BFF Bank S p A : III Pillar - Public Disclosure – 2023

Contents

Introduction

The Basel CommitteeAccords ("Basel 3") aimed at strengthening banks' capacity to absorb shocks from financial and economic tensions, improving risk management and governance and strengthening banks' transparency and reporting, entered into force in European Union law on January 1, 2014.

This being said, at Community level, the contents of "Basel 3" were adopted with two distinct pieces of legislation:

The above-mentioned European regulation became applicable in the Italian legal system on the basis of Bank of Italy Circular No. 285 "Supervisory Provisions for Banks" of December 17, 2013 as subsequently amended, which implements the provisions of the CRR and the CRD IV.

With the publication of Regulation (EU) No. 876/2019, (CRR2), the EBA introduced a series of significant amendments to the regulatory framework, applicable as of June 28, 2021.These changes, regarding in particular Part Eight of the CRR, aim to standardize the periodic disclosure to be provided to the market.

In Implementing Regulation (EU) No. 637/2021, operators were provided with instructions for mapping between the information to be published starting from the reference date of June 30, 2021 and what is set forth in supervisory reporting. In accordance with the CRR2 Regulation, banks publish the required information at least on an annual basis, and the Core Metrics on a semi-annual basis. It is also required to publish on a half-yearly basis the disclosure of exposures subject to the measures applied in response to the Covid-19crisis as established by the Bank of Italy in application of the EBA Guidelines(EBA/GL/2020/07). Credit institutions are responsible for evaluating the need to provide the required information more frequently, in light of the relevant characteristics of their activity and elements susceptible to rapid changes. The guidelines specify minimum content consistent with the significance of the reporting institution, particularly with reference to capital requirements, the breakdown and adequacy of capital, the leverage ratio, risk exposure and the general characteristics of systems in place to identify, measure and manage such risks.

The approach based on three "Pillars" was maintained.

Specifically:

• Pillar III establishes specific periodic disclosure obligations concerning capital adequacy, risk exposure and the general features of the related systems for the identification, measurement and management of such risks. This aspect has also been revised to introduce increased transparency requirements and more detailed information on the breakdown of regulatory capital and on how the Banking Group calculates its capital ratios.

Based on Article 433 of the CRR, banks publish the public disclosures required by EU regulations at least on an annual basis and on a half-yearly basis the Principal Metrics, together with the balance sheet documents and disclosures on exposures subject to the measures applied in response to the Covid-19crisis as required by the Bank of Italy in application of the EBA Guidelines(EBA/GL/2020/07).

To this end, the Board of Directors of BFF Bank has approved a dedicated procedure named "Procedure for Disclosure to the Public (Pillar III)".

Pursuant to this procedure, the disclosure to the public should be:

• approved by the Board of Directors before it is made public;
• published on the website www.bffgroup.com(Section: : https://investor.bff.com/it/pillar-iii) at least once a year and semi-annually with regard to the Principal Metrics and the disclosure of exposures subject to the measures applied in response to the Covid-19 Crisis, by the deadlines set for the publication of the financial statements, and therefore within 30 days of the date of approval of the financial statements by the Shareholders' Meeting.

The BFF Bank Banking Group (also "BFF Banking Group" or the "Group") is the largest specialized finance operator in Italy, as well as one of the leaders in Europe in the management and non-recourse disposal of trade receivables due from Public Administrations, and in the area of securities services and payment services. The Group is active in Italy, Croatia, France, Greece and Portugal through BFF Bank, in Spain through BFF Finance Iberia S.A.U. ("BFF Finance Iberia") and in Poland, the Czech Republic and Slovakia through BFF Polska S.A. ("BFF Polska") and its associates (the "BFF Polska Group").

BFF Bank meets the obligation of disclosure to the public for the BFF Banking Group and drafts this document on a consolidated basis based on the above-mentioned regulatory provisions. In line with the provisions of the CRR.

Please note that:

• Information on the risks to which the Group is exposed and on risk management and control policies is also provided in Part E of the Notes to the Consolidated financial statements at December 31, 2022;
• Information relating to Own funds and banking capital ratios, relating to the Group, is also published in Part F of the Notes to the 2022 Consolidated financial statements;
• Information on governance is also provided in the "Report on Corporate Governance and Ownership
  Structure" published in the "Governance" section of the Group website www.bff.com;
• Information regarding the Group's remuneration and incentive policies is also provided in the "Report on
  Remuneration" published in the "Governance" section of the Banking Group website;
• With reference to the best practices identified by the EBA in the Report "on assessment of Institutions'
  Pillar 3 Disclosure" (EBA/Rep/2020/09) and the Bank of Italy in the Supervisory expectations on climate- related and environmental risks (April 2022), the disclosure in terms of financial sustainability and ESG risks (environmental, social and governance risks) is provided, on the basis of regulations in force, in the
  Sustainability section on the Group's website www.bff.com.

The Disclosure to the Public (Pillar III) is also subject to the certification of the Financial Reporting Officer pursuant to Article 154-bis of Legislative Decree 58/98 (Consolidation Law on Finance, or "TUF").