-friendly design and new, personalized features, significantly enhancing the shopping experience.

In December 2019, the number of unique visitors reached 900,000, while the number of sellers stood at 45,000. In 2019, the 
company generated revenues of GEL 1.2 million, while its EBITDA amounted to GEL 0.3 million. 

Our strategy for 2020 is to integrate delivery and on-line payments services into the platform, which will enable us to provide 
end-to-end service to our customers. This will significantly enhance the user experience as it will allow us to act an escrow 
agent between sellers and buyers, ensuring timely delivery and product quality checks. This, in turn, will lead to an increase 
in on-platform transaction volume and is also expected to increase the overall market size, due to expanding cross-country 
delivery capabilities.  Furthermore, we plan to add consumer lending capabilities to the platform, which will also support the 
growth of gross merchandise volume. 

1  Based on internal estimates
2  The platforms of My Group

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019
TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

49
49

DIVISIONAL OVERVIEW CONTINUED

AUTOMOTIVE ECOSYSTEM 

MYAUTO.GE & MYPARTS.GE1 

My Group’s platforms, Myauto and Myparts, are the leading players in the automotive and spare parts markets in Georgia, 
with an estimated total digital traffic of 80% in each comparable sector in Georgia. 

These platforms offer the purchase and renting of second-hand cars as well as a wide assortment of auto parts. In December 
2019, the number of unique visitors to these platforms reached 1,550,000, while the number of listings stood at 400,000. In 
2019, the company generated revenues of GEL 2.5 million, while its EBITDA amounted to GEL 0.9 million. 

Our strategy for 2020 is to integrate auction, leasing and escrow services into the platform. Moreover, as a part of our revenue 
stream diversification strategy, we plan to expand promotion services for new car dealerships as well as start selling leads. 
Enriching the platform with various new services would help us to increase the platform’s attractiveness, which will in turn 
support the growth of transaction volume. In addition, there are various opportunities for launching new market-disrupting 
sub-platforms by leveraging the existing consumer base and digital traffic.

1  The platforms of My Group

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019
TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

LEADING E-COMMERCE 
COMPANY IN GEORGIA

www.my.ge

STAKEHOLDER ENGAGEMENT

STAKEHOLDER ENGAGEMENT

As  we  aim  to  create  value  for  all  our  stakeholders,  we  actively  engage  with 
them  in  order  to  incorporate  their  needs  and  expectations  into  our  strategy, 
purpose and values. 

As part of the Directors’ responsibilities to promote the success of the Company 
in accordance with section 172 of the Companies Act, the Board ensures that 
the Group engages with its stakeholders through many different channels to 
understand  their  needs  and  concerns,  build  trusted  relationships  and  make 
decisions  as  a  result  of  this  engagement  that  are  fair  and  balanced  for  all 
stakeholders.

OUR GOALS AND ASPIRATIONS

OUR ENGAGEMENT

Generate long-term sustainable value

STAKEHOLDER
GROUPS

Our
shareholders
and fixed
income
investors

The Group has an active investor relations programme, to enable shareholders to 
engage with the Company and the Board, not only on business issues but also to 
raise any governance concerns that they might have.

Investor meetings
The Chief Executive Officer, the Chief Financial Officer  and Director of International 
Media and Investor Relations maintain very close engagement with our major 
investors by:
 ` Communication at quarterly financial results calls;
 ` Participating in roadshows after every quarterly results announcement; 
 ` Regularly attending investor conferences across numerous geographic 

locations to promote the awareness and understanding of the Group’s business. 

During the last year, these key executives met with approximately 200 investors in 
the UK, Continental Europe, the US, Canada and the United Arab Emirates. 

TBC Capital Markets Day
All of the Bank’s senior executives are involved in hosting an annual capital markets 
day in London. They are also available for calls with key investors and face-to-face 
meetings with investors visiting Georgia.

Investor Relations website
The Group also has a dedicated investor relations website, which contains detailed 
information about the company. 

AGM
All shareholders are welcomed at the AGM where all directors are available to 
discuss any issues that they might raise. 

The Group’s business depends on continuously improving the customer experience, 
with tailored products and improving services which provide well-suited solutions 
and a superior customer experience for customers. Client feedback is regularly 
reviewed, and concerns are analysed in detail.

The Group ensures that its financial products are easily accessible to people living 
in remote areas through the Bank’s wide-network of self-service terminals and 
is also committed to support financial inclusion by developing various affordable 
offerings to micro businesses along with the  Georgian population who do not have 
bank accounts.

To better understand our customers’ requirements and develop well-suited 
solutions, we actively interact with them via various channels including:
 ` Communication via  branches, VIP service areas, the call center and digital 

channels;

 ` Regular customer satisfaction surveys by independent research companies;
 `

Active interaction via social media.

Our
customers

Make the life of our customers easier 

52

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

During 2019, the Board introduced a stakeholder impact analysis for all proposals brought to the Board and will consider an analysis 
in the annual strategy plan review. These actions assist the Directors in performing their duties under section 172 of the Companies 
Act 2006 and confirms to the Board that the impact of business plans on all stakeholders is being considered by management when 
developing initiatives for Board approval.

Throughout the year, senior management attend the Group’s board meetings to present key development and investment projects to 
the Board.  All presentations made to the Board consider both the benefit to shareholders of the proposal and the impact on other 
key stakeholders, including employees.  

One non-executive Director has been appointed to be responsible for staff engagement. It is intended that this role will be rotated 
periodically.

Our goal is to develop a strategy that is mutually beneficial to all our stakeholders and helps them achieve their aspirations. To 
measure our progress in this regard, we use a set of well-balanced performance measures that comprise both financial and non-
financial metrics and are closely linked to our executives’ remuneration. The Remuneration Committee considers remuneration and 
incentive plans across the whole business at each level.

The following table describes how our Directors have engaged with our key stakeholders during the year and the impact of this 
engagement when making key decisions as a Board. 

KEY TOPICS DISCUSSED 2019

OUR RESPONSE AND IMPACT ON BOARD DECISIONS 

 ` Marco-economic developments in the country, 

the political situation and the regional 
outlook, as well as the banking sector outlook 
and regulatory changes;

 ` New strategic objectives including the 

development of ecosystems and international 
expansion;

 ` Business performance and outlook;
 `

The existence of a proper ESG system within 
the Company; 

 ` Matters related to TBC’s founders, as 

described on page 106.

In our quarterly financial results presentation and report, we have substantially increased 
disclosure on our ecosystems.

We have also increased the coverage of our macro-economic research, which provides regular 
updates on recent macro developments in the country. 

In addition,  we have significantly enhanced our EMS systems, as described on pages 72-83.

With regards to the matters relating to our founders, we proactively approached key 
shareholders, analysts and other market participants to clarify the situation and answer 
any related questions.  We also focused on better communicating our corporate governance 
structure and its development over the last 10 years. 

Our dividend policy aims to pay out dividends based on a pay-out ratio of 25-35% of the total 
consolidated net profit each year.

Feedback from our customers reflected their 
wish to see  more personalised, digital and 
integrated solutions that are delivered in a fast 
and convenient way. 

Customers living in remote areas are also
looking for financial products that are easily 
accessible.

As a result of the feedback received from our customers, we are:
 ` Developing customer focused digital ecosystems, which provide a wide range of interrelated 

 `

 `

services and products to customers in the most simple and seamless way possible. 
Fine-tuning our internet and mobile banking applications with more intuitive and useful 
features. 
Actively developing our newly launched fully-digital Bank, Space for our digitally savvy 
customers. 

 ` Harnessing our big data analytics to develop ever more customized solutions for our 

customers. 
Further increasing our wide network of self-service terminals to remote areas.

 `

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

53

STAKEHOLDER ENGAGEMENT CONTINUED

STAKEHOLDER
GROUPS

OUR GOALS AND ASPIRATIONS

OUR ENGAGEMENT

Our
colleagues

Create the best working environment 
for our colleagues, in which people feel 
motivated, valued and safe

In order to better understand our employees’ needs, we use different online 
channels including the intranet, a Facebook group and informal meetings with 
members of top management to keep our colleagues up-to-date with the Group’s 
progress and strategy. Employees are also encouraged to share their views through 
internal forums. 

We also run an annual employee feedback survey in partnership with the leading 
international universities and research firms. The results are carefully analyzed by 
the Board and taken into consideration. In case a more detailed survey of employee 
opinion is needed, we form focus groups to understand the particular challenges of 
the department. 

Tsira Kemularia is the non-executive Director who has taken responsibility for 
engaging with employees across the Group, by meeting with key senior staff and at 
key staff briefing events. She reports back her meetings to the Board.

Our
community
and
environment

Support the community through a wide 
range of CSR activities and actively 
manage our environmental and social 
impact.

As the largest bank in Georgia, we feel a responsibility to our community and 
strive to support areas which are key for the country and its future through a wide 
range of CSR activities. We also strive to preserve Georgia’s cultural heritage and 
environment by conducting business in responsible and sustainable manner.

In order to better understand the social challenges in our community, we conduct 
regular surveys among the Georgian population and, based on the results, plan 
respective CSR activities. 

We also actively cooperate with different educational institutions to support talented 
young people in their professional development.

In terms of business development, we actively engage with entrepreneurs and 
business owners via our full-scale business support platform (www.tbcbusiness.ge).

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

KEY TOPICS DISCUSSED 2019

OUR RESPONSE AND IMPACT ON BOARD DECISIONS 

The key topic raised during the year was the 
need for better communication about the Group’s 
strategic priorities and initiatives, because as our 
Group continues to grow, employees can at times 
feel less connected to the Company. 

Many employees mentioned during informal 
meetings with management that, with the high 
pace of innovation and digitalization within the 
Group, a more informal environment with less 
bureaucracy and strict boundaries would be 
welcomed. 

In order to raise our colleagues’ awareness and understanding of the Group’s key strategic 
initiatives, we have developed special introductory programs in relation to two of our important 
ongoing initiatives: the company wide agile transformation and the data management  
principle. 

More information is given in our colleagues section on pages  60-67.

We also increased internal communication by involving the CEO to ensure employees feel as 
connected as possible to the Company. Every Friday, he meets with different departments 
informally and discusses the Group’s strategy and goals with them. In addition, top 
management also holds regular meetings with employees regarding strategic initiatives.   

This year, we started an agile transformation project within the Group. This is a huge 
transformation in the bank culture, which aims to simplify processes and reduce bureaucracy 
as well as boost employee commitment and creativity.

The key issues raised through our various 
interactions with our community are the lack 
of free educational resources for the young 
generation, especially in STEM fields, limited  
support for entrepreneurs and the shortage of 
jobs in the economy. 

In order to address the existing challenges in our community, we run several initiatives, 
including partnerships with different educational institutions as well as organizing wide-scale 
donation programmes, to support talented young people from vulnerable families. 

We also continue to actively enrich our business support platform with more useful business 
tools to support businesses to grow and prosper, which in turn will create new job openings. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

55

DOING BUSINESS RESPONSIBLY

We are dedicated to running our business in a responsible and 
sustainable manner and creating value for all our stakeholders.

OUR CUSTOMERS
We are committed to continuously improving our customers’ experience 
by offering tailored products and services in an accessible way coupled 
with superior customer service, as well as support the development of 
the business sector to foster job creation in the country.

RESPONSIBLE BANKING, DIGITAL 
ENGAGEMENT AND FINANCIAL INCLUSION
We  are  committed  to  providing  our  customers  with 
responsible  banking  products  and  services  that  are  well 
suited  to  their  needs,  simple  to  understand  and  have  a 
straightforward fee structure. In addition, in January 2019, 
The  National  Bank  of  Georgia  (the  NBG)  introduced  the 
responsible  lending  regulation,  which  further  supports 
appropriate  access  to  credit  for  customers  ensuring 
their long-term prosperity and growth. Furthermore, we 
actively  participate  in  NBG’s  larization  initiative,  which 
aims to reduce the FX risk associated with local currency 
volatility among the Georgian population by encouraging 
lending  in  the  local  currency.  In  2019,  we  issued  GEL 
669 million GEL-denominated mortgages and GEL 1,096  
million consumer loans, while the share of Lari loans in 
the total retail portfolio increased by 4.8 pp to 47.2%1  from 
December 2018, on a constant currency basis. 

As  we  strive  to  make  the  lives  of  our  customers  easier, 
we  operate  an  omni-channel  distribution  platform  with 
a  strong  focus  on  digital  channels,  which  enables  our 
customers  to  conduct  most  of  their  daily  transactions 
easily  and  remotely.  Our  award-winning  mobile  and 
Internet  banking  applications  remain  the  most  popular 
communication  channels,  accounting  for  42.0%  of  all 
transactions. The other widely used channel is self-service 
terminals, which are spread all over the country, including 
areas with no easy access to physical branches, making 
banking accessible for people living in remote districts. At 
the end of 2019, 17.0% of all transactions were conducted 
through these terminals. 

Furthermore,  in  order  to  deepen  the  relationship  with 
our customers and expand our value proposition beyond 
financial services, in 2019, we started the development of 
customer-centric digital ecosystems. In 2019 we launched 
payments,  housing  and  e-commerce  ecosystems  and 
are  also  actively  developing  an  auto  ecosystem.  These 
digital  platforms  will  enable  our  customers  to  receive 
a  wide  range  of  offerings  needed  on  daily  basis  in  the 
most  convenient  way,  as  well  as  empowering  them  to 

1  or 48.8% at 31.12.2018 exchange rates

56

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

do business such as renting or selling apartments, cars 
and  other  goods.  (Please  refer  to  pages  43-51  for  more 
information about our ecosystems). 

We  are  also  focused  on  developing  innovative  solutions 
that  aim  to  embrace  the  unbanked  Georgian  population 
and  micro  businesses.  In  this  regard,  this  year,  we  have 
introduced  several  new  products  in  the  MSME  segment, 
including:

 ` Approving  mini  loans  using  tablets,  which  enables 
micro  business  owners,  who  are  based  in  remote 
areas, to get loans approved on the spot, without going 
to branches; and

 ` The  TPay  application,  a  universal  payment  system 
enabling  cashless  transactions  in  micro  merchants, 
mainly  in  rural  areas,  where  currently  only  cash  is 
accepted.

In addition, we use our advanced data analytics capabilities 
in  order  to  develop  personalized,  affordable  offerings  to 
unbanked  individuals  considering  their  spending  habits 
and disposable income. 

CUSTOMER SATISFACTION
One  of  the  most  important  values  for  TBC  Bank,  as 
a  service  company,  is  customer  care,  well-being  and 
satisfaction.  We  regularly  request  feedback  from  our 
clients and use this information to analyse their needs and 
fine-tune  our  value  proposition  accordingly.  We  also  pay 
special attention to our customers’ concerns and have a 
dedicated  department  dealing  with  clients’  complaints. 
We react promptly to each case and work closely with a 
customer to understand his/ her problem.

We  regularly  measure  customer  satisfaction  levels 
based on various surveys conducted by independent third 
party  companies  and  maintain  the  highest  scores  in  the 
Georgian banking sector. We also hold the leading position 
among the whole retail industry in the country. 

In  order  to  reinforce  our  customer-centric  culture,  this 
year  we  conducted  a  bank-wide  survey  and  identified 
employees who demonstrated exceptional customer care. 
These employees were recognized as service leaders and 
were awarded with special gifts.

As the revenue of most MSMEs is generated in Georgian 
Lari,  we  strive  to  provide  them  with  accessible  financial 
resources  in  local  currency.  This  enables  our  clients  to 
decrease  their  exposure  to  foreign  exchange  risk  and 
ensures growth and prosperity in the long term. In 2019, 
52%  of all disbursements to MSMEs were denominated in 
the local currency.

In  addition,  we  attract  special  purpose  facilities  from 
different  international  financial  institutions  to  support 
young  entrepreneurs,  women-led  MSMEs,  businesses 
operating  in  rural  areas,  innovative  projects,  energy 
efficient and renewable energy products as well as foreign 
trade.  The  total  amount  disbursed  under  these  projects 
amounted to around GEL 569 million as of 31 December 
2019 . More information, about each facility could be found 
on our website under the press release section at  www.
tbcbankgroup.com.

Furthermore, we provide extensive non-financial support 
to MSMEs through our business support programme and 
assist business representatives with acquiring necessary 
competence,  finding  investors  and  partners,  developing 
their  activities  and  implementing  modern  technologies. 
More information about this programme can be found on 
pages 30-33 in the MSME section.

DOING BUSINESS RESPONSIBLY CONTINUED

CUSTOMER PRIVACY AND DATA SECURITY
We  are  committed  to  safeguarding  our  customers’ 
personal  information  and  are  constantly  working  on 
upgrading  our  control  systems  in  order  to  ensure  high-
level customer privacy and data security. We use advanced 
information security technologies to identify and prevent 
any  fraudulent  activities.  In  order  to  minimise  cyber 
security  risks  and  detect  cyber  threats  more  effectively, 
we constantly enhance our defence system with artificial 
intelligence measures and techniques.

We are conducting external audits and threat intelligence 
led  cyber-attack  readiness  exercises  on  a  regular  basis, 
which provides us with a practical view of our information 
and cyber security position. It also gives us a benchmark 
against  international  best  practices  and  helps  to  define 
readiness levels against real-world cyber threats. We are 
using it as one of the inputs in our continuous improvement 
cycle. The latest review was conducted in 2019 by Deloitte 
UK, which confirmed that our critical systems ensure high 
reliability against cyber threats.

We also ensure full transparency about what we do with 
the personal data of our customers, employees, suppliers 
and  business  partners,  and  only  process  it  for  specific 
business purposes. At any time, individuals can request 
to change, limit or delete the personal data that we hold 
about  them  by  contacting  us  via  email  at  compliance@
tbcbank.com.ge  or  by  post.  For  this  purpose,  we  have 
developed  a  Privacy  Policy,  which  is  in  line  with  the 
requirements of the applicable laws, including Georgian 
regulation  and  certain  relevant  requirements  of  EU 
General Data Protection Regulation (GDPR), and carefully 
monitor compliance with it. The full policy can be found 
on our IR website at www.tbcbankgroup.com

In  order  to  increase  awareness  and  help  our  clients  to 
protect  their  data,  we  send  periodic  warnings  to  them 
through  our  Internet  and  mobile  banking  applications 
regarding widespread cyber frauds and tips on how they 
should act in such cases.

We  also  conduct  regular  mandatory  trainings  on  cyber 
security and data privacy for all our employees to ensure that 
they are well aware of potential threats and remain alert.

SUPPORTING BUSINESSES DEVELOPMENT 
TBC  continues  to  be  an  important  provider  of  financial 
services to MSMEs, which is a key driver of the country’s 
economic  development.  In  2019,  we  provided  around 
GEL 2,549 million lending to our MSME clients, up 26.0% 
compared  to  2018.  The  main  sectors  financed  were 
agriculture and trade. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DOING BUSINESS RESPONSIBLY CONTINUED

Engaged and happy colleagues are key to our successful and 
sustainable development. By fostering a collaborative and 
supportive working environment, we strive to create an agile 
culture, in which each employee is empowered to take more 
responsibilities and develop his/her full potential.

OUR COLLEAGUES

AGILE TRANSFORMATION
2019 was a big organizational transformation year for TBC 
as  we  made  a  big  leap  towards  becoming  an  agile  and 
flexible organization in order to react quickly to the fast-
changing  market  environment  and  foster  an  innovative 
mindset among our employees. The agile reorganization 
process was successfully implemented in the retail, MSME 
and IT departments. The main purpose was to eliminate 
unnecessary  processes  and  bureaucracies  and  build  a 
more  dynamic,  adaptive  and  customer-centric  culture. 
The new structure stimulates creativity and innovation by 
encouraging  team  members  to  take  more  responsibility 
and  ensuring  that  everybody  is  focused  on  achieving 
a  shared  goal.  We  started  the  reorganization  process 
by  announcing  job  vacancies  internally  and  allowing 
our  employees  to  apply  for  the  positions  they  desire.  As 
a  result,  30%  of  those  employees  who  participated  in 
agile  transformation  process  applied  and  were  hired  for 
different positions, giving them opportunity to develop in a 
new field that is of more interest to them. 

An  agile  structure  allows  us  to  create  an  exceptional 
working  environment  for  our  employees  and  give  them 
more autonomy and room for creativity. For this purpose, 
we  announced  Friday  as  a  “working  outside  the  office 
day”  to  allow  our  employees  to  work  in  a  more  relaxed 
and  comfortable  atmosphere.  Also,  in  an  agile  culture, 
mistakes  are  welcomed  and  are  treated  as  part  of  the 
learning curve. 

As  feedback  and  coaching  is  an  essential  part  of  agile 
transformation, we conducted an intensive agile training 
for  our  employees  in  order  to  help  them  adapt  to  the 
new environment. In addition, we introduced 360-degree 
feedback,  which  provides  each  employee  with  the 
opportunity to receive balanced feedback from all parties 
and improve their professional performance and growth. 

The  first  results  of  the  agile  transformation  project  are 
rather  impressive.  FTE  productivity  has  increased  by 
10.0% in December 2019 compared to previous year, our 
organizational  agility  score1    has  improved  by  4.3%  and 
employee happiness2  increased by 16.0% over the same 
period.  

We  plan  to  roll-out  agile  transformation  across  other 
departments during 2020.  

ATTRACTING NEW TALENT
As people are our most valuable asset, we strive to attract 
the  best  talent  by  building  and  constantly  updating  the 
database of potential candidates. The selection process is 
comprised of several steps and is tailored to the specific 
needs  of  each  position.  Selected  candidates  are  offered 
attractive  employment  conditions,  which  include  a  fixed 
salary and a performance based bonus a well as a good 
benefits package. 

Since  2011,  we  have  also  run  a  wide-scale  internship 
programme for the best students from Georgia’s leading 
universities to give them an opportunity to gain experience 
and  expand  their  knowledge.  This  programme  has  been 
very  successful,  helping  us  to  identify  new  talents  who 
are  part  of  our  team  today.  This  year,  80  students  were 
selected  for  an  internship  and  47  were  employed  in 
various  departments  including  finance,  risks,  corporate, 
marketing, IT and data analytics. The biggest demand was 
for  IT  and  data  analytics  specialists,  given  our  strategic 
focus on digitalization and data analytics. 

In 2019, TBC established IT Academy, the learning center 
for  students  with  technical  backgrounds,  which  offers 
extensive  Front-end  and  Back-end  bootcamp  courses 
and  aims  to  train  the  young  generation  in  professions 
that are in high demand in today’s highly digitalized era. 
Bootcamp courses are conducted by foreign trainers who 
have worked with Microsoft, Oracle, SAP and other global 
technology companies. This programme is free of charge 
for students and is fully funded by TBC Bank. Out of the 
1,500 applications we received for this course, 117 students 
were  selected  for  the  course  and  25  were  employed  at 
TBC Bank. To promote informational technologies among 
young people, we also organize meetups and hackathons 
for them. 

This year we also introduced TBC Camp, a special learning 
programme  for  university  students  of  finance,  which 
aims  to  increase  students’  professional  knowledge  and 
awareness.  Within  this  programme,  this  year  we  held 
a  Stock  Pitch  Competition  (SPC)  for  fourth  year  finance 
students  in  leading  universities  in  Georgia.  The  project 

1  Based on internal survey, which measures the company’s ability to 

respond to the fast changing environment

2  Based on the internal survey

60

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

helps  us  to  identify  bright  talents  and  recruit  them  into 
the  corporate  investment  banking  department.  SPC  is  a 
unique project, which is integrated in the syllabus of the 
university  curriculum.  It  is  comprised  of  intensive  on-
site training and preparation of real investment cases in 
selected  companies,  which  are  presented  to  a  panel  of 
judges. As a result, students gain comprehensive practical 
experience  in  company  valuation  techniques  as  well  as 
improve their presentation skills. In the future, we plan to 
continue holding many other projects within TBC Camp.

LEARNING AND DEVELOPMENT 
Supporting the learning and development of our employees 
was  identified  as  one  of  our  key  priorities  this  year.  For 
this purpose, we developed several in-house educational 
programs  to  help  our  employees  gain  new  skills  and 
perspectives  that  are  closely  aligned  to  our  strategic 
objectives  and  are  needed  for  successful  performance 
of  their  duties  in  today’s  fast  changing  technological 
era.  The  courses  are  conducted  by  experienced  middle 
and  top  management  staff  members  as  well  as  leading 
professionals  from  the  respective  fields  and  are  offered 
free of charge.  

 ` Business  School  –  offers  a  tailored  course  for 
corporate,  finance  and  risk  professionals  which 
comprises  both  hard  skills  such  as  financial  and 
risk  modelling  and  soft  skills  including  effective 
communication and presentation skills. 

 ` Agile academy – offers a general course in agile and 
scrum methodology and aims to explain the benefits of 
an agile organizational structure with illustrative best 
practice examples. 

 ` Avalanche  academy  –  aims  to  increase  general 
awareness within the company about the importance 
of big data analytics by presenting implemented case 
studies. It also offers advanced training in data science 
and  engineering  for  newly  recruited  individuals  to 
work in the data analytics department.  

In  addition,  we  continue  to  run  TBC  Academy,  an  in-
house  educational  platform  that  was  established  back 
in  2011  and  offers  workshops  and  trainings  in  various 
fields  such  as  financial  institutions,  capital  markets, 
ethics  and  financial  fraud  management,  as  well  as  soft 
skills  including  leadership,  customer  service,  business 
communication, team building and others.  In total, during 
2019,  more  than  4,300  employees  attended  various  in-
house trainings mentioned above.

Moreover, we provide financial support for our employees 
to attend various external courses and gain international 
certifications such as CFA, FRM, ACCA, as well as attend 
various professional trainings in leadership, management, 
sales, customer service, finance and risks.  During 2019, 
more  than  1,500  employees  received  financial  support 
for  their  professional  development.  In  addition,  around 
80  mid-level  managers  received  trainings  in  soft  skills 
such  as  leadership,  people  management  and  effective 
communication during the course of the year. 

Since  2012,  we  have  also  offered  TBC  Scholarships  to 
our middle managers to co-finance their studies abroad 
at  the  world’s  leading  universities  as  well  as  at  top 
Georgian Universities. In 2019, 10 managers received this 
scholarship.

To  boost  employee  interest  and  motivation  regarding 
self-development,  we  have  also  organized  various 
masterclasses since 2017 for our colleagues all over the 
country, where leading Georgian professionals are invited 
to share their experience and knowledge. Since the launch, 
7,800 employees have attended these events.

This  year,  another  important  initiative  was  to  conduct 
an 
intensive,  custom-designed  strategic  session  for 
the  top  management  and  selected  members  of  middle 
management  at  Stanford  University  Graduate  School  of 
Business. The program was specifically designed around 
TBC’s  long-term  priorities  with  a  focus  on  ecosystems, 
agile  transformation  and  managing  people  and  aimed 
to  help  TBC’s  management  to  view  the  business  from  a 
variety of perspectives and generate new ideas. 

internal  championships 

EMPLOYEE MOTIVATION AND ENGAGEMENT
We  maintain  our  focus  on  increasing  our  employees’ 
motivation by organizing various social activities for them, 
including  internal  clubs,  championships  and  retreats. 
TBC club unites employees based on their interests and 
hobbies.  As  of  December  2019,  we  have  10  such  clubs, 
which  bring  together  more  than  2,000  employees.  We 
organize 
in  different  fields, 
including  the  intellectual  game  “What?  Where?  When?” 
and various sports events. Since 2014, our employees have 
also participated in the Wings for Life World Run, a running 
competition that raises funds for research to cure spinal 
cord injuries. We also offer a vast range of non-monetary 
awards  to  our  employees,  including  tickets  for  different 
events  and  special  discounts.  TBC  provides  branded 
back-to-school gift packages to the young children of our 
employees.  We  have  a  dedicated  online  brand  shop  for 
our  colleagues,  where  various  accessories  and  clothes 
are available. This year we also held a massive campaign 
across the bank related to the rugby world cup, in which 
the  Georgian  rugby  team  participated.  We  distributed 
rugby t-shirts and held online broadcast of rugby matches 
for our employees. 

Since our employees’ health is of the utmost importance 
to us, we have run TBC Fund since 2009. TBC Fund is a 
charity  fund  that  was  established  to  cover  the  medical 
expenses  of  our  employees  and  their  close  relatives  in 
case of severe diseases. 81% of our employees regularly 
donate up to 2% of their salaries and the fund has already 
helped more than 1,500 people since it was established. 

In order to accurately measure our employee satisfaction 
and engagement levels, we annually run a feedback survey 
in partnership with leading international universities and 
research  firms.  The  results  of  the  survey  are  presented 
to  the  management  board,  thoroughly  discussed  and 
relevant actions planned. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

61

STARTUP-LEAVE 
As  we  aim  to  promote  an  innovative  mindset  throughout  the  company,  this  year  we  launched  an  unparalleled  project  in 
Georgia, Startup-leave. This initiative gives an opportunity to our employees to start their own startup by taking six months 
paid leave to develop their business. In June 2019, TBC Bank organized its first Startup leave challenge for its employees. 
Applicants were asked to present original business ideas that would support the development of the Georgian market. 24 
teams participated in this competition and presented their ideas to the independent jury. In September 2019, three projects 
were selected: 

 ` Inventors.ge – is an online platform that receives orders from people to buy new and used auto parts and delivers them 

to their home address

 ` Ge Parts – aspires to create an online platform that will offer auto parts for sale from many small retailers
 ` Soko – aims to create an online platform for organizing different events. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

SOKO

The  founder  of  “Soko”  is  Tornike  Kachkachishvili,  a  digital  services 
expert at the business mobile bank department. The idea is to create a 
platform that will help people to organize different events in a simple and 
comfortable way by connecting them with relevant service providers. The 
platform will be open to all interested parties and will provide information 
about  the  details  and  availability  of  different  services  as  well  as  allow 
customer to rate the service providers, thus helping future customers to 
make more informed decisions. 

  “I  am  very  thankful  to  TBC  Bank  for  providing  me  with  this  unique 
opportunity.  It  has  been  my  dream  for  a  long  time  to  try  myself  as  an 
entrepreneur  and  now  I  have  time  to  fulfil  my  aspiration.”  commented 
Tornike Kachkachishvili, a winner. 

We  operate  a  deferred  share  bonus  scheme  for  our 
middle  managers  whereby  15%-25%  of  the  total  annual 
remuneration is paid in the form TBC PLC shares which are 
subject  to  a  three  year  continued  employment  condition 
and holding period: 33% and 33% are awarded on the first 
and second anniversaries respectively, and the remaining 
34% on the third anniversary. This scheme encourages a 
long-term commitment to the company and helps to align 
middle managers’ interests with those of the shareholders. 
In  2020,  100,931  shares  were  awarded  as  bonus  shares 
to middle managers. In addition, this year we introduced 
deferred  share  bonus  scheme  for  our  employees  who 
are part of the agile structure, whereby 10% of the total 
annual remuneration is paid in the form TBC PLC shares 
which  are  subject  to  three  year  continued  employment 
condition and holding period as mentioned above. In 2020, 
42,709  shares    were  awarded  as  bonus  shares  to  such 
employees.  (Detailed information regarding the directors’ 
remuneration  system  can  be  found  in  the  remuneration 
report on pages 151 to 179.)

EQUALITY AND DIVERSITY
We have created a sustainable and successful business in 
which all employees are treated equally and fairly and are 
supported and coached to succeed. We provide a safe work 
environment  free  from  any  kind  of  discrimination  and 
each and every employee is valued, respected and treated 
equally regardless  of gender, age,  marital status,  sexual 
orientation,  race,  ethnicity,  religious  and  political  beliefs 
or disability. We take special care of our colleagues with 
disabilities and strive to improve our workplace to make 
it more flexible for them. Furthermore, we support them 
to have the same access to learning, development and job 
opportunities.

We  remain  committed  to  having  a  gender-balanced 
workforce through a workplace environment and culture 
that  supports  and  empowers  women.  As  a  result,  65% 
of employees at TBC Bank are women while the share of 
women in senior roles is 35%. We plan to further improve 
the gender balance across managerial positions. 

DOING BUSINESS RESPONSIBLY CONTINUED

PERFORMANCE ASSESSMENT
AND REWARD
Our performance appraisal system is closely linked with 
the overall objectives of the Group and is based on three 
core  principles:  clarity,  fairness  and  integrity.  We  make 
sure  that  our  colleagues  have  a  clear  understanding 
of their role in the company and are actively engaged  in 
setting  their  personal  goals.  Employees  are  also  given 
appropriate  coaching  by  their  supervisors  to  help  them 
achieve  these  goals.  Regular  employee  feedback  and 
a  constructive  dialogue  are  an  important  part  of  our 
performance appraisal system.

We use different assessment systems for front and back 
office staff and it varies depending on the positions held. 
We  assess  our  back  office  staff  with  the  management-
by-objectives  (MBO)  system,  a  personnel  management 
technique where managers and employees work together 
to  set,  record  and  monitor  goals  for  the  financial  year. 
Goals  are  written  down  annually  and  are  continually 
monitored  by  managers  to  check  progress,  including 
semi-annual  direct  feedback  from  supervisors.  Rewards 
are based on the achievement of goals. We have a uniform 
scoring system for all employees within the MBO, which 
ensures fairness throughout the organisation. 

For  our  middle  managers,  as  well  as  employees  who 
are part of the agile structure, we also run a 360-degree 
feedback  system  that  provides  each  employee  with  the 
opportunity  to  receive  performance  feedback  from  his/
her  supervisor,  peers  and  subordinates.  The  360-degree 
feedback allows our employees to understand how their 
performance  is  viewed  by  others  and  it  helps  them  to 
better identify their strengths and weaknesses as well as 
to develop new skills.

For  front-office  employees  we  use  a  target-based 
performance  assessment  system,  wherein  performance 
is  linked  to  specific  KPIs,  including  quantitative  and 
qualitative components. Within the target-based system, 
employees  are  assessed  monthly,  quarterly  or  annually 
depending on their positions.

As  mentioned  above,  we  offer  competitive  remuneration 
packages  to  our  employees,  which  are  comprised  of 
fixed  salary,  performance  based  bonuses  and  a  benefits 
package,  which  includes  medical  insurance,  pension 
contributions,  paid  annual  and  sick  leave,  as  well  as 
six  months  of  fully  paid  maternity  and  paternity  leave. 
Additional  benefits  include  monetary  gifts  in  case  of 
marriage  and  childbirth  and  compensation  in  the  case 
of serious illness or death. Since 2013, we have also run 
a special club for large families, which aims to provide a 
one-time  gift  of  GEL  10,000  to  all  TBC  Bank  employees 
upon  the  birth  of  their  fourth  and  fifth  child  and  GEL 
50,000 upon the birth of their sixth child or more. Since the 
establishment of the club, we have granted more than GEL 
1 million to 56 employees. 

64

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Gender diversity statistics

BOARD OF DIRECTORS

SENIOR MANAGEMENT

9

0

7

6

2

2

Female

Male

Female

Male

7

7

6

1

1

1

2017

2018

2019

2017

2018

2019

MIDDLE MANAGEMENT*

ALL EMPLOYEES 

200

200

105

120

268

146

4,745

4,827

4,992

Female

Male

Female

Male

2,339

2,425

2,662

2017

2018

2019

2017

2018

2019

We also have a good mix of people comprised of employees with extensive working experience and young and bright talents 
with innovative and fresh ideas who have just graduated from top universities in Georgia and abroad. We believe that age 
diversity creates a more dynamic and high-performing team that leads to better results.

AGE DIVERSITY STATISTICS OF 2019

3%

9%

54%

under 29 years

30-39 years

40-49 years

over 50

34%

* Direct reports to senior management

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

65

DOING BUSINESS RESPONSIBLY CONTINUED

GENDER PAY GAP
We regularly review our pay levels and make sure that men 
and women are paid equally for doing the same type of job. 

As  shown  in  the  table  1  below,  the  average  gender  pay 
and bonus gaps are in favour of men. This is mainly due 
to the higher number of women being employed in junior 
roles, including customer service positions at front office, 
which is related to our business model (as shown in the 
gender  distribution  chart  below).  However,  the  gap  is 
positive  for  middle  management  positions,  whereby  we 
employ relatively lower proportion of women at higher pay 
quartiles based on their roles (please refer to table 2).

In 2019, the change in the median gender pay and bonus 
gaps of back office employees in favor of men is related 
to  the  high  number  of  employees  being  recruited  at  IT 
positions, who are predominantly men. 

We  remain  committed  to  achieving  a  better  gender 
balance and increasing the proportion of women working 
in senior roles.

GENDER DISTRIBUTION ACROSS DIFFERENT POSITIONS1 

71%

79%

65%

35%

29%

21%

56%

44%

Full Bank

Middle
Management

Front Office

Back Office

Female

Male

TABLE 1
Bank Full

mean gender pay gap in hourly pay
median gender pay gap in hourly pay
mean bonus gender pay gap
median bonus gender pay gap

2019

2018

44.4%
46.5%
56.6%
57.8%

48.9%
43.0%
53.7%
52.4%

TABLE 2
Middle Management

mean gender pay gap in hourly pay
median gender pay gap in hourly pay
mean bonus gender pay gap
median bonus gender pay gap

2019

2018

-7.3% -21.4%
-14.9% -13.4%
-40.0% -33.9%
-82.4% -104.2%

TABLE 3
Front Office Employees 

mean gender pay gap in hourly pay
median gender pay gap in hourly pay
mean bonus gender pay gap
median bonus gender pay gap

2019

2018

50.2%
52.5%
66.5%
71.5%

50.8%
54.4%
64.5%
65.5%

GENDER PAY AND BONUS GAP STATISTICS2
Gender pay gap is based on the data from April 1, 2019 to 
April 30, 2019.

Gender bonus gap is based on the data from April 6, 2018 
to April 5, 2019.

TABLE 4
Back Office Employees

mean gender pay gap in hourly pay
median gender pay gap in hourly pay
mean bonus gender pay gap
median bonus gender pay gap

2019

2018

29.6%
21.8%
-7.7%
19.7%
30.5%
20.2%
20.5% -11.3%

66

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Our  Anti-Bribery,  Anti-Corruption  and  Prevention  of 
the  Facilitation  of  Tax  Evasion  Policy  complies  with  all 
relevant  local  and  international  laws  and  regulations, 
and  applies  to  all  employees  of  the  Group.  The  policy 
provides  comprehensive  guidance  on  the  types  of 
behaviour that may give rise to violations of anti-bribery 
and  anti-corruption  laws  and/or  Criminal  Finance  Bill 
requirements,  and  reinforces  a  culture  of  honesty  and 
openness among employees.

To  ensure  employees’  protection  and  improve  working 
conditions,  we  have  a  Whistleblowing  Policy  in  place, 
available  to  all,  which  aims  to  identify  and  respond  to 
potential violations that may jeopardise employees’ work 
effectiveness. The policy encourages every staff member 
to report on any suspected violations in an open manner, 
without fear of retaliation. In addition, TBC Bank provides 
channels for anonymous whistleblowing (including hotline, 
email or letter) for anyone who believes that a violation of 
internal standards or legal requirements has taken place 
but is uncomfortable using the normal reporting lines. Our 
guidelines  seek  to  ensure  that  complaints  are  recorded 
and  that  employees  are  safeguarded  from  any  potential 
retaliation.  This  year  we  received  41  whistleblowing 
reports,  which  were  reported  to  the  Risk  Committee, 
which in turn reported to the Board. 

The Compliance Department regularly conducts employee 
training sessions in order to raise awareness and highlight 
importance  of  anti-corruption,  anti-bribery  and 
the 
ethical issues. Periodic audits are also conducted by the 
Internal  Audit  Department  to  identify  any  violations  or 
inappropriate behavior. No such material instances were 
identified during 2019.

We  are  constantly  improving  the  working  conditions  for 
our employees and strive to create a safe and comfortable 
environment.  In  October  2019,  TBC  Bank  hired  an 
independent  consulting  company  specialized  in  labour 
safety  issues.  The  company  will  help  us  to  significantly 
enhance  our  health  and  safety  policy  across  the  group 
and  implement  the  necessary  measures  to  improve 
working conditions. We also started conducting trainings 
for employees to raise their awareness about health and 
safety issues. 

ETHICAL STANDARDS, RESPONSIBLE 
CONDUCT AND SAFETY AT WORK
TBC  Bank  is  committed  to  running  a  business  that 
promotes  high  ethical  standards,  values  and  respect 
toward  human  rights,  as  well  as  by  encouraging  our 
employees to act with integrity and responsibility towards 
each other and other stakeholders. 

In  2019,  we  updated  a  set  of  internal  policies  and 
procedures and we closely monitor their execution:

 ` Code of Ethics 
 ` Code of Conduct 
 ` Anti-Bribery, Anti-Corruption and Prevention of the 

Facilitation of Tax Evasion Policy 

 ` Whistleblowing Policy

These policies apply to all employees of the Group and can 
be found on our IR website at www.tbcbankgroup.com. 

The Code of Ethics and Code of Conduct outline the ethical 
principles and standards of professional conduct expected 
from  all  employees  of  the  Group  and  set  appropriate 
relationship norms with colleagues, customers, partners 
and  others  stakeholders.  TBC  Bank’s  employees  are 
expected  to  act  with  professionalism  and  integrity  at 
all  times  and  to  comply  with  both  the  spirit  and  intent 
of  all  applicable  laws  and  regulations.  Employees  are 
also  required  to  treat  all  stakeholders  with  respect  and 
act  fairly  and  responsibly  towards  them.  In  dealing  with 
customers,  we  ensure  that  our  products  and  services 
are  tailored  to  their  needs,  straightforward  and  easy  to 
understand.  We  also  make  sure  that  clients  do  not  face 
unreasonable  post-sale  barriers  to  change  products, 
submit  a  claim  or  make  a  complaint.  With  regards  to 
suppliers and other business partners, the Group engages 
only  in  arm’s  length  transactions.  In  relation  to  our 
employees,  we  are  committed  to  fostering  a  supportive, 
safe and respectful working environment, which is free of 
any  form  of  harassment,  discrimination  (including  race, 
ancestry,  colour,  religion,  national  origin,  citizenship, 
marital  status,  veteran’s  status,  gender,  gender  identity, 
sexual  orientation,  age  or  disability)  or  inappropriate 
behavior. Environmental and social issues are also on top 
of our agenda in all our undertakings.

Compliance  with  the  Group’s  Code  of  Ethics  and  Code 
of  Conduct  is  closely  monitored  by  the  HR  Department 
and  Compliance  Department  on  a  regular  basis.  The 
Internal Audit Department also conducts periodic audits 
in order to identify any breach or misconduct in relation 
to compliance with these policies. No material breaches 
of the Group’s Code of Ethics and Code of Conduct were 
identified during 2019. 

1  The data in the given table is presented for the bank only
2  The data on gender pay gap is presented only for the bank, which 
accounts for the 82.0% of the total Group’s employees. Negative gap 
indicates a percentage pay gap in favor of women, while positive gap 
indicates a percentage pay gap in favor of men

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

67

DOING BUSINESS RESPONSIBLY CONTINUED

OUR COMMUNITY
We acknowledge our role and responsibility to Georgian society and 
are  actively  involved  in  developing  the  following  areas:  the  young 
generation, arts & culture and sport. 

YOUNG GENERATION
We remain committed to supporting young talents in their 
professional  development  and  continue  launching  new 
projects and initiatives in this regard.

ARTS & CULTURE
TBC  is  one  of  the  major  supporters  of  culture  and  art 
in  Georgia.  In  this  regard,  we  continue  to  promote  both 
cultural institutions and individual creative projects. 

Since 2016, TBC Bank has been the main partner of the 
Young Researchers and Innovators Competition Leonardo 
da Vinci, an annual event that aims to popularize science, 
technology,  engineering  and  math  (STEM)  among  the 
young  generation.  This  is  a  large-scale  event  which  is 
held  among  high-school  students  all  over  the  country. 
Participating teams are requested to present an innovative 
scientific idea that is supported by comprehensive research 
and  experiments.  This  year  was  highly  competitive  as 
45 students participated in the competition. The winning 
team  received  a  one-year  scholarship  from  TBC  Status, 
our affluent retail segment, to implement their project. 

In  2018,  in  partnership  with  the  Millennium  Innovation 
Award,  TBC  held  a  nationwide  challenge  that  aimed 
to  promote  innovations  in  STEM  fields  among  youth 
throughout  Georgia.  In  2019,  TBC  provided  financial 
support  to  send  the  winning  team  to  the  Space  Center 
University at the NASA Space Center in Houston, USA. 

TBC Bank is also supporting children’s festivals that unite 
diverse  educational  and  entertainment  activities.  This 
year, we partnered with Tbilisi International Book Festival, 
which  exhibits  and  sells  a  large  variety  of  Georgian  and 
international  literature.  This  book  fair  is  a  large-scale 
event  and  is  visited  by  many  people  from  large  cities  as 
well as Georgian regions. 

In  addition,  since  2017,  we  have  run  an  online  charity 
platform,  www.statusdonates.ge,  that  strives  to  support 
young talents and promote success. The platform features 
different  stories  of  people  in  need  or  specific  projects. 
Short movies are made on each story and uploaded to the 
platform. Since the launch, the programme has financed 
45 projects in the amount of GEL 170,000 and has improved 
the lives of over 90 people.

At  the  end  of  2018,  we  also  introduced  a  new  project 
called  “TBC  scholarship”,  which  aims  to  support  young, 
talented people from vulnerable families, in different fields 
including sport, science and arts. Since the launch, more 
than  200  Georgian  young,  talented  people  have  received 
annual scholarships in order to develop their knowledge 
and skills and become successful professionals.

Our stellar project this year was the celebration of David 
Kakabadze’s  130th  anniversary  in  partnership  with  the 
David  Kakabadze  Foundation.  David  Kakabadze  was  a 
prominent  Georgian  painter,  scientist,  inventor  and  one 
of the founders of Georgian modernism. The anniversary 
was celebrated with a multi-stage project:

 ` Gallery that united paintings, notes and sketches from 
state arts institutions as well as from the artist’s family 
and private collections;

 ` TBC  Art  Gallery  hosted  a  multimedia  project  called 
GAMMA. As part of the project, three young Georgian 
artists  created  audiovisual  spatial 
installations 
in  digital  media  based  on  inspirations  from  David 
Kakabadze’s concepts;

 ` We  published  the  anniversary  edition  of  the  David 
Kakabadze  catalogue,  which  fully  reflects  the  range 
and scale of the artist’s research and methods;    
 ` TBC  Bank  supported  the  establishment  of  David 
Kakabadze’s  archive,  which  comprises  the  artist’s 
paintings and historical documents;

 ` We  supported  digitalization  of  the  artist’s  works  in 
different museums and theaters all over the country in 
order to facilitate open and modern access to Georgian 
heritage;

 ` This year, we also launched BAZA, an interdisciplinary 
educational platform that tends to promote knowledge 
sharing  in  the  fields  of  contemporary  art,  science 
and  research.  BAZA  connects  young  artists  and 
professionals, as well as people interested in science, 
art and culture. The first symposium was dedicated to 
David Kakabadze’s 130th anniversary. 

In 2019, TBC became a partner of the National Museum 
of Georgia and will support the opening of a new modern 
museum in Vani, which is an ancient town in Georgia. The 
new  museum  will  present  various  artefacts  that  were 
found at antique archeological sites. 

Another 
important  event  was  organizing  a  photo 
exhibition of Guram Tsibakhashvili, the famous Georgian 
photographer.  The  exhibition  depicted  Georgian  history 
of the 1990s and aimed to raise public awareness of this 
post-soviet period.

68

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

In terms of our long-term projects, we continue to support Georgian literature and the Georgian alphabet:

 ` Saba is the leading literary award in Georgia, which we established back in 2003. Since its inception, Saba has awarded 
more than 160 prizes in different categories for a total amount of over GEL 750,000. We also run www.saba.com.ge, the 
largest online platform for Georgian electronic and audio books. This website provides access to 6,000 electronic books 
and has attracted c. 190,000 readers, both in Georgia and abroad. This year Saba held its seventeenth awards ceremony;
 ` To popularize the Georgian language and to integrate the Georgian alphabet into the digital world, in 2016 we launched 
#WriteinGeorgian. As part of this project, we collaborated with Microsoft in 2017 to create www.kartulad.ge, the first 
Georgian-language platform that aims to integrate the Georgian language into Microsoft’s programmes and software 
such as Skype, Office, and others. The platform encourages the Georgian population to engage with the website and 
translate  sentences  taken  out  of  Georgian  literature.  In  2019,  under  this  project,  we  held  the  second  competition  in 
Georgian  fonts,  which  aims  to  popularize  and  develop  the  Georgian  alphabet.  As  many  as  200  works  by  Georgian 
calligraphers  participated  in  the  competition,  out  of  which  the  16  best  fonts  were  selected  to  be  digitalized  and  will 
become available to public.

SPORT
TBC has been the general sponsor of Georgian Rugby Union since 2015. As the country’s national game, rugby is close to the 
heart of Georgians and promotes Georgia’s image on the international stage. We are proud to contribute to the development 
of rugby in Georgia and are committed to supporting our national rugby team. Within our partnership with Georgian Rugby 
Union, we strive to raise public awareness of rugby and conduct various campaigns including issuing special rugby cards for 
our customers and sponsoring the “Win a Trip to Japan” campaign. We also support young talents in rugby and in 2019, for 
the first time, we organized a rugby camp for 27 young rugby players with outstanding skills.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

69

DAVID KAKABADZE

David Kakabadze’s Project 
was awarded the Cross-Sector 
Partnership Award from Meliora, 
Georgia’s Responsible Business 
Awards 2019

70

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DOING BUSINESS RESPONSIBLY CONTINUED

OUR ENVIRONMENTAL
AND SOCIAL MANAGEMENT

We are strongly committed to conducting our business in a responsible 
and  sustainable  way  and  take  active  measures  to  manage  the 
environmental and social risks associated with our direct and indirect 
activities. This approach enables us to reduce our ecological footprint 
by using resources efficiently and promoting environmentally friendly 
measures to mitigate climate change.

Our  Environmental  Policy  governs  our  Environmental 
Management  System  (EMS)  within  the  group  and 
ensures  that  we  comply  with  applicable  environmental, 
health and safety and labour regulations and use sound 
environmental,  health  and  safety,  and  labour  practices, 
as well as take reasonable steps to make sure that our 
customers  also  fulfill  their  environmental  and  social 
responsibilities.  Our  Environmental  Policy 
fully 
compliant  with  Georgian  environmental  legislation  and 
follows  international  best  practices  (the  full  policy  is 
available at www.tbcbankgroup.com). 

is 

The Environmental Policy: 

 ` Defines the environmental aspects and impacts of our 

business activity;

 ` Elaborates  and  develops  measures  to  minimize  our 

negative impact on the environment;

 ` Takes 

and 
efficiency 
management into account;

responsible 

resource 

 ` Ensures  our  compliance  with 

the  applicable 

environmental, health, safety and labour regulations;

 ` Raises awareness among our staff;
 ` Prevents  the  Bank  from  financing  businesses  that 
have a negative effect on the environment and society;

 ` Promotes sustainability finance among our clients

TBC  Bank  has  a  dedicated  Environmental  and  Social 
Risk  Management  (ESRM)  team,  which  is  comprised  of 
full-time  employees.  Our  ESRM  team  is  responsible  for 
overseeing the implementation and operation of our EMS 
and for reporting environmental management plans and 
results  to  the  Environmental  Committee  on  a  quarterly 
basis.  Our  ESRM  team  is  part  of  SME  and  Corporate 
Business Credit Risk Department, which reports directly 
to the Chief Risk Officer.

Our EMS is based on four directions/pillars:

 ` Internal environmental measures;
 ` Environmental and social risk management in lending;
 ` Sustainable finance;
 ` External communication.

Pillar I - Internal Environmental Measures:
Since  banking 
is  not  a  high-polluting  activity,  the 
implementation of an internal environmental management 
system to address the Group’s resource consumption is not 
expected to have a significant impact on the surrounding 
environment. However, TBC Bank has reviewed all of the 
operational  activities,  procured  items,  and  outsourced 
services  that  it  can  control  (present  and  planned),  and 
has  identified  all  of  the  material  environmental  aspects 
relevant to the business. These are sub-categorised into 
indirect and direct environmental aspects, analyzed based 
on a comprehensive scorecard, and managed accordingly.  

As  a  premium-listed  company  trading  on  the  LSE, 
TBC  Bank  is  required  to  calculate  and  report  upon  the 
greenhouse gas (GHG) emissions stemming from its direct 
operations. For this purpose, TBC Bank has established a 
comprehensive internal environmental system to manage 
its  GHG  emissions  within  the  Group  and  is  committed 
to  reducing  its  GHG  emissions  by  closely  monitoring  its 
consumption of energy, water and paper. A guideline for 
the documentation of environmental data was elaborated 
and  responsible  staff  members  were  assigned  for  data 
collection,  including  defined  frequency  and  indicators. 
TBC  Bank  also  commissioned  an  independent  Health, 
Safety,  Environment  (HSE)  consulting  company,  G&L 
Management LTD, to verify the measurements of its GHG 
emissions.

72

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

                                                                                                                                              Total CO2 Emissions (tonnes)

             KPIs

Data for the FY 

Scope 1*
Fuel Combustion  (heating, vehicles,generators)

Scope 2
(Electricity consumption)

Scope 3
(International flights)

Total emissions (tCO2) 

Total emission per full time employee (CO2t/pp) 

Water consumption per employee (m3/pp)

Printing paper  per person in reams

2017

2,409

2018

2019

2,584

3,164

1,375

1,391

1,260

366

4,150

0.60

12.36

23.52

644

697

4,619

0.65

13.49

11.20

5,121

0.69

11.90

11.11

2020

-7%

-4%

-

-5%

-5%

-6%

-3%

*Scope 1: 
a) 1,443 CO2e emissions in tonnes (from combustion of fuel (NG) from owned operation and facilities of TBC Bank) in 2019 compared to 1,483 CO2e in 2018 and 
1,538 CO2e in 2017. 
b) 1,631 CO2e emissions in tonnes (from owned vehicles of TBC Bank) in 2019 compared to 1,013 CO2e in 2018 and 763 CO2e in 2017. 
c) 90 CO2e emissions in tonnes (from owned generators of TBC Bank) in 2019 compared to 88 CO2e in 2018 and 108 CO2e in 2017. 

In 2019, total GHG emissions increased by 11% mainly due to higher consumption of fuel from TBC owned vehicles. This was 
mainly related to our subsidiary, TBC Pay, which added 130 vehicles driven by increased network of self-service terminals. 

Total water consumption of TBC PLC was decreased by 12%, mainly due to prevention of leakages which occurred on different 
premises.  

In 2020, we aim to reduce total emissions by 5% by implementing the following measures: raising staff awareness towards 
electricity  and  gas  consumption,  closely  monitoring  central  heating  systems  as  well  as  increasing  the  share  of  electric 
vehicles in total distance traveled. As for water consumption, we are planning to install more water pressure regulators on 
selected premises, which will enable us to prevent water leakages. 

Calculation methodology
For GHG inventory the following step has been set: organization boundaries, operational boundaries, gathering data and 
calculation of carbon dioxide (CO2) equivalent. This report describes all emission sources required under the Companies Act 
2006 (Strategic Report and Directors’ Reports) Regulations 2013 (Scope 1 and 2) and additionally the emissions under Scope 
3 that are applicable to the business. In preparing the emissions data, the emissions factors from the UK Government’s 
Greenhouse Gas Conversion Factors for Company Reporting 2017 and National IPCC emission factors for electricity (tCO2*/ 
MWhe) was used. The required data was collected and report developed for the boundaries of TBC PLC’s main activities as 
follows: 

Scope 1  (combustion  of  fuel  and  operation  of  facilities)  includes  emissions  from  combustion  of  natural  gas,  diesel  and/ 
or  petrol  in  equipments  at  owned  and  controlled  sites.  Combustion  of  petrol,  diesel  fuel,  natural  gas  and  etc.  in  owned 
transportation devices;

Scope  2  (purchased  electricity  for  own  use  (lighting,  office  appliances,  cooling  &  etc.)  includes  emissions  from:  Used 
electricity at owned and controlled sites; to calculate the emissions, it has been used the conversion factor for National IPCC 
emission factors for electricity (tCO2*/MWhe); 

Scope 3 includes emissions from air business travels (a short haul, a medium haul, a long haul and an international haul); 
it should be noted that information on the travel class was considered and an “economy class” conversion factor has been 
used for the emissions calculation from the following link: www.atmosfair.de/en/offset/flight

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

73

Pillar II - Environmental and
Social Risk Management in lending
For  all  commercial  transaction,  TBC  Bank  endeavours 
to  ensure  that  customers  demonstrate  an  organized 
and  systematic  approach  to  environmental  and  social 
risk  management  and  comply  with  local  and  national 
environmental, health and safety, and labour regulations 
and standards.

For this purpose, TBC Bank has developed Environmental 
and  Social  Risk  Management  (ESRM)  Procedures  to 
ensure  that  appropriate,  risk-based,  sector  specific, 
environmental  and  social  risk  assessment  is  applied  to 
its  commercial  lending  activities.  These  procedures  are 
fully integrated into the credit risk management process 
in  TBC  Bank  and  are  applied  to  all  commercial  lending. 
The procedures incorporate appropriate consideration of 
IFC’s Performance Standards (PSs), EBRD’s Performance 
Requirements (PRs) and ADB’s Safeguard Requirements 
(SRs).

These procedures include:

 ` transaction qualification and the risk categorization;
 ` identification and appropriate assessment;
 ` mitigation and control; and
 ` monitoring and reporting of environmental and social risks.

By assessing and monitoring the environmental and social 
impacts  as  part  of  the  credit  risk  analysis  of  business 
clients,  incentivizing  the  use  of  environmental  best 
practices in their businesses and engaging in sustainability 
financing,  TBC  Bank  strives  to  mitigate  the  negative 
environmental impact of the financed businesses. 

DOING BUSINESS RESPONSIBLY CONTINUED

In order to ensure full compliance with local environmental 
regulation,  TBC  Bank  conducts  internally  environmental 
legal  check  on  annual  basis.  Our  environmental  legal 
register details the specific legal and other requirements 
applicable to TBC Bank, and shows how the requirements 
apply  to  TBC  Bank’s  environmental  aspects.  The  last 
updates of the environmental legal check was conducted 
in September, 2019.

Additionally, the following documents were enhanced and 
approved during the year:

 ` Green   Procurement  Recommendations – the document 
defines  the  general  procurement  recommendations 
within the company and also highlights product groups 
where  environmentally  friendly  or  energy  efficient 
goods have to be given priority over the normal goods. 
Environmental  clause  was  added  in  the  procurement 
agreement which defines requirement of the compliance 
with local health, safety and environmental standards. 
As a part of the supply chain development project, the 
check-list of environmental and social risk assessment 
for long term suppliers was created and the evaluation 
of suppliers against this checklist was conducted on a 
regular basis. In 2019, several spot-checks were held 
to determine appropriate corrective action plans. This 
process will continue during 2020. 

 ` Waste  Management  Guideline  –  this  document 
describes  the  categories  of  waste  that  are  separated 
and  managed  by  TBC  Bank,  the  guidelines  for  waste 
categorization,  as  well  as  frequency  and  method  of 
collection. In 2019, as a part of the waste management 
pilot  project,  we  equipped  our  head-office  buildings 
with waste separation bins. Moreover, a memorandum 
was  signed  with  a  specialized  service  provider  to 
deliver  separated  waste  to  recycling  companies.  The 
shredded  paper  is  then  delivered  to  a  company  that 
produces books that are later delivered to libraries in 
the  mountainous  regions  of  Georgia.  Glass/cans  are 
taken to re-processing plants, while plastic is shredded 
for  the  export  abroad  for  further  recycling  and  the 
production of granules. Currently, we are working with a 
service provider to add special e-waste bins at our head 
office  premises.  The  waste  management  projects  will 
be expanded to our branches next year. 

The bank also operates a green car fleet. Around 70% of  the 
bank’s vehicles are hybrid and electronic cars, leading to an 
approximately 30% reduction in the monthly use of fuel. Within 
the  project’s  scope,  electric  chargers  have  been  installed  in 
14 locations in Tbilisi and the regions, which can be used by 
TBC employees and clients as well as the public. In future, it is 
planned to increase the number of electronic chargers.  

Furthermore, 
in  order  to  raise  staff  awareness  of 
environmental  issues,  we  conduct  annual  seminars  and 
provide regular updates on our environmental activities to 
our colleagues. In 2019, all bank employees conducted the 
mandatory online EMS e-learning course and successfully 
completed the self-evaluation test.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Business loans

E&S RISK CATEGORIES BY LOAN VOLUME
AS OF 31 DECEMBER 2019

E&S RISK CATEGORIES BY NUMBER OF LOANS 
AS OF 31 DECEMBER 2019

7%

10%

1%

16%

58%

60%

25%

Low

High

Medium

A Category

23%

Low Risk - transactions with minimal or no adverse social or environmental 
impacts,  which  are  not  generally  subject  to  further  assessment  (beyond 
their  identification  as  such)  except  for  the  requirement  for  customer’s 
[assent/certification/disclosure]  of  compliance/non-compliance  with 
local and national environmental, health and safety and labour laws and 
regulations. 

Medium  Risk  –  transactions  with  limited  potential  for  adverse  social  or 
environmental  impacts  that  are  few  in  number,  generally  site-specific, 
largely reversible, clearly evident at the time of the assessment, and readily 
addressed through mitigation measures, which typically require a limited 
or  focused  environmental  and/or  social  assessment,  or  straight-forward 
application of environmental sitting, pollution standards, design criteria, or 
construction standards. 

High Risk – transactions with potential highly significant, negative and/or 
long-term  environmental  and/or  social  impacts,  the  magnitude  of  which 
may be difficult to determine at the loan application stage, which typically 
require  analysis  of  environmental  and  social  risks  and  impacts  in  the 
context of the total area of influence of the customer’s operations. As part 
of the risk assessment, the client will identify individuals and groups that 
may be differentially or disproportionately affected by its operations.

Category  A  -  with  potential  significant  adverse  social(2)  or  environmental 
impacts  which  may  be  diverse,  irreversible  or  unprecedented.  The 
assessment  of  which  usually  requires  the  inputs  of  independent  external 
experts, and may require the involvement of IFI E&S specialists in the due 
diligence assessment process.

To successfully implement ESRM procedures, TBC Bank 
conducts  regular  training  of  relevant  credit  officers  in 
collaboration with International Financial Institutions (IFIs) 
and  relies  on  the  use  of  a  variety  of  publically  available 
environmental  and  social  risk  management 
tools, 
including,  but  not  limited  to:  local  regulations;  EBRD’s 
Environmental  and  Social  Risk  Management  Manual 
(e-Manual  v4.0);  a  website  supported  by  IFC  https://
firstforsustainability.org/;  FMO’s  sectoral  guidelines  for 
environmental and social risk (further E&S) assessment; 

and  ADB’s  ESMS  Template  for  Banks  and  Funds,  which 
are  unified  in  sector  specific  Environmental  Social  Due 
Diligence  (ESDD) forms developed by TBC Bank. 

The  latest  update  of  ESRM  procedures  in  collaboration 
with our partner IFIs was conducted in the first quarter of 
2019. The following amendments were implemented: 

 ` business  sector  categorization 

(sector/industry/
sub-industry)  was  synchronized  with  IFIs’  E&S  risk 
categorization list;

 ` a  summary  of  IFIs’  sector  specific  guidance  notes  and 
local legal requirements were integrated in the respective 
ESDD forms;

 ` E&S risk categorization and reporting was integrated 
in the software, including a random selection function 
for the quarterly E&S monitoring of disbursed loans; 
 ` a list of legal requirements (licenses and permits) by 

sectors was created. 

The  automation  of  the  E&S  risk  assessment  process 
provides more flexibility for staff and limits their manual 
work, which in turn reduces errors and mistakes during 
the risk classification and selection process. 

to  communicate 

In  order 
the  above-mentioned 
amendments  to  employees,  12  extensive  E&S  training 
sessions  were  held  and  96  employees  were  trained, 
including SME Credit Officers, Credit Analyst, Credit Risk 
Managers and Business SME Lending/Sales Coordinators. 
Furthermore,  our  ESRM  team  members  successfully 
passed IFC’s sustainability training and e-learning program 
(STEP) online courses and were awarded certificates. 

As part of the supply chain development project, TBC Bank 
conducted several activities in partnership with its lenders 
and IFIs, in order to raise public awareness of ESG issues:

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

75

DOING BUSINESS RESPONSIBLY CONTINUED

 ` On 27-28 June 2019, TBC and FMO held a two-day International E&S Masterclass in Tbilisi, which was conducted for the 
first time in the Caucasus Region. The event was attended by E&S risk staff from local commercial institutions in Georgia 
as well as by bank representatives from Azerbaijan, Armenia and Uzbekistan. TBC and FMO presented existing E&S risk 
management  standards  and  best  practices,  conducted  interactive  discussions  on  case-studies  and  held  group-work 
exercises, including site-visits and field trips;

 ` “Doing Makes the Difference” – FMO and TBC delivered a public lecture on E&S risk management issues to students at 

ISET - International School of Economics;

 ` TBC and GCPF held a two-day training workshop on financing the Energy Sector (Renewable Energy Project)  on 25-26 
July, 2019. Christian Erich Grutte, an international energy expert, provided seminars about renewable projects finance 
to our clients. 

Pillar III - Sustainable finance
TBC  Bank  is  committed  to  sustainable  lending  development  within  the  company  and  is  actively  involved  in  developing  a 
standardized approach to sustainable finance, including energy efficiency, renewable energy and resource efficiency financing 
for individuals and business clients. For this purpose, we cooperate with Green for Growth Fund (GGF) to conduct local market 
research  and  set  benchmark  for  green  finance  to  streamline  and  considerably  enhance  existing  green  lending  operations 
within the company through the establishment of dedicated green lending guidelines. In addition, we are building in-house 
expertise, and our head of the ESRM team has successfully completed Renewable Academy online course in Green Finance 
Expert certification, which was provided with GGF TA support. In addition, our ESRM and Debt Capital Market team members 
participated in IFC’s Green Bonds and Sustainable Finance Executive Program. 

THE BANK’S BREAKOWN OF SUSTAINABLE LOAN PORTFOLIO IN MILLON US$  

214,5

182,7

130,5

Renewable energy

Youth support

Women in business

Energy efficient mortgages

Energy efficient auto

Energy efficient  processing

2017

2018

2019

Note: Our sustainable finance portfolio includes loans financed by special purpose funds received from IFIs except for the renewable energy, which includes all 
hydro power plants finance by the bank.

Pillar IV - External Communications
Transparency and open communication are an essential part of our daily activities. The feedback and recommendations 
received from our stakeholders and other interested parties enable us to continuously improve our performance. In doing so, 
we have developed a grievance mechanism to enable interested parties to provide their complaints in regards to E&S issues. 
Records of all communication are stored, including responses according the TBC Bank’s Procedure for addressing external 
E&S queries and concerns. Interested parties may submit their query on the webpage: http://www.tbcbank.ge/web/en/web/
guest/e-s or to the following e-mail address: E&Srisk@tbcbank.com.ge. During 2019, no such complaints were received with 
regards to environmental and social issues.

TBC Bank also takes active part in supporting the development of environmental and social regulation in the country. Our 
ESRM team is a member of the regular environmental committees organized by the American Chamber of Commerce in 
Georgia, the Business Association of Georgia (BAG) and the Business and Economic Centre. 

In 2019, our ESRM team also took part in a workshop that was jointly organized by the Ministry of Economy and Sustainable 
Development of Georgia and the German Society for International Cooperation (Deutsche Gesellschaft für Internationale  
Zusammenarbeit (GIZ) GmbH), which aims to support the development of national climate resilient economic strategies and 
the introduction of respective macroeconomic modelling tools, to achieve effective adaptation plans in Georgia. 

Outlook
In order to ensure the credibility of our Environmental Management System, we have launched a preparatory project to 
obtain certification according to ISO14001:2015 standards, which is expected in 2020.

76

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

RATINGS

MSCI ESG RATING

In 2019, TBC Bank Group received a rating of A (on a scale of AAA-CCC) in the 
MSCI ESG Rating assessment. 

MSCI
ESG RATINGS

A

CCC    B    BB    BBB    A    AA    AAA

DISCLAIMER STATEMENT 

The use by TBC of any MSCI ESG research LLC or its affiliates (“MSCI”) 
data,  and  the  use  of  MSCI  logos,  trademarks,  service  marks  or  index 
names  herein,  do  not  constitute  a  sponsorship,  endorsement, 
recommendation, or promotion of TBC BY MSCI.  MSCI services and data 
are the property of MSCI or its information providers, and are provided 
‘as-is’ and without warranty.  MSCI names and logos are trademarks or 
service marks of MSCI. 

SUSTAINALYTICS ESG RATING

TBC Bank Group PLC holds 20.6 ESG rating as of 17 December 2019

20.6 MEDIUM RISK

`

NEGLIGIBLE 

0-10

LOW

10-20

MEDIUM

20-30

HIGH

30-40

SEVERE

40+

RELATIVE PERFORMANCE

Banks (Industry Group)
Regional Banks (Subindustry)

Rank
(1st = lowest risk)
83 out of 934
11 out of 386

Percentile
(1st = lowest risk)
10th
4th

ISS ESG SCORE

As of 1st February 2020, TBC Bank Group attained the following scores for
2

Governance
Environment
Social

3

2

Lower Governance Risk = 1    Higher Governance Risk = 10
Higher E&S Disclosure = 1    Lower E&S Disclosure = 10

 
ENERGY EFFICIENCY AWARD, INVESTMENT IN FOOD PRODUCTION  

Liderfood LLC
Liderfood  is  one  of  the  key  players  in  the  Georgian  meat  production  market  with  about  a  25%  market  share,  producing 
sausages, ham, semi-finished products such as meat dumplings etc. Since its establishment in 2008, Liderfood was located 
in an old building. In 2016, TBC disbursed a loan to the Liderfood to renovate and rebrand the company, as well as invested in 
a new energy efficient building for the production line. 

Within the project, the company acquired new refrigeration equipment and constructed a completely energy efficient building 
with total investment amounting to US$ 0.5 million. As a result, Liderfood saves 657 MW/h energy annually and its CO2 
emission is reduced by 335 tons annually.

ENERGY EFFICIENCY AWARD, INVESTMENT IN ENERGY SECTOR  

Shilda HPP
In 2012, TBC Bank financed Energy LLC, a leading manufacturing company in Georgia focused on renewable energy projects, 
to build Shilda hydro power plant (Shilda HPP). The capacity of Shilda HPP is 5 MW and produces 32 GWh of electricity 
annually. Within the project, the company purchased turbines, generators and other electrical equipment.

By producing 32 GWh of electricity, Shilda HPP could reduce more than 10,000 tons of CO2 emissions in Georgia annually. 

78

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

EBRD AWARDS

In  recognition  of  our  commitment  to  financing  green  projects  under 
EBRD’s    Green  Economy  Financing  Facility,  this  year  we  received  a 
distinguished  award  from  EBRD  for  our  brilliant  performance  in  the 
corporate  banking  sector  and  our  contribution  in  promoting  Green 
Finance in Georgia.

In addition, our clients Liderfood and Shilda also received energy efficient 
awards from EBRD. 

MELIORA AWARD

TBC Bank won GREEN 
INITIATIVE AWARD for its “Green 
Car Fleet” project from Meliora, 
Georgia’s Responsible Business 
Awards 2019

80

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

81

DOING BUSINESS RESPONSIBLY CONTINUED

NON-FINANCIAL INFORMATION STATEMENT 

TBC Bank complies with non-financial reporting requirements contained in sections 414 CA and 414 CB of Companies Act 
2006. The following table summarises the reference to the non-financial matters described in the Strategic Report. 

NON-FINANCIAL INFORMATION

PAGES

The entity’s business model

Business model and strategy, pages 12 to 17

Environmental matters

Employees

Social matters

Human rights

Anti-corruption and anti-bribery

Non-financial key performance indicators
relevant to the entity's business 

Our environmental and social management, pages 72 to 
83

Our colleagues, pages 60 to 67

Our community, pages 68 to 71

Ethical standards, responsible conduct and safety at 
work, page 67

Ethical standards, responsible conduct and safety at 
work, page 67

Key performance indicators, pages 18-19

Description of principal risks and mitigations

Material existing and emerging risks, pages 84 to 92

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

MATERIAL EXISTING AND EMERGING RISKS

Risk  management  is  a  critical  pillar  of  the  Group’s 
strategy.  It  is  essential  to  identify  emerging  risks  and 
uncertainties  that  could  adversely  impact  the  Group’s 
performance,  financial  condition  and  prospects.  This 
section analyses the material principal and emerging risks 
and  uncertainties  the  Group  faces.  However,  we  cannot 
exclude the possibility of the Group’s performance being 
affected by risks and uncertainties other than those listed 
below. More details regarding risk management practices 
can be found on pages  93-107.

The  Board  has  undertaken  a  robust  assessment  of  both 
the principal and emerging risks facing the Group and the 
long-term  viability  of  the  Group’s  operations,  in  order  to 
determine  whether  to  adopt  the  going  concern  basis  of 
accounting.  For  more  information,  please  see  the  Going 
Concern and Viability Statements on pages 134-135. 

PRINCIPAL RISK AND UNCERTAINTIES
1. Credit risk is an integral part of the Group’s business 
activities 
As  a  provider  of  banking  services,  the  Group  is  exposed 
to  the  risk  of  loss  due  to  the  failure  of  a  customer  or 
counterparty to meet their obligations to settle outstanding 
amounts in accordance with agreed terms.

Risk description
Credit risk is the greatest material risk faced by the Group, 
given  the  Group    is  engaged  principally  in  traditional 
lending  activities.  The  Group’s  customers  include  legal 
entities as well as individual borrowers.

Due  to  the  high  level  of  dollarization  of  the  Georgia’s 
is  a 
financial  sector,  currency-induced  credit  risk 
component  of  credit  risk,  which  relates  to  risks  arising 
from  foreign  currency-denominated  loans  to  unhedged 
borrowers in the Group’s portfolio. Credit risk also includes 
concentration  risk,  which  is  the  risk  related  to  credit 
portfolio quality deterioration as a result of large exposures 
to single borrowers or groups of connected borrowers, or 
loan concentration in certain economic industries. Losses 
may be further aggravated by unfavorable macroeconomic 
conditions. These risks are described in more detail as a 
separate principal risk.

Risk mitigation
A comprehensive credit risk assessment framework is in 
place with a clear segregation of duties among the parties 
involved in the credit analysis and approval process. The 
credit  assessment  process  is  distinct  across  segments, 
and is further differentiated across various product types 
to  reflect  the  differing  natures  of  these  asset  classes. 
Corporate,  SME  and  larger  retail  and  micro  loans  are 
assessed  on  an  individual  basis,  whereas  the  decision-
making  process  for  smaller  retail  and  micro  loans  is 
largely automated. The rules for manual and automated 
underwriting  are  developed  by  units  within  the  risk 
function, which are independent from the origination and 
business development units. In the case of corporate and 

SME  borrowers,  the  loan  review  process  is  conducted 
within  specific  sectoral  cells,  which  accumulate  deep 
knowledge of the corresponding sectoral developments.

The  Group  uses  a  robust  monitoring  system  to  react 
promptly  to  macro  and  micro  developments,  identify 
weaknesses in the credit portfolio and outline solutions to 
make  informed  risk  management  decisions.  Monitoring 
processes  are  tailored  to  the  specifics  of  individual 
segments,  as  well  as  encompassing  individual  credit 
exposures,  overall  portfolio  performance  and  external 
trends  that  may  impact  on  the  portfolio’s  risk  profile. 
Additionally,  the  Group  uses  a  comprehensive  portfolio 
supervision system to identify weakened credit exposures 
and take prompt, early remedial actions, when necessary.

The Group’s credit portfolio is structurally highly diversified 
across  customer  types,  product  types  and  industry 
segments,  which  minimizes  credit  risk  at  Group  level. 
As of 31 December 2019, the retail segment represented 
39.9%  of  the  total  portfolio,  which  was  split  between 
mortgage and non-mortgage exposures 62.7% and 37.3%, 
respectively. No single business sector represented more 
than 8.6% of the total portfolio at the end of 2019.

Collateral  represents  the  most  significant  credit  risk 
mitigation tool for the Group, making effective collateral 
management one of the key risk management components. 
Collateral  on  loans  extended  by  the  Group  may  include, 
but is not limited to, real estate, cash deposits, vehicles, 
equipment,  inventory,  precious  metals,  securities  and 
third party guarantees.

The  Group  has  a  largely  collateralised  portfolio  in  all  its 
segments, with real estate representing a major share of 
collateral. As of 31 December 2019, 72.5% of the Group’s 
portfolio was secured by cash, real estate or gold. A sound 
collateral management framework ensures that collateral 
serves  as  an  adequate  mitigating  factor  for  credit  risk 
management purposes

2. The Group faces currency-induced credit risk due to the 
high share of loans denominated in foreign currencies in 
the Group’s portfolio. 
A potential material GEL depreciation is one of the most 
significant  risks  that  could  negatively  impact  portfolio 
quality,  due  to  the  large  presence  of  foreign  currencies 
on the Group’s balance sheet. Unhedged borrowers could 
suffer from an increased debt burden when their liabilities 
denominated in foreign currencies are amplified. 

Risk description
A significant share of the Group’s loans (and a large share 
of the total banking sector loans in Georgia) is denominated 
in  currencies  other  than  GEL,  particularly  in  US$  and 
EUR.  As  of  31  December  2019,  the  local  regulator,  the 
National  Bank  of  Georgia  (“NBG”)  reported  that  55.4%  of 
the total banking sector loans were denominated in foreign 
currencies. As of the same date, 58.7% of the Group’s total 
gross loans and advances to customers (before provision for 
loan impairment) were denominated in foreign currencies. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

The  income  of  many  customers  is  directly  linked  to  the 
foreign  currencies  via  remittances,  tourism  or  exports. 
Nevertheless,  customers  may  not  be  protected  against 
significant fluctuations in the GEL exchange rate against the 
currency of the loan. The US$/GEL rate remained volatile 
throughout  2019  and  GEL  weakened  7.1%  YoY.  The  GEL 
remains in free float and is exposed to many internal and 
external factors that in some circumstances could result in 
its depreciation.

Risk mitigation
Particular  attention  is  paid  to  currency-induced  credit 
risk, due to the high share of loans denominated in foreign 
currencies in the portfolio. The vulnerability to exchange 
rate  depreciation  is  monitored  in  order  to  promptly 
implement  an  action  plan,  as  and  when  needed.  The 
ability to withstand certain exchange rate depreciation is 
incorporated into the credit underwriting standards, which 
also  include  significant  currency  devaluation  buffers 
for  unhedged  borrowers.  In  addition,  the  Group  holds 
significant  capital  against  currency-induced  credit  risk, 
as also shown by the regulatory stress test. Details of the 
stress testing are described on page 135.

Given the experience and knowledge built throughout the 
recent currency volatility, the Group is in a good position 
to  promptly  mitigate  exchange  rate  depreciation  risks. 
In January 2019, government authorities continued their 
efforts  to  reduce  the  economy’s  dependence  on  foreign 
currency financing by increasing the cap to GEL 200,000, 
under which loans must be disbursed in local currency. In 
addition, the NBG, under its responsible lending initiative, 
which  came  into  force  on  1  January  2019,  introduced 
significantly more conservative PTI and LTV thresholds for 
unhedged retail borrowers, further limiting their exposure 
to currency induced credit risk. The NBG eased the above 
mentioned  regulation  from  April  2020.  The  changes 
is  more  relevant  to  hedged  borrowers.  For  unhedged 
borrowers  PTI  and  LTV  thresholds  will  stay  significantly 
more conservative. 

As a result, FX denominated loans in the retail segment 
decreased to 52.8% in 2019 compared to 56.1% in 2018. 

3.  The  Group’s  performance  may  be  compromised  by 
adverse developments in the economic environment.
A slowdown of economic growth in Georgia and political 
instability related to the upcoming parliamentary elections 
could have an adverse impact on the repayment capacity 
of  the  borrowers,  restraining  their  future  investment 
and  expansion  plans.  These  occurrences  would  be 
reflected in the Group’s portfolio quality and profitability, 
and  would  also  impede  portfolio  growth  rates.  Negative 
macroeconomic  developments  could  compromise  the 
through  various  parameters, 
Group’s  performance 
such  as  exchange  rate  depreciation,  a  spike  in  interest 
rates,  rising  unemployment,  a  decrease  in  household 
disposable  income,  falling  property  prices,  worsening 
loan  collateralisation,  or  falling  debt  service  capabilities 
of  companies  as  a  result  of  decreasing  sales.  Potential 

political  and  economic  instability  in  the  neighbouring 
countries  and  main  trading  partners  could  negatively 
impact Georgia’s economic outlook through a worsening 
current account (e.g. decreased exports, tourism inflows, 
remittances and foreign direct investments).

Risk description
According  to  the  Geostat,  real  GDP  increased  by  5.1% 
in  2019.  A  slightly  more  than  5.0%  economic  growth  for 
the  full  year  2019  once  more  underlines  the  resilience 
and  high  growth  potential  of  the  Georgian  economy. 
This  growth  is  particularly  encouraging  on  the  backdrop 
of  the  challenges  that  the  economy  faced  in  2019,  the 
most important being flight ban imposed by the Russian 
Federation. The GEL exchange rate depreciation and above 
target  inflation  remained  additional  challenges  in  2019, 
however,  the  response  of  the  macro  policymakers  have 
been appropriate. The NBG tightened the monetary policy 
rate from 6.5% at the beginning of September to 9.0% as 
of the end of December 2019. This tighter monetary policy 
stance  in  GEL,  coupled  with  the  strong  external  sector, 
has contributed to a stronger GEL exchange rate. By the 
end  of  2019,  the  US$/GEL  exchange  rate  stood  at  2.87, 
down by 3.0% from the previous quarter. Also, the monthly 
dynamics of prices indicate some moderation of inflation 
by the end of 2019.

Fiscal spending significantly supported the growth in 2019, 
with the budget deficit coming in at estimated 2.4% of GDP 
in 2019. The actual impact of the fiscal sector on growth 
was  even  higher,  taking  into  consideration  the  advance 
payments made by the end of 2018. 

As for the system- wide credit growth, while the penetration 
has increased, the credit to GDP ratio was still close to its 
long- term trend, especially when measured at a constant 
exchange  rate.  Despite  some  acceleration  in  FX  lending, 
the  de-dollarization  of  the  financial  sector  remains  a  top 
priority  for  the  central  bank,  however,  going  forward,  it  is 
expected  that  relatively  more  attention  will  be  devoted  to 
the liabilities’ side. Overall, from a macro perspective there 
were no signs of a build up of system- wide risks in 2019. 
At the same time, Georgia remains vulnerable to external 
and to some extent internal shocks, which could have an 
adverse impact on the Georgian economy, resulting in lower 
growth or, in some severe circumstances, a contraction of 
the economy. These negative developments could also have 
a negative impact on the GEL exchange rate.

Risk mitigation
To decrease its vulnerability to economic cycles, the Group 
identifies  cyclical  industries  and  proactively  manages  its 
underwriting approach and clients within its risk appetite 
framework.  The  Group  has  in  place  a  macroeconomic 
monitoring  process  that  relies  on  close,  recurrent 
observation of the economic developments in Georgia, as 
well as in neighboring countries, to identify early warning 
signals indicating imminent economic risks. This system 
allows the Group to promptly assess significant economic 
and  political  occurrences  and  analyse  their  implications 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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MATERIAL EXISTING AND EMERGING RISKS CONTINUED

for  the  Group’s  performance.  The  identified  implications 
are duly translated into specific action plans with regards 
to  reviewing  the  underwriting  standards,  risk  appetite 
metrics or limits, including the limits for each of the most 
vulnerable industries. Additionally, the stress-testing and 
scenario  analysis  applied  during  the  credit  review  and 
portfolio monitoring processes enable the Group to have 
an  advance  evaluation  of  the  impact  of  macroeconomic 
shocks on its business. The resilience towards a changing 
macroeconomic  environment  is  incorporated  into  the 
Group’s credit underwriting standards. As such, borrowers 
are  expected  to  withstand  certain  adverse  economic 
developments through prudent financials, debt-servicing 
capabilities and conservative collateral coverage.

4.The  Group  faces  the  capital  risk  of  not  meeting  the 
minimum regulatory requirements under the increasing 
capital requirement framework, which may compromise 
growth  and  strategic  targets.  Additionally,  adverse 
changes  in  FX  rates  may  impact  the  capital  adequacy 
ratios. 

Risk description
In  December  2017,  the  NBG  introduced  a  new  capital 
adequacy  framework.  Under  the  updated  regulation, 
capital  requirements  consist  of  a  Pillar  1  minimum 
requirement, combined buffers (systemic, countercyclical 
and conservation buffers) and Pillar 2 buffers, which are 
introduced  gradually  over  a  four-year  period.  As  of  year 
end  2019,  the  Bank’s  minimum  capital  requirements 
increased  by  0.6%,  0.7%  and  0.8%  for  CET1,  Tier  1  and 
Total  Capital,  respectively,  compared  to  the  end  of  2018. 
The increase in minimum requirements is mainly driven 
by a planned increase in the systemic risk buffer of 0.5%. 

The  Bank’s  capitalization  as  of  December  2019  stood 
at  12.0%,  14.6%  and  19.1%  compared  to  the  regulatory 
minimum  requirement  of  10.4%,  12.5%  and  17.5%  for 
CET1, Tier 1 and Total capital, respectively. The ratios were 
well above the respective regulatory minimums. In 2019, 
the  Bank  further  strengthened  and  optimized  its  capital 
position by issuing an Additional Tier 1 instrument in the 
amount of US$ 125 million. 

As a result of COVID-19 pandemic, the NBG implemented 
certain  countercyclical  measures  in  relation  to  capital 
adequacy requirements:
 ` Postponing  the  phasing  in  of  concentration  risk  and 
the  net  GRAPE  (General  Risk  Assessment  Program) 
buffer capital requirements on CET1 capital, planned 
in March 2020;

 ` Allowing banks to use the conservation buffer and 2/3 

of currency induced credit risk (CICR) buffer;

 ` Leaving possibility of releasing all the remaining pillar 
2 buffers (remaining 1/3 CICR, concentration risk and 
Net Grape buffers) in case of necessity.

During the time the Bank utilizes conservation and Pillar 
2 buffers, it is restricted to make any capital distribution.

If  the  NBG  changes  the  decision  with  regards  to  capital 
adequacy limits, the banking sector shall have one year to 
comply with the changes. 

Besides  the  expected  negative  impact  of  COVID-19 
pandemic, GEL volatility still remains one of the significant 
risks impacting the Bank’s capital adequacy. A 10% GEL 
depreciation  would  translate  into  a  0.80pp,  0.69pp  and 
0.51pp drop in the Bank’s CET 1, Tier 1 and Total regulatory 
capital adequacy ratios, respectively.

Risk mitigation

The  Group  undertakes  stress-testing  and  sensitivity 
analysis  to  quantify  extra  capital  consumption  under 
different scenarios. Such analyses indicate that the Group 
holds  sufficient  capital  to  meet  the  current  minimum 
regulatory  requirements.  Capital  forecasts,  as  well  as 
the  results  of  the  stress-testing  and  what-if  scenarios, 
are actively monitored with the involvement of the Bank’s 
Management  Board  and  Risk  Committee  to  ensure 
prudent management and timely actions when needed.

In  close  co-ordination  with  the  NBG  the  Bank  created 
an  extra  loan  loss  provision  buffer  to  prepare  for  the 
potential  impact  of  the  COVID-19  pandemic  on  the 
Georgian economy. As of 31 March 2020, TBC Bank booked 
additional provisions in accordance with local standards in 
amount of c.3.1% of the loan book.

5. The Group is exposed to regulatory and enforcement 
action risk.  
The  Bank’s  activities  are  highly  regulated  and  thus 
face  regulatory  risk.  The  NBG  can  increase  prudential 
requirements  across  the  whole  sector  as  well  as  for 
specific  institutions  within  it.  Therefore,  the  Group’s 
profitability and performance may be compromised by an 
increased regulatory burden.

Risk description
The  NBG  sets  lending  limits  and  other  economic  ratios 
(including,  inter  alia,  lending,  liquidity  and  investment 
ratios) in addition to mandatory capital adequacy ratios. 

At  the  beginning  of  2019,  the  NBG  introduced  the  full 
version of the responsible lending regulation limiting the 
growth  of  the  consumer  loans.  The  regulation  defined 
income  verification  techniques  and  introduced  caps  on 
payment-to-income 
(LTV) 
(PTI)  ratios, 
ratios and the maximum maturity of retail loans; stricter 
thresholds  are  applied  to  loans  denominated  in  foreign 
currency.

loan-to-value 

The NBG is also responsible for conducting investigations 
into  specific  transactions  to  ensure  compliance  with 
Georgian  finance  laws  and  regulations.  In  that  regard, 
the  Bank  was  subject  to  an  inspection  by  the  NBG  in 
connection  with  certain  transactions  that  took  place 
in  2007  and  2008.  The  inspection  alleged  that  these 
transactions between the Bank and certain entities were 

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not in technical compliance with Georgian law regulating 
conflicts of interest. In February 2019, the Company, the 
Bank and the NBG issued a joint statement confirming the 
settlement of this investigation and stating that the Bank 
fully complied with the economic normative requirements 
and limits set by the NBG. 

In  parallel,  the  Georgian  Office  of  Public  Prosecution 
launched  an  investigation  into  the  same  matter  and  has 
charged the founders of the Bank. The court case with the 
founders  is  ongoing.  However,  the  founders  have  stood 
down from all their positions within the Group and the Bank. 

Under  the  Georgian  banking  regulations,  the  Bank  is 
required,  among  other  things,  to  comply  with  minimum 
reserve requirements and mandatory financial ratios, and 
regularly to file periodic reports. The Bank is also regulated 
by the tax code and other relevant laws in Georgia. Following 
the  Company’s  listing  on  the  London  Stock  Exchange’s 
premium segment, the Group became subject to increased 
regulations  from  the  UK  Financial  Conduct  Authority.  In 
addition  to  its  banking  operations,  the  Group  also  offers 
other  regulated  financial  services  products,  including 
leasing, insurance and brokerage services. 

TBC Bank’s subsidiary has been granted a banking licence 
in  Uzbekistan  and  is  planning  to  launch  operations  in 
the  summer  2020.  As  a  result  of  this  project,  increased 
regulatory  compliance  requirements  for  the  Group  are 
anticipated.

Additionally, as part of the Group’s international strategy, 
the  ongoing  merger  between  Yelo  Bank  (former  Nikoil 
Bank)  and  TBC  Kredit  is  subject  to  regulatory  approval. 
Assuming the approval is granted, the Group’s intention is 
to increase its shareholding in the merged entity to over 
50%  over  a  four  year  period.  This  will,  in  turn,  increase 
the  Group’s  exposure  to  the  regulatory  environment  in 
Azerbaijan.

The  Group  takes  operational  steps  with  the  intention 
of  ensuring  compliance  with  relevant  legislation  and 
regulations.  The  Group  is  also  subject  to  financial 
covenants in its debt agreements. For more information, 
see page 301 in the Group’s Audited Financial Statements.

Risk mitigation
The  Group  has  established  systems  and  processes  to 
ensure  full  regulatory  compliance,  which  are  embedded 
in  all  levels  of  the  Group’s  operations.  The  dedicated 
compliance  department  reports  directly  to  the  Chief 
Executive Officer and has a primary role in the management 
of regulatory compliance risk. The Group’s Risk Committee 
is responsible for regulatory compliance at the Board level. 
In  terms  of  banking  regulations  and  Georgia’s  taxation 
system,  the  Group  is  closely  engaged  with  the  regulator 
to  ensure  that  new  procedures  and  requirements  are 
discussed in detail before their implementation. There was 
also  an  extensive  dialogue  with  the  regulator  regarding 
the  new  regulation  on  responsible  lending.  Together 

with  the  new  regulation  on  responsible  lending,  the 
government  introduced  initiatives  to  ensure  continuous, 
broad  access  to  financing.  These  include  simplification 
of  the  tax  code  to  incentivize  income  registration  rate. 
Although the decisions made by regulators are beyond the 
Group’s control, significant regulatory changes are usually 
preceded by a consultation period that allows all lending 
institutions to provide feedback and adjust their business 
practices. 

Regarding  the  investigations  by  the  NBG  in  February 
2019,  the  Company,  the  Bank  and  the  NBG  issued  a 
joint  announcement  confirming  the  settlement  of  this 
investigation.  In  response  to  the  regulatory  review  and 
investigations,  the  founding  shareholders  have  stood 
down  from  their  roles  within  the  Group  and  the  Bank. 
The Company has implemented a mirror board structure 
strengthening  the  board  with  the  new  appointments  (for 
further  information,  please  see  Corporate  Governance 
and  Nomination  Committee  Report  on  pages  143-146). 
In  addition,  the  Bank,  with  the  assistance  of  external 
advisers, undertook a review of the Bank’s relevant internal 
controls systems. Although these reviews did not identify 
any  material  deficiencies  in  the  Bank’s  existing  internal 
controls and compliance systems, they did make certain 
technical recommendations for further improvements of 
the  Bank’s  processes  and  procedures,  which  are  being 
implemented. 

6. The Group is exposed to concentration risk. 
Banks  operating  in  developing  markets  are  typically 
exposed  to  both  single-name  and  sector  concentration 
risks.  The  Group  has  large  individual  exposures  to 
single-name  borrowers  whose  potential  default  would 
entail  increased  credit  losses  and  higher  impairment 
charges.  The  Group’s  portfolio  is  well  diversified  across 
sectors,  resulting  in  only  a  moderate  vulnerability  to 
sector  concentration  risks.  However,  should  exposure  to 
common risk drivers increase, the risks are expected to 
amplify correspondingly.

Risk description
The  Group’s  loan  portfolio  is  diversified,  with  maximum 
exposure to the single largest industry (energy and utility) 
standing at 8.6% of the loan portfolio as of 31 December 
2019.  This  figure 
is  reasonable  and  demonstrates  
adequate  credit  portfolio  diversification.  At  the  end  of 
2019, the exposure to the 20 largest borrowers stands at 
12.3% of the loan portfolio, which is in line with the Group’s 
target of alleviating concentration risk. 

Risk mitigation
The  Group  constantly  monitors  the  concentrations  of 
its  exposure  to  single  counterparties,  as  well  as  sectors 
and common risk drivers, and it introduces limits for risk 
mitigation.  As  part  of  its  risk  appetite  framework,  the 
Group limits both single-name and sector concentrations. 
Any  considerable  change  in  the  economic  or  political 
environment,  in  Georgia  as  well  as  in  neighbouring 

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MATERIAL EXISTING AND EMERGING RISKS CONTINUED

countries,  will  trigger  the  Group’s  review  of  the  risk 
appetite criteria to mitigate emerging risk concentrations. 
Stringent  monitoring  tools  are 
in  place  to  ensure 
compliance  with  the  established  limits.  In  addition,  the 
Bank  has  dedicated  restructuring  teams  to  manage 
borrowers  with  financial  difficulties.  When  it  is  deemed 
necessary, clients are transferred to such teams for more 
efficient  handling  and,  ultimately,  to  limit  any  resulting 
credit  risk  losses.  The  NBG’s  new  capital  framework 
introduced a concentration buffer under Pillar 2 that helps 
to ensure that the Group remains adequately capitalised to 
mitigate concentration risks.

7.  Liquidity risk is inherent in the Group’s operations. 
While  the  Board  believes  that  the  Group  currently  has 
sufficient  financial  resources  available  to  meet 
its 
obligations  as  they  fall  due,  liquidity  risk  is  inherent  in 
banking operations and can be heightened by numerous 
factors. These include an overreliance on, or an inability to 
access, a particular source of funding, as well as changes 
in credit ratings or market-wide phenomena, such as the 
global financial crisis that commenced in 2007. Access to 
credit for companies in emerging markets is significantly 
influenced by the level of investor confidence and, as such, 
any factors affecting investor confidence (e.g. a downgrade 
in  credit  ratings,  central  bank  or  state  interventions,  or 
debt restructurings in a relevant industry) could influence 
the  price  or  the  availability  of  funding  for  companies 
operating in any of these markets.

Risk description
In the first quarter of 2019, the Bank experienced a higher 
volatility  of  deposit  flows.  The  decrease  was  primarily 
driven by retail deposit reductions (mostly in January and 
February) prior to the settlement of the NBG investigation, 
but it also reflected the effects of seasonality. 

Throughout  2019,  the  Group  was  in  compliance  with 
the  minimum  liquidity  requirements  set  by  the  NBG, 
which  introduced  a  liquidity  coverage  ratio  in  2017.  This 
is  in  addition  to  the  Basel  III  guidelines,  under  which  a 
conservative approach was applied to deposit withdrawal 
rates,  depending  on  the  concentration  of  client  groups. 
From October 2019, the Bank’s foreign currency mandatory 
reserve was fully categorized as a high quality liquid asset 
(HQLA)  for  regulatory  LCR  calculation  purposes,  which 
had a positive effect on the LCR ratio. 

In September 2019, the NBG also introduced a Net Stable 
Funding  Ratio.  As  of  31  December  2019,  the  net  loan  to 
deposits  plus  international  financial  institution  funding 
ratio  stood  at  104.8%,  the  liquidity  coverage  ratio  at 
110.1%, and the net stable funding ratio at 126.7%. These 
figures  are  all  comfortably  above  the  NBG’s  minimum 
requirements or guidance for such ratios.

As a result of COVID-19 pandemic, the NBG will implement 
certain  countercyclical  measures  in  relation  to  liquidity 
requirements, if necessary:

 ` Decreasing LCR limits;
 ` Decreasing  mandatory  reserve  requirements 

in 

foreign currency;

 ` Updating  criteria  for  security  or  repo  pledging  to 

support GEL liquidity.

Risk mitigation
To  mitigate  this  risk,  the  Group  holds  a  solid  liquidity 
position  and  performs  an  outflow  scenario  analysis  for 
both  normal  and  stress  circumstances  to  make  sure 
that  it  has  adequate  liquid  assets  and  cash  inflows.  The 
Group maintains a diversified funding structure to manage 
the respective liquidity risks. The Board believes there is 
adequate  liquidity  to  withstand  significant  withdrawals 
of  customer  deposits,  but  the  unexpected  and  rapid 
withdrawal of a substantial amount of deposits could have a 
material adverse impact on the Group’s business, financial 
condition, and results of operations and/or prospects. As 
part of its liquidity risk management framework, the Group 
has a liquidity contingency plan in place outlining the risk 
indicators  for  different  stress  scenarios  and  respective 
action  plans.  The  liquidity  risk  position  and  compliance 
with  internal  limits  are  closely  monitored  by  the  Assets 
and Liabilities Management Committee (ALCO).

8. Any decline in the Group’s net interest income or net 
interest margin could lead to a reduction in profitability 
Net  interest  income  accounts  for  the  majority  of  the 
Group’s total income. Consequently, fluctuations in its NIM 
affect  the  results  of  operations.  The  new  regulations  as 
well as high competition could drive interest rates down, 
compromising the Group’s profitability. At the same time, 
the cost of funding is largely exogenous to the Group and 
is derived from both national and international markets.

Risk description
The majority of the Group’s total income derives from net 
interest  income.  Consequently,  the  NIM’s  fluctuations 
affect  the  Group’s  results.  In  2019,  the  NIM  decreased 
by  1.3  pp  YoY  to  5.6%.  The  decrease  was  driven  by  the 
introduction of the responsible lending regulation from 1 
January 2019, limiting the Bank’s ability to lend money to 
higher-yield retail customers.

The  Group  manages  its  direct  exposure  to  the  LIBOR 
and  local  refinancing  rates  through  respective  limits 
and  appropriate  pricing.  As  of  31  December  2019,  GEL 
5,788  million  in  assets  (31%)  and  GEL  3,813  million  in 
liabilities (24%) were floating, related to the LIBOR/FED/
ECB (deposit facility) rates and as per internal judgment, 
whereas GEL 5,320 million of assets (29%) and GEL 3,360 
million  of  liabilities  (21%)  were  floating,  related  to  the 
NBG’s refinancing rate. The reprising maturity of floating 
liabilities  within  a  one-year  horizon  exceeds  the  one  of 
floating assets. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Risk mitigation
The  strong  increase  in  net  fee  and  commission  income 
and  other  operating  income  safeguards  against  margin 
declines  and  profitability  concerns  for  the  Group.  The 
decrease  in  credit  loss  allowance  driven  by  improved 
performance  across  all  segments  also  supports  the 
Bank’s profitability.

To mitigate the asset-liability maturity mismatch, in cases 
where  loans  are  extended  on  fixed  rather  than  floating 
terms,  the  interest  rate  risk  is  translated  into  price 
premiums, safeguarding against changes in interest rates.

9.  The  threat  posed  by  cyber-attacks  has  increased 
in  recent  years  and  it  continues  to  grow.  The  risk  of 
potential  cyber-attacks,  which  have  become  more 
sophisticated, may lead to significant security breaches. 
Such  risks  change  rapidly  and  require  continued  focus 
and investment. 

Risk description
No  major  cyber-attack  attempts  have  targeted  Georgian 
commercial  banks  in  recent  years.  Nonetheless,  the 
Group’s  rising  dependency  on  IT  systems  increases  its 
exposure to potential cyber-attacks.

Risk mitigation
The  Group  actively  monitors,  detects  and  prevents  risks 
arising  from  cyber-attacks.  Staff  members  monitor  the 
developments on both the local and international markets 
to increase awareness of emerging forms of cyber-attacks. 
Intrusion  prevention  and  Distributed  Denial  of  Service 
(DDoS) protection systems are in place to protect the Group 
from  external  cyber-threats.  Security  incident  and  event 
monitoring  systems,  in  conjunction  with  the  respective 
processes  and  procedures,  are  in  place  to  handle  cyber 
-incidents effectively. Processes are continuously updated 
and enhanced to respond to new potential threats. A data 
recovery policy is in place to ensure business continuity in 
case of serious cyber-attacks. In addition, an Information 
Security  Steering  Committee 
in 
improving  information  security  and  business  continuity 
management processes to minimise information security 
risks.
As  a  result  of  COVID-19  pandemic,  the  Bank  activated 
secure remote working policies, which ensure that home-
working  environments  are  protected  against  relevant 
cyber-threats  and  security  team  provides  effective 
oversight of teleworking channels.

is  actively 

involved 

10.  External  and  internal  fraud  risks  are  part  of  the 
operational  risk  inherent  in  the  Group’s  business. 
Considering the increased complexity and diversification 
of  operations,  together  with  the  digitalisation  of 
the  banking  sector,  fraud  risks  are  evolving.  Unless 
proactively  managed,  fraud  events  may  materially 
impact the Group’s profitability and reputation. 

Risk description
External fraud events may arise from the actions of third 
parties against the Group, most frequently involving events 
related  to  banking  cards  and  cash.  Internal  frauds  arise 
from  actions  committed  by  the  Group’s  employees,  and 
such events happen less frequently. During the reporting 
period, the Group faced only a few instances of fraud, none 
of which had a material impact upon the Group’s profit and 
loss statement. Nonetheless, fraudsters are adopting new 
techniques and approaches to exploit various possibilities 
to  illegally  obtain  funds.  Therefore,  unless  properly 
monitored and managed, the potential impact can become 
substantial.

Risk mitigation
The  Group  actively  monitors,  detects  and  prevents  risks 
arising  from  fraud  events  and  permanent  monitoring 
processes  are  in  place  to  detect  unusual  activities  in  a 
timely  manner.  The  risk  and  control  self-assessment 
exercise  focuses  on  identifying  residual  risks  in  key 
processes,  subject  to  the  respective  corrective  actions. 
Given our continuous efforts to monitor and mitigate fraud 
risks, together with the high sophistication of our internal 
processes, the Group ensures the timely identification and 
control of fraud-related activities. 

11. The Group is currently exposed to reputational risk 
The media coverage in Georgia surrounding the founders’ 
of the Bank represents a risk to the reputation of the Group 
(more information is given in page 106).

Risk Description
There are principal risks which may arise from negative 
publicity surrounding TBC Bank and its public perception, 
as well as that of the banking sector in Georgia as a whole. 
In particular, the media exposure in relation to TBC Bank 
and its founders’ has threatened to have an adverse impact 
on  the  Bank’s  operations.  An  inability  to  manage  such 
reputational risks could have an adverse impact upon the 
Bank and its stakeholders, including its clients, employees 
and shareholders.

Risk Mitigation 
To  mitigate  possibility  of  reputational  risks,  the  Bank 
works continuously to maintain strong brand recognition 
within  its  stakeholders.  The  Bank  actively  monitors  its 
brand  value  by  receiving  feedback  from  stakeholders  on 
an ongoing basis. The Group tries to identify early warning 
signals of potential reputational or brand damage in order 
to  both  mitigate  it  and  elevate  it  to  the  attention  of  the 
Board before escalation. Dedicated internal and external 
marketing and communications teams are in place which 
have the responsibility to monitor risks, develop scenarios 
and create respective action plans. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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MATERIAL EXISTING AND EMERGING RISKS CONTINUED

12.  The Group faces the risk that its strategic initiatives 
do not translate into long-term sustainable value for its 
stakeholders 
The  Group’s  business  strategy  may  not  adapt  to  the 
environment of ever changing customer needs. 

Risk Description
The  Group  may  face  the  risk  of  developing  a  business 
strategy that does not safeguard long-term value creation 
in an environment of changing customer needs, competitive 
environment  and  regulatory  restrictions.  In  addition,  the 
Group  may  be  exposed  to  the  risk  that  it  will  not  be  able 
to effectively deliver on its strategic priorities and thereby 
compromise its capacity for long-term value creation.

Risk Mitigation
The  Group  conducts  annual  strategic  review  sessions 
involving the Bank’s top and middle management in order 
to  ensure  that  it  remains  on  the  right  track  and  assess 
business  performance  across  different  perspectives, 
concentrating analysis on key trends and market practices, 
both  in  the  regional  and  global  markets.  In  addition, 
the  Bank  continuously  works  with  the  world’s  leading 
consultants in order to enhance its strategy. Further, the 
Group  conducts  quarterly  analysis  and  monitoring  of 
metrics used to measure strategy execution, and in case 
of any significant deviations, it ensures the development of 
corrective or mitigation actions.

13. The Group is exposed to risks related to its ability to 
attract and retain highly qualified employees 
A strong employee base is vital to the success of the Group

Risk Description
The Group faces the risk of losing of key personnel or the 
failure  to  attract,  develop  and  retain  skilled  or  qualified 
employees. In particular, the strategic decision to transform 
into a digital company entails increased demands on high 
calibre  IT  professionals  across  the  Group.  In  addition,  in 
order to adapt to the fast changing business environment, 
the  Group  needs  to  foster  an  “Agile”  culture  and  equip 
employees with the necessary skills.

Risk Mitigation
The  Group  pays  significant  attention  to  human  capital 
management  strategies  and  policies,  which 
include 
approaches to the recruitment, retention and development 
of  talent,  and  offers  competitive  reward  packages 
to  its  employees.  The  Group  has  also  developed  and 
implemented an “Agile” framework that aims to increase 
employee  engagement  and  satisfaction.  Moreover,  the 
Bank  set  up  an  IT  academy  to  attract  and  train  young 
professionals. The best students are offered employment 
at  the  Bank.  In  addition,  the  Bank  has  an  in-house 
academy that provides various courses for the employees 
in different fields. 

EMERGING RISKS
Emerging  risks  are  those  that  have  large  unknown 
components and may affect the performance of the Group 
over a longer time horizon. We believe the following are 
risks  that  have  a  potential  to  increase  in  significance 
overtime and could have the same impact on the Group as 
the principal risks. 

1. The Group is exposed to the risks inherent in 
international operations 
TBC  Bank’s  subsidiary,  TBC  Bank  in  Uzbekistan,  has 
obtained a banking licence in April 2020 and is planning to 
launch its operations in Uzbekistan in June 2020. The total 
amount of investment in 2020 from all shareholders will 
amount up to US$ 40 million with TBC Bank accounting 
for  51%.  This  investment  exposes  to  the  Group  to 
Uzbekistan’s  macro-economic,  political  and  regulatory 
environments,  including  exposure  to  risks  arising  from 
credit, market, operational and capital adequacy risks. In 
addition, the Group is expanding its international presence 
in Azerbaijan. 

Currently,  the  Group’s  business  activities  are  mainly 
concentrated  in  Georgia,  but  international  activities  are 
expected to contribute to around 30% of the Group’s loan 
book over the medium to long-term.

Risk description
The risk posed by the operating environment in Uzbekistan 
and Azerbaijan may change the Group’s risk profile as a 
result of this international expansion. 

According  to  the  latest  IMF  forecasts,  Uzbekistan  is  a 
rapidly  developing  economy  with  above  5%  real  GDP 
growth  projected  in  the  medium  term.  The  Uzbekistani 
economy  is  well  diversified  with  no  major  reliance  on  a 
particular industry. It has one of the lowest public debts as 
a percentage of GDP in the region and high international 
reserves,  implying  macroeconomic  stability  as  well  as 
room  for  future  high  growth.  The  new  government  of 
Uzbekistan  plans  to  reform  the  economy  and  open  it  up 
to foreign investment. While the operational environment 
in  Uzbekistan  can  be  assessed  as  attractive,  there  are 
important  risks  that  could  materially  affect  the  Group’s 
performance in the country. These risks include, but are 
not limited to, political instability, the slow pace of reforms, 
adverse developments in inflation and fluctuations in the 
exchange rate. 

Azerbaijan is a small, open economy with a high reliance on 
oil exports. The economy of Azerbaijan started to recover in 
2017 after the contraction in 2016 caused by the significant 
decline in oil prices in the period of 2014-2016. According 
to  the  latest  IMF  estimates,  the  economy  is  expected  to 
decline by 2.2% in 2020. Along with the relatively stable oil 
prices and exchange rate, annual inflation has remained 
stable  in  2019.  Azerbaijan’s  economic  recovery  has  also 
contributed  to  the  strengthening  of  its  financial  sector 
and  the  gradual  recovery  of  credit.  Despite  a  relatively 
more  stable  environment,  Azerbaijan’s  growth  is  still 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

significantly  dependent  on  oil  prices  and  any  adverse 
developments in oil prices could negatively affect growth 
perspectives and the exchange rate.

Furthermore, potential political instability and unfavorable 
developments  in  state  regulations  can  also  negatively 
affect the Group’s business in Azerbaijan.

Risk mitigation
The  Group’s  strategy  is  to  follow  an  asset-light,  limited 
capital  investment  approach  with  a  strong  focus  on 
digital channels and to invest in stages, to make sure that 
we  are  comfortable  with  the  results  and  the  operating 
environment  before  committing  additional  investment. 
The  Group  plans  to  serve  retail  and  MSME  customers, 
which will in turn lead to a non-concentrated portfolio and 
subsequently to lower credit risk. The Group will partner 
international  financial  institutions,  which  intend  to  take 
a  shareholding  in  the  Uzbek  bank  in  order,  to  ensure 
the funding of our business plan and sufficient flexibility 
across our operations in Uzbekistan.  

The Group has been operating in Azerbaijan through a small 
microfinance  organization  for  a  number  of  years,  which 
provides  experience  and  knowledge  of  the  local  banking 
environment.  In  addition,  our  exposure  in  Azerbaijan  is 
limited  before  the  option  is  exercised.  The  Group  will 
exercise the option only after it becomes comfortable with 
the  developments,  including  the  operating  environment. 
The  management  will  focus  on  establishing  a  strong 
risk  management  function  to  ensure  that  all  risks  are 
managed and mitigated properly. The Group will leverage 
its strong risk management expertise to establish sound 
risk management practices in new jurisdictions.

Overall,  from  the  Group’s  perspective, 
international 
expansion  will  result  in  diversification  of  business  lines 
and revenue streams, balancing the overall risk profile of 
the Group.

2. The Group is exposed to the risks arising from 
climate change 

Risk description
The  risks  associated  with  climate  change  have  both 
physical  impact  arising  from  more  frequent  and  severe 
weather changes and transitional impact that may entail 
extensive policy, legal and technological changes to reduce 
ecological  footprint  of  the  households  and  businesses. 
For  the  Group,  both  of  these  risks  can  materialise 
through the impairment of asset values and deteriorating 
creditworthiness  of  our  customers,  which  could  result 
in  reduction  of  the  Group’s  profitability.  The  Group  may 
also  become  exposed  to  reputational  risks  as  a  result 
of  its  lending  to  or  other  business  operations  with  the 
customers deemed to be contributing to climate change. 

Risk mitigation
The  Group’s  objective  is  to  act  responsibly  and  manage 
the  environmental  and  social  risks  associated  with  its 

operations in order to minimise negative impacts on the 
environment.  This  approach  enables  us  to  reduce  our 
ecological  footprint  by  using  resources  efficiently  and 
promoting environmentally friendly measures in order to 
mitigate climate change.

