Entrepreneurial thinking. Private banking.
Basel III
Pillar 3 Disclosures
2025
31 December
Contents
Introduction 4
Background and general information 4
Scope 4
Basis of preparation 4
Accounting principles 4
Capital & liquidity management framework 4
Key ratios 5
Supplementary voluntary disclosure of key metrics 6
Composition of the regulatory eligible capital 7
Regulatory capital instruments and other TLAC instruments (CCA) 8
Risk weighted assets 10
Overview of risk weighted assets (OV1) 10
Presentation of differences between accounting and regulatory exposures and carrying values in financial statements (LI2) 11
3.4 Encumbered and unencumbered assets (ENC) 12
The bank's risk management approach (OVA) 13
Risk governance 13
Approach to risk management 13
Risk culture, core values and ethical standards 14
Three lines of defence model 14
Risk capacity 15
Risk statement 15
Risk metrics 15
Limits framework 16
Cascading and embedding process 16
Risk appetite process 16
Risk management - measurement approach 20
Credit Risk (CRA) 21
Credit quality of assets (CR1) 25
Additional disclosures on the credit quality of assets (CRB) 26
Changes in stock of defaulted loans and debt securities (CR2) 30
Overall overview of mitigation techniques (CR3) 30
Risk exposure and credit risk mitigation effects under the standardised approach (CR4) 31
Exposures by asset class and risk weights under the standardised approach (CR5) 32
Non counterparty-related risk 34
Counterparty Credit Risk (CCRA) 35
Counterparty credit risk: Exposures by category and risk weights under standard approach (CCR3) 36
Analysis of counterparty credit risk exposure by approach (CCR1) 37
Exposures to central counterparties (CCR8) 38
Market Risk (MRA) 39
Market risks: indications when using the modeling approach (MR3) 43
Credit Valuation Adjustment risk (CVAA) 44
Reduced Basic Approach (CVA1) 45
Interest rate risk in the banking book 46
Objectives and guidelines for the management of interest rate risk in the banking book (IRRBBA) 46
Quantitative information on the exposure's structure and interest rate fixing date (IRRBBA1) 50
Quantitative information on the exposure's net present value and interest rate income (IRRBB1) 51
Operational Risk (ORA) 52
Operational risks: loss history (OR1) 54
Operational risks: activity indicator and sub-components (OR2) 55
Operational risks: minimum equity capital (OR3) 56
Liquidity risk management (LIQA) 57
Information on the Net Stable Funding Ratio 59
Liquidity Coverage Ratio 60
Leverage ratio 61
Leverage ratio: Detailed presentation (LR2) 62
Leverage ratio: Comparison of total assets versus leverage ratio exposure measure (LR1) 63
Appendices 64
Basic regulatory key figures (KM1) 64
Information on liquidity coverage ratio (LIQ1) 66
Information on net stable funding ratio (LIQ2) 67
Presentation of the eligible regulatory capital (CC1) 69
Balance sheet (CC2) 71
Geographical distribution of credit exposures used in the countercyclical capital buffer according to the Basel Minimum Standards (CCYB1) 72
Reconciliation of differences between accounting and regulatory exposures (LI1) 73
Composition of collaterals for counterparty credit risk exposure (CCR5) 74
Counterparty credit risk: Credit derivatives exposures (CCR6) 75
Abbreviations 76
Introduction
Background and general information
EFG International AG (the Group) is regulated by the Swiss Financial Market Supervisory Authority (FINMA) which requires the Group to comply with Pillar 3 disclosures that are part of the Basel III Final Reform Capital Adequacy Framework.
This annual report presents the Group's regulatory disclosures as of 31 December 2025.
Pillar III disclosures, published in this report, were approved for issue by the Board of Directors1 on 17 February 2026.
Disclosures and data were verified and approved in line with the Group's internal procedures and control system (ICS). This report has not been audited by the Group's external auditors.
In order to have the full view of the Group's regulatory environment and capital requirements, this report should be read in conjunction with the Group's Annual Report 2025, the Group's Annual Pillar III Disclosures 2024 and the Group's Half-year Pillar III Disclosures 2025 (http://www.efginternational.com).
Scope
The figures in this report are presented on a Group consolidated basis and are in line with the scope of consolidation for 31 December 2025 consolidated financial statements. No subsidiaries are proportionally consolidated.
There are no changes in the scope of consolidation affecting the comparability of this report with the past Pillar 3 disclosure reports.
Basis of preparation
This disclosure report was produced and prepared in accordance with Swiss regulatory framework, including
the FINMA Ordinance on Disclosure for Banks and Securities Firms (DisO-FINMA), and the revised Capital Adequacy Ordinance (CAO) applicable from 01 January 2025.
The report contains all disclosures mandated for the Group. Any additional information is provided on a voluntary basis to enhance transparency.
No new accounting standards and interpretations have been published for the reporting period that impact the Group in the current or future reporting periods and on foreseeable future transactions.
Accounting principles
The Group complies with IFRS accounting principles which are applied in the financial reporting presented in the Annual Report and for Capital Adequacy purposes. All figures within this report are prepared under the basis of IFRS, unless otherwise stated.
