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doc1p1i2 doc1p1i0
ANNUAL
 
FINANCIAL
 
REPORT
FOR THE YEAR ENDED
 
31 DECEMBER 2024
According to
 
Article 4 of the Law 3556/2007
 
doc1p2i2 doc1p2i3
Table
 
of Contents
A.
Statements of members of the
 
Board of Directors
B.
Report of the Directors for
 
the year ended 31 December 2024
Attachments to the Report of the
 
Directors
I.
Corporate Governance
 
Statement
II.
Sustainability Statement
C.
Audit Committee Activity Report
D.
Financial Statements for
 
the year ended 31 December 2024
I.
Consolidated Financial Statements of the Company
II.
Financial Statements οf the Company
 
E.
 
Auditor’s reports
I.
Ιndependent Auditor’s Report
II.
Independent Auditor’s Limited Assurance Report on
Sustainability Statement
doc1p1i0
Statements
 
of Members of the Board of Directors
(according to the article 4 par. 2 of the Law 3556/2007)
We declare that to the best of our knowledge:
 
the annual
 
financial statements
 
for the
 
fiscal year
 
ended 31
 
December
 
2024, which
 
have
been prepared in accordance with the applicable set of accounting standards, honestly and
accurately reflect
 
the assets
 
and liabilities,
 
the equity
 
and the
 
annual results
 
of operations
of Eurobank Ergasias Services and Holdings S.A., as well
 
as the companies included in the
consolidation considered as a whole, and
 
the report of
 
the Board of
 
Directors fairly reflects
 
the development
 
and performance
 
of the
business and the position of Eurobank Ergasias Services and Holdings
 
S.A., as well as the
companies included in the consolidation considered
 
as a whole, along with a description
 
of
the
 
main
 
risks
 
and
 
uncertainties
 
they
 
face.
 
The
 
sustainability
 
statement
 
attached
 
to
 
the
report
 
of
 
the
 
Board
 
of
 
Directors
 
has
 
been
 
prepared
 
in
 
accordance
 
with
 
the
 
sustainability
reporting standards referred to in Article 154A of
 
Law 4548/2018 and with the specifications
approved pursuant to paragraph 4 of Article 8
 
of Regulation (EU) 2020/852 of the European
Parliament
 
and
 
of
 
the
 
Council
 
of
 
18
 
June
 
2020,
 
establishing
 
a
 
framework
 
to
 
facilitate
sustainable investments and amending Regulation (EU)
 
2019/2088.
Athens, 7 March 2025
Georgios P.
 
Zanias
I.D. No AI – 414343
CHAIRMAN
 
OF THE BOARD OF
 
DIRECTORS
Fokion C. Karavias
I.D. No ΑΙ - 677962
CHIEF EXECUTIVE
OFFICER
Stavros E. Ioannou
 
I.D. No A - 00546500
DEPUTY
 
CHIEF EXECUTIVE
OFFICER
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS
1
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bn = billion
The directors present
 
their report together
 
with the financial statements for
 
the year ended 31 December
 
2024.
General information
Eurobank Ergasias Services and Holdings S.A. (the Company or Eurobank Holdings) is a holding company
 
listed on the Athens
Exchange, owning 100% of the share capital of Eurobank S.A. (the Bank). Eurobank Holdings and its subsidiaries form a group
(Group),
 
consisting
 
mainly
 
of
 
Eurobank
 
S.A.
 
group,
 
that
 
being
 
the
 
Bank
 
and
 
its
 
subsidiaries.
 
The
 
Company’s
 
operations
principally relate
 
to the
 
strategic
 
planning of
 
the
 
non-performing
 
loans management
 
and the
 
provision
 
of services
 
to the
Group entities and third parties.
Financial Results Review and Outlook
In 2024, despite the challenging international environment,
 
the macroeconomic backdrop
 
was supportive in Greece and the
other
 
countries of
 
substantial presence.
 
The
 
Group,
 
following
 
the
 
full consolidation
 
of Cyprus’
 
Hellenic Bank
 
from
 
the
 
third
quarter of 2024, grew the size of its balance sheet,
 
expanded further its business and continued its solid performance
 
across
most
 
areas.
 
It
 
enhanced
 
its core
 
profitability,
 
maintained
 
its
 
resilient
 
capital
 
position
 
and
 
asset
 
quality,
 
strengthened
 
its
liquidity, rewarded
 
its shareholders and contributed to the
 
economies and the society.
As at 31 December 2024 total assets
 
increased by €21.4bn to €101.2bn (Dec.
 
2023: €79.8bn), of which €18bn related to Hellenic
Bank
 
group,
 
with
 
gross
 
customer
 
loans
 
amounting
 
to
 
€52.3bn
 
(Dec.
 
2023:
 
€42.8bn)
 
and
 
investment
 
securities
 
reaching
€22.2bn (Dec. 2023: €14.7bn). Out of the total loan portfolio, €30.5bn has been originated from Greek operations
 
(Dec. 2023:
€28.1bn),
 
€17.4bn
 
from
 
international
 
operations
 
(Dec. 2023:
 
€10.3bn), of
 
which €5.8bn
 
related
 
to Hellenic
 
Bank and
 
€4.4bn
refer
 
to
 
notes
 
from
 
securitizations
 
of
 
loans
 
originated
 
by
 
the
 
Group
 
(Dec.
 
2023:
 
€4.5bn).
 
Business
 
(wholesale
 
and
 
small
business) loans stood at €30.9bn
 
(Dec. 2023: €25bn) and accounted for 59% of total Group
 
loans, while loans to households
reached €17bn (Dec. 2023: €13.4bn), of which 73% is the mortgage portfolio and the
 
rest are consumer loans. Group deposits,
reached
 
€78.6bn
 
(Dec. 2023:
 
€57.4bn)
 
with
 
those
 
from
 
Greek
 
operations
 
amounting
 
to
 
€43.3bn (Dec.
 
2023: €40bn),
 
while
international operations
 
contributed with €35.3bn of which €15.7bn related to Hellenic
 
Bank (Dec. 2023: €17.5bn).
 
As a result,
the (net) loan–to–deposit (L/D) ratio stood at 64.8% for the Group (Dec. 2023: 72.3%)
 
and at 77.8% for Greek operations (Dec.
2023: 78.3%). In December 2024, the Group fully repaid its secured borrowing
 
under the TLTRO
 
III refinancing program of the
European Central Bank (ECB) (Dec. 2023: €3.8bn). During the year,
 
as part of its medium-term strategy to meet the Minimum
Requirements for
 
Eligible Own Funds
 
and Eligible Liabilities
 
(MREL), the
 
Group proceeded
 
with the
 
issue of €2.3bn in
 
senior
preferred
 
notes and €0.3bn in
 
Tier II
 
notes, thereby
 
increasing its total
 
debt securities in issue
 
to €7.1bn
 
(31 December
 
2023:
€4.8bn).
 
In
 
early
 
2025,
 
the
 
Company
 
completed
 
the
 
issuance
 
of
 
€0.6bn
 
Tier
 
II
 
notes
 
including
 
the
 
issued
 
notes
 
of
 
€189m
offered for
 
exchange for the Hellenic Bank’s outstanding Tier 2 notes, while the Bank completed an issuance of €350m senior
preferred
 
notes through a private placement
 
(notes 4 and 34 of the consolidated
 
financial statements). The
 
Group Liquidity
Coverage
 
ratio (LCR)
 
increased to 188.2% (31 December 2023: 178.6%).
Pre-provision
 
Income (PPI) amounted to
 
€2,242m or €2,170m
 
excluding a) the €99m
 
gain arising from
 
the acquisition
 
of the
additional
 
shareholding
 
in
 
Hellenic
 
Bank
 
in
 
June
 
2024
 
and
 
b)
 
the
 
€27m
 
estimated
 
cost
 
for
 
contribution
 
to
 
the
 
school
renovations
 
program
 
(2023: €1,999m
 
or €1,902m
 
excluding the
 
€111m gain
 
on investment
 
in Hellenic
 
Bank (Cyprus)
 
and the
€14m contribution
 
to restoration
 
initiatives
 
after natural
 
disasters). The
 
core pre-provision
 
income (Core
 
PPI) increased
 
by
15.7% year-on-year (or 3.8% excluding €217m related to Hellenic
 
Bank) to €2,074m or
 
€2,101m excluding the €27m contribution
as above
 
(2023: €1,802m or
 
€1,816m excluding the
 
€14m contribution as
 
above).
 
Net interest
 
income (NII)
 
grew by
 
15.3% (or
1.8%
 
excluding
 
€295m
 
related
 
to
 
Hellenic
 
Bank)
 
to
 
€2,507m
 
(2023:
 
€2,174m),
 
primarily
 
attributable
 
to
 
the
 
Hellenic
 
Bank
consolidation,
 
the
 
higher
 
average
 
interest
 
rates,
 
the
 
loan growth
 
and
 
the
 
increased
 
positions
 
in investment
 
bonds
 
partly
offset by higher debt issued and deposits
 
cost. Net interest margin (NIM) stood
 
at 2.73% (2023: 2.75%) with
 
the fourth quarter
reaching
 
2.70%. Fees
 
and commissions
 
expanded
 
by
 
22.4%
 
(or 13.5%
 
excluding €48m
 
related
 
to Hellenic
 
Bank) to
 
€666m
(2023: €544m), of which
 
banking fees and commissions by 25.5% (or
 
16.5% excluding €40m related to
 
Hellenic Bank) to €561m
(2023: €447m),
 
mainly due
 
to the
 
increased fees
 
from
 
network
 
operations,
 
lending activities
 
and asset
 
management.
 
Fees
and commission over
 
assets accounted for
 
73bps (2023: 69bps). Operating
 
expenses increased by
 
18.8% (or 4.8% excluding
the €127m
 
expenses from
 
Hellenic Bank)
 
to €1,071m excluding
 
the €27m
 
contribution as
 
above (2023:
 
€902m, excluding the
€14m contribution
 
as above)
 
due to
 
the
 
higher
 
staff costs,
 
the
 
inflationary
 
pressures
 
and the
 
higher
 
IT investments,
 
partly
offset by
 
lower
 
contributions to
 
resolution
 
and deposit guarantee
 
funds. Costs
 
from international
 
operations
 
amounted to
€408m (2023: €258m), while in Greece increased by 3% to €663m
 
(2023: €644m). The cost to income (C/I) ratio for the Group
reached
 
33%, excluding
 
the
 
€99m gain
 
and the
 
€27m contribution,
 
as mentioned
 
above
 
(2023: 32.2%, excluding
 
the
 
€111m
gain and
 
the
 
€14m
 
contribution
 
as above),
 
while
 
the
 
international
 
operations
 
C/I
 
ratio
 
stood
 
at
 
32.4%
 
(2023:
 
33.1%).
 
The
respective cost to core income
ratio for
 
the Group stood at
 
33.8% (2023: 33.2%).
Trading and other
 
activities recorded net income of €168m (2023:
 
€196m net income) of which a) €84m trading gains mainly
attributable to fair value changes of derivatives used to hedge
 
dynamically the interest rate
 
risk of fixed rate loan portfolios
and non-maturing deposits, including realized
 
gains/losses from the
 
derivatives’ terminations
 
(macro hedging)
 
(2023: €86m
gain), b) €13m gains on sale of
 
investment bonds at
 
FVOCI net
 
of hedging (2023: €57m
 
gain) and c) €61m net other
 
income,
including the €99m
 
gain on the
 
additional investment
 
of Hellenic Bank, as mentioned
 
above (2023: €68m
 
income, including
the €111m gain on investment
 
in Hellenic Bank) (notes 9 and 10 to the consolidated financial
 
statements).
During
 
the
 
year,
 
the
 
Group’s
 
NPE
 
formation
 
was
 
positive
 
by
 
€222m
 
(fourth
 
quarter
 
2024:
 
€47m
 
positive),
 
(2023:
 
€138m
positive).
 
In total,
 
the
 
Group’s
 
NPE stock
 
stood at
 
€1.5bn, excluding
 
the
 
€0.2bn NPE
 
of Hellenic
 
Bank covered
 
by the
 
Asset
1
 
Definitions of the selected financial ratios and the source of the financial data are provided in the
 
Appendix.
2
 
Total operating
 
expenses divided by total core income.
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS
2
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Page
 
€ = Euro
 
m = million
 
bn = billion
Protection
 
Scheme
 
(APS)
 
(31
 
December
 
2023:
 
€1.5bn)
 
driving
 
the
 
NPE
 
ratio
 
to
 
2.9%
 
(31
 
December
 
2023:
 
3.5%).
 
The
 
loan
provisions
 
(charge),
 
excluding the
 
€16m impairment
 
release
 
related
 
to project
 
Leon, reached
 
€319m and
 
corresponded
 
to
0.69%
 
of
 
average
 
net
 
loans
 
(2023:
 
€412m
 
or
 
€345m,
 
excluding
 
the
 
loss
 
recorded
 
for
 
projects
 
‘Leon’
 
and
 
‘Solar’
 
which
corresponded to
 
0.85% of average
 
net loans), while
 
the NPE
 
coverage
 
ratio improved
 
to 88.4% (31
 
December 2023: 86.4%).
As a result, “net” NPEs amounted to €177m (31 December 2023: €206m).
Furthermore,
 
the Group
 
recognized in 2024
 
other
 
impairments, risk provisions
 
and restructuring
 
costs amounting to €228m
(2023: €133m), of which a) €161m cost for
 
Voluntary Exit Schemes
 
(VES) and related expenses mainly referring
 
to the scheme
that was
 
launched in
 
February
 
2024 for
 
eligible units
 
in Greece,
 
b) €19m
 
impairment on
 
computer hardware
 
and software
(notes 26 and 28 to the consolidated financial statements),
 
c) €21m impairment on real estate properties,
 
including the €9m
remeasurement
 
loss upon
 
classification
 
of the
 
subsidiary IMO
 
Property
 
Investments
 
Bucuresti
 
S.A. as
 
held
 
for
 
sale, and
 
d)
€12m impairment
 
losses on
 
investment
 
bonds (note
 
12 to
 
the
 
consolidated financial
 
statements).
 
Moreover,
 
it recorded
 
an
additional provision
 
of € 10m (€7.1m
 
net of tax) in relation
 
to the sale
 
of a Bank’s former
 
subsidiary, previously
 
presented as
a
 
discontinued
 
operation,
 
based
 
on
 
specific
 
indemnity
 
clauses
 
in
 
the
 
relevant
 
Sale
 
Purchase
 
Agreement
 
(note
 
30
 
to
 
the
consolidated financial statements).
 
The Group’s
 
share of associates/JVs results
 
amounted to €161m income, of which €133m
income represents
 
the share
 
of results
 
of Hellenic Bank
 
group which
 
was accounted
 
for as
 
an associate
 
until 30 June
 
2024
(note 24
 
to the
 
consolidated
 
financial statements).
 
In accordance
 
with the
 
Pillar Two
 
legislation,
 
effective
 
as of
 
1 January
2024, the
 
Group has recognized
 
a current
 
tax expense of €21.6m
 
related to the
 
top up tax applicable
 
on the profits
 
earned
for its operations
 
in Bulgaria and Cyprus (note 13 to the consolidated
 
financial statements).
Profit or Loss
Overall,
 
in
 
2024,
 
the
 
profit
 
attributable
 
to
 
shareholders
 
amounted
 
to
 
€1,448m
 
(2023:
 
€1,140m
 
profit),
 
as
 
set
 
out
 
in
 
the
consolidated income statement. The adjusted net profit, excluding a) the €121m restructuring costs (after tax), mainly related
to VES, b) the
 
€99.5m
 
gain arising from
 
the acquisition
 
of the
 
additional 26.28% shareholding
 
of Hellenic Bank as
 
above, c)
the €19m
 
Bank’s contribution
 
(after tax)
 
for
 
the Greek
 
State’s school
 
renovations
 
program,
 
d) the
 
€11m impairment
 
release
(after tax) relating
 
to the project
 
“Leon” and e) the
 
€7m net loss from
 
discontinued operations,
 
amounted to €1,484m (2023:
€1,256m). The
 
contribution of
 
international operations
 
to the
 
adjusted net profit
 
amounted to €709m
 
(2023: €468m profit),
including €275m net profit related to Hellenic
 
Bank group, which has been fully consolidated from
 
the third quarter
 
of 2024.
Based
 
on
 
the
 
Group’s
 
profits
 
for
 
2024,
 
the
 
Basic
 
Earnings
 
per
 
Share
 
(EPS)
 
reached
 
€0.40
 
(2023:
 
€0.31)
 
and
 
the
 
Return
(adjusted profit) on Tangible
 
Book Value (RoTBV)
 
amounted to 18.5% (2023: 18.1%).
Going forward, the Group pursues its
 
key financial objectives outlined in
 
the business plan for the period 2025-2027, including
a) maintaining a sustainable 15% RoTBV in a
 
lower interest rates environment,
 
following a substantial increase of equity, and
b)
 
generating
 
sufficient
 
organic
 
capital
 
to
 
support
 
business
 
growth,
 
maintain
 
capital
 
buffers,
 
reward
 
shareholders
 
by
increasing the dividend payout ratio from 30% in
 
2024 to
 
50%, subject to
 
regulatory approval, over the next years and finance
strategic initiatives,
 
mainly through the
 
following initiatives
 
and actions:
a)
Maintain
 
high
 
NII
 
mainly
 
driven
 
by
 
the
 
organic
 
loan
 
growth
 
in
 
all
 
three
 
core
 
markets
 
and
 
across
 
segments
(households
 
and
 
business)
 
and
 
the
 
increase
 
in bond
 
positions,
 
which
 
may
 
offset
 
the
 
pressures
 
from
 
the
 
ongoing
decrease in ECB rates,
 
the increasing
 
competition for
 
good quality corporate
 
customers, and the
 
issuance of MREL
eligible senior and Tier II notes,
b)
Strengthening core
 
markets presence
 
and increasing earnings and volumes
 
contribution by international
 
activities,
which will
 
be further
 
enhanced by
 
the
 
full consolidation
 
of Hellenic
 
Bank in
 
Cyprus for
 
the
 
full year
 
from
 
2025 (six
months in 2024) and its planned merger with Eurobank Cyprus (subject to customary approvals) which will allow the
synergies realization
 
over the
 
next years,
c)
Growth
 
of fee
 
and commission
 
income in
 
a number
 
of fee
 
business segments
 
such as
 
new lending,
 
network, asset
management, bancassurance
 
and wealth management activities,
d)
Initiatives
 
for
 
pursuing further
 
operating
 
efficiency,
 
cost containment
 
of “run
 
the
 
bank” activities,
 
and proceeding
with further simplification and digitalization in
 
Greece and abroad, maintaining
 
the annual increase of
 
the operating
expenses
 
at
 
a
 
mid-single
 
digit
 
%,
 
considering
 
the
 
higher
 
staff
 
costs
 
including
 
the
 
talent
 
retention
 
cost,
 
the
inflationary pressures, and the
 
“grow the bank” needs
 
including higher IT investments,
e)
Maintaining low NPE ratios in
 
all core markets in which the
 
Group has a presence, which
 
may be challenged mainly
by the high interest rates
 
burden on households’ disposable income
 
and corporate profit margins,
f)
Major transformation
 
initiatives introduced
 
in the context of the Group’s
 
transformation
 
plan “Eurobank 2030”,
g)
Support the
 
green transition
 
and financial inclusion
 
through the
 
further
 
implementation of
 
the Environment,
 
Social
and Governance (ESG) criteria
 
in all Group’s activities and processes.
The
 
geopolitical and
 
macroeconomic
 
risks, including
 
the
 
sustained -
 
albeit easing
 
- inflationary
 
pressures,
 
set a
 
number of
challenges
 
to
 
the
 
achievement
 
of
 
the
 
Group’s
 
2025-2027
 
Business
 
Plan,
 
mainly
 
related
 
with
 
growth
 
potential,
 
lending
margins,
 
deposit
 
rates,
 
asset
 
quality
 
and operating
 
cost.
 
The
 
headwinds
 
coming
 
from
 
the
 
geopolitical
 
upheaval
 
and
 
the
macroeconomic environment
 
are likely to be mitigated by:
a)
The efficient mobilization
 
of the EU funding, mainly through
 
the Recovery
 
and Resilience Facility (RRF),
b)
The substantial pipeline of new
 
investments,
c)
The decrease of the
 
unemployment rate
 
in 2025 at single digit levels in Greece,
 
close to historical lows,
d)
The positive developments
 
in the tourism sector and the strong
 
investment inflows,
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS
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e)
The upgrade of the Greek sovereign to investment grade by four out
 
of the five Eurosystem-approved External Credit
Assessment Institutions,
f)
The growth
 
of GDP in our core markets at levels
 
higher that EU average.
(see also further information
 
in the section “Macroeconomic
 
Outlook and Risks”)
Capital adequacy
As
 
at
 
31
 
December
 
2024,
 
the
 
Group’s
 
Total
 
Regulatory
 
Capital
 
amounted
 
to
 
€9.8bn
 
(31
 
December
 
2023:
 
€8.4bn)
 
and
accounted for
 
19.5%
 
(total CAD)
 
of Risk
 
Weighted
 
Assets (RWA)
 
(Dec. 2023:
 
19.4%),
 
compared to
 
the
 
CAD Overall
 
Capital
Requirements (OCR)
 
ratio of 15.16%.
 
Respectively, the
 
Common Equity Tier 1 (CET1) stood at 16.8% of RWA (Dec. 2023: 16.9%)
compared to the
 
CET1 OCR ratio
 
of 10.41% or
 
12.45%, including the
 
Additional Tier
 
1 (AT1)
 
capital shortfall.
 
Pro-forma
 
for the
accrual
 
for
 
dividend
 
distribution
 
from
 
financial
 
year
 
2024
 
profits
 
(subject
 
to
 
regulatory
 
approval),
 
the
 
completion
 
of
 
the
project “Solar”, as well as
 
the confirmation by ECB of
 
the significant risk transfer (SRT) recognition for the “Leon” loan portfolio
and a new synthetic securitization
 
(project “Wave
 
VI”) (note 20 of the consolidated financial
 
statements), the total
 
CAD and
CET1 ratios would be
 
18.5% and 15.7% respectively.
As at 31 December
 
2024, the
 
Bank’s MREL ratio
 
at consolidated
 
level stands
 
at 28.22% of RWAs
 
(Dec. 2023: 24.91%),
 
higher
than the interim non-binding MREL target of 25.62%,
 
which is applicable from January 2025. Pro
 
-forma with the completion
of the
 
project
 
“Solar”,
 
projects
 
“Leon”
 
and “Wave
 
VI”, the
 
accrual for
 
dividend distribution
 
from
 
financial year
 
2024 profits
(subject
 
to regulatory
 
approval)
 
and for
 
the
 
new
 
issuances
 
of the
 
Company and
 
the
 
Bank in
 
early
 
2025
 
(see
 
above),
 
the
Bank’s MREL ratio at consolidated
 
level stands at 29.37%
 
(note 4 to the consolidated financial statements).
Project “Wave”
In the
 
context of the
 
Group’s
 
initiatives for
 
the optimization
 
of its regulatory
 
capital, in July
 
2024 the
 
Bank proceeded
 
with
the execution of another
 
synthetic risk transfer
 
transaction (project “Wave
 
V”) in the form of a financial guarantee, providing
credit protection
 
over the
 
mezzanine loss of
 
a portfolio
 
of performing
 
SME and Large Corporate
 
loans amounting to €1.1bn,
which resulted in a capital benefit of
 
25 bps to Eurobank Holdings Group’s CAD ratio. In addition, in December 2024, another
synthetic risk transfer transaction
 
was executed (project “Wave VI”), in the form of credit linked notes (“CLN”), where the Bank
issued a
 
CLN of
 
€80m that
 
provides
 
credit protection
 
over
 
the mezzanine
 
loss of a
 
portfolio
 
of performing
 
SME and
 
Large
Corporate loans amounting to €1.1bn. The Wave
 
VI transaction is expected to contribute 18bps
 
to Eurobank Holdings Group’s
CET1 ratio.
Pursuant to the Regulation (EU) No 575/2013
 
(CRR), the deferred tax assets (DTAs) that rely on future profitability and exceed
certain limits
 
shall be
 
deducted in the
 
calculation
 
of the
 
CET1 capital.
 
This deduction
 
should be
 
applied gradually
 
by 2025.
The enactment of the article 27A of Law
 
4172/2013, as in force, provided for the Greek credit institutions that the eligible DTAs
are accounted on a) the losses from the Private Sector Involvement
 
(PSI) and the Greek State Debt Buyback Program and b)
on the
 
sum of (i)
 
the unamortized
 
part of the
 
crystallized loan losses
 
from write-offs
 
and disposals, (ii)
 
the accounting
 
debt
write-offs and (iii) the remaining accumulated provisions and other losses in general due to credit risk recorded up to
 
30 June
2015 and can
 
be converted
 
into directly
 
enforceable
 
claims (tax credits)
 
against the
 
Greek State,
 
provided that
 
the Bank’s
after tax accounting
 
result for
 
the period
 
is a loss.
 
This legislative
 
provision
 
enabled the
 
Greek credit
 
institutions, including
the
 
Bank, not
 
to deduct
 
the
 
eligible DTAs
 
from
 
CET1 capital
 
but recognise
 
them
 
as a
 
100% weighted
 
asset, with
 
a positive
effect on the
 
capital position.
A potential
 
change in
 
the
 
regulatory
 
treatment
 
of eligible
 
DTAs
 
as tax
 
credits
 
may have
 
an adverse
 
effect
 
in the
 
Group’s
capital position.
As
 
at
 
31
 
December
 
2024,
 
the
 
Bank’s
 
eligible
 
DTAs
 
for
 
conversion
 
to
 
tax
 
credits
 
(DTC)
 
amounted
 
to
 
€3,022m
 
(Dec.2023:
€3,212m), standing at 36% of CET 1 capital as of 31 December 2024 (note 4 and 13 to the consolidated
 
financial statements).
In line with the
 
Bank's initiative
 
to enhance the
 
quality of its regulatory
 
capital, the
 
amortisation of DTC
 
will be accelerated
for regulatory purposes starting from
 
2025, aiming at its elimination by 2033.
2024 Cyber Resilience Stress Test
During the first half of
 
2024 ECB conducted a
 
cyber resilience stress test on 109 directly supervised banks,
 
including Eurobank.
The
 
aim of
 
the
 
exercise
 
was to
 
assess how
 
banks respond
 
to and
 
recover
 
from
 
a cyberattack,
 
rather
 
than
 
their
 
ability to
prevent
 
it.
 
In
 
particular,
 
under
 
the
 
stress
 
test
 
scenario,
 
the
 
cyberattack
 
succeeds
 
in
 
disrupting
 
banks’
 
daily
 
business
operations. Banks then
 
tested their response and recovery
 
measures, including the activation
 
of emergency procedures
 
and
contingency plans and the restoration
 
of normal operations. ECB assessed the
 
extent to which banks can cope under such a
scenario.
This
 
stress
 
test exercise
 
does not
 
have
 
an impact
 
on capital
 
through
 
the
 
Pillar 2
 
guidance
 
(P2G), which
 
is a
 
bank-specific
capital
 
recommendation
 
on
 
top
 
of
 
the
 
binding
 
capital
 
requirements.
 
The
 
results
 
of
 
the
 
exercise
 
feeds
 
into
 
the
 
2024
Supervisory
 
Review
 
and
 
Evaluation
 
Process
 
(SREP)
 
performed
 
by
 
the
 
ECB.
 
Overall,
 
Eurobank
 
demonstrated
 
a
 
very
 
good
performance in the
 
exercise.
3
The ‘Overall
 
capital requirement (OCR) is the sum of the total SREP capital requirement (TSCR) and the combined buffer requirement
 
(CBR).
 
 
 
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2025 EU - wide stress test
The EU-wide
 
stress test exercise
 
is carried
 
out on a sample of banks
 
covering broadly
 
75% of the
 
banking sector in the
 
euro
area, each non-euro area EU Member
 
State and Norway, as expressed in terms of total
 
consolidated assets as of end 2023.
To be included in the
 
sample, banks have to have a minimum of EUR 30 bn total assets.
As per the 2025 EU-Wide Stress Test
 
Methodological Note (published on 11 November
 
2024, footnote 92), Eurobank
 
Ergasias
Services
 
and
 
Holdings
 
S.A.
 
has
 
been
 
excluded
 
from
 
the
 
sample
 
of
 
the
 
EU-wide
 
stress
 
test
 
exercise
 
because
 
of
 
a
 
major
acquisition (Hellenic Bank).
Initiation of the merger
 
process between
 
Eurobank Ergasias
 
Services and Holdings S.A. and Eurobank
 
S.A
On 18 December 2024, the Board of Directors of Eurobank Holdings
 
decided the initiation of the merger
 
process of Eurobank
Holdings with
 
the
 
Bank through
 
absorption of
 
the
 
former
 
by the
 
latter,
 
in order
 
that operational
 
efficiencies
 
and a
 
leaner
group structure
 
be achieved.
 
The merger
 
is not expected
 
to have
 
any material
 
effect
 
on the
 
Group’s
 
financial position
 
and
will be completed subject to all necessary by Law approvals
 
(note 23.3 to the consolidated financial statements).
International Operations
The Group has a significant presence in three countries apart from Greece. In
 
Cyprus, Eurobank Cyprus Ltd (Eurobank Cyprus)
and Hellenic
 
Bank Public
 
Company Ltd (Hellenic
 
Bank) (see
 
below) operate
 
in total
 
a network
 
of 71
 
branches,
 
business and
private banking centres. Specifically, Eurobank Cyprus has five main pillars of business namely, Wealth
 
& Asset Management,
Corporate &
 
Investment Banking,
 
International Business
 
Banking, Affluent Banking
 
and Global Markets,
 
while Hellenic Bank
group provides a wide range of banking and financial services, which include financing, investment, insurance, custodian and
factoring
 
services.
 
In
 
Luxembourg,
 
Eurobank
 
Private
 
Bank
 
Luxembourg
 
S.A.
 
in
 
parallel
 
to
 
its
 
operations
 
in
 
Luxembourg,
operates
 
a branch
 
in London
 
and in
 
Athens,
 
and offers
 
products
 
and services
 
in Private
 
Banking, Wealth
 
Management
 
&
Investment Fund Services, as well
 
as selected Corporate Banking services. In Bulgaria, Eurobank
 
Bulgaria AD (Postbank), is a
fully fledged multi
 
service bank,
 
holding strong
 
positions in retail
 
and wholesale banking,
 
offering
 
a wide range
 
of products
and services, through a network
 
of 200 branches and business centres.
The Company’s subsidiaries operate
 
with transparency,
 
build credibility, and apply modern corporate
 
governance practices.
A customer centric approach has been
 
adopted and they are constantly
 
evolving and adapting to a
 
demanding environment
and aiming at a sustainable development.
International
 
activities
 
are
 
on
 
a
 
Transformation
 
orbit
 
for
 
advancing
 
the
 
technological
 
capabilities
 
with
 
state-of-the-art
systems and implementation
 
of cutting-edge digital services,
 
aiming to meet the
 
demanding needs of our clients
 
and excel
customer experience.
International activities are a core
 
competitive advantage for the Group, with significant
 
contribution to its
 
results. Their vision
and strategy
 
ensure
 
responsiveness
 
to challenges,
 
growth
 
and profitability
 
while
 
promoting
 
sustainable
 
prosperity
 
in the
local communities, creating value for their
 
clients, employees, shareholders,
 
and the society at large. Furthermore,
 
the Group
is reviewing the
 
potential of expanding to new markets, aiming to boost business
 
growth via attracting
 
new clients.
Hellenic Bank Public Company Ltd, Cyprus (“Hellenic Bank”)
Hellenic
 
Bank Public
 
Company Ltd
 
(“Hellenic
 
Bank”) a
 
financial
 
institution
 
based
 
in Cyprus
 
and listed
 
in the
 
Cyprus
 
Stock
Exchange was accounted for as a Group’s associate under the
 
equity method from April 2023 until 30 June 2024 (note 24 to
the
 
consolidated
 
financial
 
statements).
 
As
 
a result
 
of the
 
agreements
 
the
 
Bank
 
had entered
 
into with
 
certain
 
of Hellenic
Bank’s
 
shareholders
 
since
 
August
 
2023,
 
on
 
4
 
June
 
2024,
 
the
 
Bank
 
announced
 
that,
 
following
 
the
 
receipt
 
of
 
the
 
relevant
regulatory
 
approvals,
 
acquired
 
an additional
 
26.1%
 
holding
 
in Hellenic
 
Bank (“Transaction”)
 
for
 
a total
 
consideration
 
of €
275.7m.
 
Following
 
the
 
aforementioned
 
Transaction,
 
pursuant to
 
the
 
Takeover
 
Bids Law
 
of 2007
 
of the
 
Republic of
 
Cyprus,
L.41(I)/2007 as amended
 
(“Law”), the
 
Bank also announced
 
the submission
 
of a Mandatory
 
Takeover
 
Bid (“Takeover
 
Bid”) to
all
 
shareholders
 
of
 
Hellenic
 
Bank
 
for
 
the
 
acquisition
 
of
 
up
 
to
 
100%
 
of
 
the
 
issued
 
share
 
capital
 
of
 
Hellenic
 
Bank.
 
The
consideration
 
offered
 
by the Bank was €2.56
 
per share, paid in cash
 
to all the shareholders
 
who would accept the
 
Takeover
Bid during the period
 
from 1 July until 30 July 2024.
 
