04
Risk management
Risk management [PAGE 124]  
Risk Management Model [PAGE 124
Corporate risk catalogue [PAGE 125
Reputation [PAGE 131]
Reputational Risk Response Service (RRRS) [PAGE 132 ]
Risk management
Risk Management Model
The Board of Directors, Senior
Management and the Group as a whole
are firmly committed to risk
management.
CaixaBank aims to maintain a medium-low
risk profile, with a comfortable level of
capital and ample liquidity measures in line
with its business model and the risk appetite
established by the Board of Directors.
As part of the internal control framework and in
accordance with the Corporate Global Risk
Management Policy, the Group has a risk
management framework that enables it to make
informed risk-taking decisions consistent with the
target risk profile and appetite level approved by
the Board of Directors. This framework comprises
the elements described below:
Key elements of the risk management framework
<<
Risk
management
framework
Governance and
organisation
<<
<<
Risk
culture
<<
<<
Strategic risk
processes
<<
01. Governance and organisation
Undertaken through policies, standards and internal procedures that ensure
appropriate risk control is exercised by the governing bodies and committees,
and the specialisation of employees.
02. Strategic risk processes to identify, measure,
monitor, control and report risks:
- Identification and assessment of risks. Risk Assessment: A six-monthly risk
self-assessment of the Group’s risk profile. Its objective is to identify material
risks, assessing for these the inherent risk situation and trends, as well as their
management and control, and identify emerging risks and the main risk events
that due to their significant impact in the medium term should be specifically
monitored.
- Classification and definition of risks. Corporate Risk Catalogue: an
annually-reviewed list and description of the material risks identified in the Risk
Assessment. It facilitates the monitoring and reporting of the Group's risks and
consistency, both internally and externally.
- Risk monitoring. Risk Appetite Framework (RAF): a comprehensive and
forward-looking tool used by the Board of Directors to determine the types and
thresholds of risk it is willing to assume in achieving the Group's strategic
objectives for all risks included in the Catalogue.
03. Risk culture
The Group’s risk culture is imparted, among others, through training,
communication and the performance-based assessment and remuneration of
staff.
Corporate Risk Catalogue
Most relevant changes to the Catalogue in 2024
CaixaBank Group reviews the Corporate Risk Catalogue annually, in accordance
with the above.
No changes in the 13 risks that make up level 1 of the Catalogue took place in
2024. The only novelty is the identification of business profitability risk as
materially affected by the cross-cutting sustainability risk factor. Previously,
only credit risk, legal and regulatory risk, other operational risks, and
reputational risk had been identified.
Milestones in risk management in the Catalogue
The most noteworthy aspects of risk management and activities in 2024 for the
various risks identified in the Corporate Risk Catalogue are detailed below:
Risks
Risk management
Key milestones
Transversal risks
Business
return
Obtaining results below market
expectations or Group targets
that, ultimately, prevent the
company from reaching a level
of sustainable returns greater
than the cost of capital.
The management of this risk is supported by the financial
planning process, which is continually monitored to assess
the fulfilment of the strategy and budget. After quantifying
the number of deviations and identifying their cause,
conclusions are presented to the management and
governing bodies to evaluate the benefits of making
adjustments to ensure that the internal objectives are
fulfilled.
Improvement of profitability and operational efficiency in 2024. The positive trend in core income,
highlighting an increase in net interest income due to the repricing of credit indices and the higher
contribution of insurance, together with the maintenance of the cost of risk at reduced levels, has
allowed ROTE to reach 18.1%. In addition, the efficiency ratio fell to 38.5%, standing at all-time lows. 
In 2025, a stabilised interest rate environment, slightly lower than at present, is foreseen. The main
milestones include liquidity remuneration management and expense management.
Own funds and
capital
adequacy
Risk caused by a restriction of
the CaixaBank Group's ability to
adapt its level of capital to
regulatory requirements or to a
change in its risk profile.