The  Group  has  in  place  an  Environmental  Policy,  which 
governs  its  Environmental  Management  System  (the 
“EMS”) and promotes adherence of the Group’s operations 
to  the  applicable  environmental,  health  and  safety  and 
labour regulations and practices. We take all reasonable 
steps  to  support  our  customers 
in  fulfilling  their 
environmental and social responsibilities. Management of 
environmental and social risks is embedded in the Group’s 
lending process through the application of the EMS. The 
Group  has  developed  risk  management  procedures  to 
identify,  assess,  manage  and  monitor  environmental 
and  social  risks.  These  procedures  are  fully  integrated 
in  the  Group’s  credit  risk  management  process.  Our 
Environmental  Policy  is  fully  compliant  with  Georgian 
environmental  legislation  and  follows  international  best 
practices (the full policy is available at www.tbcbankgroup.
com).  

3.  The  Group’s  performance  may  be  affected  by  Libor 
discontinuation and transition
Risk description
There 
is  a  number  of  different  types  of  financial 
instruments  on  the  Group’s  balance  sheet,  each  of 
which carries interest rates benchmarked to the London 
Interbank  Offered  Rate  (“LIBOR”).  LIBOR  is  also  used 
by  the  Group  in  its  risk  measurement,  accounting  and 
valuation  processes.  In  2017,  the  FCA  announced  that  it 
has agreed with LIBOR panel banks to sustain LIBOR until 
the end of 2021 and called financial sector participants to 
start  working  towards  the  transition  to  other  reference 
rates.  The  discontinuation  of  LIBOR  and  the  process 
of  transition  exposes  the  Group  to  execution,  conduct, 
financial and operational risks, and may result in earnings 
volatility, customer complaints and legal proceedings, or 
have  other  adverse  impact  on  the  Group’s  business  and 
operations.   

Risk mitigation
The  Group  is  in  the  process  of  identifying  implications  of 
such transition to other reference rates on its risk profile by 
analysing its execution, conduct, financial and operational 
risks and how such risks could be addressed. TBC is pro-
actively  working  with  industry  participants,  such  as  the 
NBG,  the  Banking  Association  of  Georgia  and  IFI  lenders 
to  facilitate  orderly  transition  to  other  reference  rates. 
The Group is starting its efforts to raise awareness of the 
transition, both internally and externally, to ensure that staff 
has all the necessary knowledge and tools to facilitate the 
transition and that all of the Group’s customers are treated 
fairly. We actively monitor the international as well as local 
transition-related  developments  to  regulate  and  align  the 
Group’s transition process with the market practice.

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MATERIAL EXISTING AND EMERGING RISKS CONTINUED

4. Spread of  coronavirus (COVID-19) comes with unpredictable economic and social consequences
Risk description
COVID-19 outbreak, declared as a pandemic by the World Health Organisation, started in China and spread rapidly around 
the world in early 2020. COVID-19 pandemic has already caused major economic disruptions, halted international travel 
and  resulted  in  country  lockdowns.  COVID-19  pandemic  results  in  a  decreased  economic  growth  in  Georgia,  increased 
unemployment, depreciation of the GEL, decreased commodity and real estate prices and impaired creditworthiness of the 
private sector, and increases financial and non-financial risks of the Group.

As tourism contribution in Georgian economy was significant, the impact is likely to be sizable. The growth is also expected to 
be impacted negatively through lower exports, remittances and FDI inflows, as well as the lockdown to prevent the widespread 
of the virus. At the same time, imports should also adjust. Nevertheless, there will be increase in current account balance. 

However, Georgia is acting very actively to attract support from the international financial organisations. According to the 
government’s announcement as of 15 March, around US$ 1.7 billion, or 10% of 2019 GDP would be mobilized to support 
predominantly the government’s financing needs and partially the central bank’s international reserves. In addition, around 
US$ 1.5 billion should be used to support the private sector. This injections are expected to materially counteract the negative 
impact of the COVID-19 crisis. Per IMF projections, as of 14th April1, Georgian economy is expected to contract by 4.0% in 
2020, while in 2021 the growth is expected to recover to 3.0%.

Together with the international support, it is also important to take into account that there we no signs of overheating of 
the Georgian economy during the pre-distress period, including the housing market. Therefore,  assuming the COVID-19 is 
predominantly temporary, rather than permanent shock, most of the industries should recover relatively quickly with the 
hospitality sector likely lagging behind for some additional period.

According to the IMF1, the economy of Azerbaijan is expected to decline by 2.2% in 2020 with 0.7% recovery a year after. In 
Uzbekistan, the growth is expected to be positive for both 2020 and 2021 with 1.8% and 7.0% respectively.

Risk mitigation
The Group actively analyses various scenarios of economic consequences of COVID-19 pandemic. We introduced three month 
grace period on payments of principal and interest for all retail and MSME customers and hardly-hit corporate borrowers.

We have close communications with our business customers discussing their strategies and sharing our outlook on the 
economy and its key sectors.

In addition, as part of the stress testing exercise, we have analysed multiple scenarios to ensure that the Group has sufficient 
liquidity and capital to meet updated regulatory capital and liquidity requirements. The NBG implemented countercyclical 
measures to support financial stability of the banking system by relaxing capital and liquidity requirements if necessary. For 
more information, please see the capital risk management section on pages 100-104.

Moreover, the government has come up with a number of initiatives to support businesses and the economy such as (i) 
deferral of income taxes for companies operating in tourism industry, (ii) subsidizing interest payments for small and medium 
sized hotels (iii) doubling the volume of VAT refunds to companies (iv) increasing capital expenditure and providing additional 
economic incentives.

1 

IMF World Economic Outlook, April 2020

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

RISK MANAGEMENT

OVERVIEW
The Group operates a strong and independent, business-minded risk management system. Its main objective is to contribute 
to the sustainability of risk-adjusted returns through the implementation of an efficient risk management system. The Group 
has adopted four primary risk management principles to better accomplish its major objectives:

 ` Govern risks transparently to obtain understanding and trust. Consistency and transparency in risk-related processes 
and policies are preconditions for gaining the trust of various stakeholders. Communicating risk goals and strategic 
priorities to governing bodies and providing a comprehensive follow-up in an accountable manner are key priorities for 
staff responsible for risk management. 

 ` Manage risks prudently to promote sustainable growth and resilience. Risk management acts as a backstop against 
excessive risk-taking. Capital adequacy management and strong forward-looking tools and decision-making ensure the 
Group’s sustainability and resilience. 

 ` Ensure that risk management underpins the implementation of strategy. The staff responsible for risk management 
provide assurance on the feasibility of achieving objectives through risk identification and management. Identifying and 
adequately pricing risks, as well as taking risk mitigation actions, supports the generation of desired returns and the 
achievement of planned targets.

 ` Use  risk  management  to  gain  a  competitive  advantage.  Comprehensive,  transparent  and  prudent  risk  governance 
facilitates understanding and trust from multiple stakeholders, ensuring the sustainability and resilience of the business 
model and the positioning of risk management as the Group’s competitive advantage and strategic enabler.

Risk management framework 
The Group’s risk management framework incorporates all the necessary components for comprehensive risk governance 
and is comprised of enterprise risk management, credit, financial and non-financial risk management, risk reporting and 
supporting IT infrastructure, cross-risk analytical tools and techniques such as capital adequacy management and stress-
testing. The following diagram depicts the risk management framework: 

CAPITAL ADEQUACY MANAGEMENT AND STRESS TESTING 

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RISK MANAGEMENT CONTINUED

GOVERNANCE 
The  Group  conducts  its  risk  management  activities  within  the  framework  of  its  unified  risk  management  system.  The 
involvement of all governance levels in risk management, the clear segregation of authority and effective communication 
between the different entities facilitate clarity regarding the Group’s strategic and risk objectives, adherence to the established 
risk appetite and sound risk management. The Group’s governance structure ensures adequate oversight and accountability, 
as well as a clear segregation of duties. The Board and the Supervisory Board have joint overall responsibility to set the tone 
at the top of the Group and monitor compliance with the established objectives, while the Management Board governs and 
directs the Group’s daily activities. 

1

RISK COMMITTEE

1

1

RISK COMMITTEE

The risk governance structure consists of three board levels, including the Board, the Supervisory Board and the Management 
Board. All three boards have dedicated risk committees. The Board and the Supervisory Board each have a Risk Committee that 
supervises the risk profile and risk governance practices within the Group, as well as an Audit Committee that is responsible 
for implementing key accounting policies and facilitating internal and external auditor activities. The Management Board’s 
Risk Committee was established to guide the Group-wide risk management activities and monitor major risk trends to ensure 
that  the  risk  profile  complies  with  the  established  risk  appetite.  The  Management  Board’s  Operational  Risk  Committee 
makes decisions related to operational risk governance, while the Assets and Liabilities Management Committee (ALCO) is 
responsible for the implementation of asset-liability management policies. The Board, the Supervisory Board and the Bank’s 
senior management govern risk objectives through the Risk Appetite Statement, which establishes the desired risk profile 
and risk limits. The statement also sets monitoring and reporting responsibilities, as well as escalation paths for different 
trigger events, and limits breaches, which prompt risk teams to frame and implement established mitigation actions. To 
effectively incorporate the Group’s risk appetite into day-to-day operations, Risk Appetite Statement metrics are cascaded 
into more granular limits at the business unit level, establishing risk allocation across different segments and activities.

The process of setting and cascading the risk appetite is undertaken in parallel with the business planning process. The 
interactive development of business and risk plans aligns the plans by solving risk-return trade-offs in the process and 
increases the feasibility of achieving targets. The Board level oversight, coupled with the permanent involvement of senior 
management in the Group’s risk management and the exercise of top-down risk allocation by the enterprise risk management 
function, ensures clarity regarding risk objectives, intense monitoring of the risk profile against the risk appetite, the prompt 
escalation of risk-related concerns and the establishment of remediation actions. The daily management of individual risks 
is based on the three lines of defence principle. While business lines are the primary owners of risks, risk teams act as 
the second line of defence by sanctioning transactions, tools and techniques for risk identification, analysis, measurement, 
monitoring  and  reporting.  The  committees  established  at  operational  levels  are  charged  with  making  transaction-level 

1  These terms are defined in the glossary on page 320

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decisions as part of a framework comprised of clear and 
sophisticated delegations of authority, based on the “four-
eyes” principle. All new products and projects pass through 
risk teams to ensure that the risks are comprehensively 
analysed.  These  control  arrangements  guarantee  that 
the Group makes informed decisions that are adequately 
priced and that any risks exceeding the Group’s established 
targets are not taken. Credit, liquidity, market, operational 
and  other  non-financial  risks  are  each  managed  by 
dedicated  teams.  The  Group’s  strong  and  independent 
risk-management structure enables the fulfilment of all 
required risk management functions within the second line 
of defence by highly skilled professionals, with a balanced 
mix  of  credentials  in  banking  and  real  sectors  in  local 
and  international  markets.  In  addition  to  the  risk  teams 
subordinated  to  the  Chief  Risk  Officer,  the  compliance 
department reports directly to the CEO and is specifically 
in charge of anti-money laundering and compliance risk 
management. As a third line of defence, the internal audit 
department is responsible for providing independent and 
objective assurance and recommendations to the Group to 
promote the further improvement of operations and risk 
management.

ENTERPRISE RISK MANAGEMENT 
A  centralised  Enterprise  Risk  Management 
(ERM) 
function  is  in  place  to  ensure  the  effective  development, 
communication  and  implementation  of  risk  strategy  and 
risk appetite across the Group. The ERM function facilitates 
cross-risk  activities  such  as  aggregation,  analytics  and 
reporting  and  addresses  issues  that  are  not  specific 
to  a  single  type  of  risk.  Accordingly,  the  ERM  function 
complements  the  role  of  other  risk  functions  to  ensure 
the coverage of key risk activities and responsibilities and 
builds capabilities in a centralised team. The major ERM 
functions can be summarised as follows:

 ` Risk appetite development, cascading and monitoring 
are essential elements of the Group’s strategy. A risk 
budget  is  allocated  to  individual  business  lines  to 
ensure the achievement of aggregated metrics. 

 ` Stress-testing  exercises  are  one  of  the  crucial  tools 
for  effective  risk  identification,  measurement  and 
mitigation.  In  that  regard,  the  Group  continuously 
advances  its  stress-testing  capabilities  and  tools. 
Various scenario analysis and stress testing methods 
are  conducted  by  Bank  to  ensure  that  the  Bank 
maintains  adequate  capital  in  order  to  withstand  the 
given stress scenario and remain in a stable financial 
condition.

 ` Long  term  capital  planning  and  continuous  work  on 
capital optimisation and analytics is also a key aspect 
of the Bank’s risk management procedures.

 ` Consistency  of  risk  management  practices  within 
TBC  Bank  is  also  an  important  task  of  the  ERM.  A 
risk  management  function  dedicated  to  promoting 
consistency ensures that risks are identified, measured 
and governed in an optimal manner within TBC Bank, 
and reported and understood on a consolidated basis.

 ` Generating an adequate return on risk, plays a crucial 
role in the sustainability of the business model. Risk 
inputs for pricing are designed in a way to serve as a 
backdrop against excessive risk taking and guarantee 
that TBC Bank takes adequately priced risks.

 ` Estimating expected losses, monitoring and analytics 
across various segments and products are further key 
features of our strategy. 

 ` Aggregation and analysis of all risk metrics to assess 
the Group’s risk profile on a consolidated basis is also 
carried out. Regular reports on TBC Bank’s risk profile 
are  submitted  to  the  Management  Board  and  to  the 
Supervisory Board’s Risk Committee.

CREDIT RISK MANAGEMENT 
As  a  provider  of  banking  services,  the  Group  is  exposed 
to  the  risk  of  losses  due  to  the  failure  of  a  customer  or 
counterparty to meet their obligations to settle outstanding 
amounts in accordance with agreed terms. Credit risk is 
the  greatest  material  risk  faced  by  the  Group  since  it  is 
engaged mainly in traditional lending activities. Thus, the 
Group dedicates significant resources to its management.

The  major  objectives  of  credit  risk  management  are  to 
put in place a sound credit approval process for informed 
risk-taking and procedures for effective risk identification, 
monitoring and measurement. The Group adopts segment- 
and product-specific approaches for prudent and efficient 
credit risk management. Therefore, the corporate, MSME 
and  retail  portfolios  are  managed  separately  to  address 
the specifics of individual segments. Corporate and MSME 
(except micro) borrowers have larger exposures and are 
managed on an individual basis, whereas micro and retail 
borrowers are managed on a portfolio basis. Major credit 
risk functions can be summarised as follows:

Credit approval 
The Group strives to ensure a sound credit-granting process 
by establishing well-defined lending criteria and building 
up an efficient process for the assessment of a borrower’s 
risk  profile.  A  comprehensive  credit  risk  assessment 
framework is in place with a clear segregation of duties 
among parties involved in the credit analysis and approval 
process. The credit assessment process is distinct across 
segments,  and  is  further  differentiated  across  various 
product types to reflect the differing natures of these asset 
classes. Corporate, SME and larger retail and micro loans 
are assessed on an individual basis, whereas the decision-
making process for smaller retail and micro loans is largely 
automated.  After  a  thorough  assessment  of  borrowers’ 
requirements,  credit  analysts  in  the  case  of  corporate 
and loan officers in the case of SME borrowers prepare a 
presentation containing certain key information in relation 
to the potential borrower and submit it for review to the 
business underwriting risk management. An underwriting 
risk  manager  ensures  that  the  project  analysis  provided 
by the credit analyst/loan officer is complete, all risks and 
mitigating factors are identified and adequately addressed, 

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RISK MANAGEMENT CONTINUED

and the loan is properly structured. Business underwriting 
risk managers specialise in a particular sector to be aware 
of current industry trends and developments. 

A  multi-tiered  system  of  loan  approval  committees 
is  in  place  with  different  approval  levels  to  consider 
the  borrower’s  overall  indebtedness  and  risk  profile. 
These  committees  are  responsible  for  reviewing  credit 
applications  and  approving  exposures,  with  different 
committees  based  on  the  size  and  risk  of  the  loan.  At 
the  highest  level,  the  Chief  Executive  Officer,  Corporate 
Business  Director  and  Chief  Risk  Officer  are  involved. 
In addition, exposures to the 20 largest borrowers or for 
amounts  exceeding  5%  of  the  Bank’s  regulatory  capital 
would  require  review  and  approval  by  the  Board  Risk 
Committee.  Loan  officers  submit  the  credit  applications 
for  retail  and  micro  exposures  to  the  respective 
underwriting  risk  management  units.  Depending  on  the 
amount of the loan, a loan approval committee will review 
the  loan  request  based  on  specified  limits  regarding 
the  risk  level  of  the  customer.  For  the  underwriting  of 
unsecured loans, point-of-sale loans and credit cards, the 
income verification process is performed according to the 
regulations on responsible lending. For decision-making, 
internal  scorecard  models  and  ratings  provided  by  the 
credit bureau are utilized. Different scorecard models are 
developed based on the type of product and the borrowers’ 
segment,  taking  into  consideration  various  internal  and 
external  data.  The  performance  of  scorecard  models  is 
closely monitored to ensure that decisions are in line with 
predefined risk limits.

Currency-induced credit risk 
The  Group  faces  currency-induced  credit  risk,  given  that 
a  large  part  of  its  exposure  is  denominated  in  foreign 
currency. However, limits have been established within the 
risk appetite framework to ensure that the Group continues 
its efforts toward minimising the share of foreign currencies 
in the portfolio. Various management tools and techniques 
are applied to mitigate the inherent currency-induced credit 
risk in the loan book, encompassing all phases of credit risk 
management. In January 2019, the government continued 
its efforts to reduce the economy’s dependence on foreign 
currency  financing  by  increasing  the  cap  to  GEL  200,000, 
under which loans must be disbursed in local currency. In 
addition, the NBG, under its responsible lending initiative, 
which  came  into  force  on  1  January  2019,  introduced 
significantly more conservative PTI and LTV thresholds for 
unhedged retail borrowers, further limiting the exposure to 
currency induced credit risk. 

The  Group  applies  conservative  lending  standards  to 
unhedged  borrowers  with  exposures  denominated  in 
foreign  currencies  to  ensure  that  they  can  withstand 
a  certain  amount  of  forex  depreciation  without  credit 
quality deterioration. In addition to the measures in place 
throughout  the  underwriting  process,  the  Group  actively 
monitors and assesses the quality of loans denominated 
in  foreign  currencies  through  stress-testing  exercises 
and  holds  sufficient  capital  buffers  against  unexpected 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

losses.  In  the  event  of  a  material  currency  depreciation, 
the Group has tools in place to accelerate its monitoring 
efforts, identify customers with potential weaknesses and 
introduce prompt mitigation.

Credit concentration risk 
The  Group  is  exposed  to  concentration  risk,  defined  as 
the potential deterioration in portfolio quality due to large 
exposures  or  individual  industries.  It  has  established  a 
set of tools to efficiently manage concentration risk and, 
in particular, concentrations of single names and sectors 
in  the  portfolio.  The  Group  is  subject  to  concentration 
limits  on  single  names  and  the  largest  20  borrowers, 
and  is  focused  on  optimising  the  structure  and  quality 
of  the  latter  portfolio.  In  addition,  the  Group  imposes 
limits  on  individual  sectors  with  more  conservative  caps 
applied for high-risk sectors, which are defined based on 
comprehensive  analysis  of  industry  cycles  and  outlook. 
Credit  concentrations  are  monitored  monthly.  Trends  in 
the  risk  positions  are  analysed  in  detail  and  corrective 
actions  are  recommended  should  new  sources  of  risk 
or  positive  developments  emerge.  Along  with  managing 
concentration levels in the portfolio, the Group estimates 
unexpected losses and the respective economic capital for 
concentrations of both single name borrowers and sectors 
using the Herfindahl-Hirschman Index, thus ensuring that 
sufficient capital is held against concentration risk.

Collateral management policy
the  most  significant  credit 
Collateral  represents 
risk  mitigation  tool  for  the  Group,  making  effective 
collateral management one of the key risk management 
components.  Collateral  on  loans  extended  by  the  Group 
may  include,  but  is  not  limited  to,  real  estate,  cash 
deposits, vehicles, equipment, inventory, precious metals, 
securities  and  third-party  guarantees.  The  collateral 
accepted  against  a  loan  depends  on  the  type  of  credit 
product  and  the  borrower’s  credit  risk.  The  Group  has  a 
largely  collateralised  portfolio  in  all  its  segments,  with 
real  estate  representing  a  major  share  of  collateral. 
A  centralised  unit  for  collateral  management  governs 
the  Group’s  view  and  strategy  in  relation  to  collateral 
management,  and  ensures  that  collateral  serves  as  an 
adequate  mitigating  factor  for  credit  risk  management. 
The  collateral  management  framework  consists  of  a 
policy-making  process,  a  sound  independent  valuation 
process,  a  haircut  system  throughout  the  underwriting 
process, collateral monitoring (including revaluations and 
statistical analysis) and collateral portfolio analysis.

The  Collateral  Management  and  Appraisal  Department 
(CMAD)  defines  Collateral  Management  Policy  & 
Collateral  Management  Procedures  (approved  by  the 
Board),  purchases  an  appraisal  service  that  must  be  in 
line  with  International  Valuation  Standards  (IVS),  acting 
NBG  regulations  and  internal  rules  (policy/procedures 
and  etc.),  authorizes  appraisal  reports,  manages 
collateral  monitoring  process  (assets  with  high  FV  are 
revaluated  annually,  while  statistical  monitoring  is  used 

for  collaterals  with  low  value).  The  CMAD  uses  a  mixed 
quality  check  scheme  for  valuation:  appraisal  reports 
are  reviewed  internally  by  its  staff  and  separately  by  an 
external company. Almost all activities under the collateral 
management  are  automated  through  an  in-house  web 
application.  The  collateral  management  function  uses 
market  researches  conducted  under  the  project:  Real 
Estate Market laboratory (REM lab).

Collection  functions  for  retail  and  micro  loans  support 
customers  who  are  experiencing  difficulties  in  fulfilling 
their  obligations.  Such  customers  may  miss  payments 
or  notify  the  Group  about  their  difficulty  with  loan 
repayments. A centralised team monitors retail borrowers 
in delinquency which, coupled with branches’ efforts, aims 
to maximise collection. Special software from FICO is used 
for early collection management purposes. 

Credit monitoring 
The Group’s risk management policies and processes are 
designed to identify and analyse risk in a timely manner 
and to monitor adherence to predefined limits by means of 
reliable and timely data. The Group dedicates considerable 
resources to gain a clear and accurate understanding of the 
credit risk faced across various business segments. The 
Group uses a robust monitoring system to react promptly 
to macro and micro developments, identify weaknesses in 
the credit portfolio and outline solutions to make informed 
risk  management  decisions.  Monitoring  processes  are 
tailored to the specifics of individual segments, as well as 
encompassing individual credit exposure, overall portfolio 
performance and external trends that may impact on the 
portfolio’s risk profile. The Risk Committee reviews reports 
relating to the credit quality of the loan portfolio quarterly. 
By  comparing  current  data  with  historical  figures  and 
analysing forecasts, the management believes that it can 
identify risks and respond to them by amending its policies 
in a timely manner.

Restructuring and collections 
The  Group  uses  a  comprehensive  portfolio  supervision 
system  to  identify  weakened  credit  exposures  and  take 
prompt,  early  remedial  actions  when  necessary.  The 
collection and recovery processes are initiated when the 
borrower  does  not  meet  the  agreed  payments  or  the 
borrower’s  financial  standing  is  weakened,  potentially 
jeopardizing  the  repayment  of  the  credit.  Dedicated 
restructuring  and  recovery  units  manage  weakened 
borrowers across all business segments, with collection 
and  recovery  strategies  tailored  for  business  segments 
and  individual  exposure  categories.  The  restructuring 
unit’s  primary  goal  is  to  rehabilitate  the  borrower  and 
transfer  the  exposure  back  to  the  performing  category. 
The  sophistication  and  complexity  of  the  rehabilitation 
process differs based on the type and size of the exposure. 
Corporate  and  SME  borrowers  are  transferred  to  the 
recovery  unit  when  there  is  a  strong  probability  that 
a  material  portion  of  the  principal  amount  will  not  be 
paid,  and  the  main  stream  of  recovery  is  no  longer  the 
borrower’s  cash  flow.  Loan  recovery  plans  may  include 
all available sources of loan recovery, such as selling the 
borrower’s assets, realising collateral or payments under 
guarantees. 

The  Group’s  goal  in  the  recovery  process  is  to  negotiate 
a  loan  recovery  strategy  with  the  borrower  and  secure 
cash  recoveries  to  the  extent  possible,  or  to  negotiate 
repayment through the sale or repossession of collateral. 

Collection  strategies  are  defined  based  on  the  size 
and  type  of  exposure.  Specific  strategies  are  tailored 
to  different  subgroups  of  customers,  reflecting  their 
respective  risk  levels,  so  that  greater  effort  is  dedicated 
to customers with a higher risk profile. Retail and micro 
loans are generally transferred to the recovery unit at 60-
90 days past due. Collateralised loans are transferred to 
the internal recovery unit, whereas the Group collaborates 
with external collection agencies for unsecured loans. To 
recover collateralised loans, the recovery plan is outlined 
considering  the  individual  borrower’s  specifics  and  may 
involve  loan  repayments  under  revised  schedules  or  the 
sale of collateral. Collection agencies generally negotiate 
with the borrowers so that the full repayment of the loan 
or loans can be rescheduled and repaid accordingly. Once 
the  exposure  is  transferred  to  the  recovery  unit,  if  the 
Group  is  unable  to  negotiate  acceptable  terms  with  the 
borrower, the Group may initiate collateral repossession, 
which  is  usually  a  standard  process  with  limited  legal 
complications,  and  may  include  court,  arbitration  or 
notary  procedures.  Restructuring  and  recovery  units  are 
supported  by  qualified  incumbent  lawyers  for  efficient 
accomplishment of litigation and repossession processes

Measurement of Expected Credit Losses
From January 2018, the Group moved to a new provisioning 
methodology  in  line  with  IFRS  9  requirements.  The 
updated  methodology  makes  it  possible  to  assess  loan-
loss  provisions  and  allowances  accurately  with  the 
incorporation of forward-looking information. In addition, 
a new IT tool for provisioning was implemented along with 
the methodology development.

The project was undertaken with the support of Deloitte 
and  the  representatives  of  the  Group’s  risk,  finance  and 
IT  departments  were  responsible  for  the  methodology 
and  IT  tool  implementation.  The  new  models  are  more 
complex and make it possible to incorporate expectations 
of  macro  developments  based  on  predefined  scenarios. 
The  expected  credit  loss  (ECL)  measurement  is  based 
on four components used by the Group: (i) probability of 
default  (“PD”);  (ii)  exposure  at  default  (“EAD”);  (iii)  loss 
given  default  (“LGD”);  and  (iv)  discount  rate.  The  Group 
uses a three-stage model for the ECL measurement and 
classifies its borrowers across three stages: 

 ` Stage I – the Group classifies its exposures as Stage 
I  if  no  significant  deterioration  in  credit  quality 
has  occurred  since  the  initial  recognition  and  the 
instrument  was  not  credit-impaired  when  initially 
recognised; 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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RISK MANAGEMENT CONTINUED

 ` Stage II – the exposure is classified as Stage II if any significant deterioration in credit quality has been identified since the 

initial recognition but the financial instrument is not considered credit-impaired; and 

 ` Stage  III  –  the  exposures  for  which  the  credit-impaired  indicators  have  been  identified  are  classified  as  Stage  III 

instruments. 

The ECL amount differs depending on exposure allocation to one of the three stages:

 ` Stage I instruments – the ECL represents that portion of the lifetime ECL that can be attributed to default events occurring 

within the subsequent 12 months from the reporting date. 

 ` Stage II instruments – the ECL represents the lifetime ECL, i.e. credit losses that can be attributed to possible default 
events during the whole lifetime of a financial instrument. Generally, lifetime is set equal to the remaining contractual 
maturity of the financial instrument. Factors such as the existence of contractual repayment schedules, options for the 
extension of repayment maturity and monitoring processes held by the Group affect the lifetime determination.

 ` Stage III instruments – a default event has already incurred and the lifetime ECL is estimated based on the expected 

recoveries.

The  Group  actively  reviews  and  monitors  the  results  produced  from  IFRS  9  models  to  ensure  that  respective  results 
adequately capture the expected losses.

FINANCIAL RISK MANAGEMENT 
Liquidity risk management
Liquidity risk is the risk that the Group either may not have sufficient financial resources available to meet all its obligations 
and commitments as they fall due, or may only be able to access those resources at a high cost. Both funding and market 
liquidity risks can emerge from a number of factors that are beyond the Group’s control. Due to financial market instability, 
factors such as a downgrade in credit ratings or other negative developments may affect the price or ability to access the 
funding necessary to make payments in respect of the Group’s future indebtedness.

Liquidity risk is managed by the financial risk management and treasury departments and is monitored by the Management 
Board’s Risk Committee or the Assets and Liabilities Management Committee (ALCO) within their predefined functions.

The principal objectives of the Group’s Liquidity Risk Management Policy are to:

 ` ensure the availability of funds to meet claims arising from total liabilities and off-balance sheet commitments, both 

actual and contingent, at an economic price;

 ` recognise any structural mismatch existing within the Group’s statement of financial position and set monitoring ratios 

to manage funding in line with the Group’s well-balanced growth; and 

 ` monitor liquidity and funding on an ongoing basis to ensure that approved business targets are met without compromising 

the Group’s risk profile.

The  Management  Board  reviews  the  Liquidity  Risk  Management  Policy,  which  is  then  presented  to  the  Board  and  the 
Supervisory Board for approval.

Liquidity risk is categorised into two risk types: funding liquidity risk and market liquidity risk.

Funding liquidity risk is the risk that the Group will not be able to efficiently meet both expected and unexpected current 
and future cash flows without affecting either its daily operations or its financial condition under both normal conditions 
and during a crisis. To manage funding liquidity risk, the Group has an internally developed model using a liquidity coverage 
ratio (LCR) and a net stable funding ratio (NSFR), both under Basel III liquidity guidelines. Additionally, the Group applies 
stress tests and “what if” scenario analyses and monitors the NBG’s minimum liquidity ratio. In 2017, the NBG introduced 
its own LCR for liquidity risk management purposes. In addition to the Basel III guidelines, the ratio applies conservative 
approaches to the deposit withdrawal rates depending on the client group’s concentration. Since September 2017, the Bank 
has also monitored compliance with the NBG’s LCR limits. In addition to the total LCR limit, the NBG has also defined limits 
per currency for the GEL and foreign currencies. The LCR is calculated by reference to the qualified liquid assets divided by 
30-day cash net outflows. It is used to help manage short-term liquidity risks. To promote larization in the country of Georgia, 
NBG defines lower limit for GEL LCR than that for FX LCR. From October 2019 FC Mandatory Reserves are considered at 
100% within HQLA for NBG LCR purposes. In addition, in the same period, NBG lowered FC mandatory reserves requirements 
from 30% to 25%.

In September 2019 the NBG introduced a Net Stable Funding Ratio (“NBG NSFR”) for funding liquidity risk management 
purposes. The NSFR is calculated by dividing the available stable funding by the required stable funding. It is used for long-
term liquidity risk management to promote resilience over a longer time horizon by creating additional incentives for the 
Bank to rely on more stable sources of funding on a continuing basis. On a monthly basis the Bank monitors compliance with 
the set limit for NBG NSFR. As of 31 December the ratios were well above the prudential limits set by the NBG as follows:

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Average Liquidity Ratio
Net Stable Funding Ratio
Total Liquidity Coverage Ratio
GEL Liquidity Coverage Ratio
FX Liquidity Coverage Ratio

2019 
32.2%
126.7%
110.1%
83.7%
128.4%

2018
33.3%
N/A
113.9%
102.5%
121.1%

2017
32.5%
N/A
112.7%
95.6%
122.9%

Market liquidity risk is the risk that the Group cannot easily offset or eliminate a position at the then-current market price 
because of inadequate market depth or market disruption. 

To manage market liquidity risk, the Group follows the Basel III guidelines on high-quality liquidity asset eligibility to ensure 
that the Group’s high-quality liquid assets can be sold without causing a significant movement in price and with minimum 
loss of value. In addition, the Group has a liquidity contingency plan, which forms part of the overall prudential liquidity policy. 
The plan is designed to ensure that the Group can meet its funding and liquidity requirements and maintain its core business 
operations in any deteriorating liquidity conditions that could arise outside the ordinary course of its business.

As a result COVID-19 pandemic, the NBG will implement certain countercyclical measures in relation to liquidity requirements, 
if necessary:

 ` Decreasing LCR limits;
 ` Decreasing mandatory reserve requirements in foreign currency;
 ` Updating criteria for security or repo pledging to support GEL liquidity.

Funding and maturity analysis 
The Group’s principal sources of liquidity include customer deposits and accounts, borrowings from local and international banks 
and financial institutions, subordinated loans from international financial institution investors, local interbank short-duration 
term deposits and loans, proceeds from sales of investment securities, principal repayments on loans, interest income and fee 
and commission income. The Board believes that a strong and diversified funding structure is one of the Group’s differentiators. 
The Group relies on relatively stable deposits from Georgia as the main source of funding. The Group also monitors deposit 
concentration for large deposits and sets limits for deposits of non-Georgian residents in its deposit portfolio

To maintain and further enhance its liability structure, the Group sets targets for deposits and funds received from international 
financial institution investors in its risk appetite via the respective ratios. The loan to deposit and IFI funding ratio (defined as 
total value of net loans divided by sum of total value of deposits and funds received from International financial institutions) 
stood at 104.8%, 89.9% and 92.5%, at the 31 December 2019, 2018 and 2017 respectively.

In order to assess the possible outflow of the bank’s customer accounts management applied value-at-risk analysis. VAR as 
of December 2019 equaled 8.4% (2018: 10.9%; 2017: 12.3%). The statistical data was used on the basis of a holding period 
of one month for a look-back period of five years with a confidence level of 99%. The value at risk analysis was performed 
for the following maturity gaps: (0-1 months), (0-3 months), (0-6 months) and (0-12 months), based on which the maximum 
percentage of deposits’ outflow was calculated.

Management believes that in spite of a substantial portion of customers’ accounts being on demand, diversification of these 
deposits by number and type of depositors, and the past experience of the Group would indicate that these customer accounts 
provide a long-term and stable source of funding for the Group. Moreover, the Group’s liquidity risk management includes 
estimation of maturities for its current deposits. The estimate is based on statistical methods applied to historic information 
on the fluctuations of customer account balances.

Market risk 
The Group follows the Basel Committee’s definition of market risk as the risk of losses in on- and off-balance sheet positions 
arising from movements in market prices. These risks are principally: (a) risks pertaining to interest rate related instruments 
and equities in the “trading book” (financial instruments or commodities held for trading purposes); and (b) foreign exchange 
risk and commodities risk throughout the Group.

The Group’s strategy is not to be involved in trading financial instruments or investments in commodities. Accordingly, the 
Group’s only exposure to market risk is foreign exchange risk in its “structural book”, comprising its regular commercial 
banking activities which have no trading, arbitrage or speculative intent.

Foreign exchange risk 
The NBG requires the Bank to monitor both balance sheet and total aggregate balance (including off-balance sheet) open 
currency positions and to maintain the latter within 20% of the Bank’s regulatory capital. For the year ended 31 December 
2019, the Bank maintained an aggregate balance open currency position of 0.5%.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

99

RISK MANAGEMENT CONTINUED

In  addition,  the  Supervisory  Board  sets  further  limits  on  open  currency  positions.  The  ALCO  has  set  limits  on  the  level 
of exposure by currency and for total aggregate position that are more conservative than those set by the NBG and the 
Supervisory Board. The heads of the treasury and financial risk management departments separately monitor the Bank’s 
compliance with these limits daily. 

Compliance with these limits is also reported daily to the Management Board and periodically to the Supervisory Board and 
its Risk Committee. On a Group-wide level, foreign-exchange risk is monitored and reported monthly.To assess the currency 
risk the Bank performs a value-at-risk (“VAR”) sensitivity analysis on a quarterly basis. The analysis calculates the effect 
on the Group’s income determined by possible worst movement of currency rates against the Georgian Lari, with all other 
variables held constant. During the years ended 31 December 2019, 2018 and 2017, the sensitivity analysis did not reveal any 
significant potential effect on the Group’s equity:

In thousands of GEL
Maximum loss (VAR, 99% confidence level)

Maximum loss (VAR, 95% confidence level)

As of 31 December 2019 
(2,291)

As of 31 December 2018
(8,890)

As of 31 December 2017
(2,206)

(1,584)

(6,162)

(1,462)

Interest rate risk management 
Interest rate risk arises from potential changes in market interest rates that can adversely affect the value of the Group’s 
financial assets and liabilities. This risk can arise from maturity mismatches of assets and liabilities, as well as from the 
re-pricing characteristics of such assets and liabilities. The deposits, and a part of the loans offered by the Group, are at 
fixed interest rates, while a portion of the Group’s borrowing is based on a floating interest rate. The Group’s floating rate 
borrowings are, to a certain extent, hedged because the NBG pays a floating interest rate on the minimum reserves that TBC 
Bank holds with it. Furthermore, many of TBC Bank’s loans to customers contain a clause allowing it to adjust the interest 
rate on the loan in case of adverse interest rate movements, thereby limiting exposure to interest rate risk. The management 
also believes that TBC Bank’s interest rate margins provide a reasonable buffer to mitigate the effect of a possible adverse 
interest rate movement. The Bank also applies for interest rate risk hedging instruments in order to mitigate interest rate 
risk.

The Group employs an advanced framework for the management of interest rate risk by establishing appropriate limits, 
monitoring compliance with them and preparing forecasts. Interest rate risk is managed by the financial risk management 
department  and  is  monitored  by  the  ALCO,  which  decides  on  actions  that  are  necessary  for  effective  interest  rate  risk 
management and follows up on their implementation. The major aspects of interest rate risk management development 
and the respective reporting are periodically provided to the Management Board, the Supervisory Board, the Board and the 
Risk Committee.

The Group measures four types of interest-rate risk based on the source of the risk: (i) re-pricing risk; (ii) yield curve risk; (iii) basis 
risk; and (iv) optionality (embedded option) risk.

The Group considers numerous stress scenarios, including different yield curve shifts and behavioural adjustments to cash 
flows (such as deposit withdrawals or loan prepayments), to calculate the impact on one year profitability and enterprise 
value. Appropriate limits are set by the Supervisory Board and the Management Board’s Risk Committee.

Counterparty risk 
Through performing banking services, such as lending in the interbank money market, settling a transaction in the interbank 
foreign exchange market, entering into interbank transactions related to trade finance or investing in securities, TBC Bank 
is exposed to the risk of losses due to the failure of a counterparty bank to meet its obligations.

To manage counterparty risk, the Bank defines limits on an individual basis for each counterparty, while on a portfolio basis 
it limits the expected loss from both treasury and trade finance exposures. As of 31 December 2019, TBC Bank’s interbank 
exposure was concentrated with banks that external agencies, such as Fitch, Moody’s and Standard and Poor’s, have assigned 
high A-grade credit ratings.

CAPITAL RISK MANAGEMENT  

Capital risk is the risk that the Group may not have sufficient level of capital to maintain its normal business activities , and 
to meet its regulatory capital requirements under normal or stressed operating conditions. The management’s objectives in 
terms of capital management are to maintain appropriate levels of capital to support the business strategy, meet regulatory 
and  stress  testing-related  requirements  and  safeguard  the  Group’s  ability  to  continue  as  a  going  concern.  The  Group 

100

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

undertakes stress-testing and sensitivity analysis to quantify extra capital consumption under different scenarios. Capital 
forecasts, as well as the results of the stress-testing and what-if scenarios, are actively monitored with the involvement of the 
Bank’s Management Board and Risk Committee to ensure prudent capital management and timely actions when needed. In 
2019, the Group and the Bank complied with all regulatory capital requirements.

In December 2017, the NBG adopted amendments to the regulations relating to capital adequacy requirements. The changes 
include amendments to the regulation on capital adequacy requirements for commercial banks, and the introduction of new 
requirements (i) on additional capital buffer requirements for commercial banks within Pillar 2; (ii) on the determination of 
the countercyclical buffer rate; and (iii) on the identification of systematically important banks and determining systemic 
buffer requirements. The purpose of these amendments is to improve the quality of banks’ regulatory capital and achieve 
better compliance with the Basel III framework.

Pillar 1 minimum requirements plus combined buffer requirements. The amendments to the regulation on capital adequacy 
requirements for commercial banks have made Pillar 1 minimum requirements in Georgia compatible with the framework 
established by the Basel Committee of Banking Supervision. The amendments included: 

 ` the separation of the 2.5% conservation buffer, which was previously merged with minimum capital requirements. The 
updated minimum regulatory capital requirements are 4.5%, 6.0% and 8.0% for Common Equity Tier 1 Capital, Tier 1 
Capital and Total Regulatory Capital, respectively; 

 ` the introduction of a requirement that banks hold an additional combined buffer through Common Equity Tier 1 Capital, 

consisting of conservation, countercyclical and systemic buffers.

The rate for the conservation buffer has been set at 2.5% of RWAs, while a 0% rate has been set for the countercyclical buffer. 
The countercyclical buffer can vary within the range of 0% to 2.5% and will be reviewed periodically based on the prevailing 
financial and macroeconomic environment. In addition, the NBG designated certain commercial banks in Georgia as DSIBs 
for which individual systemic buffers have been introduced, which means that the DSIBs will be required to set aside more 
Common Equity Tier 1 Capital relative to RWAs, with the requirements being phased in from the end of 2018 to the end of 
2021. In particular, the following systemic buffers and compliance timeframes have been set by the NBG in relation to the 
Bank: 1.0% for the period from 31 December 2018 to 31 December 2019, 1.5% for the period from 31 December 2019 to 
31 December 2020, 2.0% for the period from 31 December 2020 to 31 December 2021, and 2.5% from 31 December 2021 
onwards.

Pillar  2  requirements.  In  accordance  with  the  Basel  III  framework,  the  NBG  also  introduced  additional  capital  buffer 
requirements for commercial banks within Pillar 2 that are based on a supervisory review and assessment process and deal 
with bank-specific risks that are not sufficiently covered under Pillar 1, including an unhedged currency induced credit risk 
buffer and a net general risk assessment programme buffer. The NBG has also introduced a credit portfolio concentration 
buffer and a net stress test buffer. The credit portfolio concentration buffer has become effective from 1 April 2018 and the 
need for the net stress buffer will be assessed based on the regulatory stress testing results. Under the NBG regulation, 56% 
of the capital required under Pillar 2 should be held through Common Equity Tier 1 Capital, while 75% of the capital should 
be held through Tier 1 Capital and 100% of the capital should be held through Total Regulatory Capital. As of December 
2019, the Bank’s Pillar 2 requirement is 1.9%, 2.5% and 5.5% for Common Equity Tier 1, Tier 1 and Total Regulatory Capital, 
respectively.

Both, Tier 1 and Total Regulatory Capital adequacy ratios are calculated based on the Basel III methodology introduced by 
NBG. The following table presents the capital adequacy ratios as well as minimum requirements set by the NBG:  

In thousands of GEL
Tier 1 Capital
Tier 2 Capital
Regulatory capital
Risk-weighted Exposures
Credit Risk Weighted Exposures
Risk Weighted Exposures for Market Risk 
Risk Weighted Exposures for Operational Risk
Total Risk-weighted Exposures
Minimum Tier 1 ratio
Tier 1 Capital adequacy ratio
Minimum total capital adequacy ratio
Total Capital adequacy ratio

2019
 2,281,706 
 692,323 
2,974,029

13,825,677
15,429
1,749,821
15,590,927
12.5%
14.6%
17.5%
19.1%

  2018
1,678,716
672,553
2,351,269

11,458,497
179,381
1,516,993
13,154,871
11.8%
12.8%
16.7%
17.9%

  2017
1,437,218
448,069
1,885,287

9,754,146
28,802
970,241
10,753,189
10.3%
13.4%
12.9%
17.5%

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RISK MANAGEMENT CONTINUED

The breakdown of the Bank’s assets into the carrying amounts based on NBG accounting rules and relevant risk-weighted 
exposures as of 31 December are given in the tables below:

In thousands of GEL
Cash, cash equivalents, Interbank Exposures and Securities
Gross loans and accrued interests, 
Repossessed Assets
Fixed Assets and intangible assets
Other assets
minus general provision, penalty and interest provision
Total 
Total Off-balance
Market Risk
Operational Risk
Total  Amount

In thousands of GEL
Cash, cash equivalents, Interbank Exposures and Securities
Gross loans and accrued interests, 
Repossessed Assets
Fixed Assets and intangible assets
Other assets
minus general provision, penalty and interest provision
Total 
Total Off-balance
Market Risk
Operational Risk
Total  Amount

In thousands of GEL
Cash, cash equivalents, Interbank Exposures and Securities
Gross loans and accrued interests, 
Repossessed Assets
Fixed Assets and intangible assets
Other assets
minus general provision, penalty and interest provision
Total 
Total Off-balance
Market Risk
Operational Risk
Total  Amount

2019

Carrying Value
4,432,843
11,582,327
78,384
628,655
1,349,790
(39,886)
18,032,113
5,203,594
15,429
933,238
24,184,374

2018

Carrying Value
4,181,199
9,206,646
46,755
508,582
1,428,945
(37,705)
15,334,422
2,694,174
179,381
809,063
19,017,040

2017

Carrying Value
3,510,760
 8,233,132 
 58,530 
 437,878 
 553,176 
 (30,862)
 12,762,614 
 1,919,565 
 28,802 
 517,462 
15,228,443

RW amount
1,733,894
9,037,390
78,384
366,364
1,603,780
(39,886)
12,779,926
1,045,751
15,429
1,749,821
15,590,927

RW amount
1,625,289
7,203,609
46,755
287,403
1,639,128
(37,705)
10,764,479
694,018
179,381
1,516,993
13,154,871

RW amount
1,275,017
 6,798,464 
 58,530 
 264,768 
 713,096 
 (30,862)
9,079,013
 675,133 
 28,802 
 970,241 
10,753,189

As a result of COVID-19 pandemic, the NBG implemented certain countercyclical measures in relation to capital adequacy 
requirements:

 ` Postponing the phasing in of concentration risk and the net GRAPE (General Risk Assessment Program) buffer capital 

requirements on CET1 capital, planned in March 2020.

 ` Allowing banks to use the conservation buffer and 2/3 of currency induced credit risk (CICR) buffer
 ` Leaving possibility of releasing all the remaining pillar 2 buffers (remaining 1/3 CICR, concentration risk and Net Grape 

buffers) in case of necessity.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

During the time the Bank utilizes conservation and Pillar 2 buffers, it is restricted to make any capital distribution.

If the NBG changes the decision with regards to capital adequacy limits, the banking sector shall have one year to comply 
with the changes.

As a result of the provision made1 and also the significant depreciation of the Georgian Lari during the course of March 2020, 
TBC Bank’s CET1, Tier 1 and Total CAR as at 31 March 2020 are standing at 9.1%, 12.0% and 16.7%, respectively. These ratios 
remain well above the NBG’s revised minimum requirements of 6.9%, 8.8% and 13.3%, respectively, which allow for the 
utilization of the conservation buffer and 2/3 of the currency induced credit risk buffer.

Capital adequacy ratio under Basel Capital Accord 1988
The  Group  and  the  Bank  are  also  subject  to  minimum  capital  requirements  established  by  covenants  stated  in  loan 
agreements. These requirements include capital adequacy levels calculated in accordance with the requirements of the 
Basel Accord, as defined in the International Convergence of Capital Measurement and Capital Standards (updated April 
1998) and Amendment to the Capital Accord to incorporate market risks (updated November 2005), commonly known as 
Basel I. The composition of the Group’s capital calculated based on JSC TBC Bank’s consolidated figures in accordance with 
Basel Accord is as follows:

In thousands of GEL
Tier 1 capital
Share capital
Retained earnings and disclosed reserves
Less: Goodwill
Non-controlling interest
AT1
Total tier 1 capital
Tier 2 capital
Revaluation reserves
General Reserve
Subordinated debt (included in tier 2 capital)
Total tier 2 capital
Total capital
Credit risk weighted assets (including off-balance obligations)
Less: General Reserve
Market Risk
Total Risk-weighted assets
Minimum Tier 1 ratio
Tier 1 Capital adequacy ratio
Minimum total capital adequacy ratio
Total Capital adequacy ratio

2019

2018

2017

542,204
1,945,728
(29,459)
582
358,463
2,817,518

43,195
159,938
529,772
732,905
3,550,423
12,795,066
(152,618)
34,216
12,676,664
4.0%
22.2%
8.0%
28.0%

542,204
1,509,990
(29,459)
527
-
2,023,262

58,995
129,739
548,508
737,242
2,760,504
10,379,124
(204,391)
210,916
10,385,649
4.0%
19.5%
8.0%
26.6%

524,807
1,254,331
(26,892)
4,735
-
1,756,981

64,489
109,372
355,944
529,805
2,286,786
8,749,752
(118,492)
40,803
8,672,063
4.0%
20.3%
8.0%
26.4%

Following the Basel I guidelines the General Reserve is defined by the management as the minimum among the following:

IFRS provisions created on loans without impairment trigger event;

a. 
b.  2% of loans without impairment trigger event;
c.  1.25% of total RWA (Risk Weighted Assets).

1 

In close co-ordination with the NBG the Bank created an extra loan loss provision buffer to prepare for the potential impact of the COVID-19 pandemic 
on the Georgian economy. As of 31 March 2020, TBC Bank decided to book additional provisions in accordance with local standards in amount of c.3.1% 
of the loan book

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

103

RISK MANAGEMENT CONTINUED

The breakdown of the Group’s assets into the carrying amounts and relevant risk-weighted exposures as of 31 December 
2019, 2018, 2017 are provided in the tables below: 

In thousands of GEL

Risk weighted Exposures
Cash and other cash equivalents, mandatory cash balances with the NBG,
due from other banks, investment securities measured at FVOCI
Gross loans and accrued interests
Repossessed assets
Fixed assets and intangible assets
Other assets
Total 
Total Off-balance
Less: Loan loss provision minus General Reserve
Market Risk
Total  Amount

In thousands of GEL

Risk weighted Exposures
Cash and other cash equivalents, mandatory cash balances with the NBG,
due from other banks, investment securities measured at FVOCI
Gross loans and accrued interests
Repossessed assets
Fixed assets and intangible assets
Other assets
Total 
Total Off-balance
Less: Loan loss provision minus General Reserve
Market Risk
Total  Amount

In thousands of GEL

Risk weighted Exposures
Cash and other cash equivalents, mandatory cash balances with the NBG,
due from other banks, investment securities measured at FVOCI
Gross loans and accrued interests
Repossessed assets
Fixed assets and intangible assets
Other assets
Total 
Total Off-balance
Less: Loan loss provision minus General Reserve
Market Risk
Total  Amount

2019

Carrying Value

RW amount

4,611,420
12,661,955
157,150
626,191
562,456
18,619,172
5,171,419
(152,618)
34,216
23,672,190

203,063
10,069,296
157,150
  596,732
  562,456
11,588,670
1,206,395
(152,618)
34,216
12,676,663

2018

Carrying Value

RW amount

4,285,970
 10,372,582 
 124,643 
504,035
499,747
15,786,977
2,674,697
(204,391)
210,916
18,468,199

244,844
 8,281,144 
 124,643 
 474,576 
 499,747 
 9,624,954 
  754,170
 (204,391)
 210,916 
  10,385,649

2017

Carrying Value

RW amount

 3,609,132 
 8,553,217 
116,809
476,027
409,876
13,165,061
1,907,457
(118,492)
40,803
14,994,829

 214,353 
 6,885,960 
116,809
449,136
409,876
8,076,134
673,618
(118,492)
40,803
8,672,063

NON-FINANCIAL RISK MANAGEMENT 
Operational risk management 
One of the main risks that the Group faces is operational risk, which is the risk of loss resulting from inadequate or failed 
processes and systems, human error, fraud or external events. It includes legal risk but excludes strategic and reputational 
risk.  However,  reputational  risk  management  is  also  given  high  importance  and  priority  and  is  an  integral  part  of  the 
organisation’s overall risk culture.

The  Group  is  exposed  to  many  types  of  operational  risk,  including:  fraudulent  and  other  internal  and  external  criminal 
activities; breakdowns in processes, controls or procedures; and system failures or cyber-attacks from an external party 
with the intention of making the Group’s services or supporting infrastructure unavailable to its intended users, which in turn 
may jeopardise sensitive information and the financial transactions of the Group, its clients, counterparties or customers.

104

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Moreover, the Group is subject to risks that cause disruption to systems performing critical functions or business disruption 
arising from events wholly or partially beyond its control, such as natural disasters, transport or utility failures etc., which 
may result in losses or reductions in service to customers and/or economic losses to the Group.

The operational risks discussed above are also applicable where the Group relies on outside suppliers of services. Considering the fast-
changing environment and sophistication of both banking services and possible fraudsters, the importance of constantly improving 
processes, controls, procedures and systems is heightened to ensure risk prevention and reduce the risk of loss to the Group.

To oversee and mitigate operational risk, the Group has established an operational risk management framework, which is an 
overarching document that outlines the general principles for effective operational risk management and defines the roles 
and responsibilities of the various parties involved in the process. Policies and procedures enabling effective management 
of operational risks are an integral part of the framework. The Management Board ensures a strong internal control culture 
within the Group, where control activities are an integral part of operations. The Board sets the operational risk appetite and 
the Operational Risk Committee oversees compliance with the limits. The Operational Risk Committee discusses the Group’s 
operational risk profile and risk minimisation recommendations on a regular basis.

The operational risk management department acts as second line of defence. It is responsible for implementing the framework 
and appropriate policies and procedures to enable the Group to manage operational risks, as well as monitoring operational 
risk events, risk exposures against risk appetite and material control issues. The department is also responsible for the day-to-
day management of operational risks using various techniques. These include, but are not limited to: running risk and control 
self-assessments, which are aimed at detecting possible gaps in operations and processes with the purpose of suggesting 
appropriate  corrective  actions;  forming  an  internal  risk  event  database  for  further  quantitative  and  qualitative  analysis; 
performing internal control to detect systematic errors in banking operations, internal fraud events and monitoring key risk 
indicators; conducting scenario and root-cause analyses; providing business advisory services regarding nonstandard cases as 
well as assessments of new products and procedures; monitoring IT incident occurrence and overseeing activities targeted at 
solving identified problems; and obtaining insurance policies to transfer the risk of losses from operational risk events.

The operational risk management department has reinforced its internal control, risk assessment teams and methodologies 
to  further  fine-tune  the  existing  control  environment.  The  same  applies  to  the  set  of  actions  directed  to  homogenise 
operational risk management processes throughout the Group’s member companies. The operational risk management 
department reports to the Chief Risk Officer. Various policies, processes and procedures are in place to control and mitigate 
operational risks, including: enacting an outsourcing risk management policy, which enables the Group to control outsourcing 
(vendor) risk arising from adverse events and risk concentrations due to failures in vendor selection, insufficient controls 
and oversight over a vendor and/or services provided by a vendor and other impacts to the vendor; implementing procedures 
to  analyse  systemic  flaws  and  take  corrective  measures  to  prevent  the  reoccurrence  of  significant  losses;  involving  the 
operational risk management department in the approval process for new products and services to minimise risks relating 
thereto; and developing a special operational risk awareness programme for the Group’s employees and providing regular 
training to further strengthen the Group’s internal risk culture.

During  the  reporting  period,  one  of  the  key  operational  risk  management  focus  areas  was  the  Risk  and  Control  Self-
Assessment (RCSA) exercise, under which the Bank’s top priority processes were reviewed and areas of improvement were 
identified. Additionally, the Bank was actively working on the development of a Bank-wide operational risk registry.

Compliance 
The compliance department is the key body executing the Bank’s compliance function, has a formal status and is independent 
from operating structural units and business lines. The compliance function’s role is executed by compliance officers, who 
act as compliance advisers and coordinators, addressing compliance issues in structural units or business lines. The Chief 
Compliance Officer reports quarterly to the Risk Committee, with a disciplinary reporting line to the CEO. The department 
is responsible for the Group’s compliance and reputational risk management. It implements and monitors the fulfilment of 
requirements of the following policies: the Anti-Money Laundering and Counter Terrorist Financing Policy; the Sanctions 
Policy, the Anti-Bribery, Anti-Corruption and Anti-Facilitation of Tax Evasion Policy; the Related-Party Transaction Policy; the 
Share Dealing Policy; the Code of Ethics; the Change Management Policy and the Whistleblowing Policy. 

The  compliance  department  manages  regulatory  risk  by  ensuring  that  applicable  changes  in  laws  and  regulations  are 
implemented by the process owners in a timely manner. The compliance department participates in new product/process 
risk approval process. Additionally the department conducts analysis of customer complaints, the operational risk event 
database, internal audit findings and litigation cases to proactively reveal process weaknesses. Based on the outcomes of 
this analysis, it then initiates changes to internal instructions or gives recommendations to the Bank’s structural units on 
relevant process amendments. The compliance officers have the role of educators and advisers on compliance issues. The 
compliance department delivers training courses via distance-learning and face-to face sessions to existing staff members 
and newcomers, and promotes a compliance culture within the Group.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

105

RISK MANAGEMENT CONTINUED

The NBG is also responsible for conducting investigations into specific transactions to ensure compliance with Georgian 
finance laws and regulations. In that regard, the Bank was subject to an inspection by the NBG in connection with certain 
transactions that took place in 2007 and 2008. The inspection alleged that these transactions between the Bank and certain 
entities were not in technical compliance with the Georgian law regulating conflicts of interest. In February 2019, the Company, 
the Bank and the NBG issued a joint statement confirming the settlement of this investigation and stating that the Bank fully 
complies with the economic normative requirements and limits set by the NBG. In response to the regulatory review and 
investigations, the founding shareholders stood down from their roles at both the Group and the Bank. The Company has 
implemented a “mirror board” structure strengthening the Board with the new appointments. In addition, the Bank, with the 
assistance of external advisers, undertook a review of the Bank’s relevant internal controls systems. Although these reviews 
did not identify any material deficiencies in the Bank’s existing internal controls and compliance systems, they did make 
certain recommendations for further technical improvements for the Bank, which are being implemented.

In parallel, the Georgian Office of Public Prosecution launched an investigation into the same matter and has charged the 
founders. The court case with the founders is ongoing. However, the founders have stood down from their positions at the 
Group and the Bank. 

Anti-money laundering (AML)
The Group is committed to high standards both of anti-money laundering and counter terrorist financing (AML/CTF) and 
requires all Group member companies, management and employees to adhere to these standards in order to prevent the 
use of TBC Bank’s products and services for money laundering/terrorist financing purposes. The Group’s AML/CTF program 
is based on applicable legal and regulatory requirements, which are in line with FATF recommendations, EU regulations and 
best practices. 

The Group’s AML/CTF compliance program, as implemented, comprises written policies, procedures, internal controls and 
systems including, but not limited to:  policies and procedures to ensure compliance with AML laws and regulations; KYC and 
customer due diligence procedures; customer screening against a global list of terrorists and specially designated nationalities; 
relevant financial and other sanctions lists; regular staff training and awareness raising; and procedures for monitoring and 
reporting suspicious activities of the Bank’s customers etc.

As a part of the second line of defence, the AML unit ensures that risks are managed in accordance with the risk appetite 
defined by the Group and promotes a strong risk culture throughout the organization. 

The Group has in place sophisticated AML solution that enables the AML unit to comply with the Sanctions Policy, to monitor 
clients’  transactions  and  identify  suspicious  behavior.  The  AML  unit  works  on  the  constant  improvement  of  software  to 
increase operational efficiency and decrease false-positive alerts.

In November 2019, the new Law of Georgia on Facilitating the Suppression of Money Laundering and Terrorism Financing 
was introduced. Gap analysis have been conducted, resulting in plans to adjust internal processes and procedures in line with 
the new requirements is scheduled to take place in 2020.

Information Security Steering Committee 
An Information Security Steering Committee has been established and charged with continuously improving information 
security and business continuity management processes, and minimising information security risks. The committee has 
been formed to centralise the information security function, including physical security, HR security, data security, IT security 
and business continuity.

The Group invests in effective information security risk management, incident management and awareness programmes, 
which are enhanced with automated tools that ensure acceptable levels of information security risk within the organisation. 
Whenever preventive controls are not applicable, comprehensive business continuity and incident response plans ensure the 
Group’s ability to operate on an ongoing basis and limit losses in the event of a severe business disruption.

Legal 
The Bank’s legal department manages all legal and related matters concerning the activities of the Bank and the Group. 
In  accomplishing  its  mission  to  ensure  that  such  activities  fully  conform  with  all  applicable  laws  and  regulations,  legal 
team delivers wide array of professional legal services – it (i) interacts with internal and external clients, outside counsel, 
government and regulatory entities, (ii) issues memos and opinions, (iii) drafts standardized and individual contracts, (iv) 
prepares corporate resolutions, (v) provides regulatory updates, (vi) represents the Bank in courts, other dispute resolution 
venues and before other third parties. The legal team, which comprises lawyers with diverse backgrounds and experience, 
consists  of  the  following  key  divisions  –  regulatory  and  legal  compliance,  corporate,  dispute  resolution  and  corporate 
governance teams. Each division functions within its clear and distinct job descriptions corresponding to relevant knowledge, 
skill and capabilities of its members. As part of its agile transformation effort, several individual lawyers are working within 
and/or in close cooperation with the teams in charge of specific commercial projects. The department ensures effective 
execution of its duties through existing set of different processes and procedures.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

The Bank’s General Counsel manages the legal department. S/he determines key business objectives for all legal teams, 
introduces policies and vision, as well as ensures effective performance of their duties. The General Counsel reports directly 
to the Management Board and the Supervisory Board and their respective committees on existing legal risks, their mitigation 
strategies and vision for their effective management in the future.

Conduct risk  
Conduct risk is defined as the risk to the delivery of fair outcomes for customers and other stakeholders. In 2019 the Group 
upgraded the Code of Conduct and the Code of Ethics according to the new “Code of Ethics and Standards of Professional 
Conduct of Commercial Banks”. Both documents set high ethical standards that each employee is responsible to uphold.

The Group’s business holds a unique place of trust in the lives of more than 2.6 million customers throughout Georgia. 
Therefore, preserving market confidence through the protection of our customers’ interests is of the utmost importance for 
the financial stability of the Group and the attainment of its strategic objectives.

The Group’s employees undertake and perform their responsibilities with honesty and integrity. They are critical to maintaining 
trust and confidence in its operations and upholding the important values of trust, loyalty, prudence and care.

Additionally,  the  Group’s  management  understands  that  it  bears  responsibility  to  a  diversified  group  of  domestic  and 
international  investors  and  needs  to  embrace  the  rules  and  mechanisms  of  protecting  customers  and  maintaining  the 
confidence of investors and financial markets. The Group’s directors strive to establish the “tone from the top,” which sets 
out the messages describing and illustrating the core components of good conduct.

In managing conduct risk, the Group entrusts different departments and divisions with carrying out the task of managing, 
mitigating and eliminating conduct risk across all the Group’s operations with clients and other stakeholders. The compliance 
and operational risk departments cooperate to create a unified conduct risk management framework and assist the business 
lines and departments in the following:

1.  developing and maintaining policies and procedures to ensure that the respective departments and individual employees 
comply with the provisions set out by regulatory provisions, best practice and the Code of Conduct, the Code of Ethics 
and the Group’s internal handbook;

2.  maintaining a liaison with the compliance department regarding the administration of policies and procedures and the 

investigation of complaints regarding the conduct of the department, its manager and/or its employees;

3.  ensuring  that  the  product  information  provided  to  clients  by  front-line  employees  is  accurate  and  complete,  and  is 
conveyed (both in written and oral form) in a simple and understandable way regardless of the level of sophistication of 
a given client;

4.  maintaining records of client conversations and emails that contain sensitive and sales-related information, including 
information pertaining to the acquisition of new clients and making complex product offers to existing and prospective 
clients;

5.  delivering timely, on-going training for new employees regarding proper conduct and ensuring that all employees stay 

up to date on evolving compliance standards within the Group through periodic training;

6.  developing an open culture that encourages employees to speak up without fear of punishment. Specifically, this means 
setting  up  processes  for  the  prevention  and  detection  of  conflicts  of  interest,  creating  ethical  incentives  and  bonus 
formulas, and aligning incentives and disciplinary practices to the Group’s risk appetite; and

7.  employing  qualified  staff  and  sufficient  human  and  technological  resources  to  investigate,  analyse,  implement  and 
monitor sales and after-sales activities. This approach ensures that the management of conduct risk is not limited to 
risk management units, including the compliance department, but is fully embraced by front-line departments and that 
the proper conduct is fully integrated into required job skills.

In 2019 the Group amended its training materials to cover all requirements regarding ethical conduct and delivered training 
to the whole staff. 

VIABILITY STATEMENT
The  assessment  of  principal  risks  underpins  the  Viability  Statement  in  the  Directors’  Report  for  2019  (see  pages  134  to 
135). The assessment involved consideration of the Group’s current financial position over three years of coverage ending 1 
January 2023, which is relevant to the strategic considerations of the Group.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

107

FINANCIAL REVIEW

OVERVIEW 
TBC Bank Group PLC financial results are prepared in accordance with International Financial Reporting Standards (“IFRS”) 
as adopted by the European Union (“EU”) and the Companies Act 2006 applicable to companies reporting under IFRS. The 
Group classifies and separately discloses certain incomes and expenses, which are non-recurring by nature and are caused 
by extraordinary events, as one-off items in order to provide a consistent view and enable better analysis of the financial 
performance of the Group. Underlying performance is an alternative performance measure (APM) and the reconciliation of 
the underlying profit and loss items with the reported profit and loss items and the underlying ratios are given under Annex 
1 section on pages 122-123.

Starting from 1 January 2019, TBC Bank adopted IFRS 16. Therefore, the comparative information for 2018 is not comparable 
to the information presented for 2019.

TAX STRATEGY  
TBC is committed to complying with all applicable tax laws in all jurisdictions where TBC Group operates, including in the UK. 
In particular, we aim to pay the correct amount of tax within applicable time limits. 

Our objectives are built around the following key principles 

 ` transparency; 
 ` responsibility; and 
 ` effective interaction with tax authorities. 

We ensure that the management of tax risk and proper governance around our tax operations is supported by appropriately trained 
personnel who have clear responsibilities to identify, analyse, assess and manage tax risks. For more details, please view our tax 
strategy on our website at www.tbcbankgroup.com under the “about us” section

PERFORMANCE HIGHLIGHTS 
FY 2019 P&L Highlights
 ` Underlying profit for the period amounted to GEL 545.1 million (FY 2018: GEL 454.9 million)
 ` Reported profit for the period amounted to GEL 540.3 million (FY 2018: GEL 437.4 million)
 ` Underlying return on average equity (ROE) amounted to 22.6% (FY 2018: 22.8%)
 ` Reported return on average equity (ROE) amounted to 22.4% (FY 2018: 22.0%)
 ` Underlying return on average assets (ROA) amounted to 3.3% (FY 2018: 3.3%)
 ` Reported return on average assets (ROA) amounted to 3.2% (FY 2018: 3.2%)
 ` Cost to income of ТBC Bank standalone1 was 35.9% (FY 2018: 35.6%)
 ` Underlying cost to income of TBC Bank Group PLC stood at 39.5% (FY 2018: 37.8%)
 ` Reported Cost to income of TBC Bank Group PLC stood at 39.9% (FY 2018: 37.8%)
 ` Cost of risk on loans stood at 0.7% (FY 2018: 1.6%)
 ` Net interest margin (NIM) stood at 5.6% (FY 2018: 6.9%) 
 ` Risk adjusted net interest margin (NIM) stood at 4.8% (FY 2018: 5.4%)
 ` Basic earnings per share stood at 9.83 (FY 2018: 8.07)
 ` Diluted earnings per share 9.76 (FY 2018: 8.00)

Balance Sheet Highlights as of 31 December 2019
 ` Total assets amounted to GEL 18,410.3 million as of 31 December 2019, up by 18.8% YoY
 ` Gross loans and advances to customers stood at GEL 12,662.0 million as of 31 December 2019, up by 22.1% YoY
 ` Net loans to deposits + IFI2 funding stood at 104.8%, up by 14.9 pp YoY, and Regulatory Net Stable Funding Ratio (NSFR), 

effective from 30 September 2019, stood at 126.7%

 ` NPLs were 2.7%, down by 0.4 pp YoY 
 ` NPLs coverage ratios stood at 91.1%, or 194.2% with collateral, on 31 December 2019 compared to 102.7% or 216.4% 

with collateral, as of 31 December 2018

 ` Total customer deposits amounted to GEL 10,049.3 million as of 31 December 2019, up by 7.5% YoY 
 ` As of 31 December 2019, the Bank’s Basel III CET 1, Tier 1 and Total Capital Adequacy Ratios per NBG methodology stood 
at 12.0%, 14.6% and 19.1% respectively, while minimum requirements amounted to 10.4%, 12.5% and 17.5% respectively

Market Share3
 ` Market share by total assets reached 38.2% as of 31 December 2019, remaining the same YoY
 ` Market share by total loans was 39.5% as of 31 December 2019, up by 0.7 pp YoY 
 ` Market share of total deposits reached 39.0% as of 31 December, down by 2.2 pp YoY

1  For the ratio calculation all relevant group recurring costs are allocated to the bank
2 
3  Market share figures are based on data from the National Bank of Georgia (NBG). The NBG includes interbank loans for calculating market share in loans

International Financial Institutions

108

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

CONSOLIDATED FINANCIAL RESULTS OVERVIEW FY 2019

Income statement highlights

in thousands of GEL
Net interest income
Net fee and commission income
Other operating non-interest income4 
Credit loss allowance
Operating income after credit loss allowance
Operating expenses
Profit before tax
Income tax expense
Profit for the period
Underlying profit for the period

Balance Sheet and Capital Highlights

FY'19
801,539
187,290
139,414
(91,992)
1,036,251
(450,726)
585,525
(45,184)
540,341
545,105

FY'18
778,022
157,530
151,916
(166,239)
921,229
(411,029)
510,200
(72,765)
437,435
454,861

Change YoY
3.0%
18.9%
-8.2%
-44.7%
12.5%
9.7%
14.8%
-37.9%
23.5%
19.8%

in thousands of GEL

31-Dec-19

31-Dec-18

Change YoY

Total Assets
Gross Loans
Customer Deposits
Total Equity
Regulatory Common Equity Tier I Capital (Basel III)
Regulatory Tier I Capital (Basel III)
Regulatory Total Capital (Basel III)
Regulatory Risk Weighted Assets (Basel III)

     18,410,274 
     12,661,955 
     10,049,324 
       2,647,655 
1,871,892
2,281,706
2,974,029
15,590,927

   15,497,993 
   10,372,582 
     9,352,142 
     2,205,968 
1,629,594
1,678,716
2,351,269
13,154,871

18.8%
22.1%
7.5%
20.0%
14.9%
35.9%
26.5%
18.5%

Key Ratios

Underlying ROE
Reported ROE
Underlying ROA
Reported ROA
NIM
Risk adjusted NIM
Cost to income of standalone Bank5 
Underlying cost to income
Reported Cost to income
Cost of risk
FX adjusted cost of risk
NPL to gross loans
NPLs coverage ratio exc. collateral
CET 1 CAR (Basel III)
Regulatory Tier 1 CAR (Basel III)
Regulatory Total CAR (Basel III)
Leverage (Times)

FY'19
22.6%
22.4%
3.3%
3.2%
5.6%
4.8%
35.9%
39.5%
39.9%
0.7%
0.7%
2.7%
91.1%
12.0%
14.6%
19.1%
7.0x

FY'18
22.8%
22.0%
3.3%
3.2%
6.9%
5.4%
35.6%
37.8%
37.8%
1.6%
1.5%
3.1%
102.7%
12.4%
12.8%
17.9%
7.0x

Change YoY
-0.2 pp
0.4 pp
0.0 pp
0.0 pp
-1.3 pp
-0.6 pp
0.3 pp
1.7 pp
2.1 pp
-0.9 pp
-0.8 pp
-0.4 pp
-11.6 pp
-0.4 pp
1.8 pp
1.2 pp
0.0x

4  Other operating non-interest income includes Net insurance premium earned after claims and acquisition costs
5  For the ratio calculation all relevant group recurring costs are allocated to the bank

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

109

FINANCIAL REVIEW CONTINUED

Net Interest Income
In FY 2019, net interest income amounted to GEL 801.5 million down by 3.0% YoY. 

The YoY increase in interest income was primarily related to an increase in interest income from loans, which was related 
to growth of gross loan portfolio by GEL 2,289.4 million, or 22.1%. This effect was partially offset by a 1.3 pp drop in loan 
yields, mainly in the retail and MSME segments.  The decrease in retail loan yields was driven by a continued impact of the 
NBG’s regulation from January 2019, which limits the banks’ ability to lend money to higher-yield retail customers, while the 
decrease in MSME loan yields was in line with the overall market trend. 

Over  the  same  period,  interest  expense  increased  by  GEL  157.6  million,  or  31.1%,  which  was  mainly  related  to  interest 
expense from bonds issued in summer 2019, as well as the increase in interest expense from deposits. The latter was related 
both to growth in the respective portfolio by 7.5% YoY and to an increase in deposit cost by 0.1 pp over the same period.

In 2019, we re-classified net gains on currency swaps from other operating income to net interest income. More information 
is given in annex 2 on page 123.

Consequently, NIM stood at 5.6% in FY 2019, compared to 6.9% in FY 2018, while risk adjusted NIM for the same period 
amounted to 4.8%, down by 0.6 pp YoY.

In thousands of GEL

Interest income
Interest expense
Net gains from currency swaps
Net interest income
NIM
Risk adjusted NIM

FY'19

FY'18

Change YoY

     1,436,843 
      (663,860)
          28,556 
        801,539 
5.6%
4.8%

     1,284,235 
      (506,213)
N/A 
        778,022 
6.9%
5.4%

11.9%
31.1%
100% 
3.0%
-1.3 pp
-0.6 pp

Net fee and commission income
In FY 2019, net fee and commission income totalled GEL 187.3 million, up by 18.9% on a YoY basis. 
The increase on a YoY basis was spread across all categories and was related to overall growth of business.

In thousands of GEL

Net fee and commission income
Card operations
Settlement transactions
Guarantees issued and letters of credit
Other
Total net fee and commission income

FY'19

FY'18

Change YoY

56,037
73,228
30,289
27,736
187,290

50,174
62,051
23,414
21,891
157,530

11.7%
18.0%
29.4%
26.7%
18.9%

Other Non-Interest Income
Total other non-interest income decreased by 8.2% on a YoY basis and amounted to GEL 139.4 million in FY 2019. This was 
mainly driven by the high base of other operating income last year due to the gain from sale of investment properties and the 
recognition of an option to buy shares in one of our large corporate clients in 2018. Another driver was the decrease in net 
income from foreign currency operations related to the re-classification of net gains on currency swaps. More information is 
given in annex 2 on page 123.

This decrease was partially offset by increase in net insurance premium earned after claims and acquisition costs, which 
increased by 50.8% YoY, mainly related to the increased scale of the insurance business.  

110

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

In thousands of GEL

FY'19

FY'18

Change YoY

Other non-interest income
Net income from foreign currency operations
Net insurance premium earned after claims and acquisition costs 1
Other operating income
Total other non-interest income

101,467
18,510
19,437
139,414

106,874
12,275
32,767
151,916

-5.1%
50.8%
-40.7%
-8.2%

Credit Loss Allowance
In FY 2019, total credit loss allowance amounted to GEL 92.0 million, down by 44.7% on a YoY basis. 

The decrease was mainly related to credit loss allowance on loans to customers, which was driven by strong performance 
in all segments, as well as the portfolio product mix change, related to the responsible lending regulation effective from 1 
January 2019.

In thousands of GEL

Credit loss allowance
Credit loss allowance for loan to customers
Credit loss allowance for other transactions
Total credit loss allowance
Operating income after credit loss allowance
Cost of risk

FY'19

FY'18

Change YoY

        (82,030)
          (9,962)
        (91,992)
     1,036,251 
0.7%

      (143,723)
        (22,516)
      (166,239)
        921,229 
1.6%

-42.9%
-55.8%
-44.7%
12.5%
-0.9 pp

Operating Expenses
In FY 2019, total reported operating expenses expanded 9.7% on a YoY basis and amounted to GEL 450.7 million, while over 
the same period underlying operating expenses increased by 8.3% and stood at GEL 445.1 million. 

The increase was primarily due to an increase in staff costs and a rise in depreciation and amortization. The increase in 
staff costs was due to expansion of business as well as increase in share price over the three year period for the purpose 
of top and middle management share based bonuses accruals. The increase in depreciation and amortization was mainly 
due to the adoption of IFRS 16 from January 2019, which led to the reclassification of leases from administrative expenses 
to depreciation.  

As a result, our cost to income ratio increased by 2.1 pp and stood 39.9% in FY 2019, while underlying cost to income was 
39.5% up by 1.7 pp YoY. 

In thousands of GEL

Operating expenses
Staff costs
Provisions for liabilities and charges
Depreciation and amortization
Administrative & other operating expenses
Total reported operating expenses
Total underlying operating expenses
Reported cost to income
Underlying cost to income

FY'19

FY'18

Change YoY

(247,803)
(1,264)
(59,478)
(142,181)
(450,726)
(445,121)
39.9%
39.5%

(220,354)
(4,000)
(45,740)
(140,935)
(411,029)
(411,029)
37.8%
37.8%

12.5%
-68.4%
30.0%
0.9%
9.7%
8.3%
2.1 pp
1.7 pp

1  Net insurance premium earned after claims and acquisition costs can be reconciled to the standalone net insurance profit as follows: net insurance 
premium earned after claims and acquisition costs less credit loss allowance, administrative expenses and taxes, plus fee and commission income 
and net interest income

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

111

FINANCIAL REVIEW CONTINUED

Net Income
Reported net income for the full year 2019 increased by GEL 102.9 million, or 23.5% and stood at GEL 540.3 million. Without 
one-off items our net income would have increased by GEL 90.2 million, or 19.8% and amounted to GEL 545.1 million.

As a result, ROE stood at 22.4%, up by 0.4 pp YoY, while ROA remained unchanged and stood at 3.2%. Our underlying ROE 
stood at 22.6% down by 0.2 pp YoY, while ROA stood at 3.3% and remained the same over the same period. 

In thousands of GEL

Profit before tax
Income tax expense
Reported profit for the period
Underlying profit for the period

Reported ROE
Underlying ROE
Reported ROA
Underlying ROA

FY'19

FY'18

Change YoY

        585,525 
        (45,184)
        540,341 
545,105

        510,200 
        (72,765)
        437,435 
454,861

22.4%
22.6%
3.2%
3.3%

22.0%
22.8%
3.2%
3.3%

14.8%
-37.9%
23.5%
19.8%

0.4 pp
-0.2 pp
0.0 pp
0.0 pp

Funding and Liquidity
Since September 2019, the National Bank of Georgia had introduced net stable funding ratio (NSFR) per Basel III standards. 
The comparable figure for 2018 is based on internal estimates.

Minimum net stable funding ratio, as defined by NBG
Net stable funding ratio
Net loans to deposits + IFI funding
Leverage (Times)
Minimum liquidity ratio, as defined by the NBG
Liquidity ratio, as defined by the NBG
Minimum total liquidity coverage ratio, as defined by the NBG
Minimum LCR in GEL, as defined by the NBG
Minimum LCR in FC, as defined by the NBG
Total liquidity coverage ratio, as defined by the NBG
LCR in GEL, as defined by the NBG
LCR in FC, as defined by the NBG

31-Dec-19

31-Dec-18

100.0%
126.7%
104.8%
7.0x
30.0%
32.2%
100.0%
75.0%
100.0%
110.1%
83.7%
128.4%

N/A
129.3%1 
89.9%
7.0x
30.0%
33.3%
100.0%
75.0%
100.0%
113.9%
102.5%
121.1%

Change

N/A
-2.6%
14.9%
0.0x
0.0%
-1.1%
0.0%
0.0%
0.0%
-3.8%
-18.8%
7.3%

Regulatory Capital 
As of 31 December 2019, the Bank’s Basel III CET 1 capital stood at 12.0%, down by 0.4 pp on a YoY basis. The drop was mainly 
driven by the increased portfolio and GEL depreciation during 2019. This effect was partially offset by net income generation 
over the same period. 

Our Tier 1 and Total capital ratios increased by 1.8 pp and 1.2 pp respectively. The increase was mainly driven by income 
generation and issuance of AT1 instrument (in the amount of US$ 125 million) in summer 2019. 

In thousands of GEL

CET 1 Capital
Tier 1 Capital
Total Capital
Total Risk-weighted Exposures
Minimum CET 1 ratio
CET 1 Capital adequacy ratio
Minimum Tier 1 ratio
Tier 1 Capital adequacy ratio
Minimum total capital adequacy ratio
Total Capital adequacy ratio

1 

  Based on internal estimates  

112

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

31-Dec-19

31-Dec-18

1,871,892
2,281,706
2,974,029
15,590,927
10.4%
12.0%
12.5%
14.6%
17.5%
19.1%

1,629,594
1,678,716
2,351,269
13,154,871
8.3%
12.4%
11.8%
12.8%
15.8%
17.9%

Change

14.9%
35.9%
26.5%
18.5%
2.1 pp
-0.4 pp
2.2 pp
1.8 pp
1.7 pp
1.2 pp

Loan Portfolio
As of 31 December 2019, the gross loan portfolio reached GEL 12,662.0 million, up by 22.1% YoY, or by 17.9% on a constant 
currency basis. This was mainly supported by growth in the corporate segments (as well as by the re-segmentation  of 
certain clients from the MSME segment in 1Q 2019 in the amount of GEL 128.0 million). Over the same period, the proportion 
of gross loans denominated in foreign currency decreased by 1.4 pp on a YoY basis and accounted for 58.7% of total loans, 
while on a constant currency basis the proportion of gross loans denominated in foreign currency increased by 2.9 pp and 
stood at 57.2%.

At the end of December 2019, our market share in total loans stood at 39.5% up by 0.7 pp YoY, while our loan market share in 
legal entities was 38.9% up by 1.6 pp YoY, and our loan market share in individuals stood at 40.0% and remained the same YoY. 

In thousands of GEL

Loans and advances to customers
Retail
Retail loans  GEL
Retail loans FC
Corporate
Corporate loans  GEL
Corporate loans FC
MSME
MSME loans  GEL
MSME loans FC
Total loans and advances to customers

Loan yields
Loan yields  GEL
Loan yields FC
Retail loan yields
Retail loan yields  GEL
Retail loan yields FC
Corporate loan yields
Corporate loan yields  GEL
Corporate loan yields FC
MSME loan yields
MSME loan yields  GEL
MSME loan yields FC

31-Dec-19

31-Dec-18

Change

5,053,203
2,386,750
2,666,453
4,660,473
1,424,309
3,236,164
2,948,279
1,419,804
1,528,475
12,661,955

4,698,699
2,063,283
2,635,416
3,177,289
905,372
2,271,917
2,496,594
1,170,343
1,326,251
10,372,582

7.5%
15.7%
1.2%
46.7%
57.3%
42.4%
18.1%
21.3%
15.2%
22.1%

FY'19

11.0%
15.7%
7.8%
12.1%
18.0%
7.3%
9.3%
11.6%
8.4%
11.4%
15.4%
7.7%

FY'18

Change YoY

12.3%
17.8%
8.5%
14.2%
20.8%
7.9%
9.5%
11.0%
9.0%
12.1%
16.2%
8.7%

-1.3 pp
-2.1 pp
-0.7 pp
-2.1 pp
-2.8 pp
-0.6 pp
-0.2 pp
0.6 pp
-0.6 pp
-0.7 pp
-0.8 pp
-1.0 pp

Loan Portfolio Quality
The total PAR 30 improved by 0.3 pp on a YoY basis, driven by the retail segment, while total NPLs stood at 2.7%, down by 
0.4 pp, which was primarily attributable to the strong performance of the corporate and MSME segments as well as solid 
portfolio growth. 

Par 30

Retail
Corporate
MSME
Total Loans

Non-performing Loans

Retail

Corporate
MSME
Total Loans

31-Dec-19

31-Dec-18

2.1%
0.5%
2.8%
1.7%

2.6%
0.4%
2.8%
2.0%

31-Dec-19

31-Dec-18

3.0%

1.8%
3.8%
2.7%

2.9%

2.7%
4.2%
3.1%

Change

-0.5 pp
0.1 pp
0.0 pp
-0.3 pp

Change

0.1 pp

-0.9 pp
-0.4 pp
-0.4 pp

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

113

FINANCIAL REVIEW CONTINUED

NPLs Coverage

Corporate

Retail
MSME
Total

31-Dec-19

31-Dec-18

Exc. Collateral

Incl. Collateral

Exc. Collateral

Incl. Collateral

97.1%

111.1%
59.7%
91.1%

241.4%

182.9%
173.7%
194.2%

96.4%

132.4%
68.4%
102.7%

286.9%

204.4%
174.0%
216.4%

Cost of risk 
The total cost of risk for FY 2019 stood at 0.7%, down by 0.9 pp YoY, driven by the change of product mix, as well as by robust 
credit quality across all segments, related to the responsible lending regulation effective from 1 January 2019. 

Cost of Risk

Retail
Corporate
MSME
Total

FY'19

1.6%
-0.1%
0.3%
0.7%

FY'18

2.7%
0.4%
0.7%
1.6%

Change YoY

-1.1 pp
-0.5 pp
-0.4 pp
-0.9 pp

Deposit Portfolio
The total deposit portfolio increased by 7.5% YoY and amounted to GEL 10,049.3 million, while on a constant currency basis 
the total deposit portfolio was up by 2.9%. The proportion of deposits denominated in foreign currency increased by 0.2 
pp on a YoY basis and accounted for 65.9% of total deposits, while on a constant currency basis the proportion of deposits 
denominated in foreign currency increased by 1.3 pp and stood at 64.4%. 

By the end December 2019, our market share in deposits amounted to 39.0% down by 2.2 pp YoY, and our market share in deposits 
to legal entities stood at 40.6% down by 0.7 pp. Our market share in deposits to individuals stood at 37.9%, down by 3.3 pp YoY. 

In thousands of GEL

Customer Accounts
Retail
Retail deposits  GEL
Retail deposits FC
Corporate
Corporate deposits  GEL
Corporate deposits FC
MSME
MSME deposits  GEL
MSME deposits FC
Total Customer Accounts

Deposit rates
Deposit rates GEL
Deposit rates FC
Retail deposit yields
Retail deposit rates GEL
Retail deposit rates FC
Corporate deposit yields
Corporate deposit rates GEL
Corporate deposit rates FC
MSME deposit yields
MSME deposit rates GEL
MSME deposit rates FC

114

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

31-Dec-19

31-Dec-18

Change

5,673,917
1,098,681
4,575,236
3,187,319
1,735,746
1,451,573
1,188,088
594,388
593,700
10,049,324

5,103,971
935,339
4,168,632
3,230,653
1,754,282
1,476,371
1,017,518
515,827
501,691
9,352,142

FY'19

3.3%
5.8%
2.0%
2.8%
5.0%
2.3%
4.9%
7.4%
1.7%
0.9%
1.5%
0.3%

FY'18

3.2%
5.6%
2.1%
2.7%
4.4%
2.4%
4.9%
7.5%
1.9%
1.0%
1.7%
0.4%

11.2%
17.5%
9.8%
-1.3%
-1.1%
-1.7%
16.8%
15.2%
18.3%
7.5%

Change YoY

0.1 pp
0.2 pp
-0.1 pp
0.1 pp
0.6 pp
-0.1 pp
0.0 pp
-0.1 pp
-0.2 pp
-0.1 pp
-0.2 pp
-0.1 pp

 
SEGMENTS PROFITABILITY 

Business Segments
The segment definitions are as follows (updated in 2019):

 ` Corporate – a legal entity/group of affiliated entities with an annual revenue exceeding GEL 12.0 million or which have been 
granted facilities of more than GEL 5.0 million. Some other business customers may also be assigned to the corporate segment 
or transferred to the MSME segment on a discretionary basis;

 ` Retail – non-business individual customers; all individual customers are included in retail deposits;
 ` MSME – business customers who are not included in the corporate segment; or legal entities which have been granted a pawn 

shop loan; or individual customers of the fully-digital bank, Space; and

 ` Corporate centre and other operations – comprises the Treasury, other support and back office functions, and non-banking 

subsidiaries of the Group.

Business customers are all legal entities or individuals who have been granted a loan for business purposes. 

Income Statement by Segments

FY'19 In thousands of GEL
Interest income
Interest expense
Net gains on currency swaps 
Net transfer pricing
Net interest income
Fee and commission income
Fee and commission expense
Net fee and commission income
Net insurance premium earned after claims
and acquisition costs

Retail
582,788
(152,751)
-
(66,951)
363,086
207,258
(88,679)
118,579

MSME
299,451
(10,202)
-
(101,424)
187,825
26,271
(9,081)
17,190

Corporate
356,652
(160,064)
-
31,352
227,940
49,338
(7,069)
42,269

Corp.Centre
197,952
(340,843)
28,556
137,023
22,688
10,564
(1,312)
9,252

Total
1,436,843
(663,860)
28,556
-
801,539
293,431
(106,141)
187,290

-

-

-

18,510

18,510

Net income/(expense) from foreign currency operations

30,990

24,220

49,851

(25,782)

79,279

Foreign exchange translation gains
less losses

Net losses from derivative financial instruments

Gains less Losses from Disposal of Investment Securities 
Measured at Fair Value through Other Comprehensive Income

Other operating income

Share of profit of associates

Other operating non-interest income and insurance profit

Credit loss allowance for loans to customers

Credit loss allowance for performance guarantees
and credit related commitments

Credit loss allowance for investments
in finance lease

Credit loss allowance for other financial assets

Credit loss allowance for financial assets measured
at fair value through other comprehensive income

Profit before G&A expenses and income taxes

Staff costs

Depreciation and amortization

Provision for liabilities and charges

Administrative and other operating expenses

Operating expenses

Profit/(loss) before tax

Income tax (expense)/credit

Profit for the year

-

(264)

-

-

-

-

9,563

1,093

-

40,289

(77,323)

411

-

(3,545)

-

-

25,313

(7,968)

124

-

(11)

-

441,497

222,473

(134,143)

(48,018)

(45,522)

(7,210)

-

-

(77,563)

(21,094)

(257,228)

(76,322)

184,269

146,151

(18,101)

(14,825)

166,168

131,326

-

-

-

2,953

-

52,804

3,261

(2,691)

-

2,211

(141)

325,653

(38,360)

(2,571)

-

(17,127)

(58,058)

267,595

(29,048)

238,547

22,188

22,188

(16)

169

5,307

632

21,008

-

-

(280)

169

18,916

632

139,414

(82,030)

(2,156)

582

582

(6,753)

(8,098)

(149)

(290)

46,628

1,036,251

(27,282)

(247,803)

(4,175)

(1,264)

(59,478)

(1,264)

(26,397)

(142,181)

(59,118)

(450,726)

(12,490)

16,790

4,300

585,525

(45,184)

540,341

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

115

FINANCIAL REVIEW CONTINUED

CONSOLIDATED FINANCIAL STATEMENTS OF TBC BANK GROUP PLC

Consolidated Statement of Financial Position

in thousands of GEL
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities measured at fair value through other comprehensive income
Bonds carried at amortized cost
Investments in finance leases
Investment properties
Current income tax prepayment
Deferred income tax asset
Other financial assets
Other assets
Premises and equipment
Right of use assets
Intangible assets 
Goodwill 
Investments in associates
TOTAL ASSETS     
LIABILITIES
Due to credit institutions
Customer accounts     
Lease liabilities
Other financial liabilities    
Current income tax liability   
Debt Securities in issue
Deferred income tax liability   
Provisions for liabilities and charges  
Other liabilities     
Subordinated debt     
TOTAL LIABILITIES     
EQUITY      
Share capital
Shares held by trust
Share premium
Retained earnings
Group re-organisation reserve
Share based payment reserve
Revaluation reserve for premises
Fair value reserve
Cumulative currency translation reserve
Net assets attributable to owners
Non-controlling interest     
TOTAL EQUITY     
TOTAL LIABILITIES AND EQUITY   

31-Dec-18
31-Dec-19
     1,166,911 
      1,003,583 
          47,316 
           33,605 
     1,422,809 
      1,591,829 
   10,038,452 
    12,349,399 
     1,005,239 
         985,293 
        654,203 
      1,022,684 
        203,802 
         256,660 
          84,296 
           72,667 
            2,116 
           25,695 
            2,097 
             2,173 
        167,518 
         133,736 
        192,792 
         255,712 
        367,504 
         385,736 
                 -   
           59,693 
        109,220 
         167,597 
          31,286 
           61,558 
             2,654 
            2,432 
    18,410,274     15,497,993

        3,593,901 
      10,049,324 
             59,898 
           113,608 
               1,634 
        1,213,598 
             21,331 
             23,128 
             95,162 
           591,035 
      15,762,619 

     3,031,503 
     9,352,142 
                 -   
          98,714 
                 63 
          13,343 
          22,237 
          18,767 
        104,337 
        650,919 
   13,292,025 

            1,650 
              1,682 
                 -   
           (27,516)
        796,854 
          848,459 
     1,523,879 
       1,953,364 
      (162,166)
 (162,167)
        (16,294)
           (17,803)
          57,240 
            56,374 
            8,680 
             (6,476)
          (6,937)
             (6,850)
     2,202,906 
       2,639,067 
            3,062 
              8,588 
     2,205,968 
       2,647,655 
     18,410,274     15,497,993 

116

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
Consolidated Statement of Profit or Loss and Other Comprehensive Income

in thousands of GEL
Interest income  
Interest expense 
Net gains from currency swaps
Net interest income
Fee and commission income
Fee and commission expense
Net fee and commission income
Net insurance premiums earned
Net insurance claims incurred and agents’ commissions
Net insurance premium earned after claims and acquisition costs
Net gains from trading in foreign currencies
Net gain/(losses) from foreign exchange translation
Net gains/(losses) from derivative financial instruments
Gains less losses from disposal of investment securities measured at fair value
through other comprehensive income
Other operating income
Share of profit of associates
Other operating non-interest income
Credit loss allowance for loans to customers
Credit loss allowance for investments in finance lease
Credit loss allowance for performance guarantees and credit related commitments
Credit loss allowance for other financial assets
Credit loss allowance for financial assets measured at fair value
through other comprehensive income
Operating income after credit impairment losses
Staff costs
Depreciation and amortization
Provision for liabilities and charges
Administrative and other operating (expense)/income
Operating expenses
Profit before tax
Income tax expense
Profit for the period
Other comprehensive:
Items that may be reclassified subsequently to profit or loss:
Movement in fair value reserve
Exchange differences on translation to presentation currency
Items that will not be reclassified to profit or loss:
Revaluation of premises and equipment
Income tax recorded directly in other comprehensive income
Other comprehensive (expense)/income for the period
Total comprehensive income for the period
Profit attributable to:
 - Shareholders of TBCG
 - Non-controlling interest
Profit for the period
Total comprehensive income is attributable to:
 - Shareholders of TBCG
 - Non-controlling interest
Total comprehensive income for the period

FY’19
     1,436,843 
      (663,860)
          28,556 
        801,539 
293,431
(106,141)
187,290
38,199
(19,689)
18,510
79,279
22,188
(280)

FY’18
     1,284,235 
      (506,213)
N/A
        778,022 
235,701
(78,171)
157,530
23,601
(11,326)
12,275
91,678
15,196
173

169

18,916
632
120,904
(82,030)
582
(2,156)
(8,098)

(290)

1,036,251
(247,803)
(59,478)
(1,264)
(142,181)
(450,726)
585,525
(45,184)
540,341

(15,156)
85

-
-
(15,071)
525,270

537,895
2,446
540,341

522,843
2,427
525,270

2

31,438
1,154
139,641
(143,723)
(1,765)
(4,056)
(16,609)

(86)

921,229
(220,354)
(45,740)
(4,000)
(140,935)
(411,029)
510,200
(72,765)
437,435

6,949
425

10,749
(2,363)
15,760
453,195

435,080
2,355
437,435

450,903
2,292
453,195

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

117

FINANCIAL REVIEW CONTINUED

Consolidated Statements of Cash Flows

In thousands of GEL
Cash flows from/(used in) operating activities
Interest received 
Interest received on currency swaps
Interest paid 
Fees and commissions received
Fees and commissions paid
Insurance premium received
Insurance claims paid
Income received from trading in foreign currencies
Other operating income received
Staff costs paid
Administrative and other operating expenses paid 
Income tax paid
Cash flows from operating activities before changes in operating assets and liabilities
Net change in operating assets 
Due from other banks and mandatory cash balances with the National Bank of Georgia
Loans and advances to customers
Investment in finance lease
Other financial assets
Other assets
Net change in operating liabilities
Due to other banks
Customer accounts
Other financial liabilities
Other liabilities and provision for liabilities and charges
Net cash flows (used in)/from operating activities
Cash flows from/(used in) investing activities
Acquisition of investment securities measured at fair value through other comprehensive income
Proceeds from disposal of investment securities measured at fair value
through other comprehensive income
Proceeds from redemption at maturity of investment securities measured at fair value
through other comprehensive income
Acquisition of subsidiaries, net of cash acquired
Acquisition of bonds carried at amortised cost
Proceeds from redemption of bonds carried at amortised cost
Acquisition of premises, equipment and intangible assets
Proceeds from disposal of premises, equipment and intangible assets
Cash acquired
Proceeds from disposal of investment property
Net cash used in investing activities
Cash flows from/(used in) financing activities
Proceeds from other borrowed funds
Redemption of other borrowed funds
Repayment of principal of lease liabilities
Proceeds from subordinated debt
Redemption of subordinated debt
Proceeds from debt securities in issue
Redemption of debt securities in issue
Dividends paid
Acquisition of non-controlling interest in subsidiary
Net cash flows from financing activities
Effect of exchange rate changes on cash and cash equivalents
Net decrease in cash and cash equivalents
Cash and cash equivalents at the beginning of the year
Cash and cash equivalents at the end of the year

FY’19

FY’18

1,360,296
28,556
(647,427)
282,715
(106,526)
76,101
(21,787)
79,287
44,248
(216,465)
(169,582)
(70,413)
639,003

1,224,606
-
(501,984)
235,508
(78,140)
54,682
(15,174)
91,678
11,407
(202,897)
(136,670)
(34,918)
648,098

(22,009)
(2,013,577)
(43,719)
19,612
1,577

(343,772)
(1,718,446)
(54,784)
(35,570)
(4,486)

(1,938)
272,023
(8,267)
5,816
(1,151,479)

69,755
1,371,675
(12,136)
3,618
(76,048)

(1,781,816)

(717,729)

240,603

14,781

1,598,536

370,571

(39,297)
(613,383)
216,871
(120,333)
13,225
2,996
13,338

809
(395,717)
200,658
(89,263)
813
-
42,515
(469,260) (572,562)

1,819,899
(1,392,897)
6,453
-
(104,079)
1,176,049
(14,296)
(91,928)
-
1,386,295
71,116

1,776,489
(1,515,562)
-
255,900
(60,910)
(7,596) 
-
(85,484)
-
362,837
21,207
(163,328) (264,566)
1,166,911 1,431,477
1,003,583 1,166,911

118

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
 
 
 
 
KEY RATIOS 
Average Balances
The average balances included in this document are calculated as the average of the relevant monthly balances as of each 
month-end.  Balances  have  been  extracted  from  TBC’s  unaudited  and  consolidated  management  accounts,  which  were 
prepared from TBC’s accounting records. These were used by the management for monitoring and control purposes. 

Key Ratios

Ratios (based on monthly averages, where applicable)
Profitability ratios:
Underlying ROE1
Reported ROE2
Underlying ROA3
Reported ROA4
ROE before credit loss allowance5
Underlying Cost to Income6
Reported Cost to Income7
NIM8
Risk Adjusted NIM9
Loan Yields10
Risk Adjusted Loan Yields11
Deposit rates12
Yields on interest Earning Assets13
Cost of Funding14
Spread15
Asset quality and portfolio concentration:
Cost of Risk16
PAR 90 to Gross Loans17
NPLs to Gross Loans18
NPLs coverage exc. collateral19
NPLs coverage with collateral20
Credit loss level to Gross Loans21
Related Party Loans to Gross Loans22
Top 10 Borrowers to Total Portfolio23
Top 20 Borrowers to Total Portfolio24
Capital optimisation:
Net Loans to Deposits plus IFI Funding25
Net Stable Funding Ratio26
Liquidity Coverage Ratio27
Leverage28
CET 1 CAR (Basel III)29
Regulatory Tier 1 CAR (Basel III)30
Regulatory Total 1 CAR (Basel III)31

*  Based on internal estimates

FY'19

FY'18

22.6%
22.4%
3.3%
3.2%
26.3%
39.5%
39.9%
5.6%
4.8%
11.0%
10.3%
3.3%
10.0%
4.7%
5.5%

0.7%
1.1%
2.7%
91.1%
194.2%
2.5%
0.1%
8.3%
12.3%

104.8%
126.7%
110.1%
7.0x
12.0%
14.6%
19.1%

22.8%
22.0%
3.3%
3.2%
30.4%
37.8%
37.8%
6.9%
5.4%
12.3%
10.8%
3.2%
11.4%
4.4%
7.0%

1.6%
1.2%
3.1%
102.7%
216.4%
3.2%
0.1%
10.1%
14.2%

89.9%
129.3%*
113.9%
7.0x
12.4%
12.8%
17.9%

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

119

FINANCIAL REVIEW CONTINUED

Ratio definitions
1.  Underlying return on average total equity (ROE) equals underlying net income attributable to owners divided by the 
monthly average of total shareholders’ equity attributable to the PLC’s equity holders for the same period adjusted for 
the respective one-off items; annualised where applicable.

2.  Reported return on average total equity (ROE) equals net income attributable to owners divided by the monthly average 
of total shareholders’ equity attributable to the PLC’s equity holders for the same period; annualised where applicable.
3.  Underlying return on average total assets (ROA) equals underlying net income of the period divided by monthly average 

total assets for the same period; annualised where applicable.

4.  Reported return on average total assets (ROA) equals net income of the period divided by monthly average total assets 

for the same period; annualised where applicable.

5.  Return on average total equity (ROE) before credit loss allowance equals net income attributable to owners excluding 
all credit loss allowance divided by the monthly average of total shareholders ‘equity attributable to the PLC’s equity 
holders for the same period. 

6.  Underlying cost to income ratio equals total underlying operating expenses for the period divided by the total revenue 
for the same period. (Revenue represents the sum of net interest income, net fee and commission income and other 
non-interest income).

7.  Reported cost to income ratio equals total operating expenses for the period divided by the total revenue for the same period. 

(Revenue represents the sum of net interest income, net fee and commission income and other non-interest income).

8.  Net interest margin (NIM) is net interest income divided by monthly average interest-earning assets; annualised where 
applicable. Interest-earning assets include investment securities excluding corporate shares, net investment in finance 
lease, net loans, and amounts due from credit institutions. The latter excludes all items from cash and cash equivalents, 
excludes EUR mandatory reserves with NBG that currently have negative interest, and includes other earning items 
from due from banks.

9.  Risk Adjusted Net Interest Margin is NIM minus the cost of risk without one-offs and the currency effect.
10.  Loan yields equal interest income on loans and advances to customers divided by monthly average gross loans and 

advances to customers; annualised where applicable.

11.  Risk Adjusted Loan yield is loan yield minus the cost of risk without one-offs and currency effect. 
12.  Deposit  rates  equal  interest  expense  on  customer  accounts  divided  by  monthly  average  total  customer  deposits; 

annualised where applicable.

13.  Yields  on  interest  earning  assets  equal  total  interest  income  divided  by  monthly  average  interest  earning  assets; 

annualised where applicable. 

14.  Cost of funding equals total interest expense divided by monthly average interest bearing liabilities; annualised where 

applicable.

15.  Spread  equals  difference  between  yields  on  interest  earning  assets  (including  but  not  limited  to  yields  on  loans, 
securities and due from banks) and cost of funding (including but not limited to cost of deposits, cost on borrowings and 
due to banks).

16.  Cost of risk equals credit loss allowance for loans to customers divided by monthly average gross loans and advances to 

customers; annualised where applicable.

17.  PAR 90 to gross loans ratio equals loans for which principal or interest repayment is overdue for more than 90 days 

divided by the gross loan portfolio for the same period.

18.  NPLs to gross loans equals loans with 90 days past due on principal or interest payments, and loans with a well-defined 
weakness, regardless of the existence of any past-due amount or of the number of days past due divided by the gross 
loan portfolio for the same period.

19.  NPLs coverage ratio equals total credit loss allowance for loans to customers calculated per IFRS 9 divided by the NPL loans.
20.  NPLs  coverage  with  collateral  ratio  equals  credit  loss  allowance  for  loans  to  customers  per  IFRS  9  plus  the  total 
collateral amount of NPL loans (excluding third party guarantees) discounted at 30-50% depending on segment type 
divided by the NPL loans.

21.  Credit loss level to gross loans equals credit loss allowance for loans to customers divided by the gross loan portfolio 

for the same period.

22.  Related party loans to total loans equals related party loans divided by the gross loan portfolio.
23.  Top 10 borrowers to total portfolio equals the total loan amount of the top 10 borrowers divided by the gross loan portfolio.
24.  Top 20 borrowers to total portfolio equals the total loan amount of the top 20 borrowers divided by the gross loan portfolio.
25.  Net loans to deposits plus IFI funding ratio equals net loans divided by total deposits plus borrowings received from 

international financial institutions.

26.  Net stable funding ratio equals the available amount of stable funding divided by the required amount of stable funding 

as defined by NBG in line with Basel III guidelines. 

27.  Liquidity coverage ratio equals high-quality liquid assets divided by the total net cash outflow amount as defined by the NBG.
28.  Leverage equals total assets to total equity.
29.  Regulatory CET 1 CAR equals CET 1 capital divided by total risk weighted assets, both calculated in accordance with the 
Pillar 1 requirements of the NBG Basel III standards. The reporting started from the end of 2017. Calculations are made 
for TBC Bank stand-alone, based on local standards.

120

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

30.  Regulatory tier 1 CAR equals tier I capital divided by total risk weighted assets, both calculated in accordance with the 
Pillar 1 requirements of the NBG Basel III standards. The reporting started from the end of 2017. Calculations are made 
for TBC Bank stand-alone, based on local standards.

31.  Regulatory total CAR equals total capital divided by total risk weighted assets, both calculated in accordance with the 
Pillar 1 requirements of the NBG Basel III standards. The reporting started from the end of 2017. Calculations are made 
for TBC Bank stand-alone, based on local standards.

Exchange Rates
To calculate the YoY growth of the Balance Sheet items without the currency exchange rate effect, we used the US$/GEL 
exchange rate of 2.6766 as of 31 December 2018. As of 31 December 2019, the US$/GEL exchange rate equalled 2.8677. 
For P&L items growth calculations without currency effect, we used the average US$/GEL exchange rate for the following 
periods: FY 2019 of 2.8192, FY 2018 of 2.5345.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

121

FINANCIAL REVIEW CONTINUED

ANNEX 1 
Reconciliation of reported IFRS consolidated figures with the underlying numbers

 Item (in thousands of GEL ) FY 2019

FY 2018

Description

Consulting fees

(5,605)

Reversal of
deferred tax gain

-

(17,426)

Consulting fees incurred in 2Q 2019, in 
relation to the recent events regarding 
historic matters surrounding TBC 
Bank. For further details, please see 
the press release dated 21.02.2019 and 
the press release dated 09.01.2019.

In 2018, TBC Bank reversed the one-
off deferred tax gain recognized in 
2016 due to the recent amendment to 
the Georgian Tax Code in relation to 
corporate income tax. The amendment, 
which came into force on 12 June 2018, 
postponed tax relief for re-invested 
profit from 1 January 2019 to 1 January 
2023 for financial institutions.

Reason for exclusion from the Group’s 
current reported performance

These costs are significant and non-
recurring in nature, and therefore 
are not indicative of the Group’s 
current underlying performance.

These costs are significant and 
non-recurring in nature, and 
therefore are not indicative of 
the Group’s current underlying 
performance.

in thousands of GEL 
Reported net interest income
Reported net fee and commission income
Reported net insurance premium earned after claims and acquisition costs
Reported other operating income
Reported operating income
Reported total credit loss allowance
Reported operating income after provisions
Reported operating expenses
One-off consulting fees
Underlying operating expenses
Reported profit before tax
Underlying profit before tax
Reported income tax
Effect on tax of one-off items
Reversal of the one-off deferred tax gain
Underlying income tax
Reported net profit
Underlying net profit (APM)
Reported non-controlling interest (NCI)
Underlying NCI
Reported net profit less NCI
Underlying net profit less NCI

FY'19
801,539
187,290
18,510
120,904
1,128,243
(91,992)
1,036,251
(450,726)
5,605
(445,121)
585,525
591,130
(45,184)
(841)

(46,025)
540,341
545,105
2,446
2,446
537,895
542,659

FY'18
778,022
157,530
12,275
139,641
1,087,468
(166,239)
921,229
(411,029)
-
(411,029)
510,200
510,200
(72,765)

17,426
(55,339)
437,435
454,861
2,355
2,355
435,080
452,506

122

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

in thousands of GEL 
Average reported equity attributable to the PLC's equity holders
Adjustment for one-off items on monthly average basis
Average underlying equity attributable to the PLC's equity holders
Average reported total assets
Adjustment for one-off items on monthly average basis
Average underlying total assets

Reported cost to income
Underlying cost to income (APM)
Reported ROE
Underlying ROE (APM)
Reported ROA
Underlying ROA (APM)

ANNEX 2

Net gains from currency swaps

FY'19
2,397,141
6,079
2,403,220
16,792,320
-
16,792,320

FY'18
1,977,359
10,088
1,987,447
13,623,594
-
13,623,594

FY'19
39.9%
39.5%
22.4%
22.6%
3.2%
3.3%

FY'18
37.8%
37.8%
22.0%
22.8%
3.2%
3.3%

In 2019, the Group entered into swap agreements denominated in foreign currencies in order to decrease its cost of funding. 
As the contracts reached significant volume, the Group revisited the presentation of effects in the Statement of profit or loss. 
Reclassifications from other non-interest operating income to net interest income have been recorded for the first three 
quarters in 2019. 2018 information has not been restated due to immateriality of amounts. 

in thousands of GEL 
Net gains from currency swaps 

4Q’19
9,054

3Q’19
8,355

2Q'19
6,967

1Q19
4,179

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

123

 
diversity were key areas of focus for the Board again this 
year.    I  am  pleased  to  report  that  Arne  Berggren,  an 
independent non-executive Director has joined our Board 
and, Eric Rajendra has rejoined us as an independent non-
executive Director  following his recovery from a period of 
illness. I am also pleased to report that Arne Berggren and 
Eric  Rajendra  bring  extensive  banking  and  financial 
services  experience,  which  will  serve  to  ensure  that  the 
Board  is  well  placed  to  function  effectively  and  take 
opportunities which present themselves to us in the year 
ahead. The Board and Committee changes over the past 
year are set out in further detail in the Corporate Governance 
and Nomination Committee report on pages 143-146 .

An important part of my role as Chairman is to ensure that 
the  Board  and  its  individual  members  operate  effectively 
and  that  the  Board  environment  enables  a  culture  of 
openness,  debate  and  high-quality  decision  making.  The 
Board is collectively responsible for overseeing delivery of 
the  Group’s  strategy  and  has  a  significant  role  to  play  in 
determining that the Group’s culture, values, strategy and 
business model are all aligned in order to create sustainable 
value  for  our  shareholders  and  takes  into  account  the 
interests of all our stakeholders. A summary of our strategy 
is  outlined  on  pages  12-19  and  how  we  impact  on  our 
stakeholders is described on pages 52-55. 

In accordance with the UK Corporate Governance Code (the 
“Code”),  all  directors  will  be  subject  to  re-election  by 
shareholders at our Annual General Meeting.

Nikoloz Enukidze
Chairman
                                                                                      28 April 2020

DIRECTORS’ GOVERNANCE STATEMENT

CHAIRMAN’S GOVERNANCE OVERVIEW

Dear shareholders,
As the Chairman of the Board, I am pleased to present our 
corporate governance report for 2019.  Our aim is to ensure 
that our governance is fit for purpose and in line with best 
practice. We remain firmly of the view that strong governance 
should  prevail  throughout  our  business  and  that  a  sound 
corporate  governance  framework  is  vital  to  ensure  our 
business  functions  effectively,  while  at  the  same  time 
creating long-term, sustainable value for our shareholders 
and  taking  into  account  the  needs  of  our  other  key 
stakeholders.