Furthermore, within
 
June 2024 the
 
Bank proceeded with
 
the acquisition
of an additional 0.18% holding in Hellenic
 
Bank, for a total
 
consideration of € 2m, i.e at
 
a price of €
 
2.56 per share. Accordingly,
as of 30 June 2024 the Bank’s participation percentage
 
in Hellenic Bank reached 55.48%.
Despite being the
 
holder of
 
over
 
50% of Hellenic
 
Bank’s shares, until
 
the expiration
 
of the
 
Takeover
 
Bid acceptance
 
period,
and pursuant to the Law, Eurobank
 
as the offeror,
 
its nominees and persons acting in concert with it could not be appointed
to the
 
Board
 
of Directors
 
of Hellenic
 
Bank, nor
 
they
 
could exercise,
 
or procure
 
the
 
exercise
 
of,
 
the
 
votes
 
attaching to
 
any
shares they held in Hellenic Bank. In addition, during the
 
period when they
 
became aware that a bid was imminent and until
expiration
 
of
 
the
 
Takeover
 
Bid
 
acceptance
 
period,
 
the
 
Board
 
of
 
Directors
 
of
 
Hellenic
 
Bank
 
could
 
not
 
without
 
prior
authorization
 
of the
 
general
 
meeting of
 
shareholders,
 
take any
 
action which
 
could result
 
in the
 
frustration
 
of the
 
Takeover
Bid.
On 30 July
 
2024, the
 
acceptance period
 
for the
 
Takeover
 
Bid expired, therefore
 
the restrictions
 
imposed by the
 
Law on the
Bank’s ability to exercise
 
its voting rights
 
no longer applied,
 
and Eurobank
 
since then
 
has been able
 
to exercise
 
its rights in
full. Based on the above and considering the relevant provisions of the Cyprus’ legal framework including the Companies Law
Cap. 113, and Hellenic Bank’s articles of association in relation to the
 
exercise of shareholders’
 
rights, including the timing for
convening a general
 
meeting of the shareholders,
 
it was assessed that the Group acquired
 
control over
 
Hellenic Bank group
within July. Accordingly,
 
Hellenic Bank and its
 
subsidiaries were included in the Company’s consolidated financial statements
from the
 
beginning of
 
the
 
third quarter
 
of 2024
 
using the
 
most recent
 
available published
 
information.
 
On 7
 
August 2024,
 
 
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the Bank
 
announced that
 
after the
 
final review
 
of the
 
Acceptance and
 
Transfer
 
Forms, the
 
total percentage
 
of acceptance
of the
 
Takeover
 
Bid reached
 
0.481%,
 
giving Eurobank
 
total participation
 
of 55.962%
 
in the
 
issued share
 
capital of
 
Hellenic
Bank.
Furthermore,
 
in
 
November
 
2024,
 
the
 
Bank
 
announced
 
that
 
it
 
has
 
entered
 
into
 
share
 
purchase
 
agreements
 
with
 
certain
shareholders
 
of the
 
Hellenic Bank,
 
pursuant to
 
which, it
 
has agreed
 
to acquire
 
an additional
 
total holding
 
of 37.51%
 
in the
entity
 
for
 
a
 
total
 
consideration
 
of
 
ca.
 
 
750m,
 
corresponding
 
to
 
 
4.843
 
per
 
share.
 
As
 
of
 
31
 
December
 
2024,
 
the
 
above
transactions
 
were
 
subject
 
to
 
regulatory
 
approvals
 
and
 
upon
 
their
 
completion,
 
Eurobank’s
 
total
 
holding
 
in
 
Hellenic
 
Bank
reaches 93.47%.
Moreover,
 
in accordance
 
with
 
the
 
provisions
 
of the
 
Takeover
 
Bids Law
 
of 2007
 
in Cyprus
 
(“Law”),
 
the
 
Bank, following
 
the
completion
 
of
 
the
 
above-mentioned
 
transactions
 
has
 
the
 
obligation
 
to
 
proceed
 
to
 
a
 
tender
 
offer
 
for
 
the
 
remaining
outstanding shares
 
of Hellenic Bank
 
for at
 
least the
 
same price
 
i.e. € 4.843
 
per share,
 
whereas pursuant
 
to Article 36
 
of the
same law
 
it is able,
 
after completion
 
of the
 
said tender
 
offer
 
and given that
 
it will hold
 
more than
 
90% votes,
 
to require
 
all
the
 
holders
 
of the
 
remaining
 
securities to
 
sell those
 
securities. On
 
those grounds,
 
the
 
Bank announced
 
in November
 
2024
that it will exercise
 
its squeeze-out right to acquire any outstanding shares
 
of Hellenic Bank and take all necessary
 
steps for
the delisting of Hellenic Bank's shares from
 
the Cyprus Stock Exchange.
More recently,
 
on 11
 
February
 
2025, the
 
Bank announced
 
that following
 
the
 
receipt
 
of the
 
relevant
 
regulatory
 
approvals,
 
it
completed the acquisition of the additional holding of 37.51%
 
in Hellenic Bank, as per the aforementioned
 
agreements of the
Bank with certain of Hellenic Bank’s. shareholders.
 
Following that
 
and pursuant to the provisions
 
of the Takeover
 
Bids Law in
Cyprus, the Bank also announced the submission of a Mandatory Takeover
 
Bid for the acquisition of up to 100% of the issued
share capital of Hellenic Bank (“Takeover
 
Bid”). Further to the
 
above, on 6 March 2025 the
 
Bank announced that on 5 March
2025 the
 
Cyprus Securities and
 
Exchange Commission
 
(the “CySEC”)
 
approved
 
the Takeover
 
Bid Document
 
and authorised
its publication. Pursuant
 
to the Takeover
 
Bid Document, the
 
consideration
 
offered
 
to the shareholders
 
of Hellenic Bank who
will accept the
 
Takeover
 
Bid is € 4.843 per
 
share paid in cash.
 
The acceptance
 
period of the
 
Takeover
 
Bid commences on
 
11
March 2025 and ends on 9
th
 
April 2025.
Detailed information in relation to Hellenic Bank
 
acquisition is provided in note 23.2
 
to the consolidated financial statements.
Risk management
The
 
Group
 
acknowledges
 
that
 
taking risks
 
is an
 
integral
 
part of
 
its operations
 
in order
 
to achieve
 
its business
 
objectives.
Therefore,
 
the Group’s
 
management sets adequate
 
mechanisms to identify
 
those risks at
 
an early stage and
 
assesses their
potential impact on the achievement
 
of these objectives.
Due
 
to
 
the
 
fact
 
that
 
economic,
 
industry,
 
regulatory
 
and
 
operating
 
conditions
 
will
 
continue
 
to
 
change,
 
risk
 
management
mechanisms are
 
set in
 
a manner
 
that enable
 
the Group
 
to identify and
 
deal with
 
the risks
 
associated with
 
those changes.
The Group’s
 
structure, internal
 
processes and
 
existing control
 
mechanisms ensure
 
both the
 
independence principle
 
and the
exercise of sufficient supervision.
The Group's Management
 
considers effective
 
risk management as a top priority, as well
 
as a major competitive advantage,
for
 
the
 
organization.
 
As
 
such,
 
the
 
Group
 
has
 
allocated
 
significant
 
resources
 
for
 
upgrading
 
and
 
maintaining
 
its
 
policies,
methods and
 
infrastructure
 
up to date,
 
in order
 
to ensure
 
compliance with
 
the requirements
 
of the
 
European Central
 
Bank
(ECB)
 
and
 
of
 
the
 
Single
 
Resolution
 
Board
 
(SRB),
 
the
 
guidelines
 
of
 
the
 
European
 
Banking
 
Authority
 
(EBA)
 
and
 
the
 
Basel
Committee
 
for
 
Banking
 
Supervision
 
as
 
well
 
as
 
the
 
best
 
international
 
banking
 
practices.
 
The
 
Group
 
implements
 
a
 
well-
structured credit
 
approval process,
 
independent credit reviews
 
and effective
 
risk management policies
 
for all
 
material risks
it
 
is
 
exposed
 
to,
 
both
 
in
 
Greece
 
and
 
in
 
each
 
country
 
of
 
its
 
international
 
operations.
 
The
 
risk
 
management
 
policies
implemented by the Group
 
are reviewed
 
on a regular basis.
Risk
 
culture
 
is
 
a
 
core
 
element
 
of
 
the
 
organisation.
 
Risk
 
management
 
function
 
provides
 
the
 
framework,
 
procedures
 
and
guidance to enable all
 
employees to proactively
 
identify, manage
 
and monitor the
 
risks in their
 
own areas and improve
 
the
control and co-ordination of risk
 
taking across their business. Ongoing
 
education, communication and awareness takes place
via dedicated
 
learning programs,
 
monthly meetings,
 
sharing of
 
best practices
 
and other
 
initiatives.
 
The
 
Group
 
has also
 
a
policy in place to address any risks associated with the
 
introduction, significant modifications
 
and periodic monitoring of its
products and services.
The
 
amount of
 
risk which
 
the
 
Group
 
is willing
 
to assume
 
in the
 
pursuit of
 
its strategic
 
objectives
 
is articulated
 
via a
 
set of
quantitative
 
and
 
qualitative
 
statements
 
for
 
risks
 
assessed
 
as
 
material,
 
that
 
are
 
described
 
in
 
the
 
Group’s
 
Risk
 
Appetite
Framework.
 
The objectives are to support the
 
Group’s business growth,
 
balance a strong capital position with higher
 
returns
on equity and to ensure
 
the Group’s
 
adherence
 
to regulatory requirements.
 
The Risk Appetite,
 
that is clearly communicated
throughout
 
the
 
Group
 
determines
 
risk culture
 
and forms
 
the
 
basis on
 
which risk
 
policies
 
and risk
 
limits are
 
established
 
at
Group and regional level. Aiming to identify relevant and material
 
risks the Bank maintains a well-defined Risk Identification
and Materiality
 
Assessment (RIMA)
 
Framework.
 
The
 
identification and
 
the assessment
 
of all risks
 
is the
 
cornerstone
 
for the
effective
 
Risk Management. The
 
Group aiming to ensure
 
a collective view
 
on the risks linked
 
to the execution of
 
its strategy,
acknowledges the new
 
developments at an early stage and assesses the
 
potential impact.
The
 
Board Risk
 
Committee (BRC)
 
is a
 
committee of
 
the Board
 
of Directors
 
(BoD) and
 
its task
 
is to advise
 
and support
 
the
BoD regarding
 
the monitoring of
 
Group’s
 
overall
 
actual and future
 
risk appetite and strategy,
 
taking into account all
 
types
of risks to
 
ensure that
 
they are
 
in line with
 
the business
 
strategy,
 
objectives, corporate
 
culture and values
 
of the
 
institution.
The BRC
 
assists the
 
BoD in overseeing
 
the implementation
 
of Group’s
 
risk strategy
 
and the
 
corresponding limits
 
set. It also
 
 
 
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oversees the
 
implementation of the strategies
 
for capital and liquidity risk management as well as for
 
all material risks, such
as credit,
 
market, IRRBB,
 
sustainability risks and
 
non-financial risks
 
such as
 
operational,
 
reputational
 
conduct, legal,
 
cyber,
outsourcing,
 
in order
 
to assess
 
their
 
adequacy against
 
the
 
approved
 
risk appetite
 
limits. The
 
BRC consists
 
of five
 
(5) non-
executive directors,
 
meets at least 10
 
times per year
 
and reports to the
 
BoD on a quarterly
 
basis and on ad hoc instances
 
if
it is needed.
The Management
 
Risk Committee (MRC) is a management
 
committee established by the
 
Chief Executive Officer
 
(CEO) and
its main
 
responsibility
 
is to
 
oversee
 
the
 
risk management
 
framework
 
of the
 
Group.
 
As part
 
of its
 
responsibilities,
 
the
 
MRC
facilitates report
 
ing to the
 
BRC on the
 
range of risk-related
 
topics under its
 
purview,
 
including sustainability risks. The
 
MRC
proactively
 
supports
 
the
 
Group
 
Chief
 
Risk
 
Officer,
 
Chairman
 
of
 
the
 
MRC,
 
to
 
identify
 
material
 
risks,
 
in
 
addition
 
to
 
those
identified independently
 
by the
 
Group
 
CRO and
 
the
 
Group Risk
 
Management, and
 
to promptly
 
escalate
 
them
 
to the
 
BRC
and assists the Group CRO in ensuring that the necessary policies and procedures
 
are in place to prudently manage risk and
to comply with regulatory requirements.
The
 
Group’s
 
Risk Management
 
which is
 
headed by
 
the
 
Group Chief
 
Risk Officer
 
(GCRO), operates
 
independently from
 
the
business units and is
 
responsible for
 
the identification,
 
assessment, monitoring, measurement
 
and management of the
 
risks
that
 
the
 
Group
 
is exposed
 
to. It
 
comprises the
 
Group
 
Credit (GC),
 
the
 
Group
 
Credit Control
 
(GCC), the
 
Group
 
Credit Risk
Capital Adequacy Control
 
(GCRCAC), the
 
Group Market
 
and Counterparty
 
Risk (GMCR), the
 
Group Operational
 
and Non-
Financial
 
Risks
 
(GONFR),
 
the
 
Group
 
Model
 
Validation
 
and
 
Governance
 
(GMVG),
 
the
 
Group
 
Risk
 
Management
 
Strategy
Planning Operations
 
& Sustainability
 
Risk (GRMSPO&SR),
 
the
 
Supervisory
 
Relations
 
and Resolution
 
Planning (SRRP),
 
and
the Risk Analytics (RA) Units.
As part of its overall system of internal controls, Eurobank Ergasias Services
 
and Holdings S.A. has engaged in a
 
Service Level
Agreement (SLA) with Eurobank S.A.
 
(the banking subsidiary of
 
the Group) in order to
 
receive supporting and advisory
 
services
in all areas of risk management undertaken by
 
the Group.
The Group applies the
 
elements of the Three
 
Lines of Defense model for the
 
management of all types of risk. The Three
 
Lines
of Defense
 
Model
 
enhances
 
risk management
 
and
 
control
 
by
 
clarifying
 
roles
 
and responsibilities
 
within
 
the
 
organization.
Under the oversight
 
and direction of the Management
 
Body, the responsibilities
 
of each of these lines of defense are:
Line 1 - Own and manage
 
risk and controls.
 
The front
 
line business and operations
 
are accountable for
 
this responsibility as
they own the
 
rewards and are the
 
primary risk generators,
Line 2
 
- Monitor
 
risk and
 
controls
 
in support
 
of Executive
 
Management,
 
providing
 
oversight,
 
challenge, advice
 
and group-
wide direction. These
 
mainly include the Risk and Compliance Units,
Line 3
 
- Provide
 
independent assurance
 
to the
 
Board and
 
Executive
 
Management concerning
 
the
 
effectiveness
 
of risk
 
and
control management. This
 
refers to Internal
 
Audit.
Furthermore,
 
the Group
 
is in the process
 
of aligning Hellenic Bank risk management
 
policies and practices
 
with those of the
Group across key
 
risk types, following the
 
acquisition of control in the
 
third quarter of 2024 and in view of the
 
completion of
the Take
 
Over Bid process to acquire 100% of Hellenic Bank’s
 
shares. This includes harmonizing key risk policies, standardizing
regulatory as well as internal risk reporting,
 
and aligning risk methodologies.
The most important types of risk that
 
are addressed by the
 
risk management functions of the
 
Group are:
Credit Risk
Credit risk
 
is the
 
risk that
 
a counterparty
 
will be
 
unable to
 
fulfil its
 
payment obligations
 
in full
 
when due.
 
Credit risk
 
is also
related with
 
country risk and settlement
 
risk. Credit risk
 
arises principally from
 
the wholesale
 
and retail lending
 
activities of
the
 
Group,
 
as well
 
as from
 
credit enhancements
 
provided,
 
such as
 
financial guarantees
 
and letters
 
of credit.
 
The
 
Group is
also exposed to
 
credit risk
 
arising from
 
other
 
activities such as
 
investments
 
in debt securities,
 
trading, capital
 
markets and
settlement activities. Taking into account that credit risk
 
is the primary risk the
 
Group is exposed to,
 
it is very closely managed
and monitored by specialised risk units, reporting to the
 
GCRO.
The
 
credit review
 
and approval
 
processes
 
are centralized
 
both in
 
Greece
 
and in the
 
International
 
operations
 
following
 
the
“four-eyes”
 
principle and
 
specific
 
guidelines
 
stipulated
 
in the
 
Credit
 
Policy
 
Manual and
 
the
 
Risk Appetite
 
Framework.
 
The
segregation
 
of
 
duties
 
ensures
 
independence
 
among
 
executives
 
responsible
 
for
 
the
 
customer
 
relationship,
 
the
 
approval
process
 
and
 
the
 
loan
 
disbursement,
 
as
 
well
 
as
 
monitoring
 
of
 
the
 
loan
 
during
 
its
 
lifecycle.
 
The
 
credit
 
approval
 
process
 
in
Corporate
 
Banking is
 
centralized
 
through
 
the
 
establishment of
 
Credit
 
Committees with
 
escalating
 
Credit
 
Approval
 
Levels,
which assess and limit to the extent possible
 
the corporate credit risk. Rating models are used in order to calculate the credit
rating
 
of
 
corporate
 
customers,
 
reflecting
 
the
 
underlying
 
credit
 
risk.
 
The
 
most
 
significant
 
ones
 
are
 
the
 
MRA
 
(Moody’s
 
Risk
Analyst)
 
applied
 
for
 
companies
 
-mostly-
 
with
 
industrial
 
and
 
commercial
 
activity and
 
the
 
slotting
 
rating
 
models,
 
used
 
for
specialised lending portfolios (shipping, real estate and
 
project finance) with ring-fenced transactions. Credit risk assessment
is performed by Group Credit (GC), which assesses the credit requests submitted by the Business Units,
 
a procedure including
the
 
evaluation
 
of
 
the
 
operational
 
and
 
financial
 
profile
 
of
 
the
 
customer,
 
the
 
validation
 
of
 
the
 
borrower’s
 
rating
 
and
 
the
identification of potential risk factors
 
for the Bank.
The credit
 
review and
 
approval
 
processes
 
for loans
 
to Small Businesses
 
(turnover
 
up to €5m)
 
are also centralised
 
following
specific guidelines and applying the ‘four-eyes’
 
principle. The assessment is primarily based on the analysis of the borrower's
operational
 
characteristics and financial
 
position. The
 
same applies for
 
Individual Banking (consumer
 
and mortgage loans),
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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where the credit risk assessment
 
is based on criteria related to the characteristics of the retail
 
portfolio, such as the financial
position of the borrower,
 
the payment behaviour,
 
the existence of real estate property and the type and quality of securities.
The ongoing
 
monitoring of the
 
portfolio
 
quality and of
 
any deviations
 
that may
 
arise, lead to
 
an immediate
 
adjustment of
the credit policy and procedures, when deemed necessary. The
 
quality of the Group’s loan portfolios (business, consumer and
mortgage
 
in
 
Greece
 
and
 
abroad)
 
is
 
monitored
 
and
 
assessed
 
by
 
the
 
Group
 
Credit
 
Control
 
(GCC)
 
via
 
field,
 
desktop
 
and
thematic
 
reviews
 
in order
 
to timely
 
identify emerging
 
risks, vulnerabilities,
 
compliance to
 
credit policies
 
and consistency
 
in
underwriting. Furthermore,
 
the GCC assumes
 
oversight and supervisory
 
responsibilities for proper
 
operation of
 
credit rating
and impairment
 
models.
 
Moreover,
 
GCC regularly
 
reviews
 
the
 
adequacy of
 
provisions
 
of all
 
loan portfolios.
 
The
 
Unit also
formulates Group’s credit policies, reviews policies developed
 
by other units and participates in the development of new loan
products. Finally, it monitors regulatory developments, emerging trends and best
 
practices proposing relevant policy updates
or product enhancements
 
when necessary.
 
GCC operates
 
independently from all the
 
business units of the
 
Bank and reports
directly to the GCRO.
The
 
measurement,
 
monitoring and
 
periodic
 
reporting of
 
the
 
Group’s
 
exposure to
 
counterparty
 
risk (issuer
 
risk and
 
market
driven
 
counterparty
 
risk),
 
which
 
is
 
the
 
risk
 
of loss
 
due
 
to
 
the
 
customer’s
 
failure
 
to
 
meet
 
its
 
contractual
 
obligations
 
in
 
the
context of treasury positions, such as debt securities, derivatives, repos, reverse repos, interbank placings, etc. are performed
by the
 
Group Market
 
and Counterparty Risk
 
(GMCR). The
 
Group sets
 
limits on the
 
level of
 
counterparty risk
 
that are
 
based
mainly on the
 
counterparty’s credit
 
rating, as
 
provided by
 
international rating
 
agencies, the
 
product type
 
and the
 
maturity
of the transaction
 
(e.g. control
 
limits on net open derivative
 
positions by both
 
amount and term, sovereign
 
bonds exposure,
corporate securities, asset backed securities,
 
etc.). GMCR maintains and updates the limits’ monitoring systems and ensures
the correctness and compliance of all financial institutions limits
 
with the Bank’s policies as approved by the Group’s relevant
bodies. The
 
utilization
 
of the
 
abovementioned
 
limits, any
 
excess
 
of them,
 
as well
 
as the
 
aggregate
 
exposure
 
per
 
Group’s
entity,
 
counterparty
 
and
 
product
 
type
 
are
 
monitored
 
by
 
GMCR
 
on
 
a
 
daily
 
basis.
 
The
 
Group
 
from
 
2021
 
applies
 
the
 
new
regulatory
 
framework
 
for the
 
counterparty risk
 
from derivatives
 
Standardised Approach
 
for
 
measuring counterparty
 
credit
risk (SA-CCR).
Market Risk
The
 
Group
 
has
 
exposure
 
to
 
market
 
risk,
 
which
 
is
 
the
 
risk
 
of
 
potential
 
financial
 
loss
 
due
 
to
 
an
 
adverse
 
change
 
in
 
market
variables. Changes in interest rates,
 
foreign exchange rates,
 
credit spreads, equity prices and other
 
relevant factors, such
 
as
the implied volatilities, can affect the Group’s
 
income or the fair value of its financial
 
instruments. The market risks, the Group
is exposed
 
to, are
 
monitored, controlled
 
and estimated
 
by
 
GMCR. GMCR
 
is responsible
 
for
 
the
 
measurement,
 
monitoring,
control
 
and
 
reporting
 
of
 
the
 
exposure
 
on
 
market
 
risks
 
including
 
the
 
Interest
 
Rate
 
Risk and
 
the
 
Credit
 
Spread
 
Risk
 
in the
Banking Book (IRRBB/CSRBB)
 
of the Group.
 
The GMCR
 
reports to the
 
GCRO. The
 
exposures and the
 
utilisation of the
 
limits
are reported to the Board
 
Risk Committee and to the BoD.
Market
 
risk
 
in
 
Greece
 
and
 
International
 
Subsidiaries
 
is
 
managed
 
and
 
monitored
 
mainly
 
using
 
Value
 
at
 
Risk
 
(VaR)
methodology,
 
sensitivity and
 
stress test
 
analysis. VaR
 
is a
 
methodology
 
used in
 
measuring financial
 
risk by
 
estimating the
potential negative
 
change in the
 
market value
 
of a portfolio
 
at a given
 
confidence level
 
and over
 
a specified time
 
horizon.
The VaR
 
that the
 
Group measures
 
is an estimate based upon
 
a 99% confidence level
 
and a holding period
 
of 1 day and the
methodology
 
used
 
for
 
the
 
calculation
 
is
 
Monte
 
Carlo
 
simulation
 
(full
 
re-pricing
 
of
 
the
 
positions
 
is
 
performed).
 
Since
 
VaR
constitutes an
 
integral
 
part
 
of the
 
Group's
 
market
 
risk control
 
regime,
 
VaR
 
limits have
 
been established
 
for
 
all portfolios
(trading and investment)
 
measured at
 
fair value
 
and actual exposure is
 
monitored daily by
 
management. However,
 
the use
of this
 
approach
 
does not
 
prevent
 
losses outside
 
of these
 
limits in
 
the event
 
of extraordinary
 
market movements.
 
For
 
that
reason, the Group
 
uses additional monitoring metrics such as: Stressed VaR,
 
Expected Shortfall and Stress Tests.
 
Finally, the
Group already monitors the
 
impact from the
 
new regulatory framework
 
for market risk (Fundamental
 
Review of the Trading
Book-FRTB) and monitors the
 
evolution
 
of the relevant
 
capital charges until
 
its official application
 
(2026) based on a
 
set of
established systems and procedures.
Interest Rate Risk in the Banking Book
 
(IRRBB)
The IRRBB is defined as
 
the current and the prospective risk of a
 
negative impact to the institution’s economic value of
 
equity,
or to the institution’s net interest income, taking
 
market value changes into
 
account as appropriate, which arise
 
from adverse
movements in interest
 
rates affecting
 
interest rate sensitive
 
instruments, including gap risk, basis risk and option risk.
GMCR
 
is
 
the
 
unit
 
responsible
 
for
 
the
 
monitoring,
 
control,
 
reporting
 
and
 
estimation
 
of
 
IRRBB
 
on
 
a
 
group
 
level.
 
Both
 
the
Economic Value of Equity (EVE) and NII sensitivity to a number of stresses on interest rates are
 
estimated on a periodic basis
and
 
are
 
compared
 
with
 
the
 
approved
 
BoD
 
Risk
 
Appetite
 
Statements
 
(RAS)
 
thresholds.
 
IRRBB
 
analysis
 
currently
 
uses
 
the
established Asset
 
and Liability
 
Management (ALM)
 
tools within
 
each entity.
 
The
 
plan is
 
to expand
 
the
 
use of
 
the
 
ALM tool
applied on
 
a solo
 
level (in
 
Greece) for
 
the future
 
Group-level
 
IRRBB analysis. The
 
CSRBB analysis is
 
conducted on
 
a Group
level by
 
a centralized
 
tool. Furthermore,
 
the Group
 
already applies a set
 
of extra
 
stress test analysis
 
for specific
 
parts of its
Banking
 
Book
 
for
 
the
 
assessment
 
to
 
the
 
exposure
 
on
 
Mark-to-Market
 
(MTM)
 
volatility
 
on
 
both
 
OCI
 
and
 
Amortised
 
Cost
portfolios of investment
 
securities and for the assessment of the
 
CSRBB (Credit Spread Risk in the Banking Book). The
 
policy
for
 
the
 
management
 
of
 
IRRBB
 
as
 
approved
 
by
 
BRC
 
and
 
BoD
 
provides
 
a
 
clear
 
description
 
of
 
the
 
methodologies,
 
the
governance, the
 
limits that are used for the
 
management of IRRBB & CSRBB.
Liquidity Risk
The Group
 
is exposed on a
 
daily basis to
 
liquidity risk due to
 
deposits withdrawals,
 
maturity of medium
 
or long term notes,
maturity of secured
 
or unsecured
 
funding (interbank
 
repos and money
 
market takings),
 
collateral
 
revaluation
 
as a result
 
of
market movements,
 
loan draw-downs
 
and forfeiture
 
of guarantees. The
 
Board Risk Committee and the
 
BoD sets in the RAS
 
 
 
 
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Framework
 
the liquidity risk thresholds
 
to ensure that sufficient
 
funds are available to meet
 
all of these contingencies
 
under
any scenario.
 
The Group
 
monitors on a
 
continuous basis the
 
level of
 
liquidity risk using
 
regulatory and
 
internal metrics
 
and
methodologies (Liquidity
 
Coverage
 
Ratio/LCR,
 
Net Stable Funding Ratio/NSFR,
 
Liquidity Buffer
 
analysis, cash flow
 
analysis,
short-term and medium-term stress test etc.).
BRC’s
 
role
 
is
 
to
 
approve
 
all
 
strategic
 
liquidity
 
risk
 
management
 
decisions
 
and
 
monitor
 
the
 
quantitative
 
and
 
qualitative
aspects
 
of
 
liquidity
 
risk.
 
Group
 
Assets and
 
Liabilities
 
Committee
 
(G-ALCO)
 
has
 
the
 
mandate
 
to
 
form
 
and
 
implement
 
the
liquidity policies and
 
guidelines in conformity
 
with Group's
 
risk appetite, and to review
 
at least monthly
 
the overall
 
liquidity
position
 
of
 
the
 
Group.
 
Group
 
Treasury
 
is
 
responsible
 
for
 
the
 
implementation
 
of
 
the
 
Group's
 
liquidity
 
strategy,
 
the
 
daily
management of the Group’s
 
liquidity and for the preparation
 
and monitoring of the Group’s liquidity budget, while GMCR is
responsible for measuring,
 
control, monitoring and reporting the
 
liquidity of the Group to the
 
G-ALCO, BRC, BoD and to the
regulatory bodies.
Operational & Non-Financial Risks (NFRs)
Non-Financial Risks include operational
 
risks as well as
 
specific additional risks such as
 
business, strategic
 
and reputational
risk. Operational
 
risk is defined
 
by Basel III
 
as the
 
risk of loss
 
resulting from
 
inadequate or
 
failed internal
 
processes, people
and systems or from external events.
The
 
Group is
 
gradually
 
implementing the
 
Risk Appetite
 
Framework
 
to cover
 
NFRs, which sets
 
out the
 
mechanisms through
which the
 
Group
 
establishes
 
its risk
 
appetite and
 
ensures
 
that
 
its
 
risk profile
 
remains
 
within
 
that
 
appetite
 
to bear
 
risk in
relation to the internal
 
and external events as well
 
as other constraints.
Governance
 
responsibility
 
for
 
Non-Financial
 
Risks
 
management
 
stems
 
from
 
the
 
Board
 
of
 
Directors
 
(BoD),
 
through
 
the
Executive
 
Board
 
and
 
Senior
 
Management,
 
and
 
passes
 
down
 
to
 
the
 
Heads
 
and
 
staff
 
of
 
every
 
business
 
unit.
 
The
 
BoD
establishes the
 
mechanisms
 
used by
 
the
 
Group
 
to manage
 
NFRs, sets
 
the
 
tone and
 
expectations,
 
and delegates
 
relevant
responsibilities. The
 
Board Risk
 
Committee and the
 
Audit Committee monitor
 
the NFR
 
levels and
 
profile, including
 
relevant
events.
NFR management comprises
 
risk identification,
 
assessment, and mitigation
 
while employing independent oversight
 
and an
effective risk culture to ensure
 
that business objectives are met
 
within the NFR appetite
 
that is reflected in
 
the Group’s Policies
and Guidelines.
The Heads of each business unit (the risk owners)
 
are primarily responsible for the
 
day-to-day management of NFRs and the
adherence to relevant controls.
 
Each Business Unit appoints an Operational Risk Partner (OpRisk Partner) or an Operational
Risk Management Unit (ORMU) depending on the size of the business
 
unit, which is responsible for coordinating the
 
internal
risk management efforts
 
of the business unit while forming
 
the link between Line 1 and Line 2.
Eurobank has
 
adopted a Themes
 
-based risk taxonomy,
 
developed
 
along the lines
 
of the
 
industry reference
 
taxonomies, for
risk management
 
and reporting
 
purposes. Each
 
Risk Themes
 
is overseen
 
by Theme
 
Coordinators
 
(Second Line
 
of Defense
Units). The Risk Themes
 
which fall within the
 
scope of NFR are the following:
Group Operational
 
and Non-Financial Risks Unit (GONFR) has been positioned as an overlaying
 
framework
 
coordinator for
all
 
Non-Financial
 
Risks
 
(NFRs).
 
GONFR’s
 
overlaying
 
responsibilities
 
aim
 
to
 
harmonize
 
the
 
Second
 
Line
 
of
 
Defense
 
Units’
activities across
 
the
 
Group
 
and to
 
holistically
 
ensure
 
the effective,
 
consistent application
 
of the
 
Risk Appetite
 
Framework.
The 2LoD Units maintain their
 
responsibilities for specific Risk Theme(s)
 
owned.
Sustainability risks
Sustainability risks
 
are neither
 
new nor
 
stand-alone risks,
 
rather
 
they
 
are transverse
 
risks, manifesting
 
through
 
existing risk
types. As sustainability risks
 
interact with
 
other
 
risks and result in
 
direct distributional impacts
 
and indirect macroeconomic
impacts, the Group understands that careful
 
consideration of the cross
 
-cutting nature thereof is necessary in order to ensure
the optimal implementation
 
of adaptation activities.
Specifically,
 
sustainability
 
risks
 
are
 
defined
 
as
 
potential
 
losses
 
arising
 
from
 
any
 
negative
 
financial
 
impact
 
for
 
the
 
Group,
stemming
 
from
 
current
 
or
 
prospective
 
impacts
 
of
 
any
 
climate-related
 
&
 
environmental,
 
social
 
or
 
governance
 
event(s)
 
on
Group’s counterparties
 
or invested assets.
Definitions of sustainability risks include the following:
a)
Climate-Related and Environmental
 
risks: Climate-related and environmental
 
risks are defined as the
 
risks deriving
from potential loss or
 
negative impact to the Group, including
 
loss/ damage to
 
physical assets, disruption
 
of business
or
 
system
 
failures,
 
transition
 
expenditures
 
and
 
reputational
 
effects
 
from
 
the
 
adverse
 
consequences
 
of
 
climate
change and environmental degradation.
 
 
 
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b)
Social risk: Social
 
risk refers
 
to potential losses
 
arising from
 
any negative
 
financial impact on
 
the Group
 
stemming
from the current or prospective impacts of
 
social factors (such as
 
human rights
 
violation, income inequality, customer
safety & protection and
 
consumers’ changing preferences)
 
on the Group’s
 
counterparties or invested assets.
c)
Governance risk: Governance
 
risk refers to potential losses arising from any negative financial impact on the
 
Group
stemming
 
from
 
the
 
current
 
or
 
prospective
 
impacts
 
of
 
governance
 
factors
 
(such
 
as
 
anti-financial
 
crime,
 
non-
compliance with policies or regulations and governance practices) on the Group’s
 
counterparties or invested assets.
The Group is adopting a strategic approach
 
towards sustainability, climate change risk identification and risk management,
signifying the great importance that is given in the risks and opportunities
 
arising from the transitioning to a low-carbon and
more circular economy.
 