The target for the CET1 capital adequacy ratio for 2024 is
between 11.5% and 12.0%, without considering transitional
IFRS9 adjustments, which require a buffer of between 300
and 350 basis points on the SREP regulatory requirement.
Under the new 2025-2027 Strategic Plan and in response to
the implementation of the new countercyclical capital
buffer (CCyB) for credit exposures in Spain, the target for
the Common Equity Tier 1 (CET1) capital adequacy ratio has
been adjusted to a range of 11.5% to 12.5%, with a
transitional target of 11.5%-12.25% for 2025.
As of 31 December 2024, CaixaBank's CET1 ratio stands at 12.2%, providing the bank with a buffer
of 348 basis points, or €8,277 million, before reaching the Group's Maximum Distributable Amount
(MDA) trigger.
The minimum requirements set for December 2024, which will continue into January 2025, are as
follows:
In accordance with the 2024 Dividend Plan, the Board of Directors approved on 30 October 2024
the distribution of an interim dividend of 40% of the consolidated net profit for the first half of
2024, for an amount of €1,068 million (€0.1488 gross per share).
In addition, the Board of Directors on 30 January 2025 agreed to propose at the Annual General
Meeting the distribution of a final dividend in cash for €0.2864 gross per share charged to 2024
profits, which will be paid in April 2025. Following this second payment of dividends, the
shareholder returns in 2024 will be equivalent to 53.5% of the consolidated net profit.
Moreover, under the current Strategic Plan, in 2024 the bank has conducted
3 share buy-back programmes (third, fourth and fifth programme, announced in March, July and
October for €500 million each). Furthermore, a new share buyback program (the sixth) was
announced in January 2025, amounting to €500 million, which has been prudently accounted for by
the end of December 2024.
1 Quarterly update for retail exposures by IRB with housing collateral in Portugal
2 Quarterly update. Starting from 1 October 2025, a buffer of 0.50% will be activated for credit exposures in Spain, resulting in an estimated increase of 37 basis
points.
Dec. 2024
Pillar 1 regulatory requirement
4.50%
Pillar 2R Requirement
0.98%
Capital Conservation Buffer
2.50%
Systemic O-SII Buffer
0.50%
Sectoral Systemic Buffer1
0.06%
Countercyclical Buffer2
0.13%
Minimum CET1 capital requirements
8.68%
Model
Potential adverse
consequences for the Group
arising from decisions based
mainly on the results of internal
models with errors in the
construction, application or use
thereof.
Model risk is managed on the basis of these pillars:
> Identifying existing models, using the Corporate
Inventory of Models as a key element to set the scope
of the models, assessing the quality thereof and how
they are used by the Group.
> Governance of models involving the implementation
of a control system using a proportional (based on
tiering) and consistent approach. This is achieved
through establishing standards and guidelines for the
key stages of the model's lifecycle and creating a
uniform reporting framework.
> Monitoring, based on a control framework with a
forward-looking approach to model risk that enables
risk to be kept within the parameters defined in the
Group's RAF, through the periodic calculation of
appetite metrics and other specific model risk
indicators.
The main milestones in 2024 were the effective deployment of the new model risk tool, both in the
CaixaBank areas and in the main Group companies supporting them. Moreover, the project to
broaden the corporate model inventory and refine its taxonomy has been finalised, risk monitoring
has been enhanced by using the new KPIs and consolidating the RAF metrics and governance has
progressed with tier-based management and the identification of the models' materiality criteria.
Additionally, the economic capital for model risk has been assessed, and efforts have started to
align model risk management with emerging artificial intelligence regulations.
Reputational
Potential financial loss or lower
income for the Group as a
result of events that negatively
affect the perception that
interest groups have of the
CaixaBank Group.
The management of this risk is geared towards achieving
and sustaining a favorable perception among stakeholders,
while also anticipating, preventing, minimizing, and
mitigating potential negative reputational effects.