2019  was  a  challenging  year  for  the  Board.  Following  the 
departure of the former Chairman and Deputy Chairman, a 
number of changes were made to the boards of the Company 
and its main subsidiary JSC TBC Bank (the “Bank”). We have 
implemented a Mirror Board governance structure, with all 
non-executive  Directors  of  the  Board  also  becoming 
members  of  the  Supervisory  Board  of  the  Bank.  You  can 
read  the  full  details  about  the  Board  and  Committee 
restructuring and composition in the Corporate Governance 
and Nomination Committee report on pages 143-146. 

We continue to firmly believe that a successful and properly 
functioning  Board  requires  the  right  balance  of  skills, 
including  country-specific  knowledge,  and  diversity  of 
experience  and  perspectives 
to  achieve  maximum 
effectiveness. For this reason, composition of the Board and 

124

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

CORPORATE GOVERNANCE FRAMEWORK
The Group’s corporate governance framework provides shareholders with an explanation of how the Company has applied 
the main principles of the Code as relevant to the Company in 2019 and the Group’s approach to governance in practice, the 
work of the Board and its committees.

COMPLIANCE STATEMENT
As a premium-listed company on the LSE, the Company complies with the Code.

At the date of this report, the Company has applied the principles and complied with the provisions set out in the Code issued 
by  the  Financial  Reporting  Council  (“FRC”)  in  July  2018  in  full  throughout  2019.  In  particular,  the  Board  has  considered 
the changes made to the 2018 Code and the increased focus required upon a company’s purpose, culture and stakeholder 
engagement. The Code can be found on the FRC website www.frc.org.uk.

THE BOARD
The Board is collectively responsible for promoting the Group’s purpose, culture, values and long term success strategy and 
the delivery of sustainable value to stakeholders by establishing and overseeing the strategic direction of the Company and 
its business. The directors are aware of their duties under section 172 of the Companies Act 2006 and further insight into how 
the Board took account of the views and interests of our stakeholders can be found on pages 52-55.

The  Board  is  led  by  the  Chairman  and  provides  challenge,  oversight  and  advice  to  ensure  the  Company’s  success.  The 
Chairman ensures that there is constructive debate in the boardroom in order to create and maintain an environment where 
the Board remains open to different viewpoints and ideas.

The Board is the decision-making body in relation to all matters that are significant to the Group. There is a formal schedule 
of matters reserved for the Board’s approval in place to ensure that the Board retains control over key decisions. The matters 
exclusively  reserved  for  the  Board’s  approval  include,  among  other  things,  approval  of  the  Group’s  strategy,  long-term 
objectives, risk appetite, the annual operating and capital expenditure budgets, changes to the Group’s capital, share buy-
backs, major acquisitions and/or mergers, annual reports and accounts. The full document is available on the website at 
www. tbcbankgroup.com.

During the year ended 31 December 2019, the Board considered a wide range of matters, including:

 ` the strategic development of the Group;
 ` performance of key business units;
 ` the consolidated budget and the underlying business unit budgets;
 ` the interim and full year results;
 ` payment of a dividend;
 ` the appropriateness of the going concern basis of financial reporting;
 ` the assumptions and stress testing applied to preparing the Company’s viability statements;
 ` investment project proposals and expansions into new territories;
 ` changes to various board Committees and the appointment of new directors; and
 ` a review of the findings of the internally facilitated Board evaluation exercise and the action plans resulting there from.

The principal decisions taken by the Board during 2019, and the impact that these had on various stakeholders are detailed below:

Decision: 

2020 Business Plan and Budget

Context

Stakeholder
considerations 

The  Business  Plan  and  Budget  sets  the  annual  targets  and  the  costs  of  the  necessary 
resources to achieve these targets.  It is developed in line with the overall strategy of the 
Group and takes into account any specific challenges faced by the business. This includes 
any  stakeholder  related  considerations.  The  Chief  Executive  Officer,  supported  by  key 
members of management, presents the Business Plan and Budget for the Board’s challenge 
and approval. Key senior management responsible for the key business units attend and 
present their budget to the Board.

In reviewing the Business Plan and Budget, the Board considered the potential impact that 
each operation and project might have on its stakeholders (employees, local communities, 
government and regulators, contractors & suppliers, shareholders and customers) and 
the environment.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

125

DIRECTORS’ GOVERNANCE STATEMENT CONTINUED

Decision: 

2020 Business Plan and Budget

Strategic Actions
Supported by the Board

The strategic actions of the Business Plan and Budget supported by the Board to generate 
value for stakeholders are:

 ` continued geographic expansion into other jurisdictions in the region;
 ` further system and process enhancements based on the agile system to increase efficiency 

and improve control;

 ` wider use of digital banking technology to benefit customers;
 ` continuing high standards of corporate governance and adherence to regulations;  and
 ` approval  of  investment  plans,  generating  new  products  and  businesses  that  provide 
additional  employment  opportunities,  enhanced  customer  services  and  supplier 
opportunities.

Impact of these actions
on the long-term success
of the Company

The Business Plan and Budget creates a balance between current operating performance 
and considerations that matter to all stakeholders in the short and long-term such as 
health  &  safety,  environmental  performance  and  community  relations.  In  addition  a 
wider range of client products will become available to customers in Georgia and other 
jurisdictions across the region.

Outcome

Decision:

Context

In December 2019 the Board discussed and approved the 2020 Business Plan and Budget.  

Share buy back

Following a reduction in the share price, the Board reviewed and considered whether to 
take advantage of the powers given to it by shareholders to repurchase up to 10% of the 
company’s issued share capital. 

Stakeholder
considerations

The Board determined that, as a result of the reduction in share price, it was to the benefit 
of shareholders to put into place a short term share buyback programme.

Strategic Actions
Supported by the Board

The share buyback programme was implemented in order to:
 ` support the share price; and
 ` make treasury stock available to satisfy employee long term share plans. 

Impact of these actions
on the long-term success
of the Company

The Board actioned the share purchase programme, for a period of time and purchased 
144,380  shares  at  an  aggregate  value  of  £  1,967,133  (which  does  not  include  trade 
commission). The repurchased shares were held in treasury, and then transferred to the 
Employee Benefit Trust. 

BOARD COMMITTEES
The Board is supported by its committees (the “Committees”) and delegates a broad range of responsibilities to them, while 
maintaining the effective links between the Committees and the Board where required. The Board has four Committees: (i) the 
Audit  Committee;  (ii)  the  Remuneration  Committee;  (iii)  Corporate  Governance  and  Nomination  Committee;  and  (iv)  the  Risk 
Committee. The chair of each Committee reports matters of significance to the Board after each meeting. Each of the Committees 
is made up of independent non-executive Directors, apart from the Corporate Governance and Nominations Committee and the 
Remuneration Committee, where the Chairman, who was independent on appointment, is also a member.

All Committees undertake an annual review of effectiveness and a review of their terms of reference. 

The detailed roles and responsibilities of the Committees are set out in their terms of reference, which can be found on our website 
at www.tbcbankgroup.com.

126

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

CORPORATE GOVERNANCE STRUCTURE 
Board of Directors
Membership

Audit Committee

Remuneration
Committee

Corporate Governance 
and Nomination Committee

Risk Committee

Outside Directors

Nikoloz Enukidze

Nicholas Dominic Haag (SID)

Maria Luisa Cicognani

Tsira Kemularia

Arne Berggren 

Eric Rajendra

  Chairperson 

  Member

DIVISION OF RESPONSIBILITIES
There is a clear division of responsibilities between the Chairman, the Chief Executive Officer and the senior independent 
non-executive Director. As Chairman, Nikoloz Enukidze is responsible for leading the Board to ensure that the Board as 
a whole performs a full and constructive role in the development and determination of the Group’s strategy and overall 
commercial  objectives.  He  also  oversees  the  Board’s  decision-making  processes.  The  Chief  Executive  Officer,  Vakhtang 
Butskhrikidze, is responsible for the Company’s day-to-day management and has the principal responsibility of running the 
Group’s business. He is responsible for proposing, developing and implementing the Group’s strategy and overall commercial 
objectives, which is done in close consultation with the Chairman and the Board. In addition, the Board has appointed, in line 
with the requirements of the Code, Nicholas Haag as the new senior independent non-executive Director, who provides a 
sounding board for the Chairman. He serves as an intermediary for the other Directors where necessary and meets with 
investors to discuss the Group’s corporate governance matters. This separation of responsibilities between the Chairman, 
the Chief Executive Officer and the senior independent non-executive Director ensures that no one individual has unfettered 
powers of decision-making. The full document detailing the division of responsibilities between the Chairman, the Chief 
Executive Officer and the senior independent non-executive Director is available on our website at www.tbcbankgroup.com.

BOARD COMPOSITION
In accordance with the Code, the majority of the Board are independent non-executive Directors. At the date of this report, the 
Board is comprised of a Chairman (Nikoloz Enukidze), two executive Directors (Vakhtang Butskhrikidze and Giorgi Shagidze) 
and five independent non-executive Directors (Nicholas Haag (SID), Maria Luisa Cicognani, Tsira Kemularia, Arne Berggren 
and Eric Rajendra).  

Non-executive Directors constructively challenge and scrutinise the performance of management and help develop proposals 
on strategy. In 2019, as mentioned previously, there were changes in composition of the Board and details of these changes 
are set out in the Corporate Governance and Nomination Committee report.

The Board has considered the independence of the Company’s non-executive Directors as against the factors described in 
the Code and has determined that all non-executive Directors are independent in character and judgement.

Each non-executive Director has an ongoing obligation to inform the Board of any circumstances that could impair their independence.

Nikoloz Enukidze was considered to be independent on appointment to the Board and on taking up the role of Chairman. The 
Board is unanimously of the opinion that Mr Enukidze is an extremely valuable asset to the Company, bringing a wealth of 
experience in Georgia’s banking sector, and that it is, therefore, in the Company’s best interests that he should continue as 
the Chairman of the Company.

Details of the individual Directors and their biographies are set out on pages 136-139.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

127

 
DIRECTORS’ GOVERNANCE STATEMENT CONTINUED

TIME COMMITMENT
Each non-executive Director is required to devote such time as necessary for the effective discharge of their duties. This 
includes  attendance  at  Board  meetings  and  respective  Committees  meetings  of  which  they  are  members,  as  well  as 
scheduled away days, site visits, conference calls and email communication. Non-executive Directors consider all relevant 
materials prior to each meeting and commit additional time to the Company when it is undergoing a period of particularly 
increased activity.

BOARD AGENDA 
The Chairman is responsible for setting the Board agenda. Every Board meeting follows a tailored agenda agreed in advance 
by the Chairman. Prior to each meeting the Chairman reviews and discusses key items of business with the Chief Executive 
Officer. Board agendas are sent to Board members well in advance of meetings and are structured in such a way as to allow 
adequate time for discussion of each item on the agenda.

The Board recognises the need to prioritise time to focus on material strategic and business matters, while ensuring monitoring and 
oversight of all other key matters within its remit. 

The Board and Committees rely on the management to raise relevant items for approval. The processes of agenda setting 
and reporting to the Board are reviewed as part of the Board performance evaluation.  During the Board meetings, there 
is also an extra day allocated for strategic sessions. This provides an opportunity for the Directors to focus exclusively on 
strategy  and  gain  deeper  insights  by  hearing  from  relevant  business  line  heads  within  the  Group,  asking  questions  and 
debating matters in an informal way. 

BOARD AND COMMITTEE MEETING ATTENDANCE
In 2019, the Company held 9 scheduled and 24 additional meetings. Moreover, the Chairman and the Chief Executive Officer 
maintain  frequent  contact  (in  person  or  otherwise)  with  each  other  and  the  other  Board  members  throughout  the  year 
outside of the formal meetings.

In addition, the affairs of the Company’s main subsidiary, the Bank, are supervised by the Supervisory Board with the same 
membership as the  Board. There is also an equivalent committee structure and composition of the Supervisory Board as 
the committee structure at the Board. There are therefore, in practice, two equivalent supervisory bodies within the Group 
represented by the Board and the Supervisory Board, which are separate but interconnected together with their respective 
committees. However, the work of the Board, the Supervisory Board and their respective committees is carefully balanced, 
dividing functions according to whether they are supervising the topics that impact the Company or solely the Bank.

Attendance of meetings of the Board and the Committees in 2019 are set out below: 

Board Attendance

Vakhtang Butskhrikidze 
(Chief Executive Officer)

Giorgi Shagidze 
(Chief Financial Officer)
Non-Executive Directors
Nikoloz Enukidze
(Chairman)
Mamuka Khazaradze
(former Chairman)
Badri Japaridze
(former Deputy Chairman)
Nicholas Dominic Haag
Maria Luisa Cicognani 
Tsira Kemularia
Eric Rajendra
Arne Berggren

Board meetings
eligible to attend/
attended

Audit Committee 
meetings eligible to 
attend/attended

Remuneration 
Committee meetings 
eligible to attend/
attended

Corporate Governance and 
Nomination Committee  
meetings eligible
to attend/attended

Risk Committee  
meetings eligible to 
attend/attended

40/40

40/40

40/40

24/23

24/23

40/36
40/38
40/38
13/13
11/11

0/0

0/0

11/11

0/0

0/0

14/14
14/14
3/3
9/9
3/3

0/0

0/0

10/10

0/0

0/0

10/9
10/10
0/0
5/4
0/0

0/0

0/0

11/11

0/0

5/5

5/5
0/0
11/11
3/3
0/0

0/0

0/0

4/4

0/0

0/0

7/7
7/7
7/7
2/2
3/3

128

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Attendance of meetings of the Supervisory Board and its committees in 2019 are set out below:

Supervisory Board Attendance

Mamuka Khazaradze
(former Chairman)
Vakhtang Butskhrikidze 
(Chief Executive Officer)
Giorgi Shagidze 
(Chief Financial Officer)
Badri Japaridze 
(former Deputy 
Chairman)
Eric Rajendra 
Nikoloz Enukidze
(Chairman) 
Nicholas Dominic Haag
Maria Luisa  Cicognani  
Tsira Kemularia
Jyrki Kosleko
Arne Berggren

Supervisory Board 
meetings eligible
to attend/attended

Audit Committee 
meetings eligible to 
attend/attended

Remuneration 
Committee meetings 
eligible to attend/
attended

Corporate Governance and 
Nomination Committee  
meetings eligible to attend/
attended

Risk Committee  
meetings eligible to 
attend/attended

9/7

0/0

0/0

9/9

7/7

56/56

56/55
56/53
56/56
12/10
21/21

0/0

0/0

0/0

0/0

2/2

10/10

13/13
13/13
13/13
0/0
3/3

0/0

0/0

0/0

0/0

10/10

8/8

8/8
3/3
8/8
0/0
0/0

0/0

0/0

0/0

2/2

2/2

8/8

2/2
0/0
8/8
0/0
0/0

0/0

0/0

0/0

0/0

4/4

15/15

20/20
20/20
20/20
0/0
5/5

DIVERSITY POLICY
The Board recognises the importance of ensuring diversity and sees significant benefit to our business in having a Board 
and management team that is drawn from a diverse range of backgrounds, since this brings the required expertise, cultural 
diversity and different perspectives to the Board discussions and helps to improve the quality of decision making. 

Detailed information on our diversity policy could be found in Corporate Governance and Nomination Committee report on 
pages 143-146. 

INDUCTION AND TRAINING
A formal induction is arranged for newly appointed directors based on the individual’s need, skills and experience. Typically, 
these included a series of meetings with the Chairman and other directors and senior executives, as well as local site visits to 
provide familiarity with the business. During the year, there was one  new appointment to the Board and its Committees. The 
induction process for Arne Berggren included an on-site business introduction, followed by meetings with executives and key 
business unit managers and an introduction to the operations, risks, and governance environment of the Group. In addition, 
Arne Berggren received training on his duties as directors of a listed company including the recent changes made to the Code, 
at the offices of Baker McKenzie LLP, the Company’s external counsel.

Moreover, the Chairman takes responsibility to ensure that the Board is updated in a timely manner about the Company’s 
performance, to enable it to make proper decisions. The Chairman ensures information exchanges between the Board, the 
Committees and executives. If there is a need for independent advice, the Board can seek it directly at the Company’s expense.

Members of the Board are required to complete a self-assessment process at the end of the year, where the members of the 
Board can identify a relevant development programme.

ANNUAL BOARD EFFECTIVENESS EVALUATION
An internally facilitated annual Board performance evaluation was conducted in 2019, following an externally evaluated review 
undertaken by Independent Audit Limited in 2018 (IAL). The review was carried out at the initiative and with the participation 
of the Company’s Corporate Governance and Nomination (“CGN”) Committee. Questionnaires were distributed to all Board 
directors for their response and comment. The results were discussed at three levels: (i) among the members of the CGN 
Committee;  (ii)  between  Tsira  Kemularia  (as  Chairman  of  the  CGN    Committee)  and  Nikoloz  Enukidze    Chairman  of  the 
Board); and (iii) among the members of the Board as a whole. Following the review the SID met with all the Board members 
individually to consider the Chairman’s performance.  The comments received were fed back to him subsequently meeting.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

129

DIRECTORS’ GOVERNANCE STATEMENT CONTINUED

Board  performance  was  deemed  to  be  satisfactory.  At 
its  February  2020  meeting,  the  Board  agreed  an  action 
plan  for  2020  that  would  allow  the  Board  to  continue 
developing  its  involvement  in  reviewing  and  considering 
the  management’s  strategy  proposals  and  to  take  into 
account  stakeholder  considerations;  and  to  ensure  that 
all  Board  and  Committee  meetings  remain  focused  and 
efficient.  New  initiatives  will  be  introduced  to  support 
director  training,  and  the  CGN  Committee  will  continue 
to  review  senior  management  succession  plans  in  great 
detail. 

As a result of the 2019 action plan, approved by the Board 
in February 2019, following the external evaluation by IAL, 
the  Board  noted  that  its  members  had  spent  more  time 
considering  the  Group’s  strategy  plan  and  investment 
proposals arising from it, and more focus has been made 
on succession planning for senior executives. In addition, 
information  flows  to  both  the Board  and  its  Committees 
had  been  improved  and  a  restructuring  of  Committee 
memberships had assisted in this. 

The  Company  undertakes 
performance 
evaluations  of  the  Board  in  line  with  the  requirements 
of  the  UK  Corporate  Governance  Code.    An  externally 
facilitated review is planned for 2021.

regular 

DIRECTORS’ COMMITMENTS
The Directors are required to disclose to the Board their 
external appointments or other significant commitments 
prior  to  their  appointment.  Should  these  appointments 
change during their tenure, the Directors are required to 
disclose those changes and conflicts that might arise will 
be considered and approved by the Board.

Each  non–executive  Director  is  required  to  devote  such 
time  as  is  necessary  for  the  effective  discharge  of  their 
duties.  Whilst  the  non-executive  Directors  hold  external 
directorships  or  other  external  positions,  the  Board 
believes  they  still  have  sufficient  time  to  devote  to  their 
duties  as  a  Director  of  the  Company  and  that  the  other 
external directorships/positions held provide the Directors 
with valuable expertise which enhances their ability to act 
as a non-executive Director of the Company. No significant 
changes  to  the  commitments  of  the  Chairman  or  non-
executive Directors were identified during the year 2019.

RE-ELECTION OF DIRECTORS
As mentioned above, all Directors are subject to annual re-
election by shareholders at the Annual General Meeting, 
in  accordance  with  the  Code.  Biographical  details  of  the 
Directors are included on pages 136-139.

REMUNERATION COMMITTEE
Information on the Remuneration Committee is included 
in the Directors’ Remuneration report on pages 151 to 179.

ENGAGEMENT WITH STAKEHOLDERS
Effective communication with shareholders is given high 
priority by the Board. The Chief Executive Officer and the 
Chief Financial Officer, together with Chairman and Senior 
Independent  Director,  maintain  very  close  engagement 
with  the  Company’s  major  shareholders.  They  have 
participated in  roadshows across numerous geographic 
locations  to  promote  the  awareness  and  understanding 
of  the  Group’s  business.  In  addition  to  roadshows,  the 
Bank’s senior executive team and Directors were involved 
in  hosting  a  capital  markets  day  in  London.  They  also 
hold regular investor calls and also conduct face-to-face 
meetings with investors visiting Georgia and take an active 
part  in  government  events  abroad  aimed  at  increasing 
investor confidence in the economic stability of the country 
and its sustainable development.

The Company has a dedicated investor relations section on 
its website, which contains information on all disclosures 
made to the market, including results presentations and 
annual reports.

All announcements issued to the LSE are available on the 
Group’s website at www.tbcbankgroup.com. 

Moreover,  any  shareholders  of  the  Company,  potential 
investors and analysts are able to ask questions about the 
Group through the Company’s permanent representative 
in London, who is always available for investor meetings 
and updates relating to investor relations and international 
media  on  behalf  of  the  management  team.  The  Chief 
Executive  Officer,  Chairman  and  Senior  Independent 
Director  are  also  available  to  discuss  the  concerns  of 
shareholders at any point during the year.

Details on our engagement with the stakeholders can be 
found on pages 52-55.

ANNUAL GENERAL MEETING
The last Annual General Meeting (“AGM”) of the Company 
was held on 24 June 2019 at the offices of Baker McKenzie, 
100  New  Bridge  Street,  London.  82.35%  of  total  voting 
rights were exercised by shareholders. All resolutions put 
to shareholders were passed with votes in favour ranging 
from 89.69% to 100.0% of the votes cast.    

The  2020  AGM  Notice  will  be  circulated  to  all  the 
shareholders  at  least  21  working  days  before  the  AGM 
and it will also be made available on our investor relations 
website:  www.tbcbankgroup.com.  The  voting  on  the 
resolutions  will  be  announced  via  the  Regulatory  News 
Service  and  made  available  on  our  investor  relations 
website www.tbcbankgroup.com.

130

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

DIRECTORS’ REPORT

DIRECTORS’ REPORT
The Directors present their Annual Report together with the audited consolidated accounts for the year ended 31 December 
2019, which can be found on pages 191-318.

The Strategic Report on pages 2 to 123 was approved by the Board on 28 April 2020 and signed on its behalf by Vakhtang 
Butskhrikidze, the Company’s Chief Executive Officer.

The Management Report together with the Strategic Report on pages 2 to 123 form the Management Report for the purposes 
of DTR 4.1.5. R.

Other information that is relevant to the Directors’ Report and incorporated by reference into this report can be located as follows:

Contents

Directors’ governance statement 
Corporate Governance and Nomination Committee report 
Risk Committee report
Audit Committee report
Remuneration Committee report
Viability statement 
Going concern statement 
Greenhouse gas emissions
Risk management 
Material existing and emerging risks
Board of Directors  
Employee matters
Environmental matters
Share capital
Future developments in the business
Disclosures required under Listing Rule 9.8.4: 
Details of long-term incentive schemes
Agreements with controlling shareholders
Information on the Group’s financial risk management and
its exposure to credit risk, liquidity risk, interest rate risk and foreign currency risk
Events after reporting period
Section 172 Statement
Employee engagement
Stakeholder engagement on key decisions

Page

124
143
147
180
151
134
134
73
93
84
136
60
72
269
14

175
132

285

317
52
52
52

DIRECTORS’ CONFLICTS OF INTERESTS
The Company, in accordance with the requirements of the Companies Act 2006 and the Company’s articles of association 
(the “Articles of Association”), requires Directors to declare actual or potential conflicts of interest that could interfere with 
the interests of the Company. The Directors are required, prior to the Board meetings, to declare any conflict of interest they 
may have in relation to the matters under consideration and, if so, abstain from voting and decision-making, in relation to 
the matter in question. 

Directors  have  a  continuing  duty  to  notify  the  Chairman  and  Company  Secretary  as  soon  as  they  become  aware  of  any 
potential or actual conflicts.

DIRECTORS’ INDEMNITIES AND INSURANCE 
The Group maintains directors’ and officers’ liability insurance, which gives appropriate cover for legal action brought against 
its Directors. The Company has also granted indemnities to each of its Directors to the extent permitted by law. Neither the 
indemnity nor insurance cover provides cover in the event that a Director, officer or company secretary is proved to have 
acted fraudulently or dishonestly. The above referred liability insurance and indemnities were in force during the course of 
the financial year ended 31 December 2019 and remain in force as at the date of this report.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

131

DIRECTORS’ REPORT CONTINUED

POLITICAL DONATIONS 
The  Group  did  not  make  any  political  donations  or  incur 
any political expenditure during 2019. 

Details  of  the  movements  in  share  capital  during  the 
year are provided in Note 26 to the consolidated financial 
statements on page 269 of this Annual Report.

RELATIONSHIP AGREEMENT 
On 31 May 2016, the Company entered into a relationship 
agreement  with  Mamuka  Khazaradze,  Badri  Japaridze, 
Vakhtang Butskhrikidze, Temur Japaridze, Bob Meijer and 
David  Khazaradze  (together  the  “Presumed  Concerted 
Party Group”) (the “Relationship Agreement”) to regulate 
the degree of control that the members of the Presumed 
Concerted Party Group and their associates may exercise 
over the Group’s management and business. The principal 
purpose of the Relationship Agreement is to ensure that 
the Company and its subsidiaries are capable at all times 
of carrying on their business independently of members of 
the Presumed Concerted Party Group and their associates. 

Although neither Mamuka Khazaradze nor Badri Japaridze 
are directors of the Company or any other member of the 
Group,  the  Relationship  Agreement  continues  to  provide 
certain protections for the Group from how they and the 
other members of the Presumed Concerted Party Group 
might  act  with  respect  to  the  Group  as  shareholders  or 
otherwise. Specifically, under the Relationship Agreement, 
for  as  long  as  it  remains  in  force,  the  members  of  the 
Presumed Concerted Party Group shall, and have agreed 
that  each  of  their  associates  shall,  when  acting  in  a 
capacity (which could include as a shareholder or director) 
with any member of the Group, amongst other things:

 ` conduct  all  transactions  and  arrangements  entered 
into  between  any  member  of  the  Group  (on  the  one 
hand)  and  that  member  of  the  Presumed  Concert 
Party Group and/or his associates (on the other) on an 
arm’s length basis and on normal commercial terms 
and  in  accordance  with  the  related-party  transaction 
rules set out in the Listing Rules; 

 ` not  take  any  action  that  would  have  the  effect  of 
preventing  the  Company  from  complying  with  its 
obligations under the Listing Rules; and/or 

 ` not propose or procure the proposal of any resolution 
of the shareholders which is intended, or appears to be 
intended, to circumvent the proper application of the 
Listing Rules.

SHARE CAPITAL 
As of 28 April 2020, the Company’s issued ordinary share 
capital  comprised  55,155,896  ordinary  shares  with  a 
nominal amount of £0.01 each and carrying one vote per 
ordinary share at general meetings of the Company. There 
were no shares held in treasury. The Company has in issue 
one  class  of  ordinary  shares,  all  of  which  are  fully  paid 
up, and it does not have preference shares in issue. The 
rights and obligations attaching to the Company’s ordinary 
shares are set out in the Articles of Association. There are 
no  voting  restrictions  on  the  issued  ordinary  shares  and 
each ordinary share carries one vote.

132

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

PROFIT AND DIVIDENDS
The profit for the financial year ending 31 December 2019 
attributable to the Company’s shareholders, after taxation, 
amounts to GEL 537,895,000. The Board is not planning to 
recommend payment of a dividend.

POWERS OF DIRECTORS
The  Directors  may  exercise  all  powers  of  the  Company 
subject to applicable laws and regulations and the Articles 
of Association.

SPECIAL RIGHTS AND TRANSFER 
RESTRICTIONS

None of the ordinary shares in the capital of the Company 
carry  special  rights  with  regard  to  the  control  of  the 
Company. There are no specific restrictions on transfers 
of shares in the Company, which is governed by its Articles 
of Association and prevailing legislation, other than: 

 ` certain  restrictions  which  may  from  time  to  time  be 
imposed by laws or regulations such as those relating 
to insider dealing; 

 ` pursuant to the Group’s Share Dealing Code, whereby 
the  Directors  and  designated  employees  require 
approval to deal in the Company’s shares; 

 ` where  a  person  with  an  interest  in  the  Company’s 
shares has been served with a disclosure notice and 
has  failed  to  provide  the  Company  with  information 
concerning interests in those shares; and 

 ` pursuant 

to 

the  Group’s  Senior  Management 
Compensation  System,  whereby  Participants  (as 
defined  therein)  may  be  granted  restricted  share 
awards, which vest subject to continuous employment 
and malus and clawback provisions over three years 
from the award date.

All  employees  (including  Directors)  that  are  deemed 
by  the  Company  to  be  insiders  have  complied  with  the 
Group’s  Share  Dealing  Code.  There  are  no  restrictions 
on  exercising  voting  rights  save  in  situations  where  the 
Company is legally entitled to impose such a restriction (for 
example, under the Articles of Association where amounts 
remain unpaid in the shares after request, or the holder 
is otherwise in default of an obligation to the Company). 
The Company is not aware of any arrangements between 
shareholders that may result in restrictions on the transfer 
of securities or voting rights.

MAJOR SHAREHOLDERS 
As at 31 December 2019, the Company had been notified 
under Rule 5 of the Disclosure Guidance and Transparency 
Rules of the Financial Conduct Authority (the “DTRs”) of the 
following interests in its total voting rights of 3% or more.

As of 31 December 2019 

Shareholder 
Mamuka Khazaradze 
Badri Japaridze 
European Bank for Reconstruction and Development 
Dunross &Co
Schroder Investment Management
JPMorgan Asset Management
Creation Investments Capital Management 

% of voting rights 
10.26% 
6.00% 
8.04%
6.61%
6.48%
6.22%
3.00% 

# of voting rights 
5,658,048 
3,308,616 
4,436,406
3,647,918
3,571,864
3,430,002
1,652,388 

Subsequent to the year end, JPMorgan Asset Management notified the Company in accordance with DTR5 of an indirect 
holding of 3,435,378 ordinary shares, representing 6.23% of the Company’s issued share capital.  Also, Schroders Investment 
Management notified the Company in accordance with DTR5 of an indirect holding of 3,004,261 ordinary shares, representing 
5.45% of the Company’s issued share capital and Mamuka Khazaradze notified the Company in accordance with DTR5 of 
an  indirect  holding  of  4,863,048  ordinary  shares,  representing  8.82%  of  the  Company’s  issued  share  capital.  In  addition, 
Dunross&Co notified the Company in accordance with DTR5 of an indirect holding of 3,894,434 ordinary shares, representing 
7.06%  of  the  Company’s  issued  share  capital.  Future  regulatory  filings  by  shareholders  will  be  available  on  the  Group’s 
website at www.tbcbankgroup.com and the LSE website at www.londonstockexchange.com.

POWERS OF DIRECTORS TO ISSUE AND/OR BUY BACK COMPANY SHARES 
The Companies Act 2006 and the Articles of Association determine the powers of Directors, in relation to share issues and 
buy backs of shares in the Company. The Directors are authorised to issue and allot shares subject to approval at a general 
meeting of shareholders. Such authorities were granted to the Directors by shareholders at the Annual General Meeting of 
the Company, held on 24 June 2019, authorising the Directors to allot ordinary shares in the capital of the Company up to an 
aggregate nominal value of £ 182,865. 

This authority will apply until the conclusion of the 2020 AGM. Shareholders will be requested to renew these authorities at 
the 2020 AGM.

On 29 July 2019, the Company launched a share buy-back program and repurchased 144,380 Ordinary Shares of the Company 
that were held in Treasury and later transferred to TBC Bank Group PLC Employee Benefit Trust (the “EBT”).  EBT will use 
these shares to satisfy obligations arising from the TBC Bank Group PLC Deferred Share Plan (the “Deferred Share Plan”), 
the TBC Bank Group PLC Long Term Incentive Plan and other share awards granted to employees.

APPOINTMENT / REPLACEMENT OF DIRECTORS AND AMENDMENT OF ARTICLES
OF ASSOCIATION 
The appointment and retirement of Directors is governed by the Articles of Association, the Code and the Companies Act 
2016 and related legislation.

Shareholders  are  authorised  to  appoint/replace  the  Directors  and  make  amendments  to  the  Articles  of  Association  by 
resolution at a general meeting of the Company with the latter being required to be passed as a special resolution. 

All of the Directors will stand for annual re-election at the Annual General Meeting. As already mentioned, Arne Berggren and 
Eric Rajendra were appointed to the Board as non-executive Directors in 2019 and will stand for election by the shareholders 
at the Annual General Meeting. Vakhtang Butskhrikidze and Giorgi Shagidze have service contracts with the Company, which 
came into effect on 10 August 2016 and will continue until terminated by either party to such contracts, giving the other not 
less than seven months written notice. Biographical details and reasons for the reappointment for the Directors are given in 
the Notice of AGM.

CHANGE OF CONTROL 
There are no significant agreements to which the Company is a party of that take effect, alter or terminate upon a change of control 
of  the  Company.  In  addition,  there  are  no  agreements  between  the  Company  and  its  employees  and  the  Directors  that  contain 
compensation clauses for loss of office or employment that occurs because of a takeover bid, resulting in a case of change of control. 

EMPLOYEE DISCLOSURES 
The Company’s disclosures relating to the employee engagement and policies, as well as human rights, are included in the 
“Our Colleagues” section on pages 60 to 67 of this Annual Report. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

133

DIRECTORS’ REPORT CONTINUED

DISCLOSURE OF INFORMATION
TO THE AUDITOR 
The  Directors,  who  held  office  at  the  date  of  approval 
of  this  Annual  Report,  confirm  that,  so  far  as  they  are 
aware,  there  is  no  relevant  audit  information  of  which 
the Group’s auditors are unaware, and that each Director 
has  taken  all  steps  that  he/she  reasonably  should  have 
taken  as  a  Director  in  order  to  make  him/herself  aware 
of  any  relevant  audit  information  and  to  establish  that 
the  Company’s  statutory  auditors  are  aware  of  such 
information.  This  confirmation  is  given  and  should  be 
interpreted  in  accordance  with  the  provisions  of  section 
418 of the Companies Act 2006.

GOING CONCERN STATEMENT 
The  Board  has  fully  reviewed  the  available  information 
pertaining to the principal risks, strategy, financial health, 
liquidity and solvency of the Group, and determined that 
the  Group’s  business  remains  a  going  concern.  The 
Directors  have  not  identified  any  material  uncertainties 
that  could  threaten  the  going  concern  assumption  and 
have a reasonable expectation that the Company and the 
Group  have  adequate  resources  to  remain  operational 
and  solvent  for  the  foreseeable  future  (which  is,  for 
this  purpose,  a  period  of  12  months  from  the  date  of 
approval  of  these  financial  statements).  Accordingly,  the 
Group’s and the parent company’s consolidated financial 
statements  are  prepared  in  line  with  the  going  concern 
basis of accounting.

VIABILITY STATEMENT 
In  compliance  with  the  Code,  the  Directors  assessed 
the prospects of the Group and its viability over a three-
year  period  beginning  on  1  January  2020.  The  Directors 
determined  the  three-year  period  ending  on  1  January 
2023 to be appropriate, as it is consistent with the Group’s 
planning  cycle,  covering  financial  forecasts  and  the 
strategic  considerations  of  the  Group.  While  assessing 
the viability of the Group and its operations, the Directors 
carried  out  a  robust  and  thorough  assessment  of  the 
Group’s  risk  profile,  including  all  material  existing  and 
emerging risks that could cause a deviation in the Group’s 
financial  condition,  operations  and  prospects  from  the 
expectations  over  the  period  of  assessment.  As  part  of 
their strategic planning, the Directors looked beyond this 
period  and  took  into  consideration,  as  far  as  possible, 
information  from  a  variety  of  sources  relating  to  local, 
regional  and  other,  broader  macro-economic,  political, 
technological,  social  and  environmental  changes  which 
could  impact  the  Group’s  business  and  development.  At 
this  point,  the  Directors  have  no  reason  to  believe  that 
the  Group  will  not  stay  viable  over  the  longer-term.  In 
addition, the Directors analysed the Group’s ability to meet 
all  regulatory  requirements.  The  Directors’  assessment 
considered all of the principal and emerging risks of the 
Group  and  the  effectiveness  of  current  and  proposed 
mitigating actions. The key areas of focus were: 

 ` the  risk  of  economic  and  political  instability  and  its 

impact on the Group’s future performance;

 ` the risk of not meeting regulatory requirements, with a 

key focus on minimum capital adequacy ;

 ` foreign exchange rate risk, which is significant due to 

the high dollarisation of the Group’s portfolio;

 ` the  regulatory  risk  that  derives  from  the  significant 

regulatory changes within the last two years;

 ` the  risk  of  decreasing  net  interest  income  and  net 
interest  margin  as  a  result  of  new  regulations, 
increased competition and funding structure; and
 ` increased reputational risk  related to  the  Company’s 

founders’ media exposure. 

In  addition  the  directors  have  undertaken  a  detailed 
review of the impact of the COVID-19 virus and the Group’s 
viability.  A  summary  of  all  of  the  material  existing  and 
emerging risks the Group is exposed to and the mitigating 
actions taken by the Group are set out on pages 84 to 92.

The Group’s strategic plans 
While  reviewing  and  analysing  the  Group’s  strategic 
plans,  the  Directors  assessed  all  potential  risks  related 
to the strategic plans and the achievement of the Group’s 
strategic  objective,  and  ensured  that  those  risks  were 
properly managed. The key focus areas were: 

 ` the current business position and future prospects of 

the Group; 

 ` the capital, funding and liquidity profile of the Group; and
 ` the availability and efficient use of respective human 

and technical resources.

Effectiveness of the Group’s risk management 
framework, practice and internal control mechanisms 
The  Directors  ensure  that  the  Group’s  governance 
structure  enables  adequate  oversight  and  accountability, 
as well as a clear segregation of duties. The involvement 
of  all  governance  levels  in  risk  management,  the  clear 
segregation  of  authority,  and  effective  communications 
between  different  entities  facilitate  clarity  regarding 
the  Group’s  strategic  and  risk  objectives,  adherence  to 
the  established  risk  appetite,  risk  budget  and  sound 
risk  management.  The  centralised  ERM 
function 
ensures  effective  development,  communication  and 
implementation of risk strategy and risk appetite across 
the Group. The Directors have determined that the Group’s 
risk  management  framework  is  adequate  for  managing 
the  principal  and  emerging  risks  set  out  in  the  Annual 
Report and reducing their likelihood and impact wherever 
possible.  The  review  and  analysis  of  the  information 
presented in this Annual Report has enabled the Directors 
to confirm that they have a reasonable expectation of the 
Group’s viability over the next three years up to 1 January 
2023,  and  that  the  Group  will  be  able  to  continue  its 
operations and meet its liabilities as they fall due over the 
three-year period from 1 January 2020 to 1 January 2023. 

Stress testing 
In  2019,  the  Bank,  as  part  of  its  regular  stress  testing 
internal,  enterprise-wide 
framework,  performed  an 
stress testing exercise. The purpose of the stress test was 
to assess the vulnerability of the Bank’s capital adequacy 
and  profitability  to  different  macro  scenarios.  The  Bank 
developed  three  scenarios  of  different  severity.  The 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

stress scenarios covered certain assumptions about GEL 
devaluation, inflation, total GDP growth, sectoral growth, 
unemployment,  changes  in  real  estate  and  commodity 
prices,  changes  in  interest  rates  and  loan  and  deposit 
portfolio developments. The Directors consider the stress 
scenarios  and  the  associated  results  to  be  appropriate 
to the business and its risk appetite, therefore no urgent 
mitigation  was  required.  The  Bank  will  continue  to  use 
stress testing exercise as one of the key tools in its risk 
management framework.

In  addition,  the  Bank  performed  specific  stress  testing 
exercise  related  to  COVID-19  pandemic  by  applying 
multiple  scenarios.  Current  situation  is  highly  uncertain 
but  it  is  reasonable  to  expect  that  COVID-19  will  have 
material negative effect on the credit portfolio. Therefore, 
in the severe stress scenario the Bank applied conservative 
assumptions  such  as  economic  recession,  significant 
GEL  devaluation,  short  term  significant  decrease  in  real 
estate  prices  in  USD,  increase  in  GEL  interest  rates, 
higher  inflation,    increase  in  current  account  deficit, 
significant  decline  in  income  from  tourism,  export, 
FDI  and  remittances  as  well  as  material  increase  in 
unemployment. Significant external financing is also taken 
into account, as well as the fact that there were no signs 
of  overheating  of  the  economy  or  the  real  estate  sector 
before  the  distress.  Also,  in  the  severe  stress  scenario, 
the economic contraction is  expected to be more severe 
in 2020, and the speed of recovery to the 2019 level is also 
expcted to be slower. 

The results of the stress test shows that the Bank remains 
viable even within the severe stress scenario and is able 
to meet updated capital regulatory requirements. Please 
see  page  86  summarizing  countercyclical  measures 
introduced by the NBG in relation to the capital adequacy 
requirements.

DIRECTORS’ RESPONSIBILITIES
The  following  statement,  which  should  be  read  together 
with  the  Auditors’  report  set  out  on  pages  191-318,  is 
required by the Companies Act 2006 (the “Act”). 

The Directors are required to prepare the Company’s and 
the  Group’s  financial  statements  for  each  financial  year. 
Under the Act, the Group’s financial statements shall be 
prepared  in  accordance  with  the  International  Financial 
Reporting  Standards  (the  “IFRS”)  as  adopted  by  the 
European Union, and the Directors have elected to prepare 
the Company’s financial statements on the same basis. 

The  financial  statements  are  required  by  the  Act  and 
the  IFRS  to  present  fairly  the  financial  position  and 
performance of the Company and the Group for that period. 
The Directors must not approve the financial statements, 
unless they are satisfied that they give a true and fair view 
of the state of affairs and the profit or loss of the Company 
and the Group for that period. 

The  Directors  consider  that  in  preparing  the  financial 
statements they have used appropriate accounting policies, 
supported  by  reasonable  judgments  and  estimates,  and 
that  all  accounting  standards  which  they  consider  to  be 
applicable have been followed. The Directors also believe 
that  the  financial  statements  have  been  prepared  on 

the  going  concern  basis.  Please  see  further  the  “Going 
concern statement” on page 134 of this Annual Report. 

In  addition,  the  Group  has  in  place  an  effective  internal 
control  system  in  order  to  ensure  accurate  and  reliable 
financial  reporting.  The  Group  has  a  well-defined 
framework  of  accountability  and  delegation  of  authority, 
as well as policies and procedures that include financial 
planning  and 
reporting;  preparation  of  monthly 
management  accounts;  project  governance;  information 
security; and review of the disclosures within the annual 
report  and  accounts  from  the  respective  leads,  to 
appropriately  disclose  all  relevant  developments  within 
the Group in the year and to meet the requirements of a 
true and fair presentation.

The Directors have a responsibility that the Company and 
the  Group  keep  accounting  records,  which  disclose  with 
reasonable accuracy the financial position of the Company 
and the Group and enable the Directors to ensure that the 
accounts comply with the Act. 

The  Directors  are  also  responsible  for  safeguarding  the 
assets  of  the  Company  and  the  Group  and  for  taking 
reasonable steps for the prevention and detection of fraud 
and other irregularities. 

In  addition,  the  Directors  are  responsible  for  the 
maintenance  and  integrity  of  the  Company’s  website. 
Legislation  in  the  UK,  governing  the  preparation  and 
dissemination  of  financial  statements,  may  differ  from 
legislation in other jurisdictions.

DIRECTORS’ RESPONSIBILITY STATEMENT
Each  of  the  Directors,  whose  names  and  functions  are 
listed on pages 136 to 139 of this Annual Report, confirms 
that to the best of their knowledge: 

 ` the  Group’s  financial  statements,  which  have  been 
prepared  in  accordance  with  the  IFRS  standards,  give  a 
true and fair view of the assets, liabilities, financial position 
and profit or loss of the Company and the undertakings 
included in the consolidation taken as a whole; 

 ` the Strategic Report and Director’s Report contained 
in  this  Annual  Report  include  a  fair  review  of  the 
development and performance of the business and the 
position of the Company and the Group, together with 
a  description  of  the  principal  risks  and  uncertainties 
that they face; and 

 ` the Annual Report and financial statements, taken as 
a  whole,  are  fair,  balanced  and  understandable,  and  
provide the information necessary for the shareholders 
to  assess  the  Company’s  position  and  performance, 
business and strategy. 

This responsibility statement was approved by the Board 
and is signed on its behalf by:

Nikoloz Enukidze
Chairman
28 April  2020

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BOARD BIOGRAPHIES

NIKOLOZ ENUKIDZE

Chairman

Nikoloz Enukidze graduated from Tbilisi State University with a degree in physics in 
1993 and obtained an MBA from the University of Maryland in 1996.

In 2006 – 2010 Nikoloz Enukidze served as the Chairman (and prior to that as Vice-
Chairman) of the Supervisory Board of Bank of Georgia and was one of the key people 
leading the bank in its successful IPO on the London Stock Exchange, the first ever 
IPO in London from the Caucasus region.  He also serves as member of the board of 
Yelo Bank in Azerbaijan. Prior to his roles at Bank of Georgia, Nikoloz worked at ABN 
AMRO Corporate Finance in Moscow and London, Concorde Capital in Kyiv and Global 
One Communications in Reston, Virginia.

Nikoloz Enukidze serves as the Chairman of TBC Bank Group PLC and JSC TBC Bank 
since  25  July  2019  and  13  August  2019  respectively.  Previous  to  that,  Nikoloz  was 
appointed as the independent member of the Supervisory Board of JSC TBC Bank in 
2013 and was Senior Independent Director of the Board from 2016 to August, 2019. 

NICHOLAS DOMINIC HAAG

Senior Independent Non-Executive Director

Nicholas Haag earned an M.A. from the University of Oxford with a degree in modern 
studies in geography in 1980.

Mr Haag has 32 years of experience working in the financial services industry, with 
a  significant  emphasis  on  equity  capital  markets  and  technology.  His  experience 
includes  seven  years  at  Barclays  Bank  between  1980  and  1987  in  various  capital 
markets and project finance roles, including as the head of equity syndicate, Barclays 
de Zoete Wedd (BZW); ten years at Banque Paribas, Paribas Capital Markets between 
1989 and 1999, initially as deputy head of global equity capital markets and later senior 
banker and head of European client coverage (exFrance); two years at ING Barings 
between 1999 and 2001 as managing director and global head of technology banking 
group; six years at ABN AMRO between 2001 and 2007 based in London as the global 
head of technology banking, member of Global TMT Management Committee, senior 
managing director and member of the Senior Credit Committee; four years with the 
Royal Bank of Scotland between 2008 and 2012 and RBS Hoare Govett as managing 
director, head of London equity capital markets and member of the Global Equities 
Origination Management Committee.

Since  2012,  he  served  as  a  senior  independent  adviser  to  the  Chairman  of  the 
management  board  and,  from  2013  until  November  2016,  as  a  member  of  the 
supervisory board of Credit Bank of Moscow and a financial consultant specialising in 
capital raisings and stock exchange flotations. He also serves as an independent non-
executive director of Bayport Management Limited (pan-African and Latin American 
consumer lender) and since 2016 as a director of AS Citadele Banka in Riga. Since 
2012, he has acted as sole director of his own consulting company, Nicdom Limited.

Mr Haag was appointed to the Bank’s Supervisory Board in 2013 and to the Board as 
an independent non-executive Director in May 2016. Nicholas Haag has the recent and 
relevant financial experience required by the UK Corporate Governance Code to fulfil 
his responsibilities as a designated financial expert on the Audit Committee of TBC 
Bank Group PLC. In August 2019 Mr Haag was appointed as the Senior Independent 
Director of the Board. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

ERIC RAJENDRA

Independent Non-Executive Director

Eric  Rajendra  graduated  from  Brandeis  University,  earned  his  M.A.L.D.  at  The 
Fletcher School in 1982 (Tufts University in cooperation with Harvard University) and 
conducted postgraduate research at INSEAD Business School in the areas of financial 
markets and institutions. Mr Rajendra is also a graduate of the Australian Institute 
of Company Directors and was formerly an adjunct professor of strategy at INSEAD. 

During 2005-2014, he held the position of senior advisor to the International Financial 
Corporation  and  has  served  as  a  board  director  or  consulting  advisor  on  selected 
emerging markets financial institutions where the World Bank Group has an equity 
interest, as well as leading strategic initiatives for the firm. His IFC portfolio included 
roles as Supervisory Board Director on Locko Bank (from 2006 to 2014), where he 
was also the founder and Chairman of the Audit and Risk Committee, Orient Express 
Bank (from 2010 to 2012) where he was the Chairman of the Strategy Committee, 
and earlier at ACLEDA Bank (a leading bank in southeast Asia with a micro-finance 
original focus).  

Prior to joining the IFC, he was a vice president at Capgemini and a vice president 
at Electronic Data Systems; in both institutions, he was a key leader of the financial 
services practice. He started his career as a banker at JP Morgan Chase Bank in 1982 
and later became a partner at McKinsey & Company. Mr Rajendra was first appointed 
to the Bank’s Supervisory Board in 2010 and to the Board as an independent non-
executive Director in May 2016 where he served until his resignation on 15 March 2019 
due to health reasons. He was later re-appointed on 17 September 2019, following 
the recovery in his health.

MARIA LUISA CICOGNANI

Independent Non-Executive Director

Maria Luisa Cicognani graduated from Bocconi University in 1987 with a degree in 
Business and Administration. She holds a master degree from the Int’l University of 
Japan in International Relations with a focus on Japanese Economy and Business.

Ms  Cicognani  has  extensive  experience  in  the  field  of  banking  and  corporate 
governance. She worked at the European Bank for Reconstruction and Development 
(London, UK) between 1993 and 2005. Between 2005 and 2006, she was a director 
of  Financial  Institutions  at  Merrill  Lynch  and  a  managing  director  at  Renaissance 
Capital in London and Moscow during 2006-2008. At Renaissance Capital she was 
responsible for managing a team that developed the FIG practice of the firm both in 
Africa and CIS. Ms Cicognani was supporting Renaissance Partners in origination, 
analysis  and  processing  of  new  FIG  investment  opportunities  and  monitoring  a 
portfolio of FIG investments in Africa.

During  2008-2014,  Maria  Luisa  was  a  Managing  Director  at  Mediobanca  (London 
Branch).  She  was  responsible  for  origination  of  M&A  advisory  and  client  coverage 
for  emerging  markets.  She  supported  the  M&A  and  Corporate  Finance  Teams  in 
advising Italian clients that were interested in expanding outside of Italy or identifying 
foreign investors. During 2014-2016, she served as a non-executive member of the 
board  at  Azimut  Global  Counseling  Srl  (Italy)  and  Azimut  International  Holding  SA 
(Luxemburg).

Ms Cicognani served as an NED at Arafa Holding (Egypt) and became a board observer 
at Baird Group (UK), a subsidiary of Arafa Holding (listed on Cairo Stock Exchange). 
She is currently Chairperson of Möbius Investment Trust listed on the London Stock 
Exchange since October 2018.

Ms Cicognani was appointed to the Board as an independent non-executive Director 
of TBC Bank Group PLC and as a member of the Supervisory Board of JSC TBC Bank 
in September 2018.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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BOARD BIOGRAPHIES CONTINUED

TSIRA KEMULARIA

Independent Non-Executive Director

Tsira  Kemularia  graduated  from  the  Louisiana  State  University  with  a  degree  in 
International Trade and Finance & Economics in 1999. Ms Kemularia has 20 years of 
international experience in financial services and risk management.

From 1999 to 2005, she held various market risk management roles both In Dynegy 
Inc. in USA and UK and at Shell International Trading & Shipping Ltd (STASCO) in 
London.  From  2005  to  2008,  she  was  Manager,  M&A  and  Commercial  Finance,  in 
Group  Treasury  and  Corporate  Finance,  at  Shell  International.  From  2008  to  2011, 
she served as a Commercial Finance Manager, M&A in Group Treasury & Corporate 
finance, at Shell Exploration and Production Services (B.V) in Moscow, RF. Thereafter, 
she served as Finance Manager and a Country Controller at Shell Western Supply 
and  Trading  LTD  in  Barbados,  West  Indies  from  2011  to  2016.  From  2016  to  2019, 
Ms  Kemularia  was  the  Head  of  Group  Pensions  Strategy  and  Standards  at  Shell 
International Ltd based in London and currently she manages Internal Audit  for Shell 
International Trading and Supply businesses globally.

From  2006  to  2010,  Ms  Kemularia  was  a  board  member  of  the  British-  Georgian 
Society. In 2011, she joined the board of Shell Western Supply and Trading Ltd. From 
2016, she also serves as a company nominated Trustee of the British Gas General 
Partner Ltd and British Gas Trustee Solutions Ltd. Tsira Kemularia is a member of the 
Institute of Directors in London, UK, and is currently pursuing chartered directorship. 

Ms Kemularia was appointed to the Board as an independent non-executive Director 
of TBC Bank Group PLC, is a member of the Supervisory Board of JSC TBC Bank 
in  September  2018  and  is  a  Chairwoman  of  the  Governance  and  the  Nominations 
Committee.

ARNE BERGGREN

Independent Non-Executive Director

Mr Berggren has studied at a number of renowned academic institutions such as the 
Swedish Institute of Management, New York University Graduate School of Business, 
University of Geneva, University of Amsterdam and the University of Uppsala.

Arne Berggren has in various ways been involved in ownership issues, reconstructions 
and sales of companies and banks in Sweden and abroad during more than 25 years. 
Private  and  public  employers  as  well  as  international  organizations  have  engaged 
him as an advisor, CEO or in other similar positions. 

Arne Berggren currently serves as a member of the board of Bank of Cyprus, where 
he is the Chairman of the risk committee and a member of the audit committee. He 
also works at Piraeus Bank, where he is chairing the nomination and remuneration 
committees and is a member of the risk- audit and strategy committees.

Prior to his current roles, Mr Berggren served as a board member of Turkish asset 
management company, LBT Varlik Yonetim and Slovenian bank asset management 
company, DUBT Ltd. He also has held a number of senior leadership and advisory 
roles  at  prominent  financial  intuitions  including  the  IMF,  World  Bank,  Swedbank, 
Carnegie Investment Bank AB and the Swedish Ministry of Finance and Bank Support 
Authority. 

Mr Berggren was appointed to the Bank’s Supervisory Board in July 2019 and to the 
Board as an independent non-executive Director in August 2019.

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VAKHTANG BUTSKHRIKIDZE

CEO

Vakhtang  Butskhrikidze  joined  TBC  Bank  as  a  Senior  Manager  of  the  Credit 
Department in 1993 and was elected as Deputy Chairman of the Management Board 
in 1994. He became Chairman of the Management Board in 1996. Since 1998, he has 
held the position of CEO of TBC Bank and has headed a number of TBC’s committees.

Mr Butskhrikidze was appointed as Chief Executive Officer of the Company in May 
2016. He also served as a member of the Supervisory Board from September 2016 
till April 2018. Mr Butskhrikidze is also a member of the supervisory board of the 
Association of Banks of Georgia and is a Chairman of the financial committee of the 
Business Association of Georgia. Since 2016, Mr Butskhrikidze has been a member 
of the Visa Business Council for Central & Eastern Europe, Middle East and Africa 
(CEMEA).

In his earlier career, Mr Butskhrikidze acted as a junior specialist at the Institute of 
Economics, Academy of Sciences of Georgia, as well as an assistant to the Minister of 
Finance of Georgia between 1992 and 1993.

In 2001, Mr Butskhrikidze was honoured with the “Best Businessman of the Year” 
award by Georgian Times Magazine and in 2011, he was recognised as the “Best Banker 
2011” by GUAM – Organization for Democracy and Economic Development award. Mr 
Butskhrikidze was also named as the CEO of the Year 2014 in Central and Eastern 
Europe  and  the  CIS  by  EMEA  Finance  magazine.  In  March  2019  Mr  Butskhrikidze 
won the Special Award for Responsible Capitalism in Adversity from the prestigious 
FIRST organisation - a multidisciplinary international affairs organization, which aims 
to enhance dialogue between leaders in industry, finance and government.

Mr  Butskhrikidze  obtained  an  MBA  from  the  European  School  of  Management  in 
Tbilisi in 2001. He graduated from Tbilisi State University in 1992 with a degree in 
Economics  and  holds  postgraduate  qualifications  from  the  Institute  of  Economics, 
Academy of Sciences of Georgia.

GIORGI SHAGIDZE

Deputy CEO, CHIEF FINANCIAL OFFICER

Following  structural  changes  to  the  composition  of  the  management  board  in 
January 2020, Giorgi Shagidze assumed some functions of COO and when the Uzbek 
subsidiary starts operations he will serve as the Chairman of that subsidiary’s 
Supervisory Board.

Giorgi Shagidze became deputy CEO and Chief Financial Officer of TBC Bank and was 
appointed to the Bank’s Management Board in 2010.

Mr Shagidze was appointed as a Chief Financial Officer of the Company in May 2016. 
He is a board member of Georgian Stock Exchange and also served as member of the 
supervisory board of Bank Constanta until its merger with TBC Bank in 2015.

Prior to joining TBC Bank, Mr Shagidze acted as a global operations executive for 
Barclays Bank Plc between 2008 and 2010. In his earlier career, Mr Shagidze worked 
as  director  of  the  Distribution  Channels  Division  at  Bank  of  Georgia  and  deputy 
CEO  of  Peoples  Bank  of  Georgia,  as  well  as  occupying  various  senior  positions  at 
Tbiluniversalbank and Agro Industrial Bank of Georgia.

Mr Shagidze obtained an MBA from the University of Cambridge Judge Business School 
in 2008 and he graduated from Tbilisi State University in 1997 with a degree in economics. 
He is also a CFA Charterholder and the member of the CFA Society in the UK.

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THE BANK’S MANAGEMENT BOARD BIOGRAPHIES
(EXCEPT FOR CEO’S AND CFO’S BIOGRAPHIES, WHICH ARE PRESENTED ON PAGE 139)

GEORGE TKHELIDZE

Deputy CEO, CORPORATE AND INVESTMENT BANKING

George  joined  TBC  Bank  in  2014  as  Deputy  CEO  in  charge  of  Risk  Management. 
Following  acquisition  of  Bank  Republic  and  creation  of  Corporate  and  Investment 
Banking (CIB) unit at the Bank in November 2016, George overtook the responsibility 
for the CIB. George has more than 15 years of experience in financial services.

Prior to joining TBC Bank, George worked for Barclays Investment Bank, where he 
held  the  position  of  Vice  President  in  the  Financial  Institutions  Group  (FIG),  EMEA 
since  June  2011.  From  September  2009  he  was  an  Associate  Director  in  Barclays 
Debt Finance and Corporate Restructuring teams. During his career with Barclays 
in London, George worked on and executed multiple M&A, debt and capital markets 
transactions with European financial institutions.

In his earlier career in Georgia, George held various managerial positions at ALDAGI 
Insurance  Company  during  2000  -  2007,  where  he  also  served  as  Chief  Executive 
Officer.  George  graduated  from  the  London  Business  School  with  an  MBA  degree 
(2009). He also holds Master of Laws degree (LL.M) in International Commercial Law 
from the University of Nottingham (2002) and Graduate Diploma in Law from Tbilisi 
State University (2000).

NINO MASURASHVILI

Deputy CEO, RETAIL BANKING

Following David Chkonia’s resignation, Nino Masurashvili has been appointed as the 
new Chief Risk Officer of TBC Bank on January 24, 2020.

Nino joined TBC Bank in 2000 as a manager in the planning and control department 
and became head of that department in 2002.

Between 2004 and 2005, she acted as head of the sales department and retail bank 
coordinator.  Nino  was  appointed  as  deputy  CEO,  retail  and  SME  banking  in  2006. 
Between 2006 and 2008, Nino was the Chairman of the supervisory board of UFC. 
During 2011-2015 she also held a position of a member of the supervisory board of 
Bank Constanta until its full merger with TBC Bank. During 2011- 2016, Nino has 
been a member of the supervisory board of TBC Kredit.

In her earlier career, she held the positions of credit account manager, credit officer, 
financial  analyst  (financial  department)  and  head  of  the  financial  analysis  and 
forecasting department at JSC TbilCom Bank between 1995 and 2000. Between 1998 
and 2000, she also held the position of accountant at the Barents Group.

Nino graduated from Tbilisi State University in 1996 with a degree in Economics and 
obtained an MBA degree from the European School of Management in Tbilisi.

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THE BANK’S MANAGEMENT BOARD BIOGRAPHIES

(EXCEPT FOR CEO’S AND CFO’S BIOGRAPHIES, WHICH ARE PRESENTED ON PAGE 139)

NIKOLOZ KURDIANI

Deputy CEO, MSME BANKING AND MARKETING 

Following to structural changes to the composition of the management board in 
January 2020, Nikoloz Kurdiani assumed responsibilities for payments ecosystems.

Nika has more than fifteen years of experience in the banking industry which includes 
five years at UniCredit Group in Austria, Turkey and Kazakhstan. Immediately before 
joining TBC Bank in 2014, Nika was managing director at Kaspi Bank, a leading retail 
bank in Kazakhstan.

Prior to obtaining his MBA degree in 2007, he served as head of the retail banking 
division  of  Bank  Republic  Georgia,  Société  Générale  Group,  and  also  held  several 
positions  at  Bank  of  Georgia  between  2003  and  2006.  He  has  expertise  in  post-
acquisition integration and restructuring, as well as retail and SME banking.

Between  2008  and  2010,  Nika  held  the  position  of  senior  sales  support  expert  at 
the  CEE  retail  division  of  Bank  Austria,  UniCredit  Group,  responsible  for  Turkey, 
Kazakhstan, Ukraine and Serbia. Between 2010 and 2013, he was head of the retail 
division of ATF Bank, UniCredit Group in Kazakhstan.

Nika obtained his MBA degree from IE Business School in 2007. He also holds an 
MSc degree in International Economics from the Georgian Technical University and 
completed BBA studies at Ruhr University Bochum in Germany and the Caucasus 
School of Business.

TORNIKE GOGICHAISHVILI

Deputy CEO, CHIEF OPERATING OFFICER

Tornike Gogichaishvili has been appointed to lead retail banking business of TBC 
Bank on January 24, 2020.

Tornike joined TBC Bank in 2018 as Chief Operating Officer and deputy CEO following 
20 years of financial services and operations management experience.

Prior to joining TBC, he has served as a Deputy CEO, Chief Operation Officer at Bank of 
Georgia since 2016. Between 2010 and 2016 Tornike served as director of operations’ 
department at Bank of Georgia. He also served as head of international banking at 
Bank of Georgia Group. Between 2008-2010 Tornike held the position of CFO at BG 
Bank Ukraine (the subsidiary of Bank of Georgia).

Between 2006 and 2008 he held the position of CEO at Insurance Company Aldagi. 
He  also  served  as  chief  financial  officer  of  UEDC  PA  consulting  and  held  various 
managerial positions at BCI Insurance Company from 1998 to 2004.

Tornike graduated from the Faculty of Law at Tbilisi State University and holds an 
MBA from Caucasus School of Business and an executive diploma from Said Business 
School, Oxford.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

141

THE BANK’S MANAGEMENT BOARD BIOGRAPHIES CONTINUED
(EXCEPT FOR CEO’S AND CFO’S BIOGRAPHIES, WHICH ARE PRESENTED ON PAGE 139)

DAVID CHKONIA

Deputy CEO, Chief Risk Officer

David Chkonia stepped down from the Management Board of TBC Bank on January 24, 
2020, at the end of his contractual term in order to pursue other career opportunities.

David  joined  TBC  Bank  in  2017  as  Chief  Risk  Officer  and  deputy  CEO  following  15 
years of international banking and risk management experience. 

Prior to joining TBC, David was a director at BlackRock in the BlackRock Solutions 
group  advising  financial  institutions  and  regulators  on  topics  related  to  risk 
management, balance sheet strategy and regulation. 

Prior to that, he served as senior vice president at PIMCO responsible for the risk 
advisory practice. In 2009-2011, David worked at European Resolution Capital helping 
Western  European  banks  with  NPL  management  and  recovery  strategies  in  CEE 
subsidiaries. 

In  2006,  David  joined  Goldman  Sachs  in  the  EMEA  Structured  and  Principal 
Finance  team  where  he  completed  a  number  of  innovative  financing  transactions 
in  the  infrastructure  and  real  estate  sectors  as  well  as  focusing  on  restructuring 
assignments. 

David  started  his  career  at  the  EBRD  executing  debt  and  equity  investment 
transactions in CEE as well as has worked in the bank’s credit department. David 
holds a BSc from San Jose State University and an MBA from the Wharton School at 
the University of Pennsylvania.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

CORPORATE GOVERNANCE AND NOMINATION COMMITTEE REPORT

CHAIRMAN’S LETTER

appointed as the SID of the Bank; and Arne Berggren has 
joined the Board as an independent non-executive Director. 
At  the  same  time,  the  Supervisory  Board  of  the  Bank  
accepted the resignation of Jyrki Koskelo from his role as 
the  Chairman  of  the  Supervisory  Board  with  immediate 
effect. 

We consider that these changes will maximise efficiencies 
in the management and supervision of the Group’s business 
and will add stability to the Group’s governance.   The Board’s 
structure  is  consistent  with  the  requirements  of  the  UK 
Corporate Governance Code, including with respect to the 
independence  of  its  Chairman  and  having  a  majority  of 
independent non-executive Directors on the Board. 

The  Committee  will  continue  to  keep  under  review  the 
structure,  size  and  composition  of  the  Board  and  its 
committees  including  the  balance  of  skills,  diversity, 
knowledge  and  experience  and  will  make  appropriate 
recommendations for changes to the Board.

In 2019, the Committee initiated and supervised an internal 
performance  evaluation  of  the  Board  and  its  committees. 
The outcome was reviewed by the Board and an action plan 
agreed for 2020. 

Dear shareholders,
As the new Chairperson of the Corporate Governance and 
Nomination Committee (the “Committee”), I am pleased to 
present the Committee’s report to shareholders.  2019 was 
a  challenging  year  for  TBC  and  saw  changes  in  both  the 
structure and composition of the boards of TBC Bank Group 
PLC  (“TBC  PLC”)  and  JSC  TBC  Bank  (the  “Bank”).  The 
Committee is satisfied that throughout this period of change 
it led the process successfully. Following the decision of the 
former Chairman and Deputy Chairman to step down from 
the supervisory board of the Bank (the “Supervisory Board”)  
and the board of directors of TBC PLC (the “Board”) and the 
subsequent  appointment  of  Nikoloz  Enukidze  as  the  new 
Chairman, the Board has reviewed the governance structure 
of  TBC  PLC  and  the  Bank  ,  taking  into  consideration  the 
feedback  from  shareholders,  IFI  partners  and  other  key 
stakeholders. Taking into account all feedback, as well as its 
experience of the benefits in having the same individuals in 
non-executive  roles  for  both  TBC  PLC  and  the  Bank,  the 
Board has introduced a “Mirror Board” governance structure 
whereby:

 ` all non-executive members of the Board are also  

members of  the Supervisory Board;

 ` the Chairman of TBC PLC   also serves as the 

Chairman of the Bank; and

 ` the Senior Independent Director (“SID”) of TBC PLC  

is also the SID of the Bank.

As a result of the introduction of the Mirror Board governance 
structure, the following changes were also made: Nikoloz 
Enukidze,  the  current  Chairman  of  the  Board  has  been 
elected as the Chairman of the Supervisory Board; Nicholas 
Domenic  Haag,  the  current  SID  of  TBC  PLC  has  been 

Tsira Kemularia
Chairman of Corporate Governance
and Nomination Committee 
28 April 2020

MEMBERS OF THE COMMITTEE
As  at  28  April  2020,  the  Committee  is  composed  of  three 
independent  non-executive  Directors,  Tsira  Kemularia, 
(Chairperson), Nicholas Haag, and Eric Rajendra; as well as 
Nikoloz Enukidze the non-executive Chairman of the Board.

During 2019, Tsira Kemularia was appointed as Chairperson 
of the committee. Nicholas Haag, having been appointed as 
Senior  Independent  Director  became  a  member  of  the 
Committee. Eric Rajendra having stepped down as a director 
on  15  March  2019  due  to  ill  health,  was  reappointed  as  a 
director following a recovery in his health, and re-joined the 
Committee.  For  a  short  period  of  time  Nikoloz  Enukidze 
chaired the Committee prior to Tsira Kemularia taking over 
on  a  permanent  basis,  when  he  subsequently  became 
Chairman of the Board in August 2019. The Board believes 
that  the  Group  complies  with  the  2018  UK  Corporate 
Governance Code and that all the Committee members are 
independent. 

ATTENDANCE AT COMMITTEE MEETINGS
Only members of the Committee have the right to attend its 
meetings, but the Committee may invite others, including 
the Chief Executive Officer, the Head of Human Resources 
and external advisors, to attend all or part of any meeting if 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

143

CORPORATE GOVERNANCE AND NOMINATION COMMITTEE REPORT CONTINUED

it  thinks  it  is  appropriate  or  necessary.  The  Committee 
members meet on a quarterly basis and schedule additional 
meetings  when  appropriate.  The  Company  Secretary 
attends all meetings of the Committee.

The  attendance  of  members  at  the  Committee  meetings 
during the year is set out on pages 128-129.

COMMITTEE EFFECTIVENESS 
In  October  2019,  the  Committee  conducted  an  annual 
Effectiveness  Self-Review,  coordinated  by  the  Company 
Secretary,  and  using  an  extensive  and  customised 
questionnaire    which  drew  on  international  best  practice 
surveys  of  a  similar  nature.  Both  the  Committee  and  the 
Board  concluded  that  the  former  is  constituted  properly, 
operates effectively and carries out all its responsibilities as 
set  out  in  its  Terms  of  Reference.  Going  forward  the 
Committee  intends  to  focus  more  closely  on  succession 
planning  issues,  along  with  improved  reporting  to  the 
Committee on key issues. The Chairman of the Committee 
is working closely with the Company Secretary to set future 
agendas and all these improvements are being implemented.

COMMITTEE ROLE AND RESPONSIBILITIES
The Committee’s role and responsibilities are set out in its 
terms of reference, available on the Group’s website: www.
tbcbankgroup.com.  The  Committee’s  Terms  of  Reference 
were updated and approved by the Board in February 2020.  
Minor  changes  were  recommended  by  the  Company 
Secretary, with input from the Company’s lawyers, in order 
to bring the Terms of Reference up to date to reflect recent 
developments in the UK Corporate Governance Code. This 
review will be undertaken on an annual basis.

The  Committee  is  responsible  for  the  establishment  and 
oversight  of  the  Group’s  compliance  with  the  corporate 
governance guidelines and for making recommendations to 
the Board in respect of changes or additional actions as the 
Committee deems necessary.

The main responsibilities of the Committee, in relation to 
the development and functioning of corporate governance 
within the Group, are:

 ` approving 

 ` advising  the  Board  periodically  with  respect  to 
significant  developments  in  the  law  and  practice  of 
corporate governance;
changes 

corporate  governance 
guidelines,  monitoring  the  Group’s  compliance  with 
such  guidelines  and  applicable  legal  and  regulatory 
requirements  and  recommending  to  the  Supervisory 
Board such changes or additional action as it deems 
necessary;

to 

 ` reviewing  the  independence  standards  for  Board 

members;

 ` monitoring  and  evaluating  the  process  for  assessing 
the performance and effectiveness of the Board and its 
committees (including the annual Effectiveness Self-
Review of this Committee); and

144

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 ` reviewing the structures and procedures of the Board 
and its relationship with management to ensure it can 
function independently.

The main responsibilities of the Committee, in relation to 
nominations, are:
 ` regularly reviewing the structure, size and composition 
of the Board, including evaluating the current balance 
of skills, experience, independence and knowledge on 
the Board, including considering diversity and gender 
balance;

 ` identifying  suitable  candidates  from  a  wide  range 
of  backgrounds,  with  use  of  open  advertising  and 
services of external advisers;

 ` considering  and  making  recommendations  to  the 

Board on the composition of the Board;

 ` advising  the  Board  on  succession  planning  for  the 
roles of Chairman, Senior Independent Director, Chief 
Executive Officer and for all other Board appointments;
 ` in conjunction with human resources, setting diversity 
objectives and strategies for the Company as a whole 
and  monitoring  the  impact  and  outcome  of  diversity 
initiatives;

 ` considering  and  making  recommendations,  as 
necessary,  on  the  removal  and  resignation  of  Board 
members;

 ` assisting  the  Chairman  of  the  Board  and  the  senior 
independent  director  with  the  implementation  of  an 
annual  evaluation  process  to  assess  the  overall  and 
individual performance and effectiveness of the Board 
and its committees;

 ` making recommendations to the Board on succession 

planning for the Board over the longer term

APPOINTMENT AND RE-ELECTION
OF DIRECTORS
The Committee considers a skills matrix for appointments 
to the Board and the Board’s committees, and identifies the 
skills, core competencies, diversity and experience that the 
Group needs to be able to deliver its strategic aims, to govern 
the Group appropriately and align with the Group’s corporate 
culture  and  values.  In  accordance  with  the  UK  Corporate 
Governance Code, all the directors will stand for re-election 
at  the  Company’s  Annual  General  Meeting,  including  the 
newly-appointed independent non-executive Director, Arne 
Berggren.  The  Committee  has  carried  out  an  internally 
facilitated performance evaluations and is of the view that 
each  director  demonstrated  the  level  of  commitment 
required in connection with their role on the Board and the 
needs  of  the  business.  An  overview  of  the  evaluation  is 
provided in Directors’ Governance Statement.

Following discussions with the Bank’s regulator in Georgia 
after  the  departure  of  the  Founder  shareholder  directors 
(Mamuka Khazaradze and Badri Japaridze), the Committee 
agreed to consult with the Company’s minority shareholders 
to  identify  two  suitable  candidates  to  be  appointed  to  the 
Board.  In  light  of  these  circumstances,  the  Committee 
decided not to appoint a search consultancy, and consulted 
with the IFIs and minority shareholders to identify a suitable 
pool of candidates. Following this process and after review of 

a number of candidates, to ensure that a suitable candidate 
was identified that met the Company’s skills and expertise 
requirement,  the  Committee  made  a  recommendation  to 
appoint Arne Berggren to the Board. The Board subsequently 
approved his appointment as an independent non-executive 
Director. Biographical details of Arne Berggren are set out 
on page 138. 

Following  a  review  of  skills  available  to  the  Board,  the 
Committee  has  been  asked  by  the  Board  to  undertake  a 
search to recruit an additional non-executive Director who 
can bring additional experience to the Board in the Fintech 
and digital banking areas. In light of the request from the 
Bank’s Georgian regulator described above, the Committee 
has again engaged with its shareholders, and explored its 
own  wide  range  of  contacts,  in  order  to  identify  suitable 
candidates. This exercise is currently underway.

DIVERSITY
The Committee recognises the importance of ensuring that 
there is a broad diversity within the Group inclusive of, but 
not  limited  to,  gender,  ethnicity  and  business  experience, 
while continuing to recommend all appointments based on 
merit  against  objective  criteria  in  the  context  of  the  skills 
and  experience  required.  The  Committee  notes  the 
recommendations  of  the  Hampton  Alexander  review  to 
improve gender diversity and is pleased to report that two 
female  directors  serve  on  the  Board.  In  addition,  the 
Committee notes that there are a number of talented women 
in key positions, who report directly to the CEO and other 
members of the management board within the Group. As at 
31  December  2019,  14%  of  Group’s  top  management  and 
35% of Group’s middle management roles were performed 
by females. Moreover, 65% of employees across the Group’s 
entire workforce were female. In a review of the CEO-1 level 
succession plan, presented at the request of the Committee, 
the  Committee  were  pleased  to  note  the  high  number  of 
female  middle  management  who  will  in  time  be  able  to 
succeed at a more senior level.The Committee will continue 
to strive to further improve gender diversity going forward at 
both the Board and management levels. Regarding ethnic 
diversity, 
the 
recommendations of the “Report into the Ethnic Diversity of 
UK Boards”, made by the Parker Review Committee and the 
need to build a balanced Board, whilst remaining mindful of 
the regional nature of the business. 

taken  account  of 

the  Board  has 

THE COMMITTEE’S WORK IN 2019
In  2019,  the  Committee  led  an  extensive  process  of 
restructuring the Board and its committees. In addition, it 
has also remained focused on succession planning, diversity 
matters  and  an  assessment  of  effectiveness  of  the  Board 
and its committees.

Composition of Board and its committees
Following  the  resignation  of  the  former  Chairman  and 
Deputy Chairman in February 2019, the Committee helped 
advise the Board on a revised Mirror Board structure for the 
Group, whereby all independent non-executive Directors of 
TBC PLC were also members of the Supervisory Board. As a 

result of these changes the Committee made the following 
recommendations to the Board that:

 ` Nikoloz Enukidze be appointed as Chairman;
 ` Nicholas Haag be appointed as Senior Independent 

director;

 ` Eric Rajendra be re-appointed as an independent 

non-executive Director; and

 ` Arne Berggren be appointed as an independent non 

executive Director.

In addition following the Board appointments noted above, 
the  Committee  undertook  a  full  review  of  committee 
membership,  and  made  several  recommendations  to  the 
Board  which  were  adopted  and  are  reported  in  full  in  the 
individual committee reports. 

Succession
The Committee recognises that people are the driving force 
in sustaining the Group’s business, and succession planning 
contributes  to  the  delivery  of  the  Group’s  strategy,  by 
ensuring there is the necessary mix of skills and experience 
in both the current and future senior management teams. 
The  Committee  also  reviews  individuals  identified  as 
potential  successors  to  the  Group’s  executive  board 
members.  The  Committee  considers  succession  planning 
for the non-executive roles based on a clear understanding 
of the full range of skills currently available to it and those 
required  to  achieve  successful  delivery  of  its  strategy.  As 
part of the succession planning process, the Committee also 
consider gender balance and diversity. In addition, the Group 
is implementing an executive development program, which 
includes a clear roadmap to enhance both the knowledge 
and personal strengths of all potential candidates for senior 
management roles, including increasing their exposure to 
the Board. This will ensure that future leadership needs are 
met with an appropriate and diverse balance of skills and 
experience.

Designated non-executive Director and staff engagement
Tsira  Kemularia  is  the  designated  independent  non-
executive  Director,  responsible  for  workforce  engagement 
and  enabling  communication  between  the  Board  and  the 
Group’s  workforce.  During  2019,  in  her  role  as  Staff 
Ambassador,  she  held  three  face-to-face  meetings  with 
representative groups of staff where a wide range of topics 
were discussed. She has also visited several major branches 
and  operational  hubs  in  Georgia.  The  outcome  of  these 
discussions have been fed back to both the Committee and 
the Board. 

The meetings held under this initiative were both constructive 
and open. Employees shared their opinion and thoughts on 
a  variety  of  topics  including:  the  Company’s  mission  and 
vision; linking the Company’s mission to business objectives; 
talent acquisition and resourcing; coaching opportunities for 
senior leadership; the need for more delegation of day-to-
day  decisions  to  appropriate  levels  of  management;  and 
career development.

The  Staff  Ambassador  will  continue  meetings  different 
groups of staff in 2020; allowing more diversity of discussion 
topics and opinions. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

145

CORPORATE GOVERNANCE AND NOMINATION COMMITTEE REPORT CONTINUED

The Management Board of the Bank, supported by the Human Capital Department has developed a detailed action plan to give 
more clarity to the staff on the Group’s strategic vision and initiatives. This plan envisages a range of activities for 2020, including, 
town hall meetings, where the strategy, mission and vision will be shared with the staff. Allowing more linking of business 
objectives  to  the  strategy,  through  Quarterly  Business  Reviews,  supported  by  videos  and  online  briefings  focussed  on  the 
Company’s goals. 

The Agile programme, being undertaken across part of the organization, has allowed greater delegation to key staff, increasing 
decision making and improving employee empowerment. The increased use of personal development plans within the Group’s 
staff performance management system is a key part of career and personal development.

Corporate governance and independence
The  Committee  oversaw  the  continued  developments  of  the  Group’s  corporate  governance  framework  and  reviews  of  its 
compliance with the UK Corporate Governance Code requirements, independence of non-executive Directors and re-election of 
non-executive Directors as well as their suitability to continue in office. The Committee is satisfied with Company’s compliance 
with the UK Corporate Governance Code on these matters. 

Board performance evaluation
As required by the UK Corporate Governance Code, in 2019 an internally facilitated Board performance evaluation was undertaken 
by the Company and conducted by the Company Secretary, following the externally facilitated review undertaken by Independent 
Audit in 2018. The Committee considered the form of questionnaire to be issued to the Board and oversaw the process of the 
review. The 2019 review was undertaken by means of a written questionnaire, with anonymous ratings and responses considered 
by the individual committees and the Board. 

The outcome of the review and the action plan are described on pages 129 to 130. The Committee will monitor implementation 
of the proposed action plan in 2020. The Company will appoint an independent evaluator to assist in the performance evaluation 
process every three years.

LOOKING FORWARD TO 2020 
In the coming year, the Committee’s workload will include overseeing the implementation of the improvements recommended 
by the performance evaluation of the Board and its committees. The Committee will continue to monitor the Group’s succession 
planning process to ensure that the next generation of senior management and key roles in middle management are in place. It 
will also conclude the recruitment of a further independent non-executive Director. In addition, the Committee will continue to 
review  the Group’s overall governance structure. 

146

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

RISK COMMITTEE REPORT

Dear shareholders,
As Chairman of the Risk Committee, I am pleased to present 
the Risk Committee report for the year ending 31 December 
2019. This is my first year reporting as Chairman of the Risk 
Committee as I was appointed on 24 September 2019.

I am looking forward to working with the Risk Committee 
to  further  develop  and 
improve  the  Group’s  risk 
management practices. 

Throughout 2019, the Risk Committee continued to take a 
proactive  approach  to  risk  management  by  closely 
monitoring  and  discussing  the  internal  and  external 
challenges  the  Group  faces.  Along  with  regular  updates 
regarding  the  Group’s  risk  profile,  risk  management 
practices and results, the Committee focused on several 
other issues, namely: 

 ` Leading the review and response to the inspection by 
the NBG as well as related actions by the Georgian 
Office  of  Public  Prosecution  in  relation  to  certain 
transactions  that  took  place  in  2007  and  2008.  In 
addition, the Risk Committee closely monitored  the 
subsequent  enhancements  made  by  the  Bank  to 
relevant internal control systems;

 ` Important new regulations, including the full version 

of the NBG’s responsible lending standards;

 ` Detailed  analysis  of  the  Bank’s  liquidity  and  capital 
position,  and  the  respective  capital  and  funding 
strategy; 

 ` Enhancing the Bank’s operational risk management; and
 ` Review  and  approval  of  the  revised  version  of  the 
Risk Committee terms of reference, in line with the 
requirements of the UK corporate code.

The Risk Committee has also reviewed the analyses that 
have  been  made  on  the  potential  impact  of  COVID-19 
pandemic  on  the  Bank’s  capital  adequacy  and  liquidity 
position.

In January 2020, Nino Masurashvili, Deputy CEO, who was 
previously  in  charge  of  the  development  of  TBC  Bank’s 
retail banking operations, was appointed as the new Chief 
Risk Officer after the departure of the previous Chief Risk 
Officer at the end of his contractual term to pursue other 
career  opportunities.  The  Risk  Committee  carefully 
considered Nino Masurashvili’s appointment as Chief Risk 
Officer  and  recommended  it  to  the  Board.  With  her 
appointment,  the  Group’s  Risk  function  will  be  further 
strengthened  as  Nino  leverages  both  her  detailed 
knowledge  of  the  Group’s  business  and  the  skills  that 
brought significant success in her previous role. 

Arne Berggren
Chairman of Risk Committee
28 April 2020

COMMITTEE RESPONSIBILITIES 

The  Risk  Committee’s  primary  function  is  to  assist  the 
Board  in  its  oversight  of  all  matters  related  to  the  risk 
management  and  compliance  of  the  Company  and  the 
Group,  together  with  implementation  of  the  highest 
standards of business ethics and compliance with all of the 
legal requirements to which the Group is subject.

The Risk Committee is responsible for recommending the 
Group’s risk appetite limits to the Board and monitoring 
the  risk  profile  to  make  sure  that  it  complies  with  the 
established  limits.  It  is  also  responsible  for  reviewing, 
assessing and recommending any actions for the Board to 
take  regarding  the  Group’s  overall  risk  management 
strategy,  as  well  as  the  risk  management  system  and 
internal control framework. In addition, it determines the 
nature and extent of the principal risks the Group is willing 
to take in order to achieve its long-term strategic objectives. 

The  Risk  Committee  advises  the  Board  on  strategic 
transactions focusing on risk aspects and implications for 
the risk appetite and tolerance of the Group. 

The Risk Committee reviews and approves the statement 
concerning  internal  risk  management  and  the  Group’s 
viability  statement  included  in  this  annual  report.  It 
ensures robust assessment of the emerging and principal 
risks  faced  by  the  Group,  including  those  that  would 
threaten  the  business  model,  future  performance, 
solvency and liquidity. 

The Risk Committee is also responsible for overseeing the 
Group’s compliance activities to ensure that it complies with 
all applicable laws and regulations and maintains the highest 
standards of ethical behavior. The Risk Committee supports 
the fostering of an ethical culture within the Group, based on 
the principles of honesty, integrity, fairness and transparency. 
The Risk Committee’s Terms of Reference are available on 
the Group’s website: www.tbcbankgroup.com.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

147

RISK COMMITTEE REPORT CONTINUED

COMMITTEE MEMBERS AND MEETINGS

As  of  2  April  2020,  the  Risk  Committee  consists  of  four 
independent,  non-executive  Directors:  Arne  Berggren 
(Chairman),  Nicholas  Haag,  Maria  Luisa  Cicognani  and 
Tsira  Kemularia.  Biographies  of  the  Risk  Committee 
members can be found on pages 136 to 138. 

Arne  Berggren  joined  the  Board  in  August  2019  as  an 
independent Non-Executive Director. In September Arne 
was  appointed  as  the  Chairman  of  the  Risk  Committee. 
Nikoloz  Enukidze  served  as  the  Chairman  of  the  Risk 
Committee until September 2019, when he left this position 
and was appointed as the Chairman of the Board. The Risk 
Committee meets in person on a quarterly basis. At each 
meeting,  members  review  a  thorough  report  on  the 
quarter’s risk management results as well as updates on 
compliance  and  other  areas  within  its  remit.  The  Chief 
Executive  Officer,  CRO,  head  of  compliance  and  key 
members  of  the  Group’s  risk  and  compliance  teams 
normally  attend  the  meetings.  Additional  sessions  are 
held remotely, if needed. Members’ attendance at the Risk 
Committee’s  meetings  during  the  year,  at  the  Company 
and the Bank levels, are set out in the Directors’ Governance 
statement on pages 128-129.

RISK COMMITTEE ACTIVITIES DURING 2019 

In 2019, the Risk Committee continued to concentrate on 
its  key  responsibilities  of  monitoring  the  Group’s  risk 
management  processes,  promoting  progress  in  risk 
management  tools  and  techniques,  and  implementing 
mitigation actions against prevailing risks.

Moreover, in February 2020, the Risk Committee’s Terms 
of Reference were updated and approved. Minor changes 
were  recommended  by  the  Company  Secretary,  with 
input from the company’s lawyers, in order to bring the 
terms  of  reference  up  to  date  to  reflect  recent 
developments in the UK Corporate Governance Code and 
better to align our mission with the Terms of Reference 
for  other  committees.  This  document  is  available  on 
TBC’s website at www.tbcbankgroup.com.

Risk appetite 
The Risk Committee received and reviewed the risk appetite 
compliance reports at each of its quarterly meetings, during 
which  the  Committee’s  members  discussed  the  Group’s 
risk profile and respective outlook with the management. 
Over the course of 2019, the Risk Committee carried out a 
further review of the updates in risk appetite metrics and 
limits  proposed  by  the  CRO.  Key  updates  made  were  in 
relation  to  the  capital  adequacy,  liquidity  and  funding 
metrics, which were mainly driven by regulatory changes 
and further optimization of the capital structure of the Bank.

In  addition,  certain  temporary  changes  were  applied  to 
the  Bank’s  risk  appetite  metrics  concerning  the  capital 
adequacy. These changes were driven by the measures 
introduced by the NBG as a consequence of the COVID-19 
pandemic.  The  Rrisk  Committee  has  also  reviewed  the 
Bank’s growth prospects and growth appetite.

Credit risk

The  Risk  Committee  reviewed  the  performance  of  the 
Group’s credit portfolio at each meeting during 2019. The 
Risk Committee was presented with a comprehensive risk 
report  covering  the  structure  and  performance  of  the 
Group’s portfolio across business segments, products and 
economic sectors.  Additionally, the portfolio FX share and 
concentration  levels  were  actively  monitored.  At  the 
beginning of 2019, the NBG introduced the full version of 
the  responsible  lending  regulation.  It  defined  income 
verification  techniques,  introduced  caps  on  payment-to-
income  (PTI)  and  loan-to-value  (LTV)  ratios  and  the 
maximum maturity of retail loans; stricter thresholds are 
applied to loans denominated in foreign currency. The Risk 
Committee actively monitored the prudent implementation 
of the regulation as well as the impact of the regulation on 
the Bank’s growth and portfolio quality trends. In addition, 
as part of assessing compliance with the regulatory ratios, 
the Risk Committee discussed the changes to regulatory 
concentration ratios.

In close co-ordination with the NBG, the Bank created an 
extra regulatory loan loss provision buffer to prepare for 
the  potential  impact  of  the  COVID-19  pandemic  on  the 
Georgian economy. As of 31 March 2020, TBC Bank booked 
additional provisions in accordance with local standards in 
amount of c.3.1% of the loan book.

Operational risk 
The  Operational  Risk  department  performed  its  annual 
Risk  and  Control  Self-Assessment  (RCSA).  The  RCSA 
covered  the  most  significant  business  processes  and 
identified  areas  for  further 
improvement.  The  Risk 
Committee actively monitored the process. 

The  Operational  Risk  department  conducted  a 
comprehensive consulting project with the involvement of 
an  external  advisory  company  to  further  enhance  and 
adopt  leading  and  innovative  models  of  operational  risk 
management practices. 

Financial risks 
The  Risk  Committee  closely  re-examined  the  Group’s 
financial  risk  positions  on  a  regular  basis,  including  an 
assessment of the Bank’s risks associated with liquidity, 
FX, banking book interest rates and counterparties. 

In the first quarter of 2019, the Bank experienced a higher 
volatility  of  deposit  flows.  The  decrease  was  primarily 
driven by retail deposit reductions (mostly in January and 
February) prior to the settlement of the NBG investigation, 
but  it  also  reflected  the  effects  of  seasonality.  The  Risk 
Committee  extensively  monitored  the  deposit  flows  and 
analysed  the  various  options  to  meet  the  funding 
requirements.  In  addition,  the  Risk  Committee  reviewed 
detailed assumptions as well as the results of the liquidity 
stress test performed by the risk team.  

Moreover,  as  part  of  assessing  compliance  with  the 
approved  risk  appetite  limits,  the  Risk  Committee 
addressed the NBG’s updated regulations on the changes 
to  interest  rates  for  FX  mandatory  reserves  and  the 
changes  to  FX  mandatory  reserve  requirements.  In 
addition, from October 2019 the Bank’s foreign currency 
mandatory reserve was fully categorized as a high quality 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
 
 
liquid  asset  (HQLA)  for  regulatory  LCR  calculation 
purposes, which had a positive effect on the LCR ratio. 

Additionally, in September 2019, for long-term liquidity risk 
management purposes the NBG introduced the Basel III-
based Net Stable Funding Ratio (NSFR), to which the NBG 
applies supplementary assumptions within its discretion. 
Certain changes to the Group’s risk appetite were applied 
as a result of the regulatory change. 

the  committee  discussed 

Moreover, 
the  potential 
countercyclical  measures,  that  if  necessary,  will  be 
implemented  by  the  NBG 
liquidity 
requirements amid COVID-19 pandemic:

in  relation  to 

 ` Decreasing LCR limits;
 ` Decreasing  mandatory  reserve  requirements 

in 

foreign currency;

 ` Updating  criteria  for  security  or  repo  pledging  to 

support GEL liquidity.  

Capital management
The  Risk  Committee  continued  to  closely  monitor  the 
Bank’s  capital  standing  as  well  as  compliance  with  all 
regulatory 
ratios  under  different  macroeconomic 
scenarios. In 2019, the GEL was volatile having the negative 
impact  on  the  Bank’s  capital  adequacy.  The  committee 
analysed  capital  projections  within  the  context  of  the 
deteriorating of currency rates. 

During meetings, the Risk Committee examined the new 
NBG initiatives that impact the Bank’s capital adequacy as 
well  as  the  expected  changes  to  minimum  capital 
requirements. The key changes were: (i) an update of the 
mandatory  reserve  requirements  for  attracted  funds  in 
foreign currency; (ii) amendments to the proposed timeline 
for  the  incorporation  of  HHI  and  net  GRAPE  buffer 
requirements for Tier 1 and CET 1 capital; and (iii) changes 
applied  to  the  criteria  for  classifying  exposures  in 
residential real estate class assets. 

Certain  changes  to  the  capital  adequacy  risk  appetite 
metrics were discussed and introduced, mainly driven by 
the optimisation of the Bank’s capital structure after the 
issuance of the Bank’s US$ 125 million AT1 instrument.  

In addition, committee members extensively discussed the 
internal  stress  test  methodology,  stress  scenarios  and 
their  impact  on  the  Bank’s  capital  adequacy  and  non-
performing loan ratios. 

Furthermore,  the  Risk  Committee  analysed  in  detail  the 
latest GRAPE letter that the Bank received from the NBG. All 
commercial banks in Georgia receive GRAPE letters as part 
of the NBG’s general supervisory risk assessment program. 
The  letter  summarises  the  key  findings  the  NBG  used  to 
determine the appropriate level for its net GRAPE buffer.1

Amid COVID-19 pandemic, the NBG implemented certain 
countercyclical measures in relation to capital adequacy 
requirements:

 ` Postponing the phasing in of concentration risk and 
the net GRAPE (General Risk Assessment Program) 
buffer capital requirements on CET1 capital, planned 

in March 2020;

 ` Allowing  banks  to  use  the  conservation  buffer  and 
2/3 of currency induced credit risk (CICR) buffer;
 ` Leaving  possibility  of  releasing  all  the  remaining 
pillar  2  buffers  (remaining  1/3  CICR,  concentration 
risk and Net Grape buffers) in case of necessity.

During the time the Bank utilizes conservation and Pillar 2 
buffers,  it  is  restricted  to  make  any  form  of  capital 
distribution. 

The risk committee has reviewed various stress tests and 
anaysed the implications of these changes on the Bank’s 
capital adequacy position. 

Compliance 
Throughout the year the Risk Committee received regular 
information on significant  pieces  of  legislation that were 
introduced during the year. The Risk Committee considered 
and  discussed  several  Group  policies,  including  the 
Group’s  Compliance  Regulation  and  Whistleblowing 
Policy. The key areas of focus for 2019 were: embedding 
the  new  Code  of  Ethics;  addressing  external  adviser 
recommendations on Conflict of Interest Risk Management 
and Anti Money Laundering Risk Management; scrutinising 
the  Bank’s  AML  risk  profile;  and  enhancing  compliance 
training.    The  Risk  Committee  closely  examined  the 
Group’s related parties list and transaction tracker for the 
purposes of the UK Listing Rules and Disclosure Guidance 
and  Transparency  Rules,  as  well  as  related  party 
transactions for NBG purposes. Together with regulatory 
matters, the Risk Committee discussed other compliance 
topics in detail in each quarterly meeting.

NBG inspection related to past transactions 
As reported in the strategic report, the Bank was subject to 
an  inspection  by  the  NBG  during  late  2018  and  2019,  in 
relation  to  certain  transactions  that  the  founders  of  the 
Bank undertook in 2007 and 2008 (see also page 106). The 
Risk Committee was actively involved in the oversight of 
the inspection, and led the response of the directors to the 
NBG report, both currently and in relation to future actions 
that might be required to prevent any recurrence. The Risk 
Committee advised the Board on remedial actions to be 
taken in connection with the NBG report. In particular, the 
Risk  Committee  oversaw  the  directors’  actions  taken  in 
relation to the situation, including reviewing documentation 
and coordinating plans and remedial actions in relation to 
corporate  governance,  current  and  future  related  party 
controls, and controls over identifying and managing any 
potential  conflicts  of  interest  with  regard  to  the  Bank’s 
lending  practices.  This  is  complementary  to  the  Bank’s 
remedial actions agreed with the NBG ( more details are 
given on page 106).

Furthermore,  the  Bank,  with  the  assistance  of  external 
advisers,  undertook  a  review  of  the  Bank’s  relevant 
internal controls systems. Although these reviews did not 

1  The  net  GRAPE  buffer  is  a  pillar  II  capital  add-on  determined 
through the supervisory process for any material risks not covered 
by Pillar I and other Pillar II capital buffers defined under the NBG 
capital adequacy framework

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

149

identify any material deficiencies in the Bank’s existing internal controls and compliance systems, they did make certain 
recommendations for further technical improvements for the Bank. The Risk Committee closely monitored the whole review 
process, extensively discussed the recommendations and monitored progress in the execution of recommendations. 

THE COMMITTEE’S EFFECTIVENESS REVIEW 

The Board and the Risk Committee members conduct a review of the Risk Committee’s effectiveness every year. In 2019, the 
Risk Committee was found to be effective in overseeing the Group’s risk management, compliance activities and ethical 
standards. 

LOOKING AHEAD TO 2020 

Going forward, the Risk Committee will continue to focus on its key responsibilities: assessing quarterly risk results and 
compliance  with  the  Bank’s  risk  appetite,  providing  sign-off  on  transactions  with  the  largest  exposures,  and  facilitating 
progress in risk management tools and techniques. Moreover, the committee will continue to closely monitor the COVID-19 
pandemic developments and its implications on the Bank’s portfolio quality, operations and financial conditions including 
profitability, capital adequacy, liquidity and funding positions.

The Risk Committee will continue closely to monitor the impact that recent and upcoming regulatory changes may have on 
the Bank’s financial standing and the respective implications for risk management processes. In addition, close attention will 
be paid to overseeing the Group’s international expansion activities to ensure that the risks are managed properly across the 
Group. The Risk Committee will continue to focus on the proper management of risks that may arise from further digitalization 
of the Bank’s services.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

REMUNERATION COMMITTEE REPORT

CHAIRMAN’S STATEMENT

Dear shareholders,
As Chairman of the Board Remuneration Committee (the 
“Remuneration Committee”), I am pleased to present the 
Directors’  Remuneration  Report  for  the  year  ending  31 
December 2019.

The Committee continues to ensure that the Remuneration 
Policy is closely aligned with the strategic priorities of the 
Group (as defined below), provides fair rewards and meets 
appropriate  regulatory  requirements  and  best  practice 
standards as well as takes into consideration the views of 
all  stakeholders.  The  Remuneration  Committee  reviews 
annually  both  executive  and  non-executive  Directors’ 
compensation and benchmarks them to ensure that they 
are  aligned  with  best  market  practice.  If  any  material 
change is required, the Remuneration Committee intends 
to consult with shareholders before any new proposal is 
presented for approval at the annual general meeting.

The Director’s Remuneration Policy was approved at the 
2018 AGM and has applied since 1 January 2019. The full 
policy is given in the 2017 Annual Report, which is available 
at  our  website  at  www.tbcbankgroup.com.  In  setting 
the  Directors’  Remuneration  Policy,  the  Remuneration 
Committee  engaged  with  shareholders  and  external 
independent, consultants to ensure that the remuneration 
structure  was  appropriate,  whilst  at  the  same  time 
allowing us to attract and retain the best talent.

Principles of Remuneration 
The  following  principles  have  been  considered  when 
determining executive Directors’ remuneration: 

 ` clarity  and  simplicity  -  the  Remuneration  Committee 
strives to ensure that performance measures are clear 
and straight-forward. Executive Directors’ performance 
against their KPIs (both financial and non-financial) and 
the relative weightings thereof have been disclosed for 
2019. To increase transparency we have also disclosed 
the KPIs and relative weightings for 2020;

 ` risk - the Remuneration Committee has the discretion 
to reduce an executive Director’s variable remuneration 
if specific KPIs have not been met and every element of 
executive Directors’ variable compensation is subject 
to the relevant malus and clawback provisions. Malus 
and clawback apply for up to 3 years after the deferral 
period  ends  (for  deferred  awards)  or  settlement 
(for  conditional  shares  under  the  LTIP).    Triggers 
include,  material  misstatement,  material  downturn 
in financial performance and misconduct that causes 
serious reputational harm. Further, the Remuneration 
Committee  has  the  discretion  under  the  LTIP  and 
deferred annual bonus to reduce awards if it considers 
that either the underlying financial performance of the 
Company or the performance of the individual is such 
that the level of vesting cannot be justified1. 

 ` predictability  -  the  maximum  possible  value  of  the 
executive Directors’ remuneration has been detailed in 
the Remuneration Report at section 2.2 below and in 
the Remuneration Policy; 

 ` proportionality/alignment  with  culture 

- 

the 
Remuneration  Committee  strives  to  ensure  that 
performance measures are aligned with the corporate 
culture  of  the  Group  to  foster  the  right  behavior  and 
deliver remuneration packages that are proportionate 
in 
the  circumstances,  by  measuring  executive 
Directors’  remuneration  against  a  mix  of  financial, 
non-financial and personal KPIs. Further, by deferring 
a  large  proportion  of  executive  Directors’  salary  into 
shares, this intrinsically aligns the executive Directors’ 
pay to the long-term success of the Group and fosters 
a culture of sustainable long-term growth.

Form of Remuneration
The  executive  Directors’  remuneration  for  2019  was 
comprised of:

 ` fixed compensation consisting of both cash-based and 

share-based payments; 

 ` annual  bonus  based  on  the  level  of  achievement 
of  one-year  key  performance  indicators  (KPIs)  and 
consisting of share-based payments only;

 ` Long term incentive plan (LTIP) based on the level of 
achievement  of  performance  measures  over  3  year 
period (2019-2021) and also consisting of share-based 
payments only; and

 ` Pensions and taxable benefits.

The  share-based  payments  in  relation  to  the  fixed 
compensation  and  the  annual  bonuses  are  subject  to 
2-year  continued  employment  condition  and  holding 
period. The employment and holding conditions are lifted 

1  Further  details  of  the  malus  and  clawback  provisions  for  the  LTIP 

and deferred annual bonus are provided in section 10

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

151

REMUNERATION COMMITTEE REPORT CONTINUED

on a phased basis as follows: 50% of the award on the first 
anniversary from the award date and the other 50% on the 
second anniversary from award date. 

As a result, the annual bonus awarded to the CEO and CFO 
represented 69% and 66% of the maximum opportunity in 
2019 respectively.

Share-based  payments  in  relation  to  LTIP  are  subject 
to  2-year  holding  period  (changing  to  3  year  holding 
period  for  new  grants,  please  see  below)  and  continued 
employment requirement once they are delivered.  Shares 
granted under the LTIP, therefore, are subject to a 5 year 
(6 year under new grant) vesting and holding period. This 
approach  ensures  that  the  executive  Directors’  interests 
are  closely  aligned  with  the  Group’s  long-term  strategy 
and shareholders’ interests.

2019 Executive Directors’ KPI and Performance 
The Group recorded strong financial results in 2019. The net 
profit  increased  by  23.5%  year  on  year  (YoY)  and  reached 
GEL 540.3 million, while return on equity amounted to 22.4% 
up by 0.4 pp YoY.  The growth in net profit was supported 
by an increase in net fee and commission income and net 
interest  income.  Because  of  the  recent  National  Bank  of 
Georgia’s regulation limiting lending to high risk customers, 
the net interest margin decreased by 1.3 pp year-on-year 
and stood at 5.6% in 2019 and 5.3% in the fourth quarter of 
2019. By the end of 2019, the net interest margin has been 
fully rebased to the new level reflecting the new rules and 
going  forward  we  expect  it  to  stabilize  at  the  2019  fourth 
quarter level.  The growth in net profits was also strongly 
supported by a decrease in credit loss allowance, which was 
driven by improved performance across all segments. As a 
result, our cost of risk stood at 0.7% in 2019 compared to 
1.6% in 2018. In 2019, our operating expenses increased by 
9.7% year-on-year, resulting in a cost-to-income of 39.9%, 
up by 2.1 pp year-on-year. This increase was mainly related 
to investments in our new ecosystems as well as into the 
Group international expansion.

We also made strong progress towards our new strategic 
objectives, which included the launch of the first customer 
focused  digital  ecosystems 
in  Georgia,  expansion  of 
our  operations  in  Uzbekistan,  the  roll-out  to  certain 
departments  of  our  successful  agile  transformation  and 
important  investment  in  human  capital.  In  parallel,  we 
continued  to  maintain  our  leadership  position  in  digital 
capabilities  and  customer  experience.  The  management 
team  has  been  working  to  fulfill  these  strategic  targets 
and achieved in general the objectives we set in the KPIs. 
Core  banking  and  the  launching  of  Space  in  Uzbekistan 
were  achieved  although  with  a  slight  delay  on  schedule.  
However,  the  Remuneration  Committee  considered  the 
targets as met for the reasons set out in notes to the table 
in section 2.2. More information is given in business model 
and strategy section on pages 12-19. 

The  Remuneration  Committee  has  thoroughly  assessed 
the  executive  Directors’  performance  against  corporate 
financial  and  non-financial  targets  as  well  as  personal 
targets set at the beginning of the year and concluded that 
their performance for 2019 was meeting expectations. The 
detailed disclosure of KPIs and performance assessment 
is given in section 2 of the Remuneration Report. 

The Remuneration Committee reviewed in detail the basis for 
awarding the proposed annual bonus level given the decline in 
share price during the year and the different reasons influencing 
such  decline.  In  particular  it  took  into  account  the  fact  that 
around 85% of the executive Directors’ total compensation is in 
the form of share based payments and that total shareholders 
return (TSR) is included as LTIP performance measure with a 
40% weighting ensuring that executive Directors’ benefits are 
closely aligned with shareholders’ interest.  Considering the 
strong financial performance of the Group and its achievements 
with new initiatives, which continue to successfully implement 
the agreed strategy, the Remuneration Committee determined 
that it was not appropriate to reduce the annual bonus level 
below that which had been determined in accordance with the 
fulfilment of the performance targets set out in section 2.2. 

The  assessment  of  executive  Directors’  performance 
in  2019  against  LTIP  performance  measures  will  be 
conducted  in  2022  based  on  the  results  achieved  during 
the  performance  period  2019-2021  and  will  be  included 
in the executive Directors’ 2021 remuneration payable in 
2022.  The  detailed  information  about  LTIP  performance 
measures and targets is given in section 2.3.

In March 2020, the Remuneration Committee considered 
whether any of the events set out in the Malus or Clawback 
provisions had occurred. It was satisfied that in 2019 none 
of the trigger events occurred and so the Remuneration 
Committee  has  not  used  its  powers  under  the  Policy  to 
reduce or claw back any Share Awards. 

The  Remuneration  Committee  considered  that  the 
Policy  approved  at  the  2018  AGM  was  duly  applied  in 
2019  and  continues  to  fulfill  its  objectives  regarding  the 
compensation  quantum  and  structure  to  deliver  results 
that are in the best interests of the shareholders and the 
Group.

Non-Executive Remuneration
The  non-executive  Directors’  remuneration  is  in  the 
form  of  monthly  fixed  cash  payments  and  is  based  on 
best  practice  against  comparable  FTSE  250  financial 
companies and other regional peers’ board membership 
fees. Non-executive Directors do not receive any form of 
variable remuneration from the Group. 

During 2019, the Chairman and Deputy Chairman of the 
Board resigned and as a result the Board has undergone 
a  restructuring.  As  part  of  this  restructuring,  the  role  of 
the  Deputy  Chairman  has  been  abolished  and  the  fees 
for  the  remaining  non-executive  Directors  (including  the 
new Chairman) have been amended several times during 
the year to also comply with the principles of the NBG’s 
new Corporate Governance Code for Commercial Banks. 
To  assist  the  Remuneration  Committee  determine  the 
appropriate  fees  for  the  non-executive  Directors,  the 
Remuneration  Committee  has  completed  an  externally 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

moderated benchmarking exercise against its peer bank 
and FTSE 250 companies performed by Deloitte corporate 
governance team which was retained as advisor.

As a result, the Remuneration Committee decreased the 
Chairman’s  fees  from  US$  950,000  on  1st  January  2019 
to  US$  338,000  starting  from  25  September  2019  (more 
information is given in section 2.6) and no fees were paid 
to former Chairman and Deputy Chairman for the months 
following  their  resignations.  Committee  Chairmanship 
(from 
and  membership  fees  have  also  decreased 
$28,000  to  $12,000  and  $11,000  to  $6,000  respectively). 
The  Remuneration  Committee’s  decision  to  increase 
individual  non-executive  Directors’  (excluding  Chairman) 
fees  for  board  membership  from  $84,000  to  $130,000 
while reducing committees’ fees has been done within the 
non-executive Directors’ compensation policy approved at 
the 2018 AGM.  All-in-all the total average non-executive 
Director fees, inclusive of board membership in both the 
PLC and the JSC and committee fees, increased by 15% 
compared to 2018.  The rebalancing of the fee structure 
within  the  2018  AGM  approved  limits  reflects  a  number 
of  operational  challenges  which  the  non-executive 
board  members  are  facing.      The  increased  complexity 
of  business  and  the  different  regulatory  environments 
where  the  Group  operates,  the  implementation  of  the 
international expansion, the growth of customer focused 
ecosystems in Georgia and also in our foreign operations 
have  required  substantial  additional  time  commitment 
from  the  Board  which  has  been  estimated  at  around 
17%  in  2019  compared  to  2018.  After  the  changes  were 
implemented,  the  overall  2019  annual  costs  for  non-
executive  Directors’  compensation  reduced  by  39% 
compared to 2018, considering that until the resignation of 
the former Chairman and Deputy Chairman the previous 
level of fees were paid. Further details of the changes can 
be found in sections 9 and 12.

Changes to the Policy
The National Bank of Georgia (NBG), the regulator of JSC 
TBC  Bank,  has  introduced  a  new  Corporate  Governance 
Code  for  Commercial  Banks.    This  includes  certain 
requirements  in  relation  to  executive  remuneration  that 
comes into force from 2020. Therefore, the Remuneration 
Committee  is  preparing  changes  to  the  remuneration  of 
top management and executive Directors in relation to FY 
2020  in  order  to  meet  the  new  regulatory  requirements. 
These changes are summarized below:

1.  extend the holding period under the LTIP from 2 years 
to 3 years, so that starting from 2020, LTIP awards will 
have a 3-year vesting period, which will be followed by 
a 3-year holding period;

2.  change  the  expected  remuneration  in  such  a  way 
that  the  portion  of  the  expected  annual  bonus  as 
a  percentage  of  total  variable  remuneration,  is 
decreased  from  45%  to  40%  for  the  CFO  and  from 
46% to 40% for the CEO, while the expected portion of 
LTIP as a percentage of total variable compensation 
is increased from 55% to 60% for CFO and from 54% 
to 60% for CEO.

These  changes  will  align  even  more  closely  the  executive 
Directors’ interests to those of the shareholders and, as they 
remain within the maximum levels approved by shareholders  
in 2018 under the current remuneration policy, they will not 
require additional shareholders’ approval.

In  addition,  following  Board  restructuring,  as  mentioned 
above and more fully described in the Corporate Governance 
and Nomination Committee Report on pages 143-146 and 
as noted above, we have revised the remuneration policy for 
the non-executive Directors as follows:

 ` The  remuneration  of  the  Chairman  was  reduced, 
while the remuneration of the Deputy Chairman was 
eliminated  given  that  such  position  has  not  been 
maintained;

 ` The remuneration of the other non-executive members 
was changed to reflect the results of the benchmarking 
exercise with peer banks and against overall FTSE 250 
companies, as well as the requirements of NBG’s new 
Corporate  Governance  Code  for  Commercial  Banks. 
The  Remuneration  Committee  also  took  into  the 
account the increased complexity of business related 
to  international  expansion  and  building  of  customer 
focused  ecosystems  as  well  as 
increased  time 
commitment needed to oversee these new initiatives 
as mentioned above. 

The full details are presented in section 12. All changes made 
to  the  remuneration  for  the  non-executive  Directors  are 
within the Policy approved by shareholders at the 2018 AGM.  

Looking ahead 
As  the  business  of  the  Group  continues  to  evolve  and 
expand  with  new  products  and  in  new  markets  beyond 
Georgia  it  remains  of  paramount  importance  that  we 
maintain  a  competitive  Remuneration  Policy  to  attract 
the  best  talent  and  support  our  employees  to  acquire 
and strengthen their required skills to achieve our goals.  
We will continue to actively monitor trends in the market 
and  assess  the  Group  remuneration  competitiveness.    If 
any change will be required we will actively engage with 
shareholders  and  all  stakeholders  to  achieve  the  best 
results  and  align  all  interests.    I  would  like  to  thank  all 
the  members  of  the  Remuneration  Committee  for  their 
support and work during the year as well as the members 
of  the  Board  who  have  provided  always  their  sound 
feed-back  to  the  Remuneration  Committee.    A  fair  and 
competitive  Remuneration  Policy  remains  at  the  core  of 
giving  the  right  incentives  to  the  most  important  assets 
the Group has: its employees.