In this context, the
 
Bank has approved
 
and implements its Financed
 
Impact Strategy,
 
which focuses
on:
a)
Clients’
 
engagement
 
and
 
awareness
 
to
 
adapt
 
their
 
business
 
so
 
as
 
to
 
address
 
climate
 
change
 
challenges
 
and
opportunities,
b)
Actions for supporting clients in their
 
transition efforts
 
towards a more sustainable economic environment,
c)
Enablers and tools, such as frameworks
 
and products, to underpin sustainable financing,
d)
Assessment
 
and
 
management
 
of
 
sustainability
 
related
 
risks
 
within
 
its
 
loan
 
and
 
investment
 
portfolios,
 
including
assessing exposure to transition and physical
 
risks linked to climate change.
To facilitate
 
the classification
 
of sustainable/green financing opportunities in a structural manner,
 
the Group has developed
its Sustainable Finance Framework
 
(SFF). Through
 
its SFF,
 
the Group
 
is able to classify sustainable
 
lending solutions offered
to
 
its
 
clients,
 
specifying
 
the
 
applied
 
classification
 
approach
 
and
 
the
 
activities
 
defined
 
as
 
eligible
 
to
 
access
 
sustainable
financing (eligible green and social assets). Moreover, the Group
 
maintains a Sustainable Investment Framework
 
(SIF), which
outlines the Group’s
 
various sustainable investment
 
approaches/
 
strategies based on
 
criteria observed
 
as per international
market practices,
 
the process
 
for the
 
selection of eligible investments,
 
as well as the
 
monitoring frequency applicable to the
sustainable portfolio.
Furthermore,
 
the Group
 
has updated its
 
Sustainability Governance
 
structure by
 
introducing and defining
 
specific roles
 
and
responsibilities
 
in
 
order
 
to
 
support
 
the
 
roll-out
 
of
 
the
 
Sustainability
 
Strategy
 
and
 
the
 
integration
 
of
 
sustainability
 
risks,
through the involvement
 
of various key stakeholders (i.e. Business & Risk Units, Committees, etc.). The Group
 
applies a model
of
 
defined
 
roles
 
and
 
responsibilities
 
regarding
 
the
 
management
 
of
 
Sustainability
 
risks
 
and
 
aspects
 
across
 
the
 
3
 
Lines
 
of
Defense.
In this context and taking into
 
account the significant
 
impact of sustainability risks both
 
on financial institutions and on
 
the
global economy,
 
the
 
Group developed
 
and approved
 
its Sustainability
 
Risk Management
 
Policy
 
which aims
 
at fostering
 
a
holistic understanding of
 
the effects of sustainability risks
 
on its business
 
model, as well
 
as support
 
decision-making regarding
these
 
matters
 
and
 
provide
 
a
 
robust
 
governance
 
under
 
its
 
Risk
 
Management
 
Framework.
 
The
 
purpose
 
of
 
the
 
Policy
 
is
 
to
provide
 
an
 
overview
 
and
 
a
 
common
 
understanding
 
of
 
Group’s
 
main
 
governance
 
arrangements,
 
as
 
well
 
as
 
roles
 
&
responsibilities undertaken
 
by the
 
Group Sustainability
 
Risk (GSR),
 
in the
 
context of the
 
Group’s
 
overall
 
Sustainability risks
management activities.
The
 
Group
 
Sustainability Risk
 
(GSR) has
 
the
 
overall
 
responsibility for
 
overseeing,
 
monitoring, and
 
managing sustainability
risks.
 
More
 
specifically,
 
it
 
prepares
 
and
 
maintains
 
the
 
Bank’s
 
Sustainability
 
Risk
 
Management
 
Policy,
 
as
 
well
 
as
 
relevant
policies,
 
processes
 
and methodologies
 
(e.g.
 
ESG Risk
 
Assessment,
 
Climate
 
Risk Scorecard,
 
exclusion
 
lists) in
 
collaboration
with the Group Sustainability Unit, Business & Risk Units. In addition, GSR leads the development and implementation of the
Sustainability
 
risk
 
related
 
framework,
 
as
 
well
 
as
 
relevant
 
policies
 
and
 
processes
 
(e.g.,
 
Sustainability
 
Risk
 
Management
Framework,
 
Climate Risk Stress
 
Test
 
Framework
 
documents) across
 
the Group,
 
in coordination
 
with other
 
involved
 
units, as
well as the development and update of the Sustainable Finance Frameworks. Moreover,
 
it monitors and reports to
 
the Group
Senior
 
Sustainability
 
Officer
 
(GSSO)
 
the
 
progress
 
of
 
the
 
implementation
 
of
 
the
 
developed
 
Climate
 
Risk
 
action
 
plan
 
and
reports
 
to the
 
Board
 
for
 
Sustainability Risk
 
matters.
 
The
 
GSR supports,
 
reviews
 
and challenges
 
the
 
involved
 
stakeholders,
across
 
the
 
Group,
 
regarding
 
the
 
setting
 
of
 
the
 
Net
 
Zero
 
targets
 
and
 
of
 
the
 
Financed
 
Impact
 
Strategy,
 
through
 
the
identification
 
of
 
material
 
Sustainability
 
risk
 
related
 
areas.
 
The
 
GSR
 
also
 
leads
 
the
 
2nd
 
line
 
of
 
defense
 
independent
sustainable lending re-assessment process (i.e. provides opinion on sustainable financing regarding the CIB Portfolio, as part
of a
 
bespoke
 
process
 
and the
 
characterization
 
of products
 
of the
 
Retail Portfolio
 
as sustainable),
 
against the
 
Sustainable
Finance criteria (as
 
per pre-determined thresholds). Furthermore, GSR develops and maintains
 
the Climate Risk Stress
 
Testing
(CRST)
 
Framework,
 
as
 
well
 
as
 
scenario
 
analysis
 
and
 
stress
 
testing
 
methodologies,
 
and
 
coordinates
 
the
 
performance
 
of
sustainability risk scenario analysis and relevant stress test exercises
 
at Group level. In line with good practices
 
identified by
the ECB, the Financed Impact Strategy of the Bank focuses on sustainable financing targets / commitments. In particular, the
Bank identified total portfolio
 
and sectoral targets with regards
 
to financing the green transition
 
of its clients.
Eurobank has set the
 
following targets
 
for sustainable finance corporate
 
disbursements in the following
 
years:
Portfolio
 
targets
New disbursements
€2bn in new green disbursements to businesses by
 
2025
 
20% of
 
the
 
annual new
 
Corporate
 
& Investment
 
Banking (CIB)
 
portfolio
 
disbursements
 
to be
 
classified as
 
Green/
Environmentally sustainable
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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Green stock/ Exposure evolution
20% stock of green exposures by 2027 for
 
the CIB portfolio
Recovery and Resilience
 
Facility (RRF)
Mobilize €2.25bn total green RRF funds in the Greek
 
economy by 2026
 
Sectoral targets
Renewable energy
35% of new disbursements in the energy
 
sector will be directed to Renewable Energy Sources
 
(RES) financing
 
Green buildings
80% of new
 
disbursements related
 
to construction of
 
new buildings
 
(CIB portfolio)
 
to be allocated
 
with EPC A
 
and
above
20% of new disbursements related to
 
mortgage loans (excluding "My Home") to
 
be allocated with EPC B+ and
 
above
Furthermore,
 
Eurobank introduced
 
additional sustainable financing targets, enhancing its financed impact strategy:
Corporate and Investment
 
Banking green targets for
 
2024
New exposure to high emitters
No new investments in fixed income
 
securities (excluding exposures in Sustainability/Green bonds) towards
 
the top
20 most carbon-intensive corporates
 
worldwide
Increase in Sustainability-Linked loans
Double annual disbursements of Sustainability-Linked loans
Retail banking target for 2024
Maintain the
 
same
 
growth
 
in absolute
 
terms for
 
Retail Banking
 
new
 
green
 
disbursements (or
 
more
 
than 50%
 
increase
 
vs.
2023).
Further information
 
on the Group’s
 
financial risk management objectives
 
and policies, including the
 
policy for hedging
 
each
major type of transaction for which hedge
 
accounting is used is set out in the notes 2, 5 and 19 to the consolidated financial
statements for the year ended 31 December
 
2024 and as regards sustainability risks is provided in the Group’s Sustainability
Statement as at 31 December 2024.
Non Performing Exposures (NPE)
 
management
The Bank
 
realizes the
 
NPE Strategy
 
Plan through
 
its implementation
 
by doValue
 
Greece for
 
the assigned
 
portfolio
 
and the
securitization transactions.
Troubled Assets Committee
The Troubled
 
Assets Committee (TAC)
 
is established according to the regulatory provisions
 
and its main purpose is to act as
an independent
 
body,
 
closely
 
monitoring
 
the
 
Bank’s
 
troubled
 
assets portfolio
 
and
 
the
 
execution
 
of its
 
NPE
 
Management
Strategy.
Remedial and Servicing Strategy
 
(RSS)
The Remedial
 
Servicing and Strategy
 
(RSS) is responsible:
 
a) for
 
the management
 
of the
 
non-performing
 
and early arrears
loans of the Bank, b) for structured transactions
 
which create capital (such as Synthetic SRT STS securitizations) and/or offer
credit protection
 
and c) for
 
cooperation
 
with the
 
other
 
units of Group Strategy
 
for other
 
transactions and initiatives.
 
RSS is
closely monitoring the overall
 
performance of the
 
NPE portfolio as well
 
as the relationship of the
 
Bank with doValue Greece.
Furthermore,
 
following
 
Eurobank’s
 
commitments
 
against
 
the
 
significant
 
risk
 
transfer
 
(SRT)
 
monitoring
 
regulatory
requirements
 
pertaining
 
to
 
Bank’s
 
concluded
 
transactions,
 
RSS
 
has
 
a
 
pivotal
 
role
 
in
 
ensuring
 
that
 
relevant
 
process
 
is
performed
 
smoothly
 
and
 
in
 
a
 
timely
 
manner
 
and
 
that
 
any
 
shortcomings
 
are
 
appropriately
 
resolved,
 
while
 
providing
 
any
required clarifications
 
or additional material
 
required by the
 
regulatory authorities.
 
The Head of RSS
 
reports to the General
Manager of Group Strategy.
In this context, RSS has been assigned inter alia with the
 
following responsibilities:
a)
Structure new transactions and perform the execution of any
 
transaction processes, by also establishing negotiation
of Commercial / Legal Terms
 
as well monitoring of these transactions,
b)
Develop and actively monitor the
 
NPE targets and reduction plan,
c)
Set
 
the
 
strategic
 
principles,
 
priorities,
 
policy
 
framework
 
and
 
KPIs
 
under
 
which
 
doValue
 
Greece
 
is
 
servicing
 
the
portfolio,
d)
Closely monitor
 
the
 
execution of
 
the
 
approved
 
strategies,
 
as well
 
as all
 
contractual
 
provisions
 
under
 
the
 
relevant
contractual agreements
 
for Eurobank’s
 
portfolio
 
assigned to
 
doValue
 
Greece including
 
the securitized
 
portfolio
 
of
ERB Recovery DAC,
e)
Monitoring of
 
the performance
 
of the
 
senior notes
 
of the
 
securitizations in
 
collaboration
 
with Group
 
Risk so
 
as to
ensure compliance to significant risk transfer
 
(SRT) and to the Hellenic Asset Protection
 
Scheme (HAPS),
f)
Budget and monitor the Bank’s expenses and revenues
 
associated with the assigned portfolio,
g)
Cooperate closely with
 
doValue Greece
 
on a daily basis in achieving the Group’s
 
objectives,
h)
Maintain supervisory dialogue.
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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Project “Solar”
In the
 
context of its
 
NPE management
 
strategy,
 
the Group
 
has been
 
structuring an
 
NPE securitization
 
transaction
 
(project
‘Solar’), as part of a
 
joint initiative with
 
the other
 
Greek systemic banks (the
 
banks) since 2018.Out
 
of the notes to
 
be issued
by the SPV,
 
the Banks will hold 100% of the Senior notes as well as the 5% of the Mezzanine and Junior notes and will dispose
of the
 
remaining stake
 
of the
 
subordinated tranches
 
.
 
In June 2024,
 
the banks
 
submitted to the
 
Greek Ministry of
 
Finance a
joint application
 
for the
 
inclusion of the
 
senior notes to
 
be issued in the
 
Hellenic Asset Protection
 
Scheme. Since
 
June 2022,
the Group has classified the
 
underlying corporate loan
 
portfolio as held
 
for sale.
Other loans held
 
for sale (incl. Project “Leon”)
In December
 
2023, the
 
Bank, aiming to accelerate
 
further
 
its NPE reduction
 
plan, initiated the
 
sale process
 
of a mixed NPE
portfolio of total gross
 
book value ca. €400m, engaged in parallel in negotiations with potential investors.
 
Accordingly, as at
31 December 2023, the Bank
 
classified the aforementioned loan portfolio as held for sale. In
 
first half of
 
2024, the Bank revised
its NPE
 
sale target
 
and increased
 
the
 
aforementioned
 
perimeter
 
of NPE
 
loans by
 
ca. €240m,
 
which were
 
also classified
 
as
held-for-sale.
On 8 July 2024, the Group, through its special purpose financing vehicle ‘’LEON CAPITAL
 
FINANCE DAC’’ (SPV), issued senior,
mezzanine and junior notes of nominal amount of
 
ca. € 1.5bn, via the securitization of a mixed
 
NPE portfolio, which comprises
the
 
loans that
 
were
 
classified as
 
held for
 
sale at
 
30 June
 
2024 (project’s
 
‘’Leon’’ perimeter)
 
as well
 
as
 
written off
 
loans of
total principal
 
amount due
 
of ca.
 
€ 1.5bn
 
and gross
 
carrying
 
amount of
 
ca. €0.6bn
 
that complied
 
with the
 
requirements
 
of
Hellenic Asset
 
Protection
 
Scheme
 
law.
 
Further
 
to the
 
above,
 
on 13
 
September
 
2024, the
 
Group,
 
as the
 
holder
 
of the
 
notes
issued by
 
the
 
SPV,
 
proceeded
 
with the
 
disposal of
 
the
 
95% of
 
the
 
mezzanine and
 
junior tranches
 
to a
 
third party
 
investor.
Accordingly,
 
as
 
of
 
the
 
aforementioned
 
date,
 
the
 
Group
 
derecognized
 
the
 
underlying
 
loan
 
portfolio
 
and
 
recognized
 
the
retained notes
 
on its balance
 
sheet, i.e. 100%
 
of the senior
 
and 5% of the
 
mezzanine and junior
 
notes of Leon securitization,
at fair value.
Further information
 
is provided in note 20 to the
 
consolidated financial statements.
Macroeconomic Outlook and Risks
In
 
2024,
 
despite
 
the
 
challenging international
 
environment,
 
the
 
macroeconomic
 
backdrop
 
was
 
supportive
 
in
 
the
 
Group’s
three
 
core
 
markets.
 
In
 
particular,
 
the
 
economies
 
of
 
Greece,
 
Bulgaria
 
and
 
Cyprus
 
remained
 
in
 
expansionary
 
territory,
overperforming
 
most of their European Union (EU)
 
peers. According to the Hellenic
 
Statistical Authority (ELSTAT)
 
provisional
data, the real GDP of Greece expanded by
 
2.3% on an annual basis in the first nine months of 2024 –versus 0.5% in the euro
area (Eurostat)
 
 
driven by
 
household consumption
 
and the
 
buildup of inventories.
 
The average
 
annual inflation
 
rate based
on the Harmonized Index of Consumer Prices (HICP) decreased to 3.0% in 2024 from 4.2% in
 
2023, while the average monthly
unemployment rate declined to 10.1%
 
in 2024, from 11.1% in 2023, dropping to a 15-year low. In its Autumn Economic Forecasts
(November
 
2024), the
 
European
 
Commission
 
(EC) expects
 
real
 
GDP in
 
Greece
 
to grow
 
by
 
2.1%
 
in 2024
 
and 2.3%
 
in 2025
(2023: 2.3%). The
 
HICP growth
 
rate is
 
expected to decelerate
 
to 2.4% in
 
2025 and the
 
unemployment rate
 
to drop
 
to 9.8%,
respectively.
Growth
 
in Greece
 
as well
 
as in
 
Bulgaria and
 
Cyprus is
 
expected to
 
receive
 
a significant
 
boost from
 
EU-funded investment
projects and
 
reforms.
 
Greece shall
 
receive
 
€36bn (€18.2bn in grants
 
and €17.7bn
 
in loans) up
 
to 2026 through
 
the Recovery
and Resilience
 
Facility (RRF),
 
Next Generation
 
EU (NGEU)’s
 
largest instrument,
 
out of
 
which €18.2bn
 
(€8.6bn in
 
grants and
€9.6bn
 
in loans)
 
had been
 
disbursed by
 
the
 
EU as
 
of the
 
end 2024.
 
A further
 
€40bn is
 
due through
 
EU’s long-term
 
budget
(MFF), out of which €20.9bn
 
is to fund the National Strategic
 
Reference Frameworks
 
(ESPA 2021–2027).
On monetary
 
policy developments,
 
following
 
ten rounds
 
of interest
 
rate
 
hikes in
 
2022 and
 
in 2023
 
and on
 
the
 
back of
 
an
improved inflation outlook, the ECB implemented five interest rate cuts from June 2024 to January 2025, lowering its deposit
facility rate by
 
125 basis points in total.
On the fiscal
 
front, the
 
EC in its Autumn Economic Forecasts
 
expects a primary surplus of 2.9%
 
of GDP in 2024 and 2025, up
from
 
2.1%
 
of
 
GDP
 
in 2023.
 
The
 
gross
 
public
 
debt-to-GDP
 
ratio,
 
following
 
a
 
sizeable
 
increase
 
in
 
nominal
 
GDP
 
due
 
to
 
the
combination of
 
real GDP
 
growth
 
and inflation,
 
is expected
 
to decline
 
to 153.1%
 
in 2024 and
 
146.8% in
 
2025, from
 
163.9%
 
in
2023.
 
In
 
2024,
 
the
 
Greek
 
government
 
raised
 
 
9.55bn
 
from
 
the
 
international
 
financial
 
markets
 
through
 
the
 
Public
 
Debt
Management Agency (PDMA) by issuing two new
 
bonds (a 10-year bond at a yield of 3.478% in January and a 30-year bond
at a yield of 4.241% in
 
April), and re-opening eleven past issues with maturities of 5 and 10
 
years. At the end of 2024, the cash
reserves
 
of the Greek
 
government
 
stood close to €
 
33bn. Following
 
a series of sovereign
 
rating upgrades
 
in the second
 
half
of
 
2023,
 
the
 
Greek
 
government’s
 
long-term
 
debt
 
securities
 
were
 
considered
 
investment
 
grade
 
by
 
four
 
out
 
of
 
the
 
five
Eurosystem-approved
 
External Credit Assessment
 
Institutions (DBRS: BBB(low),
 
positive outlook, Fitch:
 
BBB-, stable outlook;
Scope: BBB,
 
stable outlook;
 
S&P: BBB-,
 
positive outlook),
 
and one
 
notch below
 
investment
 
grade by
 
the fifth
 
one, Moody’s
(Βa1, positive outlook) as of. 31 December
 
2024.
According to Bank of Greece (BoG) data, the
 
stock of credit to the non-financial private sector amounted to €113.2bn at the
end
 
of
 
2024,
 
up
 
from
 
€109.1bn
 
at
 
the
 
end
 
2023,
 
marking
 
a
 
gross
 
annual
 
increase
 
of
 
3.8%.
 
Adjusted
 
for
 
write-offs,
reclassifications
 
and foreign
 
exchange fluctuations,
 
the
 
annual growth
 
rate
 
of domestic
 
credit
 
to the
 
non-financial sector
stood at 8.3%. On the other
 
side of the ledger,
 
domestic non-financial private sector deposits were
 
up by 4.6% on an annual
basis, standing at €199.5bn
 
at the end of 2024 from
 
€190.7bn at the end of 2023.
 
On real estate market developments,
 
BoG
data
 
shows
 
that
 
residential
 
real
 
estate
 
prices
 
recorded
 
an annual
 
increase
 
of 9.2%
 
in the
 
first nine
 
months
 
of 2024,
 
and
commercial real
 
estate prices an annual increase of 7.8%
 
in the first half of 2024.
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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In Bulgaria, real GDP growth came
 
in at 2.2% on an annual basis in the first three quarters of 2024, slightly higher compared
to 2.1%
 
in the
 
same
 
period
 
of 2023.
 
Household consumption
 
and investment
 
were
 
the
 
key
 
growth
 
drivers,
 
with the
 
former
GDP component benefitted
 
from declining unemployment, significant increases in the minimum
 
wage (+19.6% since 1 January
2024),
 
as
 
well
 
as
 
in public
 
sector
 
wages
 
and
 
pensions,
 
and
 
rapid
 
credit
 
expansion
 
for
 
consumption
 
purposes.
 
The
 
rise
 
in
investment
 
came
 
from
 
inventories
 
accumulation,
 
as gross
 
fixed capital
 
formation
 
was almost
 
flat.
 
The
 
contribution
 
of net
exports
 
weakened,
 
as
 
exports
 
contracted,
 
and
 
imports
 
expanded.
 
Based
 
on
 
the
 
autumn
 
forecasts
 
by
 
the
 
EC
 
(November
2024), GDP
 
growth
 
in 2024
 
was projected
 
at 2.4%,
 
while for
 
2025 a
 
moderate
 
increase to
 
2.9%
 
is anticipated.
 
Disinflation
progressed
 
in 2024 at
 
a much faster
 
pace than
 
in 2023,
 
with the
 
latest available
 
inflation print
 
of December
 
at 2.1%
 
on an
annual basis,
 
which led
 
to an average
 
annual HICP inflation
 
in 2024
 
of 2.6%, down
 
from 8.6%
 
in 2023.
 
The
 
December print
brought Bulgaria
 
just 10 bps
 
away from
 
fulfilling the
 
only pending criterion
 
for eurozone
 
entry, i.e.
 
the one
 
concerning price
stability.
 
The
 
EC forecast
 
for
 
HICP inflation
 
stands at
 
2.3% for
 
2025 due
 
to persistent
 
services
 
inflation. On
 
the
 
fiscal front,
according to preliminary
 
data from
 
the Ministry
 
of Finance,
 
the cash-based
 
fiscal deficit stood
 
at 3% of
 
the projected
 
GDP
in 2024. The
 
Eurostat-defined deficit
 
was projected by
 
the EC at
 
2.6% for 2024,
 
up from 2% in 2023.
 
Household demand will
continue supporting
 
GDP growth
 
in 2025,
 
on the
 
back of
 
expected historically
 
low unemployment
 
at 4%,
 
and new,
 
smaller
than in previous
 
years, increases in the
 
minimum wage, public sector salaries
 
and pensions. Investment
 
financed by the
 
RRF
are expected to bolster
 
gross fixed capital formation.
 
The risks to the
 
economic outlook related
 
to political uncertainty
 
may
ease in 2025,
 
after successful
 
negotiations for
 
a new coalition
 
government
 
following
 
the October
 
2024 elections, that
 
took
power in mid-January 2025. In October, Fitch Ratings has re-affirmed Bulgaria’s long-term foreign and local currency ratings
at ‘BBB’, with a positive rating
 
outlook.
In Cyprus, according to the
 
real GDP data for
 
the first nine months
 
of 2024, the
 
annual GDP growth
 
accelerated
 
to 3.7%, up
from 2.6% in
 
the same
 
period of 2023.
 
Although exports of goods
 
fell 2.1%,
 
higher exports of
 
services by
 
9.4%,
 
supported by
a range
 
of sectors
 
according to
 
current
 
account balance
 
data (tourism,
 
Information
 
and Communication
 
Technology
 
(ICT)
activities, financial
 
services),
 
led to
 
a 7.7%
 
increase
 
in total
 
exports, making
 
them
 
central
 
to the
 
GDP increase
 
in the
 
said
period. Household consumption (+4.2%), was the second more significant growth
 
driver, on the
 
back of a tight labour market
(unemployment at a 15-year low
 
of 5%). According to EC’s autumn economic forecasts (November
 
2024), Cyprus is expected
to grow by 3.6% in
 
2024, up from 2.5%
 
in 2023, with GDP
 
expansion decelerating in 2025 to
 
2.8%. HICP inflation
 
was projected
at 2.2% in 2024 and
 
2.1% in 2025 (2023:3.9%). Investment
 
is set to keep benefitting from the RRF funding in the coming years,
whereas
 
easing financial
 
conditions are
 
expected to
 
provide
 
a further
 
stimulus. Household
 
consumption will
 
be boosted
 
in
the coming years by a further decline in unemployment, to 4.7% in 2025
 
on the back of reforms in the labor market in
 
previous
years,
 
but
 
also
 
from
 
a
 
further
 
recovery
 
in
 
household
 
purchasing
 
power
 
due
 
to
 
increases
 
in
 
nominal
 
wages
 
and
 
declining
inflation. Export
 
performance
 
is projected
 
to continue
 
benefitting from
 
growing
 
tourist receipts
 
and a
 
dynamic outlook
 
for
services, particularly
 
related to the
 
ICT,
 
but also the
 
real estate and
 
energy sectors.
 
Indicative
 
of these
 
prospects is
 
the rise
in the
 
number of
 
tourists to a
 
new all-time
 
high in the
 
January-November
 
2024 period,
 
though the
 
annual rate
 
of increase
slowed
 
down
 
to
 
5%
 
from
 
the
 
20.4%
 
seen
 
in
 
2023.
 
In
 
December
 
2024,
 
Fitch
 
Ratings
 
and
 
S&P
 
Global
 
upgraded
 
Cyprus’s
sovereign credit
 
to A- from BBB+, with a stable outlook, on economic and fiscal overperformance.
Regarding the
 
outlook for
 
the
 
next 12
 
months, the
 
major macroeconomic
 
risks and
 
uncertainties
 
in Greece
 
and our
 
region
are associated with: (a)
 
the geopolitical tensions caused primarily by
 
the war in Ukraine and
 
the fragile situation in the Middle
East, their
 
implications
 
regarding regional
 
and global
 
stability and
 
security,
 
and their
 
repercussions
 
on the
 
global and
 
the
European economy, (b) an interruption
 
or even a reversal
 
of the disinflationary trend observed
 
in the past 24 months and its
impact on
 
economic growth,
 
employment,
 
public finances,
 
household budgets,
 
firms’ production
 
costs, external
 
trade
 
and
banks’
 
asset
 
quality,
 
as
 
well
 
as
 
any
 
potential
 
social
 
and/or
 
political
 
ramifications
 
this
 
may
 
entail,
 
(c)
 
the
 
timeline
 
of
 
the
potential further
 
interest
 
rate
 
cuts by
 
the
 
ECB and
 
the
 
Federal
 
Reserve
 
Bank, as
 
persistence
 
on high
 
rates
 
for
 
longer
 
may
keep exerting pressure
 
on sovereign and private borrowing
 
costs and certain financial institutions’ balance
 
sheets, but early
rate cuts entail
 
the risk of a
 
rebound in inflation,
 
(d) the prospect
 
of Greece’s
 
and Bulgaria’s major trade
 
partners, primarily
the euro area, remaining stagnant or even facing a temporary downturn,
 
(e) the elevated political and economic uncertainty
stemming from the international and trade policy decisions of
 
the new administration in the United States, (f) the persistently
large current account deficit that seems to become once again a structural feature of the Greek economy, (g) the absorption
capacity of the NGEU and MFF
 
funds and the attraction of new investments in the countries of
 
presence, especially in Greece,
(h) the
 
effective
 
and timely
 
implementation
 
of the
 
reform
 
agenda required
 
to meet the
 
RRF milestones and
 
targets and
 
to
boost productivity,
 
competitiveness, and
 
resilience and
 
(i) the
 
exacerbation
 
of natural
 
disasters due
 
to the
 
climate change
and their effect
 
on GDP,
 
employment, fiscal balance and sustainable
 
development in the
 
long run.
Materialization of the
 
above risks would have
 
potentially adverse effects
 
on the fiscal planning of the Greek
 
government, as
it could
 
decelerate
 
the pace
 
of expected
 
growth
 
and on
 
the
 
liquidity,
 
asset quality,
 
solvency
 
and profitability
 
of the
 
Greek
banking sector.
 
In this context,
 
the Group’s
 
Management and
 
Board are
 
continuously monitoring the
 
developments
 
on the
macroeconomic, financial and geopolitical
 
fronts as well as the
 
evolution of
 
the Group’s
 
asset quality and liquidity KPIs and
have maintained
 
a high level
 
of readiness,
 
so as to
 
accommodate decisions,
 
initiatives
 
and policies to
 
protect the
 
Group’s
capital, asset
 
quality and
 
liquidity standing
 
as well
 
as the
 
fulfilment,
 
to the
 
maximum possible
 
degree, of
 
its strategic
 
and
business goals in accordance with the
 
business plan for 2025 - 2027.
Share Capital
As at 31 December 2024:
a)
The
 
total
 
share
 
capital
 
of
 
Eurobank
 
Holdings
 
amounted
 
to
 
€808,881,992.38
 
divided
 
into
 
3,676,736,329
 
common
voting
 
shares
 
of nominal
 
value
 
of €0.22
 
each. All
 
shares are
 
registered,
 
listed on
 
the
 
Athens
 
Stock Exchange
 
and
incorporate all the
 
rights and obligations set by the
 
Greek legislation,
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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b)
The
 
number of
 
Eurobank
 
Holdings shares
 
held by
 
the
 
Group’s
 
subsidiaries in
 
the
 
ordinary course
 
of their
 
business
was 1,914,541 (31 December
 
2023: 4,346,566) (note 38 to the consolidated financial statements),
On
 
23
 
July
 
2024,
 
the
 
Annual
 
General
 
Meeting
 
(AGM)
 
of
 
the
 
shareholders
 
of
 
the
 
Company,
 
among
 
others,
 
approved
 
the
cancellation
 
of
 
52,080,673
 
treasury
 
shares
 
acquired
 
in
 
2023
 
from
 
Hellenic
 
Financial
 
Stability
 
Fund.
 
Following
 
the
 
said
cancellation,
 
the
 
share
 
capital
 
and the
 
share
 
premium
 
of the
 
Company decreased
 
by €
 
11,457,748.06
 
and €
 
16,274,764.99,
respectively.
Share capital increase
Following the
 
exercise of share options granted to executives of the Group under the current
 
share options’ plan (see below),
and by
 
virtue of
 
the
 
decision
 
of the
 
Board
 
of Directors
 
of the
 
Company on
 
30 August
 
2024,
 
the
 
Company’s share
 
capital
increased by €2,714,189.50
 
through the
 
issue of 12,337,225 new
 
common voting shares
 
of a nominal value of €0.22 per
 
share
and exercise price of €0.23 per share. The
 
total difference
 
above par,
 
which amounts to 123,372.25 euros, is credited into the
account “Share premium”.
 
The new shares
 
were listed on the
 
Athens Exchange on 12 September 2024.
Share options
Under the
 
five-year
 
shares award
 
plan approved
 
in 2020
 
and initiated
 
in 2021,
 
Eurobank
 
Holdings grants
 
to its employees
and the
 
employees
 
of its
 
affiliated
 
companies share
 
options rights,
 
issuing new
 
shares with
 
a corresponding
 
share capital
increase upon the options’ exercise.
 
The maximum number of rights that can be approved
 
was set at 55,637,000
 
rights, each
of which would
 
correspond to
 
one new share
 
with exercise
 
price equal to
 
€ 0.23. The
 
final terms and the
 
implementation of
the share options plan, which is a forward
 
-looking long-term incentive aiming at the
 
retention of key executives, are
 
defined
and approved annually by
 
the Board of Directors in accordance
 
with the applicable legal and regulatory
 
framework,
 
as well
as the policies of the Group.
The options are
 
exercisable in portions annually during a period from
 
one to five years, while each portion may be exercised
wholly or partly and converted into shares at the employees’
 
option, provided that they
 
remain employed by the
 
Group until
the first available exercise date. The corporate actions that adjust the number and
 
the price of shares also adjust
 
accordingly
the share options.
Further information
 
is provided in note 40 to consolidated
 
financial statements.
Dividends/Distribution of Profits
On 23 July
 
2024, the AGM of
 
the shareholders of the Company, among
 
others, approved a) the distribution of a cash
 
dividend
of
 
€342m
 
from
 
the
 
“Special
 
Reserves”
 
account,
 
following
 
the
 
approval
 
received
 
from
 
the
 
ECB
 
on
 
5
 
June
 
2024.
 
The
 
said
dividend corresponded
 
to a
 
30% payout
 
ratio
 
of the
 
Group’s
 
net profit
 
for
 
2023 and
 
a gross
 
dividend of
 
€0.09333045
 
per
share, following
 
the cancellation
 
of treasury shares stated above
 
and b) the distribution of €404,330 to senior management
and employees
 
of the
 
Company from
 
the “Special
 
Reserves”
 
account. In
 
addition, it
 
was noted
 
in AGM
 
that the
 
respective
amount that was approved
 
to be distributed to senior management and employees
 
of the Bank was € 26,237,474.
In December 2024, the
 
Bank proceeded with the
 
distribution of non-mandatory reserves
 
for a total amount of €240m which
is part
 
of the Bank’s
 
overall contribution to its sole shareholder, Eurobank Holdings, in order to
 
enable the latter to
 
remunerate
its shareholders out of
 
the profits of the financial year 2024,
 
in accordance with the provisions of article 162
 
par.3 of Company
Law 4548/2018.
Based
 
on
 
the
 
Group’s
 
financial
 
performance
 
for
 
the
 
financial
 
year
 
2024,
 
Eurobank
 
Holdings
 
intends
 
to
 
remunerate
 
its
shareholders
 
with
 
an
 
amount
 
of €674m
 
corresponding
 
to
 
a 50%
 
payout
 
ratio
 
of
 
the
 
Group’s
 
net
 
profit
 
for
 
2024
 
less
 
the
negative goodwill (€99.5m
 
gain on acquisition of a shareholding in Hellenic Bank),
 
subject to approval of the Annual General
Meeting of its
 
shareholders
 
and the
 
regulatory authorities.
 
The
 
final remuneration
 
will be a
 
combination of cash
 
and share
buyback.
Major Shareholders
Based on the most recent notifications that Eurobank Holdings has received from shareholders controlling
 
5 per cent or more
of Eurobank Holdings’
 
voting rights, such significant shareholders
 
are the following:
a)
“Fairfax
 
Financial
 
Holdings
 
Limited”,
 
holding
 
32.89%
 
of
 
Eurobank
 
Holdings’
 
total
 
share
 
capital
 
and
 
voting
 
rights,
corresponding to 1,209,223,895
 
Eurobank Holdings’ ordinary
 
shares (effective
 
since 23 January 2025).
Specifically,
 
following
 
the
 
changes in
 
the
 
Company’s share
 
capital in
 
the
 
third
 
quarter
 
of 2024
 
(section of
 
“Share
capital”), and based
 
on the
 
latest notification
 
that Eurobank
 
Holdings had received
 
from Fairfax
 
Group (“Fairfax”),
the
 
latter
 
held 33.29%
 
of Eurobank
 
Holdings’
 
total number
 
of voting
 
rights as
 
at 31
 
December
 
2024 (31
 
December
2023: 32.93%).
 
On 23 January
 
2025, the
 
Company announced that
 
it had been
 
informed
 
by Fairfax
 
that the
 
latter
had sold 80
 
million ordinary
 
shares of the
 
Company through
 
an accelerated
 
book building
 
procedure
 
reserved
 
for
qualified investors (the
 
“Transaction”).
 