In addition, it promotes a positive perception of the Group
by all its stakeholders through ongoing and fluid  dialogue
and communication with all of them; it quantifies this risk;
analyses possible controversies from a reputational
perspective in different corporate and business
environments; and developing communication initiatives
that strengthen the visibility and recognition of corporate
values among stakeholders.
In 2024, CaixaBank enhanced its internal coordination protocols and revised its Crisis Management
Plan to address cyber, technological, and operational incidents. The bank also adjusted its first line
of defense strategies against reputational risk to comply with the DORA Regulation.
For risk prevention, CaixaBank introduced a reputational risk score related to ESG controversies,
developed predictive models for managing reputational risk, and strengthened its bi-annual self-
assessment process for step-in risk. These initiatives demonstrate CaixaBank's commitment to a
holistic and synchronized strategy in handling and reducing reputational risks. This approach
ensures seamless coordination across all management sectors and a swift response to any events
that might affect the bank's reputation.
Ƥ See section ā€œReputationā€
Financial risks
Credit
Loss of value of the assets of
Caixa Bank Group through a
customer due to the
impairment of the capacity of
this customer to meet their
commitments to the Group.
Includes the risk generated by
operations in the financial
markets (counterparty risk).
This is the most significant risk for the Group's balance
sheet. It is derived from its banking and insurance activity,
cash flow operations, and its investee portfolio,
encompassing the entire management cycle of the
operations.
The principles and policies that underpin credit risk
management are:
> A prudent approvals policy based on: (i) an
appropriate relationship between income and the
expenses borne by consumers; (ii) documentary proof
of the information provided by the borrower and the
borrower’s solvency; (iii) pre-contractual information
and information protocols that are appropriate to the
personal circumstances and characteristics of each
customer and operation.
> Monitoring the quality of assets throughout their life
cycle based on preventive management and early
recognition of impairment.
> Up-to-date and accurate assessments of the
impairment at any given time and diligent
management of non-performingloans and recoveries.
By the close of 2024, the Non-Performing Loan (NPL) ratio was reduced to 2.6% from 2.7% at the
end of 2023, with a decrease of €-280 million in non-performing loans over the year, thanks to
proactive NPL management and natural portfolio development. The NPL coverage ratio remains
robust, standing at 69% in December 2024, down slightly from 73% in December 2023. The cost of
the risk (12 months) stands at 27 basis points thanks to a prudent management.
In November, CaixaBank introduced various initiatives to support customers impacted by the
DANA, including the 'Advance on Aid' loan at 0% interest and automatic extension of working capital
credit line maturities for self-employed individuals and SMEs. The bank also facilitated applications
for government assistance, including moratoriums and ICO credit lines, as required by Royal Decree
6/2024 dated 5 November. By the end of December, CaixaBank had received 5,641 applications for
moratoriums, successfully processing payment suspensions for 3,839 loans amounting to €160.8
million. Additionally, 457 applications were processed for ICO-guaranteed contracts totalling €104.5
million.
Actuarial
Risk of a loss or adverse change
to the value of the
commitments assumed
through insurance or pension
contracts with customers or
employees due to the
differences between the
estimate for the actuarial
variables used in the
tariffmodel and reserves and
the actual performance of
these.
This risk is managed in order to ensure the Group has the
capacity to meet commitments to its insured parties, to
optimise the technical margin and to keep balances within
the limits established in the risk appetite framework.
In 2024, progress was made in modelling some of the assumptions on biometric risks based on the
Group's own experience, which were more in line with the Group's actuarial risk profile.
Furthermore, the actuarial department has incorporated the validation of IFRS 17 provisions and
continues to strengthen actuarial risk management.
Rate risk in the
banking book
Negative impact on the
economic value of balance
sheet items or on the net
interest margin due to changes
in the structure of interest rates
over time and the impact
thereof on asset and liability
instruments and off-balance
sheet items not held in the
trading portfolio.
