Raiffeisen Bank Joint Stock Company Mandatory Cash Reserves Coverage
Project description
On December 30, 2022, the Multilateral Investment Guarantee Agency (MIGA), a member of the World Bank Group issued a guarantee totaling €100 million to Raiffeisen Bank International AG (RBI) for their equity investments (including retained earnings) into its subsidiary Raiffeisen Bank Joint Stock Company (RBUA) in Ukraine. The MIGA guarantee will cover Expropriation of Funds for mandatory cash reserves in RBUA for a period of up to one year and one day.
RBUA is one of the leading banks in Ukraine, the largest private bank and the largest bank with foreign capital, measured both in total assets and in volume of performing loans. RBI is a major banking and financial services group in Austria with operations across central, eastern, and southeastern Europe. RBI is a repeat client and has a longstanding business relationship with MIGA. RBUA is one of the 12 RBI’s subsidiaries outside of Austria which holds mandatory cash reserves with the central bank, based on the volume of customer deposits. Mandatory cash reserves affect RBI’s overall risk-weighted assets (RWA) at the consolidated level, resulting in less headroom for other assets at a given level of capital.
Environmental Categorization
The MIGA project supports all lending activities at RBUA. The bank provides financial products and services to individuals, small and medium enterprises (SMEs) and corporate clients in Ukraine. RBUA supports SME and corporate clients in sectors/activities mostly considered medium risk; the environmental and social (E&S) risks and impacts associated with these sectors/activities are considered limited and can be addressed through mitigation measures. The project has thus been categorized as FI-2 according to MIGA’s Policy on Environmental and Social Sustainability (2013).
The main E&S risks of this project relate to RBUA’s ability to identify, assess, and manage the E&S risks and impacts associated with its lending activities and the management of labor matters. MIGA analyzed RBUA’s portfolio for types of transactions, tenor, size, industry sectors, and exposure to MIGA’s Exclusion List. MIGA also analyzed the bank’s E&S risk management procedures in line with the requirements of Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts (PS1), and the bank’s labor practices in line with the requirements of Performance Standard 2: Labor and Working Conditions (PS2). The applicable E&S requirements for this project are: (i) MIGA Exclusion List; (ii) applicable E&S laws and regulations in Ukraine; and (iii) the Performance Standards.
As of September 2022, RBUA’s portfolio included retail loans at about 10%; loans to large/mid-market corporates at 78%; and SME loans at 12%. The large/mid-market corporate portfolio is dominated by short-term working capital and trade finance loans with limited long-term project finance loans. The main sectors supported include wholesale and retail trade, agriculture (agribusiness, animal production and crop production), and food and beverage manufacturing. RBUA has limited exposure to activities on the MIGA Exclusion List – production or trade in alcoholic beverages, excluding beer and wine, and production or trade in tobacco.
In relation to E&S risk management, RBUA has a designated E&S officer who is responsible for overseeing E&S risk management procedures. Existing E&S risk management procedures focus on assessing clients’ compliance with local E&S laws. RBUA will implement a comprehensive E&S risk management system (ESMS) in line with RBI Group’s E&S framework and the requirements of other development finance institutions. The ESMS will include elements such as screening against an exclusion list (which incorporates the MIGA Exclusion List), compliance with national laws and regulations, and application of the Performance Standards (PSs) to eligible sub-projects. The ESMS will also include an external communication mechanism. A timeline for the full roll-out of the ESMS and capacity building has been agreed with RBUA. In addition, RBUA has emergency response procedures in place which meet the requirements of PS1, and the banks’ labor practices are also in line with PS2.
RBUA is required to report periodically to MIGA on its portfolio, the implementation of the ESMS and labor practices.
Development impact
The aim of MIGA’s guarantee is to help RBI reduce the risk of some of its assets, which would lead to a reduction in the RBI’s RWA on a consolidated basis. The RWA capacity that is freed up is expected to help RBUA maintain the supply of credit, thereby supporting employment and economic activity in a country at war.
MIGA’s coverage to RBI is aligned with the World Bank Group’s Crisis Response Package for Ukraine.
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MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring direct investment clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities. MIGA support to Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations as per the requirements of Performance Standards 1.
In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.
Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:
Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org