The Transaction
 
represented a
 
mandatory technical
 
adjustment to Fairfax’s
significant equity holding in the
 
Company, with Fairfax
 
remaining a long-term, committed reference
 
shareholder of
the Company. Furthermore,
 
on 7 February 2025, the Company announced that it had been informed by Fairfax,
 
that
following
 
the
 
aforementioned
 
sale,
 
the
 
latter
 
holds
 
32.89% of
 
Eurobank
 
Holdings’
 
total
 
share
 
capital
 
and
 
voting
rights.
 
b)
“The
 
Capital
 
Group
 
Companies,
 
Inc”,
 
holding
 
5,11%
 
of
 
Eurobank
 
Holdings’
 
total
 
number
 
of
 
voting
 
rights,
corresponding to
 
187,812,291
 
voting rights of
 
Eurobank Holdings’
 
ordinary shares.
 
(effective
 
since 1 December
 
2020,
while the percentage calculation is based on
 
the new total Company’s listed
 
shares that are tradeable on the Athens
Stock Exchange, following the
 
last share capital increase due to the exercise
 
of stock option rights),
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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c)
The “Helikon Investments Limited”, holding 5.06% of Eurobank Holdings’ total number of voting rights, corresponding
to
 
185,957,220
 
voting
 
rights
 
of
 
Eurobank
 
Holdings’
 
ordinary
 
shares.
 
(effective
 
since
 
25
 
January
 
2023,
 
while
 
the
percentage
 
calculation is
 
based on the
 
new total
 
Company’s listed shares
 
that are
 
tradeable on
 
the Athens
 
Stock
Exchange, following the
 
last share capital increase due to the
 
exercise of stock option rights).
Sundry information required
 
under Law 3556/2007 (article 4, par.7)
According to the Articles of Association:
a)
there are
 
no restrictions on the transfer
 
of the Eurobank
 
Holdings’ shares,
b)
there are
 
no shares with special controlling
 
or voting rights,
c)
there are
 
no restrictions on voting rights,
d)
the rules related
 
to the appointment
 
and replacement
 
of directors as well
 
as to the amendment
 
of the Articles
of Association are in accordance
 
with the provisions
 
of company law.
Eurobank Holdings is not aware of any shareholders’
 
agreements resulting in restrictions in the transfer
 
of its shares or in the
exercise of the shares’ voting rights. There
 
are no significant agreements that enter into force, are amended or expire if there
is change in the control
 
of Eurobank Holdings following
 
a public offer.
 
There
 
are no agreements between Eurobank
 
Holdings
and the Directors or the
 
staff for compensation
 
in the event
 
of departure as a result of a public offer.
Board of Directors
The Board
 
of Directors
 
(BoD) was elected
 
by the
 
Annual General
 
Meeting of the
 
Shareholders
 
(AGM) held
 
on 23 July
 
2024
for a
 
three - year
 
term of office
 
that will expire
 
on 23 July 2027,
 
prolonged until
 
the end of
 
the period
 
the AGM
 
for the
 
year
2027 will take place.
The BoD of Eurobank Holdings is set out in note 48 to the consolidated financial statements. Personal details of the Directors
are available on the website of Eurobank
 
Holdings (www.eurobankholdings.gr).
Information required
 
under Law 4548/2018 (article 97,
 
par.1
 
(b))
According to
 
article 97
 
par.
 
1 (b) of
 
Law 4548/2018
 
the BoD
 
members
 
owe to
 
disclose in a
 
timely and
 
adequate manner
 
to
the other
 
members of
 
the BoD
 
their own
 
interests, which may
 
arise from
 
the company's
 
transactions, which
 
fall within
 
their
duties, as well
 
as any conflict
 
of their
 
interests with
 
those of the
 
company or its
 
related companies.
 
In such case
 
and in line
with the provisions
 
of article 97 par 3 of the same law,
 
the member of the
 
BoD is not entitled to vote on issues in which there
is a conflict of interest with his own company or persons
 
with whom he is a related party.
 
In these cases, decisions are taken
by the other
 
BoD members.
For 2024, the
 
following issues were
 
noted in which there was a conflict of interest
 
with Eurobank Holdings:
For
 
the purposes of
 
discussions related
 
to the proposed
 
amendment of the
 
Shareholders Agreement
 
of Grivalia Hospitality
S.A.,
 
which
 
involved
 
a
 
business
 
arrangement
 
between
 
Eurobank,
 
a
 
subsidiary
 
of
 
Eurobank
 
Holdings,
 
and
 
certain
 
related
parties, the
 
Board
 
member
 
Mr.
 
B. Martin
 
was not
 
entitled to
 
vote.
 
This
 
restriction
 
was in
 
accordance
 
with paragraph
 
3 of
Article 97
 
of Company
 
Law 4548/2018,
 
due to
 
a conflict
 
of interest
 
arising from
 
Mr.
 
Martin’s position
 
as Vice
 
Chairman of
Strategic
 
Investments
 
at
 
Fairfax,
 
a
 
significant
 
shareholder
 
of
 
Eurobank
 
Holdings
 
and
 
a
 
related
 
party
 
to
 
the
 
particular
arrangement.
For
 
the
 
purposes
 
of a)
 
decisions
 
relating
 
to the
 
Stock
 
Options
 
plan (4th
 
series
 
implementation)
 
approved
 
by
 
the
 
Annual
General
 
Meeting of Shareholders
 
in 2020 b) approvals
 
according to article
 
86 of Law 4261/2014,
 
the CEO
 
Mr. Karavias
 
and
the Deputy
 
CEOs Messrs. Ioannou
 
and Vassiliou
 
were
 
not entitled to vote,
 
according to the
 
provisions
 
of par.
 
3 of art. 97
 
of
the Law 4548/2018, due to conflict of interests.
Related party transactions
As at
 
31 December
 
2024, the
 
Group’s
 
outstanding balances
 
of the
 
transactions
 
and the
 
relating net
 
income
 
/ expense
 
for
2024 with (a) the
 
key management personnel
 
(KMP) and the entities
 
controlled or jointly controlled
 
by KMP are: receivables
€5.3m, liabilities €21.2m, net expense €9m (b) the Fairfax
 
group (excluding Eurolife
 
FFH Insurance Group
 
Holdings S.A., which
is also a Group’s associate) are:
 
receivables €164.2m, liabilities €23.4m, guarantees issued €2.5m, net income
 
€18.8m and (c)
the associates
 
and joint ventures
 
and the Eurobank
 
Group’s personnel
 
occupational insurance
 
fund
are: receivables
 
€100m,
liabilities €106m, net expense €69m.
KMP are
 
entitled to
 
compensation in
 
the
 
form
 
of short-term
 
employee
 
benefits of
 
€11.8m (2023:
 
€8.3m) including
 
€2.2m in
upfront
 
variable
 
remuneration
 
awarded
 
as
 
profit
 
sharing,
 
and
 
long-term
 
employee
 
benefits
 
amounting
 
to
 
€5.3m
 
(2023:
€1.4m) including €3.2m
 
in deferred
 
variable remuneration
 
awarded as profit
 
sharing and payable
 
in equal instalments
 
over
the next 4-5 years. In addition, KMP have been granted €5.5m in variable remuneration
 
through share options (2023: €7.8m),
€3.3m
 
of
 
which
 
relates
 
to
 
options
 
exercisable
 
in
 
equal
 
portions
 
over
 
the
 
next
 
4-5
 
years.
 
The
 
variable
 
remuneration
 
was
awarded, following
 
the Annual
 
General
 
Meetings of the
 
shareholders
 
of the Company
 
and the Bank
 
taken place
 
on 23 July
2024, in accordance with the
 
Company’s and the Bank’s remuneration
 
policy.
At the same date, the
 
Company’s outstanding balances of the
 
transactions and the
 
relating net income / expense
 
for
 
2024
with (a) KMP are: compensation €0.4m that is referring
 
mainly to KMP services provided by Eurobank S.A. in accordance
 
with
the
 
relevant
 
agreement,
 
(b)
 
the
 
Fairfax
 
group
 
refer
 
to
 
receivables
 
and
 
operating
 
income
 
of
 
€0.33m
 
related
 
to
 
financial
consulting
 
services,
 
(c)
 
the
 
subsidiaries
 
are:
 
receivables
 
€1,822.5m,
 
liabilities
 
€0.8m
 
and
 
net
 
income
 
€355.2m
 
and
 
(d)
 
the
Group’s associate Eurolife
 
FFH Insurance Group Holdings
 
S.A. are: operating expense of €0.1m.
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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All transactions
 
with related
 
parties are
 
entered into
 
the normal
 
course of
 
business and
 
are conducted
 
on an arm's
 
length
basis. Further
 
information
 
is provided
 
in the
 
note 46
 
to the
 
consolidated financial
 
statements
 
and note
 
19 to
 
the
 
financial
statements of the Company.
External Auditors
The Eurobank
 
Holdings’ Shareholders Annual General
 
Meeting held on 23 July 2024 approved the appointment of KPMG, as
statutory auditor for the
 
financial statements (separate
 
and consolidated) for the
 
year ending 31 December 2024.
During 2024,
 
the
 
Audit Committee
 
reviewed
 
KPMG’s independence
 
and effectiveness,
 
along with
 
its annual
 
audit plan.
 
In
addition, the
 
Audit Committee
 
ensured
 
on a
 
quarterly
 
basis that
 
a) the
 
non-audit services
 
assigned to
 
KPMG, have
 
been
reviewed
 
and approved
 
as required
 
and b) there
 
is a proper
 
balance between
 
the audit and
 
non-audit fees
 
paid to KPMG,
in
 
accordance
 
with
 
the
 
relevant
 
provisions
 
of
 
the
 
Group’s
 
Policy
 
on
 
External
 
Auditors’
 
Independence
 
(note
 
47
 
of
 
the
consolidated financial statements).
Corporate Governance
 
Statement
In compliance with
 
the art.
 
17 of the
 
Law 4706/2020 for
 
the listed companies,
 
which stipulates that
 
listed companies should
adopt and implement a corporate governance code, prepared by a recognized and reputable body, and following a relevant
resolution
 
of
 
the
 
Board
 
of
 
Directors
 
of
 
Eurobank
 
Holdings
 
on
 
29
 
September
 
2021,
 
Eurobank
 
Holdings
 
has
 
adopted
 
and
implements
 
the
 
Hellenic
 
Corporate
 
Governance
 
Code
 
(Code).
 
The
 
Code
 
has
 
been
 
posted
 
on
 
Eurobank
 
Holdings’
 
website
(www.eurobankholdings.gr).
The Corporate
 
Governance Statement
 
for the year
 
2024, attached herewith,
 
is an integral part of the Directors’
 
Report, and
outlines how
 
the
 
principles stipulated
 
by the
 
Code were
 
applied, during
 
2024, to
 
Eurobank
 
Holdings
 
and to
 
Eurobank
 
S.A.
(100% subsidiary of Eurobank Holdings).
Sustainability Statement
Under the Directive
 
(EU) 2022/2464 and the Delegated Directive
 
(EU) 2023/2775 as in force,
 
which were transposed
 
into the
Greek legislation pursuant
 
to Law 5164/2024 as in force,
 
the Sustainability Statement
 
for the
 
year 2024, attached
 
herewith,
is an integral part
 
of the Directors’
 
Report and provides the
 
necessary information
 
to understand the
 
impact of the Group’s
activities on sustainability, as well as the
 
impact of sustainability on the progress,
 
performance and position
 
of the Group.
Georgios Zanias
 
Fokion
 
Karavias
Chairman
 
Chief Executive Officer
7 March 2025
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
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APPENDIX
Definition of Alternative Performance
 
Measures (APMs) in accordance with European
 
Securities and Markets Authority
(ESMA) guidelines, which are included in the
 
Report of Directors/Financial Statements:
a)
Loans to Deposits ratio:
 
Loans and advances
 
to customers at
 
amortised cost divided by
 
due to customers
 
at the
end of the reported period,
 
b)
Pre-Provision
 
Income
 
(PPI):
 
Profit
 
from
 
operations
 
before
 
impairments,
 
provisions
 
and
 
restructuring
 
costs
 
as
disclosed in the financial statements
 
for the
 
reported period,
c)
Core
 
income:
 
The
 
total
 
of
 
net
 
interest
 
income,
 
net
 
banking
 
fee
 
and
 
commission
 
income
 
and
 
income
 
from
 
non
banking services for
 
the reported period,
d)
Core Pre-provision
 
Income (Core PPI):
 
The core
 
income minus the operating
 
expenses of the reported
 
period,
e)
Net Interest Margin (NIM):
 
The net interest income of the
 
reported period, annualised and divided by the average
balance of
 
continued operations’
 
total assets
 
(the
 
arithmetic average
 
of total
 
assets, excluding
 
those related
 
to
discontinued operations’,
 
at the
 
end of the
 
reported period,
 
at the
 
end of interim
 
quarters and
 
at the
 
end of the
previous period),
f)
Fees and commissions:
 
The total of net banking fee
 
and commission income and
 
income from non banking services
of the reported period,
g)
Fees and commissions over assets ratio:
The Fees and commissions of the reported period, annualised
 
and divided
by
 
the
 
average
 
balance
 
of continued
 
operations’
 
total
 
assets (the
 
arithmetic
 
average
 
of total
 
assets, excluding
those related to discontinued operations’,
 
at the end of the
 
reported period, at the
 
end of interim quarters and at
the end of the
 
previous period),
 
h)
Income
 
from
 
trading
 
and
 
other
 
activities
:
 
The
 
total
 
of
 
net
 
trading
 
income,
 
gains
 
less
 
losses
 
from
 
investment
securities and other
 
income/ (expenses) of the
 
reported period,
i)
Cost to Income ratio:
 
Total
 
operating expenses
 
divided by total operating
 
income,
j)
Adjusted
 
net
 
profit:
Net
 
profit/loss
 
attributable
 
to
 
shareholders
 
excluding
 
restructuring
 
costs,
 
goodwill
impairment/ gain on acquisition, gains/losses related
 
to the transformation
 
and NPE reduction plans, contribution
to Greek State’s infrastructure
 
projects,
 
net loss from discontinued operations
 
and income tax adjustments,
k)
Non-performing
 
exposures
 
(NPE):
 
NPE (in
 
compliance
 
with
 
EBA Guidelines)
 
are the
 
Group’s
 
material
 
exposures
which are more than
 
90 days past-due or for
 
which the debtor is assessed
 
as unlikely to pay its credit
 
obligations
in full without
 
realization of
 
collateral,
 
regardless of
 
the existence
 
of any past due
 
amount or the
 
number of days
past due. The
 
NPE, as reported herein,
 
refer to
 
the gross
 
loans at amortised cost
 
except for
 
those that
 
have been
classified as held for
 
sale,
l)
NPE ratio:
 
NPE divided
 
by gross
 
loans and
 
advances to
 
customers
 
at amortised
 
cost at
 
the
 
end of
 
the reported
period,
m)
NPE formation:
 
Net increase/decrease of NPE in the
 
reported period excluding the
 
impact of write offs, sales and
other movements,
n)
NPE Coverage
 
ratio:
 
Impairment allowance
 
for loans
 
and advances
 
to customers
 
and impairment
 
allowance for
credit related commitments
 
(off balance sheet
 
items), divided by NPE at the end
 
of the reported period,
o)
Provisions
 
(charge) to
 
average
 
net loans
 
ratio
 
(Cost of Risk):
 
Impairment losses
 
relating to
 
loans and advances
charged
 
in
 
the
 
reported
 
period,
 
excluding
 
the
 
amount
 
associated
 
with
 
loans
 
and
 
advances
 
to
 
customers
 
at
amortized cost classified
 
as held for
 
sale,
 
annualised and divided
 
by the
 
average
 
balance of loans
 
and advances
to customers at amortised cost (the
 
arithmetic average
 
of loans and advances to customers at amortised cost, at
the end of the
 
reported period, at the
 
end of interim quarters and at the
 
end of the previous
 
period),
p)
Return on
 
tangible
 
book
 
value
 
(RoTBV):
Adjusted
 
net
 
profit
 
divided
 
by
 
average
 
tangible
 
book
 
value.
 
Tangible
book value is the total equity excluding preference
 
shares, preferred
 
securities and non controlling interests
 
minus
intangible assets,
Definition of capital and other
 
selected ratios
 
in accordance with the
 
regulatory framework,
 
which are included in the
Report of Directors/Financial Statements:
a)
Total
 
Capital
 
Adequacy
 
ratio:
 
Total
 
regulatory
 
capital
 
as
 
defined
 
by
 
Regulation
 
(EU)
 
No
 
575/2013
 
as
 
in
 
force,
based on the transitional rules
 
for the reported period,
 
divided by total Risk Weighted Assets (RWA).
 
The RWA
 
are
the Group’s
 
assets and off-balance-sheet
 
exposures, weighted according to risk factors
 
based on Regulation (EU)
No 575/2013, taking into account credit,
 
market and operational
 
risk,
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS
17
|
Page
 
€ = Euro
 
m = million
 
bn = billion
b)
Common Equity Tier 1 (CET1):
 
Common Equity Tier I regulatory
 
capital as defined by Regulation
 
(EU) No 575/2013
as in force,
 
based on the transitional
 
rules for the
 
reported period, divided by
 
total RWA,
c)
Fully loaded Common
 
Equity Tier
 
I (CET1):
 
Common Equity
 
Tier
 
I regulatory
 
capital as
 
defined by
 
Regulation No
575/2013 as in force,
 
without the application
 
of the relevant transitional
 
rules, divided by total RWA,
d)
Liquidity Coverage Ratio (LCR):
 
The total amount of high quality liquid assets divided by the net liquidity
 
outflows
for a 30-day stress period,
e)
Minimum Requirements for Eligible Own Funds and Eligible Liabilities (MREL) ratio:
The sum of i) total regulatory
capital (at
 
Eurobank
 
S.A. consolidated
 
level) as
 
defined by
 
Regulation (EU)
 
No 575/2013 as in
 
force,
 
based on the
transitional rules
 
for the
 
reported period
 
ii) part of any Tier
 
2 instruments to the
 
extent that it
 
does not qualify as
Tier 2 capital (amortized part counts towards MREL), and iii)
 
liabilities issued by Eurobank S.A. that meet the MREL-
eligibility criteria set out in Regulation (EU) No 575/2013
 
as in force,
 
divided by RWA.
The
 
following
 
table
 
presents
 
the
 
components
 
of
 
the
 
calculation
 
of
 
the
 
above
 
APMs,
 
which
 
are
 
derived
 
from
 
the
Company’s
 
consolidated
 
financial
 
statements
 
for
 
the
 
year
 
ended
 
31
 
December
 
2024
 
and
 
for
 
the
 
year
 
ended
 
31
December 2023:
Components of Alternative Performance
 
Measures
€ million
FY 2024
FY 2023
Net Interest Income
¹
2,507
2,174
Fees and commissions
666
544
Total Operating
 
income
 
3,341
2,914
Total Operating
 
income, excluding the gain on investment
 
in Hellenic Bank
²
3,242
2,803
Total Operating
 
expenses excluding the contribution to Greek
 
State’s
infrastructure projects
³
(1,071)
(902)
Pre-provision
 
income (PPI)
2,242
1,999
Pre-provision
 
income (PPI), excluding the gain on investment
 
in Hellenic Bank and
the contribution to Greek State’s
 
infrastructure projects
2,170
1,902
Core Pre-provision
 
income (Core PPI) excluding the
 
contribution to Greek State’s
infrastructure projects
2,101
1,816
Net profit/(loss) from continued operations
1,511
1,281
Restructuring costs, after tax
(121)
(29)
Gain on investment in Hellenic Bank (as an associate)
99.5
111
Contribution to Greek State’s infrastructure
 
projects, before
 
tax
 
(27)
(14)
Contribution to Greek State’s infrastructure
 
projects, after tax
 
(19)
(10)
Impairment loss/reversal
 
on projects "Solar" and "Leon", after tax
11
(48)
Impairment loss/reversal
 
on projects "Solar" and "Leon", before
 
tax
16
(67)
Adjusted net profit
1,484
1,256
Net profit attributable to shareholders
1,448
1,140
Net loss from discontinued operations
(7)
(141)
Impairment losses relating to loans and advances
(303)
(412)
NPE formation
⁽⁴⁾
222
138
Non performing exposures (NPE)
1,719
1,512
NPE excluding Hellenic Bank NPEs covered
 
by Asset Protection Scheme
 
(APS)
1,530
1,512
Due to customers
78,593
57,442
Gross Loans and advances to customers
 
at amortized cost
52,245
42,773
Impairment allowance for
 
loans and advances to customers
(1,309)
(1,258)
Impairment allowance for
 
credit related commitments
(63)
(48)
Impairment allowance for
 
NPE of Hellenic Bank covered by APS
(19)
 
-
Due to customers (Greek operations)
43,287
39,950
Gross Loans and advances to customers
 
at amortized cost (Greek operations)
34,682
32,308
Impairment allowance for
 
loans and advances to customers (Greek
 
operations)
(998)
(1,003)
Average
 
balance of continued operations’
 
total assets
 
⁽⁵⁾
91,721
79,106
Average
 
balance of loans and advances to customers
 
at amortized cost
 
⁽⁶⁾
46,237
40,645
Average
 
balance of tangible book value
⁽⁷⁾
8,024
6,957
(1)
4Q2024 NIM: Net
 
interest income
 
of the
 
fourth
 
quarter 2024 (€677m),
 
annualised, divided by
 
the average
 
balance of
 
continued
operations’
 
total
 
assets
 
(€100,372m).
 
The
 
average
 
balance
 
of
 
continued
 
operations’
 
total
 
assets,
 
has
 
been
 
calculated
 
as
 
the
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS
18
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Page
 
€ = Euro
 
m = million
 
bn = billion
arithmetic
 
average
 
of their
 
balances
 
at
 
the
 
end of
 
the
 
reporting period
 
(31 December
 
2024: €101,150
 
m) and
 
at
 
the
 
end of
 
third
quarter (30 September 2024: €99,593m).
(2)
International
 
Operations:
 
Operating
 
income:
 
€1,260m
 
(2023:
 
€778m).
 
Greek
 
operations:
 
Operating
 
income:
 
€1,982
 
m
 
(2023:
€2,025m).
(3)
 
International
 
Operations:
 
Operating
 
expenses:
 
€408m
 
(2023:
 
€258m).
 
Greek
 
operations:
 
Operating
 
expenses:
 
€663m
 
(2023:
€644m).
(4)
NPEs
 
formation
 
has
 
been
 
calculated
 
as
 
the
 
increase
 
of
 
NPE
 
in
 
2024
 
€18m,
 
after
 
deducting
 
the
 
impact
 
of
 
write-offs
 
€95m,
classifications as held for
 
sale / sales €242m and other movements
 
(€133m) including the NPE stock from Hellenic Bank acquisition.
(5)
The average balance of continued operations’
 
total assets, has been calculated as the arithmetic average of their balances at the
end of the reporting period (31 December 2024: €101,150
 
m), at the end of interim quarters (30 September 2024: €99,593m, 30 June
2024: €98,725m and 31 March 2024:
 
€79,356m), and at the end of the previous period (31 December 2023: €79,781m).
 
The respective
figures for
 
31 December
 
2023: €79,781
 
m, 30
 
September 2023:
 
€78,023m 30
 
June 2023:
 
€79,137
 
m
 
31 March
 
2023: €79,538
 
and 31
December 2022: €79,052m.
(6)
The
 
average
 
balance of
 
loans and
 
advances to
 
customers measured
 
at amortized
 
cost ,
 
has been
 
calculated as
 
the
 
arithmetic
average
 
of their
 
balances
 
at the
 
end of
 
the
 
reporting
 
period
 
(31 December
 
2024: €50,936m),
 
at the
 
end of
 
interim quarters
 
(30
September 2024:
 
€49,095
 
m, 30
 
June 2024:
 
€48,093m
 
and 31
 
March 2024:
 
€41,546m), and
 
at
 
the
 
end of
 
the
 
previous
 
period (31
December 2023
 
€41,515m). The
 
respective figures
 
for
 
31 December
 
2023: €41,515m,
 
30 September
 
2023: €40,734m
 
30 June
 
2023:
€40,604m
 
31 March 2023: €40,137 and 31 December 2022: €40,237m.
(7)
 
The
 
average
 
balance
 
of
 
tangible
 
book
 
value,
 
has
 
been
 
calculated
 
as
 
the
 
arithmetic
 
average
 
of
 
the
 
total
 
equity
 
minus
 
the
intangible assets and non
 
controlling interests
 
at the
 
end of the
 
reporting period (31
 
December 2024: €8,484m)
 
and at the
 
end of
the previous
 
period (31
 
December 2023:
 
€7,565m).
The
 
respective figures
 
for 31
 
December 2023:
 
€7,565m
 
and 31 December
 
2022:
€6,340m.
Note: For the
 
purpose of calculating the 2024 average balances used in the ratios
 
a) NIM, b) Fees and commissions over assets and
c)
 
Cost
 
of
 
risk,
 
the
 
balances
 
as
 
of
 
30
 
June
 
2024
 
for
 
continued
 
operations’
 
total
 
assets
 
and
 
loans
 
and
 
advances
 
to
 
customers
measured at amortized cost have been adjusted to include the
 
impact of respective balances for
 
Hellenic Bank group.
 
Source of financial Information
 
The
 
Directors’
 
Report
 
includes
 
financial
 
data
 
and
 
measures
 
as
 
derived
 
from
 
the
 
Company’s
 
consolidated
 
financial
statements for the year ended 31 December 2024
 
and for the year ended
 
31 December 2023, which have
 
been prepared
in accordance
 
with International
 
Financial Reporting
 
Standards (IFRS).
 
In addition,
 
it includes information
 
as derived
from
 
internal
 
information
 
systems,
 
consistent
 
with
 
the
 
Group’s
 
accounting
 
policies,
 
such
 
as
 
the
 
selected
 
financial
information
 
for
 
the
 
Group’s
 
two
 
main
 
reportable
 
segments
 
a)
 
Greek
 
Operations,
 
which
 
incorporate
 
the
 
business
activities originated
 
from the
 
Company,
 
the Bank
 
and the
 
Greek subsidiaries
 
and b) International
 
Operations,
 
which
incorporate
 
the
 
business activities
 
originated from
 
the
 
banks and
 
the
 
other
 
local subsidiaries
 
operating
 
in Bulgaria,
Cyprus and Luxembourg (as described at the
 
relevant section on page 4).
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
1
|
Page
 
CORPORATE GOVERNANCE
 
STATEMENT
 
2024
Index to the Corporate Governance
 
Statement
1.
Introduction .................................................................................................................................................................................
 
3
2.
Adoption of the Hellenic Corporate
 
Governance Code ....................................................................................................
 
3
3.
Corporate Governance
 
and Key Policies ..............................................................................................................................
 
3
3.1
 
Internal Governance
 
Control Manual ................................
 
................................
 
................................
 
................................
 
............... 3
3.2
 
Board Nomination Policy ................................
 
................................
 
................................
 
................................
 
................................
 
........
 
3
3.3
 
CEO Succession Planning................................
 
................................
 
................................
 
................................
 
................................
 
........
 
5
3.4
 
Board Evaluation Policy ................................
 
................................
 
................................
 
................................
 
................................
 
...........
 
5
3.5
 
Board of Directors Diversity
 
Policy
 
................................
 
................................
 
................................
 
................................
 
..................... 6
3.6
 
Remuneration
 
Policy................................
 
................................
 
................................
 
................................
 
................................
 
.................. 6
3.7
 
Board and Board Committees’ Attendance
 
Policy
 
................................
 
................................
 
................................
 
.................... 7
3.8
 
Directors’ Induction and Continuous Professional
 
Development Process
 
................................
 
................................
 
...... 7
3.9
 
Group Governance
 
Policy
 
................................
 
................................
 
................................
 
................................
 
................................
 
....... 7
3.10
 
Conflicts of interest Policy ................................
 
................................
 
................................
 
................................
 
................................
 
......
 
8
3.11
 
Other Key
 
Policies
 
................................
 
................................
 
................................
 
................................
 
................................
 
....................... 8
4.
Shareholders’ General
 
Meeting ..............................................................................................................................................8
4.1
 
Information about the
 
Eurobank Holdings General
 
Meetings
 
................................
 
................................
 
............................. 9
4.1.1
 
Requirements for
 
calling and convening the General
 
Meetings
 
................................
 
................................
 
...........
 
9
4.1.2
 
Participation and proxies ................................
 
................................
 
................................
 
................................
 
......................... 9
4.1.3
 
Annual General Meeting (AGM)
 
of the shareholders ................................
 
................................
 
................................
 
.
 
9
4.2
 
Information about the
 
Eurobank General
 
Meetings
 
................................
 
................................
 
................................
 
............... 10
4.2.1
 
Annual General Meeting (AGM)
 
of the shareholders ................................
 
................................
 
............................... 10
5.
Board of Directors ....................................................................................................................................................................
 
11
5.1
 
General
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
............ 11
5.2
 
Composition of the Board ................................
 
................................
 
................................
 
................................
 
................................
 
..... 11
5.3
 
CVs of Board Board
 
members and Secretary ................................
 
................................
 
................................
 
............................ 12
5.4
 
Re-election, Cessation, and Independence of Board
 
Members ................................
 
................................
 
......................... 17
5.5
 
Division of responsibilities ................................
 
................................
 
................................
 
................................
 
................................
 
.... 18
5.5.1
 
Chairperson................................
 
................................
 
................................
 
................................
 
................................
 
.................... 18
5.5.2
 
CEO ................................................................
 
................................
 
................................
 
................................
 
................................
 
.... 18
5.5.3
 
Executive Directors ................................
 
................................
 
................................
 
................................
 
................................
 
..... 18
5.5.4
 
Non-Executive Directors ................................
 
................................
 
................................
 
................................
 
.......................... 19
5.6
 
Operation of the
 
Board ................................
 
................................
 
................................
 
................................
 
................................
 
......... 19
5.6.1
 
Board Meetings................................
 
................................
 
................................
 
................................
 
................................
 
............ 19
5.6.2
 
Dissemination of Information ................................
 
................................
 
................................
 
................................
 
............... 19
5.6.3
 
Quorum in the Board Meetings ................................
 
................................
 
................................
 
................................
 
........... 19
5.6.4
 
Board Decisions and Minutes ................................
 
................................
 
................................
 
................................
 
............... 19
5.6.5
 
Company Secretary ................................
 
................................
 
................................
 
................................
 
................................
 
..
 
20
5.7
 
Attendance of Board members
 
in the Board and Board Committees ................................
 
................................
 
......... 20
5.8
 
Directorships of Board members ................................
 
................................
 
................................
 
................................
 
...................... 21
5.8.1
 
HoldCo and Eurobank Board
 
Members’ Directorships (including Directorships within
 
Eurobank
 
Group) as at 31.12.2024 ................................................................
 
................................
 
................................
 
........................... 22
5.9
 
Board Role and Responsibilities
 
................................
 
................................
 
................................
 
................................
 
....................... 23
5.10
 
Main issues the Board dealt with during 2024 ................................
 
................................
 
................................
 
......................... 24
5.10.1
 
Eurobank Holdings
 
................................
 
................................
 
................................
 
................................
 
................................
 
..... 24
5.10.2
 
Bank
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
..
 
25
5.10.3
 
Board Strategy Day ................................
 
................................
 
................................
 
................................
 
................................
 
..
 
28
5.11
 
Board and Board Committees overall
 
effectiveness
 
assessment ................................
 
................................
 
................... 28
5.11.1
 
Board and Board Committees Evaluation ................................
 
................................
 
................................
 
.................... 28
5.11.2
 
Assessment of the knowledge,
 
skills and experience (KSE) of the Board
 
collectively as well as
 
 
the KSE and contribution of individual Board members. ................................
 
................................
 
....................... 29
5.11.3
 
Individual Evaluations
 
................................
 
................................
 
................................
 
................................
 
.............................. 29
5.11.4
 
Collective Suitability Assessment................................
 
................................
 
................................
 
................................
 
....... 30
5.12
 
Directors’ Induction and Continuous Professional
 
Development ................................
 
................................
 
.................... 30
6.
Board Committees ..................................................................................................................................................................
 
30
6.1
 
Governance and Operations
 
of Board Committees
 
................................
 
................................
 
................................
 
............... 31
6.1.1
 
Board Committees’ members ................................
 
................................
 
................................
 
................................
 
............... 31
6.1.2
 
Board Committees’ Terms
 
of Reference (ToR) ................................
 
................................
 
................................
 
............. 31
6.1.3
 
Board Committees’ meetings ................................
 
................................
 
................................
 
................................
 
............... 31
6.1.4
 
Quorum in the Board Committees’
 
Meetings
 
................................
 
................................
 
................................
 
............... 31
6.1.5
 
Board Committees’ Decisions
 
................................
 
................................
 
................................
 
................................
 
............... 31
6.1.6
 
Board Committees’ Secretary and Minutes ................................
 
................................
 
................................
 
.................. 31
6.1.7
 
Board Committees’ Performance
 
Evaluation ................................
 
................................
 
................................
 
............... 31
6.2
 
Audit Committee
 
................................
 
................................
 
................................
 
................................
 
................................
 
....................... 31
6.2.1
 
AC Membership/Composition
 
................................
 
................................
 
................................
 
................................
 
.............. 32
6.2.2
 
AC Meetings................................
 
................................
 
................................
 
................................
 
................................
 
.................. 32
6.2.3
 
Attendance to the AC Meetings ................................
 
................................
 
................................
 
................................
 
......... 32
6.2.4
 
AC’s Performance
 
Evaluation
 
................................
 
................................
 
................................
 
................................
 
............... 33
6.2.5
 
ACs’ Activity in 2024 ................................................................
 
................................
 
................................
 
................................
 
.
 
33
6.3
 
Board Risk Committee ................................
 
................................
 
................................
 
................................
 
................................
 
.......... 36
6.3.1
 
BRC Membership/Composition
 
................................
 
................................
 
................................
 
................................
 
........... 36
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
2
|
Page
 
6.3.2
 
BRC Meetings
 
................................
 
................................
 
................................
 
................................
 
................................
 
................
 
37
6.3.3
 
Attendance to the BRC Meetings ................................
 
................................
 
................................
 
................................
 
.......
 
37
6.3.4
 
BRCs’ Performance
 
Evaluation
 
................................
 
................................
 
................................
 
................................
 
.............
 
37
6.3.5
 
BRCs’ Activity in 2024
 
................................
 
................................
 
................................
 
................................
 
.............................. 38
6.4
 
Remuneration
 
Committee
 
................................
 
................................
 
................................
 
................................
 
................................
 
.. 39
6.4.1
 
RemCos Membership/Composition ................................
 
................................
 
................................
 
................................
 
.. 39
6.4.2
 
RemCos meetings
 
................................
 
................................
 
................................
 