Capital & liquidity management framework
The Group's objectives when managing regulatory capital and liquidity is to comply with the requirements set by regulators of the jurisdictions in which the Group entities operate and to safeguard the Group's ability to continue as a going concern.
Capital adequacy and the use of regulatory capital is continually monitored and reported to various governing bodies (Asset and Liability Management Committee, Financial Risk Committee, Executive Committee, Risk Committee and ultimately the Board of Directors), using the framework developed by the Bank for International Settlements (BIS). The minimum regulatory requirement of the Group is ultimately determined by the rules implemented by the Swiss Financial Market Supervisory Authority (FINMA).
The Group reports regulatory capital according to the
Swiss Capital Adequacy Ordinance, therefore complying with the FINMA requirements.
1 See Corporate governance section of Annual Report for details.
Monitoring capital adequacy and liquidity is a key component of the Group's financial strategy. Management carefully considers the potential impact on the Group's capital ratios and liquidity ratios before making any major decisions about the Group's operations and the orientation of its business.
The Executive Committee monitors the capital ratios and liquidity ratios monthly for the Group, with Board oversight on a quarterly basis.
Key ratios
FINMA's capital ratio requirement is based on the Basel III Accord and is set forth in Article 41 ff. of the Capital Adequacy Ordinance (CAO). The minimum required total capital ratio for the Group was 13.0% as of 31 December 2025. The permanent requirement consists of the absolute minimum requirement for a banking license (8.0%), the capital buffer for a category 3 bank (4.0%), the national countercyclical buffer (0.1%), and the extended countercyclical buffer (0.9%). This requirement of 13.0% could also be translated as follow:
CET1 requirement 8.8%
AT1 requirement 1.8%
T2 requirement 2.4%
The Group's Common Equity tier 1 (CET1) ratio as reported to FINMA amounted to 13.4%, which is above FINMA's requirement of 8.8%. The Group's Total Capital ratio amounted to 16.6% at 31 December 2025, higher than the regulatory requirement of 13.0% (see Section 12.1). These ratios as at 31 December 2025 are negatively impacted by approximatively 0.6% as an amount recognised in CET1 (and IFRS shareholders equity) is not recognised in the calculation of Operational Risk weighted assets until received (in February 2026). To align for this timing mismatch the supplementary voluntary disclosure of key metrics in section 2.2 below adjusts for this impact.
The Group's Common Equity tier 1 (CET1) ratio adjusted as described above amounted to 14.0%. The Group's Total Capital ratio adjusted as described above amounted to 17.3% at 31 December 2025, higher than the regulatory requirement of 13.0%. The year on year movement in CET1 ratio was driven by:
-The net capital generation of approimatively 1.6%
-The acquisition of Cité Gestion and ISG (New Zealand) for approximatively (1.3)%
-The impact from a legacy legal provision (1.0)%
-The acceleration of the share buy-backs program impacting approximately (1.9)%
-Currency impact in equity for (0.6)%, and AT1 currency impact for (0.5)%
The leverage ratio amounted to 4.7% as of 31 December 2025 (see Section 11). This ratio is above the minimum regulatory requirement of 3.0%. The numerator of the ratio comprises Tier 1 capital of CHF 1,846.5 million divided by the Total Exposure of CHF 39,039.8 million. Total exposure reflects the on-balance sheet assets primarily adjusted for:
Deducting assets already deducted from Tier 1 capital (goodwill, intangible assets and certain deferred tax assets)
Grossing up securities financing transactions
Derivatives exposure adjustments
Other off-balance sheet exposures
The Group's liquidity coverage ratio (LCR) as of 31 December 2025 amounted to 270%, above the minimum regulatory requirement of 100% (see Section 10.2). At the same date, the Group's net stable funding ratio amounted to 174%, higher than the minimum regulatory requirement of 100% (see Section 10.1).
The following table summarises key metrics, which are explained in further detail in subsequent sections of this report.
Supplementary voluntary disclosure of key metrics2
CHF millions
31 December 2025
31 December 2024
Available capital
Common Equity Tier 1 (CET1)
1,495.5
1,648.9
Tier 1 capital (T1)
1,846.5
1,999.9
Total Capital
1,846.5
1,999.9
Risk weighted assets (RWA)
Credit risk
5,659.7
5,477.4
Market risk
705.1
579.6
Counterparty Credit risk
498.9
540.2
Operational risk
3,645.1
2,540.5
Other risks
186.0
181.3
Total risk weighted assets (RWA)
10,694.6
9,319.0
Risk based capital ratios as a percentage of RWA
Common Equity Tier 1 ratio (%)
14.0%
17.7%
Tier 1 capital ratio (%)
17.3%
21.5%
Total capital ratio (%)
17.3%
21.5%
BASEL III leverage ratio
Total Basel III leverage ratio exposure measure
39,039.8
41,504.2
Basel IIII Leverage Ratio (including the impact of any applicable temporary exemption of central bank reserves)
4.7%
4.8%
Liquidity coverage ratio (LCR) at period end
Total high-quality liquid assets (HQLA)
9,238.7
11,145.3
Total net cash outflow
3,418.7
4,596.7
LCR (%)
270%
242%
Net Stable Funding Ratio (NSFR) at period end
Available Stable Funding
24,468.8
24,807.8
Required Stable Funding
14,099.9
13,279.1
NSFR (%)
174%
187%
2 Including the reduction in operational risk weighted assets from an insurance recovery received in February 2026, already reflected in CET1.