In 
light  of  the  on-going  COVID-19  pandemic,  the 
Remuneration Committee will continue to closely monitor 
developments  and  consider  if  necessary  adjustments  to 
maintain  alignment  between  performance  and  executive 
pay.  As the medium and long term effects of the current 
events  remain  highly  uncertain 
the  Remuneration 
Committee  will  continuously  review  both  the  quantitative 
and  the  qualitative  factors  which  are  components  of  the 
year-end executive performance assessment.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

153

REMUNERATION COMMITTEE REPORT CONTINUED

Given the on-going COVID-19 pandemic, the executive Directors and top management of JSC TBC Bank have voluntarily 
decided to waive all variable compensation (usually representing majority of total compensation) in relation to 2020 (i.e. 
annual bonus in relation to 2020 year to be awarded in February 2021) and LTIP grants for 2020 year.

I would like to thank our shareholders for their continued support. The alignment of compensation with our shareholders’ 
interest remains an important objective for the Remuneration Committee and our work will continue to adapt to changing 
markets. I will be available at the Company’s upcoming Annual General Meeting to answer any questions in relation to this 
Remuneration Report and our Remuneration Policy. 

Maria Luisa Cicognani 
Chairman of the Remuneration Committee 
28 April 2020

1. REMUNERATION COMMITTEE
The  Company’s  Remuneration  Committee  is  responsible  for  establishing  and  overseeing  the  Group’s  Remuneration  Policy 
principles and considering and approving remuneration arrangements of executive Directors. Full details of the Remuneration 
Committee’s responsibilities are set out in the Remuneration Committee terms of reference, which are available on our website at 
www.tbcbankgroup.com. New terms of reference for both the PLC and the JSC were reviewed and approved on 19 February 2020.

The Remuneration Committee membership is comprised of solely independent non-executive Directors and the Chairman of 
the  Board (whom was independent on appointment) from a wide variety of skills and backgrounds to provide the best input. 
The members of the Remuneration Committee are: Maria Luisa Cicognani (Chairman), Nikoloz Enukidze, Eric Rajendra and 
Nicholas Haag. The meetings of the Remuneration Committee are however always open to other non-executive Directors 
who wish to participate.

The attendance of members at the Remuneration Committee meetings during the year at the Company and the Bank levels 
are set out in the Directors’ Governance Statement on pages 124-130.

1.1 Advisors to the Remuneration Committee

Members of the Remuneration Committee provide valuable input in updating the Remuneration Committee on the recent 
developments in the area of remuneration. However when there is a need, the Remuneration Committee receives external 
advisory services. TBC Bank undertook a review of non-executive Directors’ (NEDs) fees in early 2020 using benchmarking 
data provided by Deloitte.   The externally conducted benchmarking exercise was required to objectively compare the changes 
in the non-executive Directors’ remuneration policy with market practice and ensure that the non-executive board members 
are compensated for their time commitment and responsibilities in an ever increasing complex operational and regulatory 
environment in UK, Georgia and abroad. Further details of the benchmarking exercise are presented in section 2.6.

Deloitte  was  selected  as  a  result  of  a  tender  among  a  short  list  of  three  companies,  all  with  internationally  recognized 
governance and compensation practices and track record in similar assignments.  The amount of fees for the benchmarking 
advice provided by Deloitte was GBP 25,000, net of taxes. The fees were charged on a time and materials basis, which was 
capped at the amount mentioned above.   

The Board is satisfied that Deloitte’s advice was objective and independent and that Deloitte team which rendered advice did 
not have any connections with the Group that may impair its independence. The Board reviewed the potential for conflicts of 
interest and decided that Deloitte had appropriate safeguards in place.

Deloitte also provided other services during the year to the Group, including advice on tax, IFRS 9, accounting treatment and 
IT security. The provision of these services is in line with best governance practice. 

1.2 Statement of voting at Annual General Meeting
The current Remuneration Policy was presented and approved at the 2018 AGM by 99.95% of the votes cast. Last year’s 
Remuneration Report was presented and approved at the AGM on 24 June 2019. The results were as follows:

No

1

Resolution

Votes For

% of votes
cast 

Votes
Against

% of votes
cast

Total votes

% of issued
share capital
voted

Votes
Withheld

To approve 
the directors' 
remuneration 
report

41,393,441

96.84%

1,352,797

3.16% 42,746,238

77.92% 2,647,877

154

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2. SINGLE TOTAL FIGURE OF REMUNERATION
The tables below summarize the total remuneration earned by each director of the TBC Bank Group PLC (hereinafter referred 
as “the Company” or “TBCG PLC”), in respect of their employment with the Company’s Group (including TBC Bank Group PLC 
and JSC TBC Bank, defined as the “Group” or “TBCG”) for the financial years ended 31 December 2019 and 31 December 2018.

2.1 Single total figure for executive Directors (audited)

VAKHTANG BUTSKHRIKIDZE
CHIEF EXECUTIVE OFFICER - US$’000

GIORGI SHAGIDZE
CHIEF FINANCIAL OFFICER - US$’000

69% of max opportunity

66% of max opportunity

2019

51.1%

47.8%

1.1%      

1,887

2019

52.8%

46.9%

0.3%

913

85% of max opportunity

88% of max opportunity

2018

27.7%

71.8%

0.5%

3,356

2018

27.0%

72.8%

0.2%

1,716

Fixed1

Variable2

Pension and taxable benefits

Notes to chart: 

1. 
2. 

Fixed remuneration includes cash salary and deferred share salary.
Variable remuneration includes deferred share bonus award but not the LTIP, which was approved at the 2018 AGM. The first awards made under 
the LTIP were granted in 2019 and are subject to a three year performance period. 

Salary including:
Cash salary1
Deferred share salary

Taxable benefits (gross amount)
Deferred share bonus award2
Pension
Total remuneration3

Notes to table:

Vakhtang Butskhrikidze

2019 US$’0004
964
454
510

2018 US$’000
929
454
475

2019 US$’0004
482
227
255

21

902
-

1,887

18

2,409
-

3,356

3

428
-

913

Giorgi Shagidze

2018 US$’000
464
227
237

2

1,250
-

1,716

1. 
2. 

3. 
4. 

The precise figure of cash salary amounted to US$ 453,994 for CEO and US$ 227,004 for CFO. 
The decrease of deferred share bonus in 2019 as compared to 2018, is mainly due to the rebalancing of the variable remuneration component and 
moving certain part of the annual bonus to LTIP according to the new policy effective from 1 January 2019.   A full explanation of the basis of the 2019 
deferred share bonus awards is given at section 2.2. 
Directors did not receive any other items in the nature of remuneration than those disclosed in the table.
The first LTIP award has been granted in 2019, but has not yet vested and so it is not included in this table to date. More details are given in section 2.3. 

Description

Cash
Salary

Base salary paid in year to executive directors.
No additional fees were paid to executive directors.

d
e
x
i
F

Deferred
share
salary

Deferred share salary comprised of TBCG shares granted in respect of service in the relevant year.

2019

2018

The number of TBCG shares awarded 
as deferred share salary under the new 
remuneration policy, effective from 1 January 
2019, is linked to the base salary and its 
level is fixed at the maximum amount of 
US$510,000 for Mr. Vakhtang Butskhrikidze 
and US$ 255,000 for Mr. Giorgi Shagidze.

The number of shares awarded as deferred 
share salary under the old remuneration 
policy, which expired on 31 December 2018, 
was linked to the base salary and its level was 
fixed at an annual grant of 17,622 TBCG shares 
for Mr. Vakhtang Butskhrikidze and 8,811 
TBCG shares for Mr. Giorgi Shagidze.

Deferred shares in relation to 2019 were 
awarded on 19 February 2020 and its level 
was determined at 24,072 TBCG shares for 
Mr. Vakhtang Butskhrikidze and 12,135 TBCG 
shares for Mr. Giorgi Shagidze. 

Deferred shares in relation to 2018 were 
awarded on 21 March 2019. Deferred 
share salaries are subject to a condition of 
continuous employment for 3 years and malus 
and clawback provisions.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

155

REMUNERATION COMMITTEE REPORT CONTINUED

d Deferred
e
x
i
F

share
salary

e
l
b
a
i
r
a
V

Deferred
share
bonus

Deferred share salaries are subject to a 
condition of continuous employment for 2 
years and malus and clawback provisions. 
The continuous employment condition is 
lifted as follows: 50% of the award on the first 
anniversary from the award date and the other 
50% on the second anniversary from the award 
date.

The 2019 award has been valued using the 
average share price for the period of 9-18 
February 2020 (GBP 12.93 converted into US$ 
using the cross rate of the official exchange 
rates published by the NBG of 2.87 for GEL/
US$ and of 3.72 for GEL/GBP over the same 
period) and grossed up for directors’ income 
tax and national insurance contribution on 
share awards paid by the Company.

The continuous employment condition is 
lifted as follows: 10% of the award on the first 
anniversary from the award date, a further 
10%, on the second anniversary from the 
award date and the final 80% of the on the third 
anniversary from the award date.

The 2018 award has been valued using the 
closing market value of the shares on 21 
March 2019 (GBP16.0 converted into US$ 
using the cross rate of the official exchange 
rates published by the NBG of 2.68 for GEL/
US$ and 3.55 for GEL/GBP on the same date) 
and grossed up for directors’ income tax and 
national insurance contribution on share 
awards paid by the Company.

A deferred share bonus award is granted as a result of the achievement of performance 
measures for the relevant financial year1. 

2019

2018

The award is 100% deferred and is subject 
to continuous employment and malus 
and clawback provisions. The continuous 
employment condition is lifted as follows: 50% 
of the award on the first anniversary from the 
award date and the other 50% on the second 
anniversary from the award date.

Deferred shares in relation to 2019 were 
awarded on 19 February 2020 and its level 
was determined at 42,571 TBCG shares for 
Mr. Vakhtang Butskhrikidze and 20,355 TBCG 
shares for Mr. Giorgi Shagidze.

The 2019 award has been valued using the 
average share price for the period of 9-18 
February 2020 (GBP 12.93 converted into US$ 
using the cross rate of the official exchange 
rates published by the NBG of 2.87 for GEL/
US$ and of 3.72 for GEL/GBP over the same 
period) and grossed up for directors’ income 
tax and national insurance contribution on 
share awards paid by the Company.

The value of the award is determined in 
line with the achievement of performance 
measures, as explained in detail in section 2.2 
below. 

The award is 100% deferred and is subject 
to continuous employment and malus 
and clawback provisions. The continuous 
employment condition is lifted as follows: 10% 
of the award on the first anniversary from 
the award date, a further 10% on the second 
anniversary from the award date and the final 
80% of the on the third anniversary from the 
award date. 

Deferred shares in relation to 2018 were 
awarded on 21 March 2019 and its level was 
determined at 89,421 TBCG shares for Mr. 
Vakhtang Butskhrikidze and 46,674  TBCG 
shares for Mr. Giorgi Shagidze.

The 2018 award has been valued using the 
closing market value of the shares on 21 
March 2019 (GBP16.0 converted into US$ 
using the cross rate of the official exchange 
rates published by the NBG of 2.68 for GEL/ 
US$ and 3.55 for GEL/GBP on the same date) 
and grossed up for directors’ income tax and 
national insurance contribution on share 
awards paid by the Company.

The value of the award is determined in 
line with the achievement of performance 
measures, as explained in detail in the 2018 
Annual Report.

Taxable
benefits

Pension

d
n
a
n
o
i
s
n
e
P

s
t
i
f
e
n
e
b

Taxable benefits comprise medical insurance, and in the case of our CEO, security allowances.

The Group does not pay pension contributions to the executive directors. None of the executive 
directors has a prospective entitlement to a defined benefit pension. Both CEO and CFO opted 
out the state pension scheme which came into force starting from January 2019 in Georgia.

2.2 Basis for determining executive Directors’ deferred share bonus awards (audited) 
The  2019  deferred  share  bonus  awards  made  to  executive  Directors  reflect  the  Remuneration  Committee’s  assessment 
of the extent to which corporate financial, non-financial and personal KPIs were achieved. Such objectives were set by the 
Remuneration Committee and agreed by the Board at the beginning of the year. 

1  Given that the first LTIP award was granted in 2019 and is subject to a three year performance period, no money or other assets were received or 

receivable by the executive directors in 2019 or 2018 (as applicable)

156

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
The  compensation  is  structured  by  reference  to  a  set  of  stretch  targets  for  each  of  the  KPIs  that  is  reviewed  by  the 
Remuneration Committee and approved by the Board. Each KPI has three thresholds: minimum, on target and maximum 
and is evaluated as follows: 

 ` if the achievement is below minimum level, the evaluation is 0; 
 ` if the achievement is at minimum level, the evaluation is 60%; 
 ` if the achievement is on target, evaluation is 100%; 
 ` the achievement at maximum means evaluation at 140%. 

The final evaluation score for the executive Director is made up of the weighted sum of the scores of all KPIs. As a result, 
the evaluation of the executive Director is capped at 140%. If all KPIs are achieved on target, then the executive Director will 
receive 100% of the target bonus. The maximum bonus will be 140% of his target bonus. 

While one KPI can be achieved at maximum level, achieving maximum level across all KPIs is extremely difficult and to date 
it has never been achieved by any executive Director. Therefore, the maximum bonus has never been paid. The Remuneration 
Committee will continue to monitor and implement challenging goals for its executives on an annual basis. 

The below table illustrates the performance measures set for Mr. Butskhrikidze in respect of 2019, as well as his performance 
against  them.  The  selected  financial  performance  measures  are  vital  for  the  long-term  financial  sustainability  of  the 
Group and are also closely monitored by investors. Non-financial measures including strategic HR, agile transformation, 
international expansion and customer experience are closely linked to our strategic priorities as described in our business 
model and strategy section.

Performance measure

Weighting10%

i

l
a
i
c
n
a
n
F
e
t
a
r
o
p
r
o
C

%
0
5
s
e
r
u
s
a
e
m

ROE1

NIM2

Cost of risk3

Cost to income4

Strategic HR5

%
0
4
s
e
r
u
s
a
e
m

i

l
a
i
c
n
a
n
F
-
n
o
N
e
t
a
r
o
p
r
o
C

Agile (number of employees 
trained)

School of technology
(number of IT professionals 
recruited)

Data analytics
(number of employees trained)

Learning and development 
program
for certain departments
(number of employees trained)

Voice of the internal customer 
(score)

Agile transformation6

Increase employee happiness 
from the current level
(by certain percentage)

Improve FTE productivity
(by certain percentage)

Improve time-to-market and
release frequency (increase X 
times)

16%

12%

10%

12%

10%

2%

2%

2%

2%

2%

12%

3%

3%

3%

60%

140%

100%

100%

0%

140%

100%

Minimum
(60%)

Target 
(100%)

Maximum
(140%)

18.25%-20.28%

20.28%-21.40%

>21.40%

KPI 
evaluation
140%

5.18%-5.63%

5.63%-5.80%

5.6%

1.2%-1.08%

1.08%-0.95%

22.4%

>5.80%

<0.95%

0.7%

41.68%-40.30%

40.30%-39.03%

<39.03%

>600

>80

>500

509

>90

39.9%

400-600

545
545

55-80

300-400

40-55

25

300-350

350-500

50-90

80

80

35-50

2.10-2.25

1.93

13%-18%

16%

16%

2.25-2.35

>2.35

0%

13%-18%

>25%

60%

10%-15%

15%-20%

>20%

16%

10%

x1.1-x1.5

x1.5-x2

>x2

>x211

60%

140%

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

157

 
 
 
 
 
 
REMUNERATION COMMITTEE REPORT CONTINUED

Improve organizational agility 
score (by certain percentage)

International expansion7

1. Uzbekistan 

Revenue generation for Payme -
target of UZS 17,153 K

Deployment of core banking
& Space launch

2. Azerbaijan

Loan portfolio growth –
target of AZN 212 mln  

Deposit portfolio growth –
target of AZN 156 mln

Customer experience8

“The Best Service Company
in Georgia” (Retail) 

Number of status clients

%
0
4
s
e
r
u
s
a
e
m

i

l
a
i
c
n
a
n
F
-
n
o
N
e
t
a
r
o
p
r
o
C

l
a
n
o
s
r
e
P

%
0
1
s
I
P
K

Leadership9

3%

8%

4%

2%

2%

4%

2%

2%

10%

5%

5%

10%

Total Corporate KPI-s fulfillment

Total Personal KPI-s fulfillment

Total

90%

10%

100%

13%-18%

18%-25%

>25

0%

4.3%

95%-98%

98%-103%

>103%

157%

Dec 2019

Nov-Sep 2019

Earlier than Sep 2019

Dec

90%-95%

-2.7%

90%-95%

57.5%

95%-105%

>105%

95%-105%

>105%

Negative Gap with 
N1 >=-5% <=0%

Positive Gap with 
N2 >0%<=10%

Gap with #2>10%

56.000-59.000

59.000-64.000

2.7%

>64.000

84.973

A

140%

100%

0%

0%

100%

140%

100%

87%

10%

97%

Notes to chart: 
1. 
2. 

ROE target was increased from above 21.1% in 2018 to above 21.4% in 2019.
The net interest margin (NIM) has been rebased due to National Bank of Georgia’s (NBG’s) responsible lending regulation, which was introduced from the 
beginning of 2019. This regulation limits the JSC TBC Bank’s ability to disburse loans to higher yield, higher risk customers by imposing loan to value and 
payment to income limits for individuals’ loans and introducing additional requirements for income verification. As a result, the maximum NIM target has 
been decreased from above 6.7% in 2018 to above 5.8% in 2019. 
Cost of risk ratio (CoR) has also been rebased due to the NBG’s responsible lending regulation as mentioned above, resulting in the shift of the retail loan 
portfolio mix towards mortgages, which represent lower risk products. As a result, the maximum CoR target has been made more aggressive from below 
1.6% in 2018 to below 0.95% in 2019. 
The maximum target of cost to income ratio (C/I) has been increased due to the following factors:

 `

 `

the NBG’s responsible lending regulation as mentioned above, which was expected to result in decrease  in net interest income  and therefore 
decrease in C/I ratio.
the rapid expansion of the Group and building of digital ecosystems, as well as in international initiatives, which results in increased expenses for 
future development.  

As a result, the maximum C/I target increased from below 37.4% in 2018 to below 39.03% in 2019.  However, on a standalone basis, the bank’s C/I ratio 
improved by 0.3 percentage points YoY and amounted to 35.9% (for this ratio calculation purposes, all relevant group recurring costs are allocated to the Bank). 

In line with our strategic priorities, we have identified key competences that need to be developed within JSC TBC Bank and have introduced relevant 
trainings and learning programs along with their KPIs in this regard.  In addition, to ensure that the front office staff receives maximum support from the 
back offices, the Bank has introduced an initiative of the “voice of the internal customer”. Under this initiative, front office staff assess HR’s support level 
via evaluating the quality of HR service in recruiting substitute staff in front-office, based on internal pre-determined questionnaire.  This KPI is measured 
on a scale of 0-3, with 3 meaning the best quality.
The importance of agile transformation is explained in our strategy section on pages 12-19. Based on the best practice shared by the consultants that TBC 
has been working with in Agile implementation, the selected KPIs are used to measure agile implementation efficiency.  Improved FTE productivity and 
time-to-market and release frequency are direct results of a good agile programme. In addition, employee happiness and improved organizational agility 
score are additional important benefits of the cultural change. TBC has agreed to embark on ambitious targets across all these impact areas and agreed 
to set appropriate KPIs for each of them. Each KPI has a weighting of 3%:

3. 

4. 

5. 

6. 

158

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
 
 
 
 
 `
 `

 `
 `

FTE productivity implies that the same amount of work is conducted with less workforce;
Time-to-market measures the time it takes for the product to be launched from the idea origination date to the release date, while release frequency 
measures how many times the systems are renewed within the given period of time.
Organizational agility score is measured based on internal predefined survey, which is based on the best practice examples;
Employee happiness is measured based on internal predefined survey, which is based on the best practice example prepared by external consultants.  
The Remuneration Committee assessed that this KPI was satisfied at 60%. 

Agile transformation has involved 471 employees during 2019.

7. 

The rationale for our international expansion plans is described in our strategy section on pages 12-19. The selected financial measures are  based on 
management accounts. 
Core  banking  implementation  was  completed  in  December  2019.  Although  the  target  date  was  September  2019,  as  the  executive  Directors  had 
substantially achieved their targets by year-end, the Remuneration Committee assessed the satisfaction of this KPI (which carried a weighting of 2%) at 
100%. In exercising its discretion, the Remuneration Committee considered the successful launch of consumer finance in Uzbekistan and the fact that the 
delay in completing this KPI was due to a delay in the local regulatory licensing process which was outside of the executive Directors’ control. 

8. 

 In line with our aspiration to be the best service provider in Georgia, two measures were evaluated: 

9. 

10. 

 `

to conduct survey among mass retail customers to identify “Best Service Company in Georgia in Retail” in the following industries: banking, telecom, 
insurance and pharmacy, based on surveys conducted by independent research company IPM in December 2019
to be the number one in affluent banking in terms of number of clients.

 `
Leadership skills are assessed by the Board and were regarded to be achieved  “at target” level. Given the increasing complexities of the regulatory 
and operational environments, the Board, under the leadership of the Remuneration Committee, reviewed the CEO leadership performance taking into 
account the following parameters: self-leadership, people leadership, organizational leadership and cultural leadership.  In 2019, it was the first time 
such assessment was conducted within this new framework.  In 2019, the CEO effectively led the Group across a number of challenges, including the 
developments around TBC Bank related to the historic transactions and its potential impact on banks operational level. CEO, with his respective teams, 
has managed to stabilize the bank very quickly and ensured that the business performed as usual. Finally, in such challenging year, under his leadership, 
the Group recorded  very strong financial and operational performance in Georgia and abroad.  
In order to better align CEO’s KPIs with Group strategic priorities and the challenges he was facing in 2019 and which initiated in 2018, we have slightly 
reduced the weightings of the financial measures from 56% in 2018 to 50% in 2019, while the non-financial measures were enhanced to cover strategic 
HR, customer satisfaction, agile transformation and international expansion ambitions with corresponding weighting of 40% in 2019 versus 34% in 2018. 
In 2020 the weightings of the financial measures will be raised to 70% as the overall strategic plan is now much more defined and in order to increase the 
management’s focus on monetizing the Group’s strategic initiatives for the benefit of the shareholders. 

11.  Release frequency: 4-10 times improvement for in-house systems, 1.5-2 times improvement for vendor systems, time-to-market: 2-3 times improvement 

for majority of systems.

As  a  result,  during  2019,  the  Remuneration  Committee  therefore  considered  Mr  Butskhrikidze’s  performance  as  good 
and determined the overall value of the deferred share bonus award of US$ 901,934 (being the net value awarded of US$ 
714,178 grossed up for directors’ income tax and national insurance contribution on deferred bonus share awards). The 
actual deferred share bonus represented 69% of the maximum annual bonus, which could have been achieved if all the 
performance measures had been met. 

The below table illustrates the performance measures set for Mr. Shagidze in respect of 2019, as well as his performance 
against them. The selected financial performance measures are vital for the long-term financial health of the Group and are 
also closely monitored by investors. Non-financial measures including HR and customer experience are closely linked to 
our strategic priorities as described in our business model and strategy section, while TBCG PLC share price performance 
against peer bank measures our relative performance against the closest competitor. The personal KPIs represent the areas 
of the major focus for CFO due to its significant impact on the overall performance of the business. 

Performance measure

Weighting12%

i

l
a
i
c
n
a
n
F
e
t
a
r
o
p
r
o
C

%
7
3
s
e
r
u
s
a
e
m

ROE1

NIM2

Cost of risk3

Cost to income4

Strategic HR5

-
n
o
N
e
t
a
r
o
p
r
o
C

s
e
r
u
s
a
e
m

l
a
i
c
n
a
n
F

i

Agile (number of employees 
trained)

%
3
3

School of technology
(number of IT professionals 
recruited)

Data analytics
(number of employees trained)

11%

10%

8%

8%

8%

1.6%

1.6%

1.6%

Minimum
(60%)

Target 
(100%)

Maximum
(140%)

18.25%-20.28%

20.28%-21.40%

>21.40%

KPI 
evaluation
140%

5.18%-5.63%

5.63%-5.80%

5.6%

1.2%-1.08%

1.08%-0.95%

22.4%

>5.80%

<0.95%

0.7%

41.68%-40.30%

40.30%-39.03%

<39.03%

39.9%

400-600

545
545

55-80

300-400

40-55

25

300-350

350-500

>600

>80

>500

509

60%

140%

100%

100%

0%

140%

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

159

 
 
 
 
 
 
REMUNERATION COMMITTEE REPORT CONTINUED

%
3
3
s
e
r
u
s
a
e
m

i

l
a
i
c
n
a
n
F
-
n
o
N
e
t
a
r
o
p
r
o
C

Learning and development 
program
for certain departments
(number of employees trained)

Voice of the internal customer 
(score)

Agile transformation6

Increase employee happiness 
from the current level
(by certain percentage)

Improve FTE productivity
(by certain percentage)

Improve time-to-market and
release frequency (increase X 
times)

Improve organizational agility 
score (by certain percentage)

International expansion7

1. Uzbekistan 

Revenue generation for Payme -
target of UZS 17,153 K

Deployment of core banking
& Space launch

2. Azerbaijan

Loan portfolio growth –
target of AZN 212 mln  

Deposit portfolio growth –
target of AZN 156 mln

Customer experience8

“The Best Service Company
in Georgia” (Retail) 

Number of status clients

Financial:

Treasury9:

Treasury FX

l
a
n
o
s
r
e
P

%
0
3
s
I
P
K

Treasury Liquidity

International expansion - 
Uzbekistan

Non-financial:

IR10

Leadership11

Total Corporate KPI-s fulfillment
Total Personal KPI-s 
fulfillment
Total

160

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

1.6%

1.6%

8%

2%

2%

2%

2%

9%

5%

2.5%

2.5%

4%

2%

2%

8%

4%

4%

16%

8%

4%

4%

8%

14%

8%

6%

70%

30%

100%

35-50

2.10-2.25

1.93

13%-18%

16%

16

50-90

80
80

>90

100%

2.25-2.35

>2.35

0%

18%-25%

>25%

60%

10%-15%

15%-20%

>20%

16%

10%

x1.1-x1.5

x1.5-x2

13%-18%

18%-25%

4.3%

95%-98%

98%-103%

>x2

>x213

>25

>103%

157%

Dec 2019

Nov-Sep 2019

Earlier than Sep 2019

Dec

90%-95%

-2.7%

90%-95%

57.5%

95%-105%

>105%

95%-105%

>105%

Negative Gap with 
N1 >=-5% <=0%

Positive Gap with 
N2 >0%<=10%

Gap with #2>10%

56,000-59,000

59,000-64,000

2.7%

>64,000

84,973

95% -98% of the 
budget

98% -103% of the 
budget

> 103% of the 
budget

102

95% -98% of the 
budget

98% -103% of the 
budget

> 103% of the 
budget

108%

Same target as mentioned above in corporate KPIs

-10-0%

-18%14

0-10%

>10%

A

60%

140%

0%

140%

100%

0%

0%

100%

140%

100%

140%

120%

0%

100%

67%
25%

92%

 
 
 
 
 
Notes to table: 

1. 
2. 

3. 

4. 

5. 

6. 

ROE target was increased from above 21.1% in 2018 to above 21.4% in 2019.                                                                 
The net interest margin (NIM) has been rebased due to National Bank of Georgia’s (NBG’s) responsible lending regulation, which was introduced from the 
beginning of 2019. This regulation limits the JSC TBC Bank’s ability to disburse loans to higher yield, higher risk customers by imposing loan to value and 
payment to income limits for individuals’ loans and introducing additional requirements for income verification. As a result, the maximum NIM target has 
been decreased from above 6.7% in 2018 to above 5.8% in 2019. 
Cost of risk ratio (CoR) has also been rebased due to the NBG’s responsible lending regulation as mentioned above, resulting in the shift of the retail loan 
portfolio mix towards mortgages, which represent lower risk products. As a result, the maximum CoR target has been made more aggressive from below 
1.6% in 2018 to below 0.95% in 2019. 
The maximum target of cost to income ratio (C/I) has been increased due to the following factors:

 `

 `

the NBG’s responsible lending regulation as mentioned above, which was expected to result in decrease  in net interest income  and therefore 
decrease in C/I ratio. 
the rapid expansion of the Group and building of digital ecosystems, as well as in international initiatives, which results in increased expenses for 
future development. 

As a result, the maximum C/I target increased from below 37.4% in 2018 to below 39.03% in 2019.  However, on a standalone basis, the bank’s C/I ratio 
improved by 0.3 percentage points YoY and amounted to 35.9% (for this ratio calculation purposes, all relevant group recurring costs are allocated to the Bank). 

In line with our strategic priorities, we have identified key competences that need to be developed within JSC TBC Bank and have introduced relevant 
trainings and learning programmes along with their KPIs in this regard.  In addition, to ensure that the front office staff receives maximum support from 
the back offices, the Bank has introduced an initiative of the “voice of the internal customer”. Under this initiative, front office staff assess HR’s support 
level via evaluating the quality of HR service in recruiting substitute staff in front-office, based on internal pre-determined questionnaire.  This KPI is 
measured on a scale of 0-3, with 3 meaning the best quality.
The importance of agile transformation is explained in our strategy section on pages 12-19. Based on the best practice shared by the consultants that TBC 
has been working with in Agile implementation, the selected KPIs are used to measure agile implementation efficiency.  Improved FTE productivity and 
time-to-market and release frequency are direct results of a good agile programme. In addition, employee happiness and improved organizational agility 
score are additional important benefits of the cultural change. TBC has agreed to embark on ambitious targets across all these impact areas and agreed 
to set appropriate KPIs for each of them. Each KPI has a weighting of 2%:

 `
 `

 `
 `

FTE productivity implies that the same amount of work is conducted with less workforce;
Time-to-market measures the time it takes for the product to be launched from the idea origination date to the release date, while release frequency 
measures how many times the systems are renewed within the given period of time. 
Organizational agility score is measured based on internal predefined survey, which is based on the best practice examples;
Employee happiness is measured based on internal predefined survey, which is based on the best practice example prepared by external consultants.  
The Remuneration Committee assessed that this KPI was satisfied at 60%. 

Agile transformation has involved 471 employees during 2019.

7. 

The rationale for our international expansion plans is described in our strategy section on pages 12-19 The selected financial measures are  based on 
management accounts.

Core banking implementation was completed in December 2019. Although the target date was September 2019, as the executive Directors had substantially 
achieved their targets, the Remuneration Committee assessed the satisfaction of this KPI (which carried a weighting of 2.5%) at 100%. In exercising its 
discretion, the Remuneration Committee considered the successful launch of consumer finance in Uzbekistan and the fact that the delay in completing 
this KPI was due to a delay in the licensing process which was outside of the executive Directors’ control.

8. 

In line with our aspiration to be the best service provider in Georgia, two measures were evaluated: 

 `

 `

to conduct survey among mass retail customers to identify “Best Service Company in Georgia in Retail” in the following industries: banking, telecom, 
insurance and pharmacy, based on surveys conducted by independent research company IPM in December 2019
to be the number one in affluent banking in terms of number of clients.

9. 

The figures are based on the bank’s IFRS standalone numbers and envisages meeting certain level of income from foreign exchange operations and 
liquidity management.

2019 Q4 average share price multiple of TBCG PLC compared with that of the peer bank.

10. 
11.  CFO’s leadership skills were assessed based on the following parameters: self-leadership, people leadership, organizational leadership and cultural 
leadership. In addition to his daily functions, in 2019, the CFO successfully led the Uzbekistan project across a number of challenges, which resulted in 
obtaining the pre-licence for starting banking operations in Uzbekistan as well launching consumer finance operations and acquisition of the leading 
payment company, Payme.  In parallel, the CFO successfully led the senior and AT1 bonds issuance project, which has been completed successfully. 
In order to better align CFO’s KPIs with Group strategic priorities, we have reduced the weightings of the personal measures from 38% in 2018 to 30% in 
2019, while the non-financial measures were enhanced to cover strategic HR, customer satisfaction, agile transformation and international expansion 
ambitions with corresponding weighting of 33% in 2019 versus 26% in 2018. In 2020 the weightings of the financial measures will be raised to 54%  in order 
to increase the management’s focus on monetizing the Group’s strategic initiatives for the benefit of the shareholders. 

12. 

13.  Release frequency: 4-10 times improvement of in-house systems, 1.5-2 times improvement of vendor systems, time-to-market: 2-3 times improvement 

of majority of systems.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

161

REMUNERATION COMMITTEE REPORT CONTINUED

14.  The  Remuneration  Committee  and  the  board  have  assessed  IR  function  and  CFO’s  role  as  excellent  in  the  difficult  year  taking  into  the  account  the 
increased focus and need to be closer to the shareholders and other stakeholders. The Remuneration Committee did not use its discretion to increase the 
KPI given the significant drop in the share price, even though this decrease was outside management control.

The Remuneration Committee also considered Mr Shagidze’s performance as good and determined the overall value of the 
deferred share bonus award of US$ 427,721 (being the net value awarded of US$ 341,481 grossed up for directors’ income 
tax and national insurance contribution on deferred bonus share awards). The actual deferred share bonus represented 66% 
of the maximum annual bonus, which could have been achieved if all the performance measures have been met. 

According to Georgian tax code, a company is responsible for paying income tax for its employees. As about 95% of the 
remuneration of CEO and CFO is subject to Georgian tax regulations, the Group pays income taxes for the CEO and CFO total 
remuneration. 

2.3 LTIP award granted in 2019 (audited)
Awards granted in 2019 under the LTIP further align executives with the long-term success of the Group. Awards granted in 
2019 will be subject to a 3 year performance period and will be delivered in 2022. 

Performance conditions and targets together with corresponding weightings for CEO and CFO for LTIP awards granted in 
2019 in respect of performance period 2019-2021 are as follows:

Total shareholder return (TSR) for a 
period of 3 years (2019-2021) 
Average ROE for 3 years (2019-2021) 
Loan market share at the end of 2021 

KPI weight 

Below Target 60%

Target (inclusive) 100%

Above Target (140%)

40% 

40% 
20% 

15-17%

15-18%
34-36%

17-20%

18-21%
36-40%

Above 20%

Above 21%
Above 40%

In the view of the Remuneration Committee the ROE target of above 21% is  challenging given the pressure on net interest 
margin due to responsible lending regulation introduced from 1st January 2019, which limits the bank’s ability to lend money 
to  higher  yield  retail  customers  and  subsequently  negatively  affects  the  Group’s  operating  income.  Further,  the  Group’s 
planned investments into ecosystems and its international expansion initiatives (as explained in more details on pages 12-19 
of the strategic report) were also expected to squeeze the ROE over the LTIP vesting period and these were taken into account 
when setting the target.  In addition, given the expected decrease in cost of equity due to overall improvement in the risk 
profile of the country related to the continued development and expected decrease in the refinance rate, the Remuneration 
Committee considered that the ROE of above 21% would be challenging to reach and would equally be attractive for the 
investment opportunity. Equally, the Remuneration Committee determined that the market share of above 40% was also 
appropriately challenging on the back of maintaining high profitability of ROE above 21% since the intensified competition 
in  the  market  puts  pressure  on  loan  yields.  The  Remuneration  Committee  considers  that  these  targets  strike  the  right 
balance between wanting to foster and achieved long-term growth and success of the Company and to reward exceptional 
performance.

The 2019 awards are scheduled to be released in 2022 and the maximum value of the award has been calculated by reference 
to the share price of GBP 14.92 (10 days average price for the period of 22 February -3 March 2019, that is the average price 
for the 10 days after the preliminary results for the full year 2018 have been released on 21 February 2019, based on data 
published on Bloomberg platform), converted into US$ using average the cross rate of the official exchange rates published 
by the NBG of 2.67 for GEL/US$ and of 3.51 for GEL/GBP over the same period.  Accordingly, the maximum number of shares 
would be 79,217 for CEO and 39,609 for CFO. Please see section 10 for more information. 

162

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2.4 Further details of fixed and discretionary deferred share compensation granted during 2019 (audited) 
The following table sets out further details of the share awards granted to Mr Butskhrikidze and Mr. Shagidze in 2019. 

Date of 
award 

Award
type 

Face value 
% of base 
salary)1 

Face
value

Vakhtang 
Butskhrikidze

21
March
2019

Fixed:
Deferred
share
salary

Not 
applicable

US$ 
474,700

Percentage 
of award 
receivable 
if minimum 
performance 
achieved
Not 
applicable

None

As 
described
in section 
2.1 above

Performance 
measures

Basis 
of which 
award was 
made

End of 
performance 
period

End of the 
vesting/
holding
period

21
March
2019

Discretionary: 
deferred
share bonus

250%

US$ 
2,408,813

Not 
applicable

As 
described
in section 
2.1 above

See section 2.2
of 2018 
Remuneration
Report

3
March
2019

21
March 
2019

Giorgi
Shagidze

LTIP

161%

US$ 
1,554,240

44% of the 
face value of 
the awards

Fixed: Deferred 
share salary

Not 
applicable

US$ 
236,048

Not 
applicable

The 
maximum 
value
under the 
policy
As 
described
in section 
2.1 above

None

See section 2.3

31 Dec 2021

21 
March 
2019

Discretionary: 
deferred share 
bonus

259%

US$ 
1,250,408

Not 
applicable

As 
described 
in section 
2.1 above

See section 2.2
of 2018
Remuneration 
Report

31 Dec 2018. 
Subject to 
continued 
employment 
condition until 
21 March 
2022.

31 Dec 2018. 
Subject to 
continued 
employment 
condition until 
21 March 
2022.

31 Dec 2018. 
Subject to 
continued 
employment 
condition until 
21 March 
2022.

31 Dec 2018. 
Subject to 
continued 
employment 
condition until 
21 March 
2022.

21 March 
2021. The 
holding 
period for 
50% of the 
shares is 
lifted on 21 
March 20202
21 March 
2021. The 
holding 
period for 
50% of the 
shares is 
lifted on 21 
March 20202
1Q 2024 
(after expiry 
of two year 
holding 
period)
21 March 
2021. The 
holding 
period for 
50% of the 
shares is 
lifted on 21 
March 20202
21 March 
2022. The 
holding 
period for 
50% of the 
shares is 
lifted on 21 
March 2020 
1Q 2024 
(after expiry 
of two year 
holding 
period)

LTIP

161%

3 
March 
2019

US$ 
777,120

44% of the 
face value of 
the awards

See section 2.3

31 Dec 2021

The 
maximum 
value 
under the 
policy

Notes to table:

1. 
2. 

3. 

For the purpose of this calculation, the base salary paid in 2019 used.
The deferred share salary/bonus subject to a two year continued employment and holding period, lifted on a phased basis: 50% on first anniversary of 
grant and 50% on second anniversary of grant.
The share price of the deferred share salary and deferred bonus is based on closing market value of share price on 21 March 2019. Plaser refer to  table 
2.1 for  more details.

2.5 Change in remuneration of the CEO compared with the wider employee population
The table below sets out the change in salary, benefits and bonus of the CEO compared with that of the wider employee 
population between 2018 and 2019: 

Salary1
Cash bonus
Taxable benefits
Pension-related benefits3
Deferred share bonus award4
Total remuneration

Chief Executive
3.8%2
0%
13.7%
0%
-62.6%
-43.8%

All employees
-0.4%
10.2%
6.3%
100%
-87.7%
5.8%

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

163

REMUNERATION COMMITTEE REPORT CONTINUED

Notes to table:

1. 

2. 

3. 

4. 

This includes cash and fixed deferred share salary. The CEO’s cash salary increase is calculated in US dollars, the currency which is fixed for his cash 
salary.
The increase in fixed deferred share salary is related to the change in the policy, whereas the amount of deferred shares are calculated by reference to 
cash amount rather than a fixed number of shares as per old policy. 
Starting from 1st January 2019,  the Georgian government introduced the mandatory pension scheme. Under this scheme, 2% of the employee fixed salary 
is to be contributed by the JSC to a national pension fund. CEO has opted out of this scheme, therefore no contributions have been paid by the Company 
in relation to this remuneration.
The actual number of shares awarded to CEO as part of deferred shares bonus decreased from 89,421 shares in 2018 to 42,571 in 2019. The decrease of 
deferred share bonus in 2019 as compared to 2018, is mainly due to the rebalancing of the variable remuneration component and moving certain part of 
the annual bonus to LTIP according to the new policy effective from 1 January 2019. Also, there was a decrease in share price as well. More details are 
given in section 2.1.  The total number of shares granted to all qualifying employees excluding the CEO decreased  due to a decrease in the number of 
shares granted to top management (excluding CEO) by around 53% YoY mainly due to the new remuneration policy as described above, while the number 
of shares granted to other qualifying employees decreased by around 14% YoY mainly due to increase in the share price for the purpose of share based 
bonuses accruals effective from January 2019. (Expense is accrued based on grant date share price, which was fixed at GBP 14.88, whilst grant date share 
price of old scheme was USD 11.00.  GEL/USD exchange rate at grant date was fixed at 2.2399 in old scheme, while in new schemes currency exchange 
rate is not fixed). 

2.6 Single total figure for non-executive Directors (audited) 
The table below sets out the remuneration earned by each non-executive Director for the years ended 31 December 2018 
and 31 December 2019. The independent non-executive Directors are remunerated based on the number of committees they 
serve on and chair. 

Director

Mamuka Khazaradze1

Badri Japaridze1

Nikoloz Enukidze2 

Nicholas Haag 

Eric Rajendra3 

Maria Luisa Cicognani 

Tsira Kemularia

Arne Berggren4

Stefano Marsaglia5

Stephan Wilcke5

Total amounts

Notes to table:

Year
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018
2019
2018

Fees
US$’000
              382 
              950 
              328 
              800 
              248 
              166 
              157 
              135 
                68 
              154 
              149 
                38 
              144 
                33 
                51 
                 0   
0
95
0
83
                1,527
                2,454   

Taxablebenefits6 
US$’000
                           12
37
                           8 
33
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
70

Total Remuneration7 
US$’000 
                   394 
                   987 
                   336 
                   833 
                   248 
                   166 
                   157 
                   135 
                     68 
                   154 
                   149 
                     38 
                   144 
                     33 
                     51 
0   
0
95
0
83
                    1,547 
2,524  

1.  Mamuka Khazaradze and Badri Japaridze stepped down from their respective positions of Chairman and Deputy Chairman of the Board on  25 July 2019
2. 
3. 

Nikoloz Enukidze was appointed to serve as the Chairman of the Board on 25 July 2019 following the resignation of Mamuka Khazaradze.
Eric Rajendra was re-appointed as Independent non-executive Director on 17 September 2019 following his resignation on 15 March 2019 due to health 
reasons. He was appointed as a member of JSC TBC Bank Supervisory Board on 9 October 2019.
Arne  Berggren  joined  the  Board  as  an  independent  non-executive  Director  on  13  August  2019  and  was  appointed  as  a  member  of  JSC  TBC  Bank 
Supervisory Board on 18 July 2019.
Stefano Marsaglia and Stephan Wilcke resigned from the Board in September 2018 and were replaced by Maria Luisa Cicognani and Tsira Kemularia respectively.
Taxable benefits comprise medical insurance, car, and security allowance. From 1st January 2019, as a result of pension reform, the state pension scheme 
was introduced in Georgia, which required TBCG to pay into the pension scheme for Georgian resident directors (including non-executive Directors).  
Individuals above 40 years are allowed to leave the scheme before a certain date. Mamuka Khazaradze was planning to opt out of this scheme but failed to 
do so before the set deadline. The total pension contribution paid by TBCG during 2019 was GEL 12,415 and will be recovered in the first half of 2020. Badri 
Japaridze opted out the scheme and the full amount paid by TBCG (GEL 9,988) was recovered in 2019.
Non-executive Directors have not received any other payments from the Group in 2019 and 2018.

4. 

5. 
6. 

7. 

164

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

The table below shows the detailed breakdown of annual fees paid to non-executive Directors in 2019 and 2018 in relation to 
different roles paid from both TBC Bank Group PLC and JSC TBC Bank:

Fees paid
starting from 
25.09.2019
US$’000*
338
0

Fees paid from 
25.07.2019-
25.09.2019
US$’000*
320
0

Fees paid from 
4.04.2019-
25.07.2019
US$’000*
450
400

130

15
12
6

3

130

15
12
6

3

130

15
12
6

3

Fees paid before 
4.04.2019
US$’0001*

Fees paid
in 2018 
US$’0001 

950
800

84

20
28
11

0

950
800

84 

20 
28 
11

0

Chairman
Deputy Chairman
Non-executive Director
(other than Chairman
and Deputy Chairman) 
Senior independent director 
Committee Chairmanship 
Committee membership 
Employee engagement
designated independent
board  member role

Notes to the table:

1. 

Before 4 April 2019, all board members received the same remuneration for the roles listed above except for Eric Rajendra who received the following 
fees: board membership- US$ 94,533, committee Chairmanship-US$ 27,206, committee membership-US$ 10,882. This was caused by differences in tax 
treatment between jurisdictions, as TBC Bank wished non-executive Directors to receive similar net pay regardless of the tax system applicable to them. 

* These amounts reflect the annual rate that applies, or would have applied, from the date set out for that financial year. 

During  2019,  the  Chairman  and  Deputy  Chairman  of  the  Board  resigned  and  as  a  result  the  Board  has  undergone 
a  restructuring.  As  part  of  this  restructuring,  the  role  of  the  Deputy  Chairman  has  been  abolished  and  the  fees  for  the 
remaining non-executive Directors (including the new Chairman) have been amended several times during the year to also 
comply with the principles of the National Bank of Georgia’s (NBG’s) new Corporate Governance Code for Commercial Banks. 
To assist the Remuneration Committee determine the appropriate fees for the non-executive Directors, the Remuneration 
Committee has completed an externally moderated benchmarking exercise against its peer bank and FTSE 250 companies 
performed by Deloitte corporate governance team which was retained as advisor. As a result, the Remuneration Committee 
decreased the Chairman’s fees from US$ 950,000 on 1st January 2019 to US$ 338,000 starting from 25 September 2019 
and no fees were paid to former Chairman and Deputy Chairman for the months following their resignations. Committee 
Chairmanship and membership fees have also decreased (from $28,000 to $12,000 and $11,000 to $6,000 respectively). 
The Remuneration Committee’s decision to increase individual non-executive Directors (excluding Chairman) fees for board 
membership from $84,000 to $130,000 while reducing Committees’ fees has been done within the non-executive Directors’ 
compensation policy approved at the 2018 AGM.  All-in-all the total average non-executive Director fees, inclusive of board 
membership in both the PLC and the JSC and committee fees, increased by 15% compared to 2018.  The rebalancing of the 
fee structure within the 2018 AGM approved limits reflects a number of operational challenges which the non-executive 
board  members  are  facing.  The  increased  complexity  of  business  and  the  different  regulatory  environments  where  the 
Group operates, the implementation of the international expansion, the growth of customer focused ecosystems in Georgia 
and also in our foreign operations have required substantial additional time commitment from the Board which has been 
estimated at around 17% in 2019 compared to 2018. However, after the changes implemented, the overall 2019 annual costs 
for non-executive Directors’ compensation reduced by 39% compared to 2018, considering that until the resignation of the 
former Chairman and Deputy Chairman the previous level of fees were paid. Further details of the changes can be found in 
sections 9 and 12.    

The table below shows the new fee levels of the “ordinary board member”, which for these purposes is someone whom 
chairs one committee and is a member of two committees. 

Roles
Annual fees in thousands US$ per Role
Annual fees in thousands US$ per 
combined responsibility
Total Annual Fee in thousands US$

Board membership
1 
130 

Committee membership
2
6

Committee Chairmanship
1 
12 

130 

12 

12 

154 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

165

 
 
REMUNERATION COMMITTEE REPORT CONTINUED

Therefore the Board has decided not to make any adjustments to NED compensation, but will keep the matter under review, 
particularly given the time commitment required by the TBC’s governance structure necessitating non-executives to sit on 
two different Boards with different responsibilities and time commitments.

The table below shows the expected remuneration for the non-executive Directors in 2020 (unaudited).

Non-executive Directors’ expected fees in 2020 for both TBC PLC and JSC TBC Bank Boards
Nikoloz Enukidze
Nicholas Haag 
Eric Rajendra
Maria Luisa Cicognani 
Tsira Kemularia
Arne Berggren 
Total amounts

Fees US$’000
350 
175 
142 
              154
157
148 
                1,126

The  above  table  shows  the  total  fees  to  be  paid  to  non-Executive  directors  in  2020  in  relation  to  different  roles  that  they  hold  including  chairman  position, 
committee membership and chairmanship, senior independent director and employee engagement designated independent board member roles.

3. REMUNERATION OF THE TOP MANAGEMENT OF JSC TBC BANK 
The table below summarizes the total remuneration earned by the senior managers of the JSC TBC Bank for the financial 
years ended 31 December 2019 and 31 December 2018, except for the CEO and CFO (as their remuneration information is 
disclosed in section 2 of this Report).

Director 1

Year 

Base salary
US$’000 

Deferred share 
salary  US$’000 

Total for the top managers
excluding CEO and CFO 

Per Top manager excluding
CEO and CFO (average per 6 members) 

2019
2018 
2019
2018 

1,160
1,490 
232
248 

1,479
1,666 
296
278 

Taxable
benefits
US$’000 
26
15 
5
2 

Deferred share 
bonus award
US$’0002 
2,221
5,887 
444
981 

Total 
remuneration 
US$’0003 
4,886
9,058 
977
1,510 

Notes to the table:

1. 

2. 

3. 

In 2019, in addition to CEO and CFO, the top management of JSC TBC Bank was comprised of 5 individuals: Head of Retail Banking, Head of Corporate and 
Investment Banking, Head of MSME Banking, Chief Risk Officer, Chief Operating Officer.  In 2018, the top management also included the position of First 
Deputy CEO, a position which was eliminated in the beginning of 2019.
The decrease of deferred share bonus in 2019 as compared to 2018, is mainly due to the rebalancing of the variable remuneration component and moving 
certain part of the annual bonus to LTIP according to the new policy effective from 1 January 2019.
The first LTIP award has been granted in 2019, but has not yet vested as it is subject to a three year performance period.  Thus, it is not included in this table.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Description

Cash
Salary

Base salary paid in year to executive directors.
No additional fees were paid to executive directors.

d
e
x
i
F

Deferred
share
salary

e
l
b
a
i
r
a
V

Deferred
share
bonus

Deferred share salary comprises of TBCG shares granted in respect of service in the relevant year.

2019

2018

The number of TBCG shares awarded as deferred 
share salary under the new remuneration policy, 
effective from 1 January 2019, is linked to the base 
salary.

The number of shares awarded as deferred share 
salary under the old remuneration policy, which 
expired on 31 December 2018, was linked to the 
base salary.

Deferred shares in relation to 2019 were awarded 
on 19 February 2020. Deferred share salaries are 
subject to a 2 year holding period and malus and 
clawback provisions. The holding condition is lifted 
as follows: 50% of the award on the first anniversary 
from the award date and the other 50% on the 
second anniversary from the award date.

The 2019 award has been valued using the average 
share price for the period of 9-18 February 2020 
(GBP 12.93 converted into US$ using the cross 
rate of the official exchange rates published by the 
NBG of 2.87 for GEL/US$ and of 3.72 for GEL/GBP 
over the same period) and grossed up for directors’ 
income tax and national insurance contribution on 
share awards paid by the Company.

Deferred shares in relation to 2018 were awarded on 
21 March 2019. Deferred share salaries are subject 
to a condition of continuous employment for 3 years 
and malus and clawback provisions. The continuous 
employment condition is lifted as follows: 10% of 
the award on the first anniversary from the award 
date, a further 10%, on the second anniversary from 
the award date and the final 80% of the on the third 
anniversary from the award date.

The 2018 award has been valued using the closing 
market value of the shares on 21 March 2019 
(GBP16.0 converted into US$ using the cross rate of 
the official exchange rates published by the NBG of 
2.68 for GEL/US$ and 3.55 for GEL/GBP on the same 
date) and grossed up for directors’ income tax and 
national insurance contribution on share awards 
paid by the Company

A deferred share bonus award is granted as a result of the achievement of performance measures for the 
relevant financial year. 

2019

2018

The award is 100% deferred and is subject to a 
2 year holding period and malus and clawback 
provisions. The holding condition is lifted as follows: 
50% of the award on the first anniversary from 
the award date and the other 50% on the second 
anniversary from the award date.

Deferred shares in relation to 2019 were awarded on 
19 February 2020.

The 2019 award has been valued using the average 
share price for the period of 9-18 February 2020  
(GBP 12.93 converted into US$ using the cross rate 
of the official exchange rates published by the of 
2.87 for GEL/US$ and of 3.72 for GEL/GBP over the 
same period) and grossed up for directors’ income 
tax and national insurance contribution on share 
awards paid by the Company.

The award is 100% deferred and is subject to 
continuous employment and malus and clawback 
provisions. The continued employment condition 
is lifted as follows: 10% of the award on the first 
anniversary from the award date, a further 10% on 
the second anniversary from the award date and the 
final 80% of the on the third anniversary from the 
award date.  

Deferred shares in relation to 2018 were awarded on 
21 March 2019. 

The 2018 award has been valued using the closing 
market value of the shares on 21 March 2019 
(GBP16.0 converted into US$ using the cross rate 
of the official exchange rates published by the NBG 
of 2.68 for GEL/ US$ and 3.55 for GEL/GBP on the 
same date) and grossed up for directors’ income tax 
and national insurance contribution on share awards 
paid by the Company. 

s
t
i
f
e
n
e
B

Taxable
benefits

Taxable benefits comprise medical insurance and pension contributions in relation to mandatory state 
pension scheme effective from 1st January 2019  in cases where directors are not allowed to opt out of the 
scheme due to their age. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

167

REMUNERATION COMMITTEE REPORT CONTINUED

4. PAYMENTS TO PAST DIRECTORS (AUDITED)
There were no payments made to past directors relating to 2019.

5. PAYMENTS FOR LOSS OF OFFICE (AUDITED) 
There were no payments made in relation to loss of office in 2019.

6. STATEMENT OF DIRECTORS’ SHAREHOLDINGS AND SHARE INTERESTS (AUDITED)
The application of our remuneration structure naturally results in our executive Directors holding a significant number of 
shares that are subject to continued employment conditions. In addition, as described in section 10 below, the Company has 
implemented a new Minimum Shareholding Requirement for executive Directors. Both executive Directors have met the 
Minimum Shareholding Requirement. Deferred shares paid in relation to salary and annual bonus are subject to continuous 
employment and malus and clawback requirements but are not subject to any further performance conditions. 

The  following  table  sets  out  a  summary  of  each  director’s  shareholdings  and  share  interests  in  the  Company  as  at  31 
December 2019. Although not a Company requirement, some non-executive Directors have chosen to become shareholders.

Number of shares
held not subject to
the continued employment 
requirements and/or 
performance conditions1
5,658,048
3,308,616

805,367

110,157

10,000
0
0
0
0
0

Number of shares
held subject to
the continued employment 
requirements2 

Number of shares
held subject to
the performance
conditions3

Total
interests
in shares

0
0

292,502

146,916

0
0
0
0
0
0

0
0

5,658,048
3,308,616

79,217

1,177,086

39,609

296,682

0
0
0
0
0
0

10,000
0
0
0
0
0

Mamuka Khazaradze
Badri Japaridze
Vakhtang Butskhrikidze4
(Executive Director)
Giorgi Shagidze4 
(Executive Director)
Nikoloz Enukidze 
Nicholas Haag 
Eric Rajendra 
Maria Luisa Cicognani
Tsira Kemularia
Arne Berggren

Notes to table:

1. 
2. 

3. 

4. 

This figure includes all shares held which are no longer subject to any conditions or transfer restrictions.
This figure includes shares that are still subject to conditions, including transfer restrictions, a continuous employment condition and malus and clawback 
provision. The figure includes shares granted as deferred share compensation each year as a result of the achievement of performance measures for the 
relevant financial year and deferred share salary. Details of these interests are described at sections 2.1 and 2.2. 
This figure includes awards granted, but not vested, under the LTIP that are subject to performance conditions.  Details of these interest are described at 
section 2.1 and 2.3.
On 19 February 2020, the Company granted deferred shares to Mr Butskhrikidze and Mr. Shagidze, in respect of the year ended 31 December 2019, as part 
of their fixed salary and as the annual bonus. Mr Butskhrikidze has been granted 66,642 shares and Mr. Shagidze has been granted 32,490 shares. These 
shares are subject to two years continued employment and malus and clawback provisions. The continued employment condition is lifted as follows: 50% 
of the award on the first anniversary from the award date and the other 50% on the second anniversary form the award date. In addition, during the first 
quarter 2020, CEO and CFO sold 85,000 and 23,000 shares respectively.  These have not been included in the above table. All figures in the table reflect 
the position as at 31 December 2019. As at 28 April 2020, Mr Butskhrikidze held 251,757 shares and Mr. Shagidze held 125,123 shares that were subject 
to continued employment conditions.  Both the CEO and CFO have met the Shareholding Requirement - as explained in more detail on page 172.  As of 31 
December 2019, the total value of shareholdings for CEO and CFO respectively stood at 1940% and 908% of their respective base salaries. The values are 
calculated based on GBP 13.0 share price as of 31 December 2019  converted into US$ using the cross rate of the official exchange rates published by the 
NBG of 2.87 for GEL/US$ and of 3.76 for GEL/GBP for the same date. Except for the ones described above, no other changes have taken place since the 
end of 2019 till 28 April 2020. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

7. PERFORMANCE: TOTAL SHAREHOLDER RETURN 
The  following  graph  compares  the  total  shareholder  return  (TSR)  of  the  Company  for  the  period  from  the  date  when 
shares were listed on the premium segment of the London Stock Exchange (10 August 2016) to 31 December 2019, with 
the performance of the FTSE All-Share Index and FTSE 250 Index over the same time period. These market indexes were 
selected because they are most comparable to the Company in terms of listing and relevant governance and transparency 
standards. Further, the Company is included in the FTSE All-Share Index and FTSE 250 Index. 

190

180

170

160

150

140

130

120

110

100

90

TBC Bank Total Shareholder Return

FTSE All-Share Total Return Index

FTSE 250 Total Return Index

A ug - 2016

Oct - 2016

D ec - 2016

Feb- 2017

A pr- 2017

Jun- 2017

A ug- 2017

Oct- 2017

D ec- 2017

Feb- 2018

A pr- 2018

Jun- 2018

A ug- 2018

Oct- 2018

D ec- 2018

Feb- 2019

A pr- 2019

Jun- 2019

A ug- 2019

Oct- 2019

D ec- 2019

Set out below is a table that contains details of Company CEO, Vakhtang Butskhrikidze’s remuneration for each financial year 
in the relevant period: 

Financial year 

2019
2018 
2017 

Notes to table: 

Single total figure
of remuneration (US$’000)1 
1,887
3,356 
4,084 

Deferred share bonus as a percentage
of maximum opportunity (%)2 
69%
85% 
88% 

1. 

2. 

Total remuneration includes fixed cash salary, deferred share salary, deferred share bonus award and taxable benefits as described in section 2.1, but 
excludes LITP, which was awarded in 2019 but not yet vested. More details about LTIP is given in section 2.3.
For further details of the deferred share bonus please refer to section 2.2 above.

8. RELATIVE IMPORTANCE OF SPEND ON PAY
The following table illustrates the difference in spend on pay for all employees of the Group and the difference in dividend paid 
to the shareholders between 2019 and 2018. Dividends paid to shareholders in 2019 for the year ended 31 December 2018 
increased by 6% as compared to dividends paid to shareholders in 2018 for the year ended 31 December 2017. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

169

REMUNERATION COMMITTEE REPORT CONTINUED

8. RELATIVE IMPORTANCE OF SPEND ON PAY CONTINUED

Total spend on pay1 (US$’000) 
Dividends paid to shareholders2 (US$’000) 

Notes to table:

Year ended 31 
December 2019
87,900
38,145

Year ended 31 December 2018

% change

86,942
36,156

1%
6%

1. 

2. 

Total  spend  on  pay  includes  total  staff  costs  per  Group’s  IFRS  consolidated  financial  statements  and  is  converted  into  US$  using  average  US$/GEL 
exchange rate of 2.82 for 2019 and of 2.53 for 2018 respectively.
Dividend paid to shareholders are gross amounts converted into US$ using official exchange rate prevailing at the date of payment of the dividends, GEL 
2.85 and GEL 2.46 for 2019 and 2018 respectively. The dividend amount includes both cash and scrip dividend.

9. POLICY IMPLEMENTATION IN 2020 
Remuneration policy for executive Directors
The Remuneration Policy was developed with support of external consultants and KPMG and was approved by the shareholders on 
21 May 2018 at the 2018 Annual General Meeting (AGM). The Policy is applicable starting from 1 January 2019 until the end of 2021.

The National Bank of Georgia (NBG), the regulator of JSC TBC Bank, has introduced a new Corporate Governance Code 
for Commercial Banks.  This includes certain requirements in relation to executives’ remuneration that comes into force 
from 2020. Therefore, the Remuneration Committee will adopt the required modifications  to the remuneration of the top 
management and executive Directors in relation to FY 2020 in order to meet the new regulatory requirements. These changes 
are summarized below:

1.  extend the holding period under the LTIP from 2 years to 3 years, so that starting from 2020, LTIP awards will have a 

3-year vesting period, which will be followed by a 3-year holding period;

2. 

change the expected remuneration in such a way that the portion of the expected annual bonus as a percentage of total variable 
remuneration, is decreased from 45% to 40% for the CFO and from 46% to 40% for the CEO, while the expected portion of LTIP as 
a percentage of total variable compensation is increased from 55% to 60% for CFO and from 54% to 60% for CEO.

These changes will even more align executive Directors’ interests to those of the shareholders.  These changes remain within 
the maximum levels of compensation approved by shareholders under the current remuneration policy and, therefore, they 
will not require additional shareholders’ approval. 

Given the on-going COVID-19 pandemic, the executive Directors and top management of JSC TBC Bank have voluntarily 
decided to waive all variable compensation (usually representing majority of total compensation) in relation to 2020 (i.e. 
annual bonus in relation to 2020 year to be awarded in February 2021) and LTIP grants for 2020 year.

Non-executive Director compensation
See section 2.6 and further details below on changes to the non-executive Directors’ compensation. These are in line with the 
Policy approved by shareholders at the 2018 AGM.

To confirm adherence to best market practice, the Board undertook an externally performed benchmarking exercise regarding 
the compensation of its non-executive Directors including the Chairman.  This exercise was performed by Deloitte, as advisor 
to the Board, which was selected as described in section 1.1.  The benchmarking was performed taking into account two peer 
groups,  which  consist  of  a  primary  peer  group  of  UK  and  Irish  financial  service  firms  and  similar  financial  services  firms 
operating in the Central and Eastern Europe region, as well as a secondary peer group consisting of the FTSE 250 as a whole 
and FTSE 250 financial services firms. The work of the advisors presented challenges both in terms of gathering data, because 
of the availability of public disclosure by the peer banks in the Central and Eastern Europe region, and identifying suitable peers 
with similar governance structure (i.e., double boards and committees under a “mirror board” framework), geographic remit, 
size, performance and regulatory regimes.  In addition the “mirror board” structure which requires the Group non-executives 
to work under two different regulatory environments (UK LSE listed companies and Georgia Banks Corporate Governance 
Code) was a feature that has limited presence within the peer groups. Albeit these challenges, the exercise concluded that the 
Chairman fee is below the lower quartile against the UK and Irish financial services firms. The non-executive Director single 
figure amount, as presented in the table on page 165, is 93% of the cap approved by shareholders in 2018 and the total fee policy 
for the non-executive Directors is within the market competitive range when compared with certain of its closest peers in the 
UK and Irish financial services company peer group (i.e. those companies operating in multiple jurisdictions and/or with non 
executives sitting on different Boards of the same group fulfilling different roles). 

Statement of implementation
In 2020, the Remuneration Committee intends to continue to provide remuneration in accordance with the Policy as set out 
in the tables below and as approved by shareholders at the 2018 AGM. Fees and salaries may be adjusted but in all cases will 
not exceed the maximum levels stated in the relevant Policy, as approved by shareholders at the 2018 AGM. New targets will 
be set for the deferred share bonus awards. The appropriate level of awards (including awards granted under the LTIP) to be 

170

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
granted in 2020 will be assessed by the Remuneration Committee but in all cases they will remain within the maximum levels 
stated in the relevant Policy table as approved by shareholders at the 2018 AGM.

From January 2020 the following will apply: 

Executive directors 

Base salary
(cash and
deferred shares) 

Annual
bonus 

Long term
incentive plan
(LTIP) 

Non-Executive 
Directors

Fees

Notes to table:

The cash and deferred share salaries are set out in the executive directors’ service contracts. 
The Remuneration Committee reserves the right to agree changes to the base salary with the 
executive directors but no change will exceed the maximum levels stated in the Policy approved by 
shareholders at the 2018 AGM. The Remuneration Committee’s discretion will be exercised fairly 
and reasonably and with regard to appropriate comparable market practice and business strategy. 
For 2020, the base salary has been set the same as it was in 2019, that is US$ 963,994 for CEO and 
US$ 482,004 for CFO.
Performance measures and weightings: 
Performance measures for 2020 are summarized below: 

 ` Corporate financial KPIs that are comprised of return on equity, cost to income, net interest 

margin, gap with peer bank in Retail, Micro & SME loans, revenue from ecosystems. 

 ` Corporate non-financial KPIs that relate to strategic HR and customer experience.
 ` Personal KPIs include leadership skills in the case of the CEO and in the case of the CFO, 
include  financial  KPIs  comprising  of  treasury  operations  targets  and  targets  related  to 
international expansion in Uzbekistan and non-financial targets including leadership skills 
and IR function specific KPIs.

The corresponding weightings1 for 2020 are set as follows: 

Corporate financial measures 
Corporate non-financial measures 
Personal KPIs 

Financial
Non-financial

Total 

CEO 
70% 
20% 
10% 
0%
10%
100% 

CFO 
54% 
16% 
30% 
16%
14%
100% 

Performance targets: Specific performance targets are considered commercially sensitive as they 
may give our competitors information about our budget and strategy. The targets will be disclosed 
in the Group’s 2020 annual report.
Performance conditions and targets together with corresponding weightings for CEO and CFO for 
2020-2022  are as follows:

Total shareholder return (TSR)
for a period of 3 years (2020-2022) 
Average ROE for 3 years (2020-2022) 
Loan market share at the end of 2022

KPI weight  Below target 

On target 

Above target 

40% 

15-17% 17-20% Above 20%

40% 
20% 

15-18% 18-21% Above 21%
34-36% 36-40% Above 40%

The fees paid to the non-executive directors will be within the Policy approved by shareholders at 
the 2018 AGM.  The Remuneration Committee has decided to revise the compensation for the non-
executive directors starting from 25 September 2019 as follows: 

 ` Chairman’s remuneration was decreased from US$ 950,000 to US$ 338,0002
 ` Deputy Chairman’s remuneration was eliminated2
 ` Non-executive director’s remuneration was increased from  US$ 84,000 to US$ 130,000
 ` Senior Independent Director remuneration was decreased from  US$ 20,000 to US$ 15,000
 ` Committee Chairmanship remuneration was decreased from US$ 28,000 to US$ 12,000
 ` Committee membership remuneration was decreased from US$ 11,000 to US$ 6,000
 ` Employee engagement designated independent member role remuneration was set at US$  3,000

The full details are given in section 12

1. 

2. 

the  weightings  of  the  financial  measures  have  been  increased  substantially  for  CEO  and  CFO  in  2020  compared  to  2019      in  order  to  increase  the 
management’s focus on monetizing the Group’s strategic initiatives started in the previous years for the benefit of the shareholders. 
The  remuneration  of  the  Chairman  and  Deputy  Chairman  were  revised  to  reflect  the  new  board  structure  following  the  resignation  of  the  founders, 
Mamuka Khazaradze and Badri Japaridze on 25 July 2019

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

171

REMUNERATION COMMITTEE REPORT CONTINUED

10. DIRECTORS’ REMUNERATION POLICY
This section describes the new Remuneration Policy for executive Directors, which came into force on 1 January 2019 and 
will apply for 3 years until the end of 2021. This Policy was approved on 21 May 2018 at the 2018 AGM meeting.

The full Policy is given in 2017 Annual Report, which is available at our website at www.tbcbankgroup.com. 

The summary of the Policy is given in section 10.1.

Under the existing policy, the total executive Directors’ remuneration at target and maximum performance is below the  one 
under the previous policy as illustrated in the 2017 Annual Report on page 137.

As disclosed in last year’s Remuneration Report, in 2019 we made the following amendments to the Policy in relation to 
shareholding requirements:

Shareholder guidelines
Executive Directors naturally build up a significant holding of shares in the Company over time. In order to encourage this 
and set a standard position, the Company has introduced a minimum shareholding requirement of 200% base salary (the 
“Minimum Shareholding Requirement”). There is no set time during which the Minimum Shareholding Requirement must be 
met, but until it is met, executive Directors are expected to hold shares acquired under this Policy. Any deferred shares will 
count towards the Minimum Shareholding Requirement on a net of tax basis. 

Once  the  Minimum  Shareholding  Requirement  has  been  met,  the  executive  Directors  must  maintain  the  Minimum 
Shareholding Requirement for the duration of their employment with the Group. Unless otherwise agreed by the Remuneration 
Committee, the Minimum Shareholding Requirement will also apply for two years post-employment at a level equal to the 
lower of: 

 ` 50% of the Minimum Shareholding Requirement immediately prior to departure; or 
 ` the executive Director’s actual shareholding on departure. 

Deferred shares paid in relation to salary and annual bonus and any vested awards from the LTIP shall count towards the 
Minimum Shareholding Requirement. Unvested awards from the LTIP will not be counted.

Both of the executive Directors have met the Minimum Shareholding Requirement. 

Committee discretion
The  Policy  gives  discretion  to  the  Remuneration  Committee  to  override  the  formulaic  outcomes  of  the  performance 
assessment in relation to annual bonus and LTIP. Further, the Remuneration Committee also has the discretion, any time 
after an award has been granted under the LTIP and deferred annual bonus, to reduce (including to zero) an award if the 
Remuneration Committee considers that either the underlying financial performance of the Company or the performance of 
the individual is such that the level of vesting cannot be justified.

10.1 Summary of Remuneration policy for Chief Executive Director and Chief Financial Director 
Approved by the shareholders on 21 May 2018 at the 2018 Annual General Meeting (AGM). The Policy is applicable starting 
from 1 January 2019 until the end of 2021. 

Component 

Purpose and Link to
Strategy of the Group 

Fixed Pay 

Operation 

Maximum Opportunity 

Base Salary –
in the form 
of cash and 
deferred
shares 

Salaries are determined based 
on market practice and provide 
each executive director with 
a competitive fixed income to 
efficiently retain and reward 
the director, based upon 
each director’s roles and 
responsibilities within the Group 
and relative skills and experience. 

Cash salary

The cash part of the salary is 
aimed to provide fixed cash 
remuneration to reflect the 
complexity of the Group.

Both the cash and deferred 
share salaries are paid in part 
under the executive director’s 
service contract with JSC TBC 
Bank and in part under his 
service contract with TBCG PLC, 
to reflect the executive director’s 
duties to each of them.

Initial salaries are set by the 
Remuneration Committee 
based on responsibilities and 
market data and are set out in 
an executive director’s service 
contract with the Group. 

Cash salary 

The maximum annual cash 
salary for Chief Executive 
Director is US$ 453,994.

The maximum annual cash 
salary for Chief Financial 
Director is US$ 227,004.

Deferred Share Salary 

The maximum annual value for 
the deferred share salary for the 
Chief Executive Director is US$ 
510,000.

Performance 
Measures 

Not
performance
based.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Performance 
Measures 

Not
performance
based.

Component 

Purpose and Link to
Strategy of the Group 

Fixed Pay 

Operation 

Maximum Opportunity 

Deferred share salary

Part of the salary is given in 
the form of shares and despite 
being salary is still intended 
to promote the long-term 
success of the Group by closely 
aligning executive directors’ and 
shareholders’ interests.

Shares are usually delivered 
during the first quarter of the 
second year (i.e. the year after 
the work is performed) and the 
exact date is determined by the 
Remuneration Committee.

Once shares are delivered, they 
remain subject to continued 
employment; 50% of the shares 
for 1 year and the other 50% for 2 
years from the delivery date.

Whilst the shares remain subject 
to the continued employment 
condition, the shares are 
registered in the trustees name 
as nominee for the participants. 
The participants are entitled to 
receive dividends and have voting 
rights from the delivery date.

Base Salary –
in the form 
of cash and 
deferred
shares 

An executive director may be 
paid separate salaries for roles 
and responsibilities at different 
entities within the TBC Group 
as set out in a separate service 
contract with any relevant entity.

Deferred compensation is 
subject to malus during the 
holding period and clawback 
at any time before the third 
anniversary of the end of the 
holding period. If at any time 
after making the deferred 
compensation the award holder 
deliberately misleads the 
Group in relation to financial 
performance,  there is a 
material misstatement in the 
financial results of the Group, 
the award holder’s unit  suffers 
a material downturn in its 
financial performance caused 
by the award holder, there 
is misconduct on the part of 
the award holder that causes 
material harm to the Group’s 
reputation, there is misconduct 
on the part of the award holder 
that causes failure of the risk 
management resulting in a 
material loss to the Group or,  
in relation to unvested awards, 
the Board Committee (or if 
relevant the CEO) considers 
that the underlying financial 
performance  of the Company  
or the performance  of any 
individual award holder during 
the holding period is such that 
the number of shares cannot 
be justified, the Remuneration 
Committee has the right 
to cause some or all of the 
deferred compensation for that 
year or any subsequent financial 
year that is unvested (or unpaid) 
to lapse (or not be paid).

The number of shares is 
calculated based on the average 
share price of the last 10 days 
preceding the Remuneration 
Committee decision date. 
However, the maximum value 
is fixed by reference to a cash 
amount on that date.

The maximum annual value for 
the deferred share salary for the 
Chief Financial Director is US$ 
255,000. The number of shares 
is calculated based on the 
average share price of the last 
10 days preceding the committee 
decision date. However, the 
maximum value is fixed by 
reference to a cash amount on 
that date.

The Company pays income tax1  
and other employee-related 
taxes related to base salary, 
however, taxes are included in 
the maximum amounts.

These numbers include the 
salaries received from both JSC 
TBC Bank and TBC Bank Group 
PLC. The executive directors do 
not receive any additional salary 
from other Group entities.

Salaries are reviewed and may 
be adjusted annually by the 
Remuneration Committee based 
on the available market data on 
compensation among a peer 
group sample selected by the 
Remuneration Committee. The 
Remuneration Committee must 
ensure that the total reward 
potentially available is not 
excessive from the standpoint 
of relevant employment data. 
Any changes to salaries must 
be recommended by the 
Remuneration Committee and 
approved by the Board.

1  The proposed structure of paying income tax for the executives is due to the Georgian tax code, which requires a company to pay income tax on any benefit 

paid to the executives (and does not allow for alternative arrangements). However, the numbers disclosed here include such income tax estimates 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

173

Performance 
Measures 

The KPIs 
consist of 
corporate 
and individual 
performance 
measures.

Corporate KPIs 
include financial 
measures, and 
non-financial 
measures with 
long term focus.

Individual 
performance 
measures 
may include 
individual 
strategic 
objectives which 
vary per person.

The 
performance 
period is one 
year.

The 
Remuneration 
Committee may 
decide to make 
no awards 
where KPIs 
have not been 
met.

REMUNERATION COMMITTEE REPORT CONTINUED

Component 

Variable Pay 

Purpose and Link to
Strategy of the Group 

Operation 

Maximum Opportunity 

To provide a strong 
motivational tool to achieve 
the annual KPIs and to provide 
rewards to the extent those 
KPIs are achieved.

The annual KPIs are chosen to 
align our executive directors’ 
interests with the short terms 
strategic objectives of the 
Group.

The annual bonus is paid as 
to the extent that the annual 
KPIs have been met.

Shares are usually delivered 
during the first quarter of the 
second year (i.e. the year after 
the work is performed) and 
the exact date is determined 
by the Remuneration 
Committee.

Once shares are delivered, 
they remain subject to 
continued employment; 50% 
of the shares for 1 year and 
the other 50% for 2 years from 
the delivery date.

Upon the delivery, whilst the 
shares remain subject to 
the continued employment 
condition the shares are 
registered in the trustees 
name as the nominee for 
the participants and the 
participants are entitled to 
receive dividends.

Annual bonus 
in the form 
of deferred 
shares

The maximum value of 
the annual bonus for the 
Chief Executive Director, 
under the annual 
short-term incentive 
arrangements, is US$ 
1,301,760 (135% of fixed 
salary). The number 
of shares is calculated 
based on the average 
share price of the last 
10 days preceding 
the Remuneration 
Committee decision date. 
However, the maximum 
is fixed by reference to a 
cash amount on the date.

The maximum value 
of the annual bonus 
for the Chief Financial 
Officer, under the annual 
short-term incentive 
arrangements, is US$ 
650,880 (135% of fixed 
salary). The number 
of shares is calculated 
based on the average 
share price of the last 
10 days preceding 
the Remuneration 
Committee decision date. 
However, the maximum 
is fixed by reference to 
a cash amount on that 
date.

The bank pays income 
tax1 and other employee-
related taxes related 
to the award, however, 
taxes are included in the 
maximum amounts.

KPIs are set by the Remuneration 
Committee at the beginning of each 
year in relation to that year (see more 
detail at 10.3(b) of the full Remuneration 
Policy in the 2017 Annual Report). To the 
extent that the KPIs are achieved, the 
Remuneration Committee may decide 
whether an award may be made and the 
amount of such award.

The Group does not pay guaranteed 
bonuses to executive directors.

The nature of the KPIs (but not 
necessarily their specific weightings) 
will be disclosed in the annual report 
published in the performance year. 
However, the precise targets are 
commercially sensitive and will be 
disclosed retrospectively.

The Remuneration Committee may 
also adjust KPIs during the year to take 
account of material events, such as 
(without limitation): material corporate 
events, changes in responsibilities of 
an individual and/or currency exchange 
rates.

Awards are subject to malus during 
the holding period and clawback at any 
time before the third anniversary of 
the end of the holding period. If at any 
time after making the award, the award 
holder deliberately misleads the Group 
in relation to the financial performance, 
there is a material misstatement in the 
financial results, the award holder’s 
unit suffers a material downturn in 
its financial performance caused by 
the award holder, there is misconduct 
on the part of the award holder that 
causes material harm to the Group's 
reputation,  there is misconduct on 
the part of the award holder that 
causes failure of the risk management 
resulting in a material loss to the Group 
or, in relation to awards, the Board 
Committee (or if relevant the CEO) 
considers that the underlying financial 
performance  of the Company  or the 
performance  of any individual award 
holder during the holding period is such 
that the number of shares cannot be 
justified, the Remuneration Committee 
has the right to cause some or all of the 
award for that year or any subsequent 
financial year that is unvested (or 
unpaid) to lapse (or not be paid).

1  The proposed structure of paying income tax for the executives is due to the Georgian tax code, which requires a company to pay income tax on any benefit 

paid to the executives (and does not allow for alternative arrangements). However, the numbers disclosed here include such income tax estimates

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Component 

Long
Term 
Incentive 
Plan 
(LTIP) 

Purpose and Link to
Strategy of the Group 

To provide a strong 
motivational tool 
to achieve long-
term performance 
conditions and to 
provide rewards to 
the extent those 
performance 
conditions are 
achieved2. 

Performance 
conditions are 
chosen to align our 
executive directors’ 
interests with strategic 
objectives of the 
Group over multi-year 
periods and encourage 
a long-term view. 

In order for the shares 
to be delivered, 
the executive 
directors need to 
meet performance 
conditions over the 
3 year performance 
period. 

Shares are usually 
delivered during 
the first quarter of 
the fourth year (i.e. 
the year after the 
performance period 
ends) and the exact 
date is determined 
by the Remuneration 
Committee.

Once shares are 
delivered, they remain 
subject to a 2 year 
holding period and 
continued employment 
requirement.

Awards may benefit 
from dividend 
equivalents. No 
dividend equivalents 
will be paid on any 
awards (or part 
thereof) that lapse on 
or before vesting. 

Operation 

Maximum Opportunity 

Performance 
Measures 

The performance 
conditions for the 
award are set by the 
Committee each year. 
The Remuneration 
Committee’s 
current view is 
that performance 
conditions will include: 

 `

 `

 `

a measure of 
efficiency (e.g. 
ROE) 
a measure of 
share price 
performance (e.g. 
EPS/TSR) 
a measure 
of customer 
experience 

Weightings of these 
measures may vary 
year-on-year. The 
performance period is 
three year. 

The performance 
period is three year.

The maximum value of 
the award for the Chief 
Executive Director in 
any given year, under 
the LTIP to be awarded 
is US$ 1,554,240 
(161% of base salary). 
The number of 
shares is calculated 
based on the average 
share price during 
the 10 days after the 
preliminary annual 
results are published 
for the financial year 
preceding the year of 
grant. (For example, 
awards granted in 
2019, will use the 
average share price of 
the 10 days following 
publication of the 2018 
accounts, in 2019).

The maximum value 
of the award for 
the Chief Financial 
Officer in any given 
year, under the LTIP 
to be awarded is US$ 
777,120 (161% of base 
salary). The number 
of shares is calculated 
based on the average 
share price during 
the 10 days after the 
preliminary annual 
results are published 
for the  financial  year 
preceding the year of 
grant.

The Company pays 
income tax3 and other 
employee-related 
taxes related to the 
award, however, taxes 
are included in the 
maximum amounts. 

The awards may be granted in the form of conditional 
share awards, options or restricted share awards.

Performance Conditions are set by the Remuneration 
Committee and are measured over  a period 
of 3 years. (See more detail at 10.3(c) of the full 
Remuneration Policy in the 2017 Annual Report). The 
Remuneration Committee determines the size of 
award at the end of the performance period, based on 
the extent to which the performance conditions have 
been met. 

The performance conditions and respective targets 
will be disclosed in the annual report published in the 
year of the award. 

The Remuneration Committee may adjust 
performance conditions during the performance 
period to take account of material events, such 
as (without limitation): material corporate events, 
changes in responsibilities of an individual and/or 
currency exchange rates. 

Awards are subject to malus at any time before 
the award vests and clawback for a three years 
after the shares are delivered (for conditional share 
award). If at any time after making the award the 
award holder deliberately misleads the Group in 
relation to the financial performance, there is a 
material misstatement (or material error) in the 
financial statements of the Group, the award holder’s 
unit suffers a material downturn in its financial 
performance caused by the award holder, there is 
misconduct on the part of the award holder that 
causes material harm to the Company’s or the 
Bank’s reputation or there is misconduct on the 
part of the award holder that causes failure of the 
risk management resulting in a material loss to the 
Group, the Remuneration Committee has the right 
to cause some or all of the award for that year or 
any subsequent financial year that is unvested (or 
unpaid) to lapse (or not be paid) and to clawback 
any amount that has already been paid. Further, the 
Remuneration Committee also has the discretion, 
any time after an award has been granted, to reduce 
(including to zero) an award if the Remuneration 
Committee considers that either the underlying 
financial performance of the Company or the 
performance of the individual is such that the level of 
vesting cannot be justified.

For newly issued and treasury shares, the LTIP is 
limited to using 10% in 10 years for employee plans 
and 5% in 10 years for discretionary plans.

These limits will exclude shares under awards that 
have been renounced, forfeited, released, lapsed or 
cancelled or awards that were granted prior to the 
Company’s IPO or awards that the Remuneration 
Committee decide will be satisfied by existing shares. 

The LTIP will be administered by the Remuneration 
Committee. 

2  This element has been added to the Remuneration Policy, in addition to the annual bonus plan, to further extend the long term outlook of the Policy and align executive 

remuneration to long-term success of the Group

3  The proposed structure of paying income tax for the executives is due to the Georgian tax code, which requires a company to pay income tax on any benefit paid to the 

executives (and does not allow for alternative arrangements). However, the numbers disclosed here include such income tax estimates

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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REMUNERATION COMMITTEE REPORT CONTINUED

Performance 
Measures 

Not
performance
based.

Not
performance
based.

Component 

Purpose and Link to
Strategy of the Group 

Operation 

Maximum Opportunity 

The maximum employer 
contribution will not exceed 3% 
of annual salary.

To assist our employees 
in providing for their 
retirement and to 
maintain a market 
competitive benefits 
package to attract and 
retain executive directors.

Pension

The Group may introduce a 
defined contribution pension 
scheme taking into account any 
pension reform or practice in 
Georgia. The operation of the 
pension would be considered by 
the Remuneration Committee 
fairly and reasonably and with 
regard to best market practice

If introduced, there will be no 
provision for the clawback 
or withholding of pension 
payments.

Benefits are in line with 
Georgian market practice 
and are designed to be 
sufficient to attract and 
retain high caliber talent.

Benefits

Benefits available to executive 
directors consist of insurance 
(such as medical, life and 
disability insurance), physical 
examinations, tax gross ups1, 
directors’ and officers’ liability 
insurance, a car service, 
personal security arrangements 
and assistance with filling out 
tax returns, where required. 

The policy is framed by the 
nature of the benefits that the 
Remuneration Committee is 
willing to provide to executive 
directors. The maximum 
amount payable depends on the 
cost of providing such benefits 
to an employee in the location 
at which the executive director 
is based

Executive directors are 
reimbursed for reasonable 
business expenses incurred in 
the course of carrying out duties 
under their service contracts, on 
provision of valid receipts.

A tax equalization payment may 
be paid to an executive director 
if any part of his remuneration 
becomes subject to double 
taxation.

Shareholders should note that 
the cost of providing comparable 
benefits in different jurisdictions 
may vary widely

Disclosure of amounts 
paid will be provided in the 
implementation report and will 
be explained where the cost of 
benefits is significant.

11. REMUNERATION THROUGHOUT THE GROUP 
Remuneration  of  other  top  management  members  of  JSC  TBC  Bank  is  similar  to  that  of  the  executive  members  of  the 
Company. Other senior and middle management across the Group including material risk takers, employees who are part of 
the agile structure, as well as some other key employees receive their entire salary in cash and are also eligible to cash and 
share bonus variable compensation. The share bonuses granted are subject to 3 years of continued employment condition 
and holding period gradually lifting the conditions.  The long-term incentive plan applies only to top management. 

All other employees within the Group receive cash salaries and may be eligible to receive cash bonuses. Executive Director 
and employee pay is reviewed and determined through the application of appropriate market data usually with input from a 
compensation consultant. 

All employees receive a competitive benefit package in line with Georgian market practice and participate in the mandatory 
state pension scheme effective from 1 January 2019. According to the scheme, the company pays 2% of the employee’s total 
remuneration as pension contribution to the State.

1  According to Georgian tax code, the company is responsible for paying income tax for the participants. As about 95% of the remuneration of CEO and 

CFO is subject to Georgian tax regulations, the Company pays respective taxes on the relevant portion

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

12. POLICY TABLE: NON-EXECUTIVE DIRECTORS 
In the same way as the executives, the non-executive Directors receive their compensation both from the Company and the 
main subsidiary, JSC TBC Bank, proportionate to the time spent working on the respective entity’s Boards and committees. 
Starting from 25 September 2019, the compensation for the non-executive Directors is presented in the below table and is 
in line with the Policy approved by shareholders at the 2018 AGM valid until the end of 2021. The Deputy Chairman’s position 
has been eliminated in 2019 as a result of the board restructuring as described in the Corporate Governance and Nomination 
Committee Report on pages 143-146, therefore no payments will be made in relation to this position going forward. 

Component 

Purpose and Link to
Strategy of the Group 

Operation 

Maximum Opportunity as approved in 
2018 AGM

To provide appropriate 
compensation for a non-executive 
Director of the Group, sufficient to 
attract, retain and motivate high-
calibre individuals with the relevant 
skills, knowledge and experience 
to further the Group’s strategy.

In addition, for the chairman, 
the Group’s remuneration policy 
reflects the importance and unique 
role he/she fulfills within the 
Group. 

Fees 

The Group pays fees to non-executive 
directors. The fees are determined 
by the Remuneration Committee and 
the current level of fees include the 
following: 

The maximum annual fees that 
may be paid to the Chairman 
and deputy Chairman are 
US$ 950,000 and US$ 800,000 
respectively. 

The maximum annual fee paid to 
the Senior Independent Director 
is US$175,000. 

The maximum annual fee paid 
for acting as a non-executive 
Director (other than for 
Chairman, deputy Chairman and 
Senior Independent Director) is 
US$165,000. 

 ` The annual fees for the Chairman 

are US$ 338,000

 ` The annual fees for acting as a 

non-executive director (other than 
for Chairman) are US$ 130,000

 ` The annual fees for acting as 

Senior Independent Director, in 
addition to the fees received for 
acting as a non-executive Director 
are  US$ 15,000 

 ` The annual fees for relevant 

committee memberships per 
committee are US$ 6,000
 ` The annual fees for committee 

Chairman positions per committee  
are US$ 12,000

 ` The annual fees for employee 
engagement designated 
independent board member role 
are US$ 3,000

The Remuneration Committee 
reserves the right to structure 
the non-executive Directors’ fees 
differently in its absolute discretion. 
The Remuneration Committee’s 
discretion will be exercised fairly 
and reasonably and with regard to 
appropriate comparable market 
practice and business strategy. 

Fees are generally paid monthly in 
cash. However, the Remuneration 
Committee reserves the right to pay 
the fees on a different basis. Fees are 
periodically reviewed and adjusted by 
the Remuneration Committee, having 
regard to external comparators such 
as the Group’s peer group, the chair or 
committee roles and responsibilities 
and other market factors. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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REMUNERATION COMMITTEE REPORT CONTINUED

Component 

Purpose and Link to
Strategy  

Operation 

To compensate non-executive 
Directors for expenses incurred in 
connection with the performance 
of their non-executive Director 
duties and to ensure the Group 
has the appropriate non-executive 
director input as and when 
required.

Expenses

The Group may reimburse 
non-executive Directors for 
their expenses incurred in 
connection with the performance 
of their duties including 
attending Board and committee 
meetings (such as, for example, 
travel, accommodation, other 
subsistence expenses and 
personal security arrangements), 
Board/committee dinners 
and functions, Board training 
sessions, director’s and officers’ 
liability insurance, advice in 
respect of professional duties 
and corporate hospitality events 
(or the Group may pay such 
expenses directly).

Maximum Opportunity as approved in 2018 
AGM

The policy is framed by the 
nature of the expenses that the 
Remuneration Committee is 
willing to provide to non-executive 
Directors. The maximum amount 
payable depends on the cost 
of providing such expenses in 
the location at which the non-
executive director is based.
Shareholders should note that 
the cost of providing comparable 
expenses in different jurisdictions 
may vary widely. 

12.1 Non-executive Directors
Since non-executive Directors are not employees, they do not receive compensation or benefits. The non-executive Directors 
are not eligible for performance-based share awards. Awards with performance conditions are not part of the non-executive 
remuneration package as we do not wish the non-executive Directors to be driven by short-term Group performance so as 
to maintain their independence as advisors to the Group.

The non-executive Directors are entitled to broad indemnification by the Group pursuant to a deed of indemnity entered 
into with each director and are covered by the Group’s Directors & Officers’ Liability Insurance Policy which is renewed and 
reviewed on an annual basis.

13.  THE  MAXIMUM  REMUNERATION  RECEIVABLE  FOR  EXECUTIVE  DIRECTORS  IN  CASE  OF 
SHARE PRICE APPRECIATION OF 50% UNDER LTIP 
The  maximum  remuneration  receivable  for  CEO  and  CFO  in  case  of  share  price  appreciation  of  50%  during  the  relevant 
performance  period  under  LTIP  would  be  US$  2,331,360  and  US$  1,165,680  respectively.  The  calculation  is  based  on  the 
number of share granted to CEO and CFO under LTIP of 79,217 and 39,609 respectively using the average share price (GBP 
14.92 converted into US$ using the cross rate of the official exchange rates published by the NBG of 2.67 for GEL/US$ and of 
3.51 for GEL/GBP over the same period) during the 10-day period after the preliminary annual results of 2018 were issued on 
21 February 2019.

14. SERVICE CONTRACTS 
The service contracts of Vakhtang Butskhrikidze and Giorgi Shagidze who serve as CEO and CFO respectively and the letters 
of appointment of each non-executive Director are kept at TBC Bank head office at the following address: 7 Marjanishvili 
Street, Tbilisi, 0102, Georgia.

The details about the appointment of directors is given in Drectors’ Report on page 133.

15. CONSIDERATION OF EMPLOYMENT CONDITIONS WITHIN THE GROUP AND OF EMPLOYEE 
ENGAGEMENT 
In accordance with prevailing commercial practice, the Remuneration Committee evaluates the compensation and conditions 
of employees of the Group in determining the Policy with respect to executive Directors. The Remuneration Committee may 
engage  external  advisors  to  assist  in  analyzing  the  overall  policy  and  level  of  remuneration  in  the  Group.  Each  year  the 
Remuneration Committee approves the overall percentage pay out for compensation and material changes to employee 
benefit plans. Consistent with practice in the industry in which the Group operates, it is not the Group’s policy to consult with 
staff on the pay of its directors.

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

The Company recognises the importance of employee engagement in setting remuneration for the executive Directors, NEDs 
and senior management. To this end, in 2019,  the Board appointed Tsira Kemularia as the designated non-executive Director 
to enhance the dialogue between the workforce and the Board and to further strength employee engagement on the topic of 
executive remuneration. For more information about Tsira Kemularia’s appointment, please see  nomination report.

16. CONSIDERATION OF SHAREHOLDER ENGAGEMENT 
Shareholders and their representative bodies have played an active role in developing the Remuneration Policy approved at 
the 2018 AGM. The Remuneration Committee remains committed to ensuring an ongoing dialogue with shareholders and 
will actively engage with shareholders and all stakeholders with respect to any changes to the Policy to achieve the best 
results and align the interests of all. 

17. MINOR CHANGES 
The Remuneration Committee may make, without the need for shareholder approval, minor amendments to the Policy for 
regulatory, exchange control, tax or administrative purposes or to take account of changes in legislation.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

179

AUDIT COMMITTEE REPORT

Dear shareholders,

I am pleased to present the Audit Committee Report
for the Group.

Nicholas Haag
Chairman of the Audit Committee
28 April 2020

SIGNIFICANT ISSUES FOR AUDIT 
COMMITTEE IN 2019
 ` Internal  and  external  (Big  4  firm)  inspection  of 
the  historic  transactions  investigated  by  the  NBG, 
case  coordinated  by  the  Audit  Committee  -  events 
established;

 ` Engagement  with  regulator 

(National  Bank  of 
Georgia) and other stakeholders on the case - matter 
settled with regulator; 

 ` Supervised “lessons learned” analysis from historic  

case and policy refinements implemented;

 ` Review  of  terms  of  reference  for  Committee  and 
appropriate interface between Audit, Risk and other 
committees - clarified and simplified;

 ` Review  of  a  range  of  IT  issues  and  optimisation  of 
Internal Audit coverage of IT and Cybersecurity risks 
- decided on co-sourcing solution with Big 4 provider;
 ` Project “Internal Audit 3.0” to optimise function - on track;
 ` Commissioning of first External Quality Assessment 
function  -  compliant  status 

Internal  Audit 

of 
confirmed by Big 4 specialist;

 ` Consideration  of  audit  and  control 

implications 
around  expansion  of  Group  into  new  geographies 
and  business  lines  e.g.  Uzbekistan,  ecosystems, 
insurance - continuing focus with Management and 
discussed with internal and external auditors;

 ` Implications for controls and the financial reporting 
of  Group’s  broad,  agile  and  data-centric  change 
agenda  - discussed with Management and internal 
and external auditors;

 ` Supervision  of  accounting 

judgements  around 
macroeconomic forecasts under multiple economic 
scenarios  in  light  of  regional  instability  and  local 
volatility (e.g. currency) and uncertainty factors;
 ` Transition  to  new  senior  engagement  partner  at 

external auditor (PwC) - executed smoothly; 

 ` A  review  of  cultural  and  behavioural  standards 
and  procedures  within  the  Group  undertaken  by 
Internal Audit- completed with recommendations for 
incremental improvements being implemented;

COMMITTEE STRUCTURE, ROLE
AND STATEMENTS MADE
The Audit Committees of the Bank and Company (together 
the “AC” or the “Committee”) remain primarily responsible 
for  overseeing  the  financial  reporting  process  including 
the  appointment  of  external  auditors  and 
the 
implementation  of  appropriate  accounting  policies  and 
practices  ensuring  the 
integrity,  accuracy  and  full 
disclosure  of  the  Group’s  financial  condition  and  helping 
the  Board  to  assess  the  ‘going  concern’  status  of  the 
Company and to make its Viability Statement. Committee 
members  have  considered  the  accounting  treatment 
adopted by Management. We have given the Board of the 
Company our view  that it is appropriate to adopt the going 
concern  basis  of  accounting  in  the  preparation  of  our 
financial statements. PwC’s conclusions on going concern 
are  set  out  on  page  195.  We  reached  this  decision  in 
conjunction with detailed input from Management and the 
Risk  Committee  regarding  capital  adequacy  projections 
for the Group. 

The  Committee  reviews  relevant  content  in  the  Annual 
Report,  preliminary  and  interim  statements  as  well  as 
other  financial  releases.  We  check  the  clarity  and 
completeness  of  disclosures  and  ensure  that  these  are 
properly  set  in  context.    We  also  supervise  the  Bank’s 
systems of internal control in relation to financial reporting 
and certain operational risks including supporting internal 
investigations  into  any  identified  control  weaknesses  or 
fraud events.  We evaluate Management’s competence in 
all  these  areas  ensuring  that  they  take  necessary 
corrective  steps  in  a  timely  manner  to  address  any 
vulnerabilities.  Review of financial statements remains a 
core  role  of  the  Committee  but  it  also  validates  wider 
information related to the Group’s financial data which is 
included  in  strategic  reports  and  corporate  governance 
statements.

The  Committee,  together  with  the  Risk  Committee, 
represent  an  important  governance  ‘cluster’.  Over  the 
course  of  2019,  the  Committee  continued  to  coordinate 
closely with other committees of the board.  In respect of 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

risk assessment, upon the appointment of a new Chairman 
of the Risk Committee, we jointly reviewed the interface 
between  the  Committee  and  the  Risk  Committee.  There 
was  some  useful  internal  debate  about  the  optimal 
committee  to  supervise  issues  in  relation  to  IT  and,  in 
particular, cybersecurity, which is an ever more important 
focus  for  the  entire  Board.  Historically  there  was  some 
overlap and duplication of this area between committees 
and  it  was  decided  that  the  Risk  Committee  should  be 
unambiguously responsible for it given the obvious wider 
risk implications. The Committee will however continue to 
support Risk Committee in this objective and will ensure 
that  Internal  Audit  devotes  sufficient  attention  to  these 
potential vulnerabilities. Likewise the Committee worked 
with  the  Remuneration  Committee  to  confirm  that  there 
are  no  false  incentives  which  could  weaken  controls  or 
might introduce management bias for example in terms of 
expected credit losses in the loan portfolio and provisioning 
and valuations.

The Committee bases its activities on information available 
at the time of its discussions. Such information is typically 
provided by Management. The Committee is satisfied that 
it receives sufficient, reliable and timely information from 
Management and from our internal and external auditors.  
Management  takes  the  initiative  in  supplying  financial 
information rather than waiting to be asked although the 
Committee frequently does request additional data or fact-
checked evidence and this is provided in a thorough and 
prompt  fashion.    The  lines  of  communication  with 
Management  are  open  with  constructive,  candid  and 
continual  dialogue  taking  place  throughout  the  year.  We 
note  and  appreciate  that  in  our  view  Management  have 
typically  displayed  a  pattern  of  professional  caution  and 
conservatism  when  drafting  financial  statements.    The 
Committee draws on sufficient administrative resources 
and benefited in 2019 from the reinforcement of the Board 
secretariat  and  valuable  input  from  the  outsourced 
Company  Secretary  in  aligning  our  work  with  FTSE350 
best practice.

We continue to pay attention to all annual reviews by the UK 
Financial Reporting Council (FRC) regarding interpretation 
of the Code and Accounting Standards and seek to apply 
these refinements to the Group, as is demonstrated in this 
report.

We  are  increasingly  conscious  of  our  legal  and  social 
obligations  to  protect  not  only  shareholders  with  the 
transparency and clarity of our financial reporting, but the 
interests of all stakeholders. This is reflected also in the 
Group’s Section 172(1) reporting set out on pages 52 to 55.  
This  report  has  been  designed  with  all  stakeholders, 
including  potential  shareholders,  lenders,  suppliers  and 
customers in mind.

COMMITTEE COMPOSITION,
COMPETENCE AND INDEPENDENCE 
The Committee of the Group comprises four non-executive 
Directors.  We  welcomed  Arne  Berggren  who  joined  the 
Committee  soon  after  his  election  to  the  Supervisory 
Board in July and Board in August 2019. Mr. Berggren was 

(the 

appointed to the Committee, following his appointment to 
the  Board,  on  the  recommendation  of  the  Corporate 
“CGN 
Governance  &  Nominations  Committee 
Committee”).  He  underwent  an  extensive 
induction 
programme,  including  in  areas  pertaining  to  audit.  Mr. 
Berggren  has  worked  in  executive  and  non-executive 
capacities  for  a  wide  range  of  national,  international, 
governmental  and  private  sector  organisations  and  has 
experience on the audit committee of other London Stock 
Exchange listed banks. In accordance with UK governance 
standards, Nika Enukidze was required to step down from 
the  Committee  upon  being  appointed  Chairman  of  the 
Bank in August 2019 and Company in July 2019.

Nicholas Haag was appointed  Senior Independent Director 
of the Group in August 2019 and remains Chairman of the 
Audit Committee. The fact that Arne Berggren chairs the 
Risk  Committee  creates  an  additional  synergy  between 
these  key  committees.  Mr.  Haag  sits  on  all  Committees 
which  gives  him  useful  insights  also  in  his  capacity  as 
Chairman  of  the  Committee.  The  membership  of  the 
Committee has reduced from 5 to 4 during the year but we 
would  hope  that  the  planned  new  member  of  the  Board 
and the Supervisory Board will join the Committee during 
the first half of 2020. The Chairman would like to express 
his thanks to Eric Rajendra who served on the Committee 
in the first half of 2019 (and over many prior years) and I am 
delighted that he is able to rejoin the Board following his 
recovery from a period of illness.

The Committee welcomes the continued development of 
the  mirror  boards  structure  between  the  Bank  and 
Company  as  this  greatly  simplifies  the  ability  of  the 
Committee to fulfil its responsibilities across jurisdictions 
bearing  in  mind  that  the  vast  majority  of  the  Group’s 
activities  are  concentrated  in  Georgia  and  given  the 
challenge otherwise of coordinating disparate supervisory 
functions  for  external  and  internal  audit  and  control 
between London and Tbilisi.

All  non-executive  Directors  have  been  deemed  as 
independent  under  the  Code  applicable  to  companies 
listed  on  the  premium  segment  of  the  London  Stock 
Exchange. In addition, members of the Committee continue 
to satisfy the director independence criteria as defined by 
the  Georgian  Law  of  Banks.  We  are  confident  that  all 
members continue to exercise fully independent judgement 
in all matters related to the Committee’s activities.

All members of the Committee (see biographies on pages 
136-139) are financially literate, have an understanding of 
corporate  financial  matters  and  possess  a  detailed 
understanding  of  the  financial  services  sector,  with 
backgrounds  primarily  in  banking  in  the  EU  and/or  in 
emerging and frontier markets over multiple continents. 
We bring a collective view to the attention of the Board and 
in  2019  there  were  no  material  areas  of  disagreement 
(“disconnection”) between members of the Committee or 
between the AC and the Board. We are fortunate in having 
added Tsira Kemularia to the Committee last year (2018) 
as  she  brings  wider  perspective  from  the  non-banking 
industry. She has assumed a senior internal audit position 
at  Royal  Dutch  Shell,  the  largest  company  in  Europe  by 
revenue, which brings us additional valuable experience in 

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financial  experience 

leading-edge  financial  controls.  Most  members  of  the 
Committee have served on or chaired other banks’ audit 
and  risk  committees  which  gives  them  the  commercial 
and 
to  guide  and  challenge 
Management and internal and external auditors. The fact 
that we still have a Georgian national (Ms. Kemularia) on 
the Committee delivers further local context and insight 
without jeopardizing independence.

The Board has confirmed that the Committee has recent 
and  relevant  expertise  to  operate  effectively  and  it  calls 
upon  expert  external  resources  as  and  when  required. 
Only one member of the Committee has a substantially full 
time  executive  role  in  another  organisation,  all  other 
members  spend  their  time  on  other  supervisory  type 
boards  and  all  have  sufficient  time  to  devote  to  their 
responsibilities towards the Group. Appropriate training is 
available to members of the Committee and recent training 
has  focused  on  Board-wide  governance  optimisation 
including  AML  topics  which  obviously  touch  on  financial 
controls.  The  intention  is  to  undertake  more  specific 
externally-facilitated  training  for  the  Committee  in  2020 
with a focus on technical and governance-related market 
developments in accounting and financial control.

plans 

succession 

We continue to review, with our CGN Committee, suitable 
medium-term 
for  Committee 
membership. Our priority as before would be to select a 
future member with a technical background in the audit 
industry  but  recognise  that  the  Board  also  has  other 
priorities in terms of skills sought from future incoming 
directors  especially  in  the  area  of  IT  and  digital  banking 
and we regard accumulating expertise in these areas as 
also critical to safeguarding the quality of control functions 
within the Group.

ATTENDANCE AT COMMITTEE
The attendance levels at the Company’s Audit Committee 
meeting over 2019 was 100%. The majority of meetings took 
place  in  London  and  were  either  physical  in-person  or 
telephonic meetings, in the latter case with most attendees 
participating  from  locations  in  the  UK,  where  3  of  the  4 
Committee  members  reside.  Attendance  for  the  Bank’s 
Committee meetings was also 100%. As with 2018, a high 
proportion of these meetings were held in Georgia as the 
Committee continues to maintain a deep level of interaction 
with a range of on-the-ground staff, especially in internal 
audit, finance and control roles and this is most practically 
undertaken by hosting meetings in the Bank’s home country.

For the table regarding the composition and formal meeting 
attendance for the Audit Committees of the Company and 
the Bank in 2019 please refer to the pages 128-129. 

COMMITTEE MEETING FORMAT
AND FREQUENCY OF MEETINGS 
In the course of 2019, there were 14 formal meetings of the 
Committee  and  12  for  the  Bank’s  audit  committee.  The 
minutes  for  the  Bank’s  meetings  were  shared  with  the 
NBG.  In  addition,  members  of  the  Committee  are  in 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

telephone  or  email  contact  with  each  other  on  various 
matters relating to Committee work on an almost weekly 
basis. 2019 was an especially busy year for the Committee 
given  the  extra  and  often  complex    work  involved  in  the 
review of historic events related to alleged impropriety by 
the  founders  of  the  Bank  and  reporting  on  these  to  the 
wider  Board.  The  attendances  of  members  at  the  Audit 
Committee  meetings  during  2019  are  set  out  in  the 
Directors’ Governance statement on pages 124-130.

At each formal meeting, the Committee met with senior 
members of Management, and Internal and External Audit.  
We have a standing invitation for the CEO, CFO and CRO to 
attend our meetings and their attendance and contributions 
were  gratifyingly  high.    Our  External  Auditors,  PwC,  are 
invited to participate in and contribute to meetings on all 
topics where there is not a direct conflict of interest (for 
example when discussing reappointment of the auditors, 
their performance, independence or fees).

The  Committee  met  at  least  twice  in  or  around  each 
quarter of 2019, broadly in sync with our quarterly financial 
reporting  cycle.  At  least  one  such  quarterly  meeting 
coincided with the timing of Board meetings of the Group, 
with the Committee meeting prior to the Board so we could 
formally present our summary findings to the latter. Such 
reports  sometimes  highlighted  scope 
for  process 
improvement  and  invited  responses  from  Management 
which  led  to  follow-up  actions,  formally  minuted  by  the 
Board.

AUDIT COMMITTEE EFFECTIVENESS 
The  Committee’s  Terms  of  Reference  were  reviewed  in 
November  2019  and  the  update  version  was  approved  in 
February 2020. Minor changes were recommended by the 
Company Secretary, with input from the Company’s lawyers, 
in  order  to  bring  the  charter  up  to  date  to  reflect  recent 
developments in the Code and align better our mission with 
the  Terms  of  References  for  other  committees.  This 
document is available on the Company’s website at: https://
tbcbankgroup.com/about-us/governance/committees/. 
The Audit Committee Policy of the Bank was reviewed and 
approved by the Supervisory Board of the Bank in February 
2020. 

In November, the Committee conducted an annual Audit 
Committee  Evaluation  (formally  known  as  the  annual 
Effectiveness  Self-Review)  coordinated  by  the  Company 
Secretary  and  using  an  extensive  and  customised 
questionnaire  drawing  on  international  best  practice 
surveys. In addition the whole Board included in its wider 
Self-Assessment certain questions relating to the efficacy 
of  the  Committee  amongst  other  committees.  Both  the 
Committee  and  the  Board  concluded  that  the  former  is 
constituted properly, operates effectively and carries out 
all its responsibilities as laid out in its Terms of Reference. 
Nevertheless,  we  see  scope  for  further  improvement 
especially in the division of oversight activity with the Risk 
Committee  and  the  greater  formalisation  of  an  annual 
work plan for the Committee.  Overall, the intention is to 
elevate to every meeting the most relevant systemic and 
strategic  issues  facing  the  Group.  The  Chairman  of  the 

Committee  is  working  with  the  Company  Secretary  in 
setting  future  agendas  and  all  these  improvements  are 
being implemented.

QUALITY OF FINANCIAL STATEMENTS 
The Committee remains as focused as ever on ensuring 
the integrity of our financial releases and internal records. 
As  noted  above,  the  Committee  pre-vets  all  audited  and 
unaudited  financial  releases  (including  notes  thereto), 
before making recommendations to the Board to approve 
such releases. The Committee holds formal discussions 
with  the  Management  Board  and,  in  particular,  the  CEO 
and  CFO  (and  his  Finance  team),  about  each  of  these 
releases, typically with a multi-stage drafting, review and 
approval  process.  We  also  monitor  the  financial  data 
published on the Company’s website to ensure its accuracy 
and  clarity,  and  maintain  communication  channels  with 
the Group’s Investor Relations Department.

We  have  reviewed,  with  our  Finance,  Risk  and  Internal 
Audit  teams,  all  data  and  narrative  comments  and 
concluded that the Annual Report and full year financial 
statements  taken  as  a  whole  give  a  complete,  true,  fair, 
balanced  and  understandable  view  of  the  Company’s 
financial position and are consistent with the Committee’s 
understanding  of  the  facts  and  provide  the  information 
necessary  for  shareholders  and  other  stakeholders  to 
assess the financial condition of the Group. 

We  have,  as  always,  assessed  the  reasonableness  and 
appropriateness of all critical estimates and judgements in 
applying  accounting  policies  for  which  the  management 
are responsible.  In the multiple planning meetings held 
between the Committee and PwC, we focused on a number 
of areas of greatest risk and PwC convincingly articulated 
their  response  and  testing  strategies.  This  work  was 
addressed  with  appropriate  resources,  including  the 
necessary  specialists. 
  We  are  satisfied,  following 
challenge  and  discussion  with  PwC  and  with  input  from 
external  consultants,  that  the  markets  and  models  to 
which valuations are marked have liquidity and transaction 
profiles that are adequate and sufficiently robust.  We also 
believe that all off balance sheet and contingent liabilities 
have been identified and disclosed in sufficient detail.

The  Committee  is  conscious  of  the  recommendations  of 
European authorities and the FRC as regards improving 
the  reporting  of  alternate  performance  measures 
(“APMs”).  We  track  carefully  what  APMs  the  Company 
uses in its financial reporting and apply guidelines in this 
regard  from  the  European  Securities  and  Markets 
Authority  (“ESMA”).  The  Company  discloses  a  limited 
number of APMs such as underlying cost to income ratio, 
risk-adjusted  net  interest  margins  and  various  other 
return  metrics.  We  consider  that  most  of  these  are  in 
common  usage,  consistently  used 
in  context  and  
meaningful additions to our reporting designed to clarify   
our financial position and do not detract in any way from 
our core IFRS numbers. As the Group expands into wider 
financial  services  (such  as  insurance)  and  exciting  new 
geographies and growth areas (such as ecosystems), we 
are conscious of the incremental reporting risks and the 
need to supply meaningful and validated financial metrics. 