................................
 
................................
 
...... 40
6.4.3
 
Attendance to the RemCo meetings ................................
 
................................
 
................................
 
............................... 40
6.4.4
 
RemCo’s Performance
 
Evaluation ................................
 
................................
 
................................
 
................................
 
..... 40
6.4.5
 
RemCos' Activity in 2024................................
 
................................
 
................................
 
................................
 
........................ 40
6.5
 
Nomination and Corporate Governance
 
Committee
 
................................
 
................................
 
................................
 
........... 42
6.5.1
 
NomCo Membership/Composition ................................
 
................................
 
................................
 
................................
 
... 43
6.5.2
 
NomCo Meetings ................................
 
................................
 
................................
 
................................
 
................................
 
....... 43
6.5.3
 
Attendance to the NomCo meetings ................................................................
 
................................
 
............................... 43
6.5.4
 
NomCos’ Performance
 
Evaluation ................................
 
................................
 
................................
 
................................
 
.... 43
6.5.5
 
NomCos’ Activity in 2024
 
................................
 
................................
 
................................
 
................................
 
....................... 44
6.5.6
 
Board of Directors Diversity
 
................................
 
................................
 
................................
 
................................
 
.................. 45
6.5.7
 
Senior Management Diversity ................................
 
................................
 
................................
 
................................
 
............. 45
6.6
 
Board Digital & Transformation
 
Committee
 
................................
 
................................
 
................................
 
.............................. 46
6.6.1
 
BDTC Membership / Chairmanship ................................
 
................................
 
................................
 
................................
 
...
 
46
6.6.2
 
BDTC Meetings
 
................................
 
................................
 
................................
 
................................
 
................................
 
............ 46
6.6.3
 
BDTC Attendance
 
Rate
 
................................
 
................................
 
................................
 
................................
 
........................... 46
6.6.4
 
BDTC Performance
 
Evaluation
 
................................
 
................................
 
................................
 
................................
 
.............
 
47
6.6.5
 
BDTC’s Activity in 2024 ................................
 
................................
 
................................
 
................................
 
............................ 47
7.
Management Committees
 
.....................................................................................................................................................
 
47
7.1
 
Management Committees’ Policy
 
................................
 
................................
 
................................
 
................................
 
..................... 47
7.2
 
Executive Board (ExBo)................................
 
................................
 
................................
 
................................
 
................................
 
.......... 48
7.2.1
 
CVs of ExBo members (other
 
than BoD members) ................................
 
................................
 
................................
 
...
 
48
7.3
 
Strategic Planning Committee................................
 
................................
 
................................
 
................................
 
........................... 51
7.4
 
Management Risk Committee
 
................................
 
................................
 
................................
 
................................
 
........................... 52
7.5
 
Group Asset and Liability Committee (G-ALCO) ................................
 
................................
 
................................
 
..................... 52
7.6
 
Central Credit Committees ................................
 
................................
 
................................
 
................................
 
................................
 
.
 
55
7.6.1
 
Central Credit Committee I
 
................................
 
................................
 
................................
 
................................
 
................... 55
7.6.2
 
Central Credit Committee II ................................
 
................................
 
................................
 
................................
 
................. 55
7.7
 
Troubled Assets Committee................................
 
................................
 
................................
 
................................
 
................................ 56
7.8
 
Products & Services Committee
 
(PSC)
 
................................
 
................................
 
................................
 
................................
 
.......... 56
7.9
 
Sustainability Management Committee (SMC)
 
................................
 
................................
 
................................
 
........................ 56
7.10
 
Ethics Co ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
........
 
57
8.
Key Control
 
Functions ............................................................................................................................................................
 
57
8.1
 
Internal Audit................................
 
................................
 
................................
 
................................
 
................................
 
............................... 57
8.1.1
 
Eurobank Holdings
 
................................
 
................................
 
................................
 
................................
 
................................
 
......
 
57
8.1.2
 
Eurobank
 
................................
 
................................
 
................................
 
................................
 
................................
 
......................... 58
8.2
 
Risk Management
 
................................
 
................................
 
................................
 
................................
 
................................
 
.................... 59
8.2.1
 
Eurobank Holdings
 
................................
 
................................
 
................................
 
................................
 
................................
 
..... 59
8.2.2
 
Eurobank
 
................................
 
................................
 
................................
 
................................
 
................................
 
......................... 59
8.3
 
Compliance ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
.
 
60
8.3.1
 
Eurobank Holdings
 
................................
 
................................
 
................................
 
................................
 
................................
 
..... 60
8.3.2
 
Eurobank
 
................................
 
................................
 
................................
 
................................
 
................................
 
.......................... 61
8.4
 
Personal Data Protection
 
................................
 
................................
 
................................
 
................................
 
................................
 
....
 
62
8.4.1
 
Eurobank Holdings
 
................................
 
................................
 
................................
 
................................
 
................................
 
..... 62
8.4.2
 
Eurobank
 
................................
 
................................
 
................................
 
................................
 
................................
 
......................... 62
9.
System of Internal Controls ..................................................................................................................................................
 
62
9.1
Principles of Internal Controls
 
................................
 
................................
 
................................
 
................................
 
............................ 62
9.2
 
Characteristics of the
 
System of Internal Controls (SIC)
 
................................
 
................................
 
................................
 
...... 63
9.3
 
Evaluation of the System of Internal
 
Controls
 
................................
 
................................
 
................................
 
........................... 64
9.4
 
Independent Evaluation of the HoldCo/Bank
 
System of Internal Controls ................................
 
................................ 64
9.5
 
Corporate Governance
 
System Assessment in accordance with article 4 par.
 
1 of Law 4706/2020
 
............. 64
10.
Sustainability ...........................................................................................................................................................................
 
64
10.1
 
Sustainability Approach ................................
 
................................
 
................................
 
................................
 
................................
 
....... 64
10.2
 
Sustainability Policies & Frameworks ................................
 
................................
 
................................
 
................................
 
............ 65
10.3
 
Stakeholders engagement and
 
double materiality assessment ................................
 
................................
 
..................... 66
10.4
 
Reporting and Transparency ................................
 
................................
 
................................
 
................................
 
............................. 66
11.
Other information
 
required by Directive
 
2004/25/EU
 
....................................................................................................
 
67
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
3
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1.
Introduction
In accordance with Article 152(1)
 
and Article 153(3)
 
of Law 4548/2018, Law
 
4706/2020, and the Hellenic Corporate Governance
Code,
 
the
 
Report
 
of
 
the
 
Board
 
of
 
Directors
 
of
 
Eurobank
 
Ergasias
 
Services
 
and
 
Holdings
 
S.A.
 
(the
 
"Company",
 
"Eurobank
Holdings", "Holdings", or "HoldCo") includes the
 
Corporate Governance
 
Statement, which addresses the
 
following key
 
areas:
Adoption of the Hellenic Corporate
 
Governance Code
Corporate Governance
 
and Key Policies
Shareholders’ General
 
Meeting
Board of Directors
Board of Directors’ Committees
Management Committees
Key Control Functions
System of Internal Controls
Sustainability
 
Additional Disclosures Required by
 
Directive 2004/25/EU
2.
Adoption of the Hellenic Corporate
 
Governance Code
In
 
compliance
 
with
 
Article
 
17
 
of
 
Law
 
4706/2020,
 
which
 
requires
 
listed
 
companies
 
to
 
adopt
 
and
 
implement
 
a
 
corporate
governance
 
code
 
issued
 
by
 
a
 
recognized
 
and
 
reputable
 
body,
 
Eurobank
 
Holdings
 
has
 
adopted
 
and
 
applies
 
the
 
Hellenic
Corporate Governance
 
Code (the "Code").
The Code is available on Eurobank
 
Holdings’ website (https://www.eurobankholdings.gr).
Given that
 
the Eurobank
 
Holdings Group
 
(the "Group")
 
primarily comprises Eurobank
 
S.A. ("Eurobank"
 
or the
 
"Bank") and its
subsidiaries (the
 
"Eurobank
 
Group"), this
 
Corporate
 
Governance
 
Statement outlines
 
how the
 
principles set
 
out in
 
the Code
were implemented
 
across both Eurobank
 
Holdings and Eurobank throughout
 
2024.
3.
Corporate Governance
 
and Key Policies
The
 
corporate
 
governance
 
framework
 
of
 
the
 
Group,
 
aligned
 
with
 
the
 
applicable
 
legal
 
and
 
regulatory
 
requirements
 
and
international
 
best
 
practices,
 
ensures
 
that
 
HoldCo,
 
the
 
Bank,
 
and
 
their
 
subsidiaries
 
operate
 
with
 
credibility,
 
responsibility,
fairness, and transparency,
 
safeguarding the interests
 
of their shareholders
 
and all other stakeholders.
In this context,
 
HoldCo and the
 
Bank have established
 
a comprehensive
 
set of policies
 
and procedures,
 
which are regularly
reviewed
 
and approved
 
by the
 
respective Board
 
of Directors (BoD) and/or
 
Board Committees, as required.
 
The Key
 
Policies
governing HoldCo and the
 
Bank are outlined below.
3.1
Internal Governance Control
 
Manual
The Internal Governance Control Manual (IGCM) of Eurobank Holdings and Eurobank has been developed in
 
accordance with
Law 4706/2020 to ensure
 
compliance with regulatory
 
requirements
 
and internal governance
 
policies. The
 
IGCM defines the
overarching
 
framework
 
by
 
which
 
each
 
Company
 
is
 
directed
 
and
 
controlled,
 
serving
 
as
 
a
 
formal
 
record
 
of
 
the
 
high-level
internal control principles in operation.
The
 
policies and
 
controls
 
outlined in
 
both
 
the HoldCo
 
IGCM and
 
Bank IGCM
 
are designed
 
to minimize
 
the risk
 
of errors
 
or
financial losses, protect the interests of
 
shareholders and depositors, and
 
ensure full compliance with
 
regulatory requirements
at all times.
The HoldCo IGCM and Bank
 
IGCM provide a high-level overview of control policies, while
 
more detailed operating procedures
are
 
documented
 
in
 
individual
 
procedures
 
and
 
manuals
 
maintained
 
by
 
their
 
respective
 
units.
 
Subsidiaries
 
are
 
required
 
to
establish their
 
own IGCMs
 
and/or procedures
 
manuals and
 
to adopt
 
the
 
Group’s
 
policies where
 
applicable. The
 
principles
outlined
 
in the
 
IGCM
 
apply across
 
all units
 
and subsidiaries,
 
except
 
where
 
local
 
circumstances
 
or regulations
 
necessitate
deviations.
Each IGCM
 
includes a high-level
 
organizational chart
 
and a brief
 
description of
 
the key
 
responsibilities of
 
the main
 
control
functions within HoldCo and
 
Eurobank. These
 
manuals are supplemented by
 
the procedures
 
manuals of individual units and
subsidiaries, which provide a written description of the
 
uppermost levels of the
 
Group’s System of Internal Controls.
3.2
Board Nomination Policy
The
 
HoldCo/Banks’
 
Board
 
Nomination
 
Policy
 
sets
 
out
 
the
 
guidelines
 
and
 
formal
 
process
 
for
 
identifying,
 
selecting,
 
and
nominating candidates for the
 
Board. It ensures that appointments
 
are made:
(a) in compliance with legal and regulatory requirements,
(b) with due regard to the
 
expectations of major shareholders, and
(c) based on individual merit and ability,
 
following best practices.
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
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The primary objectives
 
of this Policy are
 
to:
Define
 
the
 
general
 
principles
 
that
 
guide
 
the
 
Nomination
 
and
 
Corporate
 
Governance
 
Committee
 
(NomCo)
 
in
 
all
stages of the nomination process,
Establish specific criteria and requirements for
 
Board nominees,
Ensure a transparent, efficient,
 
and fit-for-purpose nomination process,
 
and
Maintain a Board structure—including succession planning—that meets high ethical standards, achieves
 
an optimal
balance of knowledge, skills, and experience,
 
and aligns with current regulatory
 
requirements.
Nomination Criteria
The Board, supported
 
by NomCo, shall nominate candidates who meet the
 
following criteria:
1. Reputation, Honesty,
 
Integrity, and Trust
Reputation: Candidates
 
must have a
 
strong reputation
 
and high social esteem,
 
demonstrating good
 
repute in line
with the applicable regulatory
 
framework’s
 
standards for honesty and integrity.
Honesty,
 
Integrity,
 
and Trust:
 
Candidates should
 
exemplify the
 
highest standards
 
of ethics,
 
honesty,
 
fairness,
 
and
personal discipline, as evidenced by their
 
professional track
 
record, personal history,
 
and public commitments.
2. Knowledge, Skills, Experience (KSE), and General
 
Suitability
Understanding of
 
the
 
HoldCo/Bank: Candidates
 
must possess
 
sufficient knowledge,
 
skills, and
 
experience
 
(KSE) to
develop a thorough
 
and up-to-date understanding of the
 
business, governance
 
structures, regulatory environment,
markets, stakeholders,
 
and risks associated with the HoldCo
 
and its subsidiaries.
Seniority: A candidate must have several
 
years of experience in a recognized leadership position within their field of
expertise.
Independent
 
Mindset
 
and
 
Ability
 
to
 
Challenge:
 
Candidates
 
should
 
demonstrate
 
the
 
ability
 
to
 
form
 
and
 
express
independent judgments on all
 
matters before the Board, along with the candor to
 
challenge management and other
Board members when
 
necessary.
Collegiality,
 
Teamwork,
 
and
 
Leadership:
 
Candidates
 
should
 
contribute
 
constructively
 
and
 
productively
 
to
 
Board
discussions and decision-making, with the capability to lead discussions as a Committee Chair, Vice-Chair, or Board
Chair.
Additional
 
Criteria
 
for
 
Executive
 
Directors:
 
Candidates
 
for
 
Executive
 
Director
 
positions
 
must
 
have
 
demonstrated
leadership capabilities
 
through current
 
or previous executive
 
roles, along
 
with the
 
necessary expertise to
 
guide the
HoldCo/Bank in achieving its strategic
 
objectives. They
 
must also be willing to enter
 
into full-time employment
 
with
the HoldCo/Bank.
3. Conflicts of Interest and Independence of Mind
NomCo shall
 
assess candidates'
 
personal, professional,
 
financial, and
 
political
 
affiliations
 
to ensure
 
that they
 
do not
 
have
actual, potential,
 
or perceived
 
conflicts of interest
 
that cannot
 
be prevented,
 
adequately mitigated, or
 
managed under the
HoldCo/Bank’s policies. Candidates
 
must be able to represent
 
the interests
 
of all shareholders,
 
fulfill their responsibilities
 
as
Directors, and make sound, objective,
 
and independent decisions.
NomCo shall also examine candidates’
 
direct and indirect
 
monetary and non-monetary interests,
 
including their affiliations
with or membership in other
 
organizations.
4. Time Commitment
NomCo
 
shall
 
ensure
 
that
 
all
 
nominees
 
can
 
dedicate
 
the
 
time
 
required
 
to
 
effectively
 
discharge
 
their
 
responsibilities
 
as
Directors. This includes their
 
ability to attend and actively participate in Board
 
and Committee meetings on a regular basis.
5. Collective Suitability
The Board,
 
as a whole, must have the
 
ability to understand the
 
institution’s activities, assess
 
the associated risks,
 
and make
informed decisions aligned
 
with the institution’s business
 
model, risk appetite, strategy,
 
and market operations.
The
 
composition
 
of
 
the
 
Board
 
should
 
reflect
 
the
 
necessary
 
knowledge,
 
skills,
 
and
 
experience
 
required
 
to
 
fulfill
 
its
responsibilities. The Board
 
should collectively possess expertise in:
The institution’s
 
core business and its associated risks,
All material activities of the HoldCo/Bank,
Sector-specific
 
and
 
financial
 
competencies,
 
including
 
financial
 
and
 
capital
 
markets,
 
solvency,
 
risk
 
modeling,
 
and
environmental, social, and governance
 
(ESG) risks,
Financial accounting and reporting,
Risk management, compliance (including AML/CFT), and internal
 
audit,
Information and digital technology,
 
including cybersecurity,
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
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Local, regional, and global markets,
 
where applicable,
The legal and regulatory
 
framework,
Strategic planning and managerial experience,
Oversight of (inter)national
 
group structures and risks related
 
to group governance,
Corporate governance,
ESG issues, and
Gender representation, in accordance
 
with the Board Diversity
 
Policy.
Succession Planning
As part of its
 
oversight of the nomination process, NomCo shall ensure the implementation of structured, stepwise succession
planning to maintain
 
continuity and institutional
 
knowledge at the Board level. This is
 
particularly critical in
 
managing sudden
or unexpected absences or departures of Board
 
members.
To this end, NomCo shall:
Monitor
 
Board
 
members’
 
tenures
 
and
 
ensure
 
staggered
 
appointments
 
and
 
retirements
 
whenever
 
feasible.
 
The
reappointment of existing Board members shall be based on their continued adherence to the criteria set out in this
Policy.
Ensure an appropriate distribution of relevant
 
KSEs across the Board,
 
preventing undue reliance
 
on the expertise of
a few Directors.
Assess whether
 
a sufficient
 
number
 
of Board
 
members
 
are capable
 
of assuming
 
leadership roles,
 
including Board
and Committee Chair positions.
Periodically evaluate the availability of suitable candidates to
 
address the Board’s future succession planning needs.
Consider both:
a) the objectives and targets
 
defined in the HoldCo/Bank Board
 
Diversity Policy,
 
and
b) the
 
findings of
 
the
 
HoldCo
 
and Bank
 
Board Evaluations,
 
ensuring necessary
 
changes in
 
composition or
 
skills to
enhance effectiveness
 
and collective suitability.
The
 
CEO
 
Succession
 
Planning
 
Policy,
 
which
 
is
 
supplementary
 
to
 
this
 
Policy,
 
sets
 
out
 
the
 
framework
 
for
 
CEO
 
succession
planning.
3.3
CEO Succession Planning
The
 
HoldCo/Bank’s
 
CEO
 
Succession
 
Planning
 
Policy
 
(the
 
Policy)
 
plays
 
a
 
crucial
 
role
 
in
 
ensuring
 
a
 
seamless
 
leadership
transition. The
 
key elements of the
 
Policy are as follows:
Qualifications
 
for
 
the
 
CEO
 
Position:
 
The
 
Nomination
 
and
 
Corporate
 
Governance
 
Committee
 
(NomCo),
 
in
collaboration
 
with
 
the
 
current
 
CEO,
 
defines
 
the
 
qualifications
 
required
 
for
 
the
 
CEO
 
role.
 
This
 
ensures
 
that
 
the
successor possesses the necessary skills, experience,
 
and leadership attributes to guide the organization effectively.
Viable
 
Pool
 
of
 
Candidates:
 
NomCo
 
ensures
 
that
 
a
 
strong
 
pipeline
 
of
 
candidates
 
meets
 
the
 
CEO
 
position’s
requirements.
 
This includes
 
evaluating internal
 
candidates within
 
the
 
organization
 
while also
 
considering external
candidates when appropriate.
Annual Review: NomCo reviews the qualifications and candidate pool at
 
least annually to
 
ensure that the succession
planning process
 
remains
 
aligned
 
with
 
the
 
organization’s
 
evolving
 
needs,
 
regulatory
 
expectations,
 
and
 
strategic
direction.
Selection
 
Process:
 
NomCo
 
leads the
 
CEO
 
selection
 
process,
 
evaluating
 
candidates
 
based
 
on their
 
qualifications,
leadership capabilities, experience,
 
and alignment with the organization’s
 
culture and strategic objectives.
Tailored
 
Induction
 
Program:
 
Once
 
a
 
new
 
CEO
 
is
 
selected,
 
NomCo
 
approves
 
a
 
customized
 
induction
 
program
 
to
ensure
 
a
 
smooth
 
transition.
 
This
 
program
 
provides
 
the
 
new
 
CEO
 
with
 
the
 
necessary
 
knowledge,
 
resources,
 
and
support to succeed in the role
 
from the outset.
Overall,
 
the
 
CEO
 
Succession
 
Planning
 
Policy
 
ensures
 
that
 
the
 
organization
 
is
 
well-prepared
 
for
 
leadership
 
transitions,
maintaining continuity, stability,
 
and effectiveness
 
at the highest level
 
of management.
3.4
Board Evaluation Policy
The
 
Board
 
and
 
Board
 
Committees
 
Evaluation
 
Policy
 
of
 
Eurobank
 
Holdings
 
and
 
Eurobank
 
establishes
 
the
 
principles,
framework,
 
and process for the
 
annual assessment of the effectiveness
 
of the Board of Directors and its Committees at both
the HoldCo and the
 
Bank. The Policy
 
aspires to align with best European
 
banking practices
 
while fully complying with Greek
and European legal and regulatory requirements.
Under this Policy,
 
the Nomination and Corporate
 
Governance Committee (NomCo)
 
holds the overall
 
responsibility for:
Assessing the structure, size, composition, and performance
 
of the Board and its Committees,
Recommending to the Board any necessary
 
changes to enhance effectiveness,
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / CORPORATE
 
GOVERNANCE STATEMENT
 
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Evaluating the collective
 
suitability of the Board as a whole, as well as the
 
suitability and contributions of individual
Board members, and
Reporting its findings and recommendations to the
 
Board accordingly.
3.5
Board of Directors Diversity
 
Policy
 
The
 
HoldCo/Bank
 
Board
 
of
 
Directors
 
Diversity
 
Policy
 
reflects
 
the
 
organization’s
 
commitment
 
to
 
diversity
 
in
 
line
 
with
international best practices
 
and applicable legal requirements.
According to the Policy,
 
Board diversity encompasses multiple factors,
 
including:
Skills and expertise,
Educational and professional
 
background,
Geographical origin,
Gender,
Age, and
Other relevant
 
attributes that contribute to a well-balanced
 
and effective Board.
The
 
NomCo is
 
responsible
 
for
 
incorporating
 
diversity
 
considerations
 
when
 
assessing the
 
composition and
 
structure
 
of the
Board.
During
 
the
 
Board
 
collective
 
suitability
 
review,
 
NomCo
 
members
 
discuss
 
and
 
define
 
measurable
 
objectives
 
for
 
enhancing
Board
 
diversity.
 
These
 
objectives
 
guide
 
the
 
(re)appointment
 
and
 
succession
 
planning
 
of
 
individual
 
Board
 
members,
 
in
accordance with the
 
Board and Board Committees Evaluation Policy.
A key target outlined in the Policy is gender diversity.
 
Specifically, NomCo so far aimed for at least 25% representation
 
of the
less represented
 
gender on the
 
Board, calculated
 
based on the
 
total Board
 
size, according to
 
legal requirements.
 
After the
publication of Law 5178/2025, the
 
intention is to properly comply to its provisions.
3.6
Remuneration Policy
Eurobank Holdings has established
 
a Board of Directors’ Remuneration
 
Policy (Remuneration
 
Policy) in accordance
 
with the
requirements
 
of Law 4548/2018
 
(the Law).
 
The latest
 
version
 
of the
 
Policy
 
was approved
 
by the
 
Annual General
 
Meeting of
Shareholders
 
on 23 July
 
2024. The
 
Policy
 
has been designed
 
to comply with
 
the specific
 
provisions
 
of Articles 110
 
and 111 of
the Law.
The Remuneration
 
Policy sets
 
out the fundamental
 
principles and structure
 
governing the
 
remuneration
 
of Board members.
Its primary objective is to ensure that remuneration
 
is:
Reasonable and aligned with market standards,
Gender-neutral, promoting
 
equal treatment, and
Sufficiently
 
competitive
 
to
 
attract
 
and
 
retain
 
Directors
 
with
 
the
 
necessary
 
skills
 
and
 
experience
 
to
 
implement
Eurobank Holdings’ business
 
strategy effectively.
Additionally,
 
the Policy
 
safeguards the
 
long-term interests
 
and sustainability of the
 
organization by
 
discouraging excessive
risk-taking. This is achieved through continuous monitoring of market trends and best practices at both domestic and global
levels.
The
 
Policy
 
is informed
 
by external
 
and independent
 
benchmarking analyses
 
of remuneration
 
in the
 
financial and
 
banking
sectors, both in Greece and internationally. This benchmarking ensures that the remuneration
 
framework for
 
Board members
remains aligned with industry best practices.
In addition, the development
 
and implementation of the Remuneration
 
Policy are characterized
 
by:
Objectivity and transparency throughout
 
the process,
 
and
Independent
 
judgment
 
and
 
discretion
 
by
 
the
 
Board
 
when
 
approving
 
or
 
recommending
 
remuneration,
 
ensuring
alignment with both individual and Company performance.
Remuneration Report
In compliance
 
with Article 112(3)
 
of Law 4548/2018,
 
Eurobank Holdings
 
publishes an
 
annual Remuneration
 
Report, detailing
the remuneration
 
and financial benefits granted to each Executive
 
and Non-Executive Director during the
 
financial year.
The
 
Eurobank
 
Holdings
 
Remuneration
 
Report
 
for
 
2024
 
(
https://www.eurobankholdings.gr
)
 
was
 
approved
 
by
 
the
 
Annual
General
 
Meeting on
 
23 July
 
2024. The
 
report
 
provides
 
comprehensive
 
and transparent
 
disclosure
 
of Board
 
remuneration,
ensuring efficient communication with
 
shareholders and stakeholders.
 
 
 
 
 
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Remuneration Structure
Non-Executive Directors
Fixed Remuneration
 
Only: Non-Executive
 
Directors receive
 
fixed remuneration,
 
which is
 
annually approved
 
by the
Annual General Meeting. They
 
are not eligible for variable remuneration.
Board
 
Fees:
 
Their
 
fixed remuneration
 
consists of
 
Board
 
Fees,
 
determined
 
based
 
on their
 
roles
 
on the
 
Board
 
and
Committees, their expected contribution, and the
 
additional time and effort
 
required for
 
their responsibilities.
Executive Directors
Employment Contracts: Executive
 
Directors are employed
 
by the Bank under permanent, indefinite contracts.
 
These
contracts require a three
 
-month notice period in case
 
of resignation.
Remuneration
 
Structure:
o
Executive Directors
 
receive remuneration
 
under their
 
employment contracts
 
and do not receive
 
additional
compensation for their
 
role as Board members.
o
Variable
 
Remuneration:
 
Any
 
variable
 
remuneration
 
awarded
 
follows
 
the
 
provisions
 
of
 
the
 
Bank’s
Remuneration
 
Policy and is subject to approval by
 
the Shareholders'
 
General Meeting.
Remuneration Governance
Given
 
the
 
identical
 
composition
 
of
 
the
 
Boards
 
of
 
Eurobank
 
Holdings
 
and
 
Eurobank,
 
and
 
the
 
fact
 
that
 
Directors
 
are
compensated
 
solely
 
by
 
the
 
Bank,
 
any
 
reference
 
to
 
Board
 
remuneration
 
at
 
Eurobank
 
Holdings
 
also
 
applies
 
to
 
their
remuneration
 
as Directors of the Bank.
The 2024 Board and key management
 
remuneration
 
disclosure is included in the relevant note of the
 
consolidated accounts
of
 
Eurobank
 
Holdings.
 
To
 
ensure
 
market
 
transparency
 
regarding
 
remuneration
 
structures
 
and
 
associated
 
risks,
 
this
information is publicly available
 
on the Eurobank
 
Holdings website (
www.eurobankholdings.gr
).
3.7
Board and Board Committees’ Attendance
 
Policy
 
In
 
accordance
 
with
 
the
 
Board
 
and
 
Board
 
Committees’
 
Attendance
 
Policy
 
of
 
Eurobank
 
Holdings
 
and
 
Eurobank,
 
Board
members are expected to attend all Board
 
and Committee meetings to which they are appointed.
However,
 
it is
 
recognized
 
that, on
 
occasion,
 
Board
 
members
 
may be
 
unable to
 
attend certain
 
meetings due
 
to conflicting
commitments
 
or
 
unforeseen
 
circumstances.
 
To
 
ensure
 
active
 
participation,
 
each
 
member
 
must
 
maintain
 
a
 
minimum
attendance rate of 85% over
 
the course of the calendar
 
year.
Board members may miss up to 15% of scheduled
 
meetings, but only if a valid excuse is provided.
Additionally,
 
in accordance
 
with Law
 
4706/2020,
 
if a
 
Board
 
member
 
is unjustifiably
 
absent from
 
at
 
least two
 
consecutive
Board meetings,
 
they shall be
 
considered resigned.
 
This resignation
 
is formally established
 
through a Board
 
decision, which
subsequently initiates the replacement
 
process in accordance
 
with the applicable legal framework.
3.8
Directors’ Induction and Continuous Professional
 
Development Process
 
All new Board members
 
undergo a comprehensive
 
Induction Program,
 
designed to ensure a smooth and effective
 
transition
into their roles.
 
The program
 
aims to:
1.
Communicate the vision and corporate
 
culture of Eurobank Holdings and
 
Eurobank,
2.
Introduce practical
 
and procedural responsibilities
 
to facilitate a seamless onboarding
 
process,
3.
Accelerate
 
productivity by reducing the
 
time needed to familiarize new
 
members with their roles,
4.
Integrate new Directors
 
as valued members of the Board,
5.
Provide insight into the organizational
 
structure of the HoldCo/Bank, and
6.
Offer a comprehensive
 
understanding of the business, strategy,
 
market dynamics, key relationships,
 
and leadership
team of the HoldCo/Bank.
Upon
 
appointment,
 
new
 
Board
 
members
 
also
 
receive
 
a
 
Manual
 
of
 
Obligations,
 
which
 
outlines
 
their
 
core
 
responsibilities
towards the
 
Supervisory Authorities
 
and the
 
HoldCo/Bank. This
 
manual includes guidance
 
on local regulatory
 
requirements
and Board procedure
 
s.
Additionally,
 
newly
 
appointed
 
Directors
 
participate
 
in
 
meetings
 
and
 
presentations
 
with
 
key
 
executives
 
to
 
gain
 
a
 
holistic
overview of the
 
organization.
Recognizing
 
the
 
importance
 
of
 
continuous
 
professional
 
development,
 
Eurobank
 
Holdings
 
and
 
Eurobank
 
provide
 
ongoing
learning resources to support the
 
knowledge and skill enhancement of all Board
 
members.
3.9
Group Governance
 
Policy
 
In compliance with the regulatory
 
framework,
 
the Group Governance
 
Policy of Eurobank
 
Holdings and Eurobank establishes
general
 
governance
 
principles
 
for
 
the
 
Group
 
entities,
 
sets
 
common
 
governance
 
standards,
 
and
 
defines
 
authorities,
responsibilities, and expectations, ensuring the
 
Group operates
 
as a unified entity with a cohesive strategic
 
direction.
 
 
 
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The
 
policy integrates
 
internal governance
 
by clarifying
 
the
 
distinct roles
 
of the
 
parent company
 
and its
 
subsidiaries, while
also setting principles related to board composition, roles and responsibilities, chairmanship, board committees, nomination
processes,
 
board
 
diversity,
 
CEO
 
succession
 
planning,
 
board
 
evaluations,
 
professional
 
development,
 
management
committees, governance manuals,
 
and corporate governance
 
codes.
By
 
harmonizing
 
governance
 
practices
 
across
 
the
 
Group,
 
the
 
policy
 
promotes
 
accountability,
 
transparency,
 
and
 
effective
decision-making at all levels.
3.10
Conflicts of interest Policy
Eurobank
 
Holdings and
 
Eurobank
 
have
 
implemented
 
a Conflicts
 
of Interest
 
Policy,
 
approved
 
by their
 
respective
 
Boards of
Directors, to establish a comprehensive
 
framework
 
for identifying, preventing,
 
and managing actual, potential, or perceived
conflicts of interest
 
arising from
 
the Group’s
 
business activities. This
 
policy includes
 
a structured set
 
of policies, procedures,
systems, and controls to uphold ethical
 
standards and ensure transparent decision
 
-making.
To prevent
 
conflicts of duties, the Group has implemented
 
procedural
 
safeguards that:
Segregate executive
 
and non-executive responsibilities at
 
the Board
 
level, ensuring a clear
 
distinction between the
Chairperson of the Board and the
 
CEO’s executive functions,
Prevent incompatible roles
 
and conflicts of interest among Board members,
 
Management, and Executives, and
Mitigate the misuse of inside information
 
or corporate assets.
Board members are
 
expected to:
Adhere to high ethical
 
standards and comply with the principles set out in the
 
Conflicts of Interest Policy,
Act independently, making sound, objective,
 
and impartial decisions,
Disclose any personal interests that may conflict with
 
the interests of Eurobank
 
Holdings or the Group,
Maintain confidentiality
 
of non-public
 
information
 
and avoid
 
any conduct
 
that
 
could constitute
 
market
 
abuse or
create a conflict of interest.
Board members are
 
required to disclose:
All external engagements, directorships, or affiliations
 
outside the Group,
Any new or ongoing circumstances that could
 
affect their
 
independence of mind or create a conflict of interest.
All actual or potential conflicts of interest at the
 
Board level must be:
Communicated, documented, and discussed,
Decided upon and managed by the Group,
Mitigated
 
through
 
specific
 
measures
 
for
 
unexpected
 
conflicts,
 
while
 
persistent
 
conflicts
 
are
 
managed
 
through
continuous oversight.
Board
 
members
 
must
 
abstain
 
from
 
voting
 
on
 
matters
 
where
 
they
 
have
 
an
 
identified
 
conflict
 
of
 
interest,
 
ensuring
transparency,
 
impartiality, and effective
 
governance.
3.11
Other Key Policies
 
In addition
 
to the
 
above policies,
 
Eurobank
 
Holdings and
 
Eurobank
 
have established,
 
among others,
 
the following
 
policies,
which form an integral part of their
 
corporate governance
 
framework:
 
the Code of Conduct and Ethics, the
 
Anti-Bribery and
Corruption Policy,
 
and the Policy for
 
Reporting Illegal or Unethical Conduct or Violations
 
of European Union Law.
4.
Shareholders’ General
 
Meeting
The
 
Shareholders’
 
General
 
Meeting
 
(General
 
Meeting)
 
serves
 
as
 
the
 
highest
 
authority
 
within
 
Eurobank
 
Holdings
 
and
Eurobank and is convened
 
by the respective
 
Board of Directors to address all matters concerning
 
the entity.
 
