ProCredit Mandatory Reserves Coverage
On December 22, 2020, MIGA issued guarantees for €18.05 million to ProCredit Holding AG & Co. KGaA (ProCredit) of Germany covering its equity investments in its subsidiary ProCredit Bank d.d., Bosnia and Herzegovina (ProCredit Bosnia and Herzegovina) against the risk of expropriation of mandatory reserves held with the subsidiary’s central bank for a period of up to 5 years.
ProCredit is parent company headquartered in Germany and operates 12 banking subsidiaries in South eastern Europe, Eastern Europe, Ecuador, and Germany. ProCredit is a development-oriented banking group with a primary focus on lending to Small and Medium-Sized Enterprises (SMEs). ProCredit’s subsidiary banks outside of Germany are required to maintain reserves at the central banks in their respective jurisdictions, based on the volume of customer deposits that these subsidiaries have. Mandatory reserves contribute to ProCredit’s overall risk-weighted assets (RWA) at the consolidated level, resulting in less headroom for other assets at a given level of capital.
This Project is categorized as FI-2 under MIGA’s Policy on Environmental and Social Sustainability (2013). ProCredit Bosnia and Herzegovina is a commercial bank providing loans to SMEs and retail clients in Bosnia and Herzegovina. The bank operates through six branches in Bosnia and Herzegovina. Procredit Bosnia is a subsidiary of ProCredit Group, Germany. Procredit Bosnia and Herzegovina has been a MIGA client since 2010.
MIGA analyzed the portfolio of ProCredit Bosnia and Herzegovina for types of transactions, tenor, size, industry sectors, and exposure to MIGA’s Exclusion List. As of December 2019, SME finance accounts for approximately 95.6% of the bank’s total outstanding exposure, with retail banking accounting for 4.4%. The largest exposures in the SME portfolio by sector include – wholesale and retail trade, transport service, food and beverage, consumer goods, and construction and real estate. In addition, ProCredit Bosnia and Herzegovina promotes investments in renewable energy projects and its portfolio includes photovoltaic solar projects and small hydropower projects. ProCredit Bosnia and Herzegovina does not have any exposure to activities on MIGA’s Exclusion List and does not finance coal-related activities. Overall, the bank’s portfolio is considered medium risk as its lending activities cover sectors with limited environmental and social (E&S) risks and impacts. The main E&S risks of this Project are associated with ProCredit Bosnia and Herzegovina’s capacity to identify, assess and manage the E&S risks of its lending activities. The applicable E&S requirements for the ProCredit Bosnia and Herzegovina portfolio will be: (i) MIGA’s Exclusion List; (ii) applicable national environmental and social laws and regulations; and (iii) the MIGA Performance Standards.
As an existing client, ProCredit Bosnia and Herzegovina has an E&S officer and has implemented the ProCredit Group Environmental Management System (EMS) which is in line with the requirements of MIGA Performance Standard 1 regarding Environmental and Social Management Systems (ESMS). The Group EMS consists of three pillars: (i) internal environmental performance; (ii) E&S risk assessment in lending; and (iii) green finance. The Bank also implements the Group Standards for Managing the Environmental and Social Risk of Lending June 2020 that reflects the requirements of ProCredit Group Exclusion List, national laws and regulations and MIGA Performance Standards. Procredit Bosnia and Herzegovina is compliant with the E&S requirements under MIGA’s existing guarantee.
ProCredit Bosnia and Herzegovina has developed a set of human resources policies and procedures, which is in line with ProCredit Group Human Resources Management Policy, requirements of the national legislation and all the applicable requirements of MIGA Performance Standards 2: Labor and Working Conditions.
ProCredit Bosnia and Herzegovina implements the Group Business Continuity Policy which describes among other aspects, business continuity planning and strategies at the various stages of emergency, requirements for trainings and regular testing. The Bank also has in place a subsidiary-specific Business Continuity Plan and an Emergency Response Plan that cover emergency response procedures, crisis management and business recovery protocols for the critical business processes, internal/external notification and decision tree, requirements for training and drills and the requirements for auditing of the business continuity plan. To respond to the COVID-19 pandemic and national guidelines, ProCredit Bosnia and Herzegovina has implemented social distancing and hygiene measures, work from home arrangements, as well as awareness training on travel and safety at work. ProCredit Bank Bosnia and Herzegovina’s policy and plans reflect the requirements of the emergency preparedness and response plan under MIGA Performance Standard 1.
Based on MIGA’s review and applicable performance requirements, ProCredit Bosnia and Herzegovina will update its procedures on external communications in line with the MIGA Policy on E&S Sustainability 2013 requirements. ProCredit Bosnia and Herzegovina will report periodically to MIGA on the development and implementation of the EMS and application of the Performance Standards.
MIGA’s guarantees will help ProCredit reduce the risk of some of its assets, which will lead to a reduction in the group’s RWA on a consolidated basis. The RWA capacity that is freed up is expected to be used by ProCredit to extend more credit in Bosnia & Herzegovina, primarily to SMEs.
MIGA’s proposed coverage to ProCredit is aligned with the World Bank Group Country Partnership Framework (CPF) for Bosnia & Herzegovina, as it will support private sector led growth through access to finance particularly through provision of credit to SMEs.