This risk is managed by optimising the net interest margin
and keeping the carrying amount of assets within the limits
established in the risk appetite framework.
Throughout 2024, there was a notable shift in global monetary policy trends, significantly affecting
interest rates. In the European Union, this change started in June with four subsequent rate
reductions, lowering the deposit facility rate from 4% to 3%. Market forecasts suggest further
declines, expecting the rates to settle between 1.75% and 2.00% by mid-2025.
In response, CaixaBank has actively managed its balance sheet during the year to cushion the
potential negative effects of this descending interest rate cycle on its net interest income and
economic value. These strategic management actions, combined with increased lending activity,
help reduce the impact of interest rate fluctuations on the net interest income.
In September 2024, the supervisory outlier tests (SOT) for net interest income were implemented,
aiming to cap the maximum impact on net interest income over 12 months at 5% of Tier 1 capital in
the event of an adverse interest rate shock. Additionally, CaixaBank conducted a self-assessment of
its adherence to the IRRBB (interest rate risk in the banking book) and CSRBB (credit spread risk in
the banking book) guidelines, achieving fully satisfactory outcomes.
Liquidity and
funding
Risk of insufficient liquid assets
or limited access to market
financing to meet the
contractual maturities of
liabilities, regulatory
requirements, or the
investment needs of the Group.
The management approach is based on a decentralised
system with the segregation of functions aiming to
maintain an efficient level of liquid assets; the active
management of liquidity and the sustainability and stability
of funding sources in both normal and stress scenarios.
Total liquid assets amounted to € 170,723 million at 31 December 2024, up € 10,520 million in the
year, mainly due to the favourable evolution of the loan-deposit gap, generation and the provision
of collateral in the facility with the ECB. 
The Group's LCR stands at 207% and the NSFR stands at 146% at 31 December 2024. Institutional
financing amounted to €57,246 million, performing very well in 2024 due to the Group’s success in
accessing markets with different debt instruments.
There is no balance drawn down on ECB policy in 2024 following repayment of TLTRO II in
December 2023.
Market
Loss of value, with impact on
results and solvency, of a
portfolio (set of assets and
liabilities), due to adverse
movements in prices or market
rates.
Risk management is based on maintaining risk low, stable,
and within the established risk appetite limits.
The market risk of the trading book is measured daily using
an internal model subject to regulatory supervision.
-
Operational risk
Conduct and
Compliance
The application of criteria that
run contrary to the interests of
its customers and stakeholders,
or acts or omissions by the
Group that are not compliant
with the legal or regulatory
framework, or with internal
policies, regulations or
procedures, or with codes of
conduct, ethical standards and
good practice.
Conduct and compliance risk management is not just the
responsibility of a single department, but of the entire
CaixaBank Group. All employees must strive to ensure
compliance with current legislation and to implement
procedures to translate this legislation to their day-to-day
work.
Likewise, in 2024, the Group has continued to reinforce a culture and awareness of compliance
within the organisation aimed at all employees through training programmes, conduct indicators in
corporate challenges and awareness sessions. The compliance target set for the year in this respect
was met. The compliance target set for the year in this respect was met.
In addition, ongoing processes have been established to monitor the correct marketing of products
and services based on the follow-up of indicators, establishing ad hoc reviews if necessary.
During the 2024 financial year, CaixaBank successfully passed the audits for the following
certifications:
> UNE/ISO 37301 Compliance Management Systems
> UNE 19601 Criminal Compliance Systems
> UNE/ISO 37001 on Anti-Bribery Management Systems
> UNE 19602 on Tax Compliance
In addition, throughout this year, the Group's supervision model continued to be strengthened
through themonitoring of adherence to the defined framework for coordination of subsidiaries and
the implementation ofimprovements to reinforce the effectiveness of the implementation of the
compliance programme at Group level.