It holds exclusive
 
jurisdiction over
 
matters specified in
 
Article 117 of Company
 
Law 4548/2018, including
 
amendments to
 
the
Articles of
 
Association. Every
 
shareholder
 
has the
 
right to
 
participate and
 
vote
 
at the
 
General
 
Meeting, either
 
in person
 
or
through a legal representative,
 
in accordance with the prescribed
 
legal procedures.
For
 
the General
 
Meeting to reach a
 
quorum and be considered
 
valid, shareholders
 
present or represented
 
must collectively
hold at
 
least 20%
 
(1/5) of
 
the
 
paid-in share
 
capital associated
 
with voting
 
shares.
 
Resolutions
 
are
 
passed by
 
an absolute
majority and are
 
binding on both absent
 
and dissenting shareholders. However, for significant decisions such as share capital
changes or mergers,
 
a higher
 
quorum of at
 
least 50% (1/2)
 
of the
 
paid-in share
 
capital is
 
required, and
 
resolutions must
 
be
approved by a two
 
-thirds (2/3) majority.
According to Article 119(1) of Law
 
4548/2018, the Annual General Meeting must be held no later than the tenth (10th) calendar
day
 
of
 
the
 
ninth
 
month
 
following
 
the
 
end
 
of
 
the
 
business
 
year.
 
Additionally,
 
an
 
Extraordinary
 
General
 
Meeting
 
may
 
be
convened by the Board
 
of Directors when deemed necessary
 
or required by law.
 
 
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Minutes of the
 
General
 
Meeting are authenticated
 
by the
 
Chairperson and the
 
Secretary of the
 
meeting, and the
 
standard
minority rights outlined in Company Law 4548/2018 apply.
4.1
Information about the
 
Eurobank Holdings
 
General Meetings
4.1.1
Requirements for calling
 
and convening the General
 
Meetings
All persons registered as shareholders of ordinary shares
 
of Eurobank Holdings in the Dematerialized Securities System
 
(DSS),
managed by Hellenic Central
 
Securities Depository S.A., on the
 
Record Date—specifically,
 
at the start of the
 
fifth day before
the General
 
Meeting—are entitled to participate
 
and vote in the
 
HoldCo General
 
Meeting. This Record Date
 
also applies to
any Repeat Meeting.
Shareholders
 
are
 
informed
 
in advance
 
about the
 
agenda of
 
each
 
General
 
Meeting,
 
and new
 
technologies
 
are
 
utilized
 
to
facilitate
 
their
 
participation.
 
At least
 
20 days
 
before
 
the
 
meeting,
 
shareholders
 
are
 
provided
 
with access
 
to all
 
necessary
information, in full
 
compliance with Greek law.
The Notice
 
of General Meeting includes:
The date, time, and place
 
of the meeting,
The agenda items,
Participation and voting
 
rights, along with the relevant
 
procedures,
Minority shareholder rights, and
Relevant documents made available to shareholders.
All resolutions and related
 
information from
 
each General Meeting are
 
published under the Investor
 
Relations section of the
Eurobank Holdings website.
4.1.2
Participation and proxies
Eurobank
 
Holdings
 
facilitates
 
shareholder
 
participation
 
in
 
General
 
Meetings. All
 
shareholders
 
have
 
the
 
right to
 
attend
 
in
person or appoint a proxy,
 
who must be designated at least 48 hours before the
 
meeting date.
If shareholders' questions
 
regarding agenda items are
 
not addressed during the
 
General Meeting, Eurobank
 
Holdings has a
structured process in place
 
to provide the relevant
 
responses.
4.1.3
Annual General Meeting (AGM)
 
of the shareholders
 
The
 
Annual General
 
Meeting of Eurobank
 
Holdings’ shareholders
 
was held
 
on July 23,
 
2024, remotely
 
via teleconference
 
in
real-time. Shareholders representing
 
2,849,603,397 shares out of 3,664,399,104
 
shares (excluding 52,080,673 treasury shares,
in accordance
 
with Article
 
50(1) of Law
 
4548/2018) participated,
 
corresponding
 
to 77.76%
 
of the
 
paid-up share
 
capital with
voting rights on the agenda items.
The General
 
Meeting:
1.
Approved, with a majority exceeding the minimum required by law, the Annual Separate and Consolidated Financial
Statements for the
 
financial year 2023, along with the
 
Directors’ and Auditors’ Reports.
2.
Approved,
 
with a majority
 
exceeding the
 
minimum required
 
by law,
 
the overall
 
management for
 
the financial
 
year
2023, as well as the
 
discharge of the Auditors for the
 
same period.
3.
Approved, with
 
a majority exceeding the minimum required
 
by law:
a)
The
 
appointment
 
of
 
KPMG
 
Certified
 
Auditors
 
S.A.
 
(KPMG)
 
as
 
the
 
statutory
 
auditor
 
for
 
the
 
Annual
 
and
Consolidated Financial Statements of the
 
Company for the
 
financial year 2024.
b)
The approval
 
of KPMG’s fees for the
 
2024 audit, amounting to €0.3 million.
4.
Approved,
 
with
 
a
 
majority
 
exceeding
 
the
 
minimum
 
required
 
by
 
law,
 
the
 
dividend
 
distribution
 
to
 
shareholders,
amounting to €342 million, from the “Special Reserves” account, and authorized the Board of Directors to undertake
all necessary actions for its implementation.
5.
Approved,
 
with
 
a
 
majority
 
exceeding
 
the
 
minimum
 
required
 
by
 
law,
 
the
 
amendment
 
of
 
Articles
 
8
 
and
 
9
 
of
 
the
Company’s Articles of Association, updating paragraphs
 
1 and 2 of Article 8 and paragraph 5 of Article 9.
6.
Approved, with
 
a majority exceeding the minimum required
 
by law:
a)
The addition
 
of a new
 
Article 11 to the
 
Company’s Articles of Association,
 
allowing for
 
the remuneration
 
of
Board
 
members
 
through
 
participation
 
in
 
the
 
profits
 
of
 
the
 
respective
 
financial year,
 
in accordance
 
with
Article 109(2) of Law 4548/2018.
b)
The renumbering
 
of Articles 11, 12, 13, 14, and 15 to Articles 12, 13, 14, 15,
 
and 16, respectively.
7.
Approved,
 
with
 
a
 
majority
 
exceeding
 
the
 
minimum
 
required
 
by
 
law,
 
the
 
distribution
 
of
 
€404,330
 
to
 
senior
management and employees of the
 
Company from the “Special
 
Reserves” account.
8.
Approved, with
 
a majority exceeding the minimum required
 
by law:
(i)
The cancellation
 
of 52,080,673 treasury shares, in accordance
 
with Article 49 of Law 4548/2018.
 
 
 
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(ii)
The reduction
 
of the Company’s share
 
capital by €11,457,748.06,
 
corresponding to the
 
nominal value of the
cancelled shares (€0.22 per share).
(iii)
The amendment
 
of Article 5 of the Company’s Articles of Association to reflect
 
the share capital reduction.
9.
Approved, with
 
a majority exceeding the minimum required
 
by law, in accordance
 
with Article 86 of Law 4261/2014,
a higher than 100% maximum level
 
of the ratio
 
between fixed and variable remuneration
 
for the CEO, three
 
Deputy
CEOs, Group Chief Risk Officer,
 
Group Chief Financial Officer,
 
General Manager
 
Group Strategy,
 
General Manager
Markets, and CEO of Eurobank Cyprus
 
Ltd & Head of International Activities & Group Private
 
Banking.
10.
Approved,
 
with a majority exceeding
 
the minimum required
 
by law,
 
the amendment
 
of the Remuneration
 
Policy for
Directors of the Company.
11.
Approved,
 
with a
 
majority exceeding
 
the minimum
 
required
 
by law,
 
the remuneration
 
paid to
 
Board members
 
for
the
 
financial year
 
2023,
 
for
 
their
 
roles
 
as Board
 
members
 
and Committee
 
members,
 
and the
 
remuneration
 
to be
paid for the financial year
 
2024.
12.
Casted a positive vote on the
 
Remuneration
 
Report for the financial year
 
2023.
13.
Approved,
 
with a
 
majority exceeding
 
the
 
minimum required
 
by law,
 
the
 
amendment
 
of the
 
Nomination
 
Policy
 
for
Board Directors.
14.
Approved, with
 
a majority exceeding the minimum required
 
by law:
(a)
The
 
election
 
of the
 
following
 
individuals as
 
Board
 
members,
 
with their
 
term
 
of office
 
expiring on
 
July 23,
2027,
 
extended until the conclusion of the
 
Annual General Meeting of 2027:
-
Konstantinos Vassiliou
-
Alice Gregoriadi
-
George Zanias
-
Stavros Ioannou
-
Fokion
 
Karavias
-
Evangelos Kotsovinos
-
Irene Rouvitha Panou
-
Cinzia Basile
-
Burkhard Eckes
-
John Hollows
-
Rajeev Kakar
-
Bradley Paul Martin
-
Jawaid Mirza
(b)
The appointment
 
of Alice Gregoriadi, Evangelos
 
Kotsovinos, Irene
 
Rouvitha Panou, Cinzia
 
Basile, Burkhard
Eckes, John Hollows, Rajeev
 
Kakar, and Jawaid Mirza as independent non-executive
 
Board members.
15.
Approved, with
 
a majority exceeding the minimum required
 
by law:
(a)
 
The Audit Committee
 
to function as a Committee of the
 
Board of Directors, composed of Board
 
members.
(b)
 
The Audit Committee to consist of five independent non-executive
 
Board members.
(c)
 
The term of office of the Audit Committee members to coincide with their term as Board members,
 
expiring
on July 23, 2027,
 
extended until the conclusion of the Annual
 
General Meeting of 2027.
16.
Was informed
 
on the Annual Activity Report of the Audit Committee
 
for the financial year
 
2023.
17.
Was informed
 
on the Independent Non-Executive Directors’
 
Report.
All
 
information
 
regarding
 
the
 
AGM
 
of
 
Eurobank
 
Holdings
 
can
 
be
 
found
 
on
 
the
 
Eurobank
 
Holdings
 
website:
Eurobank Holdings AGM
 
2024
.
4.2
Information about the
 
Eurobank General
 
Meetings
Following
 
the demerger,
 
Eurobank Holdings
 
became
 
the sole
 
shareholder
 
of Eurobank,
 
holding 100%
 
of its
 
share capital.
 
In
accordance
 
with
 
Article
 
121(5)
 
of Law
 
4548/2018,
 
a formal
 
invitation
 
to convene
 
a General
 
Meeting is
 
not
 
required
 
if the
meeting
 
is
 
attended
 
or
 
represented
 
by
 
shareholders
 
holding
 
the
 
entire
 
share
 
capital
 
and
 
none
 
of
 
them
 
objects
 
to
 
its
convening or decision-making.
In this context, the following
 
General Meeting of Eurobank
 
was held.
4.2.1
Annual General Meeting (AGM)
 
of the shareholders
 
The Annual
 
General
 
Meeting of Eurobank’s
 
shareholders
 
was held
 
on July 23,
 
2024, in Athens,
 
at Eurobank’s
 
Headquarters,
12
 
Stadiou
 
Street
 
&
 
2
 
Omirou
 
Street.
 
The
 
sole
 
shareholder,
 
Eurobank
 
Holdings,
 
participated,
 
representing
 
3,683,244,830
shares, corresponding to 100% of the
 
paid-up share capital with voting
 
rights on the agenda items.
 
 
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The General
 
Meeting:
1.
Approved
 
the Annual
 
Separate
 
and Consolidated Financial
 
Statements for
 
the financial
 
year 2023,
 
along with the
Directors’ and Auditors’ Reports.
2.
Approved the overall
 
management for the financial year 2023
 
and the discharge of
 
the Auditors for the same period.
3.
Appointed KPMG Certified Auditors S.A. as Auditors for the
 
financial year 2024.
4.
Approved the
 
amendment of Articles 8 and 9 of the Bank’s Articles of Association.
5.
Approved the
 
addition of a new Article 11 to the Bank’s Articles of Association regarding
 
the remuneration
 
of Board
members and the renumbering
 
of Articles 11, 12, 13, and 14 accordingly.
6.
Approved the
 
distribution of net profits to the
 
senior management and employees
 
of the Bank.
7.
Approved,
 
pursuant to
 
Article 86
 
of Law
 
4261/2014, a
 
higher
 
than 100%
 
maximum level
 
of the
 
ratio
 
between fixed
and variable remuneration
 
for nine executives.
8.
Approved the
 
remuneration
 
for the financial year 2023 and the
 
advance payment of remuneration
 
for the Directors
for the financial year
 
2024.
9.
Approved
 
the election
 
of a new
 
Board of
 
Directors due
 
to the
 
expiration
 
of the
 
term of
 
the current
 
Board and
 
the
appointment of independent non-executive Board
 
members.
10.
Determined the type and composition of the
 
Audit Committee.
11.
Was informed
 
on the Annual Activity Report of the Audit Committee
 
for the financial year
 
2023.
5.
Board of Directors
5.1
 
General
The
 
HoldCo/Bank are
 
managed by
 
their respective
 
Boards of
 
Directors (Board
 
or BoD), which
 
bear collective
 
responsibility
for their long-term success. The Boards exercise their duties in compliance
 
with Greek legislation, international best practices,
their Articles of Association, and the
 
legitimate decisions of the shareholders’
 
General Meetings.
The Board’s role
 
is to provide entrepreneurial
 
leadership to the Group
 
within a framework
 
of prudent and effective
 
controls,
enabling the identification, assessment, and management of risks. It establishes the Group's strategic objectives, ensures the
availability
 
of
 
financial
 
and
 
human
 
resources
 
necessary
 
to
 
achieve
 
these
 
objectives,
 
and
 
evaluates
 
management
performance.
 
Additionally,
 
the
 
Board
 
defines the
 
Group’s
 
values and
 
standards,
 
ensuring that
 
its responsibilities
 
towards
shareholders and other
 
stakeholders are
 
recognized and fulfilled.
All Board members are
 
required to act in the best interests
 
of the Group, in full alignment
 
with their legal duties.
5.2
Composition of the Board
The
 
members
 
of the
 
Board are
 
elected by
 
the General
 
Meetings of Eurobank
 
Holdings and
 
Eurobank,
 
which determine
 
the
exact number of directors and their term of office, in accordance with legal provisions
 
and the Articles of Association of both
entities. The
 
General Meetings also designate
 
the independent non-executive directors.
During 2024:
The Boards of Directors of
 
HoldCo and Eurobank, by their
 
decisions dated May
 
30, 2024, and
 
June 28, 2024,
 
following
the respective
 
recommendations of the
 
Nomination and Corporate
 
Governance Committees (NomCos) on May 28,
2024, and
 
June 26,
 
2024, proposed
 
to the
 
Annual General
 
Meetings (AGMs)
 
of July
 
23, 2024,
 
the appointment
 
of
Mr. Evangelos Kotsovinos
 
as an independent non-executive director (iNED) of the
 
BoDs.
Following
 
the announcement by
 
Mr. Georgios
 
Chryssikos (Non-Executive Director,
 
Vice Chair of the previous
 
Board)
regarding his decision
 
not to seek
 
renewal of
 
his term, the
 
necessity of the
 
Vice Chair
 
role
 
was reviewed.
 
The BoDs
of
 
HoldCo
 
and
 
Eurobank,
 
in
 
their
 
meetings
 
dated
 
May
 
30,
 
2024,
 
and
 
June
 
28,
 
2024,
 
following
 
the
 
NomCos'
recommendations
 
on May 28,
 
2024, and June
 
26, 2024,
 
decided to discontinue
 
the role
 
of Vice
 
Chair on the
 
BoDs
and certain Committees
 
(NomCo, RemCo, and BDTCo)
 
upon the conclusion
 
of Mr.
 
Chryssikos’ term.
 
Going forward,
in the event of the Chair’s absence
 
or impediment, the most senior iNED present at the meeting—based on tenure—
shall assume the Chair’s duties.
Due to the expiration of the Boards’ tenure,
 
the AGMs of HoldCo and Eurobank on July 23, 2024, appointed the new
Boards for
 
a three-year
 
term, extending until
 
the AGMs
 
of 2027.
 
The AGMs
 
also designated the
 
independent non-
executive members
 
of the
 
Boards. The
 
new BoDs,
 
in accordance
 
with the
 
BoD decisions
 
dated May
 
30, 2024,
 
and
June 28,
 
2024, following
 
the
 
NomCos' recommendations
 
on May
 
28, 2024,
 
and June
 
26,
 
2024, comprised
 
the
 
re-
election of twelve (12) previous
 
Board members and the
 
election of one (1) new member,
 
Mr. Evangelos Kotsovinos.
In accordance
 
with the
 
above
 
AGM decisions
 
and the
 
NomCos’ recommendations
 
dated May
 
28, 2024,
 
and June
26, 2024, the new BoDs, in their meeting of
 
July 23, 2024, decided on
 
their constitution, the appointment of the Chief
Executive
 
Officer
 
(CEO) and
 
Deputy Chief
 
Executive
 
Officers
 
(DCEOs), and
 
the
 
designation
 
of executive
 
and non-
executive directors.
For efficiency
 
reasons, the composition of HoldCo’s
 
BoD is identical to that of Eurobank’s
 
BoD.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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GOVERNANCE STATEMENT
 
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Following
 
these
 
developments,
 
as
 
of
 
the
 
date
 
of
 
approval
 
of
 
this
 
Statement,
 
the
 
current
 
Boards
 
consist
 
of
 
thirteen
 
(13)
directors, categorized as follows:
Three (3) executive directors,
Two (2) non-executive
 
directors, and
Eight (8) independent non-executive directors.
Name
Position
Eurobank Holdings
Eurobank
First
appointment
End of
Term
First
appointment
End of
Term
Georgios P.
 
Zanias
Chairperson, Non-Executive Director
Mar. 2019
2027
Mar. 2020
2027
Fokion
 
C. Karavias
Chief Executive Officer
Jun. 2014
2027
Mar. 2020
2027
Stavros E. Ioannou
Deputy Chief Executive Officer
 
Apr. 2015
2027
Mar. 2020
2027
Konstantinos V.
 
Vassiliou
Deputy Chief Executive Officer
July 2018
2027
Mar. 2020
2027
Bradley Paul L. Martin
Non-Executive Director
Jun. 2014
2027
Mar. 2020
2027
Rajeev K. L. Kakar
Non-Executive Independent Director
July 2018
2027
Mar. 2020
2027
Jawaid A. Mirza
Non-Executive Independent Director
Jun. 2016
2027
Mar. 2020
2027
Alice K. Gregoriadi
Non-Executive Independent Director
Apr. 2020
2027
Apr. 2020
2027
Irene Rouvitha Panou
Non-Executive Independent Director
Apr. 2020
2027
Apr. 2020
2027
Cinzia V.
 
Basile
Non-Executive Independent Director
Dec. 2020
2027
Dec. 2020
2027
Burkhard Eckes
Non-Executive Independent Director
Jul. 2023
2027
Jul. 2023
2027
John Arthur Hollows
Non-Executive Independent Director
Jul. 2023
2027
Jul. 2023
2027
Evangelos Kotsovinos
Non-Executive Independent Director
Jul. 2024
2027
Jul. 2024
2027
5.3
CVs of Board Board
 
members and Secretary
The short
 
CVs of the
 
HoldCo and Eurobank
 
Board members,
 
summarized below,
 
demonstrate that
 
the Boards’
 
composition
aligns with
 
the knowledge,
 
skills, and
 
experience
 
necessary for
 
the effective
 
execution of
 
their duties.
 
This is
 
in accordance
with the Board Nomination
 
Policy and the business model
 
and strategy of HoldCo and Eurobank.
Additionally, the directorships held by HoldCo and Eurobank Board members as of December 31, 2023, are outlined
 
in Section
"Directorships of Board Members".
Georgios Zanias - Chairperson, Non-Executive
 
Director
-
Membership in Board Committees: Nomination and Corporate
 
Governance Committee
 
– Member
-
Year of birth: 1955
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: None
Mr. Zanias
 
joined Eurobank
 
as the
 
Chairman of the
 
Board of Directors
 
in 2019.
 
He is also a
 
Professor
 
Emeritus of
 
Economics
at the Athens University
 
of Economics and Business and a Member of the
 
Board of IOBE.
In the past, Mr Zanias has served
 
as the Minister of Finance
 
(2012), Chairman of the Board of Directors
 
of the National
 
Bank
of Greece
 
(2012-2015), Chairman of
 
the Board
 
of the
 
Hellenic Banking Association
 
(2012-2015), Member
 
of the Board
 
of the
European Banking Federation
 
(2012-2015), Member of the Board of
 
the American-Greek Chamber of Commerce ( 2019-2022),
Chairman of
 
the
 
Council of
 
Economic Advisors
 
at the
 
Ministry of
 
Finance (2009-2012),
 
General
 
Secretary of
 
the
 
Ministry of
Economy and Finance (2001-2004), Chairman and Scientific Director of the
 
National Economic Institute (KEPE) (1998-2001).
He has also served
 
as a Director on
 
the Boards
 
of Hellenic Exchanges (2000-2001),
 
Public Debt Management Office
 
(PDMA)
(2009-2012),
 
General
 
Bank
 
(1997-1998),
 
CHIPITA
 
SA
 
(2015-2019),
 
the
 
European
 
Financial
 
Stability
 
Mechanism
 
(EFSF/ESM)
(2010-2012). Also: Member of the Board
 
of Governors of the
 
Black Sea Trade
 
and Development Bank (2003-2004),
 
Alternate
Governor
 
of
 
the
 
Board
 
of
 
Governors
 
of
 
EBRD
 
(2002-2004),
 
Member
 
of
 
the
 
European
 
Securities
 
Committee
 
(2001-2002),
Member of
 
the
 
Monetary Policy
 
Committee of
 
the
 
Bank of
 
Greece
 
(May-July 2012),
 
Chairman of
 
the
 
Board of
 
Directors of
Piraeus Real Estate SA and Picar SA (2017-2019), Vice
 
Chairman of the Board of ETVA
 
Industrial Zone SA (2018-2019).
 
 
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He holds a Doctorate from Oxford University,
 
an M.Sc. for the University of Reading and a B.Sc. from the Athens University
 
of
Economics and Business.
Fokion
 
Karavias-Chief Executive Officer
 
(CEO)
-
Membership in Board Committees: None
-
Year of birth: 1964
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 775,878
Mr. Karavias
 
joined Eurobank in 1997 and served,
 
inter alia, as Member of the BoD of Eurobank
 
Private Bank Luxembourg SA
(2012-2022),
 
Senior
 
General
 
Manager,
 
Group
 
Corporate
 
&
 
Investment
 
Banking,
 
Capital
 
Markets
 
&
 
Wealth
 
Management
(2014-2015) and Executive
 
Committee Member (2014-2015),
 
General Manager and Executive Committee
 
Member (2005-2013),
Deputy General Manager
 
and Treasurer
 
(2002-2005), Head of fixed income and derivative product
 
trading (1997).
In the past,
 
Mr. Karavias
 
had also the
 
following
 
significant posts: Treasurer
 
of Telesis
 
Investment Bank (2000),
 
Head of fixed
income products
 
and derivatives
 
in Greece of
 
Citibank, Athens
 
(1994) and has also
 
worked in
 
the Market
 
Risk Management
Division of JPMorgan NY (1991).
He currently
 
also serves
 
as Vice
 
Chairman of
 
the
 
Board of
 
Directors ofHellenic
 
Bank Association
 
(HBA) ,
 
as Member
 
of the
General Council of the Hellenic
 
Federation
 
of Enterprises (SEV)
 
and as
 
Honorary Member of The Greek Tourism Confederation
(SETE).He holds a PhD in Chemical Engineering from the University of Pennsylvania, Philadelphia, USA and
 
an MA in Chemical
Engineering from
 
the same
 
university,
 
as well
 
as a Diploma
 
in Chemical
 
Engineering from
 
the National
 
Technical
 
University
of Athens. He has published articles on topics related
 
to his academic research.
Stavros Ioannou-Deputy Chief Executive Officer
 
(CEO), Group Chief Operating
 
Officer (COO) & International
 
Activities
-
Membership in Board Committees: Board Digital and Transformation
 
Committee - Member
-
Year of birth: 1961
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 358,145
Mr.
 
Ioannou holds
 
several
 
other
 
posts in
 
the
 
Eurobank
 
Group as
 
Head of
 
International
 
Activities &
 
Group Private
 
Banking,
Member of the BoD
 
of Eurobank Private Bank
 
Luxembourg S.A (since October 2024),
 
Member of the BoD
 
of Eurobank Bulgaria
AD (since October 2015), Vice-Chairman in Eurobank
 
Cyprus Ltd (since November 2022) and is also the Chairman of the BoD
inBE-Business
 
Exchanges
 
SA
 
(since
 
January
 
2014).
 
He
 
has
 
been
 
appointed
 
as
 
the
 
responsible
 
BoD
 
member
 
of
 
Eurobank
Holdings and Eurobank for
 
climate-related and environment
 
al risks and for the outsourcing
 
function.
He is currently Non-Executive Board
 
member of Grivalia Management Company S.A. (since
 
September 2019).
In the past,
 
Mr. Ioannou
 
had also the following
 
significant posts: he
 
was appointed Chief Executive
 
Officer
 
at Eurobank
 
A.D.
Beograd (2005-2008), Chairman of the
 
Executive Committee in the
 
Hellenic Banking Association (2020-2022)
 
where he had
been member since
 
2013, Vice
 
Chairman at Cardlink SA
 
(2013-2015), Member of
 
the BoD in Millennium
 
Bank, responsible for
Retail,
 
Private
 
Banking and
 
Business
 
Banking
 
(2003),
 
Head at
 
Barclays
 
Bank
 
PLC,
 
responsible
 
for
 
Retail
 
Banking,
 
Private
Banking and Operations (1990
 
-1997).
He holds an MA in Banking
 
and Finance from
 
the University
 
of Wales, UK
 
and a Bachelor Degree
 
in Business Administration
from the University
 
of Piraeus.
Kostas Vassiliou
 
-Deputy Chief Executive Officer
 
(CEO), Head of Corporate & Investment
 
Banking
-
Membership in Board Committees: None
-
Year of birth: 1972
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 356,617
Mr.
 
Vassiliou
 
holds several
 
other
 
posts in the
 
Eurobank
 
Group as
 
Chairman of the
 
BoD of Eurobank
 
Factors Single
 
Member
SA (since December 2018),
 
Member of the BoD
 
of Eurobank Equities
 
Single Member SA (since March
 
2015). He also serves as
Vice-Chairman of
 
the BoD
 
of Eurolife
 
FFH Insurance
 
Group Holdings
 
SA (since
 
January 2021), Eurolife
 
FFH Life
 
Insurance SA
(since December 2020) and Eurolife
 
FFH General Insurance
 
SA (since December 2020).
In
 
the
 
past,
 
Mr.
 
Vassiliou
 
had
 
also
 
the
 
following
 
significant
 
posts:
 
Country
 
Manager
 
for
 
Greece,
 
Cyprus
 
and
 
the
 
Balkans,
Mitsubishi
 
UFJ
 
Financial
 
Group,
 
London
 
(2000-2005)
 
and
 
Senior
 
Relationship
 
Manager,
 
Mitsubishi
 
UFJ
 
Financial
 
Group,
London (1998-2000).
He holds an MΒΑ from
 
Boston University,
 
USA and a BA in Business
 
Administration from
 
the Athens
 
University of Economics
and Business.
 
 
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Alice Gregoriadi-Independent Non-Executive Director
-
Membership in Board Committees: a) Audit Committee – Member, b) Remuneration Committee – Member,
 
c) Board
Digital and Transformation
 
Committee – Chairwoman
-
Year of birth: 1968
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: None
Mrs. Gregoriadi also serves
 
as an Affiliate Partner
 
– Management Consultant at True
 
North Partners
 
LLP,
 
London, UK and is
a Non-Executive Board Director at Climate
 
Governance Initiative
 
Greece.
 
In the past, Mrs.
 
Gregoriadi had also the
 
following significant
 
posts: Hellenic Corporation
 
of Assets & Participations
 
(HCAP),
Greece,
 
Non-Executive
 
Board
 
member,
 
Audit
 
Committee
 
member,
 
Corporate
 
Governance
 
and
 
Nominations
 
Committee
member (February
 
2017 – February
 
2021), JPMorgan, London, UK, various
 
posts as Managing Director
 
(February 2010
 
– May
2015), IBOS Board Director (April 2010 – August 2014), ABN
 
Amro Bank, Amsterdam, Netherlands & London, UK, various posts
as Managing
 
/
 
Executive
 
Director
 
(November
 
2001
 
 
December
 
2009),
 
Citibank NA,
 
London,
 
UK,
 
various
 
Senior
 
Executive
Director
 
posts (February
 
1994
 
 
August
 
2001),
 
Clearing
 
House
 
Automated
 
Payments
 
System
 
(CHAPS),
 
UK,
 
Board
 
Director
(June 1997 – July 2000).
She holds
 
an MBA from
 
the Manchester
 
Business School, UK (1991-1993),
 
including an MBA international
 
exchange program
from
 
the
 
E.J.Cox
 
School
 
of Management,
 
Texas,
 
USA
 
 
(1992),
 
an
 
Executive
 
Certification
 
on
 
Blockchain
 
for
 
business
 
from
University
 
College
 
London
 
(2019),
 
an
 
Executive
 
Certification
 
on
 
eCommerce
 
from
 
the
 
Darden
 
School
 
of
 
Business,
 
Virginia
University, USA (2000)
 
and a BSc in Business Administration from
 
the The American
 
College, Athens, (1987-1990).
Rajeev Kakar-Independent Non-Executive Director
-
Membership
 
in
 
Board
 
Committees:
 
a)
 
Audit
 
Committee
 
 
Member,
 
b)
 
Board
 
Risk
 
Committee
 
 
Chairman,
c)Nomination & Corporate Governance
 
Committee – Member
-
Year of birth: 1963
-
Nationality: Indian
-
Number of shares in Eurobank
 
Holdings: None
Mr. Kakar is a senior international
 
banker with 37 years
 
of financial services experience, and currently
 
also serves as a board
member
 
of several
 
Financial Institutions-
 
including Commercial
 
International
 
Bank (Egypt),
 
Gulf International
 
Bank Group
Board
 
(Bahrain),
 
Gulf International
 
Bank (Saudi
 
Arabia) and
 
is also
 
a Global
 
Advisory Board
 
member
 
at the
 
University
 
of
Chicago’s Booth School of Business. In the past Mr. Kakar has also
 
served as board member on several international financial
institutions/bank
 
boards
 
-
 
eg.,
 
as
 
Board
 
Member
 
of
 
Visa
 
International
 
CEEMEA
 
(United
 
Kingdom
 
2004-2006),
 
Global
Management
 
Board
 
member
 
of
 
Fullerton
 
Financial
 
Holdings
 
(Singapore
 
2006-2018),
 
Board
 
member
 
of
 
UTI
 
AMC
 
in
 
India
(2019-2024), Chairman
 
of the
 
BoD, Fullerton
 
Securities &
 
Wealth
 
Advisors (New
 
Delhi, India
 
2008-2017), board
 
Member of
Fullerton India Credit Company (India
 
2009-2017), Member of the Board of
 
Commissioners, Adira Dinamika Multi Finance Tbk,
subsidiary of Bank Danamon (Indonesia 2010-2013), etc.
Between 2006-2018, Mr. Kakar served as the Global Co-Founder
 
of Fullerton Financial Holdings (Singapore) - a wholly owned
subsidiary of Temasek
 
Holdings, Singapore.
 
In this
 
role,
 
he also
 
concurrently
 
served as
 
Fullerton’s
 
Global CEO
 
of Consumer
Banking, Regional CEO for
 
Central Europe,
 
Middle East and Africa, and also
 
as the Founder,
 
Managing Director and CEO of
Dunia Finance (Fullerton’s UAE subsidiary). Prior to 2016, he was
 
at Citibank for 20 years working across various countries and
held various senior
 
management positions, including,
 
his most recent
 
Citibank assignment where
 
he served
 
as the Regional
CEO & Division Executive for Citibank-Turkey,
 
Middle East and Africa until Jan 2006.
Mr. Kakar holds an MBA, Finance
 
& Marketing from the
 
Indian Institute of Management, Ahmedabad (India) and a Bachelor
of Technology,
 
Mechanical Engineering from
 
the Indian Institute of Technology
 
(India).
Bradley Paul Martin-Non-Executive
 
Director
-
Membership in Board Committees: None
-
Year of birth: 1959
-
Nationality: Canadian
-
Number of shares in Eurobank
 
Holdings: 122,500
In the past Mr. Martin has also served
 
as: Vice President of Fairfax
 
Financial Holdings (1998 - 2024), Vice President, Strategic
Investments
 
of Fairfax
 
Financial
 
Holdings (2012
 
- 2024),
 
Member
 
of the
 
BoD, Bank
 
of Ireland
 
(2013-2017), Chief
 
Operating
Officer (COO), Fairfax
 
Financial Holdings (2006-2012) and Partner,
 
Torys LLP law firm (before
 
1998).
Mr. Martin also
 
serves as Non-Executive
 
Director,
 
of AGT Food
 
and Ingredients Inc. and as a
 
Non-Executive Director,
 
of Blue
Ant Media Inc
He holds a ΒΑ from Harvard University,
 
USA and an LLB from the University
 
of Toronto,
 
Canada.
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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GOVERNANCE STATEMENT
 
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Jawaid Mirza-Independent Non-Executive Director
-
Membership in
 
Board Committees:
 
a) Audit Committee
 
– Vice
 
Chairman, b) Nomination
 
& Corporate
 
Governance
Committee – Member, c) Remuneration
 
Committee – Member
-
Year of birth: 1958
-
Nationality: Canadian
-
Number of shares in Eurobank
 
Holdings: None
Mr. Mirza is a strong proponent and practitioner
 
of international corporate governance
 
and brings with him over 35 years of
diversified
 
experience
 
and
 
a
 
solid
 
track
 
record
 
in
 
all
 
facets
 
of
 
financial
 
and
 
risk
 
management,
 
technology,
 
mergers
 
and
acquisitions,
 
business turnarounds and operation
 
management.
 
In the past,
 
Mr. Mirza
 
was also the lead
 
Director with Commercial
 
International Bank of Egypt,
 
as well as Independent
 
Non-
Executive
 
Director
 
with
 
South
 
Africa
 
Bank
 
of
 
Athens
 
(Johannesburg).
 
He
 
also
 
served
 
Commercial
 
Bank
 
of
 
Egypt
 
(CIB)
 
as
Managing
 
Director
 
&
 
CEO
 
of
 
Consumer
 
Banking
 
and
 
Group
 
COO.
 
Over
 
the
 
years,
 
Mr.
 