Composition of the regulatory eligible capital
As of 31 December 2025 the Group's regulatory capital is composed of:
CET1 capital
Additional Tier 1 capital
For further details on regulatory eligible capital composition see Section 12.4, and the following table on regulatory instruments.
CET1 capital comprises paid-in capital and disclosed reserves. As of 31 December 2025, the Group's share capital amounted to CHF 149.1 million and consisted of 307,100,183 fully paid-in registered shares with a par value of CHF 0.50 per share, less 8,844,832 treasury shares with a nominal value of CHF 0.50 each. CET1 capital is adjusted for regulatory deductions such as goodwill, intangible assets and deferred tax assets based on future profitability.
Additional Tier 1 capital comprises USD 400.0 million (CHF 351.0 million) of perpetual, unsecured deeply subordinated notes qualifying as Additional Tier 1 capital issued in January 2021.
Regulatory capital instruments and other TLAC instruments (CCA)
The below table summarises the outstanding capital instruments and their key features.
31 December 2025
Ordinary shares Additional Tier I
Issuer EFG International AG EFG International AG
Unique identifier CHOO22268228 CHO593O93229
Governing law of the instrument Zurich, Switzerland / Swiss law
Zurich, Switzerland /
Swiss law
Regulatory treatment
Under post-transitional Basel III rules (CET1/AT1/T2) Common equity tier 1 Additional tier 1
Eligible at single-entity, group/single-entity and group levels Group Group
Equity securities/debt securities/hybrid instruments/other instruments Equity securities Subordinated debt
Amount recognised in regulatory capital (CHF millions) 149.1 351.O
Par value of instrument CHF O.5O USD 1,OOO
Accounting classification (IFRS) Equity Equity
Original date of issuance 12.1O.2OO5 21.O1.2O21
Perpetual or dated Perpetual Perpetual
Original maturity date N/A N/A
Issuer call (subject to prior approval from supervisory authority) No Yes
Optional call date/contingent call dates/redemption amount N/A 25.07.2027 - 25.01.2028
Subsequent call dates, if applicable N/A Every interest payment date after 25.01.2028; callable upon Tax Event or
Regulatory Event
Coupons / dividends
Fixed/floating rate/initially fixed and subsequently floating rate/initially floating rate and subsequently fixed
31 December 2025
Ordinary shares Additional Tier I
Variable Fixed
Coupon rate and any related index N/A 5.5% up to 25 January
2O28
then CMT rate +
4.659%
Existence of a dividend stopper (non-payment of dividend on the instrument prohibits the payment of dividends on common shares)
No Yes
Coupon payment/dividends: fully discretionary/partially discretionary/mandatory Fully discretionary Fully discretionary
(incl. regulatory cancellation)
Existence of step up or other incentive to redeem No No
Non-cumulative or cumulative Non-cumulative Non-cumulative
Convertible or non-convertible Non-convertible Non-convertible
Write-down feature No Yes
Write-down trigger(s) N/A High trigger (7% CET1
Ratio); Viability Event (FINMA, Public Support)
Full/partial N/A Partial
Permanent or temporary N/A Permanent
34a Type of subordination Statutory Contractual
Position in subordination hierarchy in liquidation (specify instrument type immediately senior to instrument)
None Ordinary shares
Features that prevent full recognition under Basel III No No
If yes, specify non-compliant features N/A N/A
3. Risk weighted assets | |||
3.1 Overview of risk weighted assets (OV1) | |||
The table below summarises the composition of the risk weighted assets as of 31 December 2025, the change versus 30 June 2025 and the minimum requirement based on an 8.0% capital requirement. | |||
a RWA | b RWA | c Minimum Capital Requirement | |
CHF millions | 31 December 2025 | 30 June 2025 | 31 December 2025 |
1 Credit risk (excluding counterparty credit risk) | 5,659.7 | 5,543.9 | 452.8 |
2 Of which standardised approach (SA) | 5,659.7 | 5,5G3.9 | G52.8 |
Of which internal rating-based (F-IRB) approach
Of which supervisory slotting approach
Of which advanced internal ratings-based (A-IRB) approach
Counterparty Credit risk 498.9 52O.5 39.9
Of which standardised approach (SA-CCR) 378.8 361.G 30.3
7a Of which simplified standard approach (SSA-CCR)
7b Of which market value method
Of which internal model method (IMM)
9 Of which other CCR approach | 120.1 | 159.1 | 9.6 |
10 Credit Valuation Adjustment (CVA) | 182.7 | 18O.1 | 14.6 |
Equity investments in the banking book under the market-based or
internal models approaches during the five-year transitional period
Equity investments in funds - look -through approach
Equity investments in funds - mandate-based approach
Equity investments in funds - fall-back approach 14a Equity investments in funds - simplified approach 2.9 O.9 O.2
Settlement risks O.4 1.3 -
Securitisation exposures in banking book
Of which internal ratings-based approach (SEC-IRBA)
Of which external ratings-based approach (SEC-ERBA), including
internal assessment approach (SEC-IAA)
Of which standardised approach (SEC-SA)
Market risk 7O5.1 837.7 56.4
20a Of which simplified standardised approach 705.1 837.7 56.G
Of which standardised approach
Capital charge for switch between trading book and banking book
Operational risk 4,O99.6 2,723.2 328.O
Amounts below the thresholds for deduction (subject to 250% risk
weight)