Ƥ  See section ā€œGovernanceā€
Legal and
regulatory1
Potential losses or decreases in
the CaixaBank Group's
profitability as a result of
legislative changes, the
incorrect implementation of
said legislation in the
CaixaBank Group’s processes,
the misinterpretation of
legislation applied to
operations, incorrect handling
of court or administrative
rulings or of claims or
complaints received.
Legal and regulatory risks are managed so as to safeguard
the Group’s legal integrity and to anticipate and mitigate
future economic harm by monitoring regulatory changes,
participating in public consultation processes, helping to
build a predictable, efficient and sound legal framework,
and interpreting and implementing regulatory changes.
Likewise, its objective is the correct implementation, in due
time and form, of these regulatory changes, understood as
the creation or adaptation of contracts, processes and
systems, through control, centralised coordination and the
promotion of the implementation of the regulations at the
CaixaBank Group level, thus enabling adequate
management of the control of this legal and regulatory risk.
During 2024, key legislative proposals with an impact on the entity have been monitored. With
regard to those published in 2024, legal and impact analysis has been carried out for the
implementation of the regulations. Key considerations: (i) securities market reform (MiFID II/MiFIR);
(ii) The Regulation on Instant Transfers in euros; (iii) The Implementing Regulations of the DORA
(Digital Operational Resilience Act); (iv) The Artificial Intelligence Regulation; (v) Regulation of the
European digital identity framework (eIDAS); (vi) The Implementing Regulations of the Regulation on
Cryptoassets (MiCA - Markets in Crypto-Assets); (vii) The Banking Package, encompassing: The
Capital Requirements Directive (CRD VI); The Capital Requirements Regulation (CRR III); (viii) The
amendment to the Framework for setting the Bank of Spain's (BdE) countercyclical capital buffer;
(ix) The Corporate Sustainability Due Diligence Directive (CSDDD); (x) The regulatory package
addressing Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT); (xi) The
Parity Law; and (xii) Regulations stemming from the DANA, which have broad, cross-sectoral
implications.
Additionally, several ongoing initiatives are under surveillance, including: (i) this new tax is designed
to succeed the temporary levy previously imposed on credit and financial credit institutions; (ii) the
bill regulating customer service and creating the Independent Administrative Authority for the
Defence of Financial Customers for the out-of-court resolution of disputes between financial
institutions and their customers; (iii) The Law on Loan Administrators and Buyers, aimed at
enhancing the protection of consumers who are financially vulnerable; (iv) Retail Investment
Strategy, which proposes amendments to the primary rules governing the marketing of financial
instruments and insurance; (v) revision of the Crisis Management and Deposit Insurance
framework; (vi) establishment of a European Digital Identity Wallet; (vii) harmonised rules regarding
artificial intelligence; (viii) Guidance for outsourcing cloud services; and (ix) new ECB Guide on risk
governance and risk culture.
Technology
Risks of losses due to hardware
or software inadequacies or
failures in technical
infrastructure, due to
cyberattacks or other
circumstances that could
compromise the availability,
integrity, accessibility and
security of the infrastructures
and data.
Managing this risk involved identifying, measuring,
assessing, mitigating, monitoring and reporting the risk
levels involved in the governance and management of
Information Technology.
Furthermore, the risk control and management frameworks
developed have been designed according to internationally
renowned standards and evolve as potential emerging risks
are captured and managed.
During 2024, CaixaBank Group maintained a robust risk control and management framework on
the technology risks, especially in the light of external threats linked to cybersecurity.
Likewise, the risk control framework has been updated to support the increasing adoption of cloud
computing services and to comply with the mandates of the DORA regulation regarding digital
operational resilience.
Other
operational
risks
Risk of loss or damage caused
by errors or shortcomings in
processes, due to external
events or due to the accidental
or intentional actions of third
parties outside the Group. This
includes risk factors related to
outsourcing, business
continuity and external fraud.