Mirza
 
has
 
worked
 
with
 
global
institutions like Citibank and ABN
 
AMRO Bank Ltd
 
where he held several senior positions as CFO European Region, Managing
Director
 
and
 
Chief
 
Operating
 
Officer
 
for
 
Global
 
Private
 
Banking,
 
Asset
 
Management
 
and
 
New
 
Growth
 
Markets,
 
Chief
Financial Officer for
 
Asian region including Australia/New Zealand and Middle
 
East.
 
Mr. Mirza led several
 
due diligences for
acquiring banks in Europe,
 
Asia, and Latin America.
 
Mr. Mirza
 
was also a member
 
of the
 
Top Executive
 
Group (TEG)
 
of ABN
AMRO Bank as well as member of the
 
Group Finance and Group COO Board.
 
Mr.
 
Mirza also
 
serves
 
as Non-Executive
 
Independent Director
 
of AGT
 
Food
 
& Ingredients
 
(Canada), IDRF
 
(Canada) and
 
as
Non-Executive Independent Director of Commercial
 
International Bank (CIB) (Egypt).
Mr.
 
Mirza
 
holds
 
various
 
business
 
management
 
courses
 
from
 
reputable
 
institutions
 
like
 
Queens
 
Business
 
school,
 
Wharton
Business school, Stanford Graduate School of Business and
 
is also a member of
 
the Institute of Corporate Directors, Canada.
 
Irene Rouvitha Panou-Independent Non-Executive
 
Director
-
Membership
 
in Board
 
Committees:
 
a)
 
Nomination
 
& Corporate
 
Governance
 
Committee
 
 
Chairwoman,
 
b)
 
Audit
Committee – Member, c) Remuneration
 
Committee - Member
-
Year of birth: 1958
-
Nationality: Cypriot
-
Number of shares in Eurobank
 
Holdings: None
Mrs. Rouvitha Panou is an accomplished international leader with over
 
three decades of cross-border
 
financial experience in
strategy,
 
governance,
 
audit,
 
and
 
organizational
 
transformation.
 
She
 
has
 
driven
 
sustainable
 
organizational
 
growth
 
by
developing and
 
implementing strategic
 
initiatives, leading
 
corporate
 
turnarounds, enhancing governance
 
frameworks,
 
and
fostering
 
innovation,
 
also contributing
 
to the
 
drastic
 
upgrade
 
and digital
 
evolution
 
of key
 
services
 
in Cyprus,
 
a country
 
of
strategic
 
importance
 
to
 
Eurobank.
 
Her
 
career
 
spans
 
across
 
Cyprus,
 
the
 
UK,
 
Greece,
 
Romania,
 
Australia,
 
and
 
the
 
USA,
demonstrating broad
 
international exposure
 
in banking and financial services.
In
 
the
 
past, she
 
was Chair
 
of
 
the
 
Board
 
of Cyta
 
(Cyprus’
 
leading integrated
 
electronic
 
communications
 
provider)
 
for
 
two
consecutive
 
tenures
 
(July
 
2016-July
 
2021),
 
Chair
 
of
 
the
 
Management
 
Committee
 
of
 
the
 
Pensions
 
&
 
Grants
 
Fund
 
of
 
the
Personnel
 
of Cyta (January
 
2019-July 2021),
 
Chair of the
 
Board of
 
the Cyprus
 
Development
 
Bank following
 
its privatization
(September 2008-April 2014) and
 
Board Member of the Cyprus Employers and
 
Industrialists Federation (May 2020-July 2021).
She
 
was
 
Independent
 
Non-Executive
 
Director
 
and
 
Board
 
Committees
 
Chair/Member
 
of
 
the
 
Cyprus
 
Asset
 
Management
Company KEDIPES (March 2023-June 2024),
 
Alpha Bank subsidiaries in Romania, Cyprus and Greece
 
(November 2014-April
2020) and Vassiliko Cement
 
public company (February
 
2012-October 2014). She was Managing Director
 
of Laiki Bank Hellas
SA (April 2002-November 2006) and Group General Manager of Cyprus
 
Popular Bank (HSBC associate
 
bank) (January 2000-
November
 
2006)
 
also
 
serving,
 
among
 
others,
 
as
 
Group
 
Board
 
Director
 
and
 
Board
 
Member
 
of
 
the
 
Group’s
 
banking
subsidiaries in
 
Greece
 
and Australia.
 
Between
 
June 1984
 
and September
 
1991, she
 
worked
 
in Boston
 
USA, where
 
she held
senior positions in the field of management and
 
financial services consulting.
Mrs. Rouvitha Panou is also a committed board member
 
in academic and philanthropic organizations,
 
serving as a Member
of
 
the
 
Board
 
of
 
Trustees
 
of
 
the
 
UK-based
 
Stelios
 
Philanthropic
 
Foundation,
 
a
 
Member
 
of
 
the
 
International
 
Advisory
Committee
 
of
 
Komvos
 
Global
 
Hellenism
 
Network,
 
and
 
a
 
Member
 
of
 
the
 
Advisory
 
Council
 
of
 
the
 
School
 
of
 
Economics
 
&
Management
 
at
 
the
 
University
 
of
 
Cyprus,
 
focusing
 
on
 
integrating
 
financial
 
industry
 
objectives
 
into
 
academic
 
research
priorities. Her
 
leadership at
 
Cyta included
 
effecting
 
major M&A
 
activities and
 
driving key
 
digital transformation
 
projects—
such
 
as
 
the
 
early
 
rollout
 
of
 
5G
 
and
 
Fiber-To-The-Home
 
(FTTH)
 
technologies,
 
smart
 
city
 
initiatives,
 
and
 
significant
 
ESG
projects—contributing to the modernization
 
of Cyprus’ telecommunications infrastructure.
She graduated
 
from the
 
London School of
 
Economics, UK (B.Sc.
 
Economics, Metcalfe
 
Scholar) with
 
postgraduate studies
 
at
the University of Cambridge, UK (M.Phil.
 
Economics) and the Massachusetts
 
Institute of Technology, USA (M.Sc. Management,
Fulbright Scholar).
 
 
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Cinzia Basile-Independent Non-Executive Director
-
Membership in Board Committees:
 
a) Board Risk Committee
 
– Member, b) Remuneration Committee – Chairwoman,
c) Board Digital and Transformation
 
Committee – Member
-
Year of birth: 1971
-
Nationality: Italian and British
-
Number of shares in Eurobank
 
Holdings: None
Mrs Basile
 
is the
 
Chairperson of
 
Nikko
 
Asset Management
 
Europe
 
(NAME),
 
one
 
of Asia’s
 
largest
 
asset managers;
 
she
 
also
Chairs the HR Advisory Committee and is a member of the
 
Risk & Stewardship Committee.
 
Mrs
 
Basile is
 
a
 
highly
 
accomplished
 
financial
 
leader
 
with
 
deep
 
expertise
 
in
 
the
 
financial
 
sector,
 
asset
 
management,
 
and
strategic growth.
 
She serves as Chairman of My Community Bank, where
 
she has driven significant balance sheet
 
growth by
leveraging fintech solutions to promote financial
 
inclusion in underserved markets. In addition,
 
she is a
 
Non-Executive Director
at several
 
prominent financial institutions, including Zenith Global,
 
and Creditis Servizi Finanziari.
 
In the past, Mrs. Basile had also the following
 
significant posts: she set up and ran Credit Suisse AG’s Investment
 
Bank multi-
asset investment management business (Custom Markets) in the UK, Ireland and Luxembourg, Non-Executive Member
 
of the
BoD and Chair of the Operating
 
and Risk Committee of Credit Suisse Custom Markets, a sponsored
 
management company
of
 
Credit
 
Suisse
 
located
 
Luxembourg
 
(August
 
2011
 
 
August
 
2017),
 
Non-Executive
 
Member
 
of
 
the
 
BoD
 
and
 
Chair
 
of
 
the
Operating of Custom Markets plc and Custom Markets QIAF,
 
sponsored management companies of Credit Suisse located in
Ireland (August
 
2011 – August
 
2017), Non-Executive
 
Member of the
 
BoD and Chair
 
of the
 
Operating
 
and Risk Committee
 
of
Custom Markets QIAF a subsidiary of Credit Suisse located in Ireland
 
(August 2011 – August 2017).
She is a
 
fellow at the CSaP's Dowling Policy Fellowship, Cambridge University. The fellowship's mission is to help public policy-
making address
 
the
 
major challenges
 
of the
 
21st century
 
by drawing
 
more
 
effectively
 
on the
 
best research,
 
evidence,
 
and
expertise. Fellows
 
share a
 
common interest
 
in advancing policies
 
that support
 
science, innovation,
 
and entrepreneurship
 
in
the public interest.
She holds a Juris Doctor Degree from the
 
University of Rome “La Sapienza”, Italy and she was awarded a Thesis
 
Scholarship
(derivative instruments), London School
 
of Economics, UK.
John Arthur Hollows-Independent, Non-Executive
 
Director
-
Membership in Board Committees: a) Board Risk Committee – Vice
 
Chairman, b) Board Digital and Transformation
Committee – Member, c) Remuneration
 
Committee - Member
-
Year of birth: 1956
-
Nationality: British
-
Number of shares in Eurobank
 
Holdings: None
Mr. Hollows served
 
for 26 years in the KBC Group as Member of the Boards of Directors, KBC Bank and KBC Insurance (2009-
2022),
 
Member
 
of
 
the
 
Executive
 
Committee,
 
KBC
 
Group
 
(2009-2022),
 
Chair
 
of
 
the
 
Board
 
of
 
Directors
 
of
 
Československá
obchodní banka, a.
 
s. (ČSOB) and CEO
 
(2014-2022), Member
 
of the Board
 
of Directors of KBC
 
Group N.V.,
 
Group Chief Risk
Officer
 
(2010-2014),
 
CEO,
 
Central
 
and Eastern
 
Europe
 
and Russia
 
(2009-2010),
 
Senior
 
General
 
Manager,
 
Banking,
 
Central
Europe Business
 
Unit, KBC Group,
 
Brussels (2006-2009), CEO,
 
Kereskedelmi
 
es Hitelbank Rt.,
 
Hungary (2003-2006), General
Manager,
 
Asia
 
Pacific,
 
KBC
 
Bank
 
N.V.
 
(1999-2003),
 
General
 
Manager,
 
Shanghai
 
Branch,
 
KBC
 
Bank
 
N.V.
 
(1997-1999)
 
and
Commercial Banking Head, Hong Kong Branch,
 
Kredietbank N.V (1996).
In the past. Mr. Hollows served at Barclays
 
Bank PLC as Chief
 
Manager, Taipei Branch (1991-1995), Head of International Trade
Services,
 
London
 
(1989-1991),
 
Manager,
 
Export
 
Finance
 
Department,
 
London
 
(1986-1989),
 
Corporate
 
Manager,
 
Watford
Branch (1984-1986), Assistant
 
Manager, Cost Control Unit, General Manager’s Office (1982-1984)
 
and Graduate Trainee (1978-
1982). He has also served as Chair, European Council of Commerce and Trade (1994-1995) and Deputy Chair, British Exporters
Association (1989-1991).
He holds a Master of Arts, Sidney Sussex College, Cambridge (law and economics).
Burkhard Eckes - Independent, Non-Executive
 
Director
-
Membership
 
in
 
Board
 
Committees:
 
a)
 
Audit
 
Committee
 
 
Chairman,
 
b)
 
Nomination
 
and
 
Corporate
 
Governance
Committee – Member, c) Board
 
Risk Committee - Member
-
Year of birth: 1960
-
Nationality: German
-
Number of shares in Eurobank
 
Holdings: None
Mr. Eckes served
 
for more than 30 years at PwC
 
as Senior Advisor, PwC Germany
 
and EMEA (Europe, Middle East and Africa)
(2022 - 2023), Global Banking and Capital
 
Markets (BCM) ESG Leader and member of the Global Financial Services (FS) ESG
Leadership Team
 
(2019 - 2022), responsible for
 
BCM activities in ESG consulting globally,
 
EMEA BCM Leader and member
 
of
the EMEA FS Leadership Team (2017 - 2022), responsible for
 
BCM client relationships, projects and strategy in consulting and
 
 
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assurance
 
services,
 
including
 
development
 
and
 
implementation
 
of
 
banking
 
strategies,
 
business
 
models,
 
supervisory
 
and
regulatory requirements
 
and practices,
 
governance,
 
risk management,
 
accounting and reporting
 
best practices,
 
ESG, bank
restructuring
 
and bank
 
transformation
 
advice,
 
Member
 
of the
 
Global
 
BCM Leadership
 
Team
 
(2009
 
- 2022),
 
German BCM
Leader
 
and member
 
of the
 
German
 
FS Leadership
 
Team
 
(2009 -
 
2018), responsible
 
for
 
consulting and
 
assurance
 
services,
including HR,
 
people development
 
and statutory
 
audits of
 
large German
 
banks, Chair
 
of the
 
Global Banking
 
International
Accounting Group (2002 - 2023) and Partner
 
(1996 - 2022).
Mr. Eckes
 
also serves as Member
 
of the Supervisory Board
 
of Bayerische
 
Landesbank (Munich) (since May 2024),
 
as Member
of the
 
Supervisory
 
Board and
 
Chair of
 
the
 
Audit Committee
 
of Bank
 
Pictet &
 
Cie (Europe)
 
AG, Frankfurt
 
(since June
 
2023)
and as Member of the Supervisory Board
 
and Chair of the Risk and Audit Committee of Solaris SE, Berlin (since
 
April 2023).
n the
 
past, Mr.
 
Eckes has
 
served as
 
Chair of
 
the Banks
 
Working
 
Party of
 
Accountancy Europe
 
(former
 
FEE -
 
Fédération
 
des
Experts Comptables Européens) (2015 - 2022), Chair of the Banking Committee (Bankenfachausschuss
 
– BFA) of the German
Institute of Public
 
Auditors (Institut der Wirtschaftsprüfer - IDW) (2017 - 2022) and member of the BFA (2008 - 2022), Member
of
 
the
 
European
 
Parlamentary
 
Financial
 
Services
 
Forum
 
-
 
EPFSF
 
(2012
 
-
 
2023)
 
and
 
Member
 
of
 
the
 
Steering
 
Committee
Sustainability of IDW (2020 - 2022).
He
 
holds
 
an
 
MBA
 
from
 
the
 
University
 
of
 
Saarland,
 
Saarbrücken
 
(1986)
 
and
 
is
 
a
 
Certified
 
Public
 
Auditor
 
(German
Wirtschaftsfprüfer)
 
(1996).
Evan Kotsovinos-Independent, Non-Executive
 
Director
-
Membership
 
in
 
Board
 
Committees:
 
a)
 
Board
 
Risk
 
Committee
 
 
Member,
 
b)
 
Board
 
Digital
 
and
 
Transformation
Committee – Member
-
Year of birth: 1979
-
Nationality: Greek
-
Number of shares in Eurobank
 
Holdings: None
Mr. Kotsovinos also serves as Vice President of Engineering and General
 
Manager, Google, New York (since November 2022).
In the past. Mr. Kotsovinos served
 
at American Express, New York
 
as Senior Vice President and Global Head of Infrastructure,
(2019-2022). He also held senior management positions at Morgan Stanley: Asia
 
Chief Information Officer,
 
Hong Kong (2018-
2019),
 
Head
 
of
 
Asia
 
Infrastructure,
 
China
 
CIO,
 
Hong
 
Kong
 
and
 
Shanghai
 
(2014-2018),
 
Head
 
of
 
Infrastructure
 
Hungary,
Executive Director,
 
Budapest (2013-2014), EMEA CTO of Infrastructure,
 
Global CTO of Cloud, Executive
 
Director (2012-2014).
He holds
 
a Masters
 
in Finance
 
(2010-2012), London
 
Business School,
 
a PhD
 
in Computer
 
Science (2001
 
-2004), University
 
of
Cambridge and a BSc in Computer Science (1997-2001), University
 
of Crete.
The Board is served
 
by a competent and experienced company secretary,
 
the short CV of whom is outlined below:
Ioannis Chadolias-Secretary to the BoD,
 
Head of Group Company Secretariat
 
-
Secretary to the following Board Committees: a)
 
Remuneration Committee, b) Nomination & Corporate Governance
Committee, c) Board Digital and Transformation
 
Committee
-
Year of birth: 1970
-
Nationality: Hellenic
-
Number of shares: 30,000
Mr. Chadolias is responsible to lead the
 
Group Company Secretariat unit and provide
 
effective company secretarial
 
support
to
 
the
 
Board
 
and
 
Board
 
Committees
 
of
 
Eurobank
 
and
 
Eurobank
 
Holdings
 
as
 
well
 
as
 
to
 
their
 
most
 
important
 
Executive
Committees, ensuring compliance with corporate
 
law and regulations and maintaining
 
effective corporate
 
governance
 
and
internal policy framework.
With
 
nearly three
 
decades of
 
experience
 
in corporate
 
governance,
 
compliance, and
 
financial services,
 
he previously
 
served
as Deputy
 
Company Secretary
 
of Eurobank
 
and Eurobank
 
Holdings (2016–2021)
 
and led the
 
Group Corporate
 
Governance
Division (2009–2016).
 
Earlier roles
 
at Eurobank
 
include Subsidiaries
 
Control
 
and Compliance
 
Manager (2006–2009).
 
Before
joining
 
the
 
Bank,
 
he
 
held
 
managerial
 
positions,
 
among
 
others,
 
at
 
Megatrust
 
(a
 
stockbroker
 
company-member
 
of
Interamerican
 
group)
 
and
 
Cosmote
 
(the
 
largest
 
telecommunications
 
group
 
in
 
Greece),
 
while
 
he
 
began
 
his
 
career
 
as
 
an
auditor and business consultant at PwC.
He holds an MSc in Project Analysis, Finance, and Investment from
 
the University of York
 
and a Bachelor's in Economics from
the Athens University
 
of Economics and Business and several
 
professional qualifications.
5.4
Re-election, Cessation, and Independence of Board
 
Members
There
 
are
 
no
 
limitations
 
on
 
the
 
re-election
 
or
 
cessation
 
of
 
Directors
 
in
 
the
 
Articles
 
of
 
Association
 
of
 
Eurobank
 
Holdings
(HoldCo)
 
and Eurobank.
 
In
 
cases
 
where
 
a Board
 
member’s
 
term
 
has expired,
 
the
 
Board
 
retains
 
the
 
authority
 
to continue
managing
 
and
 
representing
 
the
 
HoldCo/Bank
 
without
 
immediately
 
replacing
 
the
 
expired
 
members,
 
provided
 
that
 
the
remaining members
 
constitute more
 
than half
 
of the
 
original number
 
of members
 
before
 
the lapse
 
event
 
and, in any
 
case,
are not fewer
 
than three (3).
 
 
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As stipulated in the
 
Articles of Association
 
of HoldCo and Eurobank,
 
and in compliance with
 
Law 4548/2018, the
 
Board may
consist
 
of
 
three
 
(3)
 
to
 
fifteen
 
(15)
 
members.
 
Additionally,
 
in
 
accordance
 
with
 
Law
 
4706/2020
 
on
 
corporate
 
governance,
independent non-executive
 
directors are
 
appointed by
 
the
 
General
 
Meeting and must
 
constitute at
 
least one-third
 
(1/3) of
the total number of Board members
 
(rounded to the nearest integer),
 
with a minimum of two (2) independent non-executive
directors.
For the
 
year 2024, the Nominations and Corporate
 
Governance Committees of HoldCo and Eurobank,
 
in their meetings held
on May 28, 2024, and November 26, 2024, reviewed
 
the independence criteria in accordance with Law 4706/2020, European
Commission
 
Recommendation
 
2005/162/EC,
 
and
 
the
 
Executive
 
Committee
 
Act
 
of
 
the
 
Bank
 
of
 
Greece
 
No.
 
224/23.12.2023
(BoG ECA 224/2023),
 
which incorporated the Joint ESMA
 
and EBA Guidelines
 
on the Assessment of
 
the Suitability of Members
of
 
the
 
Management
 
Body
 
and
 
Key
 
Function
 
Holders.
 
The
 
Committees
 
concluded
 
that
 
the
 
Independent
 
Non-Executive
Directors meet the
 
applicable independence criteria.
5.5
Division of responsibilities
At the top level
 
of Eurobank Holdings
 
and Eurobank,
 
there
 
is a clear separation
 
of responsibilities between
 
governance
 
and
executive
 
management.
 
The
 
Chairperson
 
oversees
 
the
 
governance
 
functions,
 
while
 
the
 
Chief Executive
 
Officer
 
(CEO)
 
and
Deputy CEOs
 
manage the
 
operational
 
and managerial
 
aspects of
 
the
 
organization.
 
Importantly,
 
the
 
roles
 
of Chairperson
and CEO are held by different
 
individuals, ensuring a balanced and effective
 
leadership structure.
5.5.1
Chairperson
The
 
Chairperson
 
of
 
the
 
HoldCo
 
and
 
Eurobank
 
Boards
 
is
 
a
 
Non-Executive
 
Director
 
and
 
does
 
not
 
concurrently
 
serve
 
as
Chairperson of the Risk or Audit Committees. Elected by all Board members,
 
including Independent Non-Executive Directors,
in accordance
 
with Law 4548/2018
 
and the Articles
 
of Association, the
 
Chairperson presides
 
over
 
Board meetings,
 
ensuring
their effective
 
organization and operation.
The Chairperson’s
 
responsibilities include:
Organizing and coordinating the work
 
of the Board.
Setting the Board’s agenda and ensuring adequate time
 
for discussions, particularly
 
on strategic matters.
Promoting a culture of open-mindedness and constructive
 
dialogue.
Facilitating and promoting good relationships
 
among Board members and ensuring the effective
 
contribution of all
Non-Executive Directors.
Ensuring that Directors receive
 
accurate, timely,
 
and clear information and that
 
their developmental
 
needs are met
to enhance Board effectiveness.
Maintaining continuous communication
 
with representatives
 
of the
 
Ministry of Finance,
 
the Bank
 
of Greece
 
(BoG),
and other public authorities.
Ensuring that the Board
 
as a whole has a satisfactory understanding of shareholder
 
views.
Ensuring
 
effective
 
communication
 
with
 
all
 
shareholders,
 
promoting
 
fair
 
and
 
equitable
 
treatment,
 
and
 
fostering
constructive dialogue to understand their perspectives.
Working
 
closely
 
with
 
the
 
CEO
 
and
 
the
 
Corporate
 
Secretary
 
to
 
prepare
 
Board
 
meetings
 
and
 
ensure
 
that
 
Board
members are fully informed.
It is noted that the Board
 
has not appointed a Senior Independent Director (SID).
5.5.2
CEO
The CEO of HoldCo and Eurobank is responsible for the development and execution of strategy in
 
alignment with the Group's
vision.
 
As
 
the
 
leader
 
of
 
the
 
organization,
 
the
 
CEO
 
is
 
accountable
 
for
 
driving
 
the
 
achievement
 
of
 
the
 
Group’s
 
goals
 
and
objectives, ensuring effective
 
implementation of strategic
 
initiatives and operational
 
excellence.
5.5.3
Executive Directors
The
 
Executive
 
Directors of
 
HoldCo and
 
Eurobank,
 
including the
 
CEO and
 
Deputy CEOs,
 
are responsible
 
for
 
the
 
day-to-day
management and oversight of the
 
Group, as well as for executing its strategy,
 
as defined by the Board. Their
 
responsibilities
include:
Regularly consulting with Non-Executive Directors
 
to assess the appropriateness of the
 
implemented strategy.
Providing
 
updates
 
to
 
the
 
Board,
 
in
 
collaboration
 
with
 
senior
 
managers,
 
regarding
 
market
 
conditions
 
and
 
other
developments affecting
 
HoldCo and Eurobank.
Promptly informing
 
the Board,
 
either jointly
 
or individually in
 
writing, by submitting
 
a report with
 
assessments and
proposals, in the event
 
of crisis situations or anticipated risks that may impact the
 
financial position of HoldCo and
Eurobank.
The CEO and Deputy CEOs fulfill their duties in
 
accordance with the Internal Governance
 
Control Manuals (IGCMs) of HoldCo
and
 
Eurobank,
 
which
 
are
 
endorsed
 
by
 
their
 
respective
 
Boards.
 
These
 
IGCMs
 
provide
 
a
 
comprehensive
 
framework
 
for
 
the
 
 
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governance,
 
direction,
 
and supervision
 
of HoldCo
 
and Eurobank,
 
ensuring compliance
 
with legal
 
and regulatory
 
corporate
governance standards.
5.5.4
Non-Executive Directors
The
 
Non-Executive
 
Directors
 
are
 
responsible
 
for
 
promoting
 
and safeguarding
 
the
 
interests
 
of HoldCo
 
and Eurobank
 
as a
whole. Their key
 
responsibilities include:
Monitoring and evaluating the strategy
 
and its execution, as well as assessing the achievement
 
of objectives.
Ensuring effective oversight
 
of executive members, including monitoring and evaluating
 
their performance.
Reviewing
 
and
 
providing
 
feedback
 
on
 
proposals
 
submitted
 
by
 
the
 
Executive
 
Directors,
 
based
 
on
 
available
information.
Approving, revising, and overseeing
 
the implementation
 
of the Group-level
 
remuneration
 
policy.
The Non-Executive Directors
 
have the authority to request, in accordance
 
with HoldCo’s and Eurobank’s
 
internal procedures,
direct
 
engagement
 
with
 
senior
 
management.
 
This
 
is
 
facilitated
 
through
 
regular
 
presentations
 
by
 
department
 
heads
 
and
service leaders.
The
 
Non-Executive
 
Directors
 
convene
 
at
 
least
 
once
 
a year,
 
or as
 
deemed
 
appropriate,
 
without
 
the
 
presence
 
of executive
members, to evaluate
 
their performance.
 
These meetings
 
do not constitute a formal
 
Board body or committee.
 
In 2024, the
Non-Executive Directors of HoldCo and Eurobank
 
held meetings on February
 
29,
 
2024, and October 23, 2024.
HoldCo and Eurobank encourage
 
Non-Executive Directors to remain well
 
-informed on all matters
 
handled by the respective
Board.
The Independent
 
Non-Executive Directors
 
are required
 
to submit their
 
own reports,
 
either
 
individually or collectively,
 
to the
Annual or Extraordinary General
 
Meeting of Shareholders, in addition to the
 
reports presented by the
 
Board.
5.6
Operation of the
 
Board
The operation of the Board, including its meeting protocols, decision-making processes, and procedural
 
guidelines, is defined
in the Internal Governance Control Manual (IGCM) of HoldCo and Eurobank. This manual, endorsed by the respective Boards,
is
 
designed
 
to
 
adhere
 
to
 
legal
 
and
 
regulatory
 
corporate
 
governance
 
standards,
 
while
 
also
 
incorporating
 
the
 
relevant
provisions of the
 
Articles of Association of HoldCo and Eurobank.
5.6.1
Board Meetings
The Board convenes
 
regularly on a quarterly basis and on an ad hoc basis whenever
 
required by law or the needs of HoldCo
and Eurobank. Each
 
year,
 
within the third
 
quarter of the
 
preceding year,
 
the Board
 
establishes an annual calendar
 
of Board
and
 
Committee
 
meetings,
 
along
 
with
 
an
 
annual
 
action
 
plan.
 
This
 
plan
 
is
 
adjusted
 
as
 
necessary
 
to
 
ensure
 
the
 
timely,
comprehensive,
 
and effective
 
execution
 
of responsibilities
 
and the
 
thorough
 
review
 
of all
 
matters
 
requiring
 
decisions.
 
Any
updates
 
or
 
modifications
 
to
 
the
 
annual
 
calendar
 
are
 
promptly
 
communicated
 
to
 
all
 
Board
 
and
 
Committee
 
members
 
to
facilitate their
 
planning.
Board meetings
 
are convened
 
with a notice
 
period of at
 
least two (2)
 
business days or five
 
(5) business days if
 
the meeting
is held outside the registered office of HoldCo or Eurobank,
 
in accordance with Company Law 4548/2018. The invitation must
clearly state the
 
agenda items. If
 
the agenda
 
is not explicitly
 
stated, decisions
 
may only be
 
made if all Board
 
members are
present or represented and no objections are
 
raised regarding the
 
meeting’s convocation
 
and decision-making. Documents
submitted to the Board are
 
typically circulated along with the
 
agenda.
5.6.2
Dissemination of Information
The
 
Board utilizes
 
technological tools
 
with necessary
 
security specifications
 
to facilitate
 
real-time information
 
sharing and
connectivity for Board members.
The CEO and senior management are responsible for ensuring that Board members have access to all necessary information
required for
 
the performance
 
of their duties at any time.
5.6.3
Quorum in the Board Meetings
The
 
Board is
 
considered
 
to have
 
quorum and
 
may conduct
 
valid meetings
 
when at
 
least half
 
plus one
 
of its
 
members
 
are
present
 
or
 
represented.
 
The
 
number
 
of
 
present
 
or
 
represented
 
members
 
may
 
not
 
fall
 
below
 
three
 
(3),
 
and
 
any
 
resulting
fraction when determin
 
ing quorum is disregarded.
Board
 
decisions are
 
made by
 
an absolute
 
majority of
 
the
 
Directors present
 
or represented.
 
In the
 
event
 
of a
 
tie vote,
 
the
Chairperson does not have a casting vote.
5.6.4
Board Decisions and Minutes
Decisions are made following discussions that fully address
 
the agenda items, ensuring
 
that all members present are satisfied
with the deliberations.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Board
 
meeting
 
minutes
 
are
 
kept
 
by
 
the
 
Company
 
Secretary,
 
approved
 
at
 
subsequent
 
Board
 
meetings,
 
and signed
 
by
 
all
members
 
present.
 
Additionally,
 
the
 
drafting
 
and
 
signing
 
of
 
minutes
 
by
 
all
 
Board
 
members
 
or
 
their
 
representatives
 
is
considered equivalent to a formal
 
Board decision, even
 
in the absence of a preceding physical meeting.
5.6.5
Company Secretary
The Boards of HoldCo
 
and Eurobank are supported by
 
a capable, skilled, and experienced Company Secretary,
 
who ensures
adherence
 
to internal
 
procedures
 
and policies,
 
as well
 
as compliance
 
with relevant
 
laws and regulations,
 
thereby
 
enabling
the effective
 
and efficient operation
 
of the Boards.
The
 
Company Secretary
 
holds
 
a senior
 
management
 
position
 
and is
 
appointed or
 
dismissed by
 
the
 
Board,
 
based
 
on the
recommendation of the
 
Chairperson.
Serving as the head of the Group Company Secretariat, a unit
 
within Eurobank, the Company Secretary, in collaboration with
the Chairperson, is responsible for:
Ensuring prompt, transparent,
 
and comprehensive communication
 
with the Board and its Committees.
Managing the integration
 
of new Board and Committee members.
Organizing General
 
Meetings of Shareholders.
Facilitating communication
 
between shareholders
 
and the Board.
Facilitating communication
 
between the Board
 
and senior management.
Additionally,
 
the
 
Company
 
Secretary
 
provides
 
advice
 
to
 
the
 
Board,
 
through
 
the
 
Chairperson,
 
on
 
governance
 
matters,
ensuring adherence
 
to Board procedures.
All Board
 
members have
 
the right
 
to access
 
the advice
 
and services
 
of the
 
Company Secretary,
 
who is also
 
responsible for
facilitating their
 
orientation and supporting their professional
 
development.
5.7
Attendance of Board members
 
in the Board and Board
 
Committees
In accordance
 
with the
 
HoldCo/Bank Board
 
and Board
 
Committees Attendance
 
Policy
 
(please refer
 
to the
 
relevant section
in
 
this
 
report),
 
and
 
within
 
the
 
scope
 
of
 
the
 
HoldCo/Bank
 
Nomination
 
and
 
Corporate
 
Governance
 
Committee’s
 
(NomCo)
responsibility to regularly
 
monitor Board members'
 
attendance and assess
 
whether
 
escalation to
 
the Board
 
is necessary
 
in
cases of inadequate participation, the NomCo conducted reviews
 
of Directors' attendance on June 28, 2024, and December
16, 2024.
Furthermore,
 
in 2024,
 
the
 
average
 
attendance
 
rate
 
of Directors
 
of HoldCo
 
and Eurobank
 
at Board
 
and Board
 
Committee
meetings was as follows:
Company
Meetings
Average
 
ratio
 
of
Directors’ attendance
2024
2023
2024
2023
HoldCo
20
24
98.8%
96.4%
Bank
 
25
23
98.16%
96.3%
During 2024, at individual level, the
 
attendance of the Directors
 
to the Board, stood above
 
the 85% threshold.
 
In addition, it
is noted that
 
all Directors
 
with missed Board
 
attendances, provided
 
representation
 
proxies, leading
 
to an attendance
 
rate
(physical and under representation)
 
of 100%.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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In particular, the
 
Directors’ attendance rates
 
at the Board meetings
 
in 2024 were the
 
following:
Name
Eurobank Holdings Board
Eurobank Board
Eligible to
attend
Attended in person
(# and %)
Eligible
to
attend
Attended in person
(# and %)
Georgios
 
Zanias,
Chairperson,
 
Non-Executive
Director
20
20
100%
25
25
100%
Georgios
 
Chryssikos,
Vice-Chairperson,
 
Non-
Executive Director
1
11
11
100%
13
13
100%
Fokion
 
Karavias,
Chief Executive Officer
20
20
100%
25
25
100%
Stavros Ioannou,
Deputy Chief Executive Officer
20
20
100%
25
25
100%
Konstantinos
 
Vassiliou,
Deputy
 
Chief
 
Executive
Officer
20
20
100%
25
25
100%
Bradley Paul Martin,
Non-Executive Director
20
18
90%
25
24
96%
Rajeev Kakar,
Non-Executive Independent Director
20
19
95%
25
24
96%
Jawaid Mirza,
Non-Executive Independent Director
20
20
100%
25
24
96%
Alice
 
Gregoriadi,
Non-Executive
 
Independent
Director
20
20
100%
25
25
100%
Irene
 
Rouvitha
 
Panou,
Non-Executive
 
Independent
Director
20
20
100%
25
25
100%
Cinzia Basile,
Non-Executive Independent Director
20
20
100%
25
25
100%
Burkhard Eckes,
Non-Executive Independent Director
20
19
95%
25
25
100%
John
 
Arthur
 
Hollows,
Non-Executive
 
Independent
Director
20
19
95%
25
24
96%
Evangelos
 
Kotsovinos,
Non-Executive
 
Independent
Director
2
9
9
100%
12
12
100%
1
Mr. Georgios
 
Chryssikos decided not
 
to pursue renewal
 
of his term, therefore
 
he remained in
 
HoldCo/Bank BoDs until their
Annual General Meetings on 23.07.2024,
 
when the new
 
BoDs were appointed.
2
Mr. Evangelos Kotsovinos
 
was appointed as BoD member on 23.07.2024.
The
 
average
 
Director’s
 
attendance
 
rates
 
to
 
HoldCo’s
 
and
 
Eurobank’s
 
Board
 
Committees,
 
along
 
with
 
the
 
individual
attendance
 
rates
 
per
 
Board
 
Committee
 
are
 
presented
 
separately,
 
under
 
the
 
subsection
 
of
 
the
 
present
 
Corporate
Governance Statement,
 
referring
 
to the Board Committees.
 