Floor adjustment
Output floor adjustment before application of the transitional cap
Output floor adjustment after application of the transitional cap
Total (1+6+1O+11+12+13+14+14a+15+16+2O+23+24+25+28) 11,149.2 9,807.6 891.9
Presentation of differences between accounting and regulatory exposures and carrying values in financial statements (LI2)
31 December 2025
a
b
Positions
c
Positions
d
Positions subject to:
e
Positions
CHF millions
Total
subject to: credit risk framework
subject to: securitisation framework
counterparty credit risk framework
subject to: market risk framework
1
Asset carrying value amount under
regulatory scope of consolidation
39,O5O.1
34,981.O
2,953.5
1,115.6
2
Liabilities carrying value amount under
regulatory scope of consolidation
1,194.O
1,1OO.3
93.7
3
Total net amount under regulatory scope of consolidation
37,856.1
34,981.0
-
1,853.2
1,021.9
4
Off-balance sheet amounts
422.3
253.6
5
Differences in valuations for securities
financing transactions (regulatory haircut)
1,673.1
1,673.1
6
Difference in valuation for derivatives
transactions (regulatory add-on)
753.O
753.O
7
Difference in netting rules
10
Exposure amounts considered for regulatory purposes
40,704.5
35,234.6
-
4,279.4
1,021.9
Explanations of differences between accounting and regulatory exposures (LIA)
The table above summarises the framework under which the assets on and off-balance sheet are assessed to determine the relevant risk weighted assets. The above total exposure amount considered for regulatory purposes of
CHF 40,704.5 million is further split in this report into:
Exposure subject to the credit risk framework of
CHF 35,234.6 million creating CHF 5,659.7 million of risk weighted assets. The only difference remains in off-balance sheet amounts that are net of credit conversion factor for the purposes of credit risk framework.
Counterparty related risk of CHF 4,279.4 million creating CHF 498.9 million of risk weighted assets
Net exposures of CHF 1,021.9 million that contribute
CHF 705.1 million of risk weighted assets from market risk.
The quality of the assets subject to the credit risk framework are analysed by geography, maturity and industry (see Section 5.2).
The majority of the assets are assessed under the credit risk framework, whilst approximatively 2.8% are subject to the market risk framework.
For details of split of assets and liabilities under each framework see Section 12.7.
Encumbered and unencumbered assets (ENC)
This table provides transparency on the availability of the Group's assets. It presents a breakdown of on-balance sheet assets into those that are encumbered (i.e., pledged or otherwise restricted) and those that are unencumbered and readily available to generate liquidity. Encumbered assets include, for example, collateral posted for derivatives and repo transactions. This disclosure allows stakeholders to assess the Group's liquidity buffer and its resilience in a stress scenario.
31 December 2025
CHF millions | a | b | c | d |
Encumbered assets | Non-encumbered | |||
without | assets without | |||
facilities with | Facilities with | facilities with | ||
Cash and balances with central banks | central bank | central bank1 5,012.3 | central bank 30.6 | Total 5,042.9 |
Due from other banks | 192.1 | 2,020.6 | 2,212.7 | |
Derivative financial instruments | 0.5 | 981.4 | 981.9 | |
Investment securities & Treasury bills and other eligible bills | 4,415.0 | 1,232.0 | 3,198.5 | 8,845.5 |
All other assets | 22,311.4 | 22,311.4 | ||
Total | 4,607.1 | 6,244.9 | 28,542.5 | 39,394.4 |
1 In accordance with the Basel Framework definition (DIS 31), the amount reported in this column for 'Investment securities & treasury bills and other eligible bills' includes assets that are pre-positioned with central banks. While these assets are currently unencumbered and remain fully available to secure funding transactions (e.g., for monetary policy or liquidity assistance), they are classified in this column rather than in column (c) 'Non-encumbered assets without facilities with central bank'.
The bank's risk management approach (OVA)
Risk management
EFG International offers private banking and asset management services and financial products with a focus on high-net-worth individuals. In pursuing its business objectives, it is exposed to risks, which may have an impact on its financial, business, social or other objectives.
A strong risk management framework is fundamental to sustainable management of its business. EFG International is committed to actively managing, and mitigating risks specific to its private banking and institutional clients, being particularly alert to compliance and operational risks, including financial crime risks, fraud risks and conduct risks.
EFG International monitors legacy risks in connection with its nostro life insurance investment portfolio and litigation cases relating to discontinued businesses.
Risk governance
EFG International is committed to maintaining a strong risk management framework in its day-to-day business activities and decision-making processes across the organisation. The EFGI risk management framework sets out the overall governance of risks. Responsibilities of involved stakeholders in the management of risks are clearly defined, as well as terms of reference for its Risk and Compliance functions.