Managing this risk involved identifying, measuring,
assessing, mitigating, monitoring and reporting the risk
levels  involved in the governance and management of
outsourcing, external fraud, business continuity, etc.
seeking to avoid or mitigate negative impacts on the Group,
either directly or indirectly due to the impact on relevant
stakeholders (e.g. customers), arising from inadequate
internal processes or from the actions of third parties.
During 2024, these risks have been studied in further depth through the specialised function of
second line of defence for "other operational risks", with a focus on preventing external fraud,
business continuity and minimising risks in outsourcing services.
In all these areas, the control environment has been strengthened, meeting the expectations of
regulators and supervisors and achieving greater alignment with international best practices and
the new DORA regulation and a balance with more agile and efficient processes.
Reputation
Reputation, a lever for trust
and commitment for CaixaBank.
CaixaBank understands corporate reputation as one of the main pillars in
building the trust among stakeholders towards the Entity. Therefore, reputation
management is a strategic area that allows the Entity to strengthen its
commitment to a business model that is social, responsible and close to its
customers.
CaixaBank Group's commitment is materialised in a series of corporate Policies
that ensure implementing a communication, reputational risk management and
relationship model with stakeholders that is transparent and of top quality and
maximum impact and that allows maintaining the Group's reputation at optimal
levels.
The Corporate policy for managing reputational risk prevents and mitigates
the potential undermining of competitive ability that would occur if the
confidence that any stakeholder has in the Group were to deteriorate. It includes
the following main areas of action:
> Boosting reputation.
> Preventive management of reputational risk.
> Establishment of reputational objectives, for which it has specific
measurement, monitoring and control indicators.
Furthermore, the Corporate Communication Policy, which includes the
following main areas of action: the professional and centralised management of
communication, in line with the specific procedures and protocols; the ongoing
relationship with the media and the use of digital channels and the monitoring,
measuring and oversight of the communication channels.
And lastly, the Corporate Sponsorships Policy, which contains the basic
strategy and principles of action of the CaixaBank Group in its relations with
third parties as a sponsor, with the commitment that they are carried out in
accordance with an efficient and rigorous model that is consistent with the
general strategy of the Group and that safeguards its reputation.
There is also an own model for the measurement of reputation, the
CaixaBank Global Reputation Index (GRI), which is part of the Strategic Plan
and the Risk Appetite Framework. The GRI quantifies CaixaBank's reputation and
reputational risk, integrating the perceptions of the main stakeholders on key
values and reputational aspects.
Throughout 2024, progress has been made in the development and
improvement of this model, as well as in the model for calculating
the impact of reputational risk on economic capital.
The measurement of reputation – Global Reputation Index (GRI)
90%
+
10%
=
Group GRI
metrics
WEIGHT
WEIGHT
GRI CaixaBank - ESP
GRI BPI - PT
                                                                       
Reputational Risk Response Service (RRRS)
The Reputational Risk Response Service (RRRS) is an internal service managed
that contributes to compliance with the Corporate Reputational Risk
Management Policy, providing support to the commercial network and other
corporate departments.
The SARR evaluates both the current and potential reputational effects
associated with various activities, projects, processes, or issues that could
significantly influence how stakeholders perceive the CaixaBank Group. Both
internal expert judgement and external tools provided by reputational risk
analysis providers are used for the analysis. The RRRS regularly reports to the
Reputational Risk Committee on its activities. 
Types of enquiries handled by the RRSR in 2024
         
39%
Other enquiries
6%
Controversial sectors with
framework for action
15%
Persons investigated/sanctioned
6%
Protocol in tax havens
6%
Transparency Committee
28%
ESG sectors (defence and ESG
policies)
In 2024, 337 queries were attended, 28% of which were
related to CaixaBank's Corporate policy for managing
sustainability/ESG risks, which includes human rights,
environment, energy and other ESG sectors, and the rest to
customers and operations with a potential reputational impact