The Committee also carefully reviews minor changes that 
the Group make over time in the definition of its operating 
segments  and  is  satisfied  that  meaningful  like-for-like 
comparisons can be made.  

The Committee recognises that the Company is a premium 
listed  company  on  the  London  Stock  Exchange  and  the 
largest financial services company in the Georgian market. 
Our business is overwhelmingly tied to the performance of 
the Georgian economy. In 2019 Georgia delivered a strong 
real GDP growth of 5.1% as published by National Statistics 
Office  of  Georgia,  an  improvement  on  the  prior  year’s 
already  very  respectable  growth  trajectory  of  4.8%. 
Forecasts for 2020 growth will be profoundly impacted by 
the  global  outbreak  of  COVID-19.    The  national  and 
international  economic  outlook  is  unfortunately  very 
unpredictable  and  locally  Georgia  will  hold  important 
parliamentary elections in October 2020 which may lead to 
some additional volatility in anticipation of the outcome of 
the vote. The Committee and the Risk Committee closely 
track relevant economic data for ‘warning signs’ that may 
trigger a more elevated level of risk to the Group which will 
require  extra  diligence  by  the  Committee  to  ensure 
realistic  levels  of  prudence  in  relation  to  our  financial 
reporting and caution as to monitoring the efficacy of our 
internal controls. The Committee and the Risk Committee 
reviews previous periods of economic or political instability 
and factors this experience into our collective judgements 
of, for example, suitable provisioning levels.

We note with satisfaction, but not complacency, that ISS’s 
ESG Governance Quality 2019 scorecard gave the Company 
a  top  decile  score  (1  out  of  10)  for  our  Audit  and  Risk 
Oversight,  a  score  which  aggregates  a  wide  range  of 
different sub-categories.

COMMENT ON INVESTIGATIVE CASE 
INVOLVING TBC BANK FOUNDERS 
The Bank was subject to an inspection by the NBG during 
late 2018 and into 2019, in relation to certain transactions 
that the founders of the Bank undertook in 2007 and 2008 
(see also page 106).

In February, the Bank reached an agreement with the NBG 
settling  its  inspection  and,  while  there  are  ongoing 
prosecutions against the founders of the Bank, they have 
stepped down from all their positions at the Bank and the 
Group. The Committee, as is customary with companies in 
these circumstances, was involved over several months of 
2019 in comprehensively investigating, with the assistance 
of a specialist Big 4 firm, the historic events that predated 
any members of the Committee’s joining the Supervisory 
Board,  reinforcing  our  independent  judgement  of  these 
events.  This  included  reviewing  all  relevant  surviving 
historic  internal  documents  and  reviewing  internal  and 
external potential witnesses.

In  light  of  the  above  inspection  and  prosecutions,  the 
Committee took steps to consider thoroughly any implications 
for  the  current  or  historic  audits.  These  matters  were 
discussed  with  PwC.  Nothing  was  identified  that  led  us  to 
consider re-stating any elements of past audits.

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As part of our ongoing commitment to good governance, 
much  work  has  been  done  by  the  CGN  Committee  and 
other committees on bedding down best practices related 
to validating the Group’s internal controls.  This work was 
given added urgency by the above investigative cases. We 
engaged  another  one  of  the  Big  4  accountancy  firms  to 
check  related  party  lending  and  anti-money  laundering 
procedures  in  the  Bank  (see  page  106).  The  Committee 
draws  comfort  from  this  work  which  demonstrated  that 
our  internal  controls  in  these  crucial  areas  continue  to 
meet international best practice, with only minor additional 
refinements  needed  and  now  being  implemented.  In 
addition, throughout 2019, various committees of the Bank, 
including  the  Committee,  were  involved  in  assessing 
cultural  and  behavioural  attitudes  in  the  Bank  and  we 
asked Internal Audit to lead a workstream on this to check 
that  appropriate  ‘values’  were  reflected  in  policies  and 
practices across the organisation (see below). While the 
prevailing levels of training and behaviour were found to be 
adequate, we identified areas where improvements could 
be  made  and,  working  with  the  wider  Board  and 
Management, these are being systematically implemented 
with IA now routinely incorporating a cultural assessment 
in its regular audit ratings.

EXTERNAL AUDIT TEAM, COORDINATION 
AND PLANNING 
The  Committee  makes  recommendations  on 
the 
appointment (or potentially removal) and compensation of 
the External Auditors and seeks to maximize the value of 
the  external  audit  relationship.  We  assess  and  approve 
audit  scope  and  frequency,  make  recommendations  to 
auditors  on  areas  for  particular  focus  and  receive  and 
review key external audit planning and progress reports. 

The  Committee  of  the  Company  held  audit  planning 
meetings  with  PwC  in  4Q  2019.  The  Committee  had  the 
opportunity  (without  participation  of  Management)  to 
highlight areas it wished the External Auditor to focus on, 
flagging relevant concerns and trends and discussing the 
appropriate audit response.  As noted, the Committee has 
a policy of regular quarterly face to face discussions with 
PwC as part of our formal meeting agendas.  In addition, 
the  Chairman  and  sometimes  other  members  of  the 
Committee  had  a  number  of  more  informal  (i.e.  not 
minuted) meetings with PwC. PwC often shared with us 
experiences of best practice across their full international 
audit  spectrum  and  this  provided  both  parties  with  the 
opportunity for open dialogue. As noted, the Chairman and 
majority of Committee members are based in the UK and 
enjoy ready access to the external audit team there. Given 
the  exceptional  regulatory  circumstances  of  2019,  the 
interaction between the Chairman of the Committee and 
PwC was even more intense than in past years.

Due to the holding company structure of the Group, both 
the London and Tbilisi practices of PwC are fully involved in 
the external audit process for the Group. PwC Georgia is 
part of PwC’s Central and Eastern Europe network firm. In 
the opinion of the Committee, this ‘double coverage’ works 
well and provides some extra reassurance to us in terms 
of scrutiny. There is one unambiguous “group engagement 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

partner” and senior statutory auditor, Allan McGrath, who 
is  fully  aware  of  his  overall  responsibility  and  ultimate 
sign-off  duties.    Allan  is  new  to  TBC  audit  team  having 
replaced Jeremy Foster, who retired from PwC at the end 
of 2019. The cooperation and communication between the 
two practices seems to be well coordinated with a common 
audit  methodology  and  draws,  as  required,  on  wider 
international  subject  matter  experts  of  the  firm,  for 
example in insurance. The London team coordinates the 
entire audit for the Company with audit instructions issued 
by London and systems in place for the monitoring of PwC 
Tbilisi’s work by PwC London both by means of in-person 
visits and remotely. 

We welcome Allan McGrath and note his deep experience 
in auditing UK-registered financial services companies at 
FTSE350  level.  We  are  pleased  to  note  that  Allan  has 
already  immersed  himself  comprehensively  in  the  TBC 
audit and has swiftly familiarised himself with the Group 
and  with  the  Georgian  macroeconomic  environment.  He 
brings  a  fresh  pair  of  eyes  and  challenge  to  the  Group’s 
audit. We are pleased that, by way of continuity, Agnieszka 
Accordi remains PwC’s engagement leader for the Bank’s 
audit  and  she  has  continued  to  develop  a  deep 
understanding of the Bank and its audit issues as well as 
bringing  to  us  the  benefit  of  her  experience  from  other 
geographic markets including Poland where she is based. 
Other  members  of  the  audit  team  in  both  London  and 
Tbilisi remain very largely unchanged and we have good 
access to Lasha Janelidze, the managing partner in PwC’s 
expanding Georgian practice. Agnieszka Accordi has been 
in post since 2017 and we anticipate that she will rotate (as 
per FRC rules for EU PIEs on Key Audit Partners rotation) 
after the 2021 year end audit.  

The  Chairman  of  the  Committee  would  like  to  take  this 
opportunity  to  thank  Jeremy  Foster,  who  had  been 
engagement leader for PwC since the creation of our PLC 
holding company in 2016, for his contribution.  We wish him 
well in his retirement.  

The audit coverage levels and underlying audit materiality 
levels have been discussed and agreed with PwC. 

EXTERNAL AUDIT AND AUDIT COMMITTEE 
AREAS OF FOCUS 
Key Audit Matters
As a Committee, we engage in substantive dialogue with 
PwC  on  Key  Audit  Matters,  to  understand  the  nature  of 
each of these and the auditors’ basis for their determination. 
From discussions with PwC we understand that they did 
not  identify  any  “elevated”  audit  risks.  We  regard  that 
“Significant”  risks  both  for  the  Group  and  Bank  remain 
management override of controls and expected credit loss 
provisions  for  impairment  of  loans  and  guarantees.  The 
former is a priority risk factor on all audit engagements, 
especially  in  a  banking  context,  since  management  is 
responsible  for  the  design  and  operation  of  systems  to 
prevent and detect fraud and thus in a unique position to 
manipulate accounting records. 

Areas of Judgement
Other risks in terms of areas of judgement that PwC has 
focused  on  included  accruals  for  litigation  and  claims, 
collateral values supporting our loan book, net realisable 
value of repossessed collateral, fair value of securities and 
derivatives,  share  based  payments  and  impairment  of 
goodwill as well as IFRS 9 model back testing, results of 
tax inspections of the bank and assessment of business 
combinations from the acquisitions made during 2019.

Loan Provisions
In terms of loan provisions, we have discussed with PwC 
the current provisioning methodology used by the Bank, 
the  reasonableness  of  the  assumptions  and  individual, 
mostly corporate, loan exposures on the non-performing 
and ‘watch’ lists and the completeness of this watch list 
which we note tends to be stable in composition without 
frequent additions that would indicate a deteriorating book 
or poor ‘capture’ of problem loans. 

We have discussed with PwC model governance controls, 
model  performance  monitoring  and  post-model 
adjustments  with  a  review  of  model  back  testing.  In 
addition, another Big 4 audit firm was involved in improving 
macroeconomic models required for IFRS 9. 

Collectively-Assessed Loans
The Committee, benefiting from work streams led by the 
Risk Committee, continues to monitor on a regular basis 
individually-assessed  loans  on  the  Bank’s  watch  list  but 
also collectively-assessed loans that are less than 90 days 
past due (and not yet classified as impaired) to calibrate 
any deterioration of credit quality that may feed through 
into  impairments.  We  have  not  observed  any  trend 
deterioration  other  than  in  the  higher-yielding  non-
mortgage  consumer  loan  portfolio  which  was  fully 
anticipated  as  part  of  the  lending  business  model.  We 
continue  to  look  for  signs  of  any  deterioration  in  loan 
vintages  of  different  loan  categories,  especially  in  the 
consumer  lending  space,  and  so  far  there  have  been  no 
adverse signals.

Stability of the Local Lari Currency
Clearly,  one  of  the  biggest  factors  impacting  and  also 
reflecting the Georgian economy is the stability of the local 
Lari  currency.  We  monitor  the  possible  impact  of  Lari 
volatility  on  expected  credit  losses.  The  Lari  has  been 
prone  to  periods  of  volatility  again  in  2019,  partly  due  to 
seasonal  factors,  and  depreciated  against  the  US  dollar 
over the year by 7% having rallied strongly towards year 
end  from  lows  recorded  in  the  autumn.  Given  the  still 
highly dollarised nature of the Georgian economy and the 
loan  book,  we  scrutinised  Management’s 
Bank’s 
judgements as to the continuing creditworthiness of those 
of our clients (retail and corporate) without matching dollar 
sources  of 
in  reviewing 
income.  The  Committee, 
provisioning levels, has sought and received detailed data 
on such currency mismatches and the Risk Committee has 
performed a deep-dive into this risk issue. We note that, in 
previous  periods  of  national  currency  volatility,  our 
assumptions regarding the impact of this on the quality of 

our  loan  book  have  proven  reassuringly  cautious  on  a 
back-tested basis.  We note that the welcome “larization” 
policy of the Georgian government has and will continue to 
diminish the credit and financial reporting risk arising.  

Accounting Standards 
Where new accounting standards are adopted, we engage 
proactively  with  Management  and  auditors  on  the 
implementation  process  including  the  transition  impact 
and  whether  the  plan  provides  sufficient  time  and 
resources  to  develop  well-reasoned  judgements.    Since 
the beginning of 2019, the Company has adopted the new 
IFRS16 accounting model to recognise assets and liabilities 
for all leases beyond a 12 months lease term.  The Group 
recognised a ‘right of use’ asset of GEL61 million against a 
corresponding lease liability on 1 January 2019. The main 
impact  was  an  increase  in  depreciation  expense  by  GEL 
13.3 million and increase in interest expense by GEL 2.7 
million.  The  Committee  discussed  this  matter  with  the 
CFO and with PwC and is satisfied that this is a suitable 
implementation of the new standard.

Eurobonds 
In  2019  upon  issuing  two  debut  Eurobonds,  the  Bank  
became,  for  the  first  time,  an  EU  Public  Interest  Entity 
(“PIE”)  following  its  debt  listings  on  the  Dublin  Stock 
Exchange.  This necessitated a long form style audit report 
but  in  essence  is  more  a  change  of  governance  than  of 
audit procedures. 

EXTERNAL AUDIT QUALITY, TENDER 
ASSESSMENT AND REAPPOINTMENT 
As  noted  earlier,  the  Committee  is  responsible  for  the 
assessment  of 
the  performance,  objectivity  and 
independence of the External Auditor and the delivery of a 
quality  audit.  Each  year  the  Committee  is  required  to 
consider the reappointment of the auditors, the suitability 
of the lead engagement partner as well as the wider audit 
team  and  the  relevant  remuneration  and  terms  of 
engagement.  This  consideration  has  gained  our  focus 
since the UK implementation of the EU Audit Regulations 
for Public Interest Entities. Given the incorporation of the 
Company and associated premium listing on the London 
Stock Exchange in 2016, the audit rotation rules permitted 
the 10-year “audit clock” for the mandatory tendering of 
the Group audit to be re-set to start in that year, obviating 
any  requirement  for  a  mandatory  audit  tender  in  the 
foreseeable future.  

Nevertheless, PwC have been the Group’s external auditor 
since  2008  and  2016  for  JSC  TBC  Bank  and  TBC  Bank 
Group  PLC  respectively.  In  2018,  the  Committee  held 
extensive  discussions  on  the  merits  and  demerits  of 
putting the Group’s audit out for tender. Consequently, the 
Committee, reporting to the Board, embarked on a series 
of  discussions  during  the  year  with  three  other  major 
firms  and  conducted  a 
international  accounting 
benchmarking exercise in respect of the potential appetite, 
skillset and likely fees proposed by other firms were they 
to take over our audit.  We concluded then that a superior 
offering at more competitive fees was not yet on offer. In 

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particular, we regret that other Big 4, or indeed smaller 
audit  firms,  are  not  yet  well-resourced  in  the  Georgian 
market  although  there  is  an  encouraging  trend  in  this 
direction.  

The  Committee  carried  out  a  formal  External  Auditor 
Assessment  Review  for  2019  which  confirmed  our  view 
that PwC continue to perform satisfactorily. 

In 2018, we held a series of relationship meetings with PwC 
in  both 
  London  and  Tbilisi  to  discuss  potential 
improvements in terms of their commitment to the Group 
especially  of  resources  from  their  wide  international 
network  of  subject  matter  experts  as  well  as  their  fee 
charging  metrics.    As  a  Committee,  and  with  the 
concurrence  of  the  Board,  we  concluded  that  we  had 
reached a satisfactory understanding with PwC both as to 
level of fees to be charged in 2019 and the resource base. 
The  commitments  made  by  PwC  in  2018  to  meeting  our 
deadlines and delivering wider resources to the audit have 
been  honored.    In  addition,  we  updated  our  review  of 
comparative  audit  costs  inside  and  outside  Georgia  and 
concluded that PwC remain broadly competitive.

As a Committee, we wish to experience PwC‘s performance 
under  their  new  engagement  leader,  who  brings  fresh 
perspective  to  the  audit  (which  mitigates  any  risk  of 
overfamiliarity) before we consider again the ongoing audit 
relationship  and  whether  to  re-launch  a  process.  We  will 
review again in 2020 the case for and against a formal audit 
tender and will take a decision based on the Committee’s and 
the Board’s continuing satisfaction with the audit quality and 
value offered by our incumbent auditor.

We  have  also  taken  into  consideration  the  current 
reputation  issues  impacting  all  Big  4  audit  firms  and 
concluded  that  there  are  no  grounds  in  this  respect  to 
challenge  the  reappointment  of  PwC  given  that  their 
reputation is no more or less under scrutiny than that of 
their  peers.    We  follow  the  FRC’s  Audit  Quality  Review 
inspection  results.    We  have  also  taken  account  of  the 
quality  of  PwC’s 
communications/responsiveness, 
industry  expertise  and  knowledge  of  the  Group  and 
countries in which we operate as well as our judgement of 
their  professional  skepticism  and  project  management 
skills.  We  have  assessed  their  internal  quality  control 
procedures  and  indicators  and  reviewed  their  annual 
transparency report.

We are following closely the extensive debate and multiple 
commissioned official reports (such as Kingman, Brydon, 
CMA and BEIS) concerning audit quality and competition.  
All of these reports have made valuable recommendations 
but so far there is no clear consensus or legislation arising 
as to best practice or how to address the perceived “audit 
expectations  gap”.  We  await  with 
interest  further 
clarification and indeed any impact of Brexit given potential 
changes  to  EU  rules  in  relation  to  audit.  We  support  in 
principle  the  idea  of  a  3  year  statement  of  a  company’s 
audit and assurance policy and allowing shareholders an 
advisory vote on this.

In our view, as formally confirmed in a Committee meeting 
resolution  in  February  2020,  PwC  continue  to  offer  an 
independent, professional and cost-effective service that  

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has  not  have  brought  to  bear  an  appropriate  degree  of 
professional  skepticism.  Any  potential  threats  to  auditor 
objectivity (overfamiliarity, self-review and so on) are, we 
believe,  contained  by  existing  safeguards  and  the 
introduction  of  a  new  lead  engagement  partner  for  the 
Company’s audit.  We reached this decision on the basis of 
PwC’s  openness  to  challenge,  our  perception  of  their 
proper  independence  from  Management  and  absence  of 
any material prior year financial restatements. We remain 
satisfied that PwC have a robust process for maintaining 
independence  and  monitoring  such  compliance 
in 
accordance with the FRC’s 2017 Ethical Standards and the 
2019 International Ethics Standards Board for Accountants 
(IESBA) to which Georgian law also refers.  

Given all the above considerations, it is our belief that the 
Company has complied for the financial year under review, 
and to the date of this report, with the requirements of The 
Statutory  Audit  Services  for  Large  Companies  Market 
Investigation  (Mandatory  Use  of  Competitive  Tender 
Processes  and  Audit  Committee  Responsibilities)  Order 
2014  which  relates  to  the  frequency  and  governance  of 
tenders for the appointment of the external auditors and 
the  scrutiny  of  a  policy  on  the  provision  of  non-audit 
services (see below).

EXTERNAL AUDITOR FEES AND PROVISION 
OF NON-AUDIT SERVICES 
Policy  for  provision  of  non-audit  services  by  the  external 
auditor is approved and available for the Group. As defined 
by  the  policy    all  non-audit  services  must  be  approved  in 
advance  by  the  Committee  following  recommendation  by 
the  Group  Chief  Financial  Officer.Overall  the  Group  spent 
US$4.0 million on work done by various accounting-based 
professional services firms over the year. 

In 2019 the Group paid PwC fees of approximately US$1.1 
million  of  which  c.  $0.7  million  was  in  respect  of  audit 
services, of which over half was for the Bank’s audit. The 
US$0.7 million included audit fees for subsidiaries of both 
the Bank and PLC, notably TBC Leasing and TBC Insurance.  
Most of the remaining balance of the US$1.1 million was 
paid  in  respect  of  work  (review  of  Q1  financials  and 
prospectus as well as comfort letters) done in relation to 
our issuance of senior and subordinated bonds during the 
year, where there were natural synergies relating to the 
audit work conducted and some market timing imperatives. 
We  benchmarked  PwC’s  fees  against  other  similar 
services  previously  performed  or  provided  to  other 
players.  Other  fees  paid  to  PwC  were  minor  in  nature, 
involving  for  example  certification  of  financial  covenants 
and  again  linked  to  the  audit  role.  Given  the  unexpected 
issues relating to the issuance of bonds, fees in total paid 
to  PwC  for  non  audit  services  totaled  US$0.415  million 
over the year which represented 53% of the average paid to 
the firm for the Group audit services over the preceding 3 
years,  this  figure  being  still  well  within  the  70%  cap  as 
required by the Group policy on non-audit services. In the 
prior year ratio was 1%.

All 4 major UK audit firms have announced that they broadly 
support a ban applicable to FTSE350 (typically from 2020) 

on  UK  auditors  selling  consultancy  and  other  non-audit 
related services to their audit clients. The Chairman of PwC 
UK has confirmed that this is the case for PwC applicable 
from January 2020. To set PwC’s fees in context, total non-
audit fees paid to other accountancy-based firms, not only 
the Big 4, amounted to c. US$1.9 million over 2019.  We have 
a policy of deliberately sharing business between firms in 
order  to  provide  diversification,  promote  competition  and 
build relationships. In 2019, we allocated work to 8 different 
accounting-based  firms  and  took  a  conscious  decision  to 
reach  out  beyond  the  Big  4.  The  largest  single  non-audit 
spend  in  2019  was  in  respect  of  work  done  externally  to 
verify  certain  facts  pertinent  to  the  above-mentioned 
historic case relating to the Bank’s founders.  

EXTERNAL AUDITOR INDEPENDENCE
The  Committee  is  rigorous  in  ensuring  (with  a  written 
policy  existing)  that  all  non-audit  assignments  to  our 
External  Auditor  do  not  jeopardise  the  latter’s  proper 
independence  of 
judgement.  Essentially,  all  such 
engagements, without exception or derogation, were first 
recommended  by  the  CFO  and  pre-cleared  with  the 
Committee.    We  only  used  PwC  for  non-audit  (and  of 
course non-prohibited) services where there was either a 
clear synergy with their audit role (i.e. an immediate ‘by 
product’ of the audit process), where required by legislation 
or where they offered superior competence or materially 
better commercial terms. We have a system in place for 
precisely tracking procurement and tendering for all non-
audit  fees  however  small.    As  noted,  we  have  already 
agreed to minimise all non-audit work contracted with our 
External  Auditor  who  from  2020  will  typically  be  self-
excluding themselves from such tenders.

(in 

in  writing 

PwC  have  confirmed 
their  annual 
‘independence letter’) both their independence and that no 
‘blacklisted’ prohibited non-audit services were provided 
over 2019. Reviewing and ensuring the continuation of the 
independence  and  objectivity  of  PwC  as  our  external 
statutory auditors was an important factor in fulfilling our 
governance as a Committee and was equally monitored by 
PwC through their own procedures for pre-approving any 
non-audit services.

INTERNAL AUDIT GOVERNANCE AND 
RESOURCING
The  Committee  relies  heavily  on  Internal  Audit  (“IA”)  to 
provide  an  objective  and  professionally  skeptical  view  of 
how the Group is handling a number of key financial and 
non-financial reporting and record-keeping tasks in order 
to protect the assets, reputation and sustainability of the 
organisation. Whilst primary responsibility to manage risk 
always resides with Management, IA’s role, as the “third 
line  of  defence”,  is  to  identify  potential  problems  and 
recommend  ways  of  improving  risk  management  and 
internal controls. The Committee meets regularly with the 
Head  of  IA  (Chief  Audit  Executive)  with  no  management 
present.  The  CAE  always  attends  the  entirety  of  our 
Committee  meetings.  IA  has  unrestricted  access  and 
scope  within  the  organisation.    As  Chairman  of  the 

Committee,  I  am  in  at  least  monthly  (and  often  weekly) 
contact  with 
functionally  reports 
unambiguously to me and makes an extensive quarterly 
submission to the Committee.  The Committee regards IA 
as its “eye and ears” within the Group. 

the  CAE  who 

IA seeks to complete audits of all the Group’s key operating 
units  on  a  regular  recurring  basis  structured  through  a 
rolling audit plan agreed in advance with the Committee. 
Such  planned  audits  continued  throughout  the  year  and 
99%  of  all  pre-agreed  internal  audit  assignments  were 
completed in 2019.  We track very closely all deficiencies 
identified  by  IA  both  in  terms  of  severity  and  trend  and 
scrutinise  remediation  follow-up  with  historic  analyses 
being  carefully  maintained.  Units  of  the  Bank  which 
showed weaknesses are routinely re-inspected to confirm 
if  improvements  have  been  made  and  the  Committee 
updated  on  the  results  of  these  repeat  audits,  such  an 
example  having  been  TBC  Pay.    The  Committee  was 
pleased  to  note  that  in  2019  there  was  again  further 
improvement  in  the  rate  and  speed  of  remediation  of 
identified IA deficiencies. We have agreed with the CEO that 
such  deficiencies,  whilst  all  addressed,  should  be  even 
more clearly prioritised into a hierarchy according to the 
potential systematic risk they represent.

The  hiring  and  retention  of  IA  staff  is  a  challenge  in  a 
country like Georgia and, whilst attracting new talent, we 
also need to embrace alternative and more flexible staffing 
models.    Nevertheless,  we  are  satisfied  that  IA  has 
sufficient  human  and  financial  resources  to  perform  its 
role and the Committee has where necessary requested 
additional funds to hire or retain staff and to purchase the 
training and tools (e.g. specialist software) necessary for 
them to function effectively.  The Committee requires all 
managerial IA executives to attend training, including for 
relevant  international  (Certified  Internal  Auditor)  exams; 
the pass rate is improving but needs to be improved further 
incentive  staff 
and  measures  have  been  taken  to 
accordingly  including  allowing  study  days.  There  is  a 
particular shortage of internal IT auditors in the country.  
After  discussion  among  the  Committee  and  given  the 
importance of mitigating IT risk, it was decided to conduct 
a tender process to select an external Big 4 firm (drawing 
on international resources in 3 countries) with whom we 
will, from 2020, co-source these skills at the same time as 
using this collaboration to educate our own audit staff and 
to  gain  experienced  insights  into  best  practices  and 
emerging technologies.  

IA’s  Audit’s  Charter  was  reviewed  and  approved  largely 
unchanged  in  December  2019  and  is  appropriate  to  the 
current needs of the organisation. The Committee routinely 
reviews IA’s remit, annual and rolling 5 year plan, provides 
feedback on it and authorises any changes to its scope. The 
plan allows for some flexibility where any urgent matters 
or emerging risks arise and the Committee supports this 
approach.  We provide targets for and formal assessment 
of IA and ensure that it is effective and suitably embedded 
in the organisation. The CAE routinely attends (as observer) 
monthly Management Board meetings. Given the overlap 
of  particularly  operational  risk  issues,  the  CAE  is  now 
invited  to  attend  also  meetings  of  the  Group’s  Risk 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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Committee.    The  CAE,  who  is  sufficiently  senior  in  the 
Group’s hierarchy, has direct access to the CEO and also 
the  External  Auditor  and  we  will  be  encouraging  more 
interaction with both in the coming year.

The  Committee  solely  determines  IA’s  budget  and 
compensation  including  variable  bonus  payments  to  the 
CAE and her staff; the Committee is also responsible for 
supervising the annual personal performance assessment 
of the CAE drawing on input from peers, direct reports and 
senior  management  including  the  CEO  and  CFO.  We 
believe,  with  corroboration  by  the  external  EQA  (see 
its  arms-length 
below), 
independence  from  Management  and  is  free  from  any 
interference in determining the scope and performance of 
its work and communication of its results. It feels properly 
empowered and motivated to do its job and is respected by 
Management and of use to them, its value reflected in the 
latter’s  proactive  requests  (with  sign-off  from  the 
Committee) for their involvement in various projects and 
internal investigations. 

IA  has  established 

that 

The CAE has now been in role for 8 years and we are aware 
of IIA guidance on tenure beyond 7 years.  We have discussed 
this as a Committee and have concluded, on the basis of her 
displayed  behaviour  and  proven  tenacity,  that  the  CAE’s 
objectivity and independence remains undoubted.

IA has delivered its annual assurance statement which sets 
out the CAE’s opinion together with the summarised reports 
of the internal audit work performed during the year and a 
summary of audit performance in comparison to the plan 
and an assessment of compliance with auditing standards.  

The Committee notes the recent (January 2020) publication 
of  an  updated  Internal  Audit  Code  of  Practice  by  the 
Chartered  Institute  of  Internal  Auditors  (IIA).  This  is  a  far 
reaching code which the Committee intends to implement 
over the course of the year. Most of its recommendations 
were already ‘in force’ for financial services firms so already 
adopted by the Group, for example in relation to the audit of 
risk  appetite  and  risk  culture.  Nevertheless  there  are  a 
number of new recommendations, for example regarding 
supporting strategic and operational decision-making.  We 
welcome this direction as it places the function of internal 
audit in an increasingly value-added internal consulting role 
whilst enhancing its core risk mitigation mission.

INTERNAL AUDIT PROJECTS
The Committee is overseeing a project (internally referred 
to as “Internal Audit 3.0”) to move the IA function towards a 
more ‘agile’ approach.  We are seeking to use robust root 
cause analysis to develop more themed reports, prioritising 
the  higher  risk  areas  of  the  Group  and  responding  even 
more  rapidly  to  emerging  issues,  undertaking  special 
deep-dive 
from 
situations  where  the  Group  may  have  heightened 
vulnerability or has been the victim of fraud) and ensuring 
that IA is able to add more strategic value.  

(particularly  arising 

investigations 

In addition to its regular workload, there were a number of 
special assignments commissioned by the Committee from 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

IA in 2019. Some involved investigations of particular fraud 
events.  We also asked them to review some of the Bank’s 
in  particular  TBC  Pay,  TBC 
significant  subsidiaries, 
Insurance and TBC Leasing as well as Space (which is TBC’s 
digital neobank). In addition, IA maintained its focus on the 
identification/reporting  processes  around  capturing  and 
disclosing related party lending and anti-money laundering 
procedures within the Group, all the more important given 
stakeholder  focus  on  these  vital  issues.  In  addition,  IA 
assessed the Bank’s compliance with SWIFT requirements 
in  terms  of  its  customer  security  control  framework, 
penetration testing and training requirements. IA undertook 
a review of certain Treasury functions and, importantly led a 
review of the Bank’s document retention and retrieval policy 
since this was an issue emerging from prior audits. We also 
requested  IA  to  confirm  the  adherence  of  the  Bank  to  its 
approved risk tolerances. A recurring theme in all IA’s audits 
was information security and data protection.

IA is in the process of updating its Internal Audit handbook. 
This  is  a  reference  guide  for  all  internal  audit  activities. 
Based  on  the  main  standards  applicable  to  best  practice 
audit functions, it describes all IA’s methodologies.  The Risk 
Committee is leading a process of updating the Group’s Risk 
Register and we believe that this will provide a useful tool 
also for IA and the Committee to align our priorities. 

CULTURE AND BEHAVIOUR 
Culture is a key driver and potential mitigant of conduct and 
operating risk within any organisation, especially in a bank.  
Therefore, as noted above, we asked IA to undertake its first 
formal review of culture and observed behaviour within the 
Bank.  As  non-executive  Directors  of  a  company,  it  is 
sometimes  hard  to  understand  the  prevailing  culture  at 
lower levels of an organisation yet this often determines the 
opportunity,  incentives  and  pressures  for  staff  to  commit 
dishonest acts or to by-pass critical procedures and even 
mentally  to  rationalise  this  behaviour.  Therefore,  the 
Committee considers that such cultural audits are essential 
to monitoring behavioural and operational risks presented 
by  our  most  valuable  asset,  our  human  capital,  and 
confirming that employees ‘live’ the ethical values espoused 
by the Company and that this is matched and driven by a 
suitable “tone at the top”. Our priority, as a Board, supported 
by  Internal  Audit,  is  to  guarantee  that  there  is  real 
commitment to good ethics beyond mere slogans, ensuring 
that we continue to be a high integrity organisation from top 
to bottom and to ensure alignment with TBC’s  strategy and 
taking into account of stakeholders’ interests.

This  audit  focused  on  issues  such  as  our  code  of  ethics, 
perceptions  of  the  Group’s  visions  and  values,  training 
issues, employee awareness of our whistleblowing hotline, 
employee  commitment  and  morale  and,  importantly, 
customer protection. The Group is ever more aware of the 
regulatory  and  moral  imperative  for  protection  of  its 
customers and has signalled its intention to move from a 
product-centric  strategy  to  a  customer-centric  one  that 
prioritises above all else customer protection and service. 
Independent surveys demonstrate that the Bank is already 
the  national  leader  in  terms  of  customer  satisfaction.  In 
addition to IA’s work in this area, the HR department recently 

completed an employee engagement survey and the Board 
has initiated a process of nominating one of our independent 
directors  as  a  rotating  ‘staff  ambassador’  to  meet  in 
confidence  with  focus  groups  of  employees  at  all  levels 
better  to  gauge  the  Bank’s  prevailing  culture.  IA  is  now 
including  an  ethics-related  evaluation  within  every  audit 
engagement. The Board and Committee has agreed that the 
Risk  Committee  will  henceforth  supervise  the  ongoing 
monitoring of ‘culture’ as part of its formal Ethics remit. 

IA  will  be  including  new  geographies  and  additional 
subsidiaries in their rolling audit plan.  We would stress 
that IA is a Group-wide not just Bank function and as we 
enter  new  geographies  and  sectors  beyond  Georgia  and 
mainstream  banking, 
for  example  Uzbekistan  and 
ecosystems,  we  will  need  to  pay  attention  to  ensuring 
process  and  ethical  standards  in  these  areas,  some  of 
which are evolving very fast and present heightened levels 
of operational and conduct risk and thus new challenges.  
For  example,  our  CAE  already  led  an  advisory  audit  of 
Nikoil  Bank  in  Azerbaijan  with  which  we  are  hoping  to 
finalise a merger with our TBC Kredit local subsidiary.  The 
Chairman of the Committee also recently made a trip to 
Baku  and  met  with  senior  management  and  internal 
auditors there.

EXTERNAL ASSESSMENT AND EVOLUTION 
OF INTERNAL AUDIT
In early 2019, the Committee supervised the completion of 
an External Quality Assessment (EQA) of our Internal Audit 
department focused on assessing IA’s function in terms of 
“efficiency  and  effectiveness  in  matters  of  Governance, 
People, Infrastructure and Operations”.  The yardstick was 
the  Code  of  Ethics  and  International  Standards  for  the 
Professional  Practice  of 
Internal  Auditing  and  the 
Chartered Institute of Internal Auditors’ (“IIA”) September 
2017 Guidance on Effective Internal Audit in the Financial 
Services  Sector.  The  exercise  was  conducted  by 
international  specialists  in  a  Big  4  firm  (selected  after  a 
tender process of the Big 4 and others). It included some 
international benchmarking analysis of our maturity level 
against peers according to the IIA’s Audit Intelligence Suite 
Benchmarking Report. It was the first time that the Group 
has  conducted  an  EQA  exercise  and  not  only  were  the 
results  reassuring  but  also  the  unit  benefited  from  the 
feedback and the assessment process itself.  

The conclusion gave IA a “generally conforms” score (the 
highest  available  ranking)  with  a  conclusion  that  “in 
general  there  is  a  high  degree  of  compliance  with  IIA 
standards’  requirements”,  with  the  function  being  “well 
aligned  with  the  Bank’s  operations  and  its  people”.  It 
confirmed that the Internal Audit function acts as a trusted 
adviser to the Bank. We were advised that the unit ranks in 
the top 20% equivalent for banks in the CEMEEA region. 
Various  recommendation  were  made  and  will  be 
implemented. In particular, we noted the recommendation 
for  more  regular  high-level  alignment  between  IA  and 
other assurance providers, notably the chief risk and chief 
compliance officers.  

We  have  reviewed  the  scale  of  Internal  Audit’s  function 
comparing it with other similar-sized financial institutions 
and consider it right-sized. We noted the EQA’s comment 
that  “Internal  Audit  Function  is  a  talent  pipeline  for  the 
business”  and  intend  to  boost  IA’s  integration  into  the 
Group and to encourage a rotation of staff both into and out 
of the department.  

The EQA assessment gave us good scores for automation 
but the direction of travel is for us to now take IA into more 
technology-driven  capabilities,  using  automated  audit 
scripts, laying the foundation for continuous (if not “robo”) 
and  more  agile  auditing  of  critical  controls,  monitoring 
high risk areas in real time. This will also free up more IA 
resources  to  shift  the  focus  from  pure  assurance 
(“policeman”) activities to more consulting level activities, 
recognising  that  IA  can  and  should  act  as  an  agent  of 
change, anticipating and deflecting risk.   

Capitalising on new software tools, we will be shifting the 
emphasis from traditional rotational heavily-documented 
audits  in  search  of  findings  to  a  more  outcome-driven 
approach  delivering  right-sized  audits,  balancing  value 
preservation  (assurance)  with  value  creation  (advisory). 
Ultimately, we hope to apply the power of data to deliver 
‘intelligent audit’.

CONTROL ENVIRONMENT 
A  sound  system  of 
internal  control  contributes  to 
safeguarding the best interests of all stakeholders and the 
Group’s assets and liabilities. Management is responsible 
for  establishing  and  maintaining  adequate 
internal 
controls over the capturing, processing and reporting of 
financial information but the Committee has responsibility 
for  ensuring  the  effectiveness  of  these  controls  and  for 
confirming  that  they  are  sufficiently  robust  to  cope  with 
changing  economic  conditions  and  continued  strong 
growth in the Group. As noted above, IA reports on control 
weaknesses  and  breakdowns  with  robust  root  cause 
analysis  and  recommendations  with  clear  ownership/
accountability  and  deadlines.  The  Committee  regularly 
reviews progress in this vital discipline and alerts the CEO, 
CFO,  divisional  heads  and,  if  necessary,  the  full  Board 
where  it  occasionally  sees  intractable  problems  and 
insufficient 
process 
improvement. The Committee was pleased to note that in 
2019  there  was  again  a  further  improvement  in  the  rate 
and speed of remediation of identified IA deficiencies.  We 
have  implemented  a  new  Internal  Audit  scoring  system 
that  sets  clear  thresholds  on  what  level  of  ‘failure’  is 
unacceptable  and  which  processes  demand  zero  failure 
rates.   

commitment 

continuous 

to 

In 2019 a Big 4 firm was commissioned to undertake an 
evaluation  of  the  Group’s  operational  risk  governance 
framework and risk assessment methodologies. 

The Committee is conscious of increased regulatory and 
stakeholder focus on ICFR (Internal Control Over Financial 
Reporting)  issues  and  the  need  for  proactive  responses 
from  companies  and  audit  committees.  Much  of  the 
Finance  function  involves  data  gathering.  We  discussed 
with PwC the level of manual processes in the Group and 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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whether these posed heightened risk. The vast majority of 
financial  numbers  are  system  generated.  The  Group  is 
increasing  its  automation  of  remaining  manual  controls 
which  reduces  the  risks  of  human  error  or  malpractice 
and also delivers cost-saving benefits. We are also working 
with Finance to understand better how using data analytics 
and  artificial  intelligence  can  deliver  sharper  predictive 
insights  which  could  be  relevant  to  our  reporting  and 
provisioning agenda. In 2020 the Committee will continue 
to work with Finance on its transformation strategy. At the 
same  time  we  are  conscious  that  new  and  disruptive 
technologies  can  bring  their  own  risks  in  collecting, 
interpreting and protecting all this data.

On  a  wider  issue,  we  are  aware  of  the  strains  that 
international expansion and diversification can potentially 
place  on  the  Finance  team  of  the  Group  and  are  taking 
steps to ensure that competent resources are in place to 
cope with the extra workload involved.

In  accordance  with  our  mandate,  we  have  reviewed  the 
robustness of the Bank’s wider controls, working with our 
External Auditor and IA. In the opinion of the Committee, 
there is a proper system and allocation of responsibilities 
for  day  to  day  monitoring  of  financial  and  other  controls 
within  the  Group  and  no  significant  systemic  failings  or 
weaknesses. We have also considered the risk of executive 
override  of  controls,  and  discussed  with  PwC  their 
assessment  of  this  mandatory  significant  audit  risk.  We 
ensure  that  the  remuneration  of  senior  and  middle 
management is calibrated so that they are not incentivised 
to take unhealthy short-term risks to generate personal 
rewards. 

After  every  noted  fraud  event  larger  than  US$20,000, 
Management  conducts a full post-mortem which is shared 
with the Committee and often the full Board (as well as the 
CEO and divisional head responsible), concluding lessons 
learned to avoid any future repeat events. The Committee 
has  directly  discussed  all  larger  frauds  with  senior 
management and is confident that the CEO and his deputies 
have taken full ownership of the issues and rectified any 
vulnerabilities arising. Our experience over 2019, as with 
2018, is that typically our processes were watertight but 
had  not  been  fully  followed  due  to  human  error  or 
deliberate  malfeasance.  The  Committee  was  promptly 
notified in accordance with escalation procedures. 

We  have  reviewed  PwC’s  management  letter  from  the 
2018 audit, discussed Management’s responses to it and 
confirmed that there are no major issues raised therein.  
We  are  also  satisfied  with  the  PwC’s  requested 
management representation letter (signed by the CEO and 
CFO) in relation to the 2019 audit. 

In 2016 the Bank’s ‘whistleblowing’ or anonymous hotline 
for staff and external entities went live, alerting the Bank to 
any  potentially  unsatisfactory  practices  relating  to 
customers, other third party entities and our employees. 
Arrangements  are 
in  place  for  proportionate  and 
independent investigation of all such cases and appropriate 
follow  up  actions.  We  agreed  in  2019  that    the  Risk 
Committee  would 
for 
overseeing these whistleblowing reports since it has the 

take  primary  responsibility 

Compliance  mandate.    However,  IA  will  continue  to  be 
involved  as  appropriate.    We  believe  that  our  employees 
and customers have come to realise that ‘speaking up’ is 
valued and taken seriously. 

The  Committee  works  closely  with  the  Remuneration 
Committee,  where  we  have  a  majority  of  overlapping 
members.    We  are  comfortable  that  the  compensation 
policies and practices for top executives are appropriate 
for  maintaining  a  robust  control  environment  and 
consistent with good stewardship. The CEO’s compensation 
is partly linked to a Leadership KPI which includes as one 
of its key elements an “Internal Audit Engagement” factor 
and since 2018 the Bank’s branch directors have also had 
an  operational  risk  mitigation  KRI  attached  to  their 
remuneration.

IT, CYBER-SECURITY AND DATA PROTECTION 
The Group is undergoing a significant amount of change in 
IT as it implements new systems and invests in network 
automation,  digitalisation  and  other  new  technologies.  
The  Group  is  pursuing  a  phased  approach  to  its  core  IT 
systems  strategy  and  is  seeking  to  bring  more  system 
development  in-house  and  to  create  more  modular, 
decentralised and agile, less monolithic, capabilities.  The 
intention is to facilitate faster development and deployment 
of  new  technologies.  The  Committee  believes  that  this 
approach will allow us to achieve our goals at lower cost 
and with lower risk of IT failure.  

The  Committee,  with  support  from  IA,  supervised  an 
internal  cyber  ‘health  check’  and  ‘gap  analysis’.  The 
Committee, together with the Risk Committee, received a 
presentation  from  the  IT  division  on  its  cyber  and 
information  security  status  highlighting  its  governance 
framework, maturity level,  improvements underway and 
threat  assessment  and  we  have  received  feedback  on 
extensive  externally  facilitated  penetration  testing.  Our 
conclusion  was  that  the  risk  environment  is  satisfactory 
and  that  we  have  sufficient  prevention,  detection  and 
containment practices in place. 

The  Bank  has  established  some  cyber-risk  insurance 
cover but is fully conscious that this area of insurance is 
evolving,  only  partial  in  protection  and  no  substitute  for 
having rigorous data policies in place. We are anticipating 
GDPR equivalent laws coming into force in Georgia and are 
taking  steps  to  be  fully  prepared  for  this.  Georgia  has 
appointed a new data regulator, the office of the Personal 
Data Protection Inspector (PDP), who we understand are 
currently working on amendments to the local law in order 
to align it with the EU’s GDPR. Safeguarding of customer 
data remains a paramount concern for all of us.

The  Group’s  Management  continuously  seeks  to  raise 
cyber-security  risk  standards  within  the  organisation 
requiring  almost  all  employees  to  pass  an  IT  security 
awareness  test  covering  vital  vulnerabilities  such  as 
access control.

As  noted  above,  it  was  agreed  in  2019  that  the  Risk 
Committee  would  assume  primary  responsibility  for 
overseeing IT and cyber risks.

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INDEPENDENT AUDITORS’ REPORT TO THE MEMBERS OF TBC BANK GROUP PLC

REPORT ON THE AUDIT OF THE FINANCIAL STATEMENTS

Opinion
In our opinion, TBC Bank Group PLC’s group financial statements and parent company financial statements (the “financial 
statements”):

 ` give a true and fair view of the state of the group’s and the parent company’s affairs as at 31 December 2019 and of 

the group’s profit and the group’s and the parent company’s cash flows for the year then ended;

 ` have been properly prepared in accordance with International Financial Reporting Standards (IFRSs) as adopted by 
the European Union and, as regards the parent company’s financial statements, as applied in accordance with the 
provisions of the Companies Act 2006; and

 ` have been prepared in accordance with the requirements of the Companies Act 2006 and, as regards the group 

financial statements, Article 4 of the IAS Regulation.

We have audited the financial statements, included within the Annual Report, which comprise the: 

 ` Consolidated and Separate Statements of Financial Position as at 31 December 2019;
 ` Consolidated Statement of Profit or Loss and Other Comprehensive Income for the year then ended; 
 ` Consolidated and Separate Statements of Cash Flows for the year then ended; 
 ` Consolidated and Separate Statements of Changes in Equity for the year then ended; 
 ` The summary of significant accounting policies; and
 ` The notes to the financial statements.

Our opinion is consistent with our reporting to the Audit Committee.

Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (“ISAs (UK)”) and applicable law. Our 
responsibilities  under  ISAs  (UK)  are  further  described  in  the  Auditors’  responsibilities  for  the  audit  of  the  financial 
statements section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to 
provide a basis for our opinion.

Independence
We remained independent of the group in accordance with the ethical requirements that are relevant to our audit of the 
financial statements in the UK, which includes the FRC’s Ethical Standard, as applicable to listed public interest entities, 
and we have fulfilled our other ethical responsibilities in accordance with these requirements.

To the best of our knowledge and belief, we declare that non-audit services prohibited by the FRC’s Ethical Standard were 
not provided to the group or the parent company.

Other than those disclosed in note 34 to the financial statements, we have provided no non-audit services to the group 
or the parent company in the period from 1 January 2019 to 31 December 2019.

Our audit approach
Overview

 ` Overall group materiality: GEL 29.3 million (2018: GEL 25.5 million), based on 5% of profit before tax.
 ` Overall parent company materiality: GEL 15.7 million (2018: GEL 15.5 million), based on 1% of total assets.
 ` Our scoping was driven by legal entity contribution to profit before tax and other key financial metrics. This approach 
also ensures that we align our resources with the location of the key financial reporting functions and material 
operations of the group. We also considered overall coverage in assessing the appropriateness of our scoping. Our 
primary location for scoping purposes is Tbilisi, Georgia.

 ` Key audit matters which were of most significance in the audit of the consolidated financial statements were the 
expected credit loss allowance for loans and advances to customers and the impact of Coronavirus (COVID-19) on 
the financial statements.

The scope of our audit
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial 
statements.  In  particular,  we  looked  at  where  the  directors  made  subjective  judgements,  for  example  in  respect  of 
significant  accounting  estimates  that  involved  making  assumptions  and  considering  future  events  that  are  inherently 
uncertain.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

191

INDEPENDENT AUDITORS’ REPORT
TO THE MEMBERS OF TBC BANK GROUP PLC CONTINUED

Capability of the audit in detecting irregularities, including fraud
Based on our understanding of the group and the legal, regulatory and banking industry in which it operates, we identified 
that the principal risks of non-compliance with laws and regulations related to the rules of the National Bank of Georgia, 
and we considered the extent to which non-compliance might have a material effect on the financial statements. We also 
considered those laws and regulations that have a direct impact on the preparation of the financial statements such as the 
Companies Act 2006, the Listing Rules and UK and local tax legislation. 

We evaluated management’s incentives and opportunities for fraudulent manipulation of the financial statements (including 
the risk of override of controls), and determined that the principal risks were related to management bias in accounting 
estimates.  The  group  engagement  team  shared  this  risk  assessment  with  the  component  auditors  referred  to  in  the 
scoping section of our report below, so that they could include appropriate audit procedures in response to such risks in 
their work. Audit procedures performed by the group engagement team and/or component auditors included:

 ` Enquiries of management, including the group’s Chief Legal Counsel, and Internal Audit, in relation to known or 

suspected instances of non-compliance with laws and regulations and fraud;

 ` Evaluation  and  testing  of  the  operating  effectiveness  of  management’s  controls  designed  to  prevent  and  detect 

fraud and errors in financial reporting;

 ` Assessment  of  matters  reported  on  the  group’s  whistleblowing  helpline  and  the  results  of  management’s 

investigation of such matters;

 ` Attendance  at  and  inquiry  of  selected  key  governance  committees  and  reviewing  management  information 

presented at these meetings;

 ` Reading key correspondence with regulatory authorities and legal advisors;
 ` Challenging  assumptions  and  judgements  made  by  management  in  their  significant  accounting  estimates,  in 

particular in relation to the impairment of loans and advances; and
 ` Identifying and testing journal entries meeting specific risk criteria.

There are inherent limitations in the audit procedures described above, and the further removed that non-compliance with 
laws and regulations is from the events and transactions reflected in the financial statements, the less likely we would 
become aware of it. Also, the risk of not detecting a material misstatement due to fraud is higher than the risk of not 
detecting one resulting from error, as fraud may involve deliberate concealment by, for example, forgery or intentional 
misrepresentations, or through collusion.

Key audit matters
Key audit matters are those matters that, in the auditors’ professional judgement, were of most significance in the audit of 
the financial statements of the current period and include the most significant assessed risks of material misstatement 
(whether or not due to fraud) identified by the auditors, including those which had the greatest effect on: the overall audit 
strategy; the allocation of resources in the audit; and directing the efforts of the engagement team. These matters, and any 
comments we make on the results of our procedures thereon, were addressed in the context of our audit of the financial 
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. This 
is not a complete list of all risks identified by our audit. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Key audit matter

How our audit addressed the key audit matter

Expected credit loss allowance of loans and advances to 
customers

Refer to pages 180 to 190 (Audit Committee Chair’s report), 
pages 206 to 224 (Summary of Significant Accounting 
Policies), page 224 to 225 (Critical Accounting Estimates), 
and pages 230-246 (note 9: Loans and Advances to 
customers).

We focused on this area as the management estimates 
regarding the expected credit loss (‘ECL’) allowance are 
complex and require a significant degree of judgement.

Under IFRS 9 management is required to determine the 
ECL allowance expected to occur over either a 12 month 
period or the remaining life of an asset, depending on the 
categorisation of the individual asset. This categorisation 
is determined by an assessment of whether or not there 
has been a significant increase in credit risk (‘SICR’) of 
the borrower since loan origination. It is also necessary 
to consider the impact of different future macroeconomic 
conditions in the determination of ECLs.

Management has designed and implemented a number 
of models to achieve compliance with the requirements 
of IFRS 9. Among others, management has applied 
judgement in situations where past experience was not 
considered to be reflective of future outcomes due to 
limited or incomplete data. As a result, we consider that 
this represents a key audit matter. 

We consider the appropriateness of the model 
methodologies and the following judgements used in 
the determination of the modelled ECL allowance to be 
significant:

 ` Setting  of  appropriate  criteria  for  what  represents  an 

SICR; 
 ` Critical 

judgements  and  assumptions  applied 

in 
the  determination  of  loss  given  default  (‘LGD’)  and 
probability of default (‘PD’); and

 ` Assessment of model limitations and use of post model 

adjustments (‘PMAs’) if required to address such risks.

We understood and evaluated the design of the key 
controls over the determination of ECL allowance and 
tested their operating effectiveness. These controls 
included among others:

 ` Model  performance  monitoring  controls,  including 
testing model estimates against actual outcomes;

 ` Review  and  approval  of  the  key 

judgements  and 
assumptions used for determining an SICR, LGDs and PDs; 
 ` Controls  over  key  parameters  calculation  by  the 

calculation engine;

 ` Controls  over  regular  monitoring  of  the  financial 

standing of the borrowers;

 ` Controls  over  assignment  of  staging  criteria  to 

exposures;

 ` Controls over ECL calculation and analysis of results; 

and

 ` Controls  over  changes  and  approval  of  ECL 

methodology.

 We noted no exceptions in the design or operating 
effectiveness of the above controls.

We assessed whether the IFRS 9 ECL model 
methodologies developed by management are 
appropriate, making use of our credit risk modelling 
specialists and our industry knowledge. This included 
an evaluation of the criteria set by management for 
determining whether there had been a significant 
increase in credit risk (‘SICR’), and the critical judgements 
and assumptions applied in determination of LGDs 
and PDs. We also critically evaluated management’s 
assumptions in response to data limitations, focusing 
on long-term PDs. We concluded that management’s 
judgements in deriving LGDs and PDs were reasonable.

We independently verified the calculation of ECL, and  
assessed whether the ECL calculations were consistent 
with the approved model methodologies.

We critically evaluated key aspects of model monitoring 
and validation (“backtesting” of projected ECL) performed 
by management relating to model performance and 
stability and critically assessed the monitoring results. We 
found no exceptions in this work.

We considered whether PMAs were required to address 
relevant risks that were not captured in the modelled 
provisions. We were satisfied that no PMAs are required.

Based on the procedures performed and the evidence 
obtained, we concluded that management’s judgements 
used in the determination of the ECLs were reasonable.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

193

INDEPENDENT AUDITORS’ REPORT
TO THE MEMBERS OF TBC BANK GROUP PLC CONTINUED

Key audit matter

How our audit addressed the key audit matter

We critically assessed the Director’s conclusions that the 
matter be treated as a non-adjusting post balance sheet 
event and that the impact cannot be reliably estimated at 
this stage. In particular we considered: 

 ` The timing of the development of the outbreak across 

the world;

 ` The timing and nature of advice from the World Health 
Organisation (WHO) and from the Georgian government 
to its citizens. 

 ` How  the  financial  statements  might  be  impacted  by 
the  aforementioned  disruption  and  the  complexity  in 
measuring such impacts. 

In forming our conclusions over going concern, we 
evaluated whether the Director’s assessment considered 
impacts arising from COVID-19. Our procedures in respect 
of going concern included:

 ` Evaluating  management’s  assessment  of  the  impact 
of  the  events  on  the  Group’s  operations,  capital  and 
liquidity positions; and

 ` Evaluating the Group’s access to funding.

Based on the work performed, we are satisfied that the 
matter has been appropriately evaluated and reflected in 
the financial statements.

Impact of Coronavirus (COVID-19) on the financial statements

Refer to page 183 (Audit Committee Chair’s report), pages 
2 to 123 (Strategic Report), 

Since the balance sheet date, there has been a global 
pandemic of COVID-19 virus. In addition to the human cost, 
the pandemic has been disruptive to the financial markets 
and is translating into a global economic crisis, potentially 
plunging the major economies into deep recessions. The 
Directors believe that, notwithstanding the unprecedented 
fiscal and monetary response from governments and 
regulators around the world, the financial impact of 
COVID-19 on TBC Bank Group plc is expected to be 
significant, at least over the short-term.  

The Directors have specifically considered the impact of 
this on the financial statements, including on the going 
concern assessment and post balance sheet events 
disclosures. The directors have concluded that the 
impact of COVID-19 is a non-adjusting post balance sheet 
event under IAS 10 “Events After the Reporting Period” 
and therefore no adjustments have been made to the 
primary financial statements or the notes to the financial 
statements. 

However, IAS 10 states that the financial statements 
should not be prepared on a going concern basis where 
events after the reporting date indicate that the going 
concern assumption is no longer appropriate. This 
guidance applies even if those events would otherwise be 
non-adjusting. The Directors have therefore considered 
whether developments subsequent to the reporting date 
have any implications for the going concern assumption 
through evaluating the impact on the Group’s capital and 
liquidity position. As stated on page 134, the Directors have 
concluded that the going concern basis of accounting is 
appropriate and in reaching their conclusions, they have 
taken into consideration all of the latest information, 
including new assumptions and judgements about 
forward-looking economic scenarios. 

Given the sudden onset of the virus, there remains a 
considerable level of uncertainty about the duration of this 
pandemic and its medium to long term consequences. 
Therefore, significant judgement has been exercised by 
management and directors in reaching their conclusions. 

How we tailored the audit scope
We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the financial 
statements as a whole, taking into account the structure of the group and the parent company, the accounting processes 
and controls, and the industry in which they operate.

TBC Bank Group’s banking and insurance activities are primarily carried out in Georgia, with small subsidiary 
operations in four other countries. The Group’s business activities comprise of four segments for which it manages 
and reports its operating results and financial position, namely Retail Banking, Corporate and Investment Banking 
and Micro Small and Medium Enterprises (‘MSME’) and Corporate Centre.

JSC TBC Bank is the largest subsidiary of the group. Its main operations are Retail and Commercial banking, with 
all significant operations based in Georgia. Accounting functions and management of JSC TBC Bank are primarily 
based in Georgia, and represent 97% of the group assets and 99% of profit before tax. We performed audit procedures 
over this component which is considered financially significant in the context of the group, using a materiality of 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

GEL 27.8 million (2018: GEL 24.2 million). We also performed other audit procedures including testing information 
technology general controls and other relevant controls related to financial reporting, to mitigate the risk of material 
misstatement.

Our audit approach and team was also designed to reflect the structure of the group, and we therefore used 
component auditors from PwC in each of the relevant territories, all of whom are familiar with the relevant 
businesses in their geographical locations, to audit the relevant component that was in scope for the group audit. 
As part of the planning and execution of the audit, the UK audit team visited the significant component in Georgia 
on several occasions, in order to ensure that the procedures performed to support the group audit were sufficient 
for our purposes. Specific audit procedures were also performed at the UK parent company, mainly related to 
the presentation of the group financial statements, the consolidation process, taxation and elements of laws and 
regulations specific to the UK. Based on the procedures we performed over the reporting units our audit scoping/
coverage accounted for 99% of revenue and 98% of total assets of the group.

Materiality
The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. 
These, together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and 
extent of our audit procedures on the individual financial statement line items and disclosures and in evaluating the effect 
of misstatements, both individually and in aggregate on the financial statements as a whole. 

Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:

Overall
materiality

How we
determined it

Rationale for 
benchmark applied

Group financial statements

Parent company financial statements

GEL 29.3 million (2018: GEL 25.5 million).

GEL 15.7 million (2018: GEL 15.5 million).

5% of profit before tax.

1% of total assets.

We believe that profit before tax is the 
primary measure used by the shareholders 
in assessing the performance of the 
Group, and is a generally accepted auditing 
benchmark. 

The parent company is the top holding 
company with investments in the subsidiaries 
within the Group. The parent company’s 
performance is measured primarily on the 
value of these investments, and therefore total 
assets is considered an appropriate materiality 
benchmark.

For each component in the scope of our group audit, we allocated a materiality that is less than our overall group 
materiality. The range of materiality allocated across components was between GEL 27.8 million and GEL 29.3 million. 
Certain components were audited to a local statutory audit materiality that was less than our overall group materiality 
allocation.

We agreed with the Audit Committee that we would report to them misstatements identified during our audit above GEL 
1.4  million  (group  audit)  (2018:  GEL  1.3  million)  and  GEL  0.8  million  (parent  only)  (2018:  GEL  0.8  million)  as  well  as 
misstatements below those amounts that, in our view, warranted reporting for qualitative reasons.

Going concern
In accordance with ISAs (UK) we report as follows:

Reporting obligation

Outcome

We are required to report if we have anything material to add 
or draw attention to in respect of the directors’ statement 
in the financial statements about whether the directors 
considered it appropriate to adopt the going concern basis 
of accounting in preparing the financial statements and the 
directors’ identification of any material uncertainties to the 
group’s and the parent company’s ability to continue as a 
going concern over a period of at least twelve months from 
the date of approval of the financial statements.

We are required to report if the directors’ statement relating 
to Going Concern in accordance with Listing Rule 9.8.6R(3) 
is  materially  inconsistent  with  our  knowledge  obtained  in 
the audit.

We have nothing material to add or to draw attention to. 
However, because not all future events or conditions can 
be predicted, this statement is not a guarantee as to the 
group’s and parent company’s ability to continue as a going 
concern. 

We have nothing to report.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

195

INDEPENDENT AUDITORS’ REPORT
TO THE MEMBERS OF TBC BANK GROUP PLC CONTINUED

Reporting on other information 
The other information comprises all of the information in the Annual Report other than the financial statements and our 
auditors’ report thereon. The directors are responsible for the other information. Our opinion on the financial statements 
does not cover the other information and, accordingly, we do not express an audit opinion or, except to the extent otherwise 
explicitly stated in this report, any form of assurance thereon. 

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, 
consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained 
in the audit, or otherwise appears to be materially misstated. If we identify an apparent material inconsistency or material 
misstatement,  we  are  required  to  perform  procedures  to  conclude  whether  there  is  a  material  misstatement  of  the 
financial statements or a material misstatement of the other information. 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 based on these responsibilities.

With respect to the Strategic Report and Directors’ Report, we also considered whether the disclosures required by the UK 
Companies Act 2006 have been included.

Based on the responsibilities described above and our work undertaken in the course of the audit, the Companies Act 2006 
(CA06), ISAs (UK) and the Listing Rules of the Financial Conduct Authority (FCA), require us also to report certain opinions 
and matters as described below (required by ISAs (UK) unless otherwise stated). 

Strategic Report and Directors’ Report
In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic 
Report and Directors’ Report for the year ended 31 December 2019 is consistent with the financial statements and 
has been prepared in accordance with applicable legal requirements. (CA06)

In light of the knowledge and understanding of the group and parent company and their environment obtained 
in the course of the audit, we did not identify any material misstatements in the Strategic Report and Directors’ 
Report. (CA06)

The directors’ assessment of the prospects of the group and of the principal risks that would threaten the 
solvency or liquidity of the group 
We have nothing material to add or draw attention to regarding: 

 ` The  directors’  confirmation  on  pages  134-135  of  the  Annual  Report  that  they  have  carried  out  a  robust 
assessment  of  the  principal  risks  facing  the  group,  including  those  that  would  threaten  its  business  model, 
future performance, solvency or liquidity.

 ` The disclosures in the Annual Report that describe those risks and explain how they are being managed or mitigated.
 ` The directors’ explanation on pages 134-135 of the Annual Report as to how they have assessed the prospects 
of the Group, over what period they have done so and why they consider that period to be appropriate, and their 
statement as to whether they have a reasonable expectation that the group will be able to continue in operation 
and meet its liabilities as they fall due over the period of their assessment, including any related disclosures 
drawing attention to any necessary qualifications or assumptions.

We have nothing to report having performed a review of the directors’ statement that they have carried out a robust 
assessment of the principal risks facing the Group and statement in relation to the longer-term viability of the Group. 
Our review was substantially less in scope than an audit and only consisted of making inquiries and considering the 
directors’  process  supporting  their  statements;  checking  that  the  statements  are  in  alignment  with  the  relevant 
provisions  of  the  UK  Corporate  Governance  Code  (the  “Code”);  and  considering  whether  the  statements  are 
consistent with the knowledge and understanding of the Group and parent company and their environment obtained 
in the course of the audit. (Listing Rules)

Other Code Provisions
We have nothing to report in respect of our responsibility to report when: 

 ` The statement given by the directors, on page 135, that they consider the Annual Report taken as a whole to 
be fair, balanced and understandable, and provides the information necessary for the members to assess the 
group’s and parent company’s position and performance, business model and strategy is materially inconsistent 
with our knowledge of the group and parent company obtained in the course of performing our audit.

 ` The section of the Annual Report on page 184 describing the work of the Audit Committee does not appropriately 

address matters communicated by us to the Audit Committee.

 ` The directors’ statement relating to the parent company’s compliance with the Code does not properly disclose 
a departure from a relevant provision of the Code specified, under the Listing Rules, for review by the auditors.

Directors’ Remuneration 
In our opinion, the part of the Directors’ Remuneration Report to be audited has been properly prepared in acco
rdance with the Companies Act 2006. (CA06)

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Responsibilities for the financial statements and the audit
Responsibilities of the directors for the financial statements
As explained more fully in the Directors’ Responsibilities Statement set out on page 135, the directors are responsible for 
the preparation of the financial statements in accordance with the applicable framework and for being satisfied that they 
give a true and fair view. The directors are also responsible for such internal control as they determine is necessary to 
enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the directors are responsible for assessing the group’s and the parent company’s 
ability to continue as a going concern, disclosing as  applicable,  matters  related  to  going  concern  and  using  the  going 
concern basis of accounting unless the directors either intend to liquidate the group or the parent company or to cease 
operations, or have no realistic alternative but to do so.

Auditors’ responsibilities for the audit of the financial statements
Our  objectives  are  to  obtain  reasonable  assurance  about  whether  the  financial  statements  as  a  whole  are  free  from 
material misstatement, whether due to fraud or error, and to issue an auditors’ 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 (UK) will 
always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered 
material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users 
taken on the basis of these financial statements. 

A further description of our responsibilities for the audit of the financial statements is located on the FRC’s website at: 
www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditors’ report.

Use of this report
This  report,  including  the  opinions,  has  been  prepared  for  and  only  for  the  parent  company’s  members  as  a  body  in 
accordance with Chapter 3 of Part 16 of the Companies Act 2006 and for no other purpose. We do not, in giving these 
opinions, accept or assume responsibility for any other purpose or to any other person to whom this report is shown or into 
whose hands it may come save where expressly agreed by our prior consent in writing.

OTHER REQUIRED REPORTING

Companies Act 2006 exception reporting
Under the Companies Act 2006 we are required to report to you if, in our opinion:

 ` we have not received all the information and explanations we require for our audit; or
 ` adequate accounting records have not been kept by the parent company, or returns adequate for our audit have not 

been received from branches not visited by us; or

 ` certain disclosures of directors’ remuneration specified by law are not made; or
 ` the parent company financial statements and the part of the Directors’ Remuneration Report to be audited, are not 

in agreement with the accounting records and returns. 

We have no exceptions to report arising from this responsibility. 

Appointment
Following the recommendation of the Audit Committee, we were appointed by the directors on 11 August 2016 to audit the 
financial  statements  for  the  year  ended  31  December  2016  and  subsequent  financial  periods.  The  period  of  total 
uninterrupted engagement is 4 years, covering the years ended 31 December 2016 to 31 December 2019.

Allan McGrath
(Senior Statutory Auditor)
for and on behalf of PricewaterhouseCoopers LLP
Chartered Accountants and Statutory Auditors
Edinburgh
28 April 2020

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

197

CONSOLIDATED STATEMENT OF FINANCIAL POSITION

In thousands of GEL

ASSETS
Cash and cash equivalents
Due from other banks
Mandatory cash balances with the National Bank of Georgia
Loans and advances to customers
Investment securities measured at fair value through other 
comprehensive income
Investment securities available for sale 
Bonds carried at amortised cost
Net Investments in leases
Investment properties
Current income tax prepayment
Deferred income tax asset
Other financial assets
Other assets
Premises and equipment
Right of use assets
Intangible assets 
Goodwill 

Investments in associates

TOTAL ASSETS

LIABILITIES
Due to credit institutions
Customer accounts
Other financial liabilities
Current  income tax liability
Debt securities in issue
Deferred income tax liability
Provisions for liabilities and charges
Other liabilities
Lease Liabilities

Subordinated debt

TOTAL LIABILITIES

EQUITY
Share capital
Shares held by trust
Share premium
Retained earnings
Group reorganisation reserve
Share based payment reserve
Revaluation reserve for premises
Fair value reserve
Revaluation reserve for available-for-sale securities
Cumulative currency translation reserve
Net assets attributable to owners
Non-controlling interest

TOTAL EQUITY

TOTAL LIABILITIES AND EQUITY

Note

31 December
2019

31 December
2018 

31 December 
2017 

6
7
8
9

10
10
11
13
17

35
12
14
15
16
15
18

19
20
23

21
35
22
24
16

25

26
26
26

26
27

39

1,003,583
33,605
1,591,829
12,349,399

1,166,911
47,316
1,422,809
10,038,452

1,431,477
39,643
1,033,818
8,325,353

985,293
-   
1,022,684
256,660
72,667
25,695
2,173
133,736
255,712
385,736
59,693
167,597
61,558 

2,654

1,005,239 
-
654,203
203,802
84,296
2,116 
2,097
167,518
192,792
367,504
-   
109,220
31,286

2,432

-   
657,938
449,538
143,836
79,232
 19,084 
 2,855 
146,144
156,651
366,913
-
83,492
28,658

1,278

18,410,274

15,497,993

12,965,910

3,593,901
10,049,324
113,608
1,634
1,213,598
21,331
23,128
95,161
             59,898 

591,035

3,031,503
9,352,142
98,714
63
13,343
22,237
18,767
104,337
-   

650,919

2,620,714
7,816,817
91,753
447
20,695
602
13,200
84,440
-

426,788

        15,762,618 

13,292,025

11,075,456

1,682
(27,517)
848,459
1,953,364
(162,166)
(17,802)
56,374
  (6,476)
-   
(6,850)
2,639,068
                 8,588

2,647,656

1,650
-   
796,854
1,523,879
(162,166)
(16,294)
57,240
8,680
-   
(6,937)
2,202,906
3,062

2,205,968

1,605
-
714,651
1,232,865
(162,166)
9,828
70,045
-
1,730
(7,359)
1,861,199
29,255

1,890,454

         18,410,274

15,497,993

12,965,910

The financial statements on pages 198 to 318 were approved by the Board of Directors on 28 April 2020 and signed on its behalf 
by:

Vakhtang Butskhrikidze 
Chief Executive Officer 

Giorgi Shagidze
Chief Financial Officer

The notes set out on pages 205 to 318 form an integral part of these financial statements.

198

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
 
 
CONSOLIDATED STATEMENT OF PROFIT OR LOSS AND OTHER COMPREHENSIVE INCOME 

In thousands of GEL
Interest income
Interest expense
Net gains on currency swaps
Net interest income 
Fee and commission income
Fee and commission expense
Net fee and commission income
Net insurance premiums earned
Net insurance claims incurred and agents’ commissions
Insurance Profit
Net gains from trading in foreign currencies
Net gains from foreign exchange translation 
Net gains/(losses) from derivative financial instruments
Net gains from disposal of Investment Securities measured at fair value 
through other comprehensive income
Net gains from disposal of Investment securities available for sale
Other operating income
Share of profit of associates
Other operating non-interest income
Credit loss allowance for loans to customers
Credit loss allowance for investments in lease
Credit loss allowance for performance guarantees and credit 
related commitments
Credit loss allowance for other financial assets
Credit loss allowance for financial assets measured at fair value through 
other comprehensive income
Operating income after credit impairment losses
Staff costs
Depreciation and amortisation
(Provision for)/recovery of provision for liabilities and charges
Administrative and other operating expenses 
Operating expenses
Profit before tax 
Income tax expense
Profit for the year
Other comprehensive income /(expense) (OCI):
Items that may be reclassified subsequently to profit or loss:
Movement in fair value reserve
Revaluation of available-for-sale investments
Exchange differences on translation to presentation currency
Items that will not be reclassified to profit or loss:
Revaluation of premises and equipment
Income tax recorded directly in other comprehensive income/(expense)
Other comprehensive income for the year
TOTAL COMPREHENSIVE INCOME/(EXPENSE)  FOR THE YEAR
Profit is attributable to:
- Shareholders of TBCG
- Non-controlling interest
Profit for the year
Total comprehensive income is attributable to:
- Shareholders of TBCG
- Non-controlling interest
Total comprehensive income for the year
Earnings per share for profit attributable to the owners of the Group:
- Basic earnings per share
- Diluted earnings per share

Note
30
30
30

31
31

32

9
13

22
12

33
15,17
22
34

35

10
10

35

2019
1,436,843
(663,860)
28,556
801,539
293,431
(106,141)
187,290
38,199
(19,689)
18,510
79,279
22,188
(280)

169
-   
18,916
632
120,904
(82,030)
582

(2,156)
(8,098)

(290)
1,036,251
(247,803)
(59,478)
(1,264)
(142,181)
(450,726)
585,525
(45,184)
540,341

(15,156)
-   
85

-
-
(15,071)
525,270

537,895
2,446
540,341

522,824
2,446
525,270

28
28

9.8
9.8

2018
1,284,235
(506,213)
-
778,022
235,701
(78,171)
157,530
23,601
(11,326)
12,275
91,678
15,196
173

2
-   
31,438
1,154
139,641
(143,723)
(1,765)

2017
1,033,939
(429,924)
-
604,015
193,944
(67,983)
125,961
12,633
(5,860)
6,773
87,099
4,374
(36)

-   
93
31,797
909
124,236
(93,823)
(492)

(4,056)
(16,609)

(153)
(12,439)

(86)
921,229
(220,354)
(45,740)
(4,000)
(140,935)
(411,029)
510,200
(72,765)
437,435

-   
754,078
(203,100)
(37,265)
2,495
(121,530)
(359,400)
394,678
(34,750)
359,928

6,949
-   
425

-   
5,489
181

10,749
(2,363)
15,760
453,195

435,080
2,355
437,435

450,903
2,292
453,195

8.1
8.0

-
(422)
5,248
365,176

354,410
5,518
359,928

359,585
5,591
365,176

6.7
6.6

The notes set out on pages 205 to 318 form an integral part of these financial statements.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

199

CONSOLIDATED STATEMENT OF CHANGES IN EQUITY 

In thousands of GEL

Note

Share
capital

Shares held 
by trust

Share 
premium

Group
reorganisation 
reserve

Share based 
payments 
reserve

Net assets Attributable to owners

Revaluation 
reserve for 
available 
for sale 
securities

Revaluation 
reserve for 
premises

Cumulative 
currency 
translation 
reserve

Fair value 
reserve1

Retained
earnings

Non-
control ling 
interest

Total

Total
 equity

Balance as of 1 January 
2017
Profit for the year
Other comprehensive 
income
Total comprehensive 
income
for 2017
Share issue
Share based payment 
Conversion of shares
Dividends declared
Balance as of 31 
December 2017
Impact of adopting IFRS 9 
as at 1 January 2018
Balance as at
1 January 2018 
Profit for the year
Other comprehensive 
income (expense)
Total comprehensive 
income for 2018
Share issue
Share based
payment 
Conversion of shares
Dividends declared
Transfer of revaluation 
surplus of 
derecognised assets to 
retained earnings
Purchase of additional 
interest from NCI
Balance as of 31 
December 201 
Profit for the year
Other comprehensive 
expense
Total comprehensive 
income for 2019
Share issue
Share buy-back 
Share based
payment 
Business Combination
Purchase of additional 
interest from NCI
Dividends declared
Transfer of revaluation 
surplus to retained 
earnings and other 
movements
Balance as of 31 
December 2019

26
27
26

26

27
27

26
27

27

1,581
-

-

-
21
-
3
-

1,605

-

1,605
-

-

-
23

 -   
22
-

-

-

1,650
-

-

-
32
-

 -   
 -   

 -   
-

-

-
-

-

-
-
-
-
-

-

-

-
-

-

-
-

-
-
-

-

-

-
-

-

677,211 (162,166)
-

-

23,327
-

70,460 (3,681)
-

-

- (7,538)
-
-

955,173 1,554,367
354,410
354,410

28,264
5,518

1,582,631
359,928

-

-

-

(415)

5,411

-
32,308
-
5,132
-

-
-
- (24,253)
10,754
-
-
-
-
-

(415)
-
-
-
-

5,411
-
-
-
-

-

-
-
-
-
-

179

-

5,175

73

5,248

179
-
-
-
-

354,410
-
-
(1,909)
(74,809)

359,585
8,076
10,754
3,226
(74,809)

5,591
-
(211)
(3,197)
(1,192)

365,176
8,076
10,543
29
(76,001)

714,651 (162,166)

9,828

70,045

1,730

- (7,359) 1,232,865 1,861,199

29,255

1,890,454

-

-

-

-

(1,730)

1,730

-

(62,928)

(62,928)

(719)

(63,647)

714,651 (162,166)
-

-

9,828
-

70,045
-

-

-

-

8,466

-
42,031

 -   
40,172
-

-

-

-
-
- (38,669)

8,466
-

-
-
-

-

-

12,547
-
-

-
-
-

- (21,271)

-

-

796,854 (162,166) (16,294)
-

-

-

-

-

-

57,240
-

-

-
-
-

-
-

-
-

-
-
(27,517)

-
51,605
-

-
-
- (35,306)
-
-

33,798
-

-
-

-
-

-
-

-

 -   
 -   

 -   
-

-

-
-

-
-

-

-

(866)

-
-

-

-
-

-
-
-

-

-

-
-

1,730 (7,359) 1,169,937 1,798,271
 435,080 

 435,080 

-

-

28,536
2,355

1,826,807
437,435

6,950

422

-

15,838

(78)

15,760

6,950
-

422
-

435,080 
-

450,918
3,385

2,277
-

453,195
3,385

-
-
-

-

-

-
-
-

-

-

-
(17,838)
(88,950)

12,547
(879)
22,356 (22,356)
(116)

(88,950)

11,668
-
(89,066)

21,271

-

-

-

4,379

4,379 (4,415)

(36)

8,680 (6,937) 1,523,879 2,202,906
537,895

537,895

-

-

3,062
2,446

2,205,968
540,341

-(15,156)

-(15,156)
-
-
-
-

-
-

-
-

-

-
-

-
-

-

85

85
-
-

-
2

-

(15,071)

-

(15,071)

537,895
-
-

522,824
16,331
(27,517)

2,446
-
-

525,270
16,331
(27,517)

-
-

33,798
2

(35)
3,134

33,763
3,136

-
-
- (108,622)

-
(108,622)

(19)
-

(19)
(108,622)

-

212

(654)

-

(654)

 1,682 

(27,517)

848,459    (162,166)  (17,802)

56,374

- (6,476) (6,850) 1,953,364 2,639,068

8,588

2,647,656

The notes set out on pages 205 to 318 form an integral part of these financial statements.

200

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

      
CONSOLIDATED STATEMENT OF CASH FLOWS

In thousands of GEL
Cash flows from (used in) operating activities
Interest received 
Interest received on currency swaps
Interest paid 
Fees and commissions received
Fees and commissions paid
Insurance and reinsurance  received
Insurance claims paid
Income received from trading in foreign currencies
Other operating income received
Staff costs paid
Administrative and other operating expenses paid 
Income tax paid
Cash flows from operating activities before changes in operating assets and liabilities
Net change in operating assets 
Due from other banks and mandatory cash balances with the National Bank of Georgia
Loans and advances to customers
Net investment in lease
Other financial assets
Other assets
Net change in operating liabilities
Due to other banks
Customer accounts
Other financial liabilities
Other liabilities and provision for liabilities and charges
Net cash flows (used in)/from operating activities
Cash flows from (used in) investing activities
Acquisition of investment securities measured at fair value through 
other comprehensive income

Acquisition of investment securities available for sale
Proceeds from disposal of investment securities measured at fair value through other 
comprehensive income
Proceeds from redemption at maturity of investment securities measured at fair value 
through other comprehensive income
Proceeds from redemption at maturity of investment securities available for sale
Acquisition of subsidiaries, net of cash acquired

Acquisition of bonds carried at amortised cost
Proceeds from redemption of bonds carried at amortised cost
Acquisition of premises, equipment and intangible assets
Proceeds from disposal of premises, equipment and intangible assets
Cash acquired from acquired subsidiaries
Proceeds from disposal of investment property
Net cash used in investing activities
Cash flows from (used in) financing activities
Proceeds from other borrowed funds
Redemption of other borrowed funds
Repayment of principal of lease liabilities 
Proceeds from subordinated debt
Redemption of subordinated debt
Proceeds from debt securities in issue
Redemption of debt securities in issue
Dividends paid
Issue of ordinary shares
Net cash flows from financing activities
Effect of exchange rate changes on cash and cash equivalents
Net (decrease)/ increase in cash and cash equivalents
Cash and cash equivalents at the beginning of the year
Cash and cash equivalents at the end of the year

Note

2019

2018

2017

1,360,296
28,556
 (647,427)
 282,715 
 (106,526)
 76,101 
 (21,787)
79,287
44,248
(216,465)
 (169,582)
(70,413)
639,003

1,224,606
-
(501,984)
235,508
(78,140)
54,682
(15,174)
91,678
11,407
(202,897)
(136,670)
(34,918)
648,098

(22,009)

(343,772)
(2,013,577) (1,718,446)
(54,784)
(35,570)
(4,486)

 (43,719)
19,612
 1,577 

1,000,571
-
(424,105)
195,285
(68,036)
23,518
(9,127)
87,099
8,992
(187,520)
(112,270)
(53,916)
460,491

(98,586)
(1,330,105)
(49,297)
(38,064)
73,814

(1,938)
272,023
(8,267)
5,816
(1,151,479)

69,755
1,371,675
(12,136)
3,618
(76,048)

(228,486)
1,329,071
18,263
3,487
140,588

10 (1,781,816)

(717,729)

-

10

10

-

-

(560,226)

240,603

14,781

-

10 1,598,536
10
-
(39,297)

11
11
15

(613,383)
216,871
(120,333)
13,225
2,996
13,338
(469,260)

370,571
-
809

(395,717)
200,658
(89,263)
813 
-
42,515
(572,562)

1,819,899

1,776,489
(1,392,897) (1,515,562)
-
255,900
(60,910)
(7,596) 
-
(85,484)

(6,453)
-
(104,079)
1,176,049
(14,296)
(91,928)

1,386,295
71,116
(163,328)
6 1,166,911
6 1,003,583

362,837
21,207
(264,566)
1,431,477
1,166,911

-
345,748
(273)

(307,248)
242,380
(114,383)
1,932
-
19,082
(372,988)

1,461,191
(800,333)
-
119,859
(59,671)
-
(2,123)
(67,927)
29
651,025
67,672
486,297
945,180
1,431,477

The notes set out on pages 205 to 318 form an integral part of these financial statements.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

201

SEPARATE STATEMENT OF FINANCIAL POSITION

In thousands of GEL
ASSETS
Cash and cash equivalents

Due from other banks
Loans and advances to customers
Other financial assets
Investments in subsidiaries
Other assets
TOTAL ASSETS
LIABILITIES
Other financial liabilities
TOTAL LIABILITIES
EQUITY

Share capital
Shares held by trust
Shares Premium
Retained earnings
Profit for the year
Other reserves
TOTAL EQUITY
TOTAL LIABILITIES AND EQUITY

Note

31 December 
2019 

31 December 
2018

31 December 
2017 

5,546

40,815
-
278
1,519,922
465
1,567,026

1,751
1,751

1,682
(27,516)
848,459
681,048
100,630
(39,028)
1,565,275
1,567,026

2

26
27
26

27

2,204

79,135
-
170
1,473,168
3
1,554,680

2,334
2,334

1,650
-
796,854
668,364
121,306
(35,828)
1,552,346
1,554,680

210

11,564
24,000
219
1,429,485
8
1,465,486

825
825

1,605
-
714,651
670,444
86,789
(8,828)
1,464,661
1,465,486

The financial statements on pages 198 to 318 were approved by the Board of Directors on 28 April 2020 and signed on its behalf by:

Vakhtang Butskhrikidze 
Chief Executive Officer 

Giorgi Shagidze
Chief Financial Officer

Registered No. 10029943

The notes set out on pages 205 to 318 form an integral part of these financial statements.

202

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
 
 
 
SEPARATE STATEMENT OF CHANGES IN EQUITY

In thousands of GEL
Balance as of 1 January 2017
Profit  for the year
Total comprehensive income for 2017
Share issue
Dividends declared
Share based payment 
Balance as of 31 December 2017
Profit  for the year
Total comprehensive income for 2018
Share issue
Dividends declared
Share based payment 
Balance as of 31 December 2018
Profit for the year
Total comprehensive income for 2019
Share issue
Share buy-back
Dividends declared
Share based payment 
Balance as of 31 December 2019

Note

26
26
27

26
26
27

26
26
26
27

Share
capital 
1,581
-
-
24
-
-
1,605
-
-
45
-
-
1,650
-
-
 32 

-
-
 1,682 

Shares held 
by trust
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
 (27,516)
-
-
(27,516) 

Share 
premium
677,211
-
-
37,440
-
-
714,651
-
-
82,203
-
-
796,854
-
-
 51,605 

-
-
848,459 

Other 
reserves
4,882
-
-
(24,253)
-
10,543
(8,828)
-
-
(38,668)
-
11,668
(35,828)
-
-
(34,941)

Retained 
Earnings
745,253
86,789
86,789
-
(74,809)
-
757,233
121,306
121,306
-
(88,869)
-
789,670
100,630
100,630
-

-
31,741
 (39,028)

(108,622)
-
 781,678

Total 
equity
1,428,927
86,789
86,789
13,211
(74,809)
10,543
1,464,661
121,306
121,306
43,580
(88,869)
11,668
1,552,346
100,630
100,630
16,696
(27,516)
(108,622)
31,741
 1,565,275 

The notes set out on pages 205 to 318 form an integral part of these financial statements.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

203

SEPARATE STATEMENT OF CASH FLOWS

In thousands of GEL

Cash flows from (used in) operating activities
Interest received 
Interest paid
Fees and commissions paid
Salaries and other employee benefits paid
Administrative and other operating expenses paid 
Other operating income received

Cash flows used in operating activities before changes
in operating assets and liabilities

Net change in operating assets 
Other financial assets
Other assets
Net change in operating liabilities
Other financial liabilities

Net cash flows used in operating activities

Cash flows from (used in) investing activities
Acquisition of subsidiaries, net of cash acquired
Cash contribution to subsidiaries
Dividends received
Income from recharge agreement
Dividends paid
Placement/withdrawal of deposits
Issuance of debt to subsidiary
Net cash flows from investing activities

Cash flows from (used in) financing activities

Net cash flows from (used in) financing activities

Effect of exchange rate changes on cash and cash equivalents

Net increase (decrease) in cash and cash equivalents

Cash and cash equivalents at the beginning of the year
Cash and cash equivalents at the end of the year

2019

2018

2017

 9,933 
 (42)
 (17)
 (4,520)
 (10,439)
 215

1,908
-
(12)
(3,797)
(3,569)
16

1,348
-
(12)
(3,469)
(1,423)
11

(4,870)

(5,454)

(3,545)

 (10)
 (101)

 360 

(4,621)

(40,162)
 (8,857)
 99,662 
 16,005 
 (91,925)
34,007
-
8,730

-

-

(767)

3,342

2,204
5,546

5
3

(161)

(5,607)

-
(800)
124,561
8,955
(85,484)
(39,555)
-
7,677

-

-

(76)

1,994

210
2,204

137
-

(3)

(3,411)

-
-
77,090
23,745
(66,733)
(8,830)
(22,000)
3,272

-

-

(50)

(189)

399
210

The notes set out on pages 205 to 318 form an integral part of these financial statements.

204

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

NOTES TO THE FINANCIAL STATEMENTS 

1. INTRODUCTION

Principal activity. TBC Bank Group PLC (“TBCG” or “Group”) is a public limited liability company, incorporated in England 
and Wales. TBCG held 99.88% of the share capital of JSC TBC Bank (hereafter the “Bank”) as at 31 December 2019 (2018: 
99.88%, 2017: 98.67%), thus representing the Bank’s ultimate parent company. The Bank is a parent of a group of companies 
incorporated in mainly in Georgia, Azerbaijan and Uzbekistan, their primary business activities include providing banking, 
leasing, brokerage and card processing services to corporate and individual customers. The Group’s list of subsidiaries is 
provided in Note 2.

The shares of TBCG (“TBCG Shares”) were admitted to the Premium Listing segment of the Official List of the UK Listing 
Authority and admitted to trading on the London Stock Exchange PLC’s Main Market for listed securities effective on 10 
August 2016 (the “Admission”). TBC Bank Group PLC’s registered legal address is Elder House St Georges Business Park, 
207 Brooklands Road, Weybridge, Surrey, KT13 0TS. Registered number of TBC Bank Group PLC is 10029943. The Bank is 
the Group’s main operating unit and it accounts for most of the Group’s activities.

JSC TBC Bank was incorporated on 17 December 1992 and is domiciled in Georgia. The Bank is a joint stock company limited 
by shares and was set up in accordance with Georgian regulations. The Bank’s registered address and place of business is 7 
Marjanishvili Street, 0102 Tbilisi, Georgia. 

The Bank’s principal business activity is universal banking operations that include corporate, small and medium enterprises, 
retail and micro operations within Georgia. The Bank has been operating since 20 January 1993 under a general banking 
license issued by the National Bank of the Georgia (“NBG”). In 2018, the Bank launched fully-digital bank, Space.

The Bank has 148 (2018:146; 2017:154) branches within Georgia. 

As of 31 December 2019, 31 December 2018 and 31 December 2017, the following shareholders directly owned more than 5% 
of the total outstanding shares of the Group. Other shareholders individually owned less than 5% of the outstanding shares. 
As of 31 December 2019, 31 December 2018 and 31 December 2017 the Group had no ultimate controlling party

Shareholders
European Bank for Reconstruction and Development
Dunross & Co.
Schroder Investment Management
JPMorgan Asset Management
Badri Japaridze*
Liquid Crystal International N.V. LLC
Mamuka Khazaradze*
Other**
Total

% of ownership interest held as of 31 December

2019
8.04%
6.61%
6.48%
6.22%
6.00%
5.55%
4.71%
56.39%
100.00%

2018 
8.18%
5.51%
7.08%
8.40%
6.08%
5.64%
6.19%
52.92%
100.00%

2017 
8.38%
0.00%
9.53%
9.21%
6.23%
5.78%
6.35%
54.52%
100.00%

*  Represents direct ownership of the shares for Mamuka Khazaradze and Badri Japaridze. Mamuka Khazaradze has beneficial ownership of 10.26% (2018: 13.54%; 2017: 

13.87% and Badri Japaridze has beneficial ownership of 6.00%, (2018: 6.77%; 2017: 6.93%).

**  Other includes individual as well as corporate shareholders. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

205

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Basis of preparation.  In  accordance  with  the  exemption  permitted  under  section  408  of  the  Companies  Act  2006,  the 
standalone statement of comprehensive income of TBCG is not presented as part of these financial statements. TBCG’s 
income for the year is disclosed within the separate statement of financial position and the separate statement of changes 
in equity. 

The consolidated financial statements of the Group and the separate financial statements of TBC Bank Group PLC, have 
been prepared in accordance with International Financial Reporting Standards (“IFRS”) and interpretations issued by the 
IFRS Interpretations Committee (IFRS IC) as adopted by the European Union (“EU”) and the Companies Act 2006 applicable 
to  companies  reporting  under  IFRS.  The  consolidated  and  separate  financial  statements  have  been  prepared  under  the 
historical cost convention, as modified by the certain financial assets and liabilities (including derivative instruments) and 
certain class of premises and equipment which are measured at fair value. The principal accounting policies applied in the 
preparation of the consolidated and separate financial statements are set out below. These policies have been consistently 
applied to all the periods presented, unless otherwise stated (refer to Note 3).

New accounting policy for leases by the Group as a lessee. The Group adopted IFRS 16, Leases, using modified retrospective 
method and applied certain simplifications or practical expedients. The standard is effective for annual periods beginning 
on or after 1 January 2019. Refer to section 2.3 below. The Group has not adopted early any other standard, interpretation or 
amendment that has been issued but is not yet effective.

Going Concern. The Board of Directors of TBC Bank Group PLC has prepared these financial statements on a going concern 
basis. In making this judgement the management considered the Group’s financial position, current intentions, profitability 
of operations and access to financial resources. The management is not aware of any material uncertainties that may cast 
significant doubt upon the Group’s ability to continue as a going concern.

Presentation currency.  These  consolidated  financial  statements  are  presented  in  thousands  of  Georgian  Lari  (“GEL 
thousands”), except per-share amounts and unless otherwise indicated.

Consolidated financial statements. Subsidiaries are those investees, including structured entities, that the Group controls 
because it (i) has power to direct relevant activities of the investees that significantly affect their returns, (ii) has exposure, or 
rights, to variable returns from its involvement with the investees, and (iii) has the ability to use its power over the investees to 
affect the amount of investor’s returns. The existence and effect of substantive rights, including substantive potential voting 
rights, are considered when assessing whether the Group has power over another entity. For a right to be substantive, the 
holder must have practical ability to exercise that right when decisions about the direction of the relevant activities of the 
investee need to be made. The Group may have power over an investee even when it holds less than the majority of voting 
power in it. In such a case, the Group assesses the size of its voting rights relative to the size and dispersion of holdings of 
the other vote holders to determine if it has de-facto power over the investee. Protective rights of other investors, such as 
those that relate to fundamental changes of investee’s activities or apply only in exceptional circumstances, do not prevent 
the Group from controlling an investee. Subsidiaries are consolidated from the date on which control is transferred to the 
Group, and are deconsolidated from the date on which control ceases.

206

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

Subsidiaries and associates. The TBC Bank Group PLC holds 99.88%of the Bank as of 31 December 2019. The consolidated 
financial statements include the following principal subsidiaries:

Proportion of voting rights and ordinary 
share capital held as of 31 December

Subsidiaries Name
JSC TBC Bank 
United Financial Corporation JSC
TBC Capital LLC
TBC Leasing JSC

TBC Kredit LLC
Banking System Service Company LLC2
TBC Pay LLC

2019
99.88%
99.53%
100.00%
100.00%

100.00%
N/A
100.00%

2018
99.88%
98.67%
100.00%
99.61%

100.00%
100.00%
100.00%

TBC Invest LLC

100.00%

100.00%

Index LLC
BG LLC1 
JSC TBC Insurance 
Redmed  LLC
TBC International LLC
Swoop JSC

Online Tickets LLC

TKT UZ
My.Ge LLC
Mypost LLC 
Billing Solutions LLC
Vendoo LLC (Geo)

Allproperty.ge LLC
F Solutions LLC

Inspired LLC

VENDOO LLC (UZ Leasing)

100.00%
N/A
100.00%
100.00%
100.00%
100.00%

55.00%

75.00%
65.00%
100.00%
51.00%
100.00%

90.00%
100.00%

51.00%

100.00%

100.00%
N/A
100.00%
N/A
N/A
100.00%

N/A

N/A
N/A
N/A
N/A
N/A

N/A
N/A

N/A

N/A

The Group has investments in the following associates:

2017

Principal place 
of business or 
incorporation
98.67% Tbilisi, Georgia
98.67% Tbilisi, Georgia
100.00% Tbilisi, Georgia
99.61% Tbilisi, Georgia

75.00% Baku, Azerbaijan
100.00% Tbilisi, Georgia
100.00% Tbilisi, Georgia
Ramat 
Gan,Israel

100.00%

100.00% Tbilisi, Georgia
N/A Tbilisi, Georgia
100.00% Tbilisi, Georgia
N/A Tbilisi, Georgia
N/A Tbilisi, Georgia
N/A Tbilisi, Georgia

N/A Tbilisi, Georgia
Tashkent, 
N/A
Uzbekistan
N/A Tbilisi, Georgia
N/A Tbilisi, Georgia
N/A Tbilisi, Georgia
N/A Tbilisi, Georgia

N/A Tbilisi, Georgia
N/A Tbilisi, Georgia
Tashkent, 
Uzbekistan
Tashkent, 
Uzbekistan

N/A

N/A

Year of 
incorporation
1992
1997
1999
2003

Industry
Banking
Card processing
Brokerage
Leasing
Non-banking credit 
1999
institution
2009 Information services
Processing
2009

2011

PR and marketing
Real estate 
management
2011
Real Estate
2018
Insurance
2014
2019
Insurance
2019 Asset management
Retail Trade
2010
Computer and 
Software Services

2015

2019
2019
2019
2019
2019

2013
2019

2011

2019

Retail Trade
E-Commerce
Postal Service
Software Services
Retail Leasing
Real estate 
management
Software Services

Processing

Retail Leasing

Associate Name

Proportion of voting rights and ordinary share 
capital held as of 31 December
2017

2018

2019

Principal place 
of business or 
incorporation

Year of 
incorporation

CreditInfo Georgia JSC

21.08%

21.08%

21.08% Tbilisi, Georgia

Online Tickets LLC3

N/A

26.00%

26.00% Tbilisi, Georgia

2005

2015

Industry
Financial 
intermediation
Computer and 
Software Services

The country of registration or incorporation is also the principal area of operation of each of the above subsidiaries. The 
Group’s corporate structure consists of a number of related undertakings, comprising subsidiaries and associates, which are 
not consolidated or equity accounted due to immateriality. A full list of these undertakings, the country of incorporation and 
the ownership of each share class is set out below.

1  The Group had de-facto control over the subsidiary (control without legal form of ownership). The company was acquired and subsequently legally 

merged with Bank in 2019. 

2  The company was merged to United Financial Corporation JSC in 2019.
3  The group became 55% shareholder of the company in 2019. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

207

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

Proportion of voting rights and ordinary 
share capital held as of 31 December

Company Name
TBC Invest International Ltd
University Development Fund2 

UFC International Ltd3 
Natural Products of Georgia LLC

2019
100.00%
33.33%

N/A
25.00%

2018
100.00%
33.33%

N/A
25.00%

2017

Principal place 
of business or 
incorporation
100.00% Tbilisi, Georgia
33.33% Tbilisi, Georgia
British Virgin 
80.00%
Islands
25.00% Tbilisi, Georgia

Mobi Plus JSC

GRDC

14.81%

14.81%

14.81% Tbilisi, Georgia

1.75%

1.75%

1.64% Tbilisi, Georgia

Georgian Card JSC 
Georgian Securities Central Depositor
JSC Givi Zaldastanishvili American 
Academy In Georgia
United Clearing Centre
Banking and Finance Academy of 
Georgia
Tbilisi's City JSC

Swift
TBC Trade

0.15%
0.05%

14.48%
18.75%

16.67%
1.80%

0.15%
0.05%

14.48%
18.75%

16.67%
1.80%

0.01%
100.00%

0.01%
100.00%

14.48% Tbilisi, Georgia
18.75% Tbilisi, Georgia

16.67% Tbilisi, Georgia
1.80% Tbilisi, Georgia
La Hulpe, 
Belgium
100.00% Tbilisi, Georgia

0.01%

Mineral Oil Distribution Corporation JSC 

9.90%

9.90%

9.90% Tbilisi, Georgia

Year of 
incorporation

Industry
2016 Investment Vehicle
Education
2007

2001 Investment Vehicle
Trade, Service
2001
Data monitoring and 
processing
Investment Real 
Estate

2009

2008

2001
2008

1998
2007

Education
Clearing Centre

Education
Education

2014
2008

2009

Finance, Service
Trade, Service
Data monitoring and 
processing

0.15% Tbilisi, Georgia
0.05% Tbilisi, Georgia

1997Plastic Card Services
Finance, Service
1999

Business combinations and Goodwill accounting. Business combinations are accounted for using the acquisition method. 
The cost of an acquisition is measured at the fair value of the consideration, including contingent consideration, given at 
the  acquisition date. Acquisition-related costs are recognised as an expense in the profit or loss in the period in which they 
are incurred. Identifiable assets acquired and liabilities and contingent liabilities assumed in a business combination are 
measured at their fair values at the acquisition date, irrespective of the extent of any non-controlling interest. 

The Group measures the non-controlling interest that represents the current ownership’s interest and entitles the holder to 
a proportionate share of net assets in the event of liquidation on a transaction by transaction basis, either at: (a) fair value, or 
(b) the non-controlling interest’s proportionate share of net assets of the acquired entity. Non-controlling interests that are 
not present ownership interests are measured at fair value.

Goodwill is measured by deducting the acquiree’s net assets from the aggregate of the consideration transferred for the 
acquiree, the amount of non-controlling interest in the acquiree and fair value of an interest in the acquiree held immediately 
before the acquisition date. Any negative amount (“negative goodwill”) is recognised in profit or loss, after the management 
reassesses whether it identified all the assets acquired and all liabilities and contingent liabilities assumed, and reviews 
appropriateness of their measurement.

The consideration transferred for the acquiree is measured at the fair value of the assets given up, equity instruments issued 
and liabilities incurred or assumed, including fair value of assets or liabilities from contingent consideration arrangements, 
but excludes acquisition related costs such as advisory, legal, valuation and similar professional services.

Transaction costs incurred for issuing equity instruments are deducted from the equity; transaction costs incurred for issuing 
debt are deducted from its carrying amount and all other transaction costs associated with the acquisition are expensed.

Intercompany  transactions,  balances  and  unrealised  gains  on  transactions  between  group  companies  are  eliminated; 
unrealised losses are also eliminated unless the cost cannot be recovered. The Bank and all of its subsidiaries use uniform 
accounting policies consistent with the Group’s policies.

2  Non-entrepreneurial (non-commercial) legal entity
3  Liquidated in 2018

208

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

Business combinations and Goodwill accounting (continued).Non-controlling interest is that part of the net results and 
of the equity of a subsidiary attributable to interests that are not owned, directly or indirectly, by the Bank. Non-controlling 
interest forms a separate component of the Group’s equity.

Associates. Associates are entities over which the Group has significant influence (directly or indirectly), but not control, 
generally accompanying a shareholding of between 20 and 50 per cent of the voting rights. Investments in associates are 
accounted for using the equity method of accounting, and are initially recognised at cost. The carrying amount of associates 
includes goodwill identified on acquisition less accumulated impairment losses, if any. Dividends received from associates 
reduce the carrying value of the investments in associates. Other post-acquisition changes in Group’s share of net assets of 
an associate are recognised as follows: (i) the Group’s share of profits or losses of associates is recorded in the consolidated 
profit or loss for the year as share of result of associates, (ii) the Group’s share of other comprehensive income is recognised 
in other comprehensive income and presented separately, (iii); all other changes in the Group’s share of the carrying value of 
net assets of associates are recognised in profit or loss within the share of result of associates. However, when the Group’s 
share of losses in an associate equals or exceeds its interest in the associate, including any other unsecured receivables, the 
Group does not recognise further losses, unless it has incurred obligations or made payments on behalf of the associate.

Unrealised gains on transactions between the Group and its associates are eliminated to the extent of the Group’s interest 
in the associates; unrealised losses are also eliminated unless the transaction provides evidence of an impairment of the 
asset transferred.

Purchases and sales of non-controlling interests. The Group applies the economic entity model to account for transactions 
with  owners  of  non-controlling  interest.  Any  difference  between  the  purchase  consideration  and  the  carrying  amount  of 
non-controlling interest acquired is recorded as a capital transaction directly in equity. The Group recognises the difference 
between sales consideration and carrying amount of non-controlling interest sold as a capital transaction in the statement 
of changes in equity.

Disposals of subsidiaries, associates or joint ventures. When the Group ceases to have control or significant influence, 
any retained interest in the entity is re-measured to its fair value, with the change in carrying amount recognised in profit or 
loss. The fair value is the initial carrying amount for the purposes of subsequently accounting for the retained interest as an 
associate, joint venture or financial asset. In addition, any amounts previously recognised in other comprehensive income in 
respect of that entity are accounted for as if the Group had directly disposed of the related assets or liabilities. This may mean 
that amounts previously recognised in other comprehensive income are recycled to profit or loss. 

If the ownership interest in an associate is reduced but significant influence is retained, only a proportionate share of the 
amounts previously recognised in other comprehensive income are reclassified to profit or loss where appropriate.

Financial instruments – key measurement terms. Fair value is the price that would be received to sell an asset or paid to 
transfer a liability in an orderly transaction between market participants at the measurement date. The best evidence of fair 
value is the price in an active market. An active market is one in which transactions for the asset or the liability take place with 
sufficient frequency and volume to provide pricing information on an ongoing basis. The fair value of financial instruments 
traded in an active market is measured as the product of the quoted price for the individual asset or liability and the quantity 
owned by the entity. This is the case even if a market’s normal daily trading volume is not sufficient to absorb the quantity 
held and placing orders to sell the position in a single transaction might affect the quoted price.

A portfolio of financial derivatives or other financial assets and liabilities that are not traded in an active market is measured 
at the fair value of a group of financial assets and financial liabilities on the basis of the price that would be received to sell 
a net long position (ie an asset) for a particular risk exposure or paid to transfer a net short position (i.e. a liability) for a 
particular risk exposure in an orderly transaction between market participants at the measurement date. 

Valuation  techniques  such  as  discounted  cash  flow  models  or  models  based  on  recent  arm’s  length  transactions  or 
consideration of financial data of the investees are used to measure the fair value of certain financial instruments for which 
external market pricing information is not available. Fair value measurements are analysed by level in the fair value hierarchy 
as follows: (i) level one are measurements at quoted prices (unadjusted) in active markets for identical assets or liabilities, (ii) 
level two measurements are valuations techniques with all material inputs observable for the asset or liability, either directly 
(that is, as prices) or indirectly (that is, derived from prices), and (iii) level three measurements are valuations not solely based 
on observable market data (that is, the measurement requires significant unobservable inputs). Transfers between levels of 
the fair value hierarchy are deemed to have occurred at the end of the reporting period. 

Cost is the amount of cash or cash equivalents paid or the fair value of the other consideration given to acquire an asset at 
the time of its acquisition and includes transaction costs.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

209

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

Transaction costs are  incremental  costs  that  are  directly  attributable  to  the  acquisition,  issue  or  disposal  of  a  financial 
instrument. An incremental cost is one that would not have incurred if the transaction had not taken place. Transaction costs 
include fees and commissions paid to agents (including employees acting as selling agents), advisors, brokers and dealers, 
levies by regulatory agencies and securities exchanges, and transfer taxes and duties. Transaction costs do not include debt 
premiums or discounts, financing costs or internal administrative or holding costs. 

Amortised cost (“AC”) is the amount at which the financial instrument was recognised at initial recognition less any principal 
repayments, plus accrued interest, and for financial assets less any write-down for expected credit losses. Accrued interest 
includes the amortisation of transaction costs deferred at initial recognition and of any premium or discount to maturity 
amount using the effective interest method. Accrued interest income and accrued interest expense, including both accrued 
coupon and amortised discount or premium (including fees deferred at origination, if any), are not presented separately and 
are included in the carrying values of related items in the consolidated statement of financial position. Repayments for loans 
are accounted for penalties in the first place, then accrued interest and after that principal amount.

The effective interest method is a method of allocating interest income or interest expense over the relevant period so as to 
achieve a constant periodic rate of interest (effective interest rate) on the carrying amount. The effective interest rate is the 
rate that exactly discounts estimated future cash payments or receipts (excluding future credit losses) through the expected 
life of the financial instrument or a shorter period, if appropriate, to the net carrying amount of the financial instrument. The 
effective interest rate discounts cash flows of variable interest instruments to the next interest repricing date, except for the 
premium or discount which reflects the credit spread over the floating rate specified in the instrument, or other variables 
that are not reset to market rates. Such premiums or discounts are amortised over the whole expected life of the instrument. 
The present value calculation includes all fees paid or received between parties to the contract that are an integral part of 
the effective interest rate (refer to income and expense recognition policy). For assets that are purchased or originated credit 
impaired (“POCI”) at initial recognition, the effective interest rate is adjusted for credit risk, i.e. it is calculated based on the 
expected cash flows on initial recognition instead of contractual payments.

Initial recognition of financial instruments. Financial instruments at FVTPL are initially recorded at fair value. All other 
financial instruments are initially recorded at fair value adjusted for transaction costs. Fair value at initial recognition is best 
evidenced by the transaction price. A gain or loss on initial recognition is only recorded if there is a difference between fair 
value and transaction price which can be evidenced by other observable current market transactions in the same instrument 
or by a valuation technique whose inputs include only data from observable markets. After the initial recognition, an ECL 
(expected credit loss) allowance is recognised for financial assets measured at AC and investments in debt instruments 
measured at FVOCI, resulting in an immediate accounting loss.

All purchases and sales of financial assets that require delivery within the time frame set by regulation or market convention 
(“regular way” purchases and sales) are recorded at trade date, which is the date that the Group commits to deliver a financial 
asset. All other purchases are recognised when the entity becomes a party to the contractual provisions of the instrument. 

Financial assets – classification and subsequent measurement – measurement categories. The Group classifies financial 
assets in the following measurement categories: FVTPL, FVOCI and AC. The classification and subsequent measurement of 
debt financial assets depends on: (i) the Group’s business model for managing the related assets portfolio and (ii) the cash 
flow characteristics of the asset. 

Financial assets – classification and subsequent measurement – business model. The business model drives classification 
of  financial  assets.  Management  applied  judgement  in  determining  the  level  of  aggregation  and  portfolios  of  financial 
instruments when performing the business model assessment. When assessing sales transactions, the Group considers 
their  historical  frequency,  timing  and  value,  reasons  for  the  sales  and  expectations  about  future  sales  activity.  Sales 
transactions aimed at minimising potential losses due to credit deterioration are considered consistent with the “hold to 
collect” business model. Other sales before maturity, not related to credit risk management activities, are also consistent 
with the “hold to collect” business model, provided that they are infrequent or insignificant in value, both individually and 
in aggregate. The Group assesses significance of sales transactions by comparing the value of the sales to the value of the 
portfolio subject to the business model assessment over the average life of the portfolio. In addition, sales of financial asset 
expected only in stress case scenario, or in response to an isolated event that is beyond the Group’s control, is not recurring 
and could not have been anticipated by the Group, are regarded as incidental to the business model objective and do not 
impact the classification of the respective financial assets. 

The “hold to collect and sell” business model means that assets are held to collect the cash flows, but selling is also integral 
to achieving the business model’s objective, such as, managing liquidity needs, achieving a particular yield, or matching the 
duration of the financial assets to the duration of the liabilities that fund those assets.

210

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2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

The residual category includes those portfolios of financial assets, which are managed with the objective of realising cash 
flows primarily through sale, such as where a pattern of trading exists. Collecting contractual cash flow is often incidental 
for this business model. 

Financial assets – classification and subsequent measurement – cash flow characteristics. Where the business model 
is to hold assets to collect contractual cash flows or to hold contractual cash flows and sell, the Group assesses whether 
the cash flows represent solely payments of principal and interest (“SPPI”). Financial assets with embedded derivatives are 
considered in their entirety when determining whether their cash flows are consistent with the SPPI feature. In making this 
assessment, the Group considers whether the contractual cash flows are consistent with a basic lending arrangement, i.e. 
interest includes only consideration for credit risk, time value of money, other basic lending risks and profit margin. 

Where the contractual terms introduce exposure to risk or volatility that is inconsistent with a basic lending arrangement, the 
financial asset is classified and measured at FVTPL. The SPPI assessment is performed on initial recognition of an asset and 
it is not subsequently reassessed. The judgements applied by the Group in performing the SPPI test for its financial assets 
is as follows:

The time value of money element may be modified, for example, if a contractual interest rate is periodically reset but the 
frequency of that reset does not match the tenor of the debt instrument’s underlying base interest rate, for example a loan 
pays three months interbank rate but the rate is reset every month. The effect of the modified time value of money was 
assessed by comparing relevant instrument’s cash flows against a benchmark debt instrument with SPPI cash flows, in 
each period and cumulatively over the life of the instrument. The Group applied a threshold of 10% to determine whether 
differences against a benchmark instruments are significantly different. In case of a scenario with cash flows that significantly 
differ from the benchmark, the assessed instrument’s cash flows are not SPPI and the instrument is then carried at FVTPL.

The Group identified and considered contractual terms that change the timing or amount of contractual cash flows. The SPPI 
criterion is met if a loan allows early settlement and the prepayment amount substantially represents principal and accrued 
interest, plus a reasonable additional compensation for the early termination of the contract. The asset’s principal is the 
fair value at initial recognition less subsequent principal repayments, i.e. instalments net of interest determined using the 
effective interest method. As an exception to this principle, the standard also allows instruments with prepayment features 
that meet the following condition to meet SPPI: (i) the asset is originated at a premium or discount, (ii) the prepayment amount 
represents contractual amount and accrued interest and a reasonable additional compensation for the early termination of 
the contract, and (ii) the fair value of the prepayment feature is immaterial at initial recognition. 

The instruments that failed the SPPI test are generally measured at FVTPL. The Bank did not have such category of Loans to 
customers during 2018 and 2019.

Financial assets – reclassification. Financial instruments are reclassified only when the business model for managing the 
portfolio as a whole changes. The reclassification has a prospective effect and takes place from the beginning of the first 
reporting period that follows after the change in the business model. The Group did not change its business model during the 
current and comparative period and did not make any reclassifications.

Financial assets impairment - expected credit loss (ECL) allowance. 
The  Group  assesses,  on  a  forward-looking  basis,  the  ECL  for  debt  instruments  measured  at  AC  and  FVOCI  and  for  the 
exposures arising from loan commitments and financial guarantee contracts. The Group measures ECL and recognises 
credit loss allowance at each reporting date. The measurement of ECL reflects: (i) an unbiased and probability weighted 
amount that is determined by evaluating a range of possible outcomes, (ii) time value of money and (iii) all reasonable and 
supportable information that is available without undue cost and effort at the end of each reporting period about past events, 
current conditions and forecasts of future conditions.