The EFGI risk management framework is underpinned by the EFGI risk appetite framework, which focuses on the approach to risk capacity, risk appetite, risk limits and indicators, documenting the level of risk that EFG International is prepared to accept.
Risk management framework
The risk management framework comprises people, policies processes, systems and controls designed to ensure that risks are appropriately identified, assessed, measured, monitored and reported, as well as mitigated on an ongoing basis.
For EFG International, risk management is of crucial importance in order to:
Ensure all employees understand and control exposure to risks taken
Ensure that risk exposures are in line with risk capacity and defined risk appetite and strategy
Ensure that key controls over business risks are functioning effectively
Support the successful implementation of the business strategy
Protect clients from potential risks, such as unsuitable products or excess concentrations
Contribute to the orderly functioning and sound reputation on the markets in which EFG International operates
Ensure independent risk oversight over risk and control processes
The EFG International risk management framework is deployed across the following dimensions:
Approach to risk management
Risk culture
Three lines of defence model
Committees and functions
Approach to risk management
EFG International has developed a multi-dimensional approach to risk management based on the following measures:
Independent Risk Control and Compliance functions with clearly defined objectives
A comprehensive and prioritised list of risk categories (based on Group risk taxonomy)
A defined risk strategy and risk appetite
A coherent and comprehensive set of policies, directives and procedures to govern risk management, including compliance
The first and second line of defence role of the Executive Committee and its delegated committees to manage risks in alignment with the risk strategy and risk appetite
The supervisory oversight of the Board of Directors which oversees the effectiveness of the risk management framework and provides oversight and advisory support through the Risk, the Audit and the Credit Committees
The objectives of risk management are to:
Provide transparency on the risks EFG International incurs
Provide independent risk oversight and challenge that risks are appropriately assessed and managed
Enable better management of the risk-return trade-off
Support the Board of Directors in defining an appropriate risk appetite and strategy in line with available risk capacity and ensure the actual risk exposure profile remains in line with these
Ensure that key controls over business risks are functioning effectively
Risk culture, core values and ethical standards
EFG International believes that behavioural element is key to ensure sound risk management, and that this is guided by the risk culture of the organisation and that risk culture is viewed as a core component of effective risk management.
EFG International approaches risk culture along four dimensions, in line with Financial Stability Board principles: - Tone from the top: The Board of Directors, Executive
Committee and senior management set the risk culture core values and ethical standard; their action and behaviour reflect the risk culture that is expected throughout EFG International and is communicated through formal and informal channels, with the aim that all stakeholders also share EFG International's risk culture, core values and ethical standards
Accountability: Our risk management framework
and the related risk policies and directives clearly assign accountability for risk management and decision-making to functions and specific unit heads
Effective communication and challenge: the corporate culture promotes open communication and promotes effective challenge in the decision-making process; this is supported by independent Risk Control, Compliance and Internal Audit
Incentives: Financial and non-financial incentives are reviewed to ensure they do not encourage excessive risk-taking
The risk awareness and culture programme, which promotes the above-mentioned principles, is focused on the following activities:
Embedding the risk management and risk appetite frameworks across EFG International
Comprehensive training in risk and compliance topics
Consistent application of the client relationship officer's risk scorecard (composed by the risk assessment, control results, losses and KRI figures) to foster a risk-conscious and compliant culture and reduce operational risks
Three lines of defence model
EFG International manages its risks in accordance with a three lines of defence model.
The three lines of defence model delineates the key responsibilities for the business, Risk and Compliance functions and Internal Audit to ensure that the organisation has a coherent and comprehensive approach to risk management and monitoring.
EFG International's interpretation of the three lines of defence model is in line with industry practice, and the model is operated both centrally and in the business units. This ensures that the most material activities and processes are subject to the most robust risk management, oversight, challenge and assurance.
Risk appetite framework
The risk appetite framework is complementary to the risk management framework and sets the overall approach to risk appetite, documenting the level of risk that EFG International is prepared to incur for the achievement of its strategic objectives in line with the available risk capacity. It includes:
Risk capacity
Risk appetite statement
Risk metrics and limits framework
Cascading and embedding process to business units
Responsibilities of the (Group and local) bodies overseeing the implementation and monitoring of the risk appetite framework
Risk appetite process, including the escalation of the risk metrics exceeding their predetermined thresholds
The risk appetite framework is linked to the risk limit system and is influenced by the overarching available risk capacity, the risk management framework and the strategic business objectives.
Risk capacity
The risk capacity is the maximum level of risk EFG International can assume, given its current capabilities and resources, before breaching EFG International's strategic targets and risk appetite. In determining the risk capacity, EFG International takes into account the constraints determined by regulatory capital and liquidity requirements and of the law enforcement agencies. Risk capacity defines an outer boundary within which EFG International must operate.
Risk appetite and risk capacity are aligned through the annual budget and planning process. EFG International holds appropriate capital and liquidity buffers to accommodate circumstances where exposures extend beyond EFG International's risk appetite. This protects EFG International from the financial and/or reputational consequences that might be associated with a breach of its risk capacity or rating ambition.