5.8
Directorships of Board members
The
 
directorships
 
held
 
by
 
Board
 
members,
 
including significant
 
non-executive
 
commitments
 
to companies
 
and non-profit
organizations, are notified prior to appointment to the
 
Chairperson of the Nomination & Corporate Governance
 
Committee
(NomCo)
 
and/or
 
NomCo,
 
in
 
accordance
 
with
 
the
 
HoldCo
 
and
 
Bank
 
External
 
Engagements
 
Policy.
 
Additionally,
 
Board
members must notify the
 
Bank Group Company Secretariat of any changes to their
 
directorships as soon as they occur.
The
 
number of
 
directorships a
 
Board member
 
may hold
 
simultaneously is
 
regulated
 
by Article
 
83 of
 
Law 4261/2014.
 
Under
this provision, a Director
 
may not hold more than one of the
 
following combinations
 
of directorships at the same
 
time:
One (1) executive directorship with two
 
(2) non-executive directorships, or
Four (4) non-executive
 
directorships.
This restriction
 
does not apply
 
to directorships within
 
the Group.
 
Additionally,
 
the Bank
 
of Greece
 
(BoG), as the
 
competent
authority, may permit a Board
 
member to hold one (1) additional non-executive
 
directorship.
Furthermore,
 
directorships
 
in
 
organizations
 
that
 
do not
 
pursue
 
predominantly
 
commercial
 
objectives
 
are
 
not
 
counted for
regulatory purposes.
 
 
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As
 
part
 
of
 
the
 
Board’s
 
overall
 
effectiveness
 
assessment,
 
through
 
which
 
NomCo
 
annually
 
evaluates
 
the
 
knowledge,
 
skills,
experience,
 
and
 
contribution
 
of
 
both
 
individual
 
Board
 
members
 
and
 
the
 
Board
 
collectively,
 
the
 
directorships
 
of
 
Board
members were
 
reviewed for
 
2024. This review
 
confirmed that all Board members
 
comply with the provisions
 
of the Law.
5.8.1
HoldCo
 
and
 
Eurobank
 
Board
 
Members’
 
Directorships
 
(including
 
Directorships
 
within
 
Eurobank
 
Group)
 
as
 
at
31.12.2024
Georgios Zanias – Chairperson, Non-Executive
 
Director
Foundation for
 
Economic and Industrial Research (IOBE) – Board Member¹
Fokion
 
Karavias – Chief Executive
 
Officer
Hellenic Bank Association (HBA) – Vice
 
Chairman¹
Stavros Ioannou – Deputy Chief Executive
 
Officer
Grivalia Management Company S.A. – Non-Executive Director
Be-Business Exchanges S.A. of Business Exchanges Networks and Accounting and Tax
 
Services – Chairman²
Eurobank Cyprus Ltd – Non-Executive
 
Director
Eurobank Private Bank Luxembourg
 
S.A. – Non-Executive Director²
Eurobank Bulgaria AD – Non-Executive
 
Director, Supervisory Board²
Konstantinos Vassiliou
 
– Deputy Chief Executive Officer
Hellenic Exchanges – Athens Stock Exchange S.A. – Non-Executive
 
Director
Marketing Greece S.A. – Non-Executive
 
Director¹
Eurolife FFH General
 
Insurance Single Member S.A. – Vice
 
Chairman, Non-Executive Director³
Eurolife FFH Life
 
Insurance Single Member S.A. – Vice
 
Chairman, Non-Executive Director³
Eurolife FFH Insurance
 
Group Holdings S.A. – Vice
 
Chairman, Non-Executive Director³
Eurobank Equities Investment
 
Firm Single Member S.A. – Non-Executive Director²
Eurobank Factors Single
 
Member S.A. – Chairman²
Bradley Paul Martin – Non-Executive
 
Director
Blue Ant Media Inc. – Non-Executive Director
AGT Food and Ingredients
 
Inc. – Non-Executive Director
Rajeev Kakar – Non-Executive Independent Director
Gulf International Bank, Bahrain
 
– Non-Executive Director
Gulf International Bank, Kingdom of Saudi Arabia
 
– Non-Executive Director
Commercial International
 
Bank (CIB) – Non-Executive Director
Jawaid Mirza – Non-Executive Independent Director
AGT Food and Ingredients
 
Inc. – Non-Executive Director
Commercial International
 
Bank (CIB) – Non-Executive Director
Alice Gregoriadi – Non-Executive Independent Director
Hellenic Blockchain Hub – Non-Executive Director¹
Climate Governance
 
Initiative – Non-Executive Director
Cinzia Basile – Non-Executive Independent Director
Creditis Servizi Finanziari S.p.A. – Non-Executive Director
Brent Shrine Credit Union (trading name
 
My Community Bank) – Non-Executive Chair of the Board¹
Zenith Service S.p.A. – Non-Executive
 
Director
Nikko Europe Asset Management
 
– Chairperson, Non-Executive Director
Nikko AM Global Umbrella Fund – Chairperson,
 
Non-Executive Director
Fincentro Finance S.p.A. – Non-Executive
 
Director
Irene Rouvitha Panou – Non-Executive
 
Independent Director
Stelios Philanthropic Foundation
 
– Member of the Board of Trustees¹
 
 
 
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Burkhard Eckes – Non-Executive
 
Independent Director
Solaris SE – Non-Executive Member of the
 
Supervisory Board
Bank Pictet & Cie (Europe) AG – Non-Executive
 
Member of the Supervisory Board
Bayerische Landesbank – Non-Executive
 
Member of the Supervisory Board
John Hollows – Non-Executive
 
Independent Director
None
Evangelos Kotsovinos – Non-Executive
 
Independent Director
None
Explanatory Notes
¹ Organization that
 
does not pursue predominantly commercial
 
objectives.
² Company that belongs to HoldCo Group and,
 
along with directorships in other HoldCo Group companies, is considered one
(1) directorship for regulatory
 
purposes.
³
 
Company
 
that
 
belongs
 
to
 
Eurolife
 
FFH
 
Group
 
and,
 
along
 
with
 
directorships
 
in
 
other
 
Eurolife
 
FFH
 
Group
 
companies,
 
is
considered one (1) directorship for
 
regulatory purposes.
 
Company that
 
belongs to
 
Gulf International
 
Bank Group
 
and, along
 
with
 
directorships
 
in other
 
Gulf International
 
Bank
Group companies, is considered one (1) directorship
 
for regulatory purposes.
 
Company that belongs to Nikko Asset Management Group and, along with directorships in other Nikko Asset Management
Group companies, is considered one (1) directorship
 
for regulatory purposes.
 
Company that
 
belongs to
 
Columbus HoldCo
 
S.à.r.l.
 
Group and,
 
along with
 
directorships in
 
other
 
Columbus HoldCo
 
S.à.r.l.
Group companies, is considered one (1) directorship
 
for regulatory purposes.
5.9
Board Role and Responsibilities
The
 
principal duties
 
and responsibilities
 
of the
 
HoldCo/Bank’s Board
 
encompass a
 
wide range
 
of strategic,
 
oversight,
 
and
governance functions:
review,
 
guide, and approve the
 
strategy, major plans of action,
 
risk policy, business and restructuring
 
plans, and set
performance objectives,
monitor
 
performance
 
and
 
oversee
 
major
 
capital
 
expenditures,
 
acquisitions,
 
divestitures,
 
and
 
formation
 
of
 
new
entities, including special purpose vehicles,
ensure the availability of necessary financial
 
and human resources, as well
 
as an internal control system,
approve the
 
annual budget and monitor its implementation quarterly,
approve the
 
three-year business plan and monitor its implementation,
review
 
and approve
 
at least
 
annually the
 
risk strategy
 
and risk
 
appetite, ensuring
 
alignment with
 
overall
 
business
strategy and other
 
plans,
receive and discuss comprehensive
 
risk reports on a quarterly basis,
develop and deliver
 
objectives in agreed restructuring plans under
 
applicable laws,
provide oversight
 
to senior management and approve
 
corporate governance
 
practices and values,
set standards shaping corporate culture
 
and integrate desired culture into systems, policies,
 
and behaviors,
approve risk and capital
 
strategy and monitor CEO and Executive
 
Board implementation,
approve organization
 
chart and related policies as required by
 
law or internal processes,
ensure
 
rigorous
 
processes
 
for
 
monitoring
 
organizational
 
compliance
 
with
 
strategy,
 
risk
 
appetite,
 
laws,
 
and
regulations,
select, compensate, monitor, and replace
 
key executives as needed and oversee
 
succession planning,
align executive and board remuneration
 
with long-term interests of Group
 
and shareholders,
facilitate formal
 
and transparent board nomination
 
and election processes,
monitor and manage potential conflicts of interest among management, board,
 
and shareholders,
ensure integrity of accounting and financial reporting systems, including independent audit and control
 
systems,
review and monitor Non-Performing
 
Loans (NPL) and Non-Performing
 
Exposures (NPE) performance,
oversee disclosure and communication
 
processes,
determine appropriate level
 
of remuneration
 
for Board and Committees’ members
 
pending ratification,
address matters related
 
to new technologies and environmental
 
issues,
identify
 
and
 
engage
 
with
 
important
 
stakeholders,
 
understanding
 
their
 
interests
 
and
 
interactions
 
with
 
Group
strategy,
facilitate
 
open dialogue
 
with
 
stakeholders
 
and utilize
 
various
 
communication
 
channels
 
for
 
effective
 
engagement
and understanding.
 
 
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These
 
duties
 
collectively
 
contribute
 
to
 
the
 
effective
 
governance,
 
strategic
 
direction,
 
risk
 
management,
 
and
 
sustainable
growth of the
 
HoldCo/Bank and its operations.
5.10
Main issues the Board dealt with
 
during 2024
In 2024, the Boards of HoldCo and Eurobank
 
conducted a comprehensive review
 
of the corporate strategy,
 
the main risks to
the business, and the system
 
of internal controls.
The
 
main issues
 
addressed
 
by the
 
Boards
 
of Directors
 
of Eurobank
 
Holdings
 
(HoldCo)
 
and Eurobank
 
in 2024
 
included the
following:
5.10.1
Eurobank Holdings
a) Governance
Proposed to the Annual General
 
Meeting (AGM) the appointment of a new Board of Directors
 
due to the expiration
of the previous
 
Board’s term and the designation
 
of independent non-executive members.
Approved the
 
new composition of Board Committees and their
 
revised Terms
 
of Reference.
Convened the Shareholders’
 
General Meeting.
Discussed the 2023 annual evaluation of the
 
Board and Board Committees and reviewed
 
the Action Plan.
Reviewed the
 
attendance of Directors at Board
 
and Board Committee meetings.
Non-Executive Directors
 
approved
 
the CEO’s
 
performance
 
evaluation
 
for
 
2023 and his
 
financial and non-financial
objectives for 2024.
Approved key
 
governance policies,
 
including:
o
CEO Succession Planning Policy
o
Board of Directors Diversity
 
Policy
o
Board Nomination Policy
 
(also submitted to the AGM for
 
approval)
o
Board and Board Committees Evaluation Policy
o
Group Governance
 
Policy
o
Related Parties Transaction
 
Policy
o
Key Function Holders
 
Selection and Appointment Policy
o
Anti-Bribery and Corruption Policy
o
External Engagements Policy
o
Insider Dealing Guidelines
o
Conflict of Interest Policy
o
C-Level Succession Planning Policy
o
Senior Management Selection and Appointment
 
Policy
Addressed remuneration
 
matters, including:
o
Approval
 
by Non-Executive
 
Directors of
 
the Remuneration
 
Policy,
 
the
 
Variable
 
Remuneration
 
Framework,
and the Group Variable
 
Remuneration
 
Pool.
o
Proposal to
 
the AGM
 
for approval
 
of the
 
Board and
 
Board Committees'
 
fees for
 
Non-Executive Directors,
the Remuneration Policy
 
for Directors, the Remuneration
 
Report for 2023, and the distribution of net profits
to senior management and employees.
Approved HoldCo’s
 
Internal Governance
 
Control Manual.
Received regular updates on Board
 
Committee matters.
Approved the
 
Board and Board Committees’ calendar
 
for 2025.
Approved and submitted to the
 
AGM the appointment of auditors for
 
the financial year 2024.
Discussed the 2024 Supervisory Review
 
and Evaluation Process (SREP)
 
assessment.
b) Strategic Issues, Corporate,
 
and Other Actions
Discussed various strategy matters.
Approved a share capital increase following
 
the exercise of stock option rights and amended Article 5
 
of the Articles
of Association in accordance with Article
 
113(3) of Law 4548/2018.
Approved
 
(subject
 
to
 
AGM
 
approval)
 
the
 
dividend
 
distribution
 
for
 
2023,
 
in
 
line
 
with
 
the
 
approved
 
Dividend
Distribution Policy.
Approved
 
an increase
 
in the
 
aggregate
 
principal
 
amount of
 
notes
 
issued
 
under
 
the
 
Medium-Term
 
Notes
 
(EMTN)
program.
Approved the initiation of the merger process for the absorption of Eurobank Holdings by Eurobank (Project Square).
 
 
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c) Capital Adequacy
Approved the
 
2024 Internal Capital & Liquidity Adequacy Statements (CAS & LAS) as part
 
of the Internal Capital &
Liquidity Adequacy Assessment Process
 
(ICAAP & ILAAP 2024).
Approved the
 
Minimum Requirement for
 
Own Funds and Eligible Liabilities (MREL) Plan 2025-2027.
d) Business Monitoring
Approved the
 
2023 annual financial statements and the 2024
 
interim financial statements.
Approved the
 
Annual Budget 2025 and the Three
 
-Year
 
Business Plan (2025-2027), including an adverse scenario.
Discussed the
 
Annual Budget
 
2025
 
and the
 
Three-Year
 
Business Plan
 
(2025-2027),
 
including assumptions
 
for
 
the
adverse scenario.
Reviewed 2024 performance
 
versus budget.
Discussed business developments and liquidity.
Approved the
 
Business and Capital Plan Policy and discussed the
 
top-down Business and Capital Plan 2024-2026.
e) Risk Management and Internal Control
Approved the
 
Group Chief Risk Officer
 
succession plan.
Acknowledged
 
the
 
annual
 
regulatory
 
reports
 
of
 
Group
 
Compliance
 
and
 
Group
 
Internal
 
Audit
 
on
 
the
 
System
 
of
Internal Controls (SIC).
Reviewed
 
the Independent
 
Triennial
 
Evaluation of
 
the
 
System of
 
Internal Controls
 
(SIC) under
 
Bank of Greece
 
Act
2577.
Received updates on significant internal
 
audit and compliance issues.
Reviewed significant legal
 
and regulatory matters.
Approved the
 
Risk Appetite Framework
 
2024 and Risk Appetite Statements.
Approved the
 
Risk Identification and Materiality Assessment
 
(RIMA) Framework
 
and Reports.
Approved the
 
updated Funding Plan, the Leverage
 
Coverage Ratio
 
(LCR), and the Net Stable Funding Ratio (NSFR)
forecast plan (2024-2026).
Addressed various issues related to Basel Committee on Banking Supervision
 
(BCBS) standard No. 239 (BCBS 239),
including:
o
Discussed the action plan for
 
the On-Site Inspection (OSI).
o
Approved the establishment of the Internal Validation
 
Function for Risk Data Aggregation & Risk Reporting
(RRDAR) purposes and its Validation
 
Framework.
o
Approved the
 
BCBS 239 Overarching Framework.
o
Approved the
 
Data Governance
 
Deployment Plan.
Approved the
 
consolidated Pillar 3 Reports (capital
 
and risk management disclosures)
 
for 2023, Q1
 
2024, Q2 2024,
and Q3 2024.
Received updates on significant risk issues,
 
including the Group Chief Risk Officer’s
 
Annual Report for 2023.
Reviewed the
 
2023 Annual Activity Report of the Audit Committee before
 
submission to the AGM.
Approved new
 
and revised risk policies and plans, including:
o
Revised Non-Financial Risk Management Policy
o
Revised Group Liquidity Risk Policy
o
Revised Market & Counterparty Risk Policy
o
Interest Rate Risk in the Banking Book
 
(IRRBB) & Credit Spread Risk in the Banking Book
 
(CSRBB) Policy
o
Outsourcing Policy
f) Transformation
 
Project
Received regular updates on the
 
transformation
 
project.
5.10.2
Bank
a) Governance
Proposed to the Annual General
 
Meeting (AGM) the appointment of a new Board of Directors
 
due to the expiration
of the previous
 
Board’s term and the designation
 
of independent non-executive members.
Approved the
 
new composition of Board Committees and their
 
revised Terms
 
of Reference.
Convened the Shareholders’
 
General Meeting.
Discussed the 2023 annual evaluation of the
 
Board and Board Committees and reviewed
 
the Action Plan.
 
 
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Reviewed the
 
attendance of Directors at Board
 
and Board Committee meetings.
Non-Executive Directors
 
approved
 
the CEO’s
 
performance
 
evaluation
 
for
 
2023 and his
 
financial and non-financial
objectives for 2024.
Approved key
 
governance policies,
 
including:
o
CEO Succession Planning Policy
o
Board of Directors Diversity
 
Policy
o
Board Nomination Policy
 
(also submitted to the AGM for
 
approval)
o
Board and Board Committees Evaluation Policy
o
Group Governance
 
Policy
o
Related Parties Transaction
 
Policy
o
Key Function Holders
 
Selection and Appointment Policy
o
Anti-Bribery and Corruption Policy
o
External Engagements Policy
o
Insider Dealing Guidelines
o
Conflict of Interest Policy
o
C-Level Succession Planning Policy
o
Senior Management Selection and Appointment
 
Policy
o
AML/CFT and Sanctions Policy
Non-Executive Directors approved
 
the Remuneration
 
Policy, the
 
Variable Remuneration
 
Framework,
 
and the Group
Variable Remuneration
 
Pool.
Approved
 
the Board
 
and Board Committees'
 
fees for
 
Non-Executive Directors
 
and the distribution
 
of net profits
 
to
senior management and employees,
 
which were subsequently submitted to the
 
AGM for approval.
Reviewed the
 
implementation of the Group
 
Subsidiary Board Remuneration
 
Policy during 2023.
Approved the
 
Bank’s Internal Governance
 
Control Manual.
Approved the establishment of the Wealth Management Unit
 
and the revised Eurobank Group Organizational Chart.
Received regular updates on Board
 
Committee matters.
Approved the
 
Board and Board Committees’ calendar
 
for 2025.
Addressed remuneration
 
matters, including variable remuneration and remuneration
 
increases for senior executives
of international subsidiaries.
Approved and submitted to the
 
AGM for approval
 
the appointment of auditors for
 
the financial year 2024.
Received updates from
 
international banking subsidiaries.
Approved credit
 
facilities to related parties.
b) Strategic Issues, Corporate,
 
and Other Actions
Discussed various strategy matters.
Approved the
 
updated Group Investment
 
and Group Divestment Policies.
Approved
 
an increase
 
in the
 
aggregate
 
principal
 
amount of
 
notes
 
issued
 
under
 
the
 
Medium-Term
 
Notes
 
(EMTN)
program.
Approved
 
the
 
merger
 
of
 
the
 
Bank
 
with
 
“ADEXA
 
MONOPROSOPI
 
ANONYMI
 
ETAIREIA
 
DIACHEIRISIS
 
KAI
EKMETALLEFSIS AKINITON”.
Approved the initiation of the merger process for the absorption of Eurobank Holdings by Eurobank (Project Square).
Project Hermione: Discussed
 
the Hellenic Bank transaction and approved
 
the Mandatory Tender
 
Offer (MTO).
Project Hermione II: Approved
 
the acquisition of shares in Hellenic Bank and Demetra.
Project Hermione III:
 
Approved the
 
acquisition of an additional stake in Hellenic Bank.
Approved the
 
signing of a binding agreement for the
 
sale and transfer of 95% of the
 
mezzanine and junior notes of
the Leon Securitization.
Approved strategic
 
investments in private equity funds and the creation
 
of a Venture Banking Unit to support these
initiatives.
Approved Arbitration
 
Agreements and authorizations.
Approved the
 
closure of the Representative
 
Office in Moscow,
 
Russia, and ratified related authorizations.
Approved the
 
sale of eight (8) real estate properties
 
(Praktiker portfolio).
 
 
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c) Capital Adequacy
Approved the
 
2024 Internal Capital & Liquidity Adequacy Statements (CAS & LAS) as part
 
of the Internal Capital &
Liquidity Adequacy Assessment Process
 
(ICAAP & ILAAP 2024).
Approved the
 
securitization of the
 
Bank’s receivables from
 
business and other
 
loan portfolios
 
(Leon) and approved
synthetic securitizations (Wave
 
V and Wave VI).
Approved the
 
Minimum Requirement for
 
Own Funds and Eligible Liabilities (MREL) Plan 2025-2027.
Discussed the Deferred
 
Tax Credit
 
(DTC) acceleration
 
plans.
d) Business Monitoring
Approved
 
the
 
2023
 
annual
 
consolidated
 
financial
 
statements
 
and
 
the
 
2024
 
interim
 
consolidated
 
financial
statements.
Approved the
 
Annual Budget 2024 and the Three
 
-Year
 
Business Plan (2024-2026), including an adverse scenario.
Discussed the
 
Annual Budget
 
2025
 
and the
 
Three-Year
 
Business Plan
 
(2025-2027),
 
including assumptions
 
for
 
the
adverse scenario.
Approved the Group’s
 
Non-Performing Exposures
 
(NPE) Targets for
 
2024-2026 and the NPE Management Strategy.
Reviewed significant subsidiary
 
activities and strategic priorities.
Discussed 2024 performance versus
 
budget.
Reviewed business developments
 
and liquidity.
e) Risk Management and Internal Control
Approved the
 
Group Chief Risk Officer
 
succession plan.
Acknowledged
 
the
 
annual
 
regulatory
 
reports
 
of
 
Group
 
Compliance
 
and
 
Group
 
Internal
 
Audit
 
on
 
the
 
System
 
of
Internal Controls (SIC).
Reviewed
 
the Independent
 
Triennial
 
Evaluation of
 
the
 
System of
 
Internal Controls
 
(SIC) under
 
Bank of Greece
 
Act
2577.
Received updates on significant internal
 
audit issues.
Reviewed compliance updates, including the
 
Anti-Money Laundering Business Risk Assessment and the Compliance
Risk Assessment.
Received updates on significant legal and regulatory
 
matters.
Approved the
 
Risk Appetite Framework
 
2024 and Risk Appetite Statements.
Approved the
 
Risk Identification and Materiality Assessment
 
(RIMA) Framework
 
and Reports.
Approved the
 
updated Funding Plan, the Leverage
 
Coverage Ratio
 
(LCR), and the Net Stable Funding Ratio (NSFR)
forecast plan (2024-2026).
Addressed various issues related to Basel Committee on Banking Supervision
 
(BCBS) standard No. 239 (BCBS 239),
including:
o
Discussed the action plan for
 
the On-Site Inspection (OSI).
o
Approved the establishment of the Internal Validation
 
Function for Risk Data Aggregation & Risk Reporting
(RRDAR) purposes and its Validation
 
Framework.
o
Approved the
 
BCBS 239 Overarching Framework.
o
Approved the
 
Data Governance
 
Deployment Plan.
Approved the
 
consolidated Pillar 3 Report (capital and risk management disclosures)
 
for 2023.
Received updates on credit and NPE-related
 
issues.
Reviewed significant risk issues,
 
including the Group Chief Risk Officer’s
 
Annual Report for 2023.
Reviewed the
 
2023 Annual Activity Report of the Audit Committee before
 
submission to the AGM.
Approved new
 
and revised risk policies, including:
o
Non-Financial Risk Management Policy
o
Group Liquidity Risk Policy
o
Market & Counterparty Risk Policy
o
Interest Rate Risk in the Banking Book
 
(IRRBB) & Credit Spread Risk in the Banking Book
 
(CSRBB) Policy
o
Outsourcing Policy
Approved the
 
appointment of the Head of Group
 
Internal Audit (Group Chief Audit Executive).
 
 
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f) Transformation
 
Project
Received regular updates on the
 
transformation
 
project.
5.10.3
Board Strategy Day
 
In addition to
 
the formal
 
meetings focused
 
on Eurobank’s
 
annual budget and three
 
-year business plan,
 
the Board
 
holds an
annual strategy
 
meeting, known
 
as the
 
Board Strategy
 
Day.
 
This meeting
 
is separate
 
from the
 
regular Board
 
of Directors’
meetings and is conducted in an informal setting, without
 
the recording of formal
 
minutes.
The purpose of the
 
Board Strategy Day is to allow
 
Board members the
 
time and flexibility to engage in in-depth discussions
and deliberations
 
on the top
 
strategic initiatives
 
that are
 
critical to Eurobank’s
 
growth
 
and competitive positioning
 
among
its peers.
During the
 
most recent
 
Board Strategy
 
Day,
 
held on
 
September 26
 
and 27,
 
2024, various
 
strategic
 
issues were
 
discussed.
Following
 
the meeting, a memorandum
 
was issued summarizing the key discussions.
5.11
Board and Board Committees overall
 
effectiveness
 
assessment
5.11.1
Board and Board Committees Evaluation
In
 
accordance
 
with
 
the
 
HoldCo/Bank
 
Board
 
and
 
Board
 
Committees
 
Evaluation
 
Policy
 
(Section
 
B4),
 
the
 
HoldCo/Bank
Nomination and
 
Corporate
 
Governance
 
Committee (NomCo)
 
is responsible
 
for
 
evaluating the
 
structure, size,
 
composition,
and
 
performance
 
of
 
the
 
Board
 
and
 
its
 
Committees
 
and
 
making
 
recommendations
 
for
 
necessary
 
changes.
 
The
 
NomCo
oversees the annual self-evaluation
 
of the Board’s and Committees' effectiveness
 
(Internal Evaluation), typically using a self-
assessment questionnaire as the
 
primary tool.
For
 
the
 
2024 Internal
 
Evaluation, all
 
thirteen (13)
 
Board
 
members
 
participated
 
by completing
 
anonymous self-assessment
questionnaires,
 
which were
 
administered
 
via Diligent’s
 
secure
 
web-based
 
platform.
 
These
 
questionnaires
 
covered
 
various
areas, including:
Strategy oversight
Engagement with management
Risk management
Board composition and dynamics
Chairperson’s role
Secretarial support
Effectiveness of
 
Board Committees
Key Findings of the Internal Evaluation
The results
 
indicated that
 
the Boards
 
of HoldCo and Eurobank
 
continued to function
 
effectively
 
in 2023, maintaining a
 
high
level of performance
 
similar to the 2022 evaluation.
Strategy Oversight
Board members
 
expressed a
 
positive impression
 
of the
 
Board’s role
 
in strategy,
 
particularly regarding
 
discussions
on major investments and transactions,
 
which were viewed
 
as robust and well-structured.
Relationship with Management
The Board’s relationship
 
with management remained strong,
 
with clear delineation of roles between
 
the Board and
executive leadership.
Strategic HR and Remuneration
The
 
Board
 
demonstrated
 
strong
 
oversight
 
of
 
banking
 
culture,
 
ensuring
 
alignment
 
with
 
corporate
 
values
 
and
governance principles.
Risk Governance and Internal
 
Control
The Board maintained high standards
 
in risk governance
 
and internal control.
Key strengths
 
included robust
 
oversight
 
of internal
 
controls,
 
conflict of interest
 
policies, internal
 
audit, and conflict
of interest management.
Board Profile and Composition
The Board was recognized
 
for its adequate knowledge, skills, experience,
 
and diversity.
Key strengths included international
 
experience, as well as an appropriate
 
size and structure.
 
 
 
 
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Board Functioning and Dynamics
The Board demonstrated
 
robust annual agenda planning, with well
 
-established and consistent procedures.
Board discussions included constructive reviews
 
and challenges, fostering effective
 
decision-making.
Board Chairperson's Role
The Chairperson’s
 
leadership was recognized as a key
 
factor in the Board’s
 
overall
 
effectiveness and success.
Board Secretarial Support
Board
 
members
 
highlighted
 
the
 
effectiveness
 
of
 
operational
 
support,
 
particularly
 
in
 
the
 
quality
 
of
 
materials
submitted by management and the preparation
 
of meeting minutes.
Opportunities for further
 
enhancement
While the evaluation
 
was overwhelmingly positive,
 
some areas for enhancement
 
were identified:
Further enhancing the
 
Board’s strategic focus
 
to provide greater
 
long-term direction.
Strengthening the
 
Board’s oversight
 
of digital transformation
 
initiatives.
Improving the monitoring of
 
subsidiary performance, ensuring strategic
 
alignment across the
 
Group.
The main conclusions of the Internal Evaluation regarding Board Committees have been
 
integrated into the relevant sections
detailing their functioning and operations.
5.11.2
Assessment
 
of
 
the
 
knowledge,
 
skills
 
and
 
experience
 
(KSE)
 
of
 
the
 
Board
 
collectively
 
as
 
well
 
as
 
the
 
KSE
 
and
contribution of individual Board members.
In
 
accordance
 
with
 
the
 
HoldCo/Bank
 
Board
 
and
 
Board
 
Committees
 
Evaluation
 
Policy
 
(see
 
the
 
relevant
 
section
 
in
 
this
Statement), the
 
NomCo is responsible
 
for assessing
 
the knowledge,
 
skills, and experience
 
(KSE) of the
 
Board collectively,
 
as
well as the KSE and contribution of individual Board
 
members, and reporting to the
 
Board accordingly.
5.11.3
Individual Evaluations
The individual
 
evaluations (assessment
 
of the
 
Board Chairperson,
 
Non-Executive Directors
 
(NEDs), and Executive
 
Directors)
consider
 
the
 
status
 
of
 
the
 
member
 
(executive,
 
non-executive,
 
independent),
 
participation
 
in
 
committees,
 
specific
responsibilities/projects undertaken,
 
time commitment, behavior,
 
and the application of
 
knowledge and experience.
A. Assessment of the Board
 
Chairperson
The Board Chairperson’s
 
evaluation is part of the
 
Internal Evaluation and is conducted by
 
all other Board
 
members through
the Board and Board Committees’
 
Self-Evaluation Questionnaire.
The 2024 evaluation
 
of the HoldCo/Bank Board Chairperson
 
remained very strong,
 
consistent with the 2022 evaluation.
B. Assessment of the Non-Executive
 
Directors’ (NEDs) Contribution to the
 
Board (Excluding the Chairperson)
The Board Chairperson is responsible for
 
conducting the assessment of NEDs' contributions and presenting the results to the
NomCo.
The assessment process
 
follows these
 
steps:
NomCo approves the
 
NEDs’ self-evaluation questionnaire.
The questionnaire is distributed to the NEDs, and responses remain strictly confidential, accessible only to
 
the Board
Chairperson or designated individuals.
The
 
Board
 
Chairperson
 
conducts
 
confidential
 
one-on-one
 
interviews
 
with
 
each
 
NED,
 
using
 
the
 
self-evaluation
questionnaire as a reference.
The Board Chairperson
 
presents an overall
 
report on the findings to the
 
NomCo.
The Board Chairperson’s views on NEDs’ performance, knowledge, skills, and experience are
 
discussed in the NomCo,
particularly during the (re)appointment and
 
succession planning of Board members.
For the
 
2023 annual assessment, the Board Chairperson
 
led the evaluation
 
of the NEDs' contribution using a self-evaluation
questionnaire consisting of 10 questions focused
 
on five key areas:
Contribution to overall
 
Board profile and skillset
Board participation and quality of contributions to
 
deliberations
Punctuality and attendance
Team spirit and demeanor
Independent thinking and constructive challenge
 
 
 
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The 2024
 
annual assessment demonstrated
 
that the
 
NEDs adequately meet
 
expectations, effectively
 
fulfilling their
 
roles as
Directors of HoldCo/Bank.
C. Executive Directors’ Performance
 
Evaluation
The evaluation
 
of Executive
 
Directors, including
 
the CEO
 
and Deputy CEOs,
 
follows
 
a structured
 
process involving
 
the CEO,
the
 
NomCo,
 
and
 
the
 
Board
 
Remuneration
 
Committee
 
(RemCo).
 
This
 
annual
 
evaluation
 
is
 
based
 
on
 
qualitative
 
and
quantitative Key Performance
 
Indicators (KPIs) approved
 
by the Non-Executive Directors.
For
 
the
 
CEO’s evaluation,
 
the
 
RemCo proposes
 
KPIs related
 
to CEO
 
remuneration,
 
which are
 
then
 
submitted to
 
the
 
Non-
Executive
 
Directors
 
for
 
approval.
 
The
 
CEO's
 
performance
 
is
 
assessed
 
based
 
on
 
these
 
approved
 
KPIs,
 
and
 
the
 
results
 
are
communicated to the CEO and considered
 
in determining remuneration.
5.11.4
Collective Suitability Assessment
 
In 2024,
 
alongside the
 
Board of
 
Directors’
 
performance
 
evaluation,
 
an assessment
 
of the
 
Board’s collective
 
suitability was
conducted
 
in
 
accordance
 
with
 
the
 
Joint
 
ESMA/EBA
 
Guidelines
 
on
 
the
 
assessment
 
of
 
the
 
suitability
 
of
 
members
 
of
 
the
management body and key function
 
holders (EBA/GL/2021/06). This assessment
 
was supported by the NomCo.
The
 
evaluation
 
examined
 
whether
 
the
 
Board
 
collectively
 
possesses
 
the
 
necessary
 
knowledge,
 
skills,
 
and
 
experience
 
to
understand the
 
business model, strategy,
 
risks, and governance
 
-related matters.
 
The assessment
 
confirmed that
 
the Board
is collectively suitable to effectively
 
address these areas.
The evaluation
 
also identified potential
 
areas for
 
improvement
 
in specific business lines
 
and products, various
 
geographies
and subsidiaries,
 