The Group applies a three stage model for impairment, based on changes in credit quality since initial recognition:

 ` Stage 1: A financial instrument that is not credit-impaired on initial recognition is classified in Stage 1. Financial assets 
in Stage 1 have their ECL measured at an amount equal to the portion of lifetime ECL that results from default events 
possible within the next 12 months or until contractual maturity, if shorter (“12 Months ECL”);

 ` Stage 2: If the Group identifies a significant increase in credit risk (“SICR”) since initial recognition, the asset is transferred 
to Stage 2 and its ECL is measured based on ECL on a lifetime basis (“Lifetime ECL”). If a SICR is no longer observed, 
instrument will move back to Stage 1. Refer to Note 37 for a description of how the Group determines, on a forward-
looking basis, when a SICR has occurred;

 ` Stage 3: Credit impaired assets are transferred to Stage 3 and allowance for Lifetime ECL is recognized. The Group’s 
definition  of  credit  impaired  assets  and  definition  of  default  is  based  on  the  occurrence  of  one  or  more  loss  events, 
described further in Note 37.

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Change in ECL is recognized in the statement of profit or loss with a corresponding allowance reported as a decrease in 
carrying value of the financial asset on the statement of financial position. For financial guarantees and credit commitments, 
provision for ECL is reported as a liability in Provisions for Liabilities and Charges.

Gross carrying amount and write offs. Gross carrying amount of a financial asset is the amortised cost of a financial asset, 
before adjusting for any loss allowance. The Group directly reduces the gross carrying amount of a financial asset when the 
entity has no reasonable expectations of recovering a financial asset in its entirety or a portion thereof. The latter includes 
penalties under the local regulation requirements. The loans are collectively assessed for write off based on overdue days 
criteria or are individually evaluated, depending on the loan segment and product type. The contractual amounts outstanding 
on loans to customers that have been written off partially or fully, but are still subject to enforcement activity was principal 
amount GEL 110 million (31 December 2018: GEL 96 million), accrued interest GEL 28 million (31 December 2018: GEL 18 
million) and accrued off balance sheet penalty GEL 114 million (31 December 2018: GEL 92 million).

Financial assets – derecognition and modification.  The  Group  derecognises  financial  assets  when  (a)  the  assets  are 
redeemed or the rights to cash flows from the assets otherwise expired or (b) the Group has transferred the rights to the 
cash  flows  from  the  financial  assets  or  entered  into  a  qualifying  pass-through  arrangement  while  (i)  also  transferring 
substantially all risks and rewards of ownership of the assets or (ii) neither transferring nor retaining substantially all risks 
and rewards of ownership, but not retaining control. Control is retained if the counterparty does not have the practical ability 
to sell the asset in its entirety to an unrelated third party without needing to impose restrictions on the sale. The Group 
sometimes renegotiates or otherwise modifies the contractual terms of the financial assets. The Group assesses whether 
the modification of contractual cash flows is substantial considering, among other, the following factors: change in interest 
rate due to market environment changes, change in the currency denomination; consolidation of two or more loans into one 
new loan; change in counterparty; loan with no schedule is replaced with loan with schedule or vice versa; Based on below 
shown internally developed methodology there are certain qualitative triggers which lead to asset derecognition with no 
further quantitative testing required. These qualitative criteria are included in the list below: 

 ` Change in contract currency;
 ` Consolidation of two or more loans into one new loan;
 ` Change in counterparty;
 ` Loan with no predetermined payment schedule is changed with loan with schedule or vice versa; 
 ` Change in contractual interest rate due to market environment changes.

The Group compares the original and revised expected cash flows to assets whether the risks and rewards of the asset are 
substantially different as a result of the contractual modification. It should be assessed whether change in contractual cash 
flow is significant (significance defined as 10% change). If the test result is above 10% threshold, loan should be derecognized, 
whereas if the test is passed and result is below or equal to 10%, financial asset can be assessed as modified. 

If the risks and rewards do not change, the modified asset will not be substantially different (exceed 10% test) from the 
original asset and the modification does not result in derecognition. The Group recalculates the gross carrying amount by 
discounting the modified contractual cash flows by the original effective interest rate or, when applicable, the revised effective 
interest rate and recognises a modification gain or loss in profit or loss. Any costs or fees incurred adjust the carrying amount 
of the modified financial asset and are amortised over the remaining term of the modified financial asset.

Financial liabilities – measurement categories. Financial liabilities are classified as subsequently measured at AC, except 
for (i) financial liabilities at FVTPL: this classification is applied to derivatives, financial liabilities held for trading (e.g. short 
positions in securities), contingent consideration recognised by an acquirer in a business combination and other financial 
liabilities designated as such at initial recognition and (ii) financial guarantee contracts and loan commitments.

Cash and cash equivalents. Cash and cash equivalents are items which are readily convertible to known amounts of cash and 
are subject to an insignificant risk of changes in value. Cash and cash equivalents include cash on hand, amounts due from 
the National Bank of Georgia (NBG), excluding mandatory reserves, and all interbank placements and interbank receivables 
with original maturities of less than three months. Funds restricted for a period of more than three months on origination are 
excluded from cash and cash equivalents. Cash and cash equivalents are carried at AC because: (i) they are held for collection 
of contractual cash flows and those cash flows represent SPPI, and (ii) they are not designated at FVTPL. Features mandated 
solely by legislation, such as the bail-in legislation in certain countries, do not have an impact on the SPPI test, unless they 
are included in contractual terms such that the feature would apply even if the legislation is subsequently changed.

The  payments  or  receipts  presented  in  the  statement  of  cash  flows  represent  the  Group’s  transfers  of  cash  and  cash 
equivalents, including amounts charged or credited to current accounts of the Group’s counterparties held with the Group, 
such as loan interest income or principal collected by charging the customer’s current account or interest payments or 
disbursement  of  loans  credited  to  the  customer’s  current  account,  which  represent  cash  or  cash  equivalent  from  the 
customer’s perspective.

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Mandatory cash balances with the National Bank of Georgia. Mandatory cash balances with the NBG are carried at AC and 
represent mandatory reserve deposits that are not available to finance the Group’s day to day operations. Hence they are not 
considered as part of cash and cash equivalents for the purposes of the consolidated statement of cash flows.

Due from other banks. Amounts due from other banks are recorded when the Group advances money to counterparty banks. 
Amounts due from other banks are carried at AC when: (i) they are held for the purposes of collecting contractual cash flows 
and those cash flows represent SPPI, and (ii) they are not designated at fair value through profit or loss (FVTPL). Otherwise 
they are carried at fair value (FV).

Investments in debt securities.  Based  on  the  business  model  and  the  cash  flow  characteristics,  the  Group  classifies 
investments in debt securities as carried at AC, fair value through other comprehensive income (FVOCI) or FVTPL. Debt 
securities are carried at AC if they are held for collection of contractual cash flows and where those cash flows represent 
SPPI, and if they are not voluntarily designated at FVTPL in order to significantly reduce an accounting mismatch. 

Debt securities are carried at FVOCI if they are held for collection of contractual cash flows and for selling, where those 
cash flows represent SPPI, and if they are not designated at FVTPL. Interest income from these assets is calculated using 
the effective interest method and recognised in profit or loss. An impairment allowance estimated using the expected credit 
loss model is recognised in profit or loss for the year. All other changes in the carrying value are recognised in OCI. When the 
debt security is derecognised, the cumulative gain or loss previously recognised in OCI is reclassified from OCI to profit or 
loss. Investments in debt securities are carried at FVTPL if they do not meet the criteria for AC or FVOCI. The Group may also 
irrevocably designate investments in debt securities at FVTPL on initial recognition if applying this option significantly reduces 
an accounting mismatch between financial assets and liabilities being recognised or measured on different accounting bases. 

Investments in equity securities.  Financial  assets  that  meet  the  definition  of  equity  from  the  issuer’s  perspective,  i.e. 
instruments that do not contain a contractual obligation to pay cash and that evidence a residual interest in the issuer’s 
net assets, are considered as investments in equity securities by the Group. Investments in equity securities are measured 
at FVTPL, except where the Group elects at initial recognition to irrevocably designate an equity investments at FVOCI. The 
Group’s policy is to designate equity investments as FVOCI when those investments are held for strategic purposes other 
than solely to generate investment returns. When the FVOCI election is used, fair value gains and losses are recognised in 
OCI and are not subsequently reclassified to profit or loss, including on disposal. Impairment losses and their reversals, if 
any, are not measured separately from other changes in fair value. Dividends continue to be recognised in profit or loss when 
the Group’s right to receive payments is established except when they represent a recovery of an investment rather than a 
return on such investment. 

Loans and advances to customers. Loans and advances to customers are recorded when the Group advances money to 
purchase or originate a loan due from a customer. Based on the business model and the cash flow characteristics, the Group 
classifies loans and advances to customers into one of the following measurement categories: (i) AC: loans that are held for 
collection of contractual cash flows and those cash flows represent SPPI and loans that are not voluntarily designated at 
FVTPL, and (ii) FVTPL: loans that do not meet the SPPI test or other criteria for AC or FVOCI are measured at FVTPL. 

Impairment allowances are determined based on the forward-looking ECL models. Note 37 provides information about inputs, 
assumptions and estimation techniques used in measuring ECL, including an explanation of how the Group incorporates 
forward-looking information in the ECL models. 

Repossessed collateral. Repossessed collateral represents non-financial assets acquired by the Group to settle overdue 
loans. The assets are initially recognised at fair value when acquired and included in premises and equipment, investment 
property or repossessed collateral  within other assets depending on their nature and the Group’s intention in respect of 
recovery of these assets and are subsequently re-measured and accounted for in accordance with the accounting policies for 
these categories of assets. Repossessed assets are recorded at the lower of cost or net realisable value.

Loan commitments. The Group issues commitments to provide loans. These commitments are irrevocable or revocable only 
in response to a material adverse change. Such commitments are initially recognised at their fair value, which is normally 
evidenced by the amount of fees received. This amount is amortised on a straight line basis over the life of the commitment, 
except for commitments to originate loans if it is probable that the Group will enter into a specific lending arrangement and 
does not expect to sell the resulting loan shortly after origination; such loan commitment fees are deferred and included in the 
carrying value of the loan on initial recognition. At the end of each reporting period, the commitments are measured at (i) the 
remaining unamortised balance of the amount at initial recognition, plus (ii) the amount of the loss allowance determined based 
on the expected credit loss model, unless the commitment is to provide a loan at a below market interest rate, in which case 
the measurement is at the higher of these two amounts. The carrying amount of the loan commitments represents a liability. 

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Financial guarantees. Financial guarantees require the Group to make specified payments to reimburse the holder of the 
guarantee for a loss it incurs because a specified debtor fails to make payment when due in accordance with the original 
or modified terms of a debt instrument. Financial guarantees are initially recognised at their fair value, which is normally 
evidenced by the amount of fees received. This amount is amortised on a straight line basis over the life of the guarantee. 
At the end of each reporting period, the guarantees are measured at the higher of (i) the amount of the loss allowance for 
the guaranteed exposure determined based on the expected loss model and (ii) the remaining unamortised balance of the 
amount at initial recognition. In addition, an ECL loss allowance is recognised for fees receivable that are recognised in the 
statement of financial position as an asset. Performance guarantees. Performance guarantees are contracts that provide 
compensation if another party fails to perform a contractual obligation. Such contracts transfer non-financial performance 
risk in addition to credit risk. Performance guarantees are initially recognised at their fair value, which is normally evidenced 
by the amount of fees received. This amount is amortised on a straight line basis over the life of the contract. At the end 
of each reporting period, the performance guarantee contracts are measured at the higher of (i) the unamortised balance 
of the amount at initial recognition and (ii) the best estimate of expenditure required to settle the contract at the end of 
each reporting period, discounted to present value. Where the Group has the contractual right to revert to its customer for 
recovering amounts paid to settle the performance guarantee contracts, such amounts will be recognised as an asset upon 
transfer  of  the  loss  compensation  to  the  guarantee’s  beneficiary.  These  fees  are  recognised  within  fee  and  commission 
income in profit or loss. 

Sale and repurchase agreements.  Sale  and  repurchase  agreements  (“repo  agreements”),  which  effectively  provide  a 
lender’s return to the counterparty, are treated as secured financing transactions. The lender provides funds to the borrower 
and receives security as collateral. Securities sold under such sale and repurchase agreements are not derecognized. The 
securities are not reclassified in the statement of financial position unless the transferee has, by contract, the right or custom 
to sell or repledge the securities, in which case they are reclassified as repurchase receivables. The corresponding liability is 
presented within amounts due to credit institutions. The repurchase agreements are short-term in nature. Available-for-sale 
securities or bonds carried at amortised cost reclassified to repurchase receivables continue to be carried at fair value or 
amortised cost respectively in accordance with the accounting policies for these categories of assets.

Securities purchased under agreements to resell (“reverse repo agreements”), which effectively provide a lender’s return 
to the Group, are recorded as due from other banks or loans and advances to customers, as appropriate. The difference 
between the sale and repurchase price is treated as interest income and accrued over the life of repo agreements using the 
effective interest method. 

Securities lent to counterparties for a fixed fee are retained in the consolidated financial statements in their original category 
in the statement of financial position unless the counterparty has the right by contract or custom to sell or repledge the 
securities, in which case they are reclassified and presented separately. Securities borrowed for a fixed fee are not recorded 
in the consolidated financial statements, unless these are sold to third parties, in which case the purchase and sale are 
recorded in profit or loss for the year within gains less losses arising from trading securities. The obligation to return the 
securities is recorded at fair value in other borrowed funds.

Based  on  classification  of  securities  sold  under  the  sale  and  repurchase  agreements,  the  Group  classifies  repurchase 
receivables into one of the following measurement categories: AC, FVOCI, and FVTPL.

Net investments in lease. Where the Group is a lessor in a lease that substantially transfers all risks and rewards incidental 
to ownership to the lessee, the assets leased out are presented as net investments in leases and carried at the present value 
of the future lease payments. Net Investments in leases are initially recognised at commencement (when the lease term 
begins) using a discount rate determined at inception (the early date of the lease agreement and the date of commitment by 
the parties to the principal provisions of the lease).

The difference between the gross receivable and the present value represents unearned finance income. This income is 
recognised over the term of the lease using the net investment method (before tax), which reflects a constant periodic rate of 
return. Incremental costs directly attributable to negotiating and arranging the lease are included in the initial measurement 
of the net investments in leases and reduce the amount of income recognised over the lease term. Finance income from 
leases is recorded within interest income in the profit or loss.

The ECL is determined in the same way as for loans and advances measured at AC and recognised through an allowance 
account to write down the receivables’ net carrying amount to the present value of expected cash flows discounted at the 
interest rates implicit in the lease investments. There is a ‘three stage’ approach which is based on the change in credit 
quality of financial lease receivables since initial recognition. Immediate loss that is equal to the 12-month ECL is recorded 
on initial recognition of financial leases that are not credit impaired. In case of a significant increase in credit risk, impairment 
is measured using lifetime ECL rather than 12-month ECL. The estimated future cash flows reflect the cash flows that may 

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result from obtaining and selling the assets subject to the lease.

Receivables from terminated leases. The company recognizes receivables from terminated contracts at the moment of lease 
contract termination. These receivables are recognized at amount comprising difference between fair value of repossessed 
assets and outstanding balance of net investments in lease. Receivables are accounted for at AC less ECL.

Prepayment for purchase of leasing assets. Prepayment  for  purchase  of  leasing  assets  comprises  of  interest  bearing 
advance  payments  made  to  purchase  assets  for  transfer  into  leases.  Such  advances  are  accounted  for  as  non-financial 
assets. On commencement of the leases, advances towards lease contracts are transferred into net investment in finance 
lease.

Due to credit institutions. Amount due to credit institutions are recorded when counterparty banks advance money or other 
assets to the Group. The non-derivative liability is carried at AC. If the Group purchases its own debt, it is removed from 
the  consolidated  statement  of  financial  position  and  the  difference  between  the  carrying  amount  of  the  liability  and  the 
consideration paid is included in gains or losses arising from retirement of debt.

Customer accounts. Customer accounts are non-derivative liabilities to individuals, state or corporate customers and are 
carried at AC. 

Subordinated debt. Subordinated debt can only be paid in the event of a liquidation after the claims of other higher priority 
creditors have been met and is included in the Bank’s “tier 2” capital. Subordinated debt is carried at AC. 

Debt securities in issue. Debt securities in issue include promissory notes, bonds, certificates of deposit and debentures 
issued  by  the  Group.  Debt  securities  are  stated  at  AC.  If  the  Group  purchases  its  own  debt  securities  in  issue,  they  are 
removed from the consolidated statement of financial position and the difference between the carrying amount of the liability 
and the consideration paid is included in gains arising from retirement of debt.

Derivative financial instruments.  Derivative  financial  instruments,  including  foreign  exchange  contracts,  interest  rate 
futures, forward rate agreements, currency and interest rate swaps, currency and interest rate options are recognized at 
their fair value. The Group also enters into offsetting deposits with its counterparty banks to exchange currencies. Such 
deposits, while legally separate, are aggregated and accounted for as a single derivative financial instrument (currency swap) 
on a net basis where (i) the deposits are entered into at the same time and in contemplation of one another, (ii) they have 
the same counterparty, (iii) they relate to the same risk and (iv) there is no apparent business purpose for structuring the 
transactions separately that could not also have been accomplished in a single transaction.

All  derivative  instruments  are  carried  as  assets  when  fair  value  is  positive  and  as  liabilities  when  fair  value  is  negative. 
Changes in the fair value of derivative instruments are included in profit or loss. The Group does not apply hedge accounting.

Certain  derivative  instruments  embedded  in  other  financial  instruments  are  treated  as  separate  derivative  instruments 
when their risks and characteristics are not closely related to those of the host contract. 

When derivative instruments are entered into with a view to decrease cost of funding, respective interest effect is presented 
as a separate line of statement of comprehensive income, within net interest income

Goodwill. Goodwill is carried at cost less accumulated impairment losses, if any. The Group tests goodwill for impairment at 
least annually and whenever there are indications that goodwill may be impaired. Goodwill is allocated to the cash-generating 
units, or groups of cash-generating units, that are expected to benefit from the synergies of the business combination. Such 
units or group of units represent the lowest level at which the Group monitors goodwill, and are not larger than an operating 
segment. Gains or losses on disposal of an operation within a cash generating unit to which goodwill has been allocated 
include the carrying amount of goodwill associated with the disposed operation. This is generally measured on the basis of 
the relative values of the disposed operation and the portion of the cash-generating unit which is retained. 

Premises and equipment.  Premises  and  equipment,  except  for  land,  buildings  and  construction  in  progress,  are  stated 
at cost, less accumulated depreciation and provision for impairment, where required. Cost of premises and equipment of 
acquired subsidiaries is the estimated fair value at the date of acquisition.

Following initial recognition, land, buildings and construction in progress are carried at a revalued amount, being the fair 
value at the date of revaluation, less any subsequent accumulated depreciation and subsequent accumulated impairment 
losses. Revaluations are performed frequently enough to ensure that the carrying amount does not differ materially from 
that which would be determined using fair values at the end of reporting period.

Any revaluation surplus is credited to the revaluation reserve for premises and equipment included in equity, except to the 
extent that it reverses a revaluation decrease of the same asset previously recognised in profit or loss. In this case the increase 

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is recognized in profit or loss to the extent of the decrease previously charged. A revaluation deficit is recognized in profit 
or loss, except that a deficit directly offsetting a previous surplus on the same asset is recognized in other comprehensive 
income and reduces revaluation reserve for premises and equipment accumulated in equity.  

Depreciation on revalued buildings is charged to profit or loss. Upon disposal of revalued property, any revaluation reserve 
relating to the particular asset being sold or retired is transferred to retained earnings. 

Costs of minor repairs and maintenance are expensed when incurred. Costs of replacing major parts or components of 
premises and equipment items are capitalised and the replaced part is retired.

If impaired, premises and equipment are written down to the higher of their value in use and fair value less costs to sell. The 
decrease in carrying amount is charged to profit or loss to the extent it exceeds the previous revaluation surplus in equity. 
An impairment loss recognised for an asset in prior years is reversed if there has been a change in the estimates used to 
determine the asset’s value in use or fair value less costs to sell.

Gains and losses on disposals determined by comparing proceeds with carrying amount are recognised in profit or loss. 

Depreciation. Land and construction in progress are not depreciated. Depreciation on other items of premises and equipment 
and  right-of-use  assets  is  calculated  using  the  straight-line  method  to  allocate  their  cost  or  revalued  amounts  to  their 
residual values over their estimated useful lives as follows: 

        30 – 100 years;

Premises 
Furniture and fixtures 
Computers and office equipment 
Motor vehicles 
Other equipment 
Right-of-use assets                                         the term of the underlying lease; and 
Leasehold improvements 

                         5 – 8 years; 
        3 – 8 years;
        4 – 5 years; 
        2 – 10 years;

        the term of the underlying lease or if not defined, not more than 7 years.

The residual value of an asset is the estimated amount that the Group would currently obtain from disposal of the asset less 
the estimated costs of disposal, if the asset was already of the age and in the condition expected at the end of its useful life. 
The residual value of an asset is nil if the Group expects to use the asset until the end of its physical life. The assets’ residual 
values and useful lives are reviewed, and adjusted if appropriate, at the end of each reporting period.

Investment property. Investment property is property that the Groups owns to earn rental income or for capital appreciation, 
or both, and that it does not occupy. 

Investment  property  is  stated  at  cost  less  accumulated  depreciation  and  provision  for  impairment,  where  required.  It  is 
amortised on a straight line basis over an expected useful life of 30 to 50 years. In case of any indication that the investment 
properties may be impaired, the Group estimates the recoverable amount as the higher of value in use and fair value less 
costs to sell. The carrying amount of an investment property is written down to its recoverable amount through a charge to 
profit or loss for the year. An impairment loss recognised in prior years is reversed if there has been a subsequent change in 
the estimates used to determine the asset’s recoverable amount. 

Land included in investment property is not depreciated. Depreciation on other items of investment properties is calculated 
using the straight-line method to allocate their cost to their residual values over their estimated useful lives of 30 to 50 years. 
Residual values of investment properties are estimated to be nil.

Earned rental income is recorded in profit or loss for the year within other operating income.

Subsequent expenditure is capitalised to the asset’s carrying amount only when it is probable that future economic benefits 
associated with the expenditure will flow to the Group and the cost can be measured reliably. All other repairs and maintenance 
costs are expensed when incurred. 

Intangible assets. All of the Group’s intangible assets have definite useful life and primarily include capitalised computer 
software and licenses. 

Acquired computer software licenses are capitalised on the basis of the costs incurred to acquire and bring to use the specific 
software. All other costs associated with computer software, e.g. its maintenance, are expensed when incurred. Intangible 
assets are amortised on a straight line basis over expected useful lives of 2 to 15 years.

Accounting for leases by the Group as a lessee from 1 January 2019. The Group leases office, branches and service centre 
premises. Leases are recognised as a right-of-use asset and a corresponding liability at the date at which the leased asset 

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is available for use by the Group. Each lease payment is allocated between the liability and finance cost. The finance cost is 
charged to profit or loss over the lease period so as to produce a constant periodic rate of interest on the remaining balance 
of the liability for each period. The right-of-use asset is recognised at cost and depreciated over the shorter of the asset’s 
useful life and the lease term on a straight-line basis.

Liabilities arising from a lease are initially measured on a present value basis. Lease liabilities include the net present value 
of the following lease payments:

 ` fixed payments (including in-substance fixed payments), less any lease incentives receivable;
 ` variable lease payment that are based on an index or a rate;
 ` amounts expected to be payable by the lessee under residual value guarantees;
 ` he exercise price of a purchase option if the lessee is reasonably certain to exercise that option, and
 ` payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.

The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be determined, the lessee’s 
incremental borrowing rate is used, being the rate that the lessee would have to pay to borrow the funds necessary to obtain 
an asset of similar value in a similar economic environment with similar terms and conditions.

Right-of-use assets are measured at cost comprising the following: 

 ` the amount of the initial measurement of lease liability;
 ` any lease payments made at or before the commencement date less any lease incentives received;
 ` any initial direct costs, and
 ` restoration costs.

As an exception to the above, the Group accounts for short-term leases and leases of low value assets by recognising the 
lease payments as an operating expense on a straight line basis.

In determining the lease term, management of the Group considers all facts and circumstances that create an economic 
incentive to exercise an extension option, or not exercise a termination option. Extension options (or periods after termination 
options) are only included in the lease term if the lease is reasonably certain to be extended (or not terminated). 

Accounting for operating leases by the Group as a lessee prior to 1 January 2019. Where the Group is a lessee in a lease 
which does not transfer substantially all the risks and rewards incidental to ownership from the lessor to the Group, the total 
lease payments are charged to profit or loss for the year (rental expense) on a straight-line basis over the period of the lease.

Leases  embedded  in  other  agreements  are  separated  if  (a)  fulfilment  of  the  arrangement  is  dependent  on  the  use  of  a 
specific asset or assets and (b) the arrangement conveys a right to use the asset.

Accounting for operating leases by the Group as a lessor. When assets are leased out under an operating lease, the lease 
payments receivable are recognised as rental income on a straight-line basis over the lease term.

Insurance and reinsurance receivables. Insurance and reinsurance receivables are recognised based on insurance policy 
terms  and  measured  at  cost.  The  carrying  value  of  insurance  and  reinsurance  receivables  is  reviewed  for  impairment 
whenever events or circumstances indicate that the carrying amount may not be recoverable, with any impairment loss 
recorded  in  the  consolidated  statement  of  income.  Reinsurance  receivables  primarily  include  balances  due  from  both 
insurance  and  reinsurance  companies  for  ceded  insurance  liabilities.  Insurance  premiums  are  recognised  as  revenue 
(earned premiums) proportionally over the period of coverage of respective insurance contracts. Premiums are shown before 
deduction of commission and are gross of any taxes or duties levied on premiums. Amounts due to reinsurers are estimated 
in a manner consistent with the associated reinsured policies and in accordance with the reinsurance contract. Premiums 
ceded and claims reimbursed are presented on a gross basis. 

An  impairment  review  is  performed  on  all  reinsurance  assets  when  an  indication  of  impairment  occurs.  Reinsurance 
receivables are impaired only if there is objective evidence that the Group may not receive all amounts due to it under the 
terms of the contract that this can be measured reliably.

Liability adequacy test.  Liability  adequacy  tests  are  performed  at  each  balance  sheet  date  to  ensure  the  adequacy  of 
recognised insurance liabilities net of related deferred acquisition costs. In performing the tests, current best estimates of 
future contractual cash flows, claims handling and administration costs in respect of claims, as well as investment income 
from assets backing such liabilities, are used. Where tests highlight a deficiency, insurance liabilities are increased with any 
deficiency being recognised in the consolidated statement of comprehensive income.

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Income taxes. Income taxes are provided in the consolidated financial statements in accordance with the legislation enacted 
or substantively enacted by the end of reporting period in the respective territories that the Bank and its subsidiaries operate. 
The income tax charge/credit comprises of current tax and deferred tax and is recognised in profit or loss except if it is 
recognised directly in other comprehensive income because it relates to transactions that are also recognised, in the same 
or a different period, directly in other comprehensive income. 

Current tax is the amount expected-to-be-paid to or recovered from the tax authorities in respect of taxable profits or losses 
for the current and prior periods. Taxable profits or losses are based on estimates if consolidated financial statements are 
authorised prior to filing relevant tax returns. Taxes, other than on income, are recorded within administrative and other 
operating expenses.

Deferred income tax is provided using the balance sheet liability method for tax loss carry forwards and temporary differences 
arising  between  the  tax  bases  of  assets  and  liabilities  and  their  carrying  amounts  for  financial  reporting  purposes.  In 
accordance  with  the  initial  recognition  exemption,  deferred  taxes  are  not  recorded  for  temporary  differences  on  initial 
recognition  of  an  asset  or  a  liability  in  a  transaction  other  than  a  business  combination  if  the  transaction,  when  initially 
recorded, affects neither accounting nor taxable profit. Deferred tax liabilities are not recorded for temporary differences on 
initial recognition of goodwill and subsequently for goodwill that is not deductible for tax purposes. Deferred tax balances are 
measured at tax rates enacted or substantively enacted at the end of reporting period that are expected to apply to the extent 
of time when the temporary differences will reverse or the tax loss carry forwards will be utilised. 

Deferred  tax  assets  and  liabilities  are  netted  only  within  the  individual  companies  of  the  Group.  Deferred  tax  assets  for 
deductible temporary differences and tax loss carry forwards are recorded only to the extent that it is probable that future 
taxable profit will be available against which the deductions can be utilised. 

Deferred  income  tax  is  provided  on  post-acquisition  retained  earnings  of  subsidiaries,  except  where  the  Group  controls 
the subsidiary’s dividend policy and it is probable that the difference will not reverse through dividends or otherwise in the 
foreseeable future.

Uncertain tax positions. The Group’s uncertain tax positions are reassessed by the management at the end of each reporting 
period. Liabilities are recorded for income tax positions that are determined by the management as more likely than not to 
result in additional taxes being levied if the positions were to be challenged by the tax authorities. The assessment is based on 
the interpretation of tax laws that have been enacted or substantively enacted by the end of reporting period and any known 
Court or other rulings on such issues. Liabilities for penalties, interest and taxes other than on income are recognised based 
on the management’s best estimate of the expenditure required to settle the obligations at the end of the reporting period. 

Provisions for liabilities and charges. Provisions for liabilities and charges are non-financial liabilities of uncertain timing 
or amount. They are accrued when the Group has a present legal or constructive obligation as a result of past events, 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. 

Share capital. Ordinary shares with discretionary dividends are classified as equity. Incremental costs directly attributable 
to the issue of new shares or options are shown in equity as a deduction, net of tax, from the proceeds. Any excess of the fair 
value of consideration received over the par value of shares issued is recorded as share premium in equity.

Dividends. Dividends are recorded in equity in the period in which they are declared. Any dividends declared after the end 
of  the  reporting  period  and  before  the  consolidated  financial  statements  are  authorised  for  issue,  are  disclosed  in  the 
subsequent events note. 

Income and expense recognition. Interest income and expense are recorded for all debt instruments, other than those at 
FVTPL, on an accrual basis using the effective interest method. As part of interest income or expense this method defers all 
fees paid or received between the parties to the contract that are an integral part of the effective interest rate, transaction 
costs and all other premiums or discounts. The group does not have Interest income on debt instruments at FVTPL.

Fees integral to the effective interest rate include origination fees received or paid by the entity relating to the creation or 
acquisition of a financial asset or issuance of a financial liability, for example fees for evaluating creditworthiness, evaluating 
and recording guarantees or collateral, negotiating the terms of the instrument and for processing transaction documents. 
Commitment fees received by the Group to originate loans at market interest rates are integral to the effective interest rate 
if it is probable that the Group will enter into a specific lending arrangement and does not expect to sell the resulting loan 
shortly after origination. The Group does not designate loan commitments as financial liabilities at FVTPL.

Interest income is calculated by applying the effective interest rate to the gross carrying amount of financial assets, except 
for (i) financial assets that have become credit impaired (Stage 3), for which interest income is calculated by applying the 

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effective interest rate to their AC, net of the ECL provision, and (ii) financial assets that are purchased or originated credit 
impaired, for which the original credit-adjusted effective interest rate is applied to the AC.

All other fees, commissions and other income and expense items are generally recorded on an accrual basis by reference 
to completion of the specific transaction assessed on the basis of the actual service provided as a proportion of the total 
services to be provided.

Fee and commission income. Fee and commission income is recognised over time on a straight line basis as the services 
are rendered, when the customer simultaneously receives and consumes the benefits provided by the Group’s performance. 
Such income includes recurring fees for recurring fees for account maintenance, account servicing fees, account subscription 
fees, annual plastic card fees etc. Variable fees are recognised only to the extent that management determines that it is 
highly probable that a significant reversal will not occur. 

Other fee and commission income is recognised at a point in time when the Group satisfies its performance obligation, 
usually upon execution of the underlying transaction. The amount of fee or commission received or receivable represents 
the transaction price for the services identified as distinct performance obligations. Such income includes fees for arranging 
a sale or purchase of foreign currencies on behalf of a customer, fees for processing payment transactions, plastic card 
transactions, merchant fees, fees for cash settlements, collection or cash disbursements, etc. 

Foreign currency translation. The Group’s presentation currency is the Georgian Lari. TBCG’s and the Bank’s functional 
currency is the Georgian Lari. The functional currency of each of the Group’s consolidated entities is the currency of the 
primary economic environment in which the entity operates. Transactions in foreign currencies are initially recorded in the 
functional currency, converted at the rate of exchange ruling at the date of the transaction. 

Monetary  assets  and  liabilities  are  translated  into  each  entity’s  functional  currency  at  the  official  exchange  rate  of  the 
territories  where  the  Bank  and  its  subsidiaries  operate,  at  the  respective  reporting  period.  Foreign  exchange  gains  and 
losses resulting from the settlement of transactions and from the translation of monetary assets and liabilities into each 
entity’s functional currency at year-end official exchange rates are recognised in profit or loss. Translation at year-end rates 
does not apply to non-monetary items, including equity investments. The effects of exchange rate changes on the fair value 
of equity securities are recorded as part of the fair value gain or loss. 

The  results  and  financial  position  of  each  group  entity  (the  functional  currency  of  none  of  which  is  a  currency  of  a 
hyperinflationary economy) are translated into the presentation currency as follows: 

(i)  Assets and liabilities for each statement of financial position presented are translated at the closing rate at the end of 

the respective reporting period; 

(ii) Income and expenses are translated at average exchange rates (unless this average is not a reasonable approximation of 
the cumulative effect of the rates prevailing on the transaction dates, in which case income and expenses are translated 
at the dates of the transactions); 

(iii) Components of equity are translated at the historic rate; and 

(iv) All resulting exchange differences are recognised in other comprehensive income. 

After losing control over a foreign operation, the exchange differences previously recognised in other comprehensive income 
are reclassified to profit or loss for the year as part of the gain or loss on disposal. On partial disposal of a subsidiary without 
loss of control, the related portion of accumulated currency translation differences is reclassified to non-controlling interest 
within equity.

Goodwill and fair value adjustments arising on the acquisition of a foreign entity are treated as assets and liabilities of the 
foreign entity and translated at the closing rate. At 31 December 2019 the closing rate of exchange used for translating 
foreign currency balances was GBP 1 = 3.7593 (2018: GBP 1 = GEL 3.3955; 2017: GBP 1 = GEL 3.5005); USD 1 = 2.8677 (2018: 
USD 1 = GEL 2.6766; 2017: USD 1 = GEL 2.5922); EUR 1 = 3.2095 (2018: EUR 1 = GEL 3.0701; 2017: EUR 1 = GEL 3.1044). 

Offsetting. Financial assets and liabilities are offset and the net amount reported in the consolidated statement of financial 
position only when there is a legally enforceable right to offset the recognised amounts, and there is an intention to either 
settle on a net basis, or to realise the asset and settle the liability simultaneously.

Staff costs and related contributions. Wages, salaries, paid annual leave and sick leave, bonuses, and non-monetary benefits 

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as well as the cash settled part of the share based payment schemes are accrued in the year in which the associated services 
are rendered by the Group’s employees. 

Earnings per share. Earnings per share (“EPS”) are determined by dividing the profit or loss attributable to owners of the 
Group by the weighted average number of participating shares outstanding during the reporting period. 

Diluted earnings per share. Diluted earnings per share is calculated by adjusting the weighted average number of ordinary 
shares outstanding to assume conversion of all dilutive potential ordinary shares. In calculating diluted EPS, non-vested 
ordinary shares are treated as outstanding on the grant date.

Segment reporting. Operating segments are reported in a manner consistent with the internal reporting provided to the 
Group’s  chief  operating  decision  maker.  Segments  whose  revenue,  result  or  assets  are  ten  percent  or  more  of  all  the 
segments are reported separately.

Share based payments.  A  share-based  payment  arrangement  is  an  agreement  between  the  entity  and  another  party 
(including an employee) that entitles the other party to receive cash or other assets of the entity for amounts that are based 
on the price (or value) of equity instruments (including shares or share options) of the entity or another group entity, or 
equity instruments (including shares or share options) of the entity or another group entity, provided the specified vesting 
conditions, if any, are met. Under the share-based compensation plan the Group receives services from the management as 
consideration for equity instruments of the Group. The fair value of the employee services received in exchange for the grant 
of the equity instruments is recognised as an expense. The total amount to be expensed is determined by the reference to 
the fair value of the equity instruments granted, excluding the impact of any non-market service and performance vesting 
conditions. Non-market vesting conditions are included in the assumptions about the number of equity instruments that are 
expected to vest. The total amount expensed is recognised over the vesting period, which is the period over which all of the 
specified vesting conditions are to be satisfied. At each balance sheet date, the Group revises its estimates of the number of 
equity instruments that are expected to vest based on the non-marketing vesting conditions. It recognises the impact of the 
revision of original estimates, if any, in profit or loss, with a corresponding adjustment to equity. Increase in equity on accrued 
shares resulting from the equity settled scheme is accounted for under share based payment reserve. Upon award of shares 
to the scheme participants, respective share based payment reserve is transferred to share capital and share premium. 
When portions of a single grant vest on two or more dates the entity applies graded vesting for accounting of share based 
payment arrangement. Vesting period of each tranche of the grant ends when the employee owns the shares with no further 
service restrictions. Under graded vesting scheme the expense for earlier years is higher than for later years. Each tranche 
is expensed over its own service period with a credit entry being equity.

Principles applied before 1 January 2018 (comparatives only)

Financial  instruments  –  key  measurement  terms  (comparatives  only).  Depending  on  their  classification  financial 
instruments are carried at fair value, cost, or amortised cost as described below.

Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between 
market participants at the measurement date. The best evidence of fair value is the price in an active market. An active 
market is one in which transactions for the asset or the liability take place with sufficient frequency and volume to provide 
pricing information on an ongoing basis. The fair value of financial instruments traded in an active market is measured as 
the product of the quoted price for the individual asset or liability and the quantity owned by the entity. This is the case even if 
a market’s normal daily trading volume is not sufficient to absorb the quantity held and placing orders to sell the position in 
a single transaction might affect the quoted price.

A portfolio of financial derivatives or other financial assets and liabilities that are not traded in an active market is measured 
at the fair value of a group of financial assets and financial liabilities on the basis of the price that would be received to sell 
a net long position (i.e. an asset) for a particular risk exposure or paid to transfer a net short position (i.e. a liability) for a 
particular risk exposure in an orderly transaction between market participants at the measurement date. This is applicable 
for assets carried at fair value on a recurring basis in case the Group: (a) manages the group of financial assets and financial 
liabilities on the basis of the entity’s net exposure to a particular market risk (or risks) or to the credit risk of a particular 
counterparty in accordance with the entity’s documented risk management or investment strategy; (b) it provides information 
on that basis about the group of assets and liabilities to the entity’s key management personnel; and (c) the market risks, 
including duration of the entity’s exposure to a particular market risk (or risks) arising from the financial assets and financial 
liabilities is substantially the same.

Valuation  techniques  such  as  discounted  cash  flow  models  or  models  based  on  recent  arm’s  length  transactions  or 

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consideration of financial data of the investees are used to measure the fair value of certain financial instruments for which 
external market pricing information is not available. Fair value measurements are analysed by level in the fair value hierarchy 
as follows: (i) level one are measurements at quoted prices (unadjusted) in active markets for identical assets or liabilities, (ii) 
level two measurements are valuations techniques with all material inputs observable for the asset or liability, either directly 
(that is, as prices) or indirectly (that is, derived from prices), and (iii) level three measurements are valuations not solely based 
on observable market data (that is, the measurement requires significant unobservable inputs). Transfers between levels of 
the fair value hierarchy are deemed to have occurred at the end of the reporting period. Refer to Note 42.

Cost is the amount of cash or cash equivalents paid or the fair value of the other consideration given to acquire an asset at 
the time of its acquisition and includes transaction costs. Measurement at cost is only applicable to investments in equity 
instruments that do not have a quoted market price and whose fair value cannot be reliably measured and derivatives that 
are linked to and must be settled by the delivery of such unquoted equity instruments. Refer to Note 41.

Transaction  costs  are  incremental  costs  that  are  directly  attributable  to  the  acquisition,  issue  or  disposal  of  a  financial 
instrument. An incremental cost is one that would not have incurred if the transaction had not taken place. Transaction costs 
include fees and commissions paid to agents (including employees acting as selling agents), advisors, brokers and dealers, 
levies by regulatory agencies and securities exchanges, and transfer taxes and duties. Transaction costs do not include debt 
premiums or discounts, financing costs or internal administrative or holding costs. 

Amortised  cost  is  the  amount  at  which  the  financial  instrument  was  recognised  at  initial  recognition  less  any  principal 
repayments, plus accrued interest, and for financial assets less any write-down for incurred impairment losses. Accrued 
interest  includes  the  amortisation  of  transaction  costs  deferred  at  initial  recognition  and  of  any  premium  or  discount  to 
maturity  amount  using  the  effective  interest  method.  Accrued  interest  income  and  accrued  interest  expense,  including 
both accrued coupon and amortised discount or premium (including fees deferred at origination, if any), are not presented 
separately and are included in the carrying values of related items in the consolidated statement of financial position.

The effective interest method is a method of allocating interest income or interest expense over the relevant period so as to 
achieve a constant periodic rate of interest (effective interest rate) on the carrying amount. The effective interest rate is the 
rate that exactly discounts estimated future cash payments or receipts (excluding future credit losses) through the expected 
life of the financial instrument or a shorter period, if appropriate, to the net carrying amount of the financial instrument. The 
effective interest rate discounts cash flows of variable interest instruments to the next interest repricing date, except for the 
premium or discount which reflects the credit spread over the floating rate specified in the instrument, or other variables 
that are not reset to market rates. Such premiums or discounts are amortised over the whole expected life of the instrument. 
The present value calculation includes all fees paid or received between parties to the contract that are an integral part of the 
effective interest rate (refer to income and expense recognition policy). 

Initial  recognition  of  financial  instruments  (comparatives  only).  Trading  securities,  derivatives  and  other  financial 
instruments at fair value through profit or loss are initially recorded at fair value. All other financial instruments are initially 
recorded at fair value plus the transaction costs. Fair value at initial recognition is best evidenced by the transaction price. 
A gain or a loss on initial recognition is only recorded if there is a difference between the fair value and the transaction price 
which can be evidenced by other observable current market transactions in the same instrument or by a valuation technique 
whose inputs include only data from observable markets.

All purchases and sales of financial assets that require delivery within the time frame set by regulation or market convention 
(“regular way” purchases and sales) are recorded at trade date, which is the date that the Group commits to deliver a financial 
asset. All other purchases are recognised when the entity becomes a party to the contractual provisions of the instrument. 

Cash and cash equivalents (comparatives only). Cash and cash equivalents are items which are readily convertible to known 
amounts of cash and are subject to an insignificant risk of changes in value. Cash and cash equivalents include cash on hand, 
amounts  due  from  the  National  Bank  of  Georgia  (NBG),  excluding  mandatory  reserves,  and  all  interbank  placements  and 
interbank  receivables  with  original  maturities  of  less  than  three  months.  Funds  restricted  for  a  period  of  more  than  three 
months on origination are excluded from cash and cash equivalents. Cash and cash equivalents are carried at amortised cost.

The  payments  or  receipts  presented  in  the  statement  of  cash  flows  represent  the  Group’s  transfers  of  cash  and  cash 
equivalents, including amounts charged or credited to current accounts of the Group’s counterparties held with the Group, 
such as loan interest income or principal collected by charging the customer’s current account or interest payments or 
disbursement  of  loans  credited  to  the  customer’s  current  account,  which  represent  cash  or  cash  equivalent  from  the 
customer’s perspective.

Investment securities available for sale (comparatives only). This classification includes investment securities which the 
Group intends to hold for an indefinite period of time and which may be sold in response to needs for liquidity or changes in 
interest rates, exchange rates or equity prices. The Group classifies investments as available for sale at the time of purchase.

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Investment  securities  available  for  sale  are  carried  at  fair  value.  Interest  income  on  available  for  sale  debt  securities  is 
calculated using the effective interest method and recognised in profit or loss for the year. Dividends on available-for-sale 
equity instruments are recognised in profit or loss for the year when the Group’s right to receive payment is established and 
it is probable that the dividends will be collected. All other elements of changes in the fair value are recognized in Other 
Comprehensive Income (“OCI”) until the investment is derecognised or impaired, at which time the cumulative gain or loss is 
reclassified from OCI to profit or loss. Impairment losses are recognised in profit or loss when incurred as a result of one or 
more events (“loss events”) arising after the initial recognition of investment securities available for sale.

A significant or prolonged decline in the fair value of an equity security below its cost is an indicator that it is impaired. The 
cumulative impairment loss – measured as the difference between the acquisition cost and the current fair value, less any 
impairment loss on that asset previously recognised in profit or loss – is removed from equity and reclassified from OCI. 
Impairment losses on equity instruments are not reversed through profit or loss. If, in a subsequent period, the fair value of 
a debt instrument classified as available for sale increases and the increase can be objectively related to an event occurring 
after the impairment loss was recognised in profit or loss, the impairment loss is reversed through the current period’s profit 
or loss for the year.

Sale and repurchase agreements (comparatives only).  Sale  and  repurchase  agreements  (“repo  agreements”),  which 
effectively provide a lender’s return to the counterparty, are treated as secured financing transactions. The lender provides 
funds to the borrower and receives security as collateral. Securities sold under such sale and repurchase agreements are not 
derecognized. The securities are not reclassified in the statement of financial position unless the transferee has, by contract, 
the right or custom to sell or repledge the securities, in which case they are reclassified as repurchase receivables. The 
corresponding liability is presented within amounts due to credit institutions. The repurchase agreements are short-term in 
nature. Available-for-sale securities or bonds carried at amortised cost reclassified to repurchase receivables continue to be 
carried at fair value or amortised cost respectively in accordance with the accounting policies for these categories of assets.

Securities purchased under agreements to resell (“reverse repo agreements”), which effectively provide a lender’s return 
to the Group, are recorded as due from other banks or loans and advances to customers, as appropriate. The difference 
between the sale and repurchase price is treated as interest income and accrued over the life of repo agreements using the 
effective interest rate method. 

Loans and advances to customers (comparatives only). Loans and advances to customers are recorded when the Group 
advances money to purchase or originate an unquoted non-derivative receivable from a customer due on fixed or determinable 
dates and has no intention of trading the receivable. Loans and advances to customers are carried at amortised cost.

When financial assets are renegotiated and the renegotiated terms and conditions differ substantially from the previous 
terms, financial asset is derecognized and the new asset is initially recognised at its fair value.

Bonds carried at amortised cost (comparatives only). Investment securities that the Group intends to hold for an indefinite 
period and that may be sold in response to needs for liquidity or changes in interest rates, exchange rates or equity prices 
have been classified as available for sale investments in the financial statements for the year ended 31 December 2014. In 
2015 the Group has reassessed its intention with regard to some of the securities under this category and has identified 
certain investments that the Group has both the intention and ability to hold to maturity. Due to the fact that transactions for 
such securities do not take place with sufficient frequency and volume to provide pricing information on an ongoing basis the 
securities are not considered to be quoted in an active market and were reclassified to loans and receivables rather than held 
to maturity investments. These securities are presented in the balance sheet under caption bonds carried at amortised cost.

When an available-for-sale financial asset with fixed maturity is reclassified to loans and receivables, the fair value of the 
financial asset on that date becomes its new amortised cost. Any previous gain or loss on that asset that has been recognised 
directly in other comprehensive income is amortised to profit and loss over the investment’s remaining life using the effective 
interest method.

Impairment of financial assets carried at amortised cost (comparatives only). Impairment losses are recognised in profit or 
loss when incurred as a result of one or more events (“loss events”) that happened after the initial recognition of the financial 
asset and which have an impact on the amount or timing of the estimated future cash flows of the financial asset or group of 
financial assets that can be reliably estimated. The Group classifies its borrowers as significant and non-significant ones for 
impairment allowance estimation purposes and assesses for impairment individually or collectively. 

Specific qualitative and quantitative events are outlined for evidence of impairment of individually and collectively assessed 
borrowers in order to ensure that loss event is identified as early as possible. 

If there is evidence that an impairment loss event on significant credit exposures has been incurred, the Bank assesses 
the borrowers on an individual basis and measures the amount of the loss as the difference between the asset’s carrying 

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amount and the present value of estimated future cash flows discounted by the exposure’s original effective interest rate 
for fixed rate loans or current effective interest rate for variable rate loans. The Bank considers two types of sources for 
recoveries: cash recoveries and/or collateral recovery. For cash recoveries the estimated recoverable amount is equal to the 
present value of the estimated future cash flows. Collateral recoveries reflect the cash flows that may result from collateral 
foreclosure. The Bank uses its best estimates to assess future recoveries, applying scenario analysis and taking into account 
all relevant information available at the reporting date including adverse changes in general macroeconomic environment or 
the industry the borrower operates in. 

If the Group determines that there is no objective evidence that an individually assessed financial asset incurred in impairment 
whether significant or not, it includes the asset in a group of financial assets with similar credit risk characteristics and 
collectively assesses them for impairment. For collective assessment purposes exposures are grouped into a homogenous 
risk pools based on similar credit risk characteristics. Common credit risk characteristics of the group include but are not 
limited to: type of counterparty (individual vs. business), type of product, past-due status of the exposure, restructuring status 
and type of collateral. 

In  order  to  calculate  impairment  allowance  for  collectively  assessed  loans  pools,  the  Bank  estimates  the  following  risk 
parameters: probability of default, cure rate, recovery rate, survival rate and loss give default, based on historical experience. 
In case of a change in either the internal or external environment and historical data no longer reflect the current situation, 
the Bank adjusts risk parameters on the basis of current observable data to reflect the effects of present conditions that did 
not affect past periods, and to remove the effects of past conditions that do no longer exist. 

If the terms of an impaired financial asset held at amortised cost are renegotiated or otherwise modified because of financial 
difficulties of the borrower or issuer, impairment is measured using the original effective interest rate before the modification 
of terms.

The Bank reverses previously recognised impairment loss if, once identified, the amount of the impairment loss decreases 
and the decrease is related to an objective event. The previously recognised impairment loss is reversed by adjusting the 
allowance account through profit or loss. In order to reverse provisions for individually significant borrowers there should be 
objective evidence that the borrowers’ financial standing has improved or there is improvement in collateral coverage. For 
collectively assessed loans the Bank applies the notion of “quarantine period” defined as period necessary for an exposure 
to satisfy performing loans criteria’s in order to be reclassified in a performing loans pool.  

Impairment losses on loans and advances and net investments in lease (comparatives only). The Group regularly reviews 
its loan portfolio and net investments in lease to assess impairment. In determining whether an impairment loss should 
be recorded in the statement of profit or loss and other comprehensive income, the Group conclude whether there is, or 
not, any observable data indicating a measurable decrease in the estimated future cash flows from a portfolio of loans or 
net investments in lease before the decrease can be identified with an individual loan in that portfolio.  This evidence may 
include observable data indicating that there has been an adverse change in the payment status of borrowers in a group, or 
national or local economic conditions that correlate with defaults on assets in the group. When scheduling future cash flows 
the management uses estimates based on historical loss experience for assets with similar credit risk characteristics. The 
methodology and assumptions used for estimating both the amount and timing of future cash flows are reviewed regularly 
to reduce any differences between loss estimates and actual loss experience. A 5% increase or decrease between actual 
loss experience and the loss estimates used would result in an additional or lower charge for loan loss impairment of GEL 
11 thousand as at 31 December 2017 and additional charge for impairment of net investments in lease of GEL 63 thousand, 
respectively.

Impairment provisions for individually significant loans and leases are based on the estimate of discounted future cash flows 
of the individual loans and leases taking into account repayments and realisation of any assets held as collateral against 
the loan or the lease. A 5% increase or decrease in the actual future discounted cash flows from individually significant 
loans which could arise from a mixture of differences in amounts and timing of the cash flows will result in an additional 
or lower charge for loan loss provision of GEL GEL14 thousand as at 31 December 2017, respectively. A 5% increase or 
decrease in the actual future discounted cash flows from individually significant leases which could arise from a mixture 
of differences in amounts and timing of the cash flows will result in an additional or lower charge for provision of GEL 14 
thousand, respectively.

Credit related commitments (comparatives only). The  Group  enters  into  credit  related  commitments,  including  letters  of 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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AUDIT COMMITTEE REPORT CONTINUED

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES CONTINUED

credit and financial guarantees. Financial guarantees represent irrevocable assurances to make payments in the event that 
a customer cannot meet its obligations to third parties and carry the same credit risk as loans. Financial guarantees and 
commitments to provide a loan are initially recognised at their fair value, which is normally evidenced by the amount of fees 
received. This amount is amortised on a straight line basis over the life of the commitments, except for those to originate loans 
if it is probable that the Group will enter into a specific lending arrangement and does not expect to sell the resulting loan shortly 
after origination; Such loan commitment fees are deferred and included in the carrying value of the loan on initial recognition. At 
the end of each reporting period, the commitments are measured at the higher of (i) the unamortised balance of the amount at 
initial recognition and (ii) the best estimate of expenditure required to settle the commitment at the end of each reporting period.

Net investments in lease (comparatives only). Where the Group is a lessor in a lease that substantially transfers all risks and 
rewards incidental to ownership to the lessee, the assets leased out are presented as net investments in lease and carried 
at the present value of the future lease payments. Net investments in lease are initially recognised at commencement (when 
the lease term begins) using a discount rate determined at inception (the early date of the lease agreement and the date of 
commitment by the parties to the principal provisions of the lease).

The difference between the gross receivable and the present value represents unearned finance income. This income is 
recognised over the term of the lease using the net investment method (before tax), which reflects a constant periodic rate of 
return. Incremental costs directly attributable to negotiating and arranging the lease are included in the initial measurement 
of the Net investments in lease and reduce the amount of income recognised over the lease term. Finance income from 
leases is recorded within interest income in the profit or loss.

Impairment losses are recognised in profit or loss when incurred as a result of one or more events (“loss events”) that took 
place after the initial recognition of investments in leases. The Group uses the same principal criteria to determine that there 
is objective evidence that an impairment loss has occurred as for loans carried at amortised costs disclosed earlier in this 
note. Impairment losses are recognised through an allowance account to write down the receivables’ net carrying amount to 
the present value of expected cash flows (which exclude future credit losses that have not been incurred) discounted at the 
interest rates implicit in the lease investment. The estimated future cash flows reflect the cash flows that may result from 
obtaining and selling the assets subject to the lease.

3.CRITICAL ACCOUNTING ESTIMATES AND JUDGEMENTS IN APPLYING ACCOUNTING POLICIES
The Group makes estimates and assumptions that affect the reported amounts of assets and liabilities within the next financial 
year. Estimates and judgements are continually evaluated and are based on the management’s experience and other factors, 
including  expectations  of  future  events  that  are  believed  to  be  reasonable  under  the  circumstances.  The  management 
also makes certain judgements, apart from those involving estimations, in the process of applying the accounting policies. 
Judgements that have the most significant effect on the amounts recognised in the consolidated financial statements and 
estimates that can cause a significant adjustment to the carrying amount of assets and liabilities within the next financial 
year include:

ECL measurement. Measurement of ECLs is a significant estimate that involves forecasting future economic conditions, 
longer the term of forecasts more management judgment is applied and those judgements may be the source of uncertainty. 
Details of ECL measurement methodology are disclosed  in Note 37.  The following components have a major  impact on 
credit loss allowance: definition of default, definition of significant increase in credit risk (SICR), probability of default (“PD”), 
exposure at default (“EAD”), and loss given default (“LGD”), as well as models of macro-economic scenarios. The Group 
regularly reviews and validates the models and inputs to the models to reduce any differences between expected credit loss 
estimates and actual credit loss experience. 

Significant increase in credit risk (“SICR”). The Bank applies both qualitative and quantitative indicators to determination of 
SICR considering all reasonable and supportable information available without undue cost and effort, on past events, current 
conditions and future behavioural aspects of particular portfolios. The Bank tries to identify indicators of increase in credit 
risk of individual instruments prior to delinquency and incorporates significant assumptions in the model in doing so. One of 
such judgement is determination of thresholds of significant increase in credit risk. The effects of respective sensitivity are 
described below: 

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3. CRITICAL ACCOUNTING ESTIMATES AND JUDGEMENTS IN APPLYING ACCOUNTING POLICIES
CONTINUED

In thousands of GEL

2019

2018

20% decrease in SICR thresholds

10% increase in Stage 2 exposures

Increase impairment allowance on loans 
and advances by GEL 1,954
Change of the Bank’s cost of credit risk 
ratio by 2 basis points

Increase impairment allowance on loans 
and advances by GEL 2,380

Increase impairment allowance on loans 
and advances by GEL 2,056
Change of the Bank’s cost of credit risk 
ratio by 2 basis points
Increase impairment allowance on loans and 
advances by GEL 2,723

Change of the Bank’s cost of credit risk 
ratio by 2 basis points

Change of the Bank’s cost of credit risk ratio by 3 
basis points

Risk parameters: Probability of default (PD) and Loss given default (LGD) parameters are one of the key drivers of expected 
credit losses. The effects of respective sensitivity are described below

In thousands of GEL

2019

2018

10% increase (decrease) in PD estimates

10% increase (decrease) in LGD estimates

Increase (decrease) 
impairment allowance on loans and 
advances by GEL 17,427 (GEL 17,547)
Change of the Bank’s cost of credit risk 
ratio by 16 (16) basis points
Increase (decrease) impairment 
allowance on loans and advances by GEL 
24,758 (GEL 26,604)
Change of the Bank’s cost of credit risk 
ratio by 22 (24) basis points

Increase (decrease) impairment allowance
on loans and advances by GEL 18,876
(GEL 18,942) Change of the Bank’s cost
of credit risk ratio by 21 (21) basis points

Increase (decrease) impairment allowance on
loans and advances by GEL 28,185
 (GEL 28,012)Change of the Bank’s cost of 
creditrisk ratio by 31 (31) basis points

4. ADOPTION OF NEW OR REVISED STANDARDS AND INTERPRETATIONS
Adoption of IFRS 16, Leases. IFRS 16 replaces IAS 17 Leases for annual periods beginning on or after 1 January 2019. The 
group has adopted IFRS 16 using modified retrospective method from 1 January 2019 with certain simplifications, and has 
not restated comparatives for the previous reporting periods, as permitted under the specific transitional provisions in the 
standard (modified retrospective approach). The reclassifications and the adjustments arising from the new leasing rules 
are therefore recognised in the opening balance sheet on 1 January 2019. The comparative information for 2018 and 2017 is 
reported under IAS 17 and is not comparable to the information presented for 2019. 

On  adoption  of  IFRS  16,  the  group  recognised  lease  liabilities  in  relation  to  leases  which  had  previously  been  classified 
as ‘operating leases’ under the principles of IAS 17 Leases. These liabilities were measured at the present value of the 
remaining lease payments, discounted using the lessee’s incremental borrowing rates as of 1 January 2019 which were 
applied on a portfolio basis of leases with reasonably similar characteristics. 

The average incremental borrowing rates applied to the lease liabilities on 1 January 2019 was 3.77% for USD denominated 
contracts and 9.19% for GEL denominated contracts. 

In applying IFRS 16 for the first time, the group has used the following practical expedients permitted by the standard:

 ` the use of a single discount rate to a portfolio of leases with reasonably similar characteristics;
 ` the accounting for operating leases with a remaining lease term of less than 12 months as at 1 January 2019 as short-term leases.
 ` excluding initial direct costs for the measurement of the right-of-use asset at the date of initial application, and
 ` using hindsight in determining the lease term where the contract contains options to extend or terminate the lease.

The Group has also elected not to reassess whether a contract is, or contains a lease at the date of initial application. Instead, 
for contracts entered into before the transition date the group relied on its assessment made applying IAS 17, Leases, and 
IFRIC 4, in determining whether an arrangement contains a Lease.

The  Group  did  not  have  finance  leases  balances  outstanding  as  at  31  December  2018.  TBCG  has  made  no  adjustments 
where the Group acts as lessor, in either a finance or operating lease, of physical assets it owns. Where TBCG acts as an 
intermediate lessor, i.e., enters into a head lease and subleases the asset to a third party, the sublease has been classified as 
either a finance or operating lease based primarily on whether the sublease term consumes the majority of the remaining 
useful life of the right-of-use asset arising from the head lease as at the transition date. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

4. ADOPTION OF NEW OR REVISED STANDARDS AND INTERPRETATIONS CONTINUED

The following table reconciles the commitments in respect of operating leases as at 31 December 2018 to the opening lease 
liabilities recognized on 1 January 2019:

In thousands of GEL
Total future minimum lease payments for non-cancellable* operating leases disclosed as at 31 December 2018.

1 January 2019
11,022

- Future lease payments that are due in periods subject to lease extension options that are reasonably certain to be exercised

- Effect of discounting to present value
-Less short-term leases not recognised as a liability
- Less low-value leases not recognised as a liability
Total effect on the Lease Liability as at 1 January 2019

Of which are:

- Current lease liabilities

- Non-current lease liabilities

58,573

(1,744)
(575
(6,233)
61,043

11,467

49,576

*   Non-cancellable leases include those cancellable only: (a) upon the occurrence of some remote contingency, (b) with the permission of the lessor, (c) if the lessee enters into a 
new lease for the same or an equivalent asset with the same lessor; or (d) upon payment by the lessee of such an additional amount that, at inception of the lease, continuation 
of the lease is reasonably certain.

The right-of use assets were measured at the amount equal to the lease liability. There were no onerous lease contracts that 
would have required an adjustment to the right-of-use assets at the date of initial application. The recognised right-of-use 
assets mostly relate to properties for own use, in particular branches and office buildings.

The change in accounting policy affected the following items in the balance sheet on 1 January 2019: 

 ` right-of-use assets – increase by GEL 61,043 thousand;
 ` lease liabilities – increase by GEL 61,043 thousand.

The net impact on retained earnings on 1 January 2019 was nil. 

IFRS 16 subsequent recognition and policies 

As at 31 December 2019, the balances of Right of the use asset and the Lease liability are GEL 59,693 thousand and GEL 
59,898 thousand respectively. The interest charge on lease liabilities presented within interest expense amounted GEL 2,670 
thousand, recognized within interest expense. During 2019, the weighted average lease term was approximately 5 years and 
depreciation expense of right-of-use assets amounted GEL 13,311 thousand. 

TBCG predominantly enters into lease contracts, or contracts that include lease components, as a lessee of real estate, 
including offices, retail branches and service centers. TBCG identifies non-lease components of a contract and accounts for 
them separately from lease components.

When TBCG is lessee in a lease arrangement, TBCG recognizes a lease liability and corresponding right-of-use (RoU) asset 
at the commencement of the lease term when TBCG acquires control of the physical use of the asset. The lease liability is 
measured based on the present value of the lease payments over the lease term, discounted using TBCG’s incremental 
borrowing rate. Interest expense on the lease liability is presented within Interest expense from financial instruments. The 
RoU asset is recorded at an amount equal to the lease liability but is adjusted for rent prepayments, initial direct costs, any 
costs to refurbish the leased asset or lease incentives received. The RoU asset is depreciated over the shorter of the lease 
term or the useful life of the underlying asset, with the depreciation presented within depreciation expense in statement of 
comprehensive income.

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4. ADOPTION OF NEW OR REVISED STANDARDS AND INTERPRETATIONS CONTINUED

Lease payments generally include fixed payments. When the lease contains an extension or termination option that the 
Group considers reasonably certain to be exercised, the expected rental payments or costs of termination are included within 
the lease payments used to generate the lease liability. TBCG does not typically enter into leases with purchase options or 
residual value guarantees.

Where TBCG acts as lessor or sublessor under a finance lease, a receivable is recognized and measured at amortized cost 
at an amount equal to the present value of the aggregate of the lease payments plus any unguaranteed residual value that 
TBCG expects to recover at the end of the lease term.

Initial direct costs are also included in the initial measurement of the lease receivable. Lease payments received during the 
lease term are allocated as repayments of the outstanding receivable.

Interest income reflects a constant periodic rate of return on TBCG’s net investment using the interest rate implicit in the 
lease (or, for subleases, the rate for the head lease). TBCG reviews the estimated unguaranteed residual value annually, and 
if the estimated residual value to be realized is less than the amount assumed at lease inception, a loss is recognized for the 
expected shortfall. Where TBCG acts as a lessor or sublessor in an operating lease of owned real estate, TBCG recognizes 
the operating lease income on a straight-line basis over the lease term.

From 1 January 2019, leases are recognised as a right-of-use asset and a corresponding liability at the date at which the 
leased asset is available for use by the group. Each lease payment is allocated between the liability and interest expense. The 
interest expense is charged to profit or loss over the lease period so as to produce a constant periodic rate of interest on the 
remaining balance of the liability for each period. The right-of-use asset is depreciated over the shorter of the asset’s useful 
life and the lease term on a straight-line basis. 

Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities include the net 
present value of the following lease payments:

 ` fixed payments (including in-substance fixed payments), less any lease incentives receivable;
 ` variable lease payment that are based on an index or a rate;
 ` amounts expected to be payable by the lessee under residual value guarantees;
 ` the exercise price of a purchase option if the lessee is reasonably certain to exercise that option, and
 ` payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.

The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be determined, the lessee’s 
incremental borrowing rate is used, being the rate that the lessee would have to pay to borrow the funds necessary to obtain 
an asset of similar value in a similar economic environment with similar terms and conditions. 

Right-of-use assets are measured at cost comprising the following at initial recognition:
 ` the amount of the initial measurement of lease liability;
 ` any lease payments made at or before the commencement date less any lease incentives received;
 ` any initial direct costs, and
 ` restoration costs.

Payments associated with short-term leases and leases of low-value assets are recognised on a straight-line basis as an 
expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less. Low-value assets comprise 
IT-equipment and small items of office furniture or the items below the market value of around GEL 15,000.

Extension and termination options 
Extension and termination options are included in a number of property and equipment leases across the group. These 
terms are used to maximize operational flexibility in terms of managing contracts. The majority of extension and termination 
options held are exercisable only by the group and not by the respective lessor. 

Judgements in determining the lease term 
In determining the lease term, management considers all facts and circumstances that create an economic incentive to 
exercise an extension option, or not exercise a termination option. Extension options (or periods after termination options) 
are only included in the lease term if the lease is reasonably certain to be extended (or not terminated). The assessment 
is reviewed if a significant event or a significant change in circumstances occurs which affects this assessment and that is 
within the control of the lessee.

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227

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

4. ADOPTION OF NEW OR REVISED STANDARDS AND INTERPRETATIONS CONTINUED

The  Group  also  determines  non-cancellable  lease  period  for  leases,  taking  into  consideration  penalties  that  would  be 
incurred  upon  termination,  including  economic  disincentives  such  as  leasehold  improvements,  cost  of  relocating  or  the 
importance of the premises to the Group’s operations.

As  for  the  adoption  date  management  has  reassessed  expected  lease  terms  for  the  branch  offices.  The  assessment 
was performed by retail sales department taking into account a few criteria, namely: location, profitability and strategic 
importance of the branch offices. Based on the analysis performed, management identified and recorded expected terms for 
the lease contracts, subject to lease extension options that are reasonably certain to be exercised. As at 31 December 2019, 
the Group has reassessed expected terms for existing lease contracts in line with standard requirements.

Adoption of other IFRS.
The following amended standards became effective from 1 January 2019, but did not have any material impact on the Group: 

 `

 `

 `

 `

 `

 `

IFRIC 23 “Uncertainty over Income Tax Treatments” (issued on 7 June 2017 and effective for annual periods beginning 
on or after 1 January 2019). 
Prepayment Features with Negative Compensation – Amendments to IFRS 9 (issued on 12 October 2017 and effective 
for annual periods beginning on or after 1 January 2019). 
Amendments to IAS 28 “Long-term Interests in Associates and Joint Ventures” (issued on 12 October 2017 and effective 
for annual periods beginning on or after 1 January 2019). 
Annual Improvements to IFRSs 2015-2017 cycle - amendments to IFRS 3, IFRS 11, IAS 12 and IAS 23 (issued on 12 
December 2017 and effective for annual periods beginning on or after 1 January 2019).
Amendments to IAS 19 “Plan Amendment, Curtailment or Settlement” (issued on 7 February 2018 and effective for 
annual periods beginning on or after 1 January 2019).
Amendment to IAS 12, Income Taxes, included in the Annual Improvements to IFRSs 2015-2017 cycle.

5. NEW ACCOUNTING PRONOUNCEMENTS
Minor amendments to IFRSs
The  IASB  has  published  a  number  of  minor  amendments  some  of  which  has  not  yet  been  endorsed  for  use  in  the  EU. 
The Group has not early adopted any of the amendments effective after 31 December 2019 and it expects they will have 
an  insignificant  effect,  when  adopted,  on  the  consolidated  financial  statements  of  the  Group  and  the  separate  financial 
statements of TBC Bank Group PLC. 

Major new IFRSs
IFRS 17 “Insurance Contracts” (issued on 18 May 2017 and effective for annual periods beginning on or after 1 January 
2021). IFRS 17 replaces IFRS 4, which has given companies dispensation to carry on accounting for insurance contracts 
using existing practices. As a consequence, it was difficult for investors to compare and contrast the financial performance 
of otherwise similar insurance companies. IFRS 17 is a single principle-based standard to account for all types of insurance 
contracts, including reinsurance contracts that an insurer holds. The standard requires recognition and measurement of 
groups of insurance contracts at: (i) a risk-adjusted present value of the future cash flows (the fulfilment cash flows) that 
incorporates all of the available information about the fulfilment cash flows in a way that is consistent with observable market 
information; plus (if this value is a liability) or minus (if this value is an asset) (ii) an amount representing the unearned profit 
in the group of contracts (the contractual service margin). Insurers will be recognising the profit from a group of insurance 
contracts over the period they provide insurance coverage, and as they are released from risk. If a group of contracts is or 
becomes loss-making, an entity will be recognising the loss immediately The Group is currently assessing the impact of the 
interpretation on its financial statements. 

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

6. CASH AND CASH EQUIVALENTS

In thousands of GEL
Cash on hand
Cash balances with the National Bank of Georgia (other than mandatory reserve deposits)
Correspondent accounts and overnight placements with other banks
Placements with and receivables from other banks with original maturities of less than three 
months
Total gross amount of cash and cash equivalents
Less: Credit loss allowance
Total carrying amount of cash and cash equivalents

2019 
650,700
35,133
191,420

2018
491,928
118,749
371,902

2017
419,605
371,342
571,078

126,360
1,003,613
(29)
1,003,584

184,429
1,167,008
(97)
1,166,911

69,452
1,431,477
-
1,431,477

85% of the correspondent accounts and overnight placements with other banks are placed with OECD (The Organization for 
Economic Co-operation and Development) banking institutions (31 December 2018: 95%; 31 December 2017: 97%).
As of 31 December 2019 GEL 11,348 thousand was placed on interbank term deposits with one non-OECD bank and GEL 
115,012 thousand with one OECD banks (31 December 2018: GEL 13,383 thousand with one non-OECD bank and GEL 171,046 
thousand with two OECD bank; 31 December 2017: GEL 12,421 thousand with one non-OECD bank and GEL 57,031 thousand 
with one OECD bank). Interest rate analysis of cash and cash equivalents is disclosed in Note 37.

The credit-rating of correspondent accounts and overnight placements with other banks is as follows:

In thousands of GEL
AA
A+ 
A
A-
BBB+
BBB
BBB-
BB+
BB
BB-
B+
B
Not rated 

Total

2019
-
66,805
13,816
-
20,286
69,302
-
733
3,680
12,346
4,452
-
-

191,420

2018
5,883
249,802
4,628
-
93,450
-
873
241
208
16,394
381
42
-

371,902

2017
-
271,366
62,434
213,247
3,235
383
45
300
224
15,919
442
185
3,298

571,078

The credit rating of placements with and receivables from other banks with original maturities of less than three months 
stands as follows: 

In thousands of GEL
AAA 
A
A-
BBB+
BB
B+
Not rated 

Total

2019 
-
-
115,012
-
1,719
9,629
-

126,360

2018
10,021
-
161,025
-
-
13,383
-

184,429

2017
-
-
-
57,031
-
-
12,421

69,452

The table illustrates the ratings by international agencies Standard & Poor’s and Fitch Ratings. When different credit ratings are 
designated by the agencies, the highest designated rating for this asset is used, after introduction of IFRS 9, as of January 2018, 
for those financial institutions which are not assigned credit ratings country ratings are used.  As of 31 December 2019 there 
were no investment securities held as collateral against placements with other banks under the reverse repo agreements (31 
December 2018: nil; 2017: nil). For the purpose of ECL measurement cash and cash equivalents balances are included in Stage 
1. As the ECL for 31 December 2018 is measured per IFRS 9, it is not comparable to the prior periods. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

229

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

7. DUE FROM OTHER BANKS
Amounts  due  from  other  banks  include  placements  with  original  maturities  of  more  than  three  months  that  are  not 
collateralised and represent neither past due nor impaired amounts at the end of 2019, 2018 and 2017. Credit ratings of 
placements with other banks with original maturities of more than three months were as follows:

In thousands of GEL
AA
A+
A
BBB+
BBB
BB+
BB
BB-
B+
B
Not rated 

Total

2019
-
9,549
-
-
2,493
-
9,045
5,323
7,195
-
-

33,605

2018
8,913
-
-
80
3,838
4,388
-
26,238
3,194
665
-

47,316

2017
-
-
8,632
78
-
-
-
4,041
661
1,520
24,711

39,643

As of 31 December 2019 the TBC Bank had no placements, with original maturities of more than three months and with 
aggregated amounts above GEL 5,000 thousand (2018: one placement with one bank; 2017: one placement with one bank). 
The total aggregated amount of these placement was nil (2018: GEL 19,311 thousand; 2017: 23,147 thousand) or 40.8% of the 
total amount due from other (2018: 41%; 2017: 58%). 

As  of  31  December  2019  GEL  11,836  thousand,  (2018:  GEL  15,725  thousand;  2017:  GEL  13,121  thousand)  were  kept  on 
deposits as restricted cash under an arrangement with a credit card company or credit card related services with other 
banks. Refer to Note 42 for the estimated fair value of amounts due from other banks. Interest rate analysis of due from other 
banks is disclosed in Note 37. As the ECL for year 2018 is measured per IFRS 9, it is not comparable to the prior periods.

For the purpose of ECL measurement due from other banks balances are included in Stage 1. The ECL for these balances as 
at 31 December 2019 is GEL 9 thousand (31 December 2018: GEL 39 thousand).

8. MANDATORY CASH BALANCES WITH THE NATIONAL BANK OF GEORGIA
Mandatory cash balances with the National Bank of Georgia (“NBG”) represent amounts deposited with the NBG. Resident 
financial institutions are required to maintain an interest-earning obligatory reserve with the NBG, the amount of which 
depends on the level of funds attracted by the financial institutions. The Group earned up to 9.0%, 1.25% and (0.7%) annual 
interest in GEL, USD and EUR respectively on mandatory reserve with NBG in 2019 (2018: 6.0%, 0.8% and (0.6%) in GEL, USD 
and EUR respectively; 2017: 5.0%, 0.6% and (0.4%) in GEL, USD and EUR respectively). 

In February 2019 Fitch Ratings has upgraded Georgia’s Long-Term Foreign and Local-Currency Issuer Default Ratings (IDRs) 
to ‘BB’ from ‘BB-’. The outlook is a stable. The issue ratings on Georgia’s long-term senior unsecured foreign and local-
currency bonds are also upgraded to ‘BB’ from ‘BB-’. The Country Ceiling is upgraded to ‘BBB-’ from ‘BB’ and the Short-
term Foreign and Local-Currency IDRs affirmed at ‘B’.

9. LOANS AND ADVANCES TO CUSTOMERS

In thousands of GEL
Corporate loans
Consumer loans
Mortgage loans
Loans to micro, small and medium enterprises
Total gross loans and advances to customers at AC
Less: credit loss allowance

2019
4,660,473
 1,884,006 
 3,169,197 
 2,948,279 
12,661,955
(312,556)

2018
3,177,289
1,989,516
2,709,183
2,496,594
10,372,582
(334,130)

Total carrying amount of loans and advances to customers at AC

12,349,399

10,038,452

2017
2,475,392
2,163,425
2,069,728
1,844,672
8,553,217
(227,864)

8,325,353

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TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

The credit loss allowance as at 31 December 2019 and 31 December 2018 is reported under IFRS 9 and is not comparable to 
the information presented for 2017.

As of 31 December 2019 loans and advances to customers carried at GEL 474,480 thousand have been pledged to local banks 
or other financial institutions as collateral with respect to other borrowed funds (2018: GEL 228,454 thousand; 2017: GEL 
246,267 thousand).

In 2019, the Group has reassessed its definition of segments as disclosed in Note 29. Some of the clients were reallocated to 
different segments. Comparative information as of 31 December 2018 has not been updated due to impracticability. 

The following tables disclose the changes in the credit loss allowance and gross carrying amount for loans and advances to 
customers carried at amortised cost between the beginning and the end of the reporting period. Below main movements in 
the table are described:

 `

 `

 `

 `
 `

 `

 `

Transfers between Stage 1, 2 and 3 due to balances experiencing significant increases (or decreases) of credit risk or 
becoming credit-impaired in the period, and the consequent “step up” (or “step down”) between 12-month and Lifetime 
ECL. It should be noted, that

 - Movement does not include exposures which were issued and repaid during the period;
 - For loans, which existed at the beginning of the period, opening exposures are disclosed as transfer amounts;
 - For newly issued loans, starting exposures are disclosed as transfer amount
 - For the exposures which changed stage several times during the period, transfers between starting and ending 

stage is disclosed.

New originated or purchased gives us information regarding gross loans and corresponding credit impairment losses 
issued during the period (however, exposures which were issued and repaid during the period and issued to refinance 
existing loans are excluded);
The line, derecognised during the period refers to starting balance of loans which were repaid or written-off during the 
period (gross exposure and corresponding credit impairment losses, however, exposures which were issued and repaid 
during the period and repaid by newly issued refinancing loans are excluded);
Net repayments refers to net changes in gross carrying amounts, consisting of withdrawal of loan and repayment;
Net write offs refer to write off of loans during the period, and net of written off and recoveries of already written off 
loans for ECL
Foreign exchange translations of assets denominated in foreign currencies and effect to translation in presentational 
currency for foreign subsidiary.
Net remeasurement due to stage transfers and risk parameters changes refers to the movements in ECL as a result of 
transfer of exposure between stages or changes in risk parameters and forward looking expectations. 

For presentation purposes, amounts are rounded to the nearest thousands of GEL, which in certain cases is disclosed as nil.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

231

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Corporate loans

Gross carrying amount

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

In thousands of GEL

Credit loss allowance

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Total

Total

At 1 January 2019

2,903,313

138,715

135,261 3,177,289

32,940

4,994

43,571

81,505

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 
to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

Net repayments

Resegmentation

Net Write-offs
Net remeasurement 
due to stage transfers 
and risk parameters 
changes
Foreign exchange  
movements

(126,154)

137,126

(10,972)

(27,531)

(5,261)

32,792

 72,484

(71,151)

(1,333)

-

-

 -

(2,876)

5,184

(2,308)

(2,914)

 (192)

3,106

 2,806

(2,806)

 -

-

-

-

-

25,355

1,638,709

-

- 1,638,709

25,355

-

1,988

(31,192)

(13,862)

(43,066)

(2,544)

(1,064)

(9,094)

(12,702)

(186,958)

(70,285)

(27,812)

(285,055)

55,356

711

-

-

-

-

-

-

-

56,067

-

-

-

176

-

-

76

-

-

-

630

-

252

630

(14,698)

(4,398)

991

(18,105)

3,815

80,750

103,478

5,746

7,305

116,529

908

175

2,732

At 31 December 2019

4,434,685

104,409

121,379 4,660,473

39,153

1,969

39,628

232

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Corporate loans

Gross carrying amount

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

In thousands of GEL

Credit loss allowance

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Total

Total

At 1 January 2018

 2,041,538 

 325,919 

 107,935 

 2,475,392 

21,208

15,036

31,719

67,963

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 
to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

Net repayments

Other movements

Resegmentation

Net Write-offs
Net remeasurement 
due to stage transfers 
and risk parameters 
changes
Foreign exchange  
movements

 (93,957)

 100,702 

 (6,745)

 (3,395)

 (85,409)

 88,804 

 129,019 

 (126,886)

 (2,133)

-

-

-

 (1,811)

 2,185 

 (374)

 (32)

 (8,341)

 8,373 

 3,908 

 (3,908)

 -   

 -   

-

-

-

 22,031 

 1,787,999 

 -   

 -   

 1,787,999 

 22,031 

 -   

 (873,776)

 (53,958)

 (14,720)

 (942,454)

 (9,217)

 (3,140)

 (21,293)

 (33,650)

 (145,691)
 2 

 36,699 

 -   

 - 

 (25,028)
-

 (39,857)
- 

 (210,576)
 2 

 488 

 -   

- 

 37,187 

 (321)

 (321)

 - 
 - 

 283 

 -   

 - 
 - 

- 

 -   

 - 
 - 

 -   

 -   

 -   

 283 

 3,269 

 3,269 

 - 

 - 

 -   

 (3,430)

 3,162 

 21,877 

 21,609 

 24,875 

 2,887 

 2,298 

 30,060 

-

-

-

-

At 31 December 2018

2,903,313

138,715

135,261

 3,177,289 

 32,940 

 4,994 

 43,571 

 81,505 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

233

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Loans to micro, small and 
medium enterprises

In thousands of GEL

Gross carrying amount

Credit loss allowance

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Total

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Total

At 1 January 2019

2,210,617

193,157

92,820

2,496,594

19,273

22,379

29,362

71,014

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 to 
Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

(181,576)

186,581

(5,005)

(51,354)

(42,338)

93,692

49,093

(48,292)

(801)

-

-

-

(3,097)

5,142

(2,045)

(2,568)

(6,711)

9,279

6,191

(5,872)

(319)

-

-

-

1,312,100

-

-

1,312,100

11,981

-

-

11,981

(354,274)

(47,777)

(48,874)

(450,925)

(2,356)

(2,582)

(6,102)

(11,040)

Net repayments

Resegmentation

(333,112)

(42,333)

(14,348)

(389,793)

(55,356)

(786)

-

(56,142)

(28,963)

(28,963)

-

-

-

-

-

-

(11,134)

6,047

10,948

5,861

-

(176)

-

-

(78)

-

-

-

(254)

-

(12,946)

(12,946)

Net Write-offs
Net remeasurement due 
to stage transfers and risk 
parameters changes
Foreign exchange 
movements

54,123

6,487

4,798

65,408

227

268

1,034

1,529

At 31 December 2019

2,650,261

204,699

93,319

2,948,279

18,341

18,593

29,211

66,145

234

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Loans to micro, small and 
medium enterprises

In thousands of GEL

Gross carrying amount

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Stage 1
(12-months 
ECL)

Total

Credit loss allowance

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Total

At 1 January 2018

1,630,103

149,799

64,770

1,844,672

9,894

11,890

24,468

46,252

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 
to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

(142,901)

152,463

(9,562)

 (83,887)

 (21,578)

 105,465 

 31,601 

 (30,683)

 (918)

-

 -   

 -   

(13,479)

15,630

(2,151)

 (6,489)

 (2,130)

 8,619 

 2,973 

 (2,552)

 (421)

-

 -   

 -   

 1,360,236 

 -   

 -   

 1,360,236 

 21,595 

 -   

 -   

 21,595 

 (528,289)

 (61,702)

 (49,272)

 (639,263)

 (4,388)

 (2,679)

 (3,210)

 (10,277)

Net repayments

Other movements

 (146,754)
 (21)

 (20,622)

 6 

 788 

 349 

 (166,588)
 334 

 - 
 - 

 - 
 - 

 - 
 - 

 -   

 -   

Resegmentation

 75,069 

 23,747 

 1,725 

 100,541 

 4,377 

 8,457 

 1,611 

 14,445 

Net Write-offs
Net remeasurement 
due to stage transfers 
and risk parameters 
changes
Foreign exchange  
movements

 -   

 - 

 -   

 (22,004)

 (22,004)

 -   

 -   

 (5,664)

 (5,664)

 - 

 - 

 -   

 4,781 

 (6,245)

 5,997 

 4,533 

 15,460 

 1,727 

 1,479 

 18,666 

 9 

 8 

 113 

 130 

At 31 December 2018

2,210,617

193,157

92,820

2,496,594

 19,273 

 22,379 

 29,362 

 71,014 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

235

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Consumer loans

Gross carrying amount

Credit loss allowance

In thousands of GEL

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Stage 3
(lifetime ECL 
for credit 
impaired)

Total

Total

At 1 January 2019

1,641,978

265,687

81,851

1,989,516

42,903

59,245

54,575 156,723

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 to 
Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

(166,459)

176,428

(9,969)

(60,362)

(67,012)

127,374

 81,453 

(80,023)

(1,430)

-

-

 -

(16,454)

21,029

(4,575)

(5,682)

(16,168)

21,850

16,851 

 (16,013))

 (838)

-

-

-

641,207

-

-

641,207

34,363

-

-

34,363

(101,437)

(39,416)

(125,004)

(265,857)

3,706

(11,085)

(7,972)

(15,351)

Net repayments

Resegmentation

(460,554)

(42,061)

109,208 

(393,407)

2,583

1,092

572

4,247

(110,243)

(110,243)

-

-

-

-

-

-

(38,995)

15,212

78,558

54,775

-   

15

-

-   

97

-

-   

-   

184

296

(97,652)

(97,652)

Net Write-offs
Net remeasurement due 
to stage transfers and risk 
parameters changes
Foreign exchange  
movements

14,853

2,122

1,568

18,543

17 

122 

663 

802 

At 31 December 2019

1,593,262 

216,817 

73,927  1,884,006

36,724 

52,439 

44,793  133,956

236

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Consumer loans

Gross carrying amount

Credit loss allowance

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Total

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Total

In thousands of GEL

At 1 January 2018

1,788,523

301,923

72,981

2,163,427

42,066

64,309

48,195

154,570

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 
to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

(244,838)

253,057

(8,219)

(97,030)

(64,020)

161,050

73,142

(71,235)

(1,907)

-

-

-

(34,737)

38,429

(3,692)

(28,073)

(16,142)

44,215

10,012

(9,115)

(897)

-

-

-

1,359,515

109

20

1,359,644

65,303

-

-

65,303

(794,286)

(96,300)

(52,401)

(942,987)

(23,551)

(13,147)

(23,220)

(59,918)

Net repayments

(339,487)

(34,337)

32,155

(341,669)

Other movements

1,033

(77)

1,636

2,592

-

-

-

-

-

-

-

-

Resegmentation

(109,359)

(24,193)

(1,725)

(135,277)

(4,886)

(8,391)

(1,611)

(14,888)

Net Write-offs
Net remeasurement 
due to stage transfers 
and risk parameters 
changes
Foreign exchange  
movements

-

-

-

-

(122,095)

(122,095)

-

- (100,885)

(100,885)

-

-

16,760

3,298

92,489

112,547

4,765

760

356

5,881

9

4

(19)

(6)

At 31 December 2018

1,641,978

265,687

81,851

1,989,516

42,903

59,245

54,575

156,723

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

237

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Mortgage loans

Gross carrying amount

In thousands of GEL

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Credit loss allowance

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Total

Stage 1
(12-months 
ECL)

Total

At 1 January 2019

2,470,604

194,410

44,169

2,709,183

1,696

9,166

14,026

24,888

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 to 
Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

Net repayments

Resegmentation

Net Write-offs
Net remeasurement due 
to stage transfers and risk 
parameters changes
Foreign exchange  
movements

(172,796)

182,744 

(9,948)

(12,481)

(23,593)

36,074 

66,513  

(64,675)

 (1,838)

-   

-   

 -

(384)

3,294 

(2,910)

(95)

(1,597)

1,692 

2,563  

 (1,991)

(572)

-

-

-

811,030

-

-

811,030

818

-

-

818

(81,648)

(46,649)

4,720 

(123,577)

(137)

(1,796)

(691)

(2,624)

(313,332)

(22,613)

(10,568)

(346,513)

(572)

(955)

(4,172)

(955)

-   

(15)

-

-   

(94)

-

-   

-   

(184)

3,608

(293)

3,608

(2,583)

(1,017)

-

-

-

-

-

-

(3,018)

2,172 

4,478

3,632

108,419 

12,562 

3,220 

124,201 

43 

532 

1,101 

1,676

At 31 December 2019

2,873,726 

231,169 

64,302 

3,169,197

1,471 

9,686 

20,548 

31,705

238

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Mortgage loans

Gross carrying amount

Credit loss allowance

Stage 1
(12-months 
ECL)

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Stage 1
(12-months 
ECL)

Total

Stage 2
(lifetime 
ECL for 
SICR) 

Stage 3
(lifetime 
ECL for 
credit 
impaired)

Total

In thousands of GEL

At 1 January 2018

 1,839,707 

 189,887 

 40,136 

 2,069,730 

 1,371 

 9,336 

 12,102 

 22,809 

Transfers:

 - to lifetime (from 

Stage 1 and Stage 3 
to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during the 
period

 (144,596)

 156,655 

 (12,059)

 (14,734)

 (20,146)

 34,880 

 50,917 

 (50,040)

 (877)

 -   

 -   

 -   

 (2,118)

 5,254 

 (3,136)

 (1,700)

 (1,248)

 2,948 

 1,717 

 (1,466)

 (251)

 -   

 -   

 -   

 1,367,848 

 -   

 -   

 1,367,848 

 3,035 

 -   

 -   

 3,035 

 (480,297)

 (67,350)

 (8,657)

 (556,304)

 (801)

 (2,083)

 (1,575)

 (4,459)

Net repayments

 (174,623)

 (18,409)

 (8,435)

 (201,467)

 211 

 (2,385)

 71 

 (61)

 1,807 

 2,089 

 -   

 (2,446)

 -   

 (3,576)

 (3,576)

 - 

 - 

 (12)

 -   

 - 

 - 

 (8)

 - 

 - 

 -   

 -   

 -   

 (20)

 -   

 1,963 

 1,963 

Other movements

Resegmentation

Net Write-offs
Net remeasurement 
due to stage transfers 
and risk parameters 
changes
Foreign exchange  
movements

 -   

 - 

 - 

 - 

 -   

 195 

 (632)

 1,969 

 1,532 

 28,556 

 3,803 

 950 

 33,309 

 9 

 13 

 6 

 28 

At 31 December 2018

 2,470,604 

 194,410 

 44,169 

 2,709,183 

 1,696 

 9,166 

 14,026 

 24,888 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

239

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Movements in the provision for loan impairment during 2019 are as follows:

In thousands of GEL
Credit Loss allowance as of 1 
January 2019
Resegmentation effect
Credit loss allowance during 
the year
Amounts written off during 
the period as uncollectible 
Recoveries
Effect of translation to 
presentation currency
Foreign exchange movements

Credit Loss allowance as of 
31 December 2019

Corporate loans

Consumer loans

Mortgage loans

81,505
767

(3,261)

-
 630 

-
1,109

156,723
-

74,581 

(110,243)
 12,591 

64
240

24,888
-

2,742 

(955)
 4,563 

115
352

Loans to micro, 
small and medium 
enterprises

71,014
(767)

Total

334,130
 -   

7,968 

82,030

(28,963)
 16,017 

(140,161)
 33,801 

383
493

562
2,194

80,750

133,956

31,705

66,145

312,556

Loans  and  advances  to  customers  written  off  in  2019  included  loans  to  customers  in  the  gross  amount  of  GEL  39,464 
thousand issued in 2019, out of which, none was previously issued performance guarantee transformed into loan in 2019 and 
GEL 100,697 thousand was issued in previous years.

Movements in the provision for loan impairment during 2018 were as follows:

In thousands of GEL
Provision for loan impairment 
as of 31 December 2017
IFRS 9 effect
Credit Loss allowance as of 1 
January 2018
Resegmentation effect
Credit loss allowance during 
the year
Amounts written off during 
the period as uncollectible 
Effect of translation to 
presentation currency

Credit Loss allowance as of 
31 December 2018

Corporate loans

Consumer loans

Mortgage loans

49,626
18,337

67,963
446

13,416

(320)

-

121,538
33,032

154,570
(14,889)

139,143

(122,095)

(6)

17,577
5,232

22,809
(21)

5,648

(3,576)

28

Loans to micro, 
small and medium 
enterprises

39,123
7,129

46,252
14,464

32,194

Total

227,864
63,730

291,594
 -   

190,401

(22,004)

(147,995)

108

130

81,505

156,723

24,888

71,014

334,130

Loans  and  advances  to  customers  written  off  in  2018  included  loans  to  customers  in  the  gross  amount  of  GEL  43,422 
thousand issued in 2018, out of which, none was previously issued performance guarantee transformed into loan in 2018 and 
GEL 104,573 thousand was issued in previous years.

240

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

                                        
                           
                                         
                                                                                           
9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Movements in the provision for loan impairment during 2017 were as follows:

In thousands of GEL
Provision for loan impairment 
as of 1 January 2017
(Recovery of)/provision for 
impairment during the year
Amounts written off during 
the year as uncollectible 
Effect of translation to 
presentation currency

Provision for loan impairment 
as of 31 December 2017

Corporate loans

Consumer loans

Mortgage loans

Loans to micro, 
small and medium 
enterprises

Total

90,100 

73,730 

23,602

37,591 

225,023

(11,088)

(29,386)

-

130,333

(82,601)

76

384

(6,507)

98

21,521

141,150

(20,265)

(138,759)

276

450

49,626

121,538

17,577

39,123

227,864

Loans and advances to customers written off in 2017 included loans to customers in the gross amount of GEL 21,056 thousand 
issued in 2017, a previously issued performance guarantee of GEL 6 thousand which was transformed into loan in 2017 and 
GEL 117,697 thousand was issued in previous years.

The credit loss allowance for loans and advances to customers recognised in the period is impacted by a variety of factors, 
details of ECL measurement are provided in Note 37. 

In 2018 the Group applied the portfolio provisioning methodology prescribed by IFRS 9. For details please refer to Note 2. For 
the periods before 1 January 2018, the Group applied the portfolio provisioning methodology prescribed by IAS 39, Financial 
Instruments: Recognition and Measurement, and it created portfolio provisions for impairment losses that were incurred but 
had not been specifically identified with any individual loan by the end of reporting period.

The table below contains an analysis of the credit risk exposure of loans and advances to customers measured at AC and for 
which an ECL allowance is recognised. The carrying amount of loans and advances to customers below also represents the 
Group’s maximum exposure to credit risk on these loans. For details please refer to Note 2.

For the periods before 1 January 2018, the Group’s policy for credit risk management purposes was to classify each loan as 
‘neither past due nor impaired’, ‘past due but not impaired’, ‘individually assessed impaired loans’ and ‘collectively assessed 
impaired loans’.  The pool of ‘neither past due nor impaired loans’ included exposures that were not overdue and were not 
classified as impaired. ‘Past due but not impaired’ loans included overdue performing loans but with no objective evidence 
of impairment identified. The classification included as well triggered loans that were not impaired because the current 
value of the expected cash and collateral recoveries were sufficient for full repayment. ‘Individually assessed impaired loans’ 
included exposures which were assessed for impairment on an individual basis, and an ad-hoc impairment allowance was 
created. ‘Collectively assessed impaired loans’ included exposures for which objective evidence of impairment was identified 
and the respective collective impairment allowance was created. 

The  Group  conducts  collective  assessment  of  the  borrowers  on  a  monthly  basis.  As  for  the  individual  assessment,  it  is 
performed quarterly.

Individually assessed impaired loans’ include exposures which are impaired and individual impairment is applied based on 
individual assessment. ‘Collectively assessed impaired loans’ include exposures for which default triggers were identified and 
the respective collective impairment allowance was created. Both individually and collectively impaired loans are classified 
as stage 3 exposures. The Group conducts collective assessment of the borrowers on a monthly basis. As for the individual 
assessment, it is performed quarterly. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

241

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

The credit quality of loans to customers carried at amortised cost is as follows at 31 December 2019:

In thousands of GEL

Corporate loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Consumer loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Mortgage loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance

Carrying amount

Loans to MSME risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL)

Stage 2
(lifetime ECL for SICR) 

Stage 3
(lifetime ECL for credit 
impaired)

4,094,403 

339,960 

322 

-   

-   

4,434,685

(39,153)
4,395,532 

1,107,490 

330,361 

155,411 

-   

-   

1,593,262

(36,724)
1,556,538

2,668,691 

182,049 

22,986 

-   

-   

2,873,726

(1,471)

2,872,255 

2,223,262 

407,106 

19,893 

-   

-   

2,650,261

(18,341)
2,631,920 

7,882 

75,872 

19,827 

828 

-   

104,409

(1,969)
102,440 

5,436 

17,620 

176,815 

16,946 

-   

216,817

(52,439)
164,378

17,970 

80,289 

121,743 

11,167 

-   

231,169

(9,686)

221,483 

23,114 

87,244 

80,947 

13,394 

-   

204,699

(18,593)
186,106 

-   

-   

-   

-   

121,379 

121,379

(39,628)
81,751 

-   

-   

-   

-   

73,927 

73,927

(44,793)
29,134

-   

-   

-   

-   

64,302 

64,302

(20,548)

43,754 

-   

-   

-   

-   

93,319 

93,319

(29,211)
64,108 

Total

4,102,285

415,832

20,149

828

121,379

4,660,473

(80,750)   
4,579,723

1,112,926

347,981

332,226

16,946

73,927

1,884,006

(133,956)
1,750,050

2,686,661

262,338

144,729

11,167

64,302

3,169,197

(31,705)

3,137,492

2,246,376

494,350

100,840

13,394

93,319

2,948,279

(66,145)
2,882,134

242

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

The credit quality of The credit quality of loans to customers carried at amortised cost is as follows at 31 December 2018:

In thousands of GEL

Corporate loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Consumer loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Mortgage loans risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance

Carrying amount

Loans to MSME risk category

 - Very low

 - Low

 - Moderate

 - High

 - Default

Gross carrying amount

Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL)

Stage 2
(lifetime ECL for SICR) 

Stage 3
(lifetime ECL for credit 
impaired)

2,712,885

189,086

1,344

-   

                   -   

2,903,315

 (32,940)
 2,870,375 

1,118,057

349,406

174,530

                         -   

                         -   

1,641,993

 (42,903)
1,599,090

2,268,634

177,274

24,695

-

-

2,470,603

 (1,697)

2,468,906

1,865,077

324,306

21,342

                         -   

                         -   

2,210,725

 (19,301)
2,191,424

6,417

130,798

1,238

260

               -   

138,713

 (4,994)
 133,719 

3,371

19,874

212,707

29,719

                    -   

265,673

 (59,245)
206,428

20,051

62,060

104,550

7,749

-

194,410

 (9,165)

185,245

16,285

72,742

84,520

19,502

                    -   

193,049

 (22,379)
170,670

               -   

               -   

             -   

-   

135,261

135,261

 (43,571)
 91,690 

                  -   

                  -   

                  -   

                  -   

81,850

81,850

 (54,575)
27,275

-

-

-

-

44,170

44,170

 (14,026)

30,144

                  -   

                  -   

                  -   

                  -   

92,820

92,820

 (29,334)
63,486

Total

2,719,302

319,884

2,582

260

135,261

3,177,289

 (81,505)
 3,095,784 

1,121,430

369,280

387,237

29,719

81,850

1,989,516

 (156,723)
1,832,793

2,288,685

239,334

129,245

7,749

44,170

2,709,183

 (24,888)

2,684,295

1,881,362

397,048

105,862

19,502

92,820

2,496,594

 (71,014)
2,425,580

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

243

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

For description of the credit risk grading used in the tables above refer to Note 37.

Analysis by credit quality of loans outstanding as of 31 December 2017 is as follows:

In thousands of GEL

Corporate loans

Consumer loans

Mortgage loans

Loans to micro, small and 
medium enterprises

Total

Neither past due nor impaired
 - Borrowers with credit 
history over two years

 - New borrowers

Total neither past due nor 
impaired

Past due but not impaired

 - 1 to 30 days overdue

 - 31 to 90 days overdue
 - 91 to 180 days overdue

 - 181 to 360 days overdue

 -  More than 360 days overdue

Total past due but not impaired
Individually assessed impaired 
loans 

 - Not overdue

 - 1 to 30 days overdue

 - 31 to 90 days overdue

 - 91 to 180 days overdue
 - 181 to 360 days overdue

 - More than 360 days overdue

Total individually assessed 
impaired loans
Collectively assessed impaired   
loans 

 - Not overdue

 - 1 to 30 days overdue

 - 31 to 90 days overdue

 - 91 to 180 days overdue

 - 181 to 360 days overdue

 - More than 360 days overdue

Total collectively assessed 
impaired loans
Total loans and advances to 
customers (before impairment)

Total provision
Total loans and advances to 
customers

 1,679,029 

 708,038 

 1,556,495 

 1,679,495 

 479,433 

 338,456 

 1,134,503 

 619,528 

 6,049,522 

 2,145,455 

2,387,067

    2,035,928

2,017,951

1,754,031

8,194,977

 -   

 -   
 23,029 

 -   

 -   

41,088

 26,433 
 165 

 116 

 48 

15,089

 10,620 
 -   

 -   

 -   

31,598

 13,395 
 -   

 -   

 -   

87,775

 50,448 
 23,194 

 116 

 48 

23,029

67,850

25,709

44,993

161,581

 39,443 

 10,351 

 4,455 

 48 
 -   

 8,740 

63,037

 1,266 

 668 

 -   

 -   

 -   

 325 

2,259

 -   

 -   

 -   

 -   
 -   

 -   

 -   

 6,669 

 2,605 

 4,078 

 28,609 

 10,246 

 7,440 

 -   

 -   

 -   

 -   
 -   

 -   

 -   

5,912

 5,097 

 5,595 

 2,561 

 4,335 

 2,568 

 2,420 

 -   

 -   

 -   
 -   

 -   

 41,863 

 10,351 

 4,455 

 48 
 -   

 8,740 

 2,420 

65,457

6,744

 2,897 

 3,542 

 10,009 

 8,969 

 11,067 

 20,591 

 11,267 

 13,215 

41,179

23,550

 21,400 

59,647

26,068

43,228

131,202

2,475,392

(49,626)

2,163,425

(121,538)

2,069,728

(17,577)

1,844,672

(39,123)

8,553,217

(227,864)

2,425,766

2,041,887

2,052,151

1,805,549

8,325,353

244

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9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

Economic sector risk concentrations within the customer loan portfolio are as follows

31 December 2019

31 December 2018

In thousands of GEL

Individual

Energy & Utilities

Hospitality & Leisure

Real Estate

Food Industry

Trade

Construction

Agriculture

Healthcare

Services

Pawn Shops

Automotive

Transportation

Metals and Mining

Financial Services

Communication

Other
Total loans and advances to 
customers (before impairment)

Amount

 5,046,804 

 1,089,643 

 988,467 

 1,076,102 

 785,539 

 616,475 

 576,923 

 498,783 

 305,152 

 212,661 

 203,633 

 183,912 

 134,223 

 99,321 

 96,430 

 43,329 

 704,558 

%

40%

Amount

4,677,328

%

45%

9%

8%

8%

6%

5%

5%

4%

2%

2%

2%

1%

1%

1%

1%

0%

5%

776,204

 759,605 

 564,197 

 570,810 

 445,290 

 359,549 

 418,432 

 220,756 

 180,045 

 278,384 

 156,241 

 80,075 

 100,855 

 71,617 

 229,522 

 483,672 

7%

7%

5%

6%

4%

3%

4%

2%

2%

3%

2%

1%

1%

1%

2%

5%

Amount

4,198,386

31 December 2017
%
49%
9%
5%
5%
7%
5%
3%
3%
2%
1%
3%
2%
1%
1%
1%
1%
2%

719,854

450,741

453,415

524,286

394,495

233,771

269,844

172,255

108,186

279,410

160,795

96,427

84,419

87,501

114,032

205,400

12,661,955

100%

10,372,582

100%

8,553,217

100%

As of 31 December 2019 the Group had 239 borrowers (2018: 170 borrowers; 2017: 142 borrowers) with aggregated gross 
loan amounts above GEL 5,000 thousand. The total aggregated amount of these loans was GEL 4,443,036 thousand (2018: 
GEL 3,054,314 thousand; 2017: GEL 2,437,750 thousand) or 35.1% of the gross loan portfolio (2018: 29.4%; 2017: 28.5%).

The amount and type of collateral required depend on an assessment of the credit risk of the counterparty.  There are three 
key types of collateral:

Real estate

 `
 ` Movable property including fixed assets, inventory and precious metals;
 `
Financial assets including deposits, shares, and third party guarantees. 

The financial effect of collateral is presented by disclosing the collateral values separately for (i) those assets where collateral 
and other credit enhancements are equal to or exceed the assets’ carrying value (“over-collateralised assets”) and (ii) those 
assets  where  collateral  and  other  credit  enhancements  are  less  than  the  assets’  carrying  value  (“under-collateralised 
assets”). 

The effect of collateral as of 31 December 2019:

In thousands of GEL
Corporate loans
Consumer loans
Mortgage loans
Loans to micro, small
and medium enterprises
Total 

Over-collateralised Assets

Under-collateralised assets

Carrying value of the assets  Fair value of collateral
 8,481,849 
 2,232,728 
 6,171,802 

 3,682,456 
 950,847 
 2,949,426 

Carrying value of the assets
 978,017 
 933,159 
 219,771 

Fair value of collateral
 310,419 
 37,658 
 107,183 

 2,579,002 
 10,161,731 

 5,983,285 
 22,869,664 

 369,277 
 2,500,224 

 164,979 
 620,239 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

245

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

9. LOANS AND ADVANCES TO CUSTOMERS CONTINUED

The effect of collateral as of 31 December 2018:

In thousands of GEL
Corporate loans
Consumer loans
Mortgage loans
Loans to micro, small and 
medium enterprises
Total 

Over-collateralised Assets

Under-collateralised assets

Carrying value of the assets  Fair value of collateral
6,516,492
2,543,720
 5,404,518 

2,857,207
1,213,594
 2,663,362 

Carrying value of the assets Fair value of collateral
47,249
34,242
 28,934 

320,082
775,922
 45,821 

2,340,847
 9,075,010

5,324,290
 19,789,020 

          155,747
 1,297,572 

68,110
 178,535 

The effect of collateral as of 31 December 2017: 

In thousands of GEL
Corporate loans
Consumer loans
Mortgage loans
Loans to micro, small and 
medium enterprises
Total 

Over-collateralised Assets

Under-collateralised assets

Carrying value of the assets  Fair value of collateral
 5,194,598 
2,132,566
 4,429,201 

2,129,927
908,387
2,042,001

Carrying value of the assets
 345,465 
1,255,038
 27,727 

Fair value of collateral
 97,386 
25,781
 17,189 

1,688,438
 6,768,753

3,970,931
 15,727,296 

156,234
 1,784,464 

146,949
 287,305 

The  financial  effect  of  collateral  is  determined  by  comparing  the  fair  value  of  collateral  to  outstanding  gross  loans  and 
advances in the reporting date.

At the central level a specific unit manages collateral to ensure that they serve as an adequate mitigation for credit risk 
management purposes. In line with the Group’s internal policies, collateral provided to loans are evaluated by the Internal 
Appraisal Group (external reviewers are used in case of loans to related parties or specific cases when complex objects are 
appraised). The Internal Appraisal Group is part of the collateral management unit and, in order to ensure adequate and 
objective appraisal procedures, it is independent from the loan granting process. Real estate collateral of significant value is 
re-evaluated annually by internal appraisers. Statistical methods are used to monitor the value of real estate collateral that 
are of non-significant value and other types of collateral such as movable assets and precious metals.

Collateral values include the contractual price of third-party guarantees, which, due to their nature, are capped at the loan’s 
carrying value. The values of third-party guarantees in the tables above amounted to GEL  595,464 thousand, GEL 625,719 
thousand and GEL 527,498 thousand as of 31 December 2019, 2018 and 2017 respectively. These third-party guarantees are 
not taken into consideration when assessing the impairment allowance. Refer to Note 42 for the estimated fair value of each 
class of loans and advances to customers. Interest rate analysis of loans and advances to customers is disclosed in Note 
37. Information on related party balances is disclosed in Note 44. As of 31 December 2019 gains less losses recognised in 
profit or loss on modifications of loans with lifetime ECL that did not lead to derecognition was GEL 844 thousand (As of 31 
December 2018: GEL 196  thousand). 

10. INVESTMENT SECURITIES MEASURED AT FAIR VALUE
THROUGH OTHER COMPREHENSIVE INCOME
The  figures  below  represent  Investment  securities  measured  at  FVOCI  under  IFRS  9  since  1  January  2018,  previously 
classified under available-for-sale category under IAS 39. The credit loss allowance as at 31 December 2019 and as at 31 
December 2018 is reported under IFRS 9 and is not comparable to the information presented for 2017.

246

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10. INVESTMENT SECURITIES MEASURED AT FAIR VALUE
THROUGH OTHER COMPREHENSIVE INCOME CONTINUED

In thousands of GEL
Corporate bonds
Ministry of Finance of Georgia Treasury Bills
Certificates of Deposit of the National Bank of Georgia
Ministry of Finance of Uzbekistan Treasury Bills
Netherlands Government Bonds
Less: Credit loss allowance
Total debt securities
Corporate shares – unquoted
Total investment securities measured at fair value 
through other comprehensive income

2019
611,694
330,096
40,346
1,596
-
(1,438)
982,294
2,999

985,293

2018
549,477
373,447
14,985
-
66,760
(1,136)
1,003,533
1,706

1,005,239

2017
328,761
319,745
7,728
-
-
-
656,234
1,704

657,938

All debt securities except for corporate bonds,  Uzbekistan treasury bills and Netherlands government bonds were issued 
by the Government of Georgia and National Bank of Georgia. Country rating for Georgia stands at BB with stable outlook (as 
assigned by international rating agencies in October 2019). Latest country ratings for Uzbekistan and Netherlands stand at 
BB- and AAA respectively. 56.7% of corporate bonds are issued by triple A rated international financial institutions, 19.7% 
of corporate bonds are issued by A rated international financial institutions and 6.0% of corporate bond are issued at BB- 
rating, whereas 17.4% and 0.2% of corporate bonds are issued by B+ and B- rated corporations respectively. The investees 
have not published recent financial information about their operations, their shares are not quoted and recent trade prices 
are not publicly accessible. At 1 January 2018, the Group designated investments in corporate shares disclosed in the above 
table as equity securities at FVOCI. In 2017, these investments were classified as AFS. Refer to Note 2 for details. The FVOCI 
designation was made because the investments are expected to be held for strategic purposes rather than with a view to 
profit on a subsequent sale, and there are no plans to dispose of these investments in the short or medium term.

As of 31 December 2019 investment securities measured at fair value through other comprehensive income  carried at GEL 
696,961 thousand have been pledged to local banks or financial institutions as collateral with respect to other borrowed 
funds (2018: GEL 613,466  thousand; 2017: GEL 424,892 thousand). Refer to Note 19. None of the debt securities measured 
at fair value through other comprehensive income are overdue or impaired. As of 31 December 2019 the principal equity 
investment securities measured at fair value through other comprehensive income are as follows:

Nature of business

Country of registration 

Carrying value as of 31 December

In thousands of GEL
JSC GRDC
Georgian Stock Exchange
Other
Total

Property development
Stock exchange

Netherlands Antilles
Georgia

2019
365
21,11
523
2,999

2018 
365
1,004
337
1,706

2017 
365
1,004
335
1,704

The movements in investment securities measured at fair value through other comprehensive income are as follows:

In thousands of GEL
Carrying amount as of 1 January
Transfers from bonds carried at amortised cost
Purchases
Disposals
Redemption at maturity
Revaluation
Interest income accrued 
Interest income received
Effect of translation to presentation currency
Transfer to investments in associate
Change in credit loss allowance*
Carrying amount as of 31 December

Note

30

2019 
1,005,239
27,241
1,781,817
(240,603)
(1,598,534)
(15,156)
74,043
(58,539)
10,087
-
(302)
985,293

2018 
657,938
-
717,630
(14,781)
(370,571)
6,949
57,057
(48,442)
595
-
(1,136)
1,005,239

2017
430,703
-
560,226
-
(345,748)
5,489
43,735
(36,214)
(158)
(95)
-
657,938

*For the purpose of ECL measurement, securities balances are included in Stage 1. Refer to Note 37 for the ECL measurement approach. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

247

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

11. BONDS CARRIED AT AMORTISED COST

In thousands of GEL
Ministry of Finance Treasury Bills
Certificates of Deposit of the National Bank of Georgia
Georgian Government notes
Corporate bonds
Less: Credit loss allowance
Total bonds carried at amortised cost

2019
1,023,459
-
-
1,131
(1,906)
1,022,684

2018
654,618
-
-
500
(915)
654,203

2017
424,876
24,662
-
-
-
449,538

All debt securities except for corporate bonds are issued by the Government of Georgia and National Bank of Georgia. Country 
rating for Georgia stands at BB- with stable outlook (as per international rating agencies in October 2019).

