The Bank follows standardized approach for Credit, Market Risk and Basic indicator approach for Operational Risk. A capital Management policy has been approved by the Board under which Bank has defined threshold limits for capital adequacy ratio with a minimum capital requirement ratio of 12% (same as required by Central Bank of Bahrain (CBB)) and a maximum threshold level. Within this range 3 trigger ratios are defined i.e. internal target ratio, lower trigger ratio, and ICAAP capital adequacy ratio. Action points are triggered in case of breach of any of lower trigger ratio. The ICAAP capital adequacy ratio represents the capital position which the Bank will maintain the additional buffer over 12% to accommodate any capital requirements under Pillar II and effects of stress test on the level of capital required. In order to manage the Pillar II risks the Bank has adopted risk diversification policies by geographic, sector, rating classifications. Stress tests are performed at quarterly intervals and reported to the Board.
For example the Geographic areas are broken into six categories under the country risk management policy based on country ratings. Exposure limits have been set up on each category. Similarly sector limits and rating wise limits have been defined under the credit risk policy to avoid concentration risk. Currently the Geographic risk is concentrated to one country i.e. Iran apart from Bahrain.
The Bank follows CBB definition of Large exposure limits and all credit approvals are based on adherence to the maximum limit of 15% of capital base except those specifically approved by CBB. All Large exposures are monitored by Risk Department on daily basis and a report presented to the Risk Committee on monthly basis. Certain sensitive exposures such as connected party exposure and Iran exposure are monitored on daily basis.
Any credit obligation which remains unpaid on the due date is considered as past due on the next succeeding day. All past dues are closely monitored through daily, monthly reports. The rating model adopted by the Bank automatically downgrades an account to weak list (rating E+) or watch list (rating E) depending upon the length of the past dues. Account is downgraded to impaired asset if the past due status extends beyond 90 days. Provisions are made based on IAS - 39 standards.
In addition high value NPAs are subjected to quarterly revaluation of security based on 3 independent valuations and lowest value considered in order to ensure that all provisions are made on a conservative basis.
A collective impairment provision is also maintained as additional cushion based on the Probabilities of Default for each rating category. Since the Bank does not have its own PDs in the absence of adequate historical data, the PDs of external rating agencies have been mapped to Banks Rating categories on a best effort basis. This is an improvement over the previous methodology which did not consider the PDs for entire lending portfolio.
In order to minimize potential legal risks , the Bank has adopted best practices in lending activities especially in the area of consumer lending which includes dissemination of information relating to products, tariffs etc. through various media including website, literature and documentation, complaint disposal mechanism, staff training etc. There were no material legal claims against the Bank as of 31 December 2009. A separate Compliance department is functional which monitors the compliance risk.
The Bank has adopted a policy for conducting stress testing on various portfolios in order to determine additional capital requirements as part of its ICAAP.