Risk statement
The risk statement comprises the qualitative component of EFG International's risk appetite. It comprises a set of statements describing the level of risk that EFG International is prepared to accept in each risk category to achieve its strategic business objectives.
The risk appetite statement is aligned with the corporate strategy of EFG International. The risk appetite statement is operationalised through the risk appetite metrics and the limit framework.
Risk metrics
The quantitative component of risk appetite contains measures (i.e. metrics) that describe the quantum of risk to which EFG International is exposed to.
The metrics are compared to trigger levels (i.e. thresholds), which can have the nature of limits or warning indicators. The metrics are selected, and thresholds are calibrated in
accordance with the risk appetite statement, which in turn reflects the corporate strategy.
Risk metrics can be set at EFG International Board of Directors aggregated level or, if deemed appropriate, at EFG International Executive Committee level.
Limits framework
EFG International Executive Committee's delegated committees review risk limits and indicators and the related trigger levels at a global and business unit level.
The EFG International Executive Committee reviews and recommends the global thresholds to the Risk Committee for its review and recommendation for approval by the EFG International Board of Directors.
Cascading and embedding process
The risk appetite framework, risk appetite statement and risk metrics and related thresholds are defined at EFG International level and are binding for all EFG International business units and local and foreign entities, as set out in the risk management framework.
The EFG International Executive Committee allocates, according to cascading and embedding rules, the limits and risk thresholds to the various local entities.
In this way, EFG International appropriately identifies, limits and monitors the risks associated with its local business activities and measures and reports local risk appetite according to consolidated supervision rules.
Risk appetite process
This process is composed of four main pillars: annual review, off-cycle adjustments, reporting and escalation. The risk appetite statements and metrics are reviewed annually by the respective competent bodies. If needed, off-cycle adjustments of existing metrics and thresholds are also undertaken. The regular reporting is performed on a monthly and quarterly basis while escalations are reported immediately to the respective committees.
Risk categories
The risk categories of EFG International are defined in the risk taxonomy included in the risk management framework and are described in the related risk policies and general directives.
The Group's risk categories establish a common denominator on risks across EFG International and thereby enable alignment across business units, geographies and functions.
Business and strategic risk
Business and strategic risk is the risk of loss arising from changes in the business environment and from adverse business decisions or improper implementation of decisions. The business and strategic risk includes the following risk categories:
Client portfolio risk: The risk inherent in client portfolios in general as well as the risk of a reduction in assets under management and/or loss of client relationships as a result of other risk types, e.g. performance, reputation, operational risks, compliance, etc.
Strategic risk and governance: The risk of the enterprise or particular business areas making inappropriate strategic choices, or being unable to successfully implement selected strategies or related plans and decisions, which may result in a variance to business plans and strategies
Competitive risk: The risk of an inability to build or maintain sustainable competitive advantage in a given market or markets
Project risk: The risk of harm or loss resulting from an acquisition and/or subsequent post-merger integration or any other large-scale project the institution is undertaking
Human resources risk: The risk arising from inadequate or insufficient human resource performance and/or staffing or key people (including client relationship officers) leaving EFG International
The business and strategic risk management strategy approved by the Board of Directors is defined as follows:
Whilst the nature of EFG International business entails some earnings volatility, this is monitored and controlled to remain consistent safeguarding EFG International's financial performance and reputation, also under severe stress conditions
EFG International limits earnings volatility by focusing on the core business activities in line with business strategy
EFG International monitors client investment portfolios in order to avoid excessive risk concentrations across portfolios and inadequate performance with potential negative implications on client's assets under management and thereby its own reputation and revenue base
EFG International monitors concentrations of clients and assets under management across its client relationship officers and will investigate potential actions when these concentrations exceed the defined thresholds, in order to mitigate key person risk
EFG International actively manages the cost base balancing the target of a healthy cost-income ratio with ensuring adequate resourcing and infrastructure
EFG International actively manages the risks arising through the integration of any acquired/merged entity and for potential further mergers and acquisitions
Compliance risk
Compliance risk is defined as the risk of legal or regulatory sanctions, material financial loss, or loss of reputation which EFG International may suffer as a result of its failure to comply with laws, regulations, rules, self-regulatory organisation standards, generally accepted practices, and codes of conduct applicable to all its activities.
Compliance risk is identified, assessed and measured, monitored, reported and mitigated by the Compliance function, in alignment with the roles and responsibilities defined in EFG International's risk management framework. The Compliance function reports to the Group Head of Legal & Compliance.
Changes in the regulatory environment are monitored, and directives and procedures are adapted as required. In line with these evolving regulations, EFG International continuously invests in its people, processes, system and controls to ensure effective compliance risk management.
EFG International's Compliance function is centrally managed from Switzerland, with local compliance officers situated in all the organisation's booking centres and other entities around the world. A compliance risk policy is in place, complemented by a comprehensive set of directives and procedures and ongoing training sessions for all staff to ensure they maintain appropriate knowledge of compliance risks and understand their roles and responsibilities in mitigating these risks.