The movements in bonds carried at amortised cost are as follows:

In thousands of GEL
Carrying amount as of 1 January
Transfers to investment securities at FVOCI
Purchases
Redemption at maturity
Interest income accrual
Interest income received
Effect of translation to presentation currency
Change in credit loss allowance
Carrying amount as of 31 December

2019 
654,203
(27,241)
614,000
(216,667)
58,682
(59,316)
14
(991)
1,022,684

2018 
449,538
-
396,217
(200,658)
40,625
(30,611)
7
(915)
654,203

2017
372,956
-
307,248
(242,380)
32,328
(20,601)
(13)
-
449,538

For the disclosure of bonds’ fair value carried at amortised cost refer to Note 42. An analysis on interest rate for bonds carried 
at amortised cost is disclosed in Note 37.

As of 31 December 2019 bonds carried at amortised cost of GEL 579,142 thousand have been pledged to local banks or 
financial institutions as collateral with respect to other borrowed funds (2018: GEL 212,337 thousand; 2017: GEL 223,860 
thousand). Refer to Note 19.

None of the bonds carried at amortised cost as of 31 December 2019, 31 December 2018 and 31 December 2017 were either 
overdue or impaired. For the purpose of ECL measurement securities balances are included in Stage 1. Refer to Note 37 for 
the ECL measurement approach. As the ECL for year 2019 is measured per IFRS 9, it is not comparable to the prior periods.

12. OTHER FINANCIAL ASSETS
In thousands of GEL
Receivables from sales of repossessed assets 
Receivables on guarantees / letters of credit
Prepayments for purchase of leasing assets
Insurance and reinsurance receivables
Receivables on credit card services and money transfers
Receivable on terminated leases
Trade receivable
Rental income receivables
Bank assurance income receivable
Factored receivables
Foreign exchange forward contracts
Other
Total gross amount of other financial assets
Less: Credit loss allowance
Total carrying amount of other financial assets

2019
32,844
1,695
3,866
26,177
21,895
21,837
4,921
2,833
-
-
2,087
46,450
164,605
(30,869)
133,736

2018
43,671
36,869
32,293
21,451
14,390
12,651
8,292
3,492
2,527
-
1,490
18,486
195,612
(28,094)
167,518

2017
6,619
20,983
25,478
15,742
26,703
8,961
13,862
4,414
15,923
6,182
1,767
17,530
164,164
(18,020)
146,144

The credit loss allowance as at 31 December 2019 and as at 31 December 2018 is reported under IFRS 9 and is not comparable 
to the information presented for 2017.

248

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

12. OTHER FINANCIAL ASSETS CONTINUED 

Movements in the credit loss allowance of other financial assets during 2019 were as follows:

 In thousands of GEL
Credit loss allowance as of 1 January 2019
Credit loss allowance during the year
Amounts written off during the year as uncollectible
Foreign exchange translation gains less losses
Credit loss allowance as of 31 December 2019

Receivables on 
terminated leases 
9,377
5,382
-
-
14,759

Other 
18,717
(1,102)
(1,489)
(16)
16,110

Total
28,094
4,280
(1,489)
(16)
30,869

The credit loss allowance as at 31 December 2019 and as at 31 December 2018 is reported under IFRS 9 and is not comparable 
to the information presented for 2017.

Movements in the provision for impairment of other financial assets during 2018 were as follows:

In thousands of GEL 
Provision for impairment as of 31 December 2017
IFRS 9 effect

Credit loss allowance as of 1 January 2018
Credit loss allowance during the year
Amounts written off during the year as uncollectible
Foreign exchange translation gains less losses
Credit loss allowance as of 31 December 2018

Receivables on 
terminated leases 
6,234
-

6,234
3,143
-
-
9,377

Other 
11,786
1,019

12,805
12,097
(6,404)
219
18,717

Total
18,020
1,019

19,039
15,240
(6,404)
219
28,094

Additions  less  releases  recorded  in  profit  or  loss  for  credit  loss  allowance  of  other  financial  assets  include  write-off  of 
insurance debtors in the amount of GEL 163 thousand that were included in insurance and reinsurance receivables.

Movements in the provision for impairment of other financial assets during 2017 were as follows:

 In thousands of GEL
Provision for impairment as of 1 January 2017
Provision for impairment during the year
Amounts written off during the year as uncollectible
Recovery of amounts previously written off
Foreign exchange translation gains less losses
Provision for impairment as of 31 December 2017

Receivables on 
terminated leases 
4,666
1,568
-
-
-
6,234

Other 
1,994
10,645
(1,011)
189
(31)
11,786

Total
6,660
12,213
(1,011)
189
(31)
18,020

Additions less releases recorded in profit or loss for provision for of other financial assets include write-off of insurance 
debtors in the amount of GEL 226 thousand that were included in insurance and reinsurance receivables.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

249

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

12. OTHER FINANCIAL ASSETS CONTINUED 

As at 31 December 2019 and 2018, presentation of other financial assets gross carrying amount and credit loss allowance by 
IFRS 9 stages is as follows:

Stage 1
(12-months 
ECL)
126,785 

Gross carrying amount

Stage 2
(lifetime 
ECL for 
SICR) 
74

Stage 3
(lifetime ECL 
for credit 
impaired)
47,302

Stage 1
(12-months 
ECL)
13,144

Total
174,161

Credit loss allowance

Stage 2
(lifetime 
ECL for 
SICR) 
14

Stage 3
(lifetime ECL 
for credit 
impaired)
14,936

Total
28,094

In thousands of GEL
At 1 January 2019
Transfers:

 - to lifetime (from Stage 1 and 

Stage 3 to Stage 2)

 - to credit-impaired (from Stage 

1 and Stage 2 to Stage 3)

 - to 12-months ECL (from Stage 

2 and Stage 3 to Stage 1)
New originated or purchased
Changes to ECL measurement 
model assumptions
Derecognised during the period
Net repayments
Net Write-offs
Foreign exchange movements
At 31 December 2019

 (21)

 (55)

47
106,839 

-
(115,851)
 4,022 
 -   
 123 
121,889

 23 

 (15)

(47)
 -   

-
 (11)
 -   
 -   
 1 
25

 (2)

 70 

 -   

 -   

 (4)

 (1)

 4 

 (15)

 -  
 -   

 -   
  106,839 

4
 21,675 

         (4)
 -   

 -   

 16

 -   

 -   

 -  
 -   

 -   
 21,675 

-
 (30,852)
 355
 (1,489)
 1,130 
16,514

-
(146,714)
 4,377 
(1,489)
 1,254 
138,428

 31 
(16,642) 
 - 
  -    
 -   
18,207

 (6)
13 
 - 
  -    
 -   
6

 1,448
  (2,255) 
 - 
(1,489)
-
12,656

1,473
(18,884)
 - 
(1,489)
-
30,869

Gross carrying amount

Stage 2
(lifetime 
ECL for 
SICR) 
174
-
174

Stage 3
(lifetime ECL 
for credit 
impaired)
33,099
-
33,099

Stage 1
(12-months 
ECL)
115,149
-
115,149

In thousands of GEL
At 31 December 2017
IFRS 9 effect
At 1 January 2018
Transfers:

Credit loss allowance

Stage 1
(12-months 
ECL)
9,099
796
 9,895 

Total
148,422
-
148,422

Stage 2
(lifetime 
ECL for 
SICR) 
1
31
 32 

Stage 3
(lifetime ECL 
for credit 
impaired)

Total
8,920 18,020
1,019
 9,112  19,039

192

 - to lifetime (from Stage 1 and 

Stage 3 to Stage 2)

 - to credit-impaired (from Stage 

 (48)

1 and Stage 2 to Stage 3)

 (5,013)

 - to 12-months ECL (from Stage 

2 and Stage 3 to Stage 1)

New originated or purchased
Changes to ECL measurement 
model assumptions
Derecognised during the period
Net repayments
Net Write-offs
Foreign exchange movements
At 31 December 2018

 210 
 50,343 

-
 (26,787)
 (6,070)
 -   
 (999)
126,785 

 48 

 (17)

 (86)
 13 

-
 (44)
 (14)
 -   
 -   
74

 -   

 5,030 

 -   

 -   

 (3)

 (81)

 3 

 (4)

 -   

 85 

-

 -   

 (124)
 35,855 

 -   
   86,211

 57 
 4,439 

       (20)
 1 

 (37)

 -   
 5,596  10,036

-
 (1,243)
 (130)
 (16,772)
 (8,413)
47,302

-
(28,074)
 (6,214)
 (16,772)
 (9,412)
174,161

 (653)
 (510)
 - 
  -    
 -   
13,144

 8 
 (6)
 - 
  -    
 -   
14

 7,707 
(1,342)
 - 
(6,404)
219

 7,062 
(1,858)
 - 
(6,404)
219    
14,936 28,094

250

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

12. OTHER FINANCIAL ASSETS CONTINUED 

The credit quality of Other Financial Assets is as follows at 31 December 2019: 

In thousands of GEL
Other Financial Assets risk category
- Very low
- Low
- Moderate
- High
- Default
Gross carrying amount
Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL) 

Stage 2
(lifetime ECL for SICR)  

Stage 3
(lifetime ECL for credit 
impaired)

 121,589 
 219 
 81 
 -   
 -   
 121,889 
 (18,207)
 103,682 

 1 
 1 
 23 
 -   
 -   
 25 
 (6)
 19 

 -   
 -   
 -   
 -   
 16,514 
 16,514 
 (12,656)
 3,858 

The credit quality of Other Financial Assets is as follows at 31 December 2018

In thousands of GEL
Other Financial Assets risk category
- Very low
- Low
- Moderate
- High
- Default
Gross carrying amount
Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL) 

Stage 2
(lifetime ECL for SICR)  

Stage 3
(lifetime ECL for credit 
impaired)

 126,540 
 238 
 7 
 -   
 -   
 126,785 
 (13,144)
 113,641 

 18 
 39 
 17 
 -   
 -   
 74 
 (14)
 60 

 -   
 -   
 -   
 -   
 47,302 
 47,302 
 (14,936)
 32,366 

Total

 121,590 
 220 
 104 
 -   
 16,514 
 138,428 
 (30,869)
 107,559

Total

 126,558 
 277 
 24 
 -   
 47,302 
 174,161 
 (28,094)
 146,067 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

251

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

12. OTHER FINANCIAL ASSETS CONTINUED 

The table below illustrates the credit quality of other financial assets:

In thousands of GEL
Neither past due nor impairment

 - Prepayments for purchase of leasing assets
 - Insurance and Reinsurance Receivables
 - Receivables on credit card services and money transfers
 - Trade receivable
 - Receivables from sales of repossessed assets
 - Rental income receivables
 - Bank assurance income receivable
 - Receivables on guarantees / letters of credit
 - Factored receivables
 - Other

Total neither past due nor impaired
Past due but not impaired

 - Receivables on guarantees

 - More than 90 days overdue
Total past due but not impaired 
Receivables individually determined to be impaired (gross)

 - Receivables on terminated leases

 - Less than 90 days overdue
 - More than 90 days overdue

 - Receivables on guarantees and letters of credit

 - Less than 90 days overdue
 - More than 90 days overdue

 - Receivables on repossessed assets disposed

 - Less than 90 days overdue
 - More than 90 days overdue

 - Other receivables

 - Less than 90 days overdue
 - More than 90 days overdue
Total individually impaired (gross)
Less credit loss allowance
Total other financial assets

Credit rating of other financial assets neither past due nor impaired is as follows:

In thousands of GEL
A+
A
BBB+
BBB
BB
BB-
B+
B-
B
Not rated 
Total

252

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

31 December 2017

25,478
15,742
26,703
13,862
6,481
4,414
15,923
2,990 
6,182
14,120
131,895

16,773
16,773

8,961
-
8,961
1,220
-
1,220
138
-
138
5,177
-
5,177
15,496
(18,020)
146,144

2017
13,003
4,116
6,265
-
217
7
4,332
-
726
103,229
131,895

12. OTHER FINANCIAL ASSETS CONTINUED 

Impaired receivables include receivables on terminated leases and other receivables for which impairment provision was 
assessed individually. A receivable’s overdue status is a primary factor for the Group to consider a receivable as impaired. 
Receivables on terminated leases individually determined to be impaired are under-collateralised and their estimated fair 
value of collateral amounts to GEL 1,531 thousand (2018: GEL 1,484  thousand; 2017: GEL 1,206 thousand). The remaining 
assets are not collateralised. 

13. NET INVESTMENTS IN LEASE
As of 31 December 2019 net investments in lease of GEL 256,660 thousand (2018: GEL 203,802 thousand; 2017: GEL 143,836 
thousand) are represented by leases of fixed assets excluding land and buildings.

Finance lease payments receivable (gross investment in the leases) and their present values are as follows: 

In thousands of GEL
Lease payments receivable as of 31 December 2019
Unearned finance income
Credit loss allowance
Present value of lease payments receivable as of 31 December 2019

Due in 1 year
 147,959 
 (41,969)
 (1,430)
 104,560 

Due between 1 and 5 years
 193,143 
 (39,688)
 (1,355)
 152,100 

Lease payments receivable as of 31 December 2018
Unearned finance income
Credit loss allowance
Present value of lease payments receivable as of 31 December 2018

Lease payments receivable as of 31 December 2017
Unearned finance income
Impairment loss provision
Present value of lease payments receivable as of 31 December 2017

122,056
(32,981)
(1,789)
87,286

86,186
(23,720)
(765)
61,701

148,623
(30,294)
(1,813)
116,516

105,595
(22,727)
(733)
82,135

Total
 341,102 
 (81,657)
 (2,785)
 256,660 

270,679
(63,275)
(3,602)
203,802

191,781
(46,447)
(1,498)
143,836

For fair values refer to Note 42.

The  credit  loss  allowance  as  at  31  December  2019  and  as  at  31  December  2018  is  reported  under  IFRS  9  and  is  not 
comparable to the information presented for 2017. The table below illustrates the movements in the credit loss allowance of 
net investment in lease:

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

253

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

13. NET INVESTMENTS IN LEASE CONTINUED 

The following table discloses the changes in the credit loss allowance and gross carrying amount for net Investments in  
lease between the beginning and the end of the reporting period:

At 31 December 2019

1,999 

In thousands of GEL

At 1 January 2019
Transfers:

 - to lifetime (from 

Stage 1 and Stage 
3 to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during 
the period
Partial repayment
Net repayments
Foreign exchange 
movements
Other movements

In thousands of GEL

At 31 December 2017
IFRS 9 effect
At 1 January 2018
Transfers:

 - to lifetime (from 

Stage 1 and Stage 
3 to Stage 2)

 - to credit-impaired 
(from Stage 1 and 
Stage 2 to Stage 3)
 - to 12-months ECL 
(from Stage 2 and 
Stage 3 to Stage 1)

New originated or 
purchased
Derecognised during 
the period
Partial repayment
Net repayments
Foreign exchange 
movements
Other movements

Credit loss allowance

Gross carrying amount

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Stage 3
(lifetime ECL for 
credit impaired

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Stage 3
(lifetime ECL for 
credit impaired)

Total

Total

2,045

205

1,352

3,602

178,171

10,861

18,372

207,404

 (14)

 14 

 -   

 -   

 (5,951)

 6,598 

 (647)

 (27)

 (65)

 92 

 -   

 (22,099)

 (2,941)

 25,040 

 1 

1,319 

(858)
-
(467)

-
-

 (1)

89 

(154)
-
8 

-
-

96 

 -   

 -   

 4,968 

 (2,972)

 (1,996)

81 

1,489 

138,634 

18,663 

5,836 

163,133 

(1,536)
-
701 

(2,548)
-
242 

(55,562)
(38,828)
-

-
-

-
-

 2,622 
 3,660 

(4,849)
(2,253)
-

 170 
 522 

(10,407)
(9,448)
-

(70,818)
(50,529)
-

 1,022 
 2,259 

 3,814 
 6,441 

690  2,785 

205,615 

23,799 

30,031 

259,445 

 -   

 -   

 -   

Credit loss allowance

Gross carrying amount

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Stage 3
(lifetime ECL for 
credit impaired

519
345
864

51
394
445

928
-
928

Stage 1
(12-months 
ECL)

Stage 2
(lifetime ECL 
for SICR) 

Stage 3
(lifetime ECL for 
credit impaired)

128,500
-
128,500

11,610
-
11,610

5,224
-
5,224

Total

1,498
739
2,237

Total

145,334
-
145,334

 (9)

 9 

 -   

 (367)

 (20)

 387 

 357 

 (357)

  -    

-

-

-

 (3,996)

 4,078 

 (82)

 (10,605)

 (4,533)

 15,138 

 1,052 

 (1,033)

 (19)

 -   

 -   

 -   

1,350

(103)
-
 (47)

-
-

108

(81)
-
 101 

-
-

205

256

1,714

 120,992 

 7,208 

 5,165 

133,365 

(717)
-
 498 

(901)
-
 552 

(36,040)
 (24,985)
-

-
-

-
-

 1,250 
 2,003 

(5,372)
 (1,468)
-

 94 
 277 

(3,541)
 (4,887)
-

(44,953)
(31,340)
-

 289 
 1,085 

 1,633 
 3,365 

1,352

3,602

178,171

10,861

18,372

207,404

At 31 December 2018

2,045

254

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

13. NET INVESTMENTS IN LEASE CONTINUED 

The Group applied the portfolio provisioning methodology prescribed by IFRS 9 for the periods beginning 1 January 2018 
and IAS 39 for the periods before 1 January 2018 and created portfolio provisions for impairment losses that were incurred 
but have not been specifically identified with any individual lease by the reporting date. The Group’s policy is to classify each 
lease as “neither past due nor impaired” until specific objective evidence of impairment of the lease is identified. The primary 
factors  taken  into  account  to  consider  whether  or  not  a  lease  is  impaired  are  the  deterioration  of  the  lessee’s  financial 
position, its overdue status, and liquidity of the leased asset. 

The Group normally structures its finance lease contracts so that the lessee makes a minimum prepayment of 20% of the 
equipment purchase price at the inception of the lease term. The Group holds title to the leased assets during the lease term. 
The title to the asset under the finance lease contract is transferred to the lessees at the end of the contracts terms, including 
full repayment of lease payments. Generally the lease terms are up to five years.

The amount and type of collateral required depends on an assessment of the credit risk of the counterparty.  The main types 
of collateral obtained are:

 ` Leased assets (inventory and equipment);
 ` Down payment;
 ` Real estate properties; 
 ` Third party guarantees.

The financial effect of collateral is presented by disclosing the collateral values separately for (i) those assets where collateral 
and other credit enhancements are equal to or exceed the assets’ carrying value(“over-collateralised assets”) and (ii) those 
assets  where  collateral  and  other  credit  enhancements  are  less  than  the  assets’  carrying  value  (“under-collateralised 
assets”).

Per IFRS 9 impairment methodology, the Company classifies its portfolio into three stages: 

 ` Stage 1 – assets for which no significant increase of credit risk since initial recognition is identified; 
 ` Stage 2 – assets for which significant increase in credit risk since initial recognition is identified;
 ` Stage 3 – credit-impaired exposures.

For stage 1 exposures the Company creates 12 months expected credit losses, whereas for stage 2 and stage 3 lifetime 
expected credit losses are created. 

For the Stage 2 classification purposes the Company applies both quantitative and the qualitative criteria including, but not 
limited to: 

 ` 30 days past due (DPD) overdue;
 ` Downgrade of the risk category of the borrower since initial recognition;

Default definition includes criteria such as: (i) 90 DPD overdue (ii) distressed restructuring and (iii) other criteria indicating 
the borrower’s unlikeness to repay the liabilities.

The Group incorporates forward looking information (FLI) for both individual and collective assessment. For FLI purposes the 
Company defines three scenarios, which are: 

 ` Baseline (most likely);
 ` Upside (better than most likely);
 ` Downside (worse than most likely).

The  Group  derives  the  baseline  macro  scenario  and  takes  into  account  projections  from  various  external  sources  –  the 
National Bank of Georgia, Ministry of Finance, IMF as well as other IFIs - to ensure the alignment to the consensus market 
expectations. Refer to Note 37 for the description of how the Group incorporates FLI in ECL calculations. Upside and downside 
scenarios are defined based on the framework developed by the Bank’s macroeconomic unit. 

The Group calculates expected impairment losses for each scenario. In order to come up with the final expected credit loss 
figures the bank applies probability weighted average approach where probabilities of each scenario are used as weights. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

255

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

13. NET INVESTMENTS IN LEASE  CONTINUED 

As at 31 December 2019, credit quality of net investment in lease is analysed below:

In thousands of GEL
Net Investments in Lease risk category
- Very low
- Low
- Moderate
- High
- Default
Gross carrying amount
Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL) 

Stage 2
(lifetime ECL for SICR)  

Stage 3
(lifetime ECL for credit 
impaired)

 175,468 
 30,147 
 -   
 -   
 -   
205,615
 (1,999)
203,616

 -   
 13,688 
 6,361 
 3,750 
 -   
23,799
 (96)
23,703

 -   
 -   
 -   
 -   
 30,031 
30,031
 (690)
29,341

As at 31 December 2018, credit quality of net investment in lease is analysed below:

In thousands of GEL
Net Investments in Lease risk category
- Very low
- Low
- Moderate
- High
- Default
Gross carrying amount
Credit loss allowance
Carrying amount

Stage 1 
(12-months ECL) 

Stage 2
(lifetime ECL for SICR)  

Stage 3
(lifetime ECL for credit 
impaired)

145,220
32,951
- 
-   
-   
178,171
(2,045)
176,126

- 
2,350
6,712
1,799
-   
10,861
(205)
10,656

-   
-   
-   
-   
18,372
18,372
(1,352)
17,020

Credit quality of net investment in lease as at 31 December 2017 is analysed below:

In thousands of GEL
Neither past due nor impaired
- Customers with more than two year experience
- New customers
Total neither past due nor impaired

Past due but not impaired
- Less than 30 days overdue
-31 days to 90 days overdue
Total past due but not impaired

impaired leases
- 31 days to 90 days overdue
- From 91 to 180 days
- From 181 to 360 days
- More than 360 days
Total impaired gross*

Total investment in lease

Impairment loss provision

Total net investment in lease

*Total impaired leases include both collectively and individually impaired leases

256

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Total

175,468
43,835
6,361
3,750
30,031
259,445
 (2,785)
256,660

Total

145,220
35,301
6,712
1,799
18,372
207,404
(3,602)
203,802

31 December 2017

 22,705 
 90,668 
113,373

 19,047 
 9,310 
28,357

 343 
 2,204 
 339 
 718 
3,604

145,334

(1,498)

143,836

13. NET INVESTMENTS IN LEASE  CONTINUED 

The effect of collateral as of 31 December 2019: 

In thousands of GEL
Investment in leases
Total 

Over-collateralised assets

Under-collateralised assets

Carrying value of 
the assets 
228,651
228,651

Fair value of 
collateral
365,934
365,934

Carrying value
 of the assets
30,794
30,794

Fair value of 
collateral
22,292
22,292

The effect of collateral as of 31 December 2018:

In thousands of GEL
Investment in leases
Total 

Over-collateralised assets

Under-collateralised assets

Carrying value of 
the assets 
166,362
166,362

Fair value of 
collateral
253,582
253,582

Carrying value
 of the assets
41,042
41,042

Fair value of 
collateral
34,527
34,527

The effect of collateral as of 31 December 2017:

In thousands of GEL
Investment in leases
Total 

14. OTHER ASSETS

In thousands of GEL
Current other assets
Repossessed collateral 
Prepayments for other assets
Prepayments for purchase of leasing assets
Other inventories
Prepaid taxes other than income tax
Total current other assets
Non-current other assets
Reinsurer's Assets
Assets repossessed from terminated leases
Assets purchased for leasing purposes
Prepayments for construction in progress
Prepaid insurance of leasing assets
Other
Total non-current other assets

Total other assets

Over-collateralised assets

Under-collateralised assets

Carrying value of 
the assets 
 96,015 
 96,015 

Fair value of 
collateral
 153,813 
 153,813 

Carrying value
 of the assets
 49,319 
 49,319 

Fair value of 
collateral
 9,710 
 9,710 

2019

152,109
33,664
31,426
6,965
2,890
227,054

6,968
6,321
190
10,401
2,876
1,902
28,658

255,712

2018

120,663
29,027
-
4,198
856
154,744

14,529
10,819
6,985
2,259
2,174
1,282
38,048

192,792

2017

116,809
9,721
-
4,194
5,788
136,512

8,342
3,210
 2,733 
2,745
 1,884 
1,225
20,139

156,651

Repossessed  collateral  represents  real  estate  assets  acquired  by  the  Group  in  settlement  of  overdue  loans.  The  Group 
expects to dispose of the assets in the foreseeable future. The assets do not meet the definition of non-current assets held 
for sale, and are classified as inventories in accordance with IAS 2 “Inventories”. The assets were initially recognised at fair 
value when acquired. In 2019, collateral repossessed for settlement of impaired loans amounted to GEL 78.9 million (2018: 
GEL 30million; 2017: GEL 53 million). 

With regards to certain repossessed collateral, the Group has granted previous owners a right to repurchase the repossessed 
collateral  at prices equal to or higher than the carrying value of the loan at the date of repossession. This right is usually 
effective for a period of 6 to 24 months from the reporting date, during this time the repossessed collateral may not be 
disposed to third parties. As of 31 December 2019, the carrying value of the repossessed collateral subjected to the repurchase 
agreement was GEL 62,578 thousand (2018: GEL 44,024 thousand; 2017: GEL 11,170 thousand).

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

257

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

15. PREMISES, EQUIPMENT AND INTANGIBLE ASSETS

Land, Premises 
and leasehold 
improvements

Office and Other
equipment*

Construction in
progress

Total premises and 
equipment

Intangible 
Assets

Total

217,299

175,636

53,164

446,099

90,950 

 537,049

(30,349)

(101,718)

-

(132,067)

(29,993)

(162,060)

73,918
26,440

53,164
48,663

314,032
80,787

60,957
34,877

374,989
115,664

-

(11,326)

-

1,114
(11,962)

79

-

-
(88)

11

-

1,114
(12,050)

90

(782)
(25,663)

(1,916)
(10,436)

(2,698)
(36,099)

9,383

30

9,413

(75)

57

(18)

-
-

-

(46)
-

-

-

197,924

78,534

90,455

366,913

83,492

450,405

233,118

191,762

90,455

515,335

123,834

639,169

(35,194)

(113,228)

-

(148,422)

(40,342)

(188,764)

78,534

 46,619 
301

90,455

 8,538 
-

366,913

83,492

450,405

63,961
3,908

 42,525 
-

 106,486 
3,908

 -   

 (2,661)

 -   

 -   

 -   

 1,317 
(32,628)
 -   
 114 

 -   

 (4)
 -   

 1,317 
(32,628)
 (27,105)
 10,749 

 -   
-
 (603)
-

 1,317 
(32,628)
 (27,708)
 10,749 

 46 

 11 

 57 

 (499)
 (28,302)

 -   
 (16,257)

 (499)
 (44,559)

 348 

 8,783 

 -   

 9,131 

 58 

 9,189 

186,950
5,684

11,326

1,114
(2,324)

-
(9,638)

25

54

(6)
(5,567)

(730)
(20,096)

747

(25)

8,636

(50)

197,924

 8,804 
3,607

 2,661 

 -   
-
 (4,160)
 10,635 

 -   
-
 (22,945)
 -   

 23 

 23 

 (474)
 (5,754)

 (21)
 (22,548)

In thousands of GEL
Cost or valuation as of 1 January 
2017
Accumulated depreciation/
amortisation Including 
accumulated impairment loss
Carrying amount as of 1 January 
2017
Additions
Transfers within premises and 
equipment
Transfer from investment 
property
Disposals
Effect of translation to 
presentation currency -Cost
Impairment charge to profit and 
loss
Depreciation/amortisation charge
Elimination of accumulated 
depreciation/amortisation on 
disposals 
Effect of translation to 
presentation currency - 
Accumulated depreciation
Carrying amount as of 31 
December 2017

Cost or valuation as of 31 
December 2017
Accumulated depreciation/
amortisation including 
accumulated impairment loss
Carrying amount as of 31 
December 2017

Additions
Business combination
Transfers within premises and 
equipment
Transfer from investment 
property
Transfer to investment property
Disposals
Revaluation
Effect of translation to 
presentation currency - Cost
Impairment charge to profit and 
loss
Depreciation/amortisation charge

Elimination of accumulated 
depreciation/amortisation on 
disposals 

258

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

15. PREMISES, EQUIPMENT AND INTANGIBLE ASSETS CONTINUED

In thousands of GEL
Effect of translation to 
presentation currency - 
Accumulated depreciation
Carrying amount as of 31 
December 2018
Cost or valuation as of 31 
December 2018
Accumulated depreciation/
amortisation including 
accumulated impairment loss
Carrying amount as of 31 
December 2018
Additions
Business combination
Transfers within premises and 
equipment
Transfer from investment 
property
Transfer to Financial leases or 
repossessed assets
Disposals
Effect of translation to 
presentation currency - Cost
Impairment charge to profit and 
loss

Depreciation/amortisation charge
Elimination of accumulated 
depreciation/amortisation on 
disposals 
Effect of translation to 
presentation currency - 
Accumulated depreciation

Carrying amount as of 31 
December 2019
Cost or valuation as of 31 
December 2019
Accumulated depreciation/
amortisation including 
accumulated impairment loss
Carrying amount as of 31 
December 2019

Land, Premises 
and leasehold 
improvements

Note

Office and Other
equipment*

Construction in
progress

Total premises and 
equipment

Intangible 
Assets

Total

 (22)

 35 

 -   

 13 

 (6)

 7 

 213,592 

 88,781 

 65,131 

 367,504 

 109,220 

 476,724 

 254,214 

 215,739 

 65,131 

 535,084 

 165,767 

 700,851 

 (40,622)

 (126,958)

 -   

 (167,580)

 (56,547)

 (224,127)

 213,592 
 4,359 
 1,027 

 3,597 

 -   

45

17

 88,781 
 27,862 
 857 

 36 

 -   

 65,131 
 24,946 
 -   

 (3,633)

 367,504 
 57,167 
 1,884 

 109,220 
 70,319 
 4,782 

 476,724 
 127,486 
 6,666 

 1,817 

 1,817 

 -   

 -   

 -   

 -   

 1,817 

 -   
 (6,020)

 (1,439)
 (11,805)

 -   
 (4,785)

 (1,439)
 (22,610)

 -   
 (753)

 (1,439)
 (23,363)

 48 

 -   

 75 

 44 

 (5,761)

 (22,869)

 1,582 

 8,393 

 (48)

 (45)

 -   

 (6)

 -   

 -   

 -   

 123 

 38 

 23 

  -   

 146 

 38 

 (28,630)

 (16,604)

 (45,234)

 9,975 

 635 

 10,610 

 (93)

 (25)

 (118)

212,376

89,890

83,470

385,736

167,597

553,333

 257,340 

 232,071 

 83,470 

 572,881 

 240,468 

 813,349 

 (44,964)

 (142,181)

 -   

 (187,145)

 (72,871)

 (260,016)

212,376

89,890

83,470

385,736

167,597

553,333

 *Office and other equipment include furniture and fixtures, computer and office equipment, motor vehicles as well as other equipment.

The depreciation and amortisation charge presented on the face of the statement of profit or loss and other comprehensive 
income  include  depreciation  and  amortisation  charge  of  premises  and  equipment,  investment  properties  and  intangible 
assets. 

Construction in progress consists of construction and refurbishment of branch premises and the Bank’s new headquarters. 
Upon completion, assets are to be transferred to premises. 

The latest valuation date of premises to market value is 30 November 2018. The valuation was carried out by an independent 
firm of valuators which holds a recognised and relevant professional qualification and who have recent experience in valuation 
of  assets  of  similar  location  and  category.  In  the  process  of  comparison,  they  have  used  three  comparative  analogues 
(registered sale and/or offer for sale), in which prices were applied adjustments based on the difference between subject 
assets and analogues.  Most of the assets have been estimated by using the market approach/method due to the market 
situation, namely by existence of a sufficient number of registered sales and proposals by the date of valuation. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

259

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

15. PREMISES, EQUIPMENT AND INTANGIBLE ASSETS CONTINUED

The management considers that the fair value has not changed significantly between 30 November 2018 and 31 December 
2019.  Fair value of respective assets is disclosure below.

In thousands of GEL
(except for range of inputs)

Fair value as of 30 
November 2018 
(valuation date)

Valuation 
technique

Other key
 information

Unobservable
 inputs

Office buildings

Branches 

153,590

98,737

Sales comparison 
approach

Sales comparison 
approach

Land
Buildings
Land

Buildings

Price per square 
meter

Price per square 
meter

Range of
unobservable inputs  
(weighted average)
 287 – 10,274 (577)
 670 – 5,257 (2,715)
 7 – 4,057 (235)

337 – 12,911 (2,982)

Sensitivity of the input to fair value – increase/(decrease) in the price per square metre would result in increase/(decrease) 
in fair value.

As  of  31  December  2019  the  carrying  amount  of  premises  would  have  been  GEL  165,491  thousand  (2018:  GEL  166,707 
thousand; 2017: GEL 144,778 thousand) had the assets been carried at cost less depreciation and impairment losses. At 31 
December 2019 the carrying amount of construction in progress would have been GEL 60,581 thousand (2018: GEL 42,243 
thousand; 2017: GEL 67,033 thousand) had the assets been carried at cost less impairment losses.

16. RIGHT OF USE ASSETS AND LEASE LIABILITIES
The Group leases offices, branches and service centers. Rental contracts are typically made for fixed periods of 1 to 15 years. 

Until 31 December 2018 leases of premises were classified as operating leases. From 1 January 2019, leases are recognised 
as a right-of-use asset and a corresponding liability from the date when the leased asset becomes available for use by the 
Group. 

The right of use assets by class of underlying items is analysed as follows:

In thousands of GEL
Carrying amount at 1 January 2019
Additions
Disposals
Depreciation charge 
Carrying amount at 31 December 2019

Buildings
61,043
20,437
(8,476)
(13,311)
59,693

Total
61,043
20,437
(8,476)
(13,311)
59,693

Interest expense on lease liabilities was GEL 2,670 thousand.

Expenses relating to short-term leases (included in in administrative and other operating expenses) and to leases of low-
value assets that are not shown as short-term leases are included in in administrative and other operating expenses:

In thousands of GEL
Expense relating to short-term leases
Expense relating to leases of low-value assets that are not shown above as short-term leases

2019
7,388
6,154

Total cash outflow for leases in 2019 was GEL 16,066 thousand.

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 collateral for borrowings.

Extension  and  termination  options  are  included  in  a  number  of  property  leases  across  the  Group.  These  are  used  to 
maximise operational flexibility in terms of managing the assets used in the Group’s operations. The majority of extension 
and termination options held are exercisable only by the Group and not by the respective lessor.

260

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

17. INVESTMENT PROPERTIES

In thousands of GEL

Gross book value as of 1 January

Accumulated depreciation as of 1 January

Carrying amount as of 1 January
Transfer to premises and equipment
Transfer from repossessed collateral
Transfer to repossessed collateral
Addition from foreclosure
Disposals at cost
Elimination of depreciation on disposal
Depreciation charge
Acquisition through business combination
Transfer from Premises and equipment
Effect of translation to presentation currency
Gross book value as of 31 December
Accumulated depreciation as of 31 December
Carrying amount as of 31 December

Note

15

45

2019 

 86,884 

 (2,588)

84,296
(1,817) 
4,914 
-
47
(13,507)
717
(933)
-   
-   
(1,050)
 76,521 
 (3,854)
72,667

2018 

83,871

(4,639)

79,232
(1,317)
4,625
-
-
(36,080)
3,232
(1,181)
3,157
32,628
-
86,884
(2,588)
84,296

2017

99,347

(3,732)

95,615
(1,143)
752
(590)
943
(15,438)
259
(1,166)
-
-
-
 83,871 
 (4,639)
79,232

As of 31 December 2019, investment properties comprised of 63 lots (2018: 73 lots; 2017: 102lots) of land and 111 buildings 
(2018: 127 buildings; 2017: 144 buildings) located in Tbilisi and other regions of Georgia with the fair value amounting to GEL 
123,325 thousand (2018: GEL 97,425 thousand; 2017: GEL 85,012 thousand). 

For disclosure purposes a fair valuation exercise was carried out for investment properties as of 31 December 2019. The 
valuation in 2019 and 2018 was carried out by external valuators (in 2017 by internal valuators) who hold a recognised and 
relevant professional qualification and who have recent experience in valuation of assets of similar location and category. 
In the process of comparison, they have used three comparative analogues (registered sale and/or offer for sale), in which 
prices were applied adjustments based on the difference between subject assets and analogues.  Most of the assets have 
been estimated by using the market approach/method due to the market situation, particularly based on a sufficient number 
of registered sales and proposals by the date of valuation. 

In thousands of GEL (except for range of inputs)

Land

Buildings

Fair value as of 31 
December 2019 
(valuation date)

60,946

62,379

Valuation technique
Sales comparison 
approach
Sales comparison 
approach

Unobservable 
inputs
Price per 
square meter
Price per 
square meter

Range of unobservable 
inputs  (weighted average)

 0.80 – 974 (88)

3.92 – 4,098 (960)

Where the Group is the lessor, the future minimum lease payments receivable under non-cancellable operating leases, were 
as follows: 

In thousands of GEL
Not later than 1 year
Later than 1 year and not later than 5 years
Total operating lease payments receivable

18. GOODWILL

2019
207
230
437

2018
185
-
185

Movements in goodwill arising on the acquisition of subsidiaries are:

In thousands of GEL
Carrying amount as of 1 January
Acquisition of subsidiaries
Carrying amount as of 31 December

Note

45

2019
31,286
30,272
61,558

2018
28,658
2,628
31,286

2017
177
-
177

2017
28,658
-
28,658

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

261

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

18. GOODWILL CONTINUED

Goodwill Impairment Test 
Goodwill is allocated to cash-generating units (CGUs, which represent the lowest level within the Group at which the goodwill 
is monitored by Management and which are not larger than a segment) as follows:

In thousands of GEL
JSC Bank Republic*

Bank Republic Retail
Bank Republic Corporate
Bank Republic MSME
Bank Republic Other
LLC Bonaco
JSC Swoop 
CGU Micro
JSC United Financial Corporation

LLC TBC Kredit
JSC TBC Insurance
LLC Inspired (Note 45)
LLC F Solution LLC
LLC My.ge (Note 45)
LLC TKT.ge
Total carrying amount of goodwill

2019
24,166
11,088
7,491
4,791
796
2,567
61
769
695
1,262
1,766
14,015
270
15,812
175
61,558

2018
24,166
11,088
7,491
4,791
796
2,567
61
769
695
1,262
1,766
-
-
-
-
31,286

2017
24,166
11,088
7,491
4,791
796
-
-
769
695
1,262
1,766
-
-
-
-
28,658

*Due to the Bank Republic merger in 2017, carrying amount of goodwill was allocated across multiple CGU’s of the Bank, that also equal to the 
operating and reporting segments.

The recoverable amount of each CGU was determined based on value-in-use calculations. These calculations use cash flow 
projections based on financial budgets approved by the management covering a five-year period. Cash flows beyond the five-
year period are extrapolated using the estimated growth rates stated below.

In thousands of GEL
JSC Bank Republic** 
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
CGU SME / JSC Bank Constanta
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
JSC United Financial Corporation
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
LLC TBC Kredit
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
JSC TBC Insurance 
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
LLC Bonaco
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
LLC My.ge
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate
LLC Inspired
Growth rate beyond five years of Free Cash Flow to equity
Pre-tax discount rate

2019

2018

2017

4.64 p.a.
16.50% p.a.

4.64 p.a.
10.36 p.a.

4.64 p.a.
15.51% p.a.

2.7% p.a.
16.37% p.a.

4.64 p.a.
17.49% p.a.

4.64 p.a.
10.17% p.a.

4.64 p.a.
17.49% p.a.

5.5 p.a.
21.14% p.a.

5.54% p.a. 
20.27% p.a.

4.17% p.a. 
18.71% p.a.

5.54% p.a.
13.06% p.a.

4.17% p.a.
12.01% p.a.

5.54% p.a.
18.31% p.a.

4.17% p.a.
18.16% p.a.

1.3% p.a.
24.57% p.a.

1.3% p.a.
31.35% p.a.

5.54% p.a.
18.24% p.a.

4.17% p.a.
18.15% p.a.

-
-

-
-

-
-

-
-

-
-

-
-

**Assumptions related to JSC Bank Republic are similar for all related CGU’s.

262

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

18. GOODWILL CONTINUED

Goodwill Impairment Test (continued) The management determined the budgeted gross margin based on past performance 
and its market expectations. The weighted average long term growth rates used are consistent with the forecasts included in 
the industry reports. The discount rates reflect specific risks related to the relevant CGUs.

If the revised estimated pre-tax discount rate applied to the discounted cash flows of CGU Bank Republic Retail had been 
10 percentage points higher than the management’s estimates, the Group would not need to reduce the carrying value of 
goodwill or carrying value of net assets of the CGU. Recoverable amount of Bank Republic Retail CGU exceeds its carrying 
amount by GEL 3,068,466 thousand (2018: GEL 84,111 thousand; 2017: GEL 781,330 thousand). The CGU’s carrying amount 
would equal its value in use at a discount rate of 39.87% p.a. (2018: 21.77% p.a.; 2017: 29.92% p.a.).

If the revised estimated pre-tax discount rate applied to the discounted cash flows of CGU Bank Republic Corporate had 
been 10 percentage points higher than the management’s estimates, the Group would not need to reduce the carrying value 
of either goodwill or carrying value of net assets of the CGU. Recoverable amount of Bank Republic Retail CGU exceeds its 
carrying amount by GEL 2,316,056 thousand (2018: GEL 850,072 thousand; 2017: GEL 402,679 thousand). The CGU’s carrying 
amount would equal its value in use at a discount rate of 36.34% p.a. (2018: 38.86% p.a.; 2017: 27.97% p.a.).

If the revised estimated pre-tax discount rate applied to the discounted cash flows of CGU Bank Republic MSME had been 10 
percentage points higher than the management’s estimates, the Group would not need to reduce the carrying value of either 
goodwill or carrying value of net assets of the CGU. Recoverable amount of Bank Republic Retail CGU exceeds its carrying 
amount by GEL 1,210,045 thousand (2018: GEL 461,500 thousand; 2017: GEL 246,759 thousand). The CGU’s carrying amount 
would equal its value in use at a discount rate of 36.52% p.a. (2018: 35.83% p.a.; 2017: 27.11% p.a.).

If the revised estimated pre-tax discount rate applied to the discounted cash flows of CGU Micro/JSC Bank Constanta had 
been 10 percentage points higher than the management’s estimates, the Group would not need to reduce the carrying value 
of either goodwill or carrying value of net assets of the CGU (2018: nil; 2017: nil). Recoverable amount of CGU Micro/JSC 
Bank Constanta CGU exceeds its carrying amount by GEL 732,567 thousand (2018: GEL 913,325 thousand; 2017: GEL 440,075 
thousand). The CGU’s carrying amount would equal its value in use at a discount rate of 29.74% p.a. (2018: 48.53%   p.a.; 2017: 
34.60% p.a.).

If  the  revised  estimated  pre-tax  discount  rate  applied  to  the  discounted  cash  flows  of  JSC  United  Financial  Corporation 
had been 10 percentage points higher than the management’s estimates, the Group would not need to reduce the carrying 
value of goodwill or carrying value of net assets of the CGU (. Recoverable amount of JSC United Financial Corporation CGU 
exceeds its carrying amount by GEL 8,222 thousand (2018: GEL 13,458 thousand; 2017: GEL 17,866 thousand). The CGUs’ 
carrying amount would equal its value in use at a discount rate of 19.53% p.a. (2018: 29.8% p.a.; 2017: 39.27% p.a.)

If the revised estimated pre-tax discount rate applied to the discounted cash flows of LLC TBC Kredit had been 10 percentage 
points higher than the management’s estimates, the Group would not need to reduce the carrying value of goodwill (2018:nil; 
2017: nil). Recoverable amount of LLC TBC Kredit CGU exceeds its carrying amount by GEL 192,436 thousand (2018: GEL 
277,830 thousand; 2017: GEL 36,420 thousand). The CGUs’ carrying amount would equal its value in use at a discount rate 
134.64% of p.a.(2018: 132.34% p.a.; 2017: 119.51% p.a.).

If  the  revised  estimated  pre-tax  discount  rate  applied  to  the  discounted  cash  flows  of  JSC  TBC  Insurance  had  been  10 
percentage points higher than the management’s estimates, the Group would not need to reduce the carrying value of either 
goodwill or carrying value of net assets of the CGU (2018: nil; 2017: nil). Recoverable amount of JSC TBC Insurance CGU 
exceeds  its  carrying  amount  by  GEL  142,799  thousand  (2018:  GEL  208,095  thousand;  2017:  51,549).  The  CGU’s  carrying 
amount would equal its value in use at a discount rate of 62.29% p.a. (2018: 111.71% 2017: 63.63%).

If the revised estimated pre-tax discount rate applied to the discounted cash flows of LLC Bonaco had been 10 percentage 
points higher than the management’s estimates, the Group would not need to reduce the carrying value of either goodwill 
or carrying value of net assets of the CGU (2018: nil; 2017: nil). Recoverable amount of LLC Bonaco CGU exceeds its carrying 
amount by GEL 500,031thousand. The CGU’s carrying amount would equal its value in use at a discount rate of 49.45% p.a.

If the revised estimated pre-tax discount rate applied to the discounted cash flows of LLC My.ge had been 10 percentage 
points higher than the management’s estimates, the Group would not need to reduce the carrying value of either goodwill 
or carrying value of net assets of the CGU (2018: nil; 2017: nil). Recoverable amount of LLC My.ge CGU exceeds its carrying 
amount by GEL  48,629 thousand. The CGU’s carrying amount would equal its value in use at a discount rate of 35.31% p.a..

If the revised estimated pre-tax discount rate applied to the discounted cash flows of LLC Inspired had been 10 percentage 
points higher than the management’s estimates, the Group would not need to reduce the carrying value of either goodwill or 
carrying value of net assets of the CGU (2018: nil; 2017: nil). Recoverable amount of LLC Inspired CGU exceeds its carrying 
amount by GEL 22,965 thousand. The CGU’s carrying amount would equal its value in use at a discount rate of 37.65% p.a..

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

263

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

19. DUE TO CREDIT INSTITUTIONS

In thousands of GEL
Due to other banks
Correspondent accounts and overnight placements
Deposits from banks
Short-term loans from banks

Total due to other banks

Other borrowed funds
Borrowings from foreign banks and financial institutions
Borrowings from local banks and financial institutions
Borrowings from Ministry of Finance
Borrowings from other financial institutions
Total other borrowed funds
Total amounts due to credit institutions

2019 

2018

2017

 27,747 
 139,267 
-   

167,014

 2,005,900 
 1,378,995 
536
41,456 
3,426,887
3,593,901

23,273
136,161
-   
159,434

2,065,560
769,911
1,520
35,078
2,872,069
3,031,503

21,777
64,441
-
86,218

1,591,778
908,271
2,914
31,533
2,534,496
2,620,714

As of 31 December 2019 for the purposes of maturity analysis of financial liabilities (Note 37) the above-mentioned loans are 
included within the amounts for which repayment is expected within 3 months.

20. CUSTOMER ACCOUNTS

In thousands of GEL

State and public organisations
- Current/settlement accounts
- Term deposits
Other legal entities
- Current/settlement accounts
- Term deposits

Individuals
- Current/demand accounts
- Term deposits
Total customer accounts

2019 

2018 

2017 

 616,397 
 298,177 

 3,151,507 
 310,558 

 2,712,910 
 2,959,775 
10,049,324

667,553
538,311

2,791,092
251,215

2,426,597
2,677,374
9,352,142

 810,783 
 209,641 

 2,207,630 
 210,498 

 1,973,685
 2,404,580 
7,816,817

State and public organisations include government owned profit orientated businesses. 

Economic sector concentrations within customer accounts are as follows:

In thousands of GEL
Individual
Construction
Trade
Government sector
Transportation
Energy & Utilities
Financial Services
Services
Real Estate
Hotels and Leisure
Healthcare
Agriculture
Metals and Mining
Food Industry
Automotive
Communication
Other
Total customer accounts

31 December 2019

31 December 2018

 31 December 2017

Amount
5,672,685
596,703
741,385
505,494
308,268
322,331
288,860
446,876
322,416
110,816
98,294
50,915
12,264
-
-
-
572,017
10,049,324

%
56%
6%
7%
5%
3%
3%
3%
5%
3%
1%
1%
1%
0%
0%
0%
0%
6%
100%

Amount
5,103,971
613,973
550,527
531,964
422,281
397,653
394,336
360,084
207,227
102,529
76,464
35,884
12,479
- 
- 
- 
542,770
9,352,142

%
55%
7%
6%
6%
5%
4%
4%
4%
2%
1%
1%
0%
0%
0%
0%
0%
5%
100%

Amount
4,378,265
377,944
209,339
330,356
376,333
429,722
379,772
236,128
119,507
174,777
106,439
29,199
16,976
175,676
71,628
50,059
354,697
7,816,817

%
56%
5%
3%
4%
5%
5%
5%
3%
2%
2%
1%
0%
0%
2%
1%
1%
5%
100%

264

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

20. CUSTOMER ACCOUNTS CONTINUED

As of 31 December 2019 the Group had 359 customers (2018: 305 customers; 2017: 261 customers) with balances above GEL 
3,000 thousand. Their aggregate balance was GEL 4,327,035 thousand (2018: GEL 4,117,881 thousand; 2017: GEL 3,439,673 
thousand) or 43% of total customer accounts (2018: 44%; 2017: 44%). 

As of 31 December 2019 included in customer accounts are deposits of GEL 9,555 thousand and GEL 101,615 thousand (2018: 
GEL 6,766 thousand and GEL 158,306 thousand;  2017: GEL 11,040 thousand and GEL 120,406 thousand)  held as collateral 
for irrevocable commitments under letters of credit and guarantees issued, respectively. Refer to Note 38. As of 31 December 
2019, deposits held as collateral for loans to customers amounted to GEL 469,205 thousand (2018: GEL 270,787 thousand; 
2017: 224,899 thousand).

Refer to Note 42 for the disclosure of the fair value of each class of customer accounts. Information on related party balances 
is disclosed in Note 44.

21. DEBT SECURITIES IN ISSUE

In thousands of GEL
Bonds issued on Irish stock exchange 
Bonds issued on Irish stock exchange
Total debt securities in issue

Currency
USD
USD

Carrying amount in GEL 
as of 31 December 2019
842,471
371,127
1,213,598

In thousands of GEL
Bonds issued on Georgian stock exchange 
Bonds issued on Georgian stock exchange 
Total debt securities in issue

Currency
USD
USD

In thousands of GEL
Bonds issued on Georgian stock exchange 
Bonds issued on Georgian stock exchange
Bonds issued on Georgian stock exchange
Total debt securities in issue

Currency
USD
USD
USD

Carrying amount in GEL 
as of 31 December 2018
7,927
5,416
13,343

Carrying amount in GEL 
as of 31 December 2017
7,637
5,224
7,834
20,695

Maturity Date
19-Jun-24
3-Oct-24

Coupon rate Effective interest rate
6.4%
11.4%

5.8%
10.8%

Maturity Date
22-Jul-19
16-May-19

Coupon rate Effective interest rate
8.1%
8.7%

7.3%
8.0%

Maturity Date
22-Jul-19
16-May-19
15-Aug-18

Coupon rate Effective interest rate
8.1%
8.7%
8.6%

7.3%
8.0%
7.8%

Refer to Note 42 for the disclosure of the fair value of debt securities in issue.

On  19  June  2019  the  Bank  completed  the  transaction  of  a  debut  USD  300  million  5-year  5.75%  (6%  yield) 
senior  unsecured  bonds  issue  (the  “Notes”).  The  Notes  are  listed  on  the  regulated  market  of  Euronext  Dublin 
and  are  rated  Ba2  by  Moody’s  and  BB-  by  Fitch.  The  Notes  have  been  simultaneously  listed  on  JSC  Georgian 
Stock  Exchange,  making  it  the  first  dual-listed  international  offering  of  senior  unsecured  Notes  from  Georgia. 

On 3 July 2019 the Bank completed the transaction of a debut inaugural USD 125 million 10.75% yield Additional Tier 1 
Capital Perpetual Subordinated Notes issue (“AT1 Notes”). The AT1 Notes are listed on the regulated market of Euronext 
Dublin and are rated B- by Fitch. The AT1 Notes have been simultaneously listed on JSC Georgian Stock Exchange, making 
it the first dual-listed international offering of additional Tier 1 Capital Notes from Georgia.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

265

 
NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

22. PROVISION FOR PERFORMANCE GUARANTEES, CREDIT RELATED COMMITMENTS AND 
LIABILITIES AND CHARGES 
Movements in credit loss allowance for performance guarantees, credit related commitment and liabilities and charges 
are as follows:

In thousands of GEL
Carrying amount as of 1 January 2017
Charges less releases recorded in profit or loss
Assuming guarantees following asset purchase
Additions through Business Combinations
Carrying amount as of 31 December 2017
IFRS 9 transition effect
Carrying amount as of 1 January 2018
Charges less releases recorded in profit or loss
Effect of translation to presentation currency
Carrying amount as of 31 December 2018
Charges less releases recorded in profit or loss
Utilization of provision
Effect of translation to presentation currency
Carrying amount as of 31 December 2019

Performance 
guarantees
2,635
 (579)
-
11
2,067
684
2,751
1,640
2
4,393
          3,069
-
                  4
           7,466

Credit related 
commitments 
8,049
 190 
-
-
8,239
(4,661)
3,578
 1,846 
-
 5,424 
(913)
-
-
4,511

Other
5,342
(332)
 (2,116)
-
2,894
-
2,894
6,056
-
8,950
3,305
(1,104)
-
11,151

Total
16,026
(721)
 (2,116)
11
13,200
(3,977)
9,223
9,542
2
18,767
5,461
(1,104)
4
23,128

Credit related commitments and performance guarantees: Impairment allowance estimation methods differ for (i) letter of 
credits and guarantees and (ii) undrawn credit lines. 

For letter of credits and guarantees allowance estimation purposes the Bank applies the staged approach and classifies 
them in stage 1, stage 2 or stage 3. Significant stage 3 guarantees are assessed individually. Non-significant stage 3 as well 
as all stage 1 and stage 2 guarantees and letter of credits are assessed collectively using exposure, marginal probability of 
conversion, loss given default and discount factor. Amount of the expected allowance differs based on the classification of the 
facility in the respective stage. 

For impairment allowance assessment purposes for undrawn exposures the Bank distinguishes between revocable and 
irrevocable loan commitments. For revocable commitments the Bank does not create impairment allowance. As for the 
irrevocable undisbursed exposures the Bank estimates utilization parameter (which represents expected limit utilization 
percentage conditional on the default event) in order to convert off-balance part of the exposure to on-balance.

Once the respective on balance exposure is estimated, the Bank applies the same impairment framework approach as the 
one used for the respective type of on balance exposures.

Additions  less  releases  recorded  in  profit  or  loss  for  “Other”  provisions  does  not  include  gross  change  in  total  reserves 
for  insurance  claims  in  amount  of  GEL  2,040  thousand  (2018:  GEL  1,486  thousand;  2017:  GEL  1,621  thousand)  that  are 
included in net claims incurred. Additions less releases recorded in profit or loss for provision for impairment of credit related 
commitments include provision for insurance receivables in the amount of GEL 842 thousand (2018: GEL 570 thousand) that 
are included in charges less releases recorded in profit or loss for “Other” provision.

For the purpose of ECL measurement other guarantees balances are included in mainly Stage 1 or Stage 2. Refer to Note 
37 for the ECL measurement approach.

266

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

23. OTHER FINANCIAL LIABILITIES
Other financial liabilities comprise the following:

In thousands of GEL
Security deposits for net investments in lease 
Trade payables
Derivative financial liabilities
Debit or credit card payables
Insurance Contracts Liabilities
Other accrued liabilities
Total other financial liabilities

Note

41

2019 
  27,094  
 23,687 
  20,161
 13,259 
 7,613 
21,794 
113,608

2018
22,100
24,270
2,119
19,146
16,839
14,240
98,714

Refer to Note 42 for disclosure of the fair value of other financial liabilities. 

24. OTHER LIABILITIES
Other financial liabilities comprise the following:

In thousands of GEL
Accrued employee benefit costs
Taxes payable other than on income 
Advances received
Unearned insurance premium
Other
Total other liabilities

2019 
42,197
10,730
11,260
24,156
6,818
95,161

2018 
48,393
19,477
10,867
17,911
7,689
104,337

2017
20,647
31,497
575
10,567
10,992
17,475
91,753

2017 
42,497
14,180
10,350
14,221
3,192
84,440

All of the above liabilities are expected to be settled within twelve months after the year-end.

25. SUBORDINATED DEBT

As of 31 December 2019, subordinated debt comprised of:  

In thousands of GEL
Kreditanstalt für Wiederaufbau Bankengruppe
Kreditanstalt für Wiederaufbau Bankengruppe
Green for Growth Fund
European Fund for Southeast Europe
European Fund for Southeast Europe
Asian Development Bank (ADB)
Private lenders
Subordinated Bond
Global climate partnership fund
ResponsAbility SICAV (Lux) Microfinance Leaders
ResponsAbility SICAV (Lux) Financial inclusion fund
ResponsAbility Micro and SME finance fund
BlueOrchard Microfinance Fund
BlueOrchard Microfinance Fund
European Fund for Southeast Europe
Total subordinated debt

Grant Date Maturity Date
8-May-21
10-Jun-14
8-May-21
4-May-15
18-Dec-25
18-Dec-15
18-Dec-25
18-Dec-15
15-Mar-26
15-Mar-16
18-Oct-26
18-Oct-16
19-Dec-24
8-Jun-17
30-Nov-22
17-Aug-18
20-Nov-28
20-Nov-18
30-Nov-28
30-Nov-18
30-Nov-28
30-Nov-18
30-Nov-28
30-Nov-18
14-Dec-25
14-Dec-18
14-Dec-28
14-Dec-18
21-Dec-28
21-Dec-18

Outstanding 
amount in original 
currency 
 6,162 
 6,739 
 15,305 
 7,663 
 7,662 
 50,585
 25,218 
 10,101 
 25,089
 1,006 
 3,117
 5,935 
 14,924 
 14,920 
 20,074 

Currency
GEL
GEL
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD

Outstanding 
amount in GEL
 6,162 
 6,739 
 43,890 
 21,975 
 21,971 
 145,064 
 72,318 
 28,976 
 71,948 
 2,884 
 8,940 
 17,020 
 42,797 
 42,786 
 57,565 
 591,035 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

267

    
 
NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

25. SUBORDINATED DEBT CONTINUED

As of 31 December 2018, subordinated debt comprised of:

In thousands of GEL
Deutsche Investitions und Entwicklungsgesellschaft MBH
Nederlandse Financierings-Maatschappij Voor 
Ontwikkelingslanden N.V.
Kreditanstalt für Wiederaufbau Bankengruppe
Kreditanstalt für Wiederaufbau Bankengruppe
Green for Growth Fund
European Fund for Southeast Europe
European Fund for Southeast Europe
Asian Development Bank (ADB)
Private lenders
Subordinated Bond
Global climate partnership fund
ResponsAbility SICAV (Lux) Microfinance Leaders
ResponsAbility SICAV (Lux) Financial inclusion fund
ResponsAbility Micro and SME finance fund
BlueOrchard Microfinance Fund
BlueOrchard Microfinance Fund
European Fund for Southeast Europe
Total subordinated debt

Grant Date Maturity Date
15-Jun-20
26-Jun-13

Currency
USD

Outstanding 
amount in original 
currency 
 7,509 

Outstanding 
amount in GEL
 20,100 

19-Dec-13
10-Jun-14
4-May-15
18-Dec-15
18-Dec-15
15-Mar-16
18-Oct-16
30-Jun-17
17-Aug-18
20-Nov-18
30-Nov-18
30-Nov-18
30-Nov-18
14-Dec-18
14-Dec-18
21-Dec-18

15-Apr-23
8-May-21
8-May-21
18-Dec-25
18-Dec-25
15-Mar-26
31-Oct-26
30-Jun-23
30-Nov-22
20-Nov-28
30-Nov-28
30-Nov-28
30-Nov-28
14-Dec-25
14-Dec-28
21-Dec-28

USD
GEL
GEL
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD
USD

 29,213 
 6,161 
 6,737 
 15,312 
 7,666 
 7,665 
 50,617 
 25,218 
 10,109 
 25,111 
 1,007 
 3,121 
  5,943 
 14,916 
 14,915 
 20,049 

 78,191 
 6,161 
 6,737 
 40,983 
 20,520 
 20,516 
 135,482 
 67,497 
 27,057 
 67,211 
 2,695 
 8,354 
 15,906 
 39,923 
 39,923 
 53,663 
 650,919 

As of 31 December 2017, subordinated debt comprised of: 

In thousands of GEL
Deutsche Investitions und Entwicklungsgesellschaft MBH
Deutsche Investitions und Entwicklungsgesellschaft MBH
Nederlandse Financierings-Maatschappij Voor 
Ontwikkelingslanden N.V.
Kreditanstalt für Wiederaufbau Bankengruppe
Kreditanstalt für Wiederaufbau Bankengruppe
Green for Growth Fund
European Fund for Southeast Europe
European Fund for Southeast Europe
Asian Development Bank (ADB)
Private lenders
LC Opportunity fund (Thales)
Total subordinated debt

Grant Date Maturity Date
15-Jul-18
19-Feb-08
15-Jun-20
26-Jun-13

Currency
USD
USD

Outstanding 
amount in original 
currency 
 10,467 
 7,496 

Outstanding 
amount in GEL
  27,134
19,430

19-Dec-13
10-Jun-14
4-May-15
18-Dec-15
18-Dec-15
15-Mar-16
18-Oct-16
30-Jun-17
14-Jul-17

15-Apr-23
8-May-21
8-May-21
18-Dec-25
18-Dec-25
15-Mar-26
18-Oct-26
30-Jun-23
5-Dec-18

USD
GEL
GEL
USD
USD
USD
USD
USD
USD

 35,577 
 6,161 
 6,737 
 15,259 
 7,640 
 7,639 
 50,467 
 24,114 
 1,008 

  92,222
6,161
 6,737 
  39,554
19,805
19,802
130,822
62,508
  2,613
426,788

The debt ranks after all other creditors in case of liquidation.

Refer to Note 42 for the disclosure of the fair value of subordinated debt. Information on related party balances is disclosed 
in Note 44.

268

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

 
26. SHARE CAPITAL  

In thousands of GEL except for number of shares
As of 1 January 2017
Shares issued
Scrip dividend issued
Share exchange
As of 31 December 2017
Shares issued
Scrip dividend issued
Share exchange
As of 31 December 2018
Shares issued
Scrip dividend issued
As of 31 December 2019

Number of
ordinary shares
52,166,703
516,140
 146,903 
 102,121 
 52,931,867 
618,640
58,762
635,060
54,244,329
615,175
296,392
55,155,896

Share capital 
1,581
16
 5 
 3 
 1,605 
21
2
22
1,650
22
10
1,682

As  of  31  December  2019  the  total  authorised  number  of  ordinary  shares  was  55,155,896  shares  (31  December  2018: 
54,244,329 shares; 31 December 2017: 52,931,867 shares). Each share has a nominal value of one British Penny. All issued 
ordinary shares are fully paid and entitled to dividends.

Shares are held by employee benefit trust (EBT) for the purpose of future employee share based payments plan. The number 
of shares held by trust as at 31 December 2019 comprised 595,380. The EBT has waived its rights to receive dividends on 
such shares. 

On 21 March 2019, 615,175 new ordinary shares of TBC Bank Group PLC were admitted to the premium segment of the 
London Stock Exchange. The Offer Shares were issued pursuant to the terms of the TBC PLC group long term incentive plan 
and rank pari passu in all respects with TBC PLC’s existing ordinary shares.

On 24 June 2019, at the Annual General Meeting, TBC Bank Group PLC’s shareholders agreed on a dividend of GEL 1.98 
per share, based on the 2018 audited financial statements. The dividend was recorded respectively and on 12 July 2019 
shareholders received the payment of the total GEL 91,926 dividends. Scrip dividend shares amounted to 296,392 and were 
issued on 12th of July.

On 21 May 2018, at the Annual General Meeting, TBC Bank Group PLC’s shareholders agreed on a dividend of GEL 1.64 per 
share, based on the 2017 audited financial statements. The dividend was recorded on 24 May 2018 of amount GEL 88,869 
thousand and was paid on 22 June 2018 out of which scrip dividend shares amounted to 58,762 and were issued on 22th of 
June.

On 24 April 2018, 635,060 new ordinary shares of TBC Bank Group PLC were admitted to the premium segment of the London 
Stock Exchange. The Offer Shares were issued pursuant to the terms of a private offer to the holders of the ordinary shares 
of JSC TBC Bank who have tendered Bank shares pursuant to the Offer. The holders of Bank shares are individuals that did 
not participate in the tender offer to holders made in 2016 or 2017 by TBC Bank Group PLC. Holders of Bank shares received 
one Offer Share for each Bank Share tendered pursuant to the Offer.

On  8  March  2018,  618,640  new  ordinary  shares  of  TBC  Bank  Group  PLC  were  admitted  to  the  premium  segment  of  the 
London Stock Exchange. The Offer Shares were issued pursuant to the terms of the TBC PLC group long term incentive plan 
and rank pari passu in all respects with TBC PLC’s existing ordinary shares.

On 23 June 2017, 102,121 new ordinary shares of TBC Bank Group PLC were admitted to the premium segment of the London 
Stock Exchange. The Offer Shares were issued pursuant to the terms of a private offer to the holders of the ordinary shares of 
JSC TBC Bank who have tendered Bank shares pursuant to the Offer. The holders of Bank shares are individuals that did not 
participate in the tender offer to holders made in 2016 by TBC Bank Group PLC prior to TBC Bank Group PLC’s admission to 
the premium segment of the London Stock Exchange. Holders of Bank shares received one Offer Share for each Bank Share 
tendered pursuant to the Offer.

On 5 June 2017, at the Annual General Meeting TBC Bank Group PLC’s shareholders agreed on a dividend of GEL 1.42 per share, 
based on the 2016 audited financial statements. The dividend was recorded on 9 June 2017 of amount GEL 74,809 thousand and 
was paid on 14 July 2017 out of which scrip dividend shares amounted to 146,903 and were issued on 14th of July.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

269

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

27. SHARE BASED PAYMENTS

June 2015 arrangement: 
In June 2015, the Bank’s Supervisory Board approved management compensation scheme for the top and middle management 
and it accordingly authorised the issue of a maximum 3,115,890 new shares. The system was enforced from 2015 through 
2018. According to the scheme, each year, subject to predefined performance conditions, a certain number of shares were 
awarded to the Group’s top managers and most of the middle ones. The performance features key performance indicators 
(KPIs) divided into (i) corporate and (ii) individual. The corporate KPIs are mainly related to achieving profitability, efficiency, 
and portfolio quality metrics set by the Board as well as non-financial indicators with regards to customers’ experience and 
employees’ engagement. The individual performance indicators are set on an individual basis and are used to calculate the 
number of shares to be awarded to each employee. According to the scheme, members of top management also received the 
fixed number of shares.  Once awarded, all shares carry service conditions and, before those conditions are met, are eligible 
to dividends; however they cannot be sold or transferred to third parties.  

Service conditions foresee continuous employment until the gradual transfer of the full title to the scheme participants is 
complete. Shares for each of the 2015, 2016, 2017 and 2018 tranche gradually ran over on the second, third and fourth year 
following the performance appraisal. Eighty percent of the shares are vested in the fourth year after being awarded. Under 
this compensation system the total vesting period extends to March 2022. 

In 2015 the Group considered 17 June as the grant date. Based on the management’s estimate of reached targets, as of 31 
December 2015 1,908,960 shares were granted. The shares were gradually awarded to the members as per the described 
scheme. At the grant date the fair value amounted to GEL 24.64 per share, as quoted on the London Stock Exchange.

Following the listing on the Premium segment of the London Stock Exchange, the share-based payment scheme remained 
conceptually the same and was only updated to reflect the Group’s new structure, whereby TBC Bank Group PLC distributes 
its shares to the scheme’s participants, instead of JSC TBC Bank. The respective shares’ value is recharged to JSC TBC Bank. 
As a result, the accounting of the scheme did not change in the consolidated financial statements.

The Bank also payed personal income tax on behalf of equity settled scheme beneficiaries, which was accounted as cash 
settled part. 

The share based payment scheme for middle management and other eligible employees continues under existing terms for 
2019-2020.

December 2018 arrangements:
The new compensation system was approved by shareholders at the AGM on 21 May 2018 and came into effect on 1 January 
2019. On 28 December 2018, the Board of Directors approved following new compensation schemes for the top management 
and group considers that as a grant date.  Arrangements are discussed in below paragraphs:

Deferred share salary plan
Part of the top management salary is given in the form of shares and despite being salary, is still intended to promote the 
long-term success of the Group by closely aligning executive  directors’  and shareholders’ interests.   The new system is 
enforced  from  January  2019  through  2021.  Shares  are  usually  delivered  during  the  first  quarter  of  the  second  year  (i.e. 
the year after the work is performed) and the exact date is determined by the Remuneration Committee. Once shares are 
delivered, they remain subject to continued employment; 50% of the shares for 1 year and the other 50% for 2 years from 
the delivery date. Upon the delivery, whilst the shares remain subject to the continued employment condition, the shares are 
registered in the trustees name as nominee for the participants and the participants are entitled to receive dividends.

Where applicable, deferred share salary is paid in part under the executive director’s service contract with TBC JSC and in 
part under his service contract with TBC PLC, to reflect the executive director’s duties to each. Initial salaries are set by the 
Remuneration Committee based on responsibilities and market data and are set out in a directors’ service contracts with the 
Group. Deferred compensation is subject to the Group’s malus and clawback policies until the shares are vested and during 
the holding period. If at any time after making the deferred compensation there is a material misstatement in the financial 
results for the year in respect of which the compensation was formally granted, the Remuneration Committee has the right 
to cause some or all of the deferred compensation for that year or any subsequent financial year that is unvested (or unpaid) 
to lapse (or not be paid).

The number of shares is calculated based on the average share price of the last 10 days preceding the committee decision 
date. The bank pays income tax and other employee-related taxes related to the award, however, taxes are included in the 
maximum amounts.

270

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

27. SHARE BASED PAYMENTS CONTINUED

Deferred Bonus plan
The annual bonus for the top management is determined as to the extent that the annual KPIs have been met. The new 
system is enforced from January 2019 through 2021. Shares are usually delivered during the first quarter of the second year 
(i.e. the year after the work is performed) and the exact date is determined by the remuneration committee. Once shares are 
delivered, they remain subject to continued employment; 50% of the shares for 1 year and the other 50% for 2 years from 
the delivery date. Upon the delivery, whilst the shares remain subject to the continued employment condition the shares are 
registered in the trustees name as the nominee for the participants and the participants are entitled to receive dividends.

KPIs are set by the Remuneration Committee at the beginning of each year in relation to that year. To the extent that the 
KPIs  are  achieved,  the  Remuneration  Committee  may  decide  whether  an  award  may  be  made  and  the  amount  of  such 
award. The Group does not pay guaranteed bonuses to executive directors. The nature of the KPIs (but not necessarily their 
specific weightings) will be disclosed in the annual report published in the performance year. However, the precise targets 
are commercially sensitive and will be disclosed retrospectively. Awards are subject to the Group’s malus and clawback 
policies until the shares are vested and during the holding period. If at any time after making the award there is a material 
misstatement in the financial results for the year in respect of which the award was formally granted, the Remuneration 
Committee has the right to cause some or all of the award for that year or any subsequent financial year that is unvested (or 
unpaid) to lapse (or not be paid).

The number of shares is calculated based on the average share price of the last 10 days preceding the committee decision 
date. The bank pays income tax and other employee-related taxes related to the award, however, taxes are included in the 
maximum amounts.

Long Term Incentive Plan (LTIP) 
Long term incentive plan is used to provide a strong motivational tool to achieve long term performance conditions and to provide 
rewards to the extent those performance conditions are achieved. Performance conditions are chosen to align our executive 
directors’ interests with strategic objectives of the Group over multi-year periods and encourage a long-term view. In order for 
the shares to be delivered, the executive directors need to meet performance conditions over the 3 year performance period. 
The new system will be enforced from 2021 through 2023. Shares are usually delivered during the first quarter of the fourth year 
(i.e. the year after the performance period ends) and the exact date is determined by the remuneration committee. Once shares 
are delivered, they remain subject to 2 year holding period and continued employment requirements. An award holder shall 
have no voting rights, or rights to receive dividends, in respect of a conditional share award before such award becomes a vested 
award. The awards may be granted in the form of conditional share awards, options or restricted share awards. Performance 
Conditions are set by the Remuneration Committee for a period of 3 years. The Remuneration Committee determines the 
level of award at the end of the performance period, based on the extent to which the performance conditions have been met. 
Awards are subject to the Group’s malus and clawback policies until three years after the shares are delivered. If at any time 
after making the award the award holder deliberately mislead the Company or the Bank in relation to the financial performance, 
there is a material misstatement (or material error) in the financial statements of the Company or the Bank, the award holder’s 
unit has suffered a material downturn in its financial performance caused by the award holder, there is misconduct on the part 
of the award holder that caused material harm to the Company’s or the Bank’s reputation or there is misconduct on the part 
of the award holder that caused failure of the risk management resulting in a material loss to the Company or the Bank, the 
Remuneration Committee has the right to cause some or all of the award for that year or any subsequent financial year that 
is unvested (or unpaid) to lapse (or not be paid) and to clawback any amount that has already been paid. For newly issued and 
treasury shares, the LTIP is limited to using 10% in 10 years for employee plans and 5% in 10 years for discretionary plans. 
These limits will exclude shares under awards that have been renounced, forfeited, released, lapsed or cancelled or awards 
that were granted prior to the Company’s IPO or awards that the Remuneration Committee decide will be satisfied by existing 
shares.

The number of shares is calculated based on the average share price during the 10 days after the preliminary annual results 
of the year preceding the year of each grant is announced. The bank pays income tax and other employee-related taxes 
related to the award, however, taxes are included in the maximum amounts.

The performance conditions for the award are set by the Committee each year. The Remuneration Committee’s current view 
is that performance conditions will include: 1) a measure of efficiency (e.g. ROE) 2) a measure of share price performance 
(e.g. EPS/TSR) 3) a measure of customer experience Weightings of these measures may vary year-on-year.The performance 
period is three year.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

271

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

27. SHARE BASED PAYMENTS CONTINUED

Tabular information on both of the schemes is given below:

In GEL except for number of shares
Number of unvested shares at the beginning of the period
Number of shares granted
Change in estimates of number of shares
expected to be granted**
Change in estimate of number of shares expected to vest based on 
performance conditions
Number of shares vested
Number of unvested shares at the end of the period
Value at grant date per share according to
June 2015 scheme (GEL)
Value at grant date per share (GEL) middle management and other 
eligible employees plan
Value at grant date per share (GEL) Deferred share salary plan
Value at grant date per share (GEL) Deferred bonus plan
Value at grant date per share (GEL) LTIP*
Expense on equity-settled part (GEL thousand)
Expense on cash-settled part (GEL thousand)
Expense recognised as staff cost during the period (GEL thousand)

31 December 2019
2,121,129
1,613,101

31 December 2018
  2,284,773  
-

31 December 2017
2,622,707
-

(57,058)

(16,501)
(519,130)
3,141,541

    24.64

50.16
50.16
50.16
50.16
33,798
59
33,857

-

-

166,377
(330,021)
2,121,129

(13,100)
(324,834)
2,284,773

  24.64

-
-
-
-
11,668
8,424
20,092

  24.64

-
-
-
-
10,543
5,119
15,662

*Grant date for LTIP plan has been determined for the first award tranche only, which is planned in 2021. For remaining tranches 
expense is accrued based on estimated fair value during the future grant date.
** The maximum amount is fixed for deferred share compensation for top management, the exact number will be calculated as per 
policy. 

Liability in respect of the cash-settled part of the award amounted to GEL 3,160 thousand as of 31 December 2019 (31 
December 2018: GEL 11,001 thousand; 31 December 2017: GEL 12,675 thousand). Tax part of the new bonus system for 
the top management is accounted under equity settled basis.

Staff costs related to equity settled part of the share based payment schemes are recognised in the income statement 
on a straight line basis over the vesting period of each relevant tranche and corresponding entry is credited to share 
based payment reserve in equity.

On 31 December 2019 based on level of achievement of key performance indicators the management has reassessed 
the number of shares that will have to be issued to the participants of the share based payment system and decreased 
estimated number of shares to vest by 16,501 (31 December 2018: increased by 166,377 shares; 31 December 2017: 
decreased by 13,100 shares).

In 2019 the Group established employee benefit trust (EBT) set up Executive Equity Compensation Trustee – Sanne 
Fiduciary  Services  Limited  (the  “Trustee”)  which  acts  as  the  trustee  of  the  Group’s  share  based  payments  plan.  It 
purchases Group’s shares from the open market and holds them before they are awarded to participants and vesting 
date is due. The number of shares to be purchased and held are instructed by the Group. The shares are presented as 
treasury shares under Shares held by trust category in the Statement of Financial Position until they are awarded to 
participants. As at 31 December 2019 the share number held by Trustee was 595,380. 

272

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

28. EARNINGS PER SHARE 

Basic earnings per share are calculated by dividing the profit or loss attributable to the owners of the Bank by the weighted 
average number of ordinary shares in issue during the year.

In thousands of GEL except for number of shares
Profit for the period attributable to the owners of the Bank
(excluding the profit attributable to the shares encumbered
under the share based payment scheme) 
Weighted average number of ordinary shares in issue  
Basic earnings per ordinary share attributable
to the owners of the Bank (expressed in GEL per share)

2019

2018

2017

537,895
54,684,038

435,080
53,906,472

354,410
52,685,702

9.8

8.1

6.7

Diluted earnings per share are calculated by dividing the profit or loss attributable to owners of the Bank by the weighted 
average number of ordinary shares adjusted for the effects of all dilutive potential ordinary shares during the year. Ordinary 
shares with dilutive potential represent those shares that were granted to the participants of the share based payments 
scheme and are not yet distributed.

In thousands of GEL except for number of shares
Profit for the period attributable to the owners of the Bank
(excluding the profit attributable to the shares encumbered
under the share based payment scheme)
Weighted average number of ordinary shares in issue adjusted for the effects
of all dilutive potential ordinary shares during the period 
Diluted earnings per ordinary share attributable
to the owners of the Bank (expressed in GEL per share)

2019

2018

2017

537,895

435,080

354,410

55,129,444

54,415,642

53,480,632

9.8

8.0

6.6

29. SEGMENT ANALYSIS

The Board of Directors is the chief operating decision maker and it reviews the Group’s internal reporting in order to assess 
the performance and to allocate resources. In 2019 the Group made the re-segmentation after which some of the clients 
were reallocated to different segments – GEL 166 million of loans and customers amount was transferred from MSME to 
Corporate segment. In the tables below is disclosed the information as of 31 December 2019 both with and without re-
segmentation effect.

The operating segments in 2019 and 2018 are determined as follows:
 ` Corporate – legal entity/group of affiliated entities with an annual revenue exceeding GEL 12.0 million or who have been 
granted facilities    with more than GEL 5.0 million. Some other business customers may also be assigned to the corporate 
segment or transferred to MSME on a discretionary basis;

 ` Retail – non-business individual customers; all individual customers are included in retail deposits;
 ` MSME – Business customers who are not included in either corporate or legal entities who have been granted a Pawn 

shop loan; or individual customers of the newly-launched fully-digital bank, Space;

 ` Corporate centre and other operations - comprises of the Treasury, other support and back office functions, and non-

banking subsidiaries of the Group. 

The operating segments during the year  2017 were as follows:
 ` Corporate – all business customers with an annual revenue of GEL 8.0 million or more or who have been granted a loan in 
an amount equivalent to USD 1.5 million or more. Some other business customers may also be assigned to the Corporate 
segment on a discretionary basis;

 ` Micro, small and medium enterprises  – all business customers who are not included in Corporate segment; Some other 

customers may also be assigned to the MSME segment on a discretionary basis;

 ` Retail – all individual customers not included in the other categories;
 ` Corporate Centre and Other Operations – comprises of the Treasury, other support and back office functions, and non-

banking subsidiaries of the Group.

The Board of Directors assesses the performance of the operating segments based on a measure of adjusted profit before 
income tax. 

The reportable segments are the same as the operating segments.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

273

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

29. SEGMENT ANALYSIS CONTINUED 

No revenue from transactions with a single external customer or counterparty amounted to 10% or more of the Group’s total 
revenue in 2019, 2018 or 2017.

The vast majority of the entity’s revenues are attributable to Georgia. A geographic analysis of origination of the Group’s 
assets and liabilities is given in Note 37.

Allocation is performed based on drivers identified for each type of cost if possible. If there is no identifiable driver for any type 
of expense/overhead cost, those expenses are allocated between segments based on the same logic as applied for the most 
related  expenses to it (e.g. other operating expenses would follow the pattern of closest category of operating expenses).

A summary of the Group’s reportable segments for the years ended 31 December 2019, 2018 and 2017 is provided below: 

Per new segmentation:

Inter-segment interest income(expense)

In thousands of GEL
31 December 2019
Interest income
 -
 -
interest expense
 - Net gains on currency swaps 
 -
Net interest income
 - Fee and commission income
 - Fee and commission expense
Net Fee and commission income
 -
 - Net gains from trading in foreign currencies
 - Net gains from foreign exchange translation 
 - Net losses from derivative financial instruments
 - Gains less losses from disposal of

Insurance Profit

investment securities measured at FVOCI

 - Other operating income
 - Share of profit of associates
Other operating non-interest income
 - Credit loss allowance for loans to customers
 - Credit loss allowance for performance 

guarantees and credit related commitments

 - Credit loss allowance for
net investments in lease

 - Credit loss allowance for other financial assets
 - Credit loss allowance for financial assets 

measured at FVOCI

Profit before administrative and other expenses 
and income taxes
 - Staff costs
 - Depreciation and amortisation
 - Provision for liabilities and charges
 - Administrative and other operating expenses
 - Operating expenses
 - Profit/(loss) before tax
 -
 - Profit for the year

Income tax  (expense)/credit

Total gross loans and advances 
to customers reported
Total customer accounts reported
Total credit related commitments
and performance guarantees

274

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

356,652
(160,064)
-
31,352
227,940
49,338
(7,069)
42,269
-
49,851
-
-

-
2,953
-
52,804
3,261

582,788
(152,751)
-
(66,951)
363,086
207,258
(88,679)
118,579
-
30,990
-
(264)

-
9,563
-
40,289
(77,323)

(2,691)

411

-
2,211

(141)

325,653
(38,360)
(2,571)
-
(17,127)
(58,058)
267,595
(29,048)
238,547

-
(3,545)

-

441,497
(134,143)
(45,522)
-
(77,563)
(257,228)
184,269
(18,101)
166,168

299,451
(10,202)
-
(101,424)
187,825
26,271
(9,081)
17,190
-
24,220
-
-

-
1,093
-
25,313
(7,968)

124

-
(11)

-

222,473
(48,018)
(7,210)
-
(21,094)
(76,322)
146,151
(14,825)
131,326

197,952
(340,843)
28,556
137,023
22,688
10,564
(1,312)
9,252
18,510
(25,782)
22,188
(16)

169
5,307
632
21,008
-

1,436,843
(663,860)
28,556
-
801,539
293,431
(106,141)
187,290
18,510
79,279
22,188
(280)

169
18,916
632
139,414
(82,030)

-

(2,156)

582
(6,753)

582
(8,098)

(149)

(290)

46,628
(27,282)
(4,175)
(1,264)
(26,397) 
(59,118)
(12,490)
16,790
4,300

1,036,251
(247,803)
(59,478)
(1,264)
(142,181)
(450,726)
585,525
(45,184)
540,341

4,660,473
3,187,319

5,053,203
5,673,917

2,948,279
1,188,088

- 12,661,955
- 10,049,324

2,451,769

205,433

302,648

-

2,959,850

29. SEGMENT ANALYSIS CONTINUED

Per old segmentation:

Inter-segment interest income(expense)

In thousands of GEL
31 December 2019
Interest income
 -
 -
interest expense
 - Net gains on currency swaps
 -
Net interest income
 - Fee and commission income
 - Fee and commission expense
Net Fee and commission income
 -
 - Net gains from trading in foreign currencies
 - Net losses from foreign exchange translation 
 - Net losses from derivative financial instruments
 - Gains less losses from disposal of investment 

Insurance Profit

securities measured at fair value 
through other comprehensive income

 -
 - Other operating income
 - Share of profit of associates
Other operating non-interest income
 - Credit loss allowance for loans to customers
 - Credit loss allowance for performance 

guarantees and credit related commitments

 - Credit loss allowance for net

investments in lease

 - Credit loss allowance for other financial assets
 - Credit loss allowance for financial assets 

measured at fair value through OCI

Profit before administrative and other expenses 
and income taxes
 - Staff costs
 - Depreciation and amortisation
 - Provision for liabilities and charges
 - Administrative and other operating expenses
 - Operating expenses
 - Profit/(loss) before tax
 -
Income tax expense
 - Profit for the year

Total gross loans and advances 
to customers reported
Total customer accounts reported
Total credit related commitments
and performance guarantees

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

 344,107 
 (159,088)
 -   
 31,352 
 216,371 
 48,516 
 (7,069)
 41,447 
  -  
 51,671 
  -  
  -  

 582,788 
 (152,751)
 -   
 (66,951)
 363,086 
 207,258 
 (88,679)
 118,579 
  -  
 30,990 
  -  
 (264)

  -  
 2,953 
  -  
 54,624 
 3,261 

  -  
 9,563 
  -  
 40,289 
 (77,323)

 (2,691)

 411 

 - 
 2,211 

 (141)

 - 
 (3,545)

 - 

 315,082 
 (38,471)
 (2,571)
  -  
 (17,313)
 (58,355)
256,727
 (29,020)
227,707

 441,497 
 (135,842)
 (45,522)
  -  
 (83,486)
 (264,850)
 176,647 
 (17,371)
 159,276 

 311,996 
 (11,178)
 -   
 (101,424)
 199,394 
 27,093 
 (9,081)
 18,012 
  -  
 22,400 
  -  
  -  

  -  
 1,093 
  -  
 23,493 
 (7,968)

 124 

 - 
 (11)

 - 

 233,044 
 (48,546)
 (7,210)
  -  
 (22,993)
 (78,749)
154,295
 (14,593)
139,702  

 197,952 
 (340,843)
 28,556 
 137,023 
 22,688 
 10,564 
 (1,312)
 9,252 
 18,510 
 (25,782)
 22,188 
 (16)

 1,436,843 
 (663,860)
 28,556 
 -   
 801,539 
 293,431 
 (106,141)
 187,290 
 18,510 
 79,279 
 22,188 
 (280)

 169 
 5,307 
 632 
 21,008 
 - 

 169 
 18,916 
 632 
 139,414 
 (82,030)

 - 

 (2,156)

 582 
 (6,753)

 582 
 (8,098)

 (149)

 (290)

 46,628 
 (24,944)
 (4,175)
 (1,264)
 (18,389)
 (48,772)
 (2,144)
 15,800 
 13,656 

 1,036,251 
 (247,803)
 (59,478)
 (1,264)
 (142,181)
 (450,726)
 585,525 
 (45,184)
 540,341 

 4,494,349 
 3,100,953 

 5,053,203 
 5,672,602 

 3,114,403 
 1,275,769 

 -     12,661,955 
 -     10,049,324 

 2,451,769 

 205,433 

 302,648 

 -   

 2,959,850 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

275

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

29. SEGMENT ANALYSIS CONTINUED

In thousands of GEL
31 December 2018
Interest income
 -
interest expense
 -
 -
Inter-segment interest income(expense)
Net interest income
 - Fee and commission income
 - Fee and commission expense
Net Fee and commission income
 -
 - Net gains/(losses) from trading in foreign 

Insurance Profit

currencies

 - Net gains from foreign exchange translation 
 - Net gains/(losses) from derivative financial 

instruments

 - Gains less losses from disposal of

investment securities measured at fair value 
through other comprehensive income

 - Other operating income
 - Share of profit of associates
Other operating non-interest income
 - Credit loss allowance for loans to customers
 - Credit loss allowance for performance 

guarantees and credit related commitments

 - Credit loss allowance for
net investments in  lease

 - Credit loss allowance for other financial assets
 - Credit loss allowance for financial assets 
measured a fair value through other 
comprehensive income

Profit before administrative and other expenses 
and income taxes
 - Staff costs
 - Depreciation and amortisation
 - Provision for liabilities and charges
 - Administrative and other operating expenses
 - Operating expenses
 - Profit before tax
 -
 - Profit for the year

Income tax expense

Total gross loans and advances 
to customers reported
Total customer accounts reported

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

264,559
(133,302)
35,531
166,788
40,667
(6,661)
34,006
-

609,989
(123,729)
(78,453)
407,807
170,082
(64,270)
105,812
-

44,629
-

28,811
-

255,833
(9,710)
(83,475)
162,648
22,498
(6,861)
15,637
-

22,002
-

153,854
(239,472)
126,397
40,779
2,454
(379)
2,075
12,275

1,284,235
(506,213)
-
778,022
235,701
(78,171)
157,530
12,275

(3,764)
15,196

91,678
15,196

-

(223)

-

396

173

-
19,691
-
64,320
(9,826)

-
8,658
-
37,246
(118,043)

(2,827)

(412)

-
(8,634)

-
(3,959)

(95)

-

243,732
(30,266)
(2,226)
-
(12,616)
(45,108)
 198,624 
(29,907)
168,717

428,451
(128,957)
(36,745)
-
(90,329)
(256,031)
 172,420 
(22,898)
149,522

-
748
-
22,750
(15,854)

(247)

-
(2)

-

184,932
(43,385)
(4,980)
-
(21,184)
(69,549)
 115,383 
(17,250)
98,133

2
2,341
1,154
27,600
-

2
31,438
1,154
151,916
(143,723)

(570)

(4,056)

(1,765)
(4,014)

(1,765)
(16,609)

9

(86)

64,114
(17,746)
(1,789)
(4,000)
(16,806)
(40,341)
 23,773 
(2,710)
21,063

921,229
(220,354)
(45,740)
(4,000)
(140,935)
(411,029)
 510,200 
(72,765)
437,435

3,177,289
3,230,653

4,698,699
5,103,971

2,496,594
1,017,518

- 10,372,582
9,352,142
-

276

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

29. SEGMENT ANALYSIS CONTINUED

In thousands of GEL
31 December 2017
Interest income
 -
interest expense
 -
 -
Inter-segment interest income(expense)
 - Net interest income
Fee and commission income
 -
 -
Fee and commission expense
Net Fee and commission income
 -
 - Net gains/(losses)  from trading in foreign 

Insurance Profit

currencies

 - Net gains from foreign exchange translation 
 - Net losses from derivative financial instruments
 - Net gains from disposal of available for sale 

investment securities
Other operating income
 -
 -
Share of profit of associates
Other operating non-interest income
Provision for loan impairment
 -
Provision for  performance guarantees and 
 -
credit related commitments
Provision for impairment of net investments in 
lease
Provision for impairment of other financial 
assets

 -

 -

Profit before administrative and
other expenses and income taxes
 -
 -
 -
 -
 -
 -
 -
 -

Staff costs
Depreciation and amortisation
Provision for liabilities and charges
Administrative and other operating expenses
Operating expenses
Profit/(loss) before tax
Income tax (expense)/credit
Profit for the year

Total gross loans and advances 
to customers reported
Total customer accounts reported
Total credit related commitments
and performance guarantees

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

203,082
(103,707)
22,489
121,864
30,037
(6,942)
23,095
-

38,885
-
-

-
13,465
-
52,350
27,031

183

-

535,851
(118,516)
(73,141)
344,194
140,582
(51,199)
89,383
-

22,597
-
-

-
12,670
-
35,267
(106,579)

(261)

-

 (7,666)

 (17)

 216,857
(25,989)
(1,438)
-
(7,457)
(34,884)
 181,973 
 (27,738)
 154,235 

 361,987 
(128,331)
(29,813)
-
(81,356)
(239,500)
 122,487 
 (15,527)
 106,960 

184,008
(11,661)
(51,488)
120,859
20,335
(8,949)
11,386
-

26,885
-
-

-
1,726
-
28,611
(14,275)

467

-

 (64)

 146,984 
(31,225)
(4,972)
-
(15,118)
(51,315)
 95,669 
 (13,820)
 81,849 

2,475,392
2,410,862

4,233,153
4,378,265

1,844,672
1,027,690

1,160,517

229,178

199,662

110,998
(196,040)
102,140
17,098
2,990
(893)
2,097
6,773

1,033,939
(429,924)
-
604,015
193,944
(67,983)
125,961
6,773

(1,268)
4,374
(36)

93
3,936
909
 14,781 
-

(542)

(492)

87,099
4,374
(36)

93
31,797
909
 131,009 
(93,823)

(153)

(492)

 (4,692)

(12,439)

 28,250 
(17,555)
(1,042)
2,495
(17,599)
(33,701)
 (5,451)
 22,335 
 16,884 

754,078
(203,100)
(37,265)
2,495
(121,530)
(359,400)
394,678
(34,750)
359,928

-
-

-

8,553,217
7,816,817

1,589,357

In thousands of GEL
31 December 2019
 - Fee and commission income
 - Other operating income
Total
Timing of revenue recognition:
 - At point in time
 - Over time

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

 49,338 
 2,952 
 52,290 

 207,258 
 9,563 
 216,821 

 52,262 
 28 

 215,341 
 1,480 

 26,271 
 1,093 
 27,364 

 27,359 
 5 

 10,564 
 5,308 
 15,872 

 293,431 
 18,916 
 312,347 

 15,872 
-

 310,834 
 1,513 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

277

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

29. SEGMENT ANALYSIS CONTINUED

In thousands of GEL
31 December 2018
 - Fee and commission income
 - Other operating income
Total
Timing of revenue recognition:
 - At point in time
 - Over time

Corporate

Retail

Micro, small and 
medium enterprises

Corporate centre and
other operations

Total 

40,667
19,691
60,358

56,397
3,961

170,082
8,658
178,740

160,555
18,185

22,498
748
23,246

22,950
296

2,454
2,341
4,795

4,790
5

235,701
31,438
267,139

244,692
22,447

Reportable segments’ assets were reconciled to total assets as follows:

In thousands of GEL 
Total segment assets (gross loans and advances to customers)
Credit loss allowance (provision for loan impairment for comparatives)
Cash and cash equivalents
Mandatory cash balances with National Bank of Georgia
Due from other banks
Investment securities measured at fair value
through other comprehensive income
Investment securities available for sale (comparatives only)
Bonds carried at amortised cost
Current income tax prepayment
Deferred income tax asset
Other financial assets
Net investments in leases
Other assets
Premises and equipment
Intangible assets
Investment properties
Goodwill 
Right of use assets (Net) 
Investments in Associates
Total assets per statement of financial position

31 December 2019
12,661,955
(312,556)
1,003,583
1,591,829
33,605

31 December 2018
10,372,582
(334,130)
1,166,911
1,422,809
47,316

31 December 2017
8,553,217
(227,864)
1,431,477
1,033,818
39,643

985,293
-
1,022,684
                 25,695 
                    2,173 
               133,736 
               256,660 
               255,712 
               385,736 
167,597
                 72,667 
61,558
                 59,693 
2,654
18,410,274

1,005,239
-
654,203
2,116
2,097
167,518
203,802
192,792
367,504
109,220
84,296
31,286
-
2,432
15,497,993

-
657,938
449,538
19,084
2,855
146,144
143,836
156,651
366,913
83,492
79,232
28,658
-
1,278
12,965,910

Reportable segments’ liabilities are reconciled to total liabilities as follows:

In thousands of GEL 
Total segment liabilities (customer accounts)
Due to credit institutions
Debt securities in issue
Current  income tax liability
Deferred income tax liability
Provisions for liabilities and charges
Other financial liabilities
Other liabilities
Subordinated debt
Total liabilities per statement of financial position

31 December 2019
10,049,324
3,593,901
1,213,598
  1,634
21,331
23,128
173,506
95,161
591,035
      15,762,618

31 December 2018
 9,352,142 
 3,031,503 
 13,343 
 63 
 22,237 
18,767 
 98,714 
104,337
 650,919 
13,292,025

31 December 2017
7,816,817
2,620,714
20,695
447
602
13,200
91,753
84,440
426,788
11,075,456

278

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

30. INTEREST INCOME AND EXPENSE

In thousands of GEL 

2019

2018

2017

Interest income calculated using effective interest method
Loans and advances to customers
Bonds carried at amortised cost 
Investment securities available for sale

Investment securities measured at fair value through OCI
Due from other banks
Other financial assets
Other interest income
Investments in leases
Total interest income
Interest expense
Customer accounts
Due to credit institutions
Subordinated debt
Debt securities in issue
Other interest expense
Lease liabilities
Other

Total interest expense

Net gains on currency swaps
Net interest income

1,225,196
58,682
-

74,043
29,570
1,418

47,934
1,436,843

320,379
226,899
63,693
50,248

2,670
 (29)

663,860

28,556
801,539

1,123,972
40,625
-

57,057
23,744
-

38,837
1,284,235

266,741
196,498
41,571
1,403

-
-

506,213

-
778,022

919,796
32,328
43,735

-
 14,807
-

 23,273 
1,033,939

233,884
157,122
36,975
1,943

-
-

429,924

-
604,015

In the year ended 31 December 2019 the interest accrued on impaired loans amounted to GEL 14,372 thousand (2018: 41,373 
thousand; 2017: 16,332 thousand).

In 2019, the Group entered into swap agreements denominated in foreign currencies in order to decrease its cost of funding. 
As the contracts reached significant volume, the Group revisited the presentation of effects in the Statement of profit or loss. 
2018 information has not been restated due to immateriality of amounts.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

279

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

31. FEE AND COMMISSION INCOME AND EXPENSE

In thousands of GEL 
Fee and commission income
Fee and commission income in respect of financial instruments
not at fair value through profit or loss:

 - Card operations
 - Settlement transactions
 - Guarantees issued
 - Cash transactions
 - Issuance of letters of credit
 - Foreign exchange operations
 - Other

Total fee and commission income
Fee and commission expense
Fee and commission expense in respect of financial instruments
not at fair value through profit or loss:

 - Card operations
 - Settlement transactions
 - Cash transactions
 - Guarantees and letters of credit received
 - Self-service and point of service (POS) terminal transactions
 - Other

Total fee and commission expense
Net fee and commission income

32. OTHER OPERATING INCOME

In thousands of GEL 
Gain from sale of investment properties
Revenues from operational leasing
Warrant option
Gain from sale of repossessed collateral
Revenues from sale of cash-in terminals
Revenues from non-credit related fines
Gain on disposal of premises and equipment
Gain from sale of receivables 
Reimbursement of taxes
Gain from marketing promotional services
Other  
Total other operating income

2019

2018

2017

 138,620 
  86,967
  28,701  
 13,211 
  5,215
 2,841 
 17,876
293,431

82,583
13,739
4,732
3,627
31
1,429
106,141
187,290

2019
938
3,046
-
2,755
926
344
2,440
-
-
-
8,467
18,916

106,067
70,720
19,815
17,147
6,463
2,183
13,306
235,701

55,893
8,669
5,180
2,863
34
5,532
78,171
157,530

2018
9,781
6,544
2,677
2,577
1,715
683
352
225
-
-
6,884
31,438

82,525
59,739
15,121
17,424
5,735
1,339
12,061
193,944

46,360
7,421
4,393
2,873
6,436
500
67,983
125,961

2017
4,353
6,544
-
2,383
1,093
1,408
1,017
4,090
2,486
2,077
6,346
31,797

Revenue from operational leasing is wholly attributable to investment properties. The carrying value of the repossessed 
collateral disposed in the year ended 31 December 2019 was GEL 32,306 thousand (2018: GEL 33,295 thousand; 2017: GEL 
24,284 thousand).

280

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

33. STAFF COSTS 

In thousands of GEL 
Salaries and bonuses
Share based compensation 
Other compensation cost  
Salaries and other employee benefits

2019
201,344
33,857
12,602
247,803

2018
190,304
20,092
9,958
220,354

2017
 182,784
 15,662 
 4,654 
203,100

In  2019  the  monthly  average  number  of  persons  employed  by  the  Group  was  7,262  people  (2018:  7,170;  2017:  6,993). 
Breakdown of monthly average number of employees by categories is as follows: 

In thousands of GEL 
Headquarters*

Branches* 
Other administrative staff **

2019
2,924

3,638
700

2018
2,837

3,824
509

2017
2,788

3,773
432

*  Under  monthly  average  number  of  employees  in  headquarters  and  branches  employees  in  JSC  TBC  Bank,  JSC  Bank 
Republic, JSC TBC Insurance, Bank Constanta JSC and LLC TBC Kredit’s are considered.

** Employees from other subsidiaries are considered under other administrative staff.   

In 2019 monthly average number of employees in TBC PLC was 10 individuals (2018: 10; 2017: 10).

34. ADMINISTRATIVE AND OTHER OPERATING EXPENSES

In thousands of GEL 
Advertising and marketing services
Rent*
Professional services
Intangible asset enhancement
Taxes other than on income
Utility services
Premises and equipment maintenance

Communications and supply
Stationery and other office expenses
Insurance
Business trip expenses
Transportation and vehicle maintenance
Security services
Personnel training and recruitment
Charity
Loss on disposal of premises and equipment
Loss on disposal of inventories
Impairment of intangible assets
Write down of current assets to fair value less cost to sell
Reversal of previously written-down current assets
to fair value less costs to sell
Other
Total administrative and other operating expenses 

2019
22,634
13,541
25,865
12,885
6,962
6,874
9,828

5,960
5,167
1,660
2,612
2,140
2,035
3,120
1,990
938
1,310
 - 
2,545

(815)
14,930
142,181

2018
 29,575 
 24,389 
 13,951 
 11,366 
 6,757 
 6,491 
 6,098 

 5,173 
 4,841 
 4,589 
 2,273 
 2,043 
 2,040 
 1,880 
 1,074 
 860 
 137 
 1 
567

 (1,593)
 18,423 
140,935

2017
 18,430 
 23,132 
 14,332 
 10,304 
 5,670 
 6,067 
 5,413 

 4,063 
 4,936 
 2,461 
 2,021 
 1,637 
 1,965 
 1,444 
 1,045 
 492 
 1,239 
 1,916 
2

 (540)
 15,501 
121,530

*2019 information is reported under IFRS 16 and is not comparable with information presented for 2018 and 2017, which 
irs reported under IAS 17.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

281

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

34. ADMINISTRATIVE AND OTHER OPERATING EXPENSES CONTINUED

Auditors’ remuneration is included within professional services expenses above and comprises:

In thousands of GEL
2019
Fees payable to the company’s auditors and its associates for the audit of 
parent company and consolidated financial statements
Audit of the financial statements of the company’s subsidiaries
Audit-related assurance services
Other assurance services
Total auditors’ remuneration

2018
Fees payable to the company’s auditors and its associates for the audit of 
parent company and consolidated financial statements
Audit of the financial statements of the company’s subsidiaries
Audit-related assurance services
Other assurance services
Total auditors’ remuneration

2017
Fees payable to the company’s auditors and its associates for the audit of 
parent company and consolidated financial statements
Audit of the financial statements of the company’s subsidiaries
Audit-related assurance services
Other assurance services
Total auditors’ remuneration

Audit  Audit Related

Other Services

Total

 1,427 
248   
 -   
 -   
 1,675 

1,894 
241
-
-
2,135 

1,145 
296
-
-
1,441 

 -   
  - 
 561 
 -   
 561 

-
- 
310 
-
310 

-
- 
213 
-
213 

 -   
 -   
 -   
864 
864 

-
-
-
97 
97 

-
-
-
 196 
 196 

 1,427 
 248 
 561 
864 
3,100 

1,894 
241 
310 
97 
 2,542 

1,145 
296 
213 
 196 
 1,850 

Fees presented in the tables above are exclusive of taxes. As of 31 December 2019, GEL 1,125 thousands is attributable to 
reporting accountant fees related to listing of debt securities on the Irish stock exchange. 

35. INCOME TAXES

Income tax expenses comprises of the following: 

In thousands of GEL 
Current tax charge
Deferred tax (credit)/charge 
Total income tax expense for the year

2019
46,166
(982)
45,184

2018
52,914
19,851
72,765

2017
39,313
(4,563)
34,750

The income tax rate applicable to the majority of the Group’s income was 15% (2018: 15%; 2017: 15%). The income tax rate 
applicable to the majority of subsidiaries income ranged from 15% to 20% (2018: 15% - 20%; 2017: 15% - 20%). 

Reconciliation between the expected and the actual taxation charge is provided below.

In thousands of GEL 
Profit before tax
Theoretical tax charge at statutory rate
(2019: 15%-20%; 2018: 15%-20%; 2017: 15%-20%)
Tax effect of items which are not deductible
or assessable for taxation purposes:

 - Income which is exempt from taxation

 - Non-deductible expenses

 - Effect of change in tax legislation

 - Other differences

Total income tax expense for the year

282

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

2019
585,525

2018
510,200

2017
394,678

87,829

76,500

59,119 

(19,318)

(2,083)

(20,757)

(487)
45,184

(16,869)

(746)

13,833

47
72,765

(12,958)

(117)

(11,794)

500 
34,750 

35. INCOME TAXES CONTINUED

Differences between IFRS as adopted by the EU and statutory taxation regulations in Georgia and Azerbaijan give rise to 
temporary differences between the carrying amount of assets and liabilities for financial reporting purposes and their tax 
bases. The tax effect of the movements in these temporary differences is detailed below and is recorded at the rate of 15% 
(2018: 15%; 2017: 15%) for Georgia and 20% for Azerbaijan and United Kingdom (2018: 20%; 2017: 20%).

Income which is exempt from taxation includes interest income from placements in NBG, Georgian government Treasury 
bills and IFI securities. Non-deductible expenses include penalties paid and charity expenses towards beneficiary which are 
not registered charity organizations.

On 13 May 2016 the Government of Georgia enacted the changes in the Tax Code of Georgia effective from 1 January 2019, for 
commercial banks, credit unions, insurance organizations, microfinance organizations and pawnshops and from 1 January 
2017  for  other  entities.  However,  during  2018  Georgian  Government  changed  transition  date  to  1  January  2023.The  new 
code impacts the recognition and measurement principles of the Group’s income tax and it also affects the Group’s deferred 
income tax assets/liabilities. Companies do not have to pay income tax on their profit before tax (earned since 1 January 2017 
or 1 January 2023 for commercial banks, credit unions, insurance organizations, microfinance organizations and pawnshops) 
until that profit is distributed in a form of dividend or other forms of profit distributions. Once dividend is paid, 15% income tax 
is payable at the moment of the dividend payment, regardless of whether in monetary or non-monetary form, to the foreign 
non-resident legal entities and foreign and domestic individuals. The dividends paid out to the resident legal entities are tax 
exempted. Apart from dividends’ distribution, the tax is still payable on expenses or other payments incurred not related 
to economic activities, free delivery of goods/services and/or transfer of funds and representation costs that exceed the 
maximum amount determined by the Income Tax Code of Georgia, in the same month they are incurred. 

As of 31 December 2019, deferred tax assets/liabilities are re-measured to the amounts that are estimated to be utilized in 
the period from 1 January 2020 to 31 December 2022.

In thousands of GEL
Tax effect of deductible/(taxable) temporary 
differences and tax loss carry forwards
Premises and equipment
Loan to customers
Other financial assets
Due to credit institutions
Subordinated debt
Other financial liabilities
Other liabilities
Share based payment
Net deferred tax asset/(liability)
Recognised deferred tax asset
Recognised deferred tax liability
Net deferred tax asset/(liability)

1 January 2019 

(Credited)/
 Charged to
profit or loss 

Charged directly to 
other comprehensive 
income

31 December 2019

(23,202)
2,866
2,421
(3,641)
(70)
(41)
864
663
 (20,140)
 2,097 
 (22,237)
 (20,140)

9,386
(11,688)
2,300
1,155
70
833
(2,664)
1,590
 982 
 76 
 906 
 982 

-
-
-
-
-
-
-
-
-
-
-
-

(13,816)
(8,822)
4,721
(2,486)
-
792 
(1,800)
2,253
(19,158)
 2,173 
 (21,331)
(19,158)

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

283

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

35. INCOME TAXES CONTINUED

In thousands of GEL
Tax effect of deductible/(taxable) temporary 
differences and tax loss carry forwards
Premises and equipment
Loan to customers
Other financial assets
Other assets
Investment property
Due to credit institutions
Subordinated debt
Other financial liabilities
Other liabilities
Share based payment
Tax loss carried forward
Net deferred tax asset/(liability)
Recognised deferred tax asset
Recognised deferred tax liability
Net deferred tax asset/(liability)

In thousands of GEL
Tax effect of deductible/(taxable) temporary 
differences and tax loss carry forwards
Premises and equipment
Loan impairment provision
Fair valuation of AFS
Other financial assets
Other assets
Investment property
Due to credit institutions
Subordinated debt
Other financial liabilities
Other liabilities
Share based payment
Tax loss carried forward
Net deferred tax asset/(liability)
Recognised deferred tax asset
Recognised deferred tax liability
Net deferred tax asset/(liability)

1 January 2018 

(Charged)/
credited to profit or 
loss 

Charged directly to 
other comprehensive 
income

31 December 2018 

 (4,298)
2,401 
2,266
29
 (342)
 (816)
 (23)
 (72)
 1,651 
 1,486 
 (29)
2,253
 2,855 
 (602)
2,253

(16,460)
417
301
(29)
342
(2,825)
(47)
31
(787)
(823)
29
(19,851)
(659)
(19,192)
(19,851)

(2,444)
-
-
-
-
-
-
-
-
-
-
(2,444)
-
(2,444)
(2,444)

(23,202)
2,866
2,421
-
-
(3,641)
(70)
(41)
864
663
-
(20,140)
2,097
(22,237)
(20,140)

1 January 2017 

(Credited)/
 Charged to profit or 
loss 

Charged directly to 
other comprehensive 
income

31 December 2017 

 (5,323)
 (92)
 165 
 2,368 
 39 
 (982)
 (1,295)
 (85)
 197 
 2,226 
 676 
 (29)
 (2,135)
 3,511 
 (5,646)
 (2,135)

 648 
 2,400 
 483 
 (104)
 (10)
 640 
 479 
 62 
 (269)
 (575)
 810 
 -   
 4,563 
 (753)
 5,316 
 4,563 

 377 
 -   
 (648)
 -   
 -   
 -   
 -   
 -   
 -   
 -   
 -   
 -   
 (271)
-
 (271)
 (271)

 (4,298)
 2,401 
 -   
2,266
29
 (342)
 (816)
 (23)
 (72)
 1,651 
 1,486 
 (29)
 2,253 
 2,855 
 (602)
 2,253 

In the context of the Group’s current structure and Georgian tax legislation, tax losses and current tax assets of different group 
companies may not be offset against current tax liabilities and taxable profits of other group companies and, accordingly, 
taxes may accrue even where there is a consolidated tax loss. Therefore, deferred tax assets and liabilities are offset only 
when they relate to the same taxable entity and the same taxation authority.

284

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

36. RECONCILIATION OF LIABILITIES ARISING FROM FINANCING ACTIVITIES

The table below sets out movements in the Group’s liabilities from financing activities for each of the periods presented. The 
items of these liabilities are those that are reported as financing activities in the statement of cash flows.

