RF - Alter Modus Senior Debt



Project number:


Business sector:

Financial institutions

Notice type:


Approval date:

28 Jul 2020



PSD disclosed:

29 Jul 2020

As permitted by paragraph 2.6 of Section III of the Access to Information Policy, disclosure of this PSD was deferred in accordance with paragraph 1.4.4 of the Directive on Access to Information.

Project Description

This project was approved in the context of the Bank's response to the COVID-19 pandemic.  To avoid delays to the delivery of this project, the Bank's President granted a deviation from the ordinary timelines for PSD disclosure, as contemplated by Section V of the Directive on Access to Information.  Details of the Bank's response to COVID-19, and this deviation, can be found on our website.

Under this project, the Bank will proivide Alter Modus ("AM") with a EUR 2 million senior unsecured loan under the Resilience Framework ("RF").


Project Objectives

The proceeds of the Bank's investment will be used for on-lending to eligible sub-borrowers (micro and small enterprises, MSEs) in accordance with the Policy Statement.

Transition Impact

ETI score: 70

ETI Score: 70

Resilient (Primary Quality) - The transaction will suthspport the economic recovery in Montenegro and its response to external shocks. It will contribute to the resilience of AM by enabling it to continue sustainable lending operations to eligible sub-borrowers despite balance sheet pressures tirggered by the economic fallout from the pandemic.

Competitive (Secondary Quality) - EBRD's financing will support AM's efforts to keep providing financing to Montenegrin MSEs that are the key operational priorities of AM. The funding is additional given the imposed moratorium measures and is competitive to IDF's and commercial banks' lending to MSMEs and corporates.

Client Information


AM is the largest micro-finance institution (MFI) in Montenegro. It  is 100%-onwed by NGO Alter Modus. AM holds a market share of 73% by total assets and customer loans in the MFI sector. It serves its 21,500 MSE and retail clients through 18 branches and outlets across the country. Business model is expected to remain sustainable in the medium to long-term thanks to AM's (i) good knowledge of its borrowers, especially in the MSE market, (ii) adequate credit underwriting practices and procedures, (iii) strong and loyal management, (iv) well-established and long-standing clientele, (v) good reputation and (vi) solid capitalisation. 

EBRD Finance Summary

EUR 2,000,000.00

Total Project Cost

EUR 2,000,000.00


This crisis response project aimed to help AM to deal with the liquidity needs of its MSE clients experiencing a decrease in activity, turnover and profitability, leading to payment delays and liquidity issues for the whole economy.


Environmental and Social Summary

Categorised FI (ESP 2019). AM is an existing client of the Bank and its E&S performance has been satisfactory to date as evidenced by annual reporting on environmental and social matters and confirmed by the Management during a phone interview. A Human Resources policy was developed end 2018.  Alter Modus is offering microfinancing services largely for the retail segment with an average loan size of 2,500 €; this is considered as low E&S risk. In the context of this new transaction, AM will be required to continue to comply with Performance Requirements 2, 4 and 9, and to apply EBRD's E&S Risk Management Procedures for Corporate and SME loans. AM should continue to provide annual E&S reporting to the Bank on compliance with the applicable PRs and any other E&S matters arising during the year.

Technical Cooperation and Grant Financing


Company Contact Information

Ana Kentera
+382 20 655 280
+382 20 655 260
Studentska bb 81000 Podgorica Montenegro

PSD last updated

29 Jul 2020

Understanding Transition

Further information regarding the EBRD’s approach to measuring transition impact is available here.

Business opportunities

For business opportunities or procurement, contact the client company.

For business opportunities with EBRD (not related to procurement) contact:

Tel: +44 20 7338 7168
Email: projectenquiries@ebrd.com

For state-sector projects, visit EBRD Procurement:

Tel: +44 20 7338 6794
Email: procurement@ebrd.com

General enquiries

Specific enquiries can be made using the EBRD Enquiries form.

Environmental and Social Policy (ESP)

The ESP and the associated Performance Requirements (PRs) set out the ways in which the EBRD implements its commitment to promoting “environmentally sound and sustainable development”.  The ESP and the PRs include specific provisions for clients to comply with the applicable requirements of national laws on public information and consultation as well as to establish a grievance mechanism to receive and facilitate resolution of stakeholders’ concerns and grievances, in particular, about environmental and social performance of the client and the project. Proportionate to the nature and scale of a project’s environmental and social risks and impacts, the EBRD additionally requires its clients to disclose information, as appropriate, about the risks and impacts arising from projects or to undertake meaningful consultation with stakeholders and consider and respond to their feedback.

More information on the EBRD’s practices in this regard is set out in the ESP.

Integrity and Compliance

The EBRD's Office of the Chief Compliance Officer (OCCO) promotes good governance and ensures that the highest standards of integrity are applied to all activities of the Bank in accordance with international best practice. Integrity due diligence is conducted on all Bank clients to ensure that projects do not present unacceptable integrity or reputational risks to the Bank. The Bank believes that identifying and resolving issues at the project assessment approval stages is the most effective means of ensuring the integrity of Bank transactions. OCCO plays a key role in these protective efforts, and also helps to monitor integrity risks in projects post-investment.

OCCO is also responsible for investigating allegations of fraud, corruption and misconduct in EBRD-financed projects. Anyone, both within or outside the Bank, who suspects fraud or corruption should submit a written report to the Chief Compliance Officer by email to compliance@ebrd.com. All matters reported will be handled by OCCO for follow-up. All reports, including anonymous ones, will be reviewed. Reports can be made in any language of the Bank or of the Bank's countries of operation. The information provided must be made in good faith.

Access to Information Policy (AIP)

The AIP sets out how the EBRD discloses information and consults with its stakeholders so as to promote better awareness and understanding of its strategies, policies and operations following its entry into force on 1 January 2020. Please visit the Access to Information Policy page to find out what information is available from the EBRD website.

Specific requests for information can be made using the EBRD Enquiries form.

Independent Project Accountability Mechanism (IPAM)

If efforts to address environmental, social or public disclosure concerns with the Client or the Bank are unsuccessful (e.g. through the Client’s Project-level grievance mechanism or through direct engagement with Bank management), individuals and organisations may seek to address their concerns through the EBRD’s Independent Project Accountability Mechanism (IPAM).

IPAM independently reviews Project issues that are believed to have caused (or to be likely to cause) harm. The purpose of the Mechanism is: to support dialogue between Project stakeholders to resolve environmental, social and public disclosure issues; to determine whether the Bank has complied with its Environmental and Social Policy or Project-specific provisions of its Access to Information Policy; and where applicable, to address any existing non-compliance with these policies, while preventing future non-compliance by the Bank.

Please visit the Independent Project Accountability Mechanism webpage to find out more about IPAM and its mandate; how to submit a Request for review; or contact IPAM  via email ipam@ebrd.com to get guidance and more information on IPAM and how to submit a request.


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