Group Compliance maintains a common platform of tools and processes to ensure the consistent application of compliance guidelines across the organisation.
Compliance risk in EFG International is mitigated through the three lines of defence model, outlined in detail in the risk management framework.
In mitigating compliance risks that it is exposed to, EFG International takes into account the size, structure, nature and diversity of its business and services/product offerings. EFG International is committed to a sound and effective compliance risk management framework, as being the core foundation for a sustainable financial institution protecting EFG International from loss or reputational damage. It supports the way EFG International conducts business both
for its clients and its shareholders and it is a prerequisite for long-term and sustainable growth, in line with shareholders' expectations.
A major focus of regulators around the world is the fight against money laundering and terrorism financing which could expose EFG International to enforcement actions, criminal proceedings and high reputational risks. A proper and timely mitigation of AML/CFT risks is a prerequisite to the guarantee of irreproachable business activity required by the Swiss regulator.
AML/CFT risk refers to risks associated with the firm being exposed to money laundering or terrorist financing schemes, which comprises (1) laundering moneys deriving from AML predicate offenses / criminal misconduct and (2) using legitimate or illegitimate assets to finance terrorism and / or terrorist activities.
International sanction risks refer generally to the risk associated with the firm (1) providing services to individuals or entities targeted by applicable sanction regimes or located in countries under embargo-like applicable sanctions, (2) being used to service this category of clients and / or to make economic resources available to them and (3) being used to circumvent the implementation of applicable sanction regimes.
EFG International has in place comprehensive directives on anti-money laundering, know your customer, as well as on international sanctions, anti-bribery and corruption, to prevent, detect and report such risks. Through dedicated monitoring and quality assessment programmes and applications, EFG International Compliance monitors compliance with such directives across the Group.
EFG International has defined a set of standards governing the cross-border services it offers and has developed country-specific manuals for the major markets it serves. A mandatory staff training programme is in place to ensure adherence to the standards and compliance with the country manuals. They are complemented by a tax compliance framework, the purpose of which is to prevent the unlawful acceptance of untaxed assets. Those frameworks are continuously enhanced to comply with regulatory updates or developments.
Conduct and regulatory compliance risk refers to the risk that EFG International fails to abide by the letter and spirit of all applicable laws, regulations, regulatory expectations, and standards of conduct applicable to its activities, and, as a consequence, incurs regulatory censure and sanctions,
reputational damage, and faces litigation risk. Conduct and Regulatory Compliance Risk arises from: i) breaching duties towards Customers; ii) failing to detect, monitor or prevent inappropriate market abuse, and failing to abide by appropriate market conduct requirements; iii) failing to properly manage cross-border risk and complying with rules applicable to cross border activities; iv) failing to perform appropriate oversight over Independent Asset Managers and Business Introducers; v) failing to appropriately identify and properly manage conflicts of interests; and vi) failing to identify and implement, in a timely manner, regulatory developments concerning Conduct and Regulatory Compliance Risk management.
Legal risk
Legal risk is the risk to the firm's profitability arising from changes in legislation and/or as a result of legal actions against the institution. Any change in the legal environment can constitute a challenge for EFG International in its relations with competent authorities, clients and counterparties in Switzerland and globally.
Group Head of Legal & Compliance and Group Head of Litigation and Investigations ensure that EFG International adequately manages and controls its legal risks. This includes supervising and giving strategic direction to all outside counsel advising EFG International on civil, regulatory and enforcement matters.
Group Head of Legal & Compliance is responsible for providing legal advice to EFG International's management as well as handling client complaints, litigations and assisting federal and local authorities in their criminal and administrative investigations.
Group Head of Litigation and Investigations has principal responsibility for overseeing and advising EFG International's management on significant civil litigation and all government enforcement matters involving EFG International globally.
Credit risk
See Section 5.
Market risk
See Section 7.
Operational risk
See Section 9.
Liquidity risk
See Section 10.
Reputational risk
Reputational risk is defined as the risk of an activity performed by an entity of EFG International or its representatives impairing its image in the community or public confidence, and that this will result in the loss of business and/or legal action or additional regulatory oversight. Typically, it is a result of other risk categories.
EFG International considers its reputation to be among its most important assets and is committed to protecting it. Reputational risk for EFG International inherently arises from: - Potential non-compliance with increasingly complex
regulatory requirements
Potential non-compliance with anti-money laundering regulatory requirements
Its dealings with politically exposed persons or other clients with prominent public profiles
Its involvement in transactions executed on behalf of clients other than standard investment products
Potential major incidents in the area of IT security and data confidentiality
Potential misconduct by its employees
Any other potential negative internal or external event arising from other risk categories (e.g. in case of financial risk arising from significant downturn on bonds, equities markets or of a particular housing market speculative bubble, etc.)
EFG International manages these potential reputational risks through the establishment and monitoring of the risk appetite set by the Board of Directors, and through established policies and control procedures.
Emerging risk
EFG International aims to prevent or manage emerging risks; they can be new risks or even be familiar risks that become apparent in new or unfamiliar conditions. Their sources can be natural or human, and often are both.
Emerging risks arise from new technologies, for example, artificial intelligence, as well as economic, regulatory or political change.