In thousands of GEL
Liabilities from financing activities 
at 1 January 2017
Cash flows
Foreign exchange adjustments 
Other non-cash movements 
Liabilities from financing activities 
at 1 January 2018
Cash flows
Foreign exchange adjustments 
Other non-cash movements 
Liabilities from financing activities 
at 31 December 2018
Adoption of IFRS 16, Leases
Liabilities from financing activities 
at 1 January 2019
Cash flows
Foreign exchange adjustments 
Other non-cash movements 
Liabilities from financing activities 
at 31 December 2019

Other
borrowed funds 

Debt
Securities in Issue

Subordinated
debt 

Lease
liabilities

Liabilities from financing activities

1,880,670
 519,289 
 (13,266)
 147,803 

2,534,496
 79,390 
 70,883
 187,300 

 2,872,069
-

 2,872,069 
222,395
 122,591 
209,832

23,508
 (3,251)
 (1,505)
 1,943 

20,695
 (9,308)
 554
 1,402 

13,343 
-

 13,343 
 1,160,729
 37,362
 2,164 

368,381
 22,837 
 (765)
 36,335 

426,788
 171,781 
 9,958
42,392

 650,919 
-

 650,919 
 (167,847) 
 45,533 
 62,430 

-
-
-
-

-
-
-
-

-
61,043

61,043
 (21,417) 
 4,108 
 16,164 

Total 

2,272,559
 538,875 
 (15,536)
 186,081 

2,981,979
 241,863 
 81,395
 231,094 

 3,536,331
61,043

3,597,374
  1,193,860
 209,594 
290,590 

 3,426,887

 1,213,598 

 591,035 

59,898

 5,291,418 

37. FINANCIAL AND OTHER RISK MANAGEMENT

TBC Bank Group’s strong risk governance reflects the importance placed by the Board and the Group’s Risks, Ethics and 
Compliance Committee on shaping the risk strategy and managing credit, financial and non-financial risks. All components 
necessary for comprehensive risk governance are embedded into risk organization structure: enterprise risk management; 
credit, financial and non-financial risks management; risk reporting & supporting IT infrastructure; cross-risk analytical 
tools and techniques such as capital adequacy management and stress-testing. Comprehensive, transparent and prudent 
risk governance facilitates understanding and trust from multiple stakeholders, ensures sustainability and resiliency of the 
business model and positioning of risk management as Group’s competitive advantage and strategic enabler. 

The TBC Bank Group’s governance structure ensures adequate oversight and accountabilities as well as clear segregation 
of duties. The Risks, Ethics and Compliance Committee is responsible for taking all the day-to-day decisions relating to the 
Group apart from those that are reserved for the Board. Namely, the committee carries out following duties: 1) Review and 
assessment of the Group’s risk management strategy, risk appetite and tolerance, risk management system and risk policies; 
2) Review and monitoring of the processes for compliance with laws, regulations and ethical codes of practice; 3) monitoring 
of the remediation of internal control deficiencies identified by internal and external auditors around compliance, ethics and 
risk management functions; 4) Annual self-assessment of the committee’s performance and reporting of the results to the 
Board; 5) Review of the key risk management framework and other policy documents and make recommendations to the 
Board for their approval. 

On the Bank level, risk management is the duty of the Supervisory Board, which has the overall responsibility to set the tone 
at the top and monitor compliance with established objectives. At the same time, Management Board governs and directs 
Groups’ daily activities. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

285

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

Both  the  Supervisory  Board  and  the  management  Board  have  established  dedicated  risk  committees.  Risk,  Ethics  and 
Compliance Committee of Supervisory Board approves Bank’s Risk Appetite, supervises risk profile and risk governance 
practice within the Bank while Audit Committee is responsible for implementation of key accounting policies and facilitation 
of activities of internal and external auditors. Management Board Risk Committee is established to guide group-wide risk 
management activities and monitor major risk trends to make sure risk profile complies with the established Risk Appetite 
of  the  Group.  Operational  Risk  Committee  makes  decisions  related  to  operational  risk  governance  while  Asset-Liability 
Management Committee (“ALCO”) is responsible for implementation of ALM policies. 

The  Board,  the  Supervisory  Board  and  Senior  Management  govern  risk  objectives  through  Risk  Appetite  Statement  (“RAS”) 
which sets desired risk profile and respective risk limits for different economic environments. Risk Appetite (“RA”) establishes 
monitoring and reporting responsibilities as well as escalation paths for different trigger events and limit breaches which as well 
prompt risk teams to establish and implement agreed mitigation actions. In order to effectively implement Risk Appetite in the 
Group’s day-to-day operations, the RA metrics are cascaded into more granular business unit level limits. That way risk allocation 
is established across different segments and activities. The Board level oversight coupled with the permanent involvement of 
the Senior Management in TBC Group risk management ensures the clarity regarding risk objectives, intense monitoring of risk 
profile against risk appetite, prompt escalation of risk-related concerns and establishment of remediation actions. 

The daily management of individual risks is based on the principle of the three lines of defense. While business lines are 
primary risk owners, risk teams assume the function of the second line defense. This role is performed through sanctioning 
transactions as well as tools and techniques for risk identification, analysis, measurement, monitoring and reporting. The 
committees are established at operational levels in charge of making transaction-level decisions that comprise of component 
of clear and sophisticated delegations of the authority framework based on “four-eye principle”. All new products/projects go 
through the risk teams to assure risks are analyzed comprehensively.  

Such control arrangements guarantee that the Bank takes informed risk-taking decisions that are adequately priced, avoiding 
taking risks that are beyond the Group’s established threshold. Within the Risk Organization the below teams manage the 
credit, liquidity, market, operational and other non-financial risks:

 ` Enterprise Risk Management (ERM);
 ` Credit Risk Management;
 ` Underwriting (Credit sanctioning);
 ` Restructuring and Collections;
 ` Financial Risk Management;
 ` Operational Risk Management.

The strong and independent structure enables fulfillment of all the required risk management functions within the second 
line of defense by highly skilled professionals with a balanced mix of credentials in banking and real sectors both on the local 
and international markets. 

In  addition  to  the  above-mentioned  risk  teams,  the  Compliance  Department  (reporting  directly  to  CEO)  is  specifically  in 
charge of AML and compliance risk management. As the third line of defense, the Internal Audit Department provides an 
independent and objective assurance and recommendations to Group that facilitates further improvement of operations and 
risk management. 

For the management of each significant risk, the Bank puts in place specific policies and procedures, governance tools 
and techniques, methodologies for risk identification, assessment and quantification. Sound risk reporting systems and IT 
infrastructure are important tools for efficient risk management of TBC Bank. Thus, significant emphasis and investments 
are made by the Bank to constantly drive the development of required solutions. Comprehensive reporting framework is in 
place for the Management Board, the Supervisory Board and the Board that enables intense oversight over risk developments 
and taking early remedial actions upon necessity. 

Beyond the described risk governance components, compensation system features one of the most significant tools for 
introducing incentives for staff, aligned with the Bank’s long term interests to generate sustainable risk-adjusted returns. 
The risk Key Performance Indicators (“KPIs”) are incorporated into both the business line and the risk staff remunerations. 
The performance management framework differentiates risk staff incentives to safeguard the independence from business 
areas  that  they  supervise  and  at  the  same  time  enable  attraction  and  maintenance  of  qualified  professionals.  For  that 
purpose, the Bank overweighs risk KPIs for risk and control staff and caps the share of variable remuneration. 

286

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Credit risk. The Group is exposed to credit risk, which is the risk that a customer or counterparty will be unable to meet its 
obligation to settle outstanding amounts. The Group’s exposure to credit risk arises as a result of its lending operations and 
other transactions with counterparties giving rise to financial assets. Maximum exposure to credit risk of on-balance sheet 
items equals their carrying values. For maximum exposure on off-balance sheet commitments refer to Note 38. 

Credit risks include: risks arising from transactions with individual counterparties, concentration risk, currency-induced 
credit risks and residual risks.

 ` Risks arising from transactions with individual counterparties are the loss risk related to default or non-fulfillment of 

contracts due to deterioration in the counterparty’s credit quality;

 ` Concentration risk is the risk related to the quality deterioration due to large exposures provided to single borrowers or 

a group of connected borrowers, or loan concentration in certain economic industries;

 ` Currency-induced credit risks relate to risks arising from foreign currency-denominated loans in the Group’s portfolio;
 ` Residual risks result from applying credit risk-mitigation techniques, which could not satisfy expectation in relation to 

received collateral.

Comprehensive  risk  management  methods  and  processes  are  established  as  part  of  the  Group’s  risk  management 
framework  to  manage  credit  risk  effectively.  The  main  principles  for  Group’s  credit  risk  management  are:  establish  a 
prudent credit risk environment; operate under a sound credit-granting process; and maintain efficient processes for credit 
risk identification, measurement, control and monitoring. Respective policies and procedures establish a framework for 
lending decisions reflecting the Group’s tolerance for credit risk. This framework includes detailed and formalised credit 
evaluation  and  collateral  appraisal  processes,  administration  and  documentation,  credit  approval  authorities  at  various 
levels,  counterparty  and  industry  concentration  limits,  and  clearly  defined  roles  and  responsibilities  of  entities  and  staff 
involved in the origination, monitoring and management of credit.  

Credit Approval: The Group strives to ensure a sound credit-granting process by establishing well-defined credit granting 
criteria and building up an efficient process for the comprehensive assessment of a borrower’s risk profile. The concept of 
three lines of defense is embedded in the credit risk assessment framework, with a clear segregation of duties among the 
parties involved in the credit assessment process.

The credit assessment process differs across segments, being further differentiated across various product types reflecting 
the different natures of these asset classes. Corporate, SME and larger retail and micro loans are assessed on an individual 
basis with thorough analysis of the borrower’s creditworthiness and structure of the loan; whereas smaller retail and micro 
loans are mostly assessed in an automated way applying respective scoring models for the loan approval. Lending guidelines 
for business borrowers have been tailored to individual economic sectors, outlining key lending criteria and target ratios 
within each industry.

The Loan Approval Committees are responsible to review the credit applications and approve the credit products. Different 
Loan  Approval  Committees  with  clearly  defined  delegation  authority  are  in  place  for  the  approval  of  credit  exposures  to 
Corporate, MSME and Retail customers (except those products which are assessed applying scorecards).  The composition 
of  a  Loan  Approval  Committee  depends  on  aggregated  liabilities  of  the  borrower  and  the  borrower’s  risk  profile.  Credit 
risk managers (as members of respective Loan Approval Committees) ensure that the borrower and the proposed credit 
exposure risks are thoroughly analysed. A loan to the Bank’s top 20 borrowers or exceeding 5% of the Bank’s regulatory 
capital  requires  the  review  and  the  approval  of  the  Supervisory  Board’s  Risk,  Ethics  and  Compliance  Committee.  This 
committee also approves transactions with related parties resulting in exposures to individuals and legal entities exceeding 
GEL 150 and 200 thousand, respectively.

Credit Risk Monitoring: The Group’s risk management policies and processes are designed to identify and analyse risk in 
a timely manner, and monitor adherence to predefined limits by means of reliable and timely data. The Group dedicates 
considerable resources to gain a clear and accurate understanding of the credit risk faced across various business segments. 
The Group uses a robust monitoring system to react timely to macro and micro developments, identify weaknesses in the 
credit portfolio and outline solutions to make informed risk management decisions. Monitoring processes are tailored to the 
specifics of individual segments, as well as they encompass individual credit exposures, overall portfolio performance and 
external trends that may impact the portfolios risk profile. Early warning signals serve as an important early alert system for 
the detection of credit deteriorations, leading to mitigating actions.

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

Complex monitoring system is in place for monitoring of individual counterparties with frequency of monitoring depending 
on the borrower’s risk profile and exposure. Based on the results of the monitoring borrowers are classified across different 
risk categories. In case there are certain weaknesses present, which if materialized may lead to loan repayment problems, 
borrowers are classified as “watch” category. Although watch borrowers’ financial standing is sufficient to repay obligations, 
these borrowers are closely monitored and specific actions are undertaken to mitigate potential weaknesses. Watch category is 
used as one of the qualitative indicators for transferring of exposures to stage 2 for the corporate and SME borrowers. For retail 
and micro borrowers along with other portfolio level indicators, portfolio breakdown across risk categories is monitored on a 
regular basis. In case there are indicators that portfolio distribution across risk categories deteriorates above the predefined 
threshold it might trigger transferring the respective portfolio to stage 2, as long as deterioration signs are in place.

Reports  relating  to  the  credit  quality  of  the  credit  portfolio  are  presented  to  the  Board’s  Risk,  Ethics  and  Compliance 
Committees on a quarterly basis. By comparing current data with historical figures and analysing forecasts, the management 
believes that it is capable identifying risks and responding to them by amending its policies in a timely manner.

Credit Risk Mitigation: Credit decisions are based primarily on the borrower’s repayment capacity and creditworthiness; in 
addition, the Group uses credit risk mitigation tools such as collateral and guarantees to reduce the credit risk. The reliance 
that can be placed on these mitigation factors is carefully assessed for legal certainty and enforceability, market valuation of 
collateral and counterparty risk of the guarantor. 

A centralised unit for collateral management governs the Group’s view and strategy in relation to collateral management 
and ensures that collateral serves as an adequate mitigating factor for credit risk management purposes. The collateral 
management framework consists of a sound independent appraisal process, haircut system throughout the underwriting 
process, monitoring and revaluations.

Credit Risk Restructuring and Collection: A comprehensive portfolio supervision system is in place to identify weakened or 
problem credit exposures in a timely manner and to take prompt remedial actions. Dedicated restructuring units manage 
weakened borrowers across all business segments. The Bank differentiates between two types of restructuring considering 
the severity of financial weakness of the borrowers. For the measurement of ECL, restructured borrowers may be classified 
either in Stage 2 or Stage 3. The primary goal of the restructuring units is to rehabilitate the borrower and return to the 
performing category or to Stage 1. The sophistication and complexity of rehabilitation process differs based on the type and 
size of exposure. 

A centralised monitoring team monitors retail borrowers in delinquency, which coupled with branches’ efforts, are aimed at 
maximizing collection. The specialised software is applied for early collection processes management. Specific strategies 
are  tailored  to  different  sub-groups  of  customers,  reflecting  respective  risk  levels,  so  that  greater  effort  is  dedicated  to 
customers with a higher risk profile. Correcting the delinquency at early stage limits the amount of exposures becoming past 
due more than 30 days (one of the criteria indicating SICR) and transferred to Stage 2. 

Dedicated recovery units manage loans with higher risk profile. Corporate and SME borrowers are transferred to a recovery 
unit in case of a strong probability that a material portion of the principal amount will not be paid and the main stream of 
recovery  is  no  longer  the  borrower’s  cash  flow.  Retail  and  micro  loans  are  generally  transferred  to  the  recovery  unit  or 
external collection agencies (in the case of unsecured loans) at 90 days overdue, although they may be transferred earlier if 
it is evident that the borrower is unable to repay the loan.

Credit  Quality.  Depending  on  the  type  of  financial  asset  the  Group  may  utilize  different  sources  of  asset  credit  quality 
information including credit ratings assigned by the international rating agencies (Standard & Poor’s, Fitch), credit scoring 
information  from  credit  bureau  and  internally  developed  credit  ratings.  Financial  assets  are  classified  in  an  internally 
developed credit quality grades by taking into account the internal and external credit quality information in combination 
with other indicators specific to the particular exposure (e.g. delinquency). The Group defines following credit quality grades: 

 ` Very low risk – exposures demonstrate strong ability to meet financial obligations; 
 ` Low risk – exposures demonstrate adequate ability to meet financial obligations;  
 ` Moderate risk – exposures demonstrate satisfactory ability to meet financial obligations; 
 ` High risk – exposures that require closer monitoring, and
 ` Default – exposures in default, with observed credit impairment. 

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The internal credit ratings are estimated by the Group by statistical models with the limited involvement of credit officers. 
Statistical models include qualitative and quantitative information that shows the best predictive power based on historical 
data on defaults. 

The rating models are regularly reviewed and back tested on actual default data. The Group regularly validates the accuracy 
of ratings estimates and appraises the predictive power of the models. 

Expected credit loss (ECL) measurement. ECL is a probability-weighted estimate of the present value of future cash shortfalls.  
An ECL measurement is unbiased and is determined by evaluating a range of possible outcomes. ECL measurement is 
based on four components used by the Group: Probability of Default (“PD”), Exposure at Default (“EAD”), Loss Given Default 
(“LGD”) and Discount Rate. The estimates consider forward looking information, that is, ECLs reflect probability weighted 
development of key macroeconomic variables that have an impact on credit risk. 

The Bank uses is a three-stage model for ECL measurement and classifies its borrowers across three stages: The Bank 
classifies  its  exposures  as  Stage  1  if  no  significant  deterioration  in  credit  quality  occurred  since  initial  recognition  and 
the instrument was not credit-impaired when initially recognized. The exposure is classified to Stage 2 if the significant 
deterioration in credit quality was identified since initial recognition but the financial instrument is not considered credit-
impaired. The exposures for which the credit-impaired indicators have been identified are classified as Stage 3 instruments. 
The Expected Credit Loss (ECL) amount differs depending on exposure allocation to one of the Stages. In the case of Stage 
1 instruments, the ECL represents that portion of the lifetime ECL that can be attributed to default events occurring within 
the next 12 months from the reporting date. In case of Stage 2 instruments, the ECL represents the lifetime ECL, i.e. credit 
losses that can be attributed to possible default events during the whole lifetime of a financial instrument. Generally, lifetime 
is  set  equal  to  the  remaining  contractual  maturity  of  the  financial  instrument.  Factors  such  as  existence  of  contractual 
repayment schedules, options for extension of repayment maturity and monitoring processes held by the Bank affect the 
lifetime determination.  In case of Stage 3 instruments, default event has already incurred and the lifetime ECL is estimated 
based on the expected recoveries.

Definition of default. Financial assets for which the Group observed occurrence of one or more loss events are classified 
in Stage 3. For purposes of disclosure, the Group fully aligned the definition of default with the definition of credit-impaired 
assets. The Group’s definition of default for the purpose of ECL measurement, is in accordance with the Capital Requirements 
Regulation (EU).

The Group uses both quantitative and qualitative criteria for the definition of default. The borrower is classified as defaulted 
if at least one of the following occurred:

 ` Any amount of contractual repayments is past due more than 90 days; 
 ` Factors indicating the borrower’s unlikeliness-to-pay. 

In  case  of  individually  significant  borrowers  the  Bank  additionally  applies  criteria  including  but  not  limited  to:  bankruptcy 
proceedings, significant fraud in the borrower’s business that significantly affected its financial condition, breach of the contract 
terms etc. For SME and corporate borrowers default is identified on the counterparty level, meaning that all the claims against 
the borrower are treated as defaulted. As for retail and micro exposures, facility level default definition is applied considering 
additional pulling effect criteria. If the amount of defaulted exposure exceeds predefined threshold, all the claims against the 
borrower are classified as defaulted. Once financial instrument is classified as defaulted, it remains as such until it no longer 
meets any of the default criteria for a consecutive period of six months, in which case exposure is considered to no longer be in 
default (i.e. to have cured). Grace period of six months has been determined on analysis of likelihood of a financial instrument 
returning to default status after curing. Exposures which are moved to stage 2 from default state are kept there for certain 
period before transferring to Stage 1 and classified as fully performing instruments again.

Significant increase in credit risk (“SICR”). Financial assets for which the Group identifies significant increase in credit risk 
since its origination are classified in Stage 2. SICR indicators are recognized at financial instrument level even though some 
of them refer to the borrower’s characteristics. The Group uses both quantitative and qualitative indicators of SICR. 

Quantitative criteria
On a quantitative basis the Bank assesses change in probability of default parameter for each particular exposure since 
initial recognition and compares it to the predefined threshold. When absolute change in probability of default exceeds the 
applicable threshold, SICR is deemed to have occurred and exposure is transferred to Stage 2.  Quantitative indicator of SICR 
is applied to retail and micro segments, where the Group has sufficient number of observations. 

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED 

Qualitative criteria

Financial asset is transferred to Stage 2 and lifetime ECLs is measured if at least one of the following SICR qualitative criteria 
is observed:

 ` delinquency period of more than 30 days on contractual repayments;
 ` exposure is restructured, but is not credit impaired;
 ` borrower is classified as “watch”. 

The Group has not rebutted the presumption that there has been significant increase in credit risk since origination when 
financial asset becomes more than 30 days past due. This qualitative indicator of SICR together with debt restructuring 
is applied to all segments. Particularly for corporate and SME segment the Group uses downgrade of risk category since 
origination of the financial instrument as a qualitative indicator of SICR. Based on the results of the monitoring borrowers 
are classified across different risk categories. In case there are certain weaknesses present, which if materialized may lead 
to loan repayment problems, borrowers are classified as “watch” category. Although watch borrowers’ financial standing 
is sufficient to repay obligations, these borrowers are closely monitored and specific actions are undertaken to mitigate 
potential weaknesses. Once the borrower is classified as “watch” category it is transferred to Stage 2. If any of the SICR 
indicators described above occur financial instrument is transferred to Stage 2. Financial asset may be moved back to Stage 
1, if SICR indicators are no longer observed.

ECL  measurement:  The  Group  utilizes  two  approaches  for  ECL  measurement  –  individual  assessment  and  collective 
assessment. Individual assessment is mainly used for credit impaired individually significant borrowers. Additionally, the 
Bank  may  arbitrarily  designate  selected  exposures  to  individual  measurement  of  ECL  based  on  the  Bank’s  credit  risk 
management or underwriting departments’ decision. 

The Bank uses the discounted cash flow (DCF) method for the determination of recovery amount under individual assessment. 
In order to ensure the accurate estimation of recoverable amount the Bank may utilize scenario analysis approach. Scenarios 
may be defined considering the specifics and future outlook of individual borrower, sector the borrower operates in or changes 
in values of collateral.  In case of scenario analysis the Bank forecasts recoverable amount for each scenario and estimates 
respective losses. Ultimate ECL is calculated as the weighted average of losses expected in each scenario, weighted by the 
probability of scenario occurring.

As for the non-significant and non-impaired significant borrowers the Bank estimates expected credit losses collectively. 
For  the  collective  assessment  and  risk  parameters  estimation  purposes  the  exposures  are  grouped  into  a  homogenous 
risk pools based on similar credit risk characteristics. Common credit risk characteristics of the group include but are not 
limited to: Stage (Stage 1, Stage 2 or Stage 3), type of counterparty (individual vs business), type of product, rating (external or 
internal), overdue status, restructuring status, months in default category or any other characteristics that may differentiate 
certain sub-segments for risk parameter’s estimation purposes. Number of pools differs for different products/ segments 
considering specifics of portfolio and availability of data within each pool. Collective ECL is the sum of the multiplications of 
the following credit risk parameters: EAD, PD and LGD, that are defined as explained below, and discounted to present value 
using the instrument’s effective interest rate. 

The key principles of calculating the credit risk parameters:

Exposure at default (EAD). The EAD represents estimation of exposure to credit risk at the time of default occurring during 
the life of financial instrument. The EAD parameter used for the purpose of the ECL calculation is time-dependent, i.e. the 
Bank allows for various values of the parameter to be applied to subsequent time periods during the lifetime of an exposure. 
Such structure of the EAD is applied to all Stage 1 and Stage 2 financial instruments. In case of Stage 3 financial instruments 
and defaulted POCI assets, the EAD vector is one-element with current EAD as the only value. EAD is determined differently 
for  amortising  financial  instruments  with  contractual  repayment  schedules  and  for  revolving  facilities.  For  amortising 
products EAD is calculated considering the contractual repayments of principal and interest over the 12-month period for 
facilities classified in Stage 1 and over lifetime period for remaining instruments. It is additionally adjusted to include effect of 
reduction in exposure due to prepayments. For revolving products, the Bank estimates the EAD based on the expected limit 
utilisation percentage conditional on the default event.

Probability of default (PD). Probability of default parameter describes the likelihood of a default of a facility over a particular 
time horizon. It provides an estimate of the likelihood that a borrower will be unable to meet its contractual debt obligations. 
The PD parameter is time-dependent (i.e. has a specific term structure) and is applied to all non-defaulted contracts. Taking 

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into account specific nature of different segments of clients for which the PD is estimated as well as unique characteristics 
that drive their default propensity, the PD is modelled differently for Retail and Micro segments and Corporate and SME 
segments. PD assessment approach is also differentiated for different time horizons and is further adjusted due to expected 
influence of macroeconomic variables as forecasted for the period. Two types of PDs are used for calculating ECLs: 12-month 
and lifetime PD. Lifetime PDs represent the estimated probability of a default occurring over the remaining life of the financial 
instrument and it is a sum of the 12 months marginal PDs over the life of the instrument. The Group uses different statistical 
approaches such as the extrapolation of 12-month PDs based on migration matrixes, developing lifetime PD curves based 
on the historical default data and gradual convergence of long-term PD with the long-term default rate. 

Loss given default (LGD). The LGD parameter represents the share of an exposure that would be irretrievably lost if a borrower 
defaults. For Stage 1 and Stage 2 financial instruments, the LGD is estimated for each period in the instrument’s lifetime and 
reflects the share of the expected EAD for that period that will not be recovered over the remaining lifetime of the instrument 
after the default date. For Stage 3 financial instruments, the LGD represents the share of the EAD as of reporting date that will 
not be recovered over the remaining life of that instrument. Assessment of LGD varies by the type of counterparty, segment, 
type of product, securitization level and availability of historical observations. The general LGD estimation process employed by 
the Bank is based on the assumption that after the default of the exposure, two mutually exclusive scenarios are possible. The 
exposure either leaves the default state (cure scenario) or does not leave the default state and will be subject to recovery process 
(non-cure scenario). The probability that an exposure defaults again in the cure scenario is involved in the estimation process. 
Risk parameters applicable to both scenarios, i.e. cure rates and recovery rates, are estimated by means of migration matrices 
approach, where risk groups are defined by consecutive months-in-default. For certain portfolios based on the limitations of 
observations alternative versions of the general approach may be applied. 

Forward-looking  information.  The  measurement  of  unbiased,  probability  weighted  ECL  requires  inclusion  of  forward 
looking information obtainable without undue cost or effort. For forward looking information purposes the Bank defines 
three macro scenarios. The scenarios are defined as baseline (most likely), upside (better than most likely) and downside 
(worse than most likely) scenarios of the state of the Georgian economy with weights of 50%, 25% and 25% assigned to each 
scenario respectively. 

To derive the baseline macro-economic scenario, the Group takes into account forecasts from various external sources – the 
National Bank of Georgia, Ministry of Finance, International Monetary Fund (“IMF”) as well as other International Financial 
Institutions  (“IFI”’s)  –  in  order  to  ensure  the  to  the  consensus  market  expectations.  Upside  and  downside  scenarios  are 
defined based on the framework developed by the Bank’s macroeconomic unit.

The forward looking information is incorporated in both individual and collective assessment of expected credit losses.

Model maintenance and validation. The Group regularly reviews its methodology and assumptions to reduce any difference 
between  the  estimates  and  the  actual  credit  loss.  Such  back-testing  is  performed  at  least  once  a  year.  As  part  of  the 
back-testing process, the Group evaluates actual realization of the risk parameters and their consistency with the model 
estimates. Additionally staging criteria are also analysed within the back-testing process. The results of back-testing the 
ECL measurement methodology are communicated to the Group Management and further actions for tuning the models and 
assumptions are defined after discussions between authorised persons. 

Geographical risk concentrations. Assets, liabilities, credit related commitments and performance guarantees have generally 
been attributed to geographic regions based on the country in which the counterparty is located. Balances legally outstanding 
to/from off-shore companies which are closely related to Georgian counterparties are allocated to the caption “Georgia”. Cash 
on hand and premises and equipment have been allocated based on the country in which they are physically held.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

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NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED 

The geographical concentration of the Group’s assets and liabilities as of 31 December 2019 is set out below:

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances
with National Bank of Georgia
Loans and advances to customers
Investment securities measured
at fair value through OC
Bonds carried at amortised cost
Investments in leases
Other financial assets
Total financial assets
Non-financial assets
Total assets
Liabilities
Due to credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Lease liabilities
Subordinated debt
Total financial liabilities
Non-financial liabilities
Total liabilities
Net balance sheet position
Performance guarantees
Credit related commitments

Georgia

OECD

Non-OECD

Total

 701,993 
 21,538 

 1,591,829 
 11,775,027 

 985,293 
 1,022,684 
 255,596 
 132,060 
 16,486,020 
1,029,732
17,515,752

 1,813,684 
 8,406,484 
 1,213,598 
 113,271 
 59,898 
 100,993 
11,707,928
135,131
11,843,059
5,672,693
603,910
1,485,032

 287,079 
 12,067 

  -    
 408,217 

  -    
  -    
  -    
 1,431 
 708,794 
 28
708,822

 1,744,130 
 733,778 
  -    
 329 
  -    
 343,861 
2,822,098
 829 
2,822,927
(2,114,105)
232,328
4,476

 14,511 
 - 

 1,003,583 
 33,605 

  -    
 166,155 

 1,591,829 
 12,349,399 

 - 
  -    
 1,064 
 245 
 181,975 
3,725
185,700

 36,087 
 909,062 
  -    
 8 
  -    
 146,181 
1,091,338
5,294
1,096,632
(910,932)
622,646
11,459

 985,293 
 1,022,684 
 256,660 
 133,736 
 17,376,789 
1,033,485
18,410,274

 3,593,901 
 10,049,324 
 1,213,598 
 113,608 
 59,898 
 591,035 
15,621,364
141,254
15,762,618
2,647,656
1,458,884
1,500,967

Table above includes geographical concentration by country of incorporation. Loans and advances to OECD and Non-OECD 
resident customers, as well as to Georgian customers, are issued to the entities most of which are based and performing in 
Georgia. As at 31 December 2019, out of total net exposure of loans and advances to customers, GEL 12,330,467 thousand is 
issued to the entities operating in Georgian market, GEL 18,932 thousand operating in other economies.

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED 

The geographical concentration of the Group’s assets and liabilities as of 31 December 2018 is set out below:

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities measured at fair value through OCI
Bonds carried at amortised cost
Investments in leases
Other financial assets
Total financial assets
Non-financial assets
Total assets
Liabilities
Due to credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Subordinated debt
Total financial liabilities
Non-financial liabilities
Total liabilities
Net balance sheet position
Performance guarantees
Credit related commitments

Georgia

OECD

Non-OECD

Total

 650,575 
 28,418 
 1,422,809 
 9,526,939 
 1,004,564 
 654,203 
 202,850 
166,899
 13,657,257 
788,042
14,445,299

 1,154,327 
 7,790,236 
 7,927 
 98,379 
 94,264 
 9,145,133 
144,386
9,289,519
5,155,780
 684,810 
870,446

 515,159 
 12,852 
 -   
 121,713 
 -   
 -   
 -   
 329 
 650,053 
 55 
 650,108 

 1,811,299 
 697,753 
 -   
 296 
 420,031 
2,929,379 
 525 
2,929,904 
(2,279,796)
 291,795 
3,751

 1,177 
 6,046 
 -   
 389,800 
 675 
 -   
 952 
 290 
 398,940 
 3,646 
 402,586 

 65,877 
 864,153 
 5,416 
 39 
 136,624 
 1,072,109 
 493 
1,072,602
 (670,016)
 219,207 
 1,638 

 1,166,911 
 47,316 
 1,422,809 
 10,038,452 
 1,005,239 
 654,203 
 203,802 
167,518
 14,706,250 
  791,743
 15,497,993

 3,031,503 
 9,352,142 
 13,343 
 98,714 
 650,919 
 13,146,621 
145,404
 13,292,025
2,205,968
 1,195,812 
 875,835 

Table above includes geographical concentration by country of incorporation. Loans and advances to OECD and Non-OECD 
resident customers, as well as to Georgian customers, are issued to the entities most of which are based and performing in 
Georgia. As at 31 December 2018, out of total net exposure of loans and advances to customers, GEL 10,015,062 thousand is 
issued to the entities operating in Georgian market, GEL 23,390 thousand operating in other economies.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

293

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED 

The geographical concentration of the Group’s assets and liabilities as of 31 December 2017 is set out below:

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities available for sale
Bonds carried at amortised cost
Investments in leases
Other financial assets
Total financial assets
Non-financial assets
Total assets
Liabilities
Due to credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Subordinated debt
Total financial liabilities
Non-financial liabilities
Total liabilities
Net balance sheet position
Performance guarantees
Credit related commitments

Georgia

OECD

Non-OECD

Total

820,647
27,183
1,033,818
7,960,107
657,068
449,538
143,836
145,798
11,237,995
733,417
11,971,412

1,069,211
6,499,134
7,821
90,649
62,508
7,729,323
96,759
7,826,082
4,145,330
387,890
968,019

608,728
8,733
-
67,805
-
-
-
141
685,407
55
685,462

1,535,644
694,821
-
474
232,263
2,463,202
1,084
2,464,286
(1,778,824)
151,502
2,996

2,102
3,727
-
297,441
870
-
-
205
304,345
4,691
309,036

15,859
622,862
12,874
630
132,017
784,242
846
785,088
(476,052)
72,905
6,045

1,431,477
39,643
1,033,818
8,325,353
657,938
449,538
143,836
146,144
12,227,747
738,163
12,965,910

2,620,714
7,816,817
20,695
91,753
426,788
10,976,767
98,689
11,075,456
1,890,454
612,297
977,060

Market risk. The Bank follows the Basel Committee’s definition of market risk as the risk of losses in on- and off-balance 
sheet positions arising from movements in market prices. This risk is principally made up of (a) risks pertaining to interest 
rate instruments and equities in the trading book and (b) foreign exchange rate risk (or currency risk) and commodities 
risk throughout the Bank. The Bank’s strategy is not to be involved in trading book activity or investments in commodities. 
Accordingly, the Bank’s exposure to market risk is primarily limited to foreign exchange rate risk in the structural book.  

Currency risk. Foreign exchange rate risk arises from the potential change in foreign currency exchange rates, which can 
affect the value of a financial instrument. This risk stems from the open currency positions created due to mismatches 
in foreign currency assets and liabilities. The NBG requires the Bank to monitor both balance-sheet and total aggregate 
(including off-balance sheet) open currency positions and to maintain the later one within 20% of the Bank’s regulatory 
capital. As of 31 December 2019, the Bank maintained an aggregate open currency position of 0.5% of regulatory capital 
(2018: 7.6%; 2017: 1.5%). The Asset-Liability Management Committee (“ALCO”) has set limits on the level of exposure by 
currency as well as on aggregate exposure positions which are more conservative than those set by the NBG. The Bank’s 
compliance with such limits is monitored daily by the heads of the Treasury and Financial Risk Management Departments. 

On 13 August 2018 the NBG introduced new regulation on changes to OCP calculation method, according to this regulation, 
from March 2019 special reserves assigned to FC balance-sheet assets would be deductible gradually for OCP calculation 
purposes  and  fully  implemented  by  July  2022  in  line  with  the  transition  period  defined  by  the  NBG  (according  to  the 
amendment disclosed in December 2019).

Currency risk management framework is governed through the Market Risk Management Policy, market risk management 
procedure and relevant methodologies. The Bank has in place the methodology developed for allocating capital charges 
for  FX  risk  following  Basel  guidelines.  The  table  below  summarises  the  Group’s  exposure  to  foreign  currency  exchange 
rate risk at the balance sheet date. While managing open currency position the Group considers part of the provisions to 
be  denominated  in  the  FC  currency.  Gross  amount  of  currency  swap  deposits  is  included  in  Derivatives.  Therefore  total 
financial assets and liabilities below are not traceable with either balance sheet or liquidity risk management tables, where 
net amount of gross currency swaps is presented.

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED 

In thousands of GEL
Georgian Laris
US Dollars
Euros
Other
Total 

As of 31 December 2019

Monetary
financial assets
7,502,497 
6,846,799 
2,970,008 
57,485 
17,376,789 

Monetary
financial liabilities
5,706,300 
8,774,033 
1,035,944 
105,087 
15,621,364 

Derivatives
(100,140)
1,955,050 
(1,925,463)
56,136 
(14,417)

Net position
1,696,057 
27,816 
8,601 
8,534 
1,741,008 

In thousands of GEL

As of 31 December 2018

Monetary 
financial 
assets

Monetary
financial 
liabilities

Georgian Lari
US Dollars
Euros
Other
Total 

 5,920,867 
 7,309,173 
 1,375,295 
 100,915 

 4,663,300 
 7,445,413 
 948,398 
 89,498 
14,706,250  13,146,609 

As of 31 December 2017

Net 
balance sheet 
position

Monetary
financial
assets

Monetary
financial
liabilities

1,343,689
187,066
17,332
10,959
1,559,046 

 4,814,429 
 6,475,155 
 816,565 
 121,579 

 3,767,858 
 6,299,024 
 805,153 
 104,732 
 12,227,728  10,976,767 

Net
balance sheet 
position

1,211,092
22,682
2,097
15,948
1,251,819 

Derivatives

 164,521 
 (153,449)
 (9,315)
 (899)
 858 

Derivatives

 86,122 
 323,306 
 (409,565)
 (458)
 (595)

US Dollar strengthening by 10% (weakening 10%) would increase Group’s profit or loss and equity in 2019 by GEL 2,782 
(decrease by GEL 2,782). Euro strengthening by 10% (weakening 10%) would increase Group’s profit or loss and equity in 
2019 by GEL 860 (decrease by GEL 860). US Dollar strengthening by 10% (weakening 10%) would increase Group’s profit or 
loss and equity in 2018 by GEL 18,807 (decrease by GEL 18,807). Euro strengthening by 10% (weakening 10%) would increase 
Group’s profit or loss and equity in 2019 by GEL 1,733 (decrease by GEL 1,733). US Dollar strengthening by 10% (weakening 
10%) would increase Group’s profit or loss and equity in 2017 by GEL 2,268 (decrease by GEL 2,268). Euro strengthening by 
10% (weakening 10%) would increase Group’s profit or loss and equity in 2019 by GEL 210 (decrease by GEL 210).

Interest rate risk. Interest rate risk arises from potential changes in the market interest rates that can adversely affect 
the fair value or future cash flows of the financial instrument. This risk can arise from maturity mismatches of assets and 
liabilities, as well as from the re-pricing characteristics of such assets and liabilities. 

The Bank’s deposits and the part of the loans are at fixed interest rates, while a portion of the Bank’s borrowings is at a 
floating interest rate. The Bank’s floating rate borrowings are, to a certain extent, hedged by the NBG paying a floating rate 
on the minimum reserves that the Bank holds with the NBG. The Bank used to enter also into interest rate swap agreements 
or apply for other interest rate risk hedging instruments in order to mitigate interest rate risk. Furthermore, many of the 
Bank’s loans to customers contain a clause allowing it to adjust the interest rate on the loan in case of adverse interest 
rate movements, thereby limiting the Bank’s exposure to interest rate risk. The management also believes that the Bank’s 
interest rate margins provide a reasonable buffer to mitigate the effect of possible adverse interest rate movements. 

The table below summarises the Group’s exposure to interest rate risks. It illustrates the aggregated amounts of the Group’s 
financial assets and liabilities at the amounts monitored by the management and categorised by the earlier of contractual 
interest re-pricing or maturity dates. Cross-Currency  swaps are not netted when assessing the Group’s exposure to interest 
rate risks. Therefore, total financial assets and liabilities below are not traceable with either balance sheet or other financial 
risk management tables. The tables consider both reserves placed with NBG and Interest bearing Nostro accounts. Income 
on NBG reserves and Nostros are calculated as benchmark minus margin whereby for benchmark Federal funds rate and 
ECB rates are considered in case of USD and EUR respectively. Therefore, they have impact on the TBC’s Net interest income 
in case of both upward and downward shift of interest rates. 

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NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

In thousands of GEL
31 December 2019
Total financial assets
Total financial liabilities
Net interest sensitivity gap
as of 31 December 2019
31 December 2018
Total financial assets
Total financial liabilities
Net interest sensitivity gap
as of 31 December 2018
31 December 2017
Total financial assets
Total financial liabilities
Net interest sensitivity gap
as of 31 December 2017

Less than 1
month

From 1 to 6
months

From 6 to 12 
months

More than 1
year

Total

6,650,943
6,016,285

5,034,027
3,087,372

1,022,854
1,026,326

5,354,287
6,184,815

18,062,111
16,314,798

 634,658 

 1,946,655 

 (3,472)

 (830,528)

 1,747,313 

4,782,800
4,563,135

3,610,949
3,337,999

1,017,711
948,719

5,295,712
4,297,701

14,707,172
13,147,554

 219,665 

 272,950 

 68,992 

 998,011 

1,559,618

3,427,631
4,094,978

2,449,029
2,634,518

1,069,488
1,038,842

5,302,335
3,229,143

12,248,483
10,997,481

(667,347)

(185,489)

 30,646 

 2,073,192 

 1,251,002

As of 31 December 2019, if interest rates had been 100 basis points lower with all other variables held constant, profit for 
the year would have been GEL 19.4 million lower (2018: GEL 4.8 million; 2017 GEL 7.4 million;), mainly as a result of lower 
interest income on variable interest assets. Other comprehensive income would have been GEL 9.4  million higher (2018: GEL 
8.6 million; 2017: GEL 6.1 million), as a result of an increase in the fair value of fixed rate financial assets measured at fair 
value through other comprehensive income and repurchase receivables.

If interest rates had been 100 basis points higher, with all other variables held constant, profit would have been GEL 20 million 
higher (2018: GEL 4.8 million; 2017: GEL 7.4 million), mainly as a result of higher interest income on variable interest assets. 
Other comprehensive income would have been GEL 9.1  million lower (2018: GEL 8.2 million; 2017: GEL 5.9million), as a 
result of decrease in the fair value of fixed rate financial assets measured at fair value through other comprehensive income.

With the assistance of Ernst & Young LLC the Bank has developed an advanced model to manage the interest rate risk on a 
standalone basis. The interest rate risk analysis is performed monthly by the Financial Risk Management Department.

The Bank calculates the impact of changes in interest rates using both Net Interest Income and Economic Value sensitivity. 
Net Interest Income sensitivity measures the impact of a change of interest rates along the various maturities on the yield 
curve on the net interest revenue for the nearest year. Economic Value measures the impact of a change of interest rates 
along the various maturities on the yield curve on the present value of the Group’s assets, liabilities and off-balance sheet 
instruments. When performing Net Interest Income and Economic Value sensitivity analysis, the Bank uses parallel shifts 
in interest rates as well as number of different scenarios. TBC Bank closely monitors the adverse effect of possible parallel 
yield curve shift scenarios on net interest income over a one-year period to ensure compliance with the predefined risk 
appetite of the Bank.

In order to manage Interest Rate risk the Bank establishes appropriate limits. The Bank monitors compliance with the limits 
and prepares forecasts. ALCO decides on actions that are necessary for effective interest rate risk management and follows 
up on the implementation. Periodic reporting is done to Management Board and the Board’s Risk, Ethics and Compliance 
Committee.

Liquidity Risk. The liquidity risk is the risk that TBC Bank either does not have sufficient financial resources available to meet 
all of its obligations and commitments as they fall due, or can access those resources only at a high cost. The risk is managed 
by the Financial Risk Management and Treasury Departments and is monitored by the ALCO. 

The principal objectives of the TBC Bank’s liquidity risk management policy are to: (i) ensure the availability of funds in order 
to meet claims arising from total liabilities and off-balance sheet commitments, both actual and contingent, at an economic 
price; (ii) recognise any structural mismatch existing within TBC Bank’s statement of financial position and set monitoring 
ratios to manage funding in line with well-balanced growth; and (iii) monitor liquidity and funding on an on-going basis to 
ensure that approved business targets are met without compromising the risk profile of the Bank.

The liquidity risk is categorised into two risk types: the funding liquidity risk and the market liquidity risk. 

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

Funding liquidity risk is the risk that TBC will not be able to efficiently meet both expected and unexpected current and 
future cash flow and collateral needs without affecting either its daily operations or its financial condition. To manage funding 
liquidity risk TBC Bank internally developed Liquidity Coverage ratio and a Net Stable Funding ratio models set, forth under 
Basel III, as well as minimum liquidity ratio defined by the NBG. In addition the Bank performs stress tests and “what-if” 
scenario analysis and minimum liquidity ratio defined by the NBG. In 2017, for liquidity risk management purposes National 
Bank of Georgia introduced Liquidity Coverage Ratio (“NBG LCR”), where in addition to Basel III guidelines conservative 
approaches were applied to Mandatory Reserves’ weighting and to the deposits’ withdrawal rates depending on the clients 
group’s concentration. From 1st of September, 2017 the Bank also monitors compliance with NBG LCR limits. In 2019, for 
long-term liquidity risk management purposes NBG introduced Net Stable Funding Ratio (“”NBG NSFR”). From September, 
2019, on a monthly basis the Bank monitors compliance with the set limit for NBG NSFR.

The Liquidity Coverage  Ratio  is  used  to  help  manage  short-term  liquidity  risks.  The  Bank’s  liquidity  risk  management 
framework is designed to comprehensively project cash flows arising from assets, liabilities and off-balance sheet items 
over certain time buckets and ensure that NBG LCR limits, are met on a daily basis. TBC Bank also stress tests the results 
of liquidity through large shock scenarios provided by the NBG.

The Net Stable Funding ratio is used for long-term liquidity risk management to promote resilience over a longer time 
horizon by creating additional incentives for TBC Bank to rely on more stable sources of funding on a continuous basis. The 
Bank also monitors deposit concentration for large deposits and set limits for non-Georgian residents deposits share in total 
deposit portfolio.

The management believes that a strong and diversified funding structure is one of TBC Bank’s differentiators. The Bank 
relies on relatively stable deposits from Georgia as the main source of funding. In order to maintain and further enhance the 
liability structure TBC Bank sets the targets for deposits and IFI funding within the Bank’s risk appetite. 

The loan to deposit and IFI funding ratio (defined as total value of net loans divided by total value of deposits and funds 
received from International financial institutions)) stood at 104.8%, 89.9% and 92.5%, at the 31 December 2019, 2018 and 
2017 respectively.

Maturity analysis. The table below summarizes the maturity analysis of the Group’s financial liabilities, based on remaining 
undiscounted contractual obligations as of 31 December 2019’ Subject-to-notice repayments are treated as if notice were 
to be given immediately. However, the Group expects that many customers will not request repayment on the earliest date 
the Group could be required to pay and the table does not reflect the expected cash flows indicated by the Group’s deposit 
retention history.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

297

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

The maturity analysis of financial liabilities as of 31 December 2019 is as follows:

In thousands of GEL
Liabilities
Due to Credit institutions 
Customer accounts – individuals
Customer accounts – other
Other financial liabilities
Lease liabilities
Subordinated debt
Debt securities in issue
Gross settled forwards
Performance guarantees 
Financial guarantees and letters of credit
Other credit related commitments
Total potential future payments for financial obligations

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

Over
5 years

Total

1,590,089
3,407,952
3,722,452
90,944
4,367
2,019
-
1,476,685
115,997
84,103
1,150,110
11,644,718

616,417
1,658,316
339,113
10,133
12,509
55,182
-
552,630
332,833
176,822
-
3,753,955

3,724,084
699,554
250,328
4,917
57,058
1,255,291
1,213,598
164,099
909,502
89,342
 -   
8,367,773

435,233
27,344
142,043
 -   
11,988
2,330,270
 -   
 -   
100,552
 590 
 -   
3,048,020

6,365,823
5,793,166
4,453,936
105,994
85,922
3,642,762
1,213,598
2,193,414
1,458,884
350,857
1,150,110
26,814,466

The maturity analysis of financial liabilities as of 31 December 2018 is as follows: 

In thousands of GEL
Liabilities
Due to Credit institutions 
Customer accounts – individuals
Customer accounts – other
Other financial liabilities
Subordinated debt
Debt securities in issue
Gross settled forwards
Performance guarantees 
Financial guarantees and letters of credit
Other credit related commitments
Total potential future payments for financial obligations

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

Over
5 years

Total

950,084
3,152,851
3,821,862
77,522
5,267
366
567,259
119,959
9,932
769,863
9,474,965 

372,517
1,408,710
208,250
21,192
71,519
13,847
16,008
349,354
44,703
-
2,506,100

 1,909,587 
628,831
 137,275 
-
 388,594 
 -   
 -   
 671,333 
 51,337 
-
3,786,957 

 187,454 
27,397
 195,007 
-
 588,197 
 -   
 -   
 55,166 
 -   
-

3,419,642
5,217,789
4,362,394
98,714 
 1,053,577 
 14,213 
 583,267 
 1,195,812 
 105,972 
769,863
 1,053,221  16,821,243 

The maturity analysis of financial liabilities as of 31 December 2017 is as follows:

In thousands of GEL
Liabilities
Due to Credit institutions 
Customer accounts – individuals
Customer accounts – other
Other financial liabilities
Subordinated debt
Debt securities in issue
Gross settled forwards
Performance guarantees 
Financial guarantees and letters of credit
Other credit related commitments
Total potential future payments for financial obligations

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

1,142,865
2,532,039
3,068,027
 82,685 
5,060
504
176,822
55,914
52,256
728,178
 7,844,350 

418,613
1,378,835
192,852
 8,808 
74,191
8,814
5,509
241,460
122,014
-
 2,451,096 

1,167,970
522,104
133,236
 260 
198,042
13,687
-
306,788
74,457
-
2,416,544

Over
5 years

151,417
40,727
80,976
-
346,703
-
-
8,135
155
-
628,113

Total

2,880,865
4,473,705
3,475,091
91,753
623,996
23,005
182,331
612,297
248,882
728,178
13,340,103

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

The  undiscounted  financial  liability  analysis  gap  does  not  reflect  the  historical  stability  of  the  current  accounts.  Their 
liquidation has historically taken place over a longer period than the one indicated in the tables above. These balances are 
included in amounts due in less than three months in the tables above. 

Term Deposits included in the customer accounts are classified based on remaining contractual maturities, according to the 
Georgian Civil Code, however, individuals have the right to withdraw their deposits prior to maturity if they partially or fully 
forfeit their right to accrued interest and the Group is obliged to repay such deposits upon the depositor’s demand. Based 
on the Bank’s deposit retention history, the management does not expect that many customers will require repayment on 
the earliest possible date; accordingly, the table does not reflect the management’s expectations as to actual cash outflows.

The  Group  does  not  use  the  above  undiscounted  maturity  analysis  to  manage  liquidity.  Instead,  the  Group  monitors  the 
liquidity gap analysis based on the expected maturities. In particular, the customers’ deposits are distributed in the given 
maturity gaps following their behavioural analysis. 

As of 31 December 2019 the analysis by expected maturities may be as follows:

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities measures at fair value through OCI
Bonds carried at amortised cost
Net investments in lease
Insurance and Reinsurance Receivables
Other financial assets
Total financial assets
Liabilities
Due to Credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Lease liabilities
Insurance contracts liabilities
Subordinated debt
Total financial liabilities
Credit related commitments and performance guarantees
Performance guarantees
Financial guarantees
Other credit related commitments
Credit related commitments and performance guarantees 
Net liquidity gap as of 31 December 2019
Cumulative gap as of 31 December 2019

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

Over
5 years

Total

  1,003,583
 15,193 
1,591,829
 1,303,711 
985,293
 124,006 
 34,448 
9,072
 104,612 
 5,171,747 

 1,573,720 
 1,082,198 
 -   
90,944 
 4,394 
1,850
 331 
 2,753,437 

 7,466 
 4,511 
 100,212 
112,189
 2,306,121 
2,306,121

 -   
 3,500 
 -   
 2,307,064 
 -   
 215,711 
 70,398 
17,104
 2,946 
 2,616,723 

 427,794 
 174,905 
 -   
 10,133 
 8,513 
5,763
 -   
 627,108 

 -   
 14,912 
 -   
 5,108,650 
 -   
 555,379 
 148,542 
-
 2 
 5,827,485 

 1,496,459 
 -   
 1,213,598 
 4,918 
 38,831 
-
 113,497 
 2,867,303 

 -   
 -   
 -   
 3,629,974 
 -   
 127,588 
 3,272 
-
 -   
 3,760,834 

1,003,583
33,605
  1,591,829
  12,349,399
  985,293
1,022,684
  256,660
26,176
  107,560
 17,376,789 

 95,928 
 8,792,221 
 -   
 -   
 8,160
-
 477,207 
 9,373,516 

 3,593,901 
 10,049,324 
 1,213,598 
 105,995
59,898
7,613
 591,035 
 15,621,364 

 -   
 -   
 -   
 -   
1,989,615 
4,295,736

 -   
 -   
 -   
 -   
 2,960,182 
7,255,918

 -   
 -   
 -   
 -   
 (5,612,682)
1,643,236

 7,466 
 4,511 
 100,212
112,189
 1,643,236 

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299

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

As of 31 December 2018 the analysis by expected maturities may be as follows: 

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities measures at fair value through OCI
Bonds carried at amortised cost
Net investments in lease 
Other financial assets
Total financial assets
Liabilities
Due to Credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Subordinated debt
Total financial liabilities
Credit related commitments and performance guarantees
Performance guarantees
Financial guarantees
Other credit related commitments
Credit related commitments and performance guarantees 
Net liquidity gap as of 31 December 2018
Cumulative gap as of 31 December 2018

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

Over
5 years

Total

 1,166,911 
 27,153 
 1,422,809 
1,090,521
 1,005,239 
 119,489 
 31,133 
 131,586 
4,994,841

 933,511 
 997,594 
 112 
 77,522 
 3,048 
 2,011,787 

 4,393 
 5,424 
 103,029 
112,846
 2,870,208 
2,870,208

 -   
 11,075 
 -   
2,056,149
 -   
 92,877 
 56,432 
 34,268 
2,250,801

 -   
 9,088 
 -   
4,152,436
 -   
 368,843 
 113,087 
 1,664 
4,645,118

 -   
 -   
 -   
2,739,346
 -   
 72,994 
 3,150 
 -   
2,815,490

 1,166,911 
 47,316 
 1,422,809 
 10,038,452 
 1,005,239 
 654,203 
 203,802 
 167,518 
 14,706,250 

 271,993 
 128,395 
 13,231 
21,192
 23,246 
458,057 

 1,653,575 
 -   
 -   
 -   
 182,986 
 1,836,561 

 172,424 
 8,226,153 
 -   
 -   
 441,639 
 8,840,216 

 3,031,503 
 9,352,142 
 13,343 
98,714
 650,919 
  13,146,621 

 -   
 -   
 -   
 -   
 1,792,744 
4,662,952

 -   
 -   
 -   
 -   
 2,808,557 
7,471,509

 -   
 -   
 -   
 -   
 (6,024,726)
1,446,783

 4,393 
 5,424 
 103,029 
112,846
 1,446,783 

The management believes that the Group has sufficient liquidity to meet its current on- and off-balance sheet obligations.

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37. FINANCIAL AND OTHER RISK MANAGEMENT CONTINUED

As of 31 December 2017 the analysis by expected maturities may be as follows

In thousands of GEL
Assets
Cash and cash equivalents
Due from other banks
Mandatory cash balances with National Bank of Georgia
Loans and advances to customers
Investment securities available for sale
Bonds carried at amortised cost
Net investments in lease 
Other financial assets
Total financial assets
Liabilities
Due to Credit institutions
Customer accounts
Debt securities in issue
Other financial liabilities
Subordinated debt
Total financial liabilities
Credit related commitments and performance guarantees
Performance guarantees
Financial guarantees
Other credit related commitments
Credit related commitments and performance guarantees 
Net liquidity gap as of 31 December 2017
Cumulative gap as of 31 December 2017

38. CONTINGENCIES AND COMMITMENTS

Less than
3 months

From 3 to
12 months

From
12 months  to
5 years

Over
5 years

Total

1,431,477
32,845
1,033,818
1,031,608
657,938
81,859
22,896
110,604
4,403,045

1,137,076
844,123
47
82,685
3,471
2,067,402

-
3,071
-
1,767,797
-
105,956
38,526
22,207
1,937,557

351,381
136,821
7,778
8,808
49,694
554,482

 2,067 
 8,239 
105,268
115,574
2,220,069
2,220,069

-
-
-
-
1,383,075
3,603,144

-
3,727
-
3,438,180
-
216,177
82,414
13,333
3,753,831

990,480
-
12,870
260
97,372
1,100,982

-
-
-
-
2,652,849
6,255,993

-
-
-
2,087,768
-
45,546
-
-
2,133,314

141,777
6,835,873
-
-
276,251
7,253,901

-
-
-
-
(5,120,587)
1,135,406

1,431,477
39,643
1,033,818
8,325,353
657,938
449,538
143,836
146,144
12,227,747

2,620,714
7,816,817
20,695
91,753
426,788
10,976,767

 2,067 
 8,239 
105,268
115,574
1,135,406

Legal proceedings. When determining the level of provision to be set up with regards to such claims, or the amount (not 
subject  to  provisioning)  to  be  disclosed  in  the  financial  statements,  the  management  seeks  both  internal  and  external 
professional advice. The management believes that the provision recorded in these financial statements is adequate and 
the amount (not subject to provisioning) need not be disclosed as it will not have a material adverse effect on the financial 
condition or the results of future operations of the Group.

Tax legislation. Georgian and Azerbaijani tax and customs legislation is subject to varying interpretations, and changes, 
which can occur frequently. The management’s interpretation of the legislation as applied to the Group’s transactions and 
activity may be challenged by the relevant authorities. Fiscal periods remain open to review by the authorities in respect 
of taxes for five calendar years preceding the review period. To respond to the risks, the Group has engaged external tax 
specialists to carry out periodic reviews of Group’s taxation policies and tax filings. The Group’s management believes that 
its  interpretation  of  the  relevant  legislation  is  appropriate  and  the  Group’s  tax  and  customs  positions  will  be  sustained. 
Accordingly, as of 31 December 2019, 2018 and 2017 no provision for potential tax liabilities has been recorded.

Compliance with covenants. The Group is subject to certain covenants primarily related to its borrowings. Non-compliance 
with such covenants may result in negative consequences for the Group including growth in the cost of borrowings and 
declaration of default. The Group was in compliance with all covenants as of 31 December 2019, 31 December 2018 and 31 
December 2017. In April 2017, the group had breached one of the covenants with a foreign financial institution lender. The 
group has obtained the waiver from the financial institution in June 2017, whereby the breach was retrospectively waived. 
The Group was in compliance with all other covenants as of 31 December 2019, 31 December 2018 and 31 December 2017.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

301

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

38. CONTINGENCIES AND COMMITMENTS CONTINUED

Credit related commitments and financial guarantees. The primary purpose of these instruments is to ensure that funds 
are available to a customer as required. Financial guarantees and standby letters of credit, which represent the irrevocable 
assurances that the Group will make payments in the event that a customer cannot meet its obligations to third parties, carry 
the same credit risk as loans. Documentary and commercial letters of credit, that are written undertakings by the Group on 
behalf of a customer authorising a third party to draw drafts on the Group up to a stipulated amount under specific terms 
and conditions, are collateralised by the underlying shipments of goods to which they relate or cash deposits and therefore 
carry less risk than a direct borrowing.

Commitments to extend credit represent unused portions of authorisations to prolong credit in the form of loans, guarantees 
or letters of credit. With respect to credit risk on commitments to extend credit, the Group is potentially exposed to a loss 
in an amount equal to the total unused commitments. However, the likely amount of loss is lower than the total unused 
commitments  since  most  commitments  to  extend  credit  are  contingent  upon  customers  maintaining  specific  credit 
standards. The Group monitors the term to maturity of credit related commitments because longer-term commitments 
generally have a greater degree of credit risk than shorter-term ones.

Outstanding credit related commitments are as follows: 

In thousands of GEL
Undrawn credit lines
Letters of credit issued
Financial guarantees issued
Total credit related commitments (before provision)
Credit loss allowance for credit related commitments
Total credit related commitments

2019
 1,150,110 
 109,733 
241,124
1,500,967
(4,511)
1,496,456

2018
769,863
105,972
-
875,835
(5,424)
870,411

2017
728,178
106,919
141,963
977,060
(8,239)
968,821

The total outstanding contractual amount of undrawn credit lines, letters of credit, and guarantees does not necessarily 
represent future cash requirements, as these financial instruments may expire or terminate without being funded. Non-
cancellable commitments as of 31 December 2019 were GEL 472,485 thousand (2018: GEL 344,360 thousand; 2017: GEL 
389,148 thousand).

Performance guarantees. Performance guarantees are contracts that provide compensation in case of another party fails 
to perform a contractual obligation. Such contracts do not transfer credit risk. The risk under the performance guarantee 
contracts is the possibility that the insured event occurs (i.e.: the failure to perform the contractual obligation by another 
party). The key risks the Group faces are significant fluctuations in the frequency and severity of payments incurred on such 
contracts, relative to expectations.

Outstanding amount of performance guarantees and respective provision as of 31 December 2019 is GEL 1,458,884 
 thousand and GEL 7,466 thousand (2018: GEL 1,195,812 thousand and GEL 4,393 thousand, 2017: GEL 612,297 thousand and 
GEL 2,067 thousand).

Fair value of credit related commitments were GEL 4,511 thousand as of 31 December 2019 (2018: GEL 5,424 thousand; 
2017: GEL 8,239 thousand). Total credit related commitments and performance guarantees are denominated in currencies 
as follows:

In thousands of GEL
Georgian Laris
US Dollars
Euros
Other
Total

2019
1,155,422
1,203,296
542,303
58,830
2,959,851

2018
853,965
955,829
218,091
43,762
2,071,647

2017
618,544
734,970
166,304
69,539
1,589,357

Capital expenditure commitments. As of 31 December 2019, the Group has contractual capital expenditure commitments 
amounting to GEL 33,723 thousand (2018: GEL 12,210 thousand; 2017: GEL 7,816 thousand). Out of total amount as at 31 
December 2019, contractual commitments related to the head office construction amounted GEL 13,186.

302

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

39. NON-CONTROLLING INTEREST

The following table provides information about each subsidiary with a non-controlling interest as of 31 December 2019:

In thousands of GEL
Inspired LLC

TKT Online LLC
TKT UZ 
My.GE LLC
AllProperty.ge LLC
Billing Solutions LLC
TBC Bank JSC including:

TBC Leasing JSC*
United Financial Corporation JSC

Proportion of non-controlling 
interest’s voting rights held 
49%
45%
25%
35%
10%
49%
0.12%
0.39%
0.47%

Profit attributable to
non-controlling interest
1,350
303
(0)
130
(65)
0
728
11 
63 

Accumulated non-controlling 
interest in the subsidiary
1,906
815
21
2,094
(36)
169
3,619 
-
582 

 *In May 2019 the Group purchased remaining 0.39% shareholding from TBC Leasing JSC shareholders and became 100% owner of the Company. 

The summarised financial information of these subsidiaries was as follows as of 31 December 2019:

In thousands of GEL
Inspired LLC
TKT Online LLC
TKT UZ
My.GE LLC
AllProperty.ge LLC
Billing Solutions LLC
TBC Bank JSC
TBC Leasing JSC
TBC Kredit LLC
*In 2018 the Group 
purchased remaining 
25% shareholding 
from TBC Kredit LLC 
shareholders and 
became 100% owner of 
the company

Current  
assets
2,796
1,586
231
863
1,286
-
8,026,612
180,282
10,605

Non-current 
assets
1,177
1,562
5
5,845
1,053
344

Current  
liabilities
185
1,336
1
586
426
-
10,280,004 11,254,319
133,198
6,238

172,275
14,140

Non-current 
liabilities
-
-
-
-
582
-
4,520,588
182,804
5,730

Revenue
5,683
1,468
-
2,122
1,965
-
1,010,616
29,894
4,543

Profit
2,759
714
(1)
442
651
-
545,055
6,861
2,221

Total
comprehensive
income
2,756
675
(1)
442
651
-
545,080
6,861
2,221

Cash flows
1,686
1,280
230
482
697
-
(434,292)
719
473

9,507

8,821

155

435

12,023

4,725

4,725

(622)

The following table provides information about each subsidiary with a non-controlling interest as of 31 December 2018: 

In thousands of GEL
TBC Bank JSC including:

TBC Leasing JSC
TBC Kredit LLC
United Financial Corporation JSC

BG LLC

Proportion of non-controlling 
interest’s voting rights held 
0.12%
0.39%
-
1.33%

Profit attributable to
non-controlling interest
2,357
26
251
59

Accumulated non-controlling 
interest in the subsidiary
3,062
96
-
517

-

(88)

-

*In 2018 the Group purchased remaining 25% shareholding from TBC Kredit LLC shareholders and became 100% owner of the company

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

303

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

39. NON-CONTROLLING INTEREST CONTINUED

Summarised financial information of these subsidiaries was as follows as of 31 December 2018:

In thousands of GEL
TBC Bank JSC
TBC Leasing JSC
TBC Kredit LLC
United Financial 
Corporation JSC
BG LLC

Current  
assets
 7,421,134 
 160,619 
 19,639 

Non-current 
assets

Current  
liabilities
 8,031,716   9,955,303 
 138,582 
13,961

 128,610 
 14,987 

Non-current 
liabilities
 3,385,828
 126,954 
  10,813

Revenue
1,066,089
26,998
3,177

Profit
433,051
6,585
1,836

Total
comprehensive
income
448,749
6,585
1,836

Cash flows
(264,368)
10,773
(1,622)

 8,711 
 8,964 

 6,646 
 1 

 3,284 
 60 

-   
 8,993 

12,401
123

4,427
(88)

4,427
(88)

(438)
63

The following table provides information about each subsidiary with non-controlling interest as of 31 December 2017: T

In thousands of GEL
TBC Bank JSC including:

TBC Leasing JSC
TBC Kredit LLC
United Financial Corporation JSC

Proportion of non-controlling 
interest’s voting rights held 
1.33%
0.39%
25%
1.33%

Profit attributable to
non-controlling interest
5,518
14
275
63

Accumulated non-controlling 
interest in the subsidiary
29,255
70
4,165
500

he summarised financial information of these subsidiaries was as follows as of 31 December 2017:

In thousands of GEL
TBC Bank JSC
TBC Leasing JSC
TBC Kredit LLC
United Financial 
Corporation JSC

Current  
assets
6,490,075
111,169
19,771

Non-current 
assets

Current  
liabilities
6,447,122 8,830,604
95,988
11,858

87,928
20,319

Non-current 
liabilities
2,258,231
85,262
20,636

Revenue
850,450
15,236
5,172

Profit
362,429
3,436
1,098

Total
comprehensive
income
367,678
3,436
1,098

Cash flows
466,249
2,450
(3,631)

6,353

5,136

1,255

45

12,708

4,733

4,733

40

40. OFFSETTING FINANCIAL ASSETS AND FINANCIAL LIABILITIES 

As of 31 December 2019, financial instruments subject to offsetting, enforceable master netting and similar arrangements 
were as follows:

Gross amounts
before offsetting
 in the statement of 
financial position
(a)

Gross amount
 set off in the 
statement
of financial
position
(b)

Net amount after 
offsetting in the 
statement of 
financial position 
(c) = (a) - (b)

In thousands of GEL
ASSETS
Other financial assets:
 - Receivables on credit card 

services and money transfers

24,139

2,244

21,895

TOTAL ASSETS SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT
LIABILITIES
Other financial liabilities:
 - Payables on credit card services 

and money transfers

TOTAL LIABILITIES SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT

304

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

24,139

2,244

21,895

17,518

2,244

15,274

17,518

2,244

15,274

Amounts subject to
master netting and similar 
arrangements not set off in the 
statement of financial position

Financial
instruments 
(d)  

Cash collateral 
received 
(e)

Net amount of 
exposure
(c) - (d) - (e)

-

-

-

-

-

-

-

-

21,895

21,895

15,274

15,274

40. OFFSETTING FINANCIAL ASSETS AND FINANCIAL LIABILITIES CONTINUED

As of 31 December 2018, financial instruments subject to offsetting, enforceable master netting and similar arrangements 
were as follows: 

Gross amounts
before offsetting
 in the statement of 
financial position
(a)

Gross amount
 set off in the 
statement
of financial
position
(b)

Net amount after 
offsetting in the 
statement of 
financial position 
(c) = (a) - (b)

Amounts subject to
master netting and similar 
arrangements not set off in the 
statement of financial position

Financial
instruments 
(d)  

Cash collateral 
received 
(e)

Net amount of 
exposure
(c) - (d) - (e)

In thousands of GEL
ASSETS
Other financial assets:
 - Receivables on credit card 

services and money transfers

17,544

3,154

14,390

TOTAL ASSETS SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT
LIABILITIES
Other financial liabilities:
 - Payables on credit card services 

and money transfers

TOTAL LIABILITIES SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT

17,544

3,154

14,390

21,426

3,154

18,272

21,426

3,154

18,272

-

-

-

-

-

-

-

-

14,390

14,390

18,272

18,272

As of 31 December 2017, financial instruments subject to offsetting, enforceable master netting and similar arrangements 
were as follows: 

Gross amounts
before offsettin
 in the statement of 
financial position
(a)

Gross amount
 set off in the 
statement
of financial
position
(b)

Net amount after 
offsetting in the 
statement of 
financial position 
(c) = (a) - (b)

Amounts subject to
master netting and similar 
arrangements not set off in the 
statement of financial position

Financial
instru-ments 
(d)  

Cash collateral 
received 
(e)

Net amount of 
exposure
(c) - (d) - (e)

In thousands of GEL
ASSETS
Other financial assets:
 - Receivables on credit card 

services and money transfers

29,308

2,605

26,703

TOTAL ASSETS SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT
LIABILITIES
Other financial liabilities:
 - Payables on credit card services 

and money transfers

TOTAL LIABILITIES SUBJECT TO 
OFFSETTING, MASTER NETTING 
AND SIMILAR ARRANGEMENT

29,308

2,605

26,703

12,964

2,605

10,359

12,964

2,605

10,359

-

-

-

-

-

-

-

-

26,703

26,703

10,359

10,359

The amount set off in the statement of financial position reported in column (b) is the lower of (i) the gross amount before 
offsetting reported in column (a) and (ii) the amount of the related instrument that is eligible for offsetting. Similarly, the 
amounts in columns (d) and (e) are limited to the exposure reported in column (c) for each individual instrument in order not 
to understate the ultimate net exposure.

Deposits placed with other banks and deposits received from other banks as part of gross settled currency swap arrangements 
have been netted-off in these financial statements and the instrument has been presented as either asset or liability at a fair value. 

The disclosure does not apply to loans and advances to customers and related customer deposits unless they are netted-off 
in the statement of financial position.

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

305

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

41. DERIVATIVE FINANCIAL INSTRUMENTS 

In the normal course of business, the Group enters into various derivative financial instruments, to manage currency, liquidity 
and interest rate risks and for trading purposes. 

In thousands of GEL
Fair value of gross settled currency swaps,
included in other financial assets or due from banks
Fair value of foreign exchange forwards and gross settled currency swaps, 
included in other financial liabilities
Fair value of Interest rate swaps, included in other financial liabilities
Total

2019

5,849

(20,266)
-
(14,417)

2018

1,490

(2,085)
-
(595)

2017

1,767

 (909)
 (267)
591

Foreign Exchange Forwards and gross settled currency swaps. Foreign exchange derivative financial instruments the Group 
entered are generally traded in an over-the-counter market with professional counterparties on standardised contractual 
terms and conditions. Derivatives have potentially favourable (assets) or unfavourable (liabilities) conditions as a result of 
fluctuations in market interest rates, foreign exchange rates or other variables relative to their terms. The aggregate fair 
values of derivative financial assets and liabilities can fluctuate significantly from time to time.

The table below sets out fair values, at the balance sheet date, of currencies receivable or payable under foreign exchange 
forwards contracts and gross settled currency swaps the Group entered. The table reflects gross positions before the netting 
of any counterparty positions (and payments) and covers the contracts with settlement dates after the respective balance 
sheet date. The contracts are short term by their nature.

In thousands of GEL
Foreign exchange forwards and 
gross settled currency swaps: fair 
values, at the balance sheet date, of
 - USD payable on settlement (-)
 - USD receivable on settlement (+)
 - GEL payable on settlement (-)
 - GEL receivable on settlement (+)
 - EUR payable on settlement (-)
 - EUR receivable on settlement (+)
 - Other payable on settlement (-)
 - Other receivable on settlement (+)
Fair value of foreign exchange 
forwards and gross settled 
currency swaps
Net fair value of foreign exchange 
forwards and gross settled 
currency swaps

2019

2018

2017

Contracts with 
positive fair
value

Contracts with 
negative fair 
value

Contracts with 
positive fair 
value

Contracts with 
negative fair 
value

Contracts with 
positive fair 
value

Contracts with 
negative fair 
value

-
  2,089,038
-
105,152
-
  25,239
-
  60,652

(133,987)
-
(205,292)
-
  (1,950,702)
-
(4,517)
-

-
 105,753 
-
442,831
-
 32,052 
-
 1,158 

  (19,631)
-
 (119,520)
-
 (441,617)
-
 (1,621)
-

-
 12,877 
-
 165,881 
-
 -   
-
 1,348 

 (166,326)
-
 (1,360)
-
 (9,315)
-
 (2,247)
-

2,280,081        (2,294,498)

      581,794 

      (582,389)

 180,106 

 (179,248)

(14,417)

(595)

858

Interest rate swaps. In March 2010 TBC Bank entered into an interest rate swap agreement, to hedge floating interest rate 
on its subordinated debt. The hedge covers the payment of floating rate interest payments with the notional principal of USD 
44,000 thousand. The swap expired in November 2018. At the reporting date in 2018 the fair value of interest rate swaps was 
negative GEL 267 thousand; 2017: negative GEL 267 thousand).

Information on related party balances is disclosed in Note 44.

306

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

42. FAIR VALUE DISCLOSURES

(a) Recurring fair value measurements 
Recurring fair value measurements are those that the accounting standards require or permit in the statement of financial 
position  at  the  end  of  each  reporting  period.  The  level  in  the  fair  value  hierarchy  into  which  the  recurring  fair  value 
measurements are categorised as follows:

31 December 2019

31 December 2018

31 December 2017

Level 1 

Level 2 

Level 3

Total Level 1 

Level 2 

Level 3

Total Level 1 

Level 2  Level 3

Total

In thousands of GEL
ASSETS AT FAIR VALUE
FINANCIAL ASSETS 
Investment securities 
measured at fair 
value through other 
comprehensive income
 - Government notes
 - Certificates of 

Deposits of National 
Bank of Georgia
 - Corporate bonds
 - Netherlands 

Government Bonds
 - Ministry of Finance 

Treasury Bills
 - Foreign exchange 

forwards and gross 
settled currency 
swaps, included in 
other financial assets 
or due from banks

NON-FINANCIAL 
ASSETS
 - Premises and 
leasehold 
improvements

TOTAL ASSETS 
RECURRING
FAIR VALUE 
MEASUREMENTS 

LIABILITIES CARRIED 
AT FAIR VALUE

FINANCIAL LIABILITIES 

 - Interest rate swaps 
included in other 
financial liabilities

Foreign exchange 
forwards and gross 
settled currency swaps, 
included in other 
financial liabilities

TOTAL LIABILITIES 
RECURRING 
FAIR VALUE 
MEASUREMENTS 

 -   

 - 

 -   

-

 -   

 - 

 -   

-

-

-

40,346
611,000

14,982
-
- 548,864

1,596

-

66,760

329,352

- 372,927

-
-

-

-

14,982
548,864

-
7,728
- 328,761

66,760

-

-

372,927

- 319,745

-

-
-

-

-

-

7,728
328,761

-

319,745

5,849

-

1,490

-

1,490

-

1,767

-

1,767

40,346
611,000

1,596

329,352

5,849

-
-

-

-

-

-
-

-

-

-

-

- 212,376

212,376

-

- 277,798

277,798

-

- 283,905

283,905

-

988,143 212,376 1,200,519

- 1,005,023 277,798 1,282,821

- 658,001 283,905

941,906

-

-

-

-

20,266

20,266

-

-

-

-

20,266

20,266

-

-

-

-

2,085

2,085

-

-

-

-

2,085

2,085

-

-

-

267

909

1,176

-

-

-

267

909

1,176

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

307

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

42. FAIR VALUE DISCLOSURES CONTINUED

There were no transfers between levels 1 and 2 during the year ended 31 December 2019 (2018 none, 2017: none). For 
sensitivity disclosures of premises and leasehold improvements please refer to the Note 15.

(a) Recurring fair value measurements (continued)
The  description  of  the  valuation  technique  and  the  description  of  inputs  used  in  the  fair  value  measurement  for  level  2 
measurements:

In thousands of GEL
ASSETS AT FAIR VALUE
FINANCIAL ASSETS 
 - Certificates of Deposits of NBG, Ministry of 
Finance Treasury Bills, Government notes, 
Corporate bonds

 - Foreign exchange forwards and gross 

settled currency swaps,
included in due from banks

TOTAL ASSETS RECURRING
FAIR VALUE MEASUREMENTS
LIABILITIES CARRIED AT FAIR VALUE
FINANCIAL LIABILITIES 
Other financial liabilities 

 - Interest rate swaps included in other 

financial liabilities

 - Foreign exchange forwards included in 

other financial liabilities

TOTAL RECURRING FAIR VALUE 
MEASUREMENTS  AT LEVEL 2

Fair value at 31 December

2019

2018

2017

Valuation technique

Inputs used

982,295

1,003,533

656,234

5,848

1,490

1,767

988,143

1,005,023

658,001

Discounted
cash flows
(“DCF”)
Forward pricing 
using present value 
calculations

Government
bonds yield
curve
Official
exchange rate,
risk-free rate

-

-

267

20,266

20,266

2,085

909

2,085

1,176

Swap model using 
present value 
calculations 
Forward pricing 
using present value 
calculations

Observable yield 
curves
Official
exchange rate,
risk-free rate

There were no changes in the valuation technique for the level 2 and level 3 recurring fair value measurements during the 
year ended 31 December 2019 (2018: none; 2017: none).  

Fair value measurement analysis by level in the fair value hierarchy is disclosed in Note 2.

For details the techniques and inputs used for Level 3 recurring fair value measurement of (as well as reconciliation of 
movements in) premises refer to
Note 15. The unobservable input to which the fair value estimate for premises is most sensitive is price per square meter: 
the higher the price per square meter,
the higher the fair value.

308

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

42. FAIR VALUE DISCLOSURES CONTINUED

(b) Assets and liabilities not measured at fair value but for which fair value is disclosed
Fair values analysed by level in the fair value hierarchy and carrying value of assets not measured at fair value are as follows: 

31 December 2019

31 December 2018

31 December 2017

Level 1 

Level 2 

Level 3

Carrying 
Value

Level 1 

Level 2 

Level 3

Carrying 
Value

Level 1 

Level 2 

Level 3

Carrying 
Value

 650,700 

 352,883   

 -   

 33,605 

 -   

 -   

 1,003,583 

 491,928 

 674,983   

 -   

 1,166,911  419,605

1,011,872

 33,605 

 -   

 47,316 

 -   

 47,316 

-

1,591,829

-

1,591,829

-

1,422,809

-

1,422,809

 -   

 -   

 -   

 -   

 -   

 -   

4,838,348

4,579,723

1,876,364

1,750,050

3,354,901

3,137,492

 -   

 -   

 -   

 -   

3,212,490

3,095,784

 -   

1,970,006

1,832,793

 -   

2,702,768

2,684,295

 -   

 -   

2,891,382

2,882,134

 -   

 -   

2,440,078

2,425,580

-

990,537

-

1,022,684

-

660,916

-

654,203 

 -   

-

 -   

265,165

256,660

 -   

 -   

207,579

203,802

-

127,888

127,888

-

-

166,028

166,028

 -   

 -   

123,325

72,667

 -   

 -   

97,425

84,296

-

-

-

1,431,477

39,643

1,033,818

39,643

1,033,818

-

-

-

-

3,292,352

2,425,766

2,125,733

2,041,887

2,058,468

2,052,151

1,891,528

1,805,549

458,950

-

449,538

-

-

-

145,877

143,836

144,377

144,377

85,012

79,232

-

-

-

-

-

-

-

-

-

-

TOTAL ASSETS

650,700 2,968,854  13,477,373    16,458,315  491,928  2,806,024    10,796,374   13,783,817  419,605

2,544,283 9,743,347   11,647,274 

-

-

1,136,297

3,600,318

-

3,593,901

6,480,250 3,580,630 10,049,324

-

-

153,240

594,893 

-

-

-

 1,136,297 

153,240  

 591,035 

1,136,297 10,828,701  3,580,630 15,523,797

-

-

-

-

-

-

3,028,180

-

3,031,503

5,885,242 3,482,741

9,352,142

13,343

96,629

648,802 

-

-

-

 13,343 

 96,629 

 650,919 

9,672,196  3,482,741 13,144,536

-

-

-

-

-

-

2,626,155

-

2,620,714

4,992,099 2,937,349

7,816,817

20,695

-

20,695

 90,577 

 -   

 90,577 

425,809

-

426,788

8,155,335  2,937,349  10,975,591 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

309

In thousands of 
GEL

FINANCIAL
ASSETS 

Cash and cash 
equivalents 

Due from
other banks

 - Mandatory 

cash
balances with 
the NBG

 - Loans and

advances to 
customers:

 - Corporate
loans

 - Consumer

loans

 - Mortgage
loans

 - Loans to

micro, small
and medium
enterprises

Bonds carried at 
amortised cost

Investments
in leases

Other
financial assets 

NON-
FINANCIAL 
ASSETS

Investment
properties,
at cost

FINANCIAL
LIABILITIES 

Due to credit 
institutions

Customer
accounts

Debt securities
in issue

Other financial 
liabilities 

Subordinated 
debt

TOTAL 
LIABILITIES

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

42. FAIR VALUE DISCLOSURES CONTINUED

The fair values in the level 2 and level 3 of fair value hierarchy were estimated using the discounted cash flows valuation 
technique. The fair value of unquoted fixed interest rate instruments was calculated based on estimated future cash flows 
expected to be received discounted at current interest rates for new instruments with similar credit risk and remaining 
maturity. The fair value of investment properties was estimated using market comparatives (refer to Note 17). 
Amounts due to credit institutions were discounted at the Group’s own incremental borrowing rate. Liabilities due on demand 
were discounted from the first date that the Group could be required to pay the amount. There were no changes in the 
valuation technique for the level 2 and level 3 measurements of assets and liabilities not measured at fair values in the year 
ended 31 December 2019 (2018: none; 2017: none). 

43. PRESENTATION OF FINANCIAL INSTRUMENTS BY MEASUREMENT CATEGORY
For the measurement purposes, IFRS 9, classifies financial assets into the categories discussed in Note 2. The following 
table provides a reconciliation of classes of financial assets with these measurement categories as of 31 December 2019: 

In thousands of GEL
ASSETS
Cash and cash equivalents
Due from other banks
Mandatory cash balances with the National Bank of 
Georgia
Loans and advances to customers
Investment securities measured at fair value FVOCI 
Bonds carried at amortised cost
Other financial assets
TOTAL FINANCIAL ASSETS SUBJECT TO IFRS 9 
MEASUREMENT CATEGORIES
INVESTMENTS IN LEASES
NON-FINANCIAL ASSETS
TOTAL ASSETS

Amortised cost

Fair value through other 
comprehensive income

Fair value through 
profit or loss

Total 

1,003,583
33,605

1,591,829
12,349,399
-
1,022,684
133,736

16,134,836
-
-
-

-
-

-
-
985,293
-
-

985,293
-
-
-

-
-

-
-
-
-
-

-
-
-
-

1,003,583
33,605

1,591,829
12,349,399
985,293
1,022,684
133,736

17,120,129
256,660
1,033,485
18,410,274

For  the  periods  before  1  January  2018:  for  the  measurement  purposes,  IAS  39,  Financial  Instruments:  Recognition  of 
Measurement, classifies financial assets into the following categories: (a) loans and receivables; (b) available for sale financial 
assets; (c) financial assets held to maturity and (d) financial assets at fair value through profit or loss (“FVTPL”). Financial 
assets at fair value through profit or loss have two subcategories: (i) assets designated as such upon initial recognition, and 
(ii) those classified as held for trading. In addition, net investments in lease form a separate category. The following table 
provides a reconciliation of classes of financial assets with these measurement categories as of 31 December 2018:

In thousands of GEL
ASSETS
Cash and cash equivalents
Due from other banks
Mandatory cash balances with the National Bank of 
Georgia
Loans and advances to customers
Investment securities measured at fair value through 
other comprehensive income
Bonds carried at amortised cost
Other financial assets
TOTAL FINANCIAL ASSETS SUBJECT TO IFRS 9 
MEASUREMENT CATEGORIES
INVESTMENTS IN LEASES
NON-FINANCIAL ASSETS
TOTAL ASSETS

310

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

Amortised cost

Fair value through other 
comprehensive income

Fair value through 
profit or loss

Total 

1,166,911
47,316

1,422,809
10,038,452

-
654,203
167,518

13,497,209
-
-
-

-
-

-
-

1,005,239
-
-

1,005,239
-
-
-

-
-

-
-

-
-
-

-
-
-
-

1,166,911
47,316

1,422,809
10,038,452

1,005,239
654,203
167,518

14,502,448
203,802
791,743
15,497,993

43. PRESENTATION OF FINANCIAL INSTRUMENTS BY MEASUREMENT CATEGORY CONTINUED

The  following  table  provides  a  reconciliation  of  classes  of  financial  assets  with  these  measurement  categories  as  of  31 
December 2017:

In thousands of GEL
ASSETS
Cash and cash equivalents
Due from other banks
Mandatory cash balances
with the National Bank of Georgia
Loans and advances to customers
Investment securities available for sale
Bonds carried at amortised cost
Investments in leases
Other financial assets:
- Other financial receivables
TOTAL FINANCIAL ASSETS
NON-FINANCIAL ASSETS
TOTAL ASSETS

Loans and 
receivables

Available
for sale assets

Net  investments 
in lease

Assets held
for trading

1,431,477
39,643

1,033,818
8,325,353
-
449,538
-

144,377
11,424,206
-
-

-
-

-
-
657,938
-
-

-
657,938
-
-

-
-

-
-
-
-
143,836

-
143,836
-
-

Total 

1,431,477
39,643

1,033,818
8,325,353
657,938
449,538
143,836

-
-

-
-
-
-
-

1,767
1,767
-
-

146,144
12,227,747
738,163
12,965,910

The  following  table  provides  a  reconciliation  of  classes  of  financial  assets  with  these  measurement  categories  as  of  31 
December 2017:
As of 31 December 2019 and 2018 all of the Group’s financial liabilities except for derivatives are carried at amortised cost. 
Derivatives belong to the assets fair value through profit or loss measurement category under IFRS 9.
As of 31 December 2017, all of the Group’s financial liabilities except for derivatives are carried at amortised cost. Derivatives 
belong to the assets held for trading measurement category under IAS 39.

44. RELATED PARTY TRANSACTIONS
Pursuant  to  IAS  24  “Related  Party  Disclosures”,  parties  are  generally  considered  to  be  related  if  the  parties  are  under 
common control or one party has the ability to control the other or it can exercise significant influence over the other party in 
taking financial or operational decisions. In considering each possible related party relationship, attention is directed to the 
substance of the relationship, not merely the legal form:

 ` Parties  with  more  than  10%  of  ownership  stake  in  the  TBCG  or  with  representatives  in  the  Board  of  Directors  are 

considered as Significant Shareholders. 

 ` The key management personnel include members of TBCG’s Board of Directors, the Management Board of the Bank and 

their close family members. 

Transactions between TBC Bank Group PLC and its subsidiaries also meet the definition of related party transactions. Where 
these are eliminated on consolidation, they are not disclosed in the Group Financial Statements. 

The definition of the related party is different per standards of National Bank of Georgia and is regulated by the published 
Decree N 26/04 of the Governor of the National Bank of Georgia (link to the document below in the footnote1).

As of 31 December 2019, the Group’s outstanding balances with related parties were as follows: 

In thousands of GEL
Gross amount of loans and advances to customers 
(contractual interest rate: 6.6% – 36.0%)
Impairment provisions for loans
and advances to customers 
Customer accounts
(contractual interest rate: 0.0% – 11.5%)

Significant shareholders

Key management personnel

 77 

 - 

 16,418 

 9,723 

 1 

 12,997 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

311

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

44. RELATED PARTY TRANSACTIONS CONTINUED

The Group’s income and expense items with related parties except from key management compensation for the year 2019 
were as follows: 

In thousands of GEL
Interest income - loans and advances to customers
Interest expense

Gains less losses from
trading in foreign currencies

Foreign exchange translation gains less losses 
Fee and commission income
Administrative and other operating expenses
(excluding staff costs)

Significant shareholders
 42 
 87 

Key management personnel
 620 
 197 

 159 

50
 77 

68

 68 

283
 61 

978

The Group’s income and expense items with related parties except from key management compensation for the year 2019 
were as follows: 

In thousands of GEL
Amounts advanced to related parties during the year 
Amounts repaid by related parties during the year

Significant shareholders
 249 
 (1,878)

Key management personnel
 15,160 
 (17,747)

During the year 2019, 3 related parties were removed from the insider list. If they had remained in the list, customer accounts 
with related parties as of 31 December 2019 would have been GEL  266 thousand higher.

As of 31 December 2019, transactions and balances of TBC Bank Group PLC with JSC TBC Bank were as follows: 

In thousands of GEL
Due from other banks (contractual interest rate: 8.05% – 9.03 %)
Cash and cash equivalents

Investment in subsidiary

Balance as of 31 December 2019
40,815
6,612

1,463,084

Included in Investments in subsidiary in Separate Statement of Financial Position GEL 7,823 thousands relates to investment 
in JSC TBC Insurance.

The income and expense items for TBC Bank Group PLC with JSC TBC Bank except from key management compensation 
for the year 2019 were as follows: 

In thousands of GEL
Interest income
Fee and commission expense

Dividend income

2019
5,625
48

109,520

As of 31 December 2018, the Group’s outstanding balances with related parties were as follows: 

In thousands of GEL
Gross amount of loans and advances to customers 
(contractual interest rate: 0.4% – 48.0%)
Impairment provisions for loans and advances to customers 

Customer accounts (contractual interest rate: 0.0% – 10.2 %)
Guarantees
Provision on guarantees 

Significant shareholders

Key management personnel

                                     1,614 
-

                                   27,095 
10,216
36

                                   11,407 
9

                                   21,328 
-
-

1  https://www.nbg.gov.ge/uploads/legalacts/fts/eng/regulation_on_the_management_of_the_conflict_of_interests.pdf

312

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

44. RELATED PARTY TRANSACTIONS CONTINUED

The Group’s income and expense items with related parties except from key management compensation for the year 2018 
were as follows:

In thousands of GEL
Interest income - loans and advances to customers
Interest expense
Gains less losses from trading in foreign currencies

Foreign exchange translation gains less losses 
Fee and commission income
Administrative and other operating expenses
(excluding staff costs)

Significant shareholders
 22 

Key management personnel
 591 

 411 
 479 

 28
 87 

89

 301 
 65 

352
 50 

297

 The aggregate loan amounts advanced to, and repaid, by related parties during 2018 were as follows: 

In thousands of GEL
Amounts advanced to related parties during the year 
Amounts repaid by related parties during the year

Significant shareholders
 2,465 
 (1,055)

Key management personnel
13,547
 (10,195)

During the year 2018, 7 related parties were removed from the insider list. If they had remained in the list, customer accounts 
with related parties as of 31 December 2018 would have been GEL 227 thousand higher.

As of 31 December 2018, transactions and balances of TBC Bank Group PLC with JSC TBC Bank were as follows: 

In thousands of GEL
Due from other banks (contractual interest rate: 8.05% – 9.03 %)
Cash and cash equivalents

Investment in subsidiary

Balance as of 31 December 2018
79,135
2,176

1,465,345

Included in Investments in subsidiary in Separate Statement of Financial Position GEL 7,823 thousands relates to investment 
in JSC TBC Insurance.

The income and expense items for TBC Bank Group PLC with JSC TBC Bank except from key management compensation 
for the year 2018 were as follows: 

In thousands of GEL
Interest income
Fee and commission expense

Dividend income

2018
5,879
3

124,561

As of 31 December 2017, the Group’s outstanding balances with related parties were as follows: 

In thousands of GEL
Gross amount of loans and advances to customers 
(contractual interest rate: 0.4% - 36.0%)
Impairment provisions for loans and advances to customers 

Customer accounts (contractual interest rate: 0.0% – 11.8 %)

Guarantees
Provision on guarantees 

Significant shareholders

Key management personnel

154
- 

 40,100
9,901

30

 7,112 
 11 

 11,190 

 512 

2

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

313

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

44. RELATED PARTY TRANSACTIONS CONTINUED

The Group’s income and expense items with related parties except from key management compensation for the year 2017 
were as follows: 

In thousands of GEL
Interest income - loans and advances to customers
Interest income - available securities for sale
Interest expense

Gains less losses from trading in foreign currencies

Foreign exchange translation gains less losses 

Fee and commission income

Fee and commission expense
Administrative and other operating expenses
(excluding staff costs)
Net loss on derivative financial instruments

Significant shareholders
 20 
747
928 

Key management personnel
 444 
-
 449 

 108 

(46)

 122 

104

58
46

 56 

(36)

 94 

-

239
-

The aggregate loan amounts advanced to, and repaid, by related parties during 2017 were as follows: 

In thousands of GEL
Amounts advanced to related parties during the year 
Amounts repaid by related parties during the year

Significant shareholders
 573 
 (1,293)

Key management personnel
 3,012 
 (3,920)

During the year 2017, 13 related parties were removed from the insider list. If they had remained in the list, guarantees with 
related parties as of 31 December 2017 would have been GEL 1,139 thousand higher, net assets with related parties as of 31 
December 2017 would have been GEL 214,767 thousand lower.

As of 31 December 2017, transactions and balances of TBC Bank Group PLC with JSC TBC Bank were as follows: 

In thousands of GEL
Loans and advances to customers
Due from other banks

Cash and cash equivalents

Investment in subsidiary

Balance as of 31 December 2017
24,000
11,564

57

1,422,462

Included in Investments in subsidiary in Separate Statement of Financial Position GEL 7,023 thousands relates to investment 
in JSC TBC Insurance.

The income and expense items for TBC Bank Group PLC with JSC TBC Bank except from key management compensation 
for the year 2017 were as follows: 

In thousands of GEL
Interest income
Interest expense

Fee and commission expense

2017
1,807
9

90,552

314

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

44. RELATED PARTY TRANSACTIONS CONTINUED

The compensation of the TBCG Board of Directors and the Bank’s Management Board is presented below: 

In thousands of GEL
Salaries and bonuses

Cash settled bonuses related to share-based compensation

Equity-settled share-based compensation 

Total

2019

Accrued 
liability
-

-

-

-

Expense
12,481

6,424

9,369

28,274

2018

Accrued 
liability
270

8,395

-

Expense
13,339

3,905

8,469

2017

Accrued 
liability
-

9,772

-

8,665

25,713

9,772

Expense
10,274

(1,627)

25,695

34,342

Included in salaries and bonuses for 2019, GEL 2,879 thousand (2018: GEL 2,347 thousand; 2017: GEL 2,326  thousand) 
relates to compensation for directors (2019: 9 person, 2018: 8 person, 2017: 8 person) of TBCG paid by TBC Bank Group PLC. 
Details of director’s compensation is discussed in the remuneration comittee report. Details of director’s compensation is 
discussed in the remuneration comittee report.

45. BUSINESS COMBINATION
Acquisition of Inspired LLC
In May 2019 TBC bank group PLC finalized acquisition process of Inspired LLC – the leading payment platform “Payme”. The 
acquired interest amounted 51% of total shareholding. The transaction is in line with the Group’s international expansion 
strategy of operations. The consideration amounted GEL 14,981 thousands.

The acquisition-date fair value of the total purchase consideration is follows: 

In thousands of GEL
Cash consideration paid
Total purchase consideration

14,981
14,981

The  consideration  paid  by  the  Group  was  based  on  results  of  an  appraisal  of  the  acquiree’s  business  taken  as  a  whole. 
However, in accordance with IFRS 3 “Business Combinations”, the Group must account for acquisitions based on fair values 
of the identifiable assets acquired and liabilities and contingent liabilities assumed. These two different approaches can lead 
to differences; and, as set out in the table below, recognition of goodwill. Details of the assets and liabilities acquired and 
goodwill arising is as follows: 

In thousands of GEL
Cash and cash equivalents 
Due from other banks

Other financial assets

Premises and equipment

Intangible assets 

Other assets

Other liabilities

Fair value of net assets of subsidiary

Non-controlling interest

Goodwill arising from the acquisition

Total purchase consideration

Less: cash and cash equivalents of subsidiary acquired

Outflow of cash and cash equivalents on acquisition

Fair Values 
 223 
 424 

 676 

 379 

 212 

 79 

 (159)

1,834

(868)

14,015

14,981

(223)

14,758

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

315

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

45. BUSINESS COMBINATION CONTINUED

The goodwill is primarily attributable to the profitability of the acquired business and the positive synergies expected to arise.  

The acquired business combination contributed to Group’s net revenue in the amount of GEL 5,683 thousand and to Group’s 
net profit in the amount of GEL 2,759 thousand from the date of acquisition to 31 December 2019. If the acquisition had 
occurred on 1st of January 2019, the contribution to the Group’s net revenues for the year ended 31 December 2019 would 
have been of GEL 8,561 thousand and to net profit would have been positive of GEL 4,272 thousand.

Acquisition of My.ge LLC
In August 2019 TBC bank group PLC finalized acquisition process of LLC My.ge – the leading online services platform in 
Georgia “My Group”. The acquired interest amounted 65% of total shareholding. The transaction is in line with the Group’s 
international expansion strategy of operations. The consideration amounted GEL 19,450 thousands.

The acquisition-date fair value of the total purchase consideration is follows: 

In thousands of GEL
Cash consideration paid
Total purchase consideration

19,450
19,450

The  consideration  paid  by  the  Group  was  based  on  results  of  an  appraisal  of  the  acquiree’s  business  taken  as  a  whole. 
However, in accordance with IFRS 3 “Business Combinations”, the Group must account for acquisitions based on fair values 
of the identifiable assets acquired and liabilities and contingent liabilities assumed. These two different approaches can lead 
to differences; and, as set out in the table below, recognition of goodwill. Details of the assets and liabilities acquired and 
goodwill arising is as follows 

In thousands of GEL
Cash and cash equivalents 
Other financial assets

Premises and equipment

Intangible assets 

Other assets

Other financial liabilities

Other liabilities

Fair value of net assets of subsidiary

Non-controlling interest

Goodwill arising from the acquisition

Total purchase consideration

Less: cash and cash equivalents of subsidiary acquired

Outflow of cash and cash equivalents on acquisition

Fair Values 
1,667
232

1,208

4,403

1

(1,862)

(51)

5,598

(1,960)

15,812

19,450

(1,667)

17,783

The goodwill is primarily attributable to the profitability of the acquired business and the positive synergies expected to arise.  

The acquired business combination contributed to Group’s net revenue in the amount of GEL 2,122 thousand and to Group’s 
net  profit  in  the  amount  of  GEL  442  thousand  from  the  date  of  acquisition  to  31  December  2019.  If  the  acquisition  had 
occurred on 1st of January 2019, the contribution to the Group’s net revenues for the year ended 31 December 2019 would 
have been of GEL 5,208 thousand and to net profit would have been positive of GEL 1,497 thousand.

316

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

46. EVENTS AFTER REPORTING PERIOD

COVID 19- outbreak

In late February 2020 the first incident of the coronavirus (COVID-19) was reported in Georgia. This is clearly a serious situation 
impacting not just Georgia, but also the global economy. The position has been, and continues to be difficult to predict with 
any certainty. The Group does not consider COVID-19 to be an adjusting event and as such any impacts are not reflected within 
these financial statements. Our economists’ latest analysis forecasts the Georgian economy to contract in 2020, which will 
have a negative impact on many businesses and individuals in the country.  Therefore, in close co-ordination with the National 
Bank of Georgia (“NBG”), we have decided to create an extra loan loss provision buffer to prepare for the potential impact of 
the COVID-19 pandemic on the Georgian economy. 

TBC Bank has implemented a number of actions to protect its customers and staff members and to minimize disruption to 
the  Group’s  operations  during  the  COVID-19  outbreak.  In  developing  our  response,  we  have  looked  at  best  practices  from 
major global companies as well as organizations like the World Health Organization.  We are also closely coordinating with 
the Government of Georgia, NBG and the other banks in the country. While for the time being most of our branches remain 
open, we have introduced a number of additional security and infection prevention measures in our branch network. We have 
introduced  remote  working  practices  for  most  of  our  head  office  and  back  office  units  and  divided  all  our  critical  service 
units into different groups and locations. We have also refreshed the list of critical roles in the company and ensured their 
continuous operational engagement and remote access.

In  order  to  support  our  customers  during  the  coming  difficult  months,  in  coordination  with  the  Government,  NBG  and  the 
banking sector, we have introduced a three-month grace period on principle and interest payments for all our individual and 
MSME customers as well as those corporate customers whose business is the most exposed in the current situation.

Our digital penetration is very high, mainly driven by mobile banking transactions. To ensure continued communication and 
customer care, we have activated and enhanced all our channels, launched intensive communication campaigns to promote 
cashless transactions (cash is a potential transmission vector for the virus) and active usage of our digital channels.  For the 
next three months, we have revised tariff plans to further incentivize our digital channel usage. The multichannel promotion 
campaigns together with the loan repayment grace period are expected to substantially decrease customer flow in our branch 
network  and  reduce  the  risk  of  spreading  the  infection.  If  needed,  this  will  allow  us  to  further  optimize  branch  network 
operations and decrease the number of front office staff as well as to introduce different shifts in branches.  In terms of our IT 
infrastructure, we have rigorous measures to ensure adequate capacity and security, and we are closely monitoring the system 
with all controls active.

We expect the pandemic to have a negative economic effect as long as the number of cases is expanding, but we expect a 
gradual return of economic strength as the number of cases eases.  The government has come up with a number of initiatives 
to support businesses and the economy. 

The group assessed the changes in the environment on its capital and liquidity positions and is comfortable that it can keep 
solid financial standing. Management will keep monitoring the developments and update its strategy and course of actions as 
necessary in circumstances.

However, taking into consideration the unprecedented uncertainty triggered by the COVID-19 outbreak, the Board of Directors 
has decided not to recommend a dividend.  The decision will be revisited once there is better visibility on the potential economic 
impact of the outbreak, which we do not expect to occur before the end of May 2020.

Banking licence in Uzbekistan

In April 2019 the Group’s subsidiary, TBC Bank in Uzbekistan (“TBC UZ”), has obtained its banking licence and is planning 
to  launch  banking  operations  in  June  2020.  The  range  of  products  offered  by  the  bank  at  launch  will  include  current  and 
savings accounts, cash loans, salary backed loans and car loans; and  cards, mobile application and transactional capabilities 
including (but not limited to) P2P transactions, money transfers and utility payments. In addition, the bank will also run the 
point-of-sale consumer finance operation. 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

317

NOTES TO THE FINANCIAL STATEMENTS CONTINUED 

FULL LIST OF RELATED UNDERTAKINGS AND THE COUNTRY
OF INCORPORATION IS SET OUT BELOW

Company Name
JSC TBC Bank 

Country of incorporation
7 Marjanishvili Street, 0102, Tbilisi, Georgia

United Financial Corporation JSC

154 Agmashenebeli Avenue, 0112, Tbilisi, Georgia

TBC Capital LLC

TBC Leasing JSC

TBC Kredit LLC

11 Chavchavadze Avenue, 0179, Tbilisi, Georgia

80 Chavchavadze Avenue, 0162,, Tbilisi, Georgia

71-77, 28 May Street, AZ1010, Baku, Azerbaijan

Banking System Service Company LLC

7 Marjanishvili Street, 0102, Tbilisi, Georgia

TBC Pay LLC

TBC Invest LLC

Index LLC

JSC TBC Insurance

Redmed LLC

TBC Invest International Ltd

University Development Fund

JSC CreditInfo Georgia

LTD Online Tickets

VENDOO LLC

Swoop JSC

Natural Products of Georgia LLC

Mobi Plus JSC

7 Marjanishvili Street, 0102, Tbilisi, Georgia

7 Jabonitsky street, , 52520, Tel Aviv, Israel

8 Tetelashvili,0102,, Tbilisi, Georgia

24B, Al. Kazbegi Avenue, 0160, Tbilisi, Georgia

24 Al. Kazbegi Avenue, 0160, Tbilisi, Georgia

7 Marjanishvili Street, 0102, Tbilisi, Georgia

1 Chavchavadze Avenue, 0128 , Tbilisi, Georgia

2 Tarkhnishvili street, 0179, Tbilisi, Georgia

3 Irakli Abashidze street, 0179, Tbilisi, Georgia

3 Chavchavadze Avenue, 0128, Tbilisi, Georgia

74 Chavchavadze Avenue, 0162, Tbilisi, Georgia

1 Chavchavadze Avenue, 0128 , Tbilisi, Georgia

45 Vajha Pshavela Street, 0177, Tbilisi, Georgia

Mineral Oil Distribution Corporation JSC 

11 Tskalsadeni Street, 0153, Tbilisi, Georgia

Georgian Card   JSC 

106 Beliashvili Street, 0159, Tbilisi Georgia

Georgian Securities Central Depositor

74 Chavchavadze Avenue, 0162, Tbilisi, Georgia

JSC Givi Zaldastanishvili American Academy In Georgia

37 Chavchavadze Avenue, 0162, Tbilisi Georgia

United Clearing Centre

GRDC

5 Sulkhan Saba Street, 0105, Tbilisi, Georgia

2 Vagzali Square, 0112, Tbilisi, Georgia

Banking and Finance Academy of Georgia

123, Agmashenebeli Avenue, 0112, Tbilisi, Georgia

Tbilisi's City JSC

Swift

TBC Trade

15 Rustaveli Avenue, 0108, Tbilisi Georgia

1 Adele Avenue, B-1310, La Hulpe, Belgium

11A Chavchavadze Ave, 0179, Tbilisi, Georgia

318

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

SHAREHOLDERS INFORMATION

REPORTS AND COMMUNICATIONS
We issue regulatory announcements through the Regulatory News Service (“RNS”). Our regulatory announcements are also 
available at our website www.tbcbankgroup.com in the “regulatory news” section.

SHARE PRICE INFORMATION
Our latest and historical share prices are available through our website www.tbcbankgroup.com.

SHAREHOLDER INQUIRES
TBC Bank Group’s share register is maintained by Equiniti.
If you have any questions about your TBC Bank Group’s shares, please contact Equiniti

SHAREHOLDER HELPLINE
UK callers: 0371 384 2030
International callers: +44 121 415 7047
Aspect House
Spencer Road
Lancing
West Sussex
BN99 6DA
United Kingdom

OUR REGISTERED ADDRESS
TBC Bank Group PLC
Elder House St Georges Business Park
207 Brooklands Road
Weybridge, Surrey
KT13 0TS
United Kingdom

WEBSITE
Our annual report, financial results and investor presentations, as well as other significant information are available through 
our website: www.tbcbankgroup.com

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

319

GLOSSARY

Bank 

Bankassurance 

Bank Republic

Board 

Chairman

Joint Stock Company TBC Bank 

An arrangement in which a bank and an insurance company form a partnership, 
so that the insurance company can sell its products to the bank’s client base 

Joint Stock Company Bank Republic 

Board of Directors of TBC Bank Group PLC 

Chairman of Board of Directors of the Company 

Chief Executive Officer (or CEO) 

Chief Executive Officer of TBC Bank Group PLC 

Chief Financial Officer (or CFO) 

Chief Financial Officer of TBC Bank Group PLC 

Code 

Company 

Corporate segment

Corporate Centre 

Deputy Chairman 

Director(s) 

Engagement index

Fully digital on-boarding

Group 

High-net-worth individuals

The UK Corporate Governance Code 

TBC Bank Group PLC 

A legal entity/group of affiliated entities with an annual revenue exceeding
GEL 12.0 million, or which have been granted facilities of more than GEL 5 
million. Some other business customers may also be assigned to the corporate 
segment or transferred to MSME on a discretionary basis

Comprises the Treasury, other support and back office functions, and the
non-banking subsidiaries of the Group 

Deputy chairman of Board of Directors of the Company 

Members of the Board of TBC Bank Group PLC 

Employees feel involved and committed to TBC Bank

Share of legal entities registered online out of total number of
newly-registered legal entities

The UK-incorporated parent company of Joint Stock Company TBC Bank
(the Bank) and its subsidiaries 

To qualify for high-net-worth individuals sub-segment, one needs to have
a deposit equal to US$ 100,000 or more

Management Board 

Management Board of Joint Stock Company TBC Bank 

Mobile banking penetration ratio 

Number of active mobile banking users divided by total number
of active retail clients 

Mobile and Internet banking penetration ratio 

MSME (Micro, Small  and Medium) segment 

Nikoil Bank

Offloading ratio 

Retail segment 

Supervisory Board 

TBC Bank 

TBC Status clients 

TBC Bank Group PLC 

TBCG 

TBC Insurance 

TBC JSC 

TBC PLC 

Number of active mobile and Internet banking users divided by total number
of active retail clients 

Business customers who are not included in either the corporate or the retail 
segments; or legal entities who have been granted a pawn shop loan;
or individual customers of the newly launched, fully digital bank - Space

Nikoil Open Joint-Stock Company Investment Commercial Bank

Number of transactions conducted in remote channels divided by total number 
of transactions, based on JSC TBC Bank standalone data 

Non-business individual customers or individual business customers who have 
been granted mortgage loans; all individual customers are included
in retail deposits;

Supervisory Board of Joint Stock Company TBC Bank

The UK-incorporated parent company of Joint Stock Company
TBC Bank (the Bank) and its subsidiaries

Clients with minimum monthly income of GEL 3,000 or a loan of GEL 30,000
or more, or deposit of GEL 30,000 or more

The UK-incorporated parent company of Joint Stock Company
TBC Bank (the Bank)

TBC Bank Group PLC (except for Remuneration Report, where it means
TBC Bank Group PLC and JSC TBC Bank together)

Joint Stock Company TBC Insurance, formerly Joint Stock Company Insurance 
Company Kopenbur

Joint Stock Company TBC Bank 

TBC Bank Group PLC 

320

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

ABBREVIATIONS

ACCA 

Association of Chartered Certified Accountants

IASB 

International Accounting Standards Board 

AFS 

Available for sale 

ALCO 

Asset-liability management committee 

APM

ATM 

BNY 

Alternative performance measure

Automated teller machine 

Bank of New York 

CAGR 

Compounded annual growth rate 

CAR 

СEE 

CEO 

CFA 

CFO 

CGU 

CIB 

CIS 

COR 

CRM 

CRO 

Capital adequacy ratio 

Central and Eastern Europe 

Chief executive officer 

Chartered Financial Analyst 

Chief financial officer 

Cash generating unit 

Corporate investment banking 

The Commonwealth of Independent States

Cost of risk 

Customer relationship management 

Chief risk officer 

СSAT 

Customer satisfaction 

CSR 

CVP 

DCF

EBRD 

ECL 

EECG

Corporate social responsibility 

Cost volume profit 

Discounted cash flows 

European Bank for Reconstruction and 
Development

Expected credit losses 

Energy Efficiency Centre Georgia 

EFSEDF  The Development Facility of the European Funds for 

Southeast Europe

EMEA 

Europe, Middle East and Africa 

ENPS 

Employee Net Promoter Score 

EPS 

ERM 

Earnings per share 

Enterprise risk management 

ESRM 

Environmental and social risk management

EU 

EUR 

FDI 

European Union 

Euro 

Foreign direct investment 

FTSE 

Financial Times Stock Exchange 

FVOCI 

Fair value through other comprehensive income

FVPL 

Fair value through profit or loss 

GBP 

GDP 

GDR 

GEL 

GHG 

GWP

Great British pound, national currency of the UK

Gross domestic product 

Global depositary receipt 

Georgian lari, national currency of Georgia 

Greenhouse gas 

Gross written premium

HNWI 

High-net-worth individuals 

HR 

IAS 

Human resources 

International Accounting Standards 

IDR 

IFC

IFI 

IFRIC 

IFRS 

IMF 

IPCC 

IPO 

IT 

JSC 

KPI 

LED 

LSE 

MBA 

MBO 

Issuer default rating 

International Finance Corporation

International financial institution 

International Financial Reporting Interpretations 
Committee

International Financial Reporting Standards

International Monetary Fund 

Intergovernmental Panel on Climate Change

Initial public offering 

Information technology 

Joint stock company 

Key performance indicators 

Light-emitting diode 

London Stock Exchange 

Master of Business Administration 

Management-by-objectives 

MSME 

Micro, small and medium-sized enterprises

NBG 

NCI 

NIM 

NPL 

NPS 

OCI 

OECD 

PLC 

POS 

PPP 

PWC 

ROA 

ROE 

SME 

SPPI 

National Bank of Georgia 

Non-controlling interest 

Net interest margin 

Non-performing loans 

Net promoter score 

Other comprehensive income 

Organisation for Economic Cooperation and 
Development 

Public limited company 

Point of sale 

Purchasing power parity 

PricewaterhouseCoopers 

Return on average assets 

Return on average equity 

Small and medium-sized enterprises 

Solely payments of principal and interest 

STEM 

Science, technology, engineering and mathematics 

UK 

US$ 

VAR 

VIP 

WB 

WRI 

United Kingdom of Great Britain and Northern 
Ireland 

The US dollar, national currency of the United 
States 

Value-at-risk 

Very important person 

World Bank 

World Resources Institute 

TBC BANK ANNUAL REPORT AND ACCOUNTS 2019

321

NOTES

2019

TBC Bank Group PLC
Elder House St Georges Business Park
207 Brooklands Road
Weybridge, Surrey
KT13 0TS
United Kingdom