Environmental, social and governance (ESG) factors, affecting other risk categories, relate to issues such as climate change, social inequality, or corporate misconduct, which have in turn an influence on EFGI reputation and business success. ESG can affect the Bank directly (e.g. storm damage to company buildings), but also affect customers (change in sales opportunities, production disruptions, asset stranding, etc.) leading to capital, liquidity or financial impacts.
EFG International manage, via regular risk assessments, emerging risk that could create potential reputational risks and impact future income generation capacity:
EFG International closely monitors developments in new technologies like artificial intelligence and cyber as well as economic, regulatory or political changes
EFG International strives to ensure that current and potential clients perceive and share EFG International as a conscious the management of emerging risks
Environmental and social challenges are a source of both opportunities and risks, and the financial industry has a crucial role to play in addressing these topics. Since 2021, EFG International refined the sustainability strategy and established the Sustainability Advisory Board to oversee and monitor the progress in implementing this strategy across the organisation.
Assessing and managing ESG-related risks is a key component of this new strategy. EFG International defined a specific risk appetite statement as part of the overarching risk appetite framework, underscoring the commitment to positioning EFG International as an ESG-focused financial institution. In line with international guiding principles, EFG International also launched an ESG risk management process to identify and manage potential adverse impacts that EFG International operations could have on the environment and society, as well as any associated reputational consequences or other risks affecting EFG International and its clients.
In 2023, the Board of Directors defined specific metrics to monitor progress in this area. These include:
A reduction of greenhouse gas (GHG) emissions from our own operations;
An increase in female representation in senior management (in percentage terms);
A dedicated ESG focus on the volume of Assets under Management in sustainable investment products
As pointed out in the Sustainability Report2025, EFG International has committed to five strategic climate-related measures in the areas of sustainable finance and greenhouse gas (GHG) reduction. The publication of our Sustainability Report fulfils one of these strategic climate-related measures.
EFG International has set a specific target to reduce those emissions by 50% by 2030 and to achieve net zero emissions by 2050. Furthermore, EFG International is implementing a GHG reduction trajectory for its own assets and expanding its responsible investment offering to enable clients to invest in assets that help the transition to a more regenerative economy.
Regarding climate risks in particular, EFG International is focusing its attention on further embedding climate-related aspects in its risks management framework. EFG International is further embedding climate-related financial risks affecting the known risk categories (credit, market, liquidity, business and operational risks), also integrating financed emissions from our main portfolios.
EFG International has enhanced its climatenature-related risk monitoring activities and is continuously strengthening its internal control framework and operational capabilities to define appropriate metrics for assessing climatenature-related risks. In this regard, in line with regulatory requirements and expectations, EFG International is monitoring a set of climate-related risk metrics at single entity and at Group level for key portfolios (loans, own investments and securities in assets under management).
In addition to our established climate-related financial risk assessment, EFG started measuring other nature-related financial risks in its key portfolios. The assessment of other nature-related financial risks is performed under the form of a risk heatmap, covering both dependencies and impacts.
Dependencies are analysed in terms of soil erosion and water supply. Impacts are assessed in terms of land use, water use, air pollution, soil waste pollution, emission of toxic soil and water pollutants.
Nature- (including climate-) related financial risks can be monitored via dedicated dashboards that enable the organisation to monthly assess the main exposures and track key risk indicators exposures pertaining to the nature and climate related mentioned financial risks. These exposures are reported monthly to the Financial Risk Committee and Executive Committee and quarterly to the Board Risk Committee.
Risk management - measurement approach
Basel III gives flexibility to banks to apply several approaches for managing risk exposures. Below are details of the Group's regulatory approach for each risk category managed.
Credit Risk
The Group uses the International Standardised Approach (SA-BIS) to determine which risk weights to apply to credit risk.
Additionally, the Group adopted the Comprehensive method to deal with the collateral portion of a credit transaction. In the SA-BIS approach, the Group can use ratings assigned by rating agencies to the risk weighted positions.
Non-Counterparty Risk
For non-counterparty related assets, the Group applies the SA-BIS approach.
Operational Risk
The Group applies the Standardised Approach to calculate operational risk, in accordance with Art. 90 of the Capital Adequacy Ordinance (CAO).
Under this method, the baseline capital requirement is determined by the Business Indicator Component (BIC), which is calculated by multiplying the Business Indicator (BI)-a financial statement-based proxy for operational risk exposure-by regulatory marginal coefficients.
In accordance with Art. 93 para. 3 of the CAO, the Group calculates a specific Internal Loss Multiplier (ILM) based on its own historical loss data. The ILM is derived from the Loss Component (LC), which represents the average annual operational losses incurred over the previous years.
Consequently, the final minimum capital requirement for operational risk corresponds to the BIC multiplied by the ILM.
Market Risk
The simplified Standardised approach is used for market risk. This approach requires capital for the following positions:
Interest rate instruments held in the trading book,
Equity securities held in the trading book,
Foreign exchange positions, and
Gold and commodity positions.
General market risk associated with interest rate risk instruments are calculated using the Maturity Method and for commodities using the Maturity Ladder Method. The Delta-plus method is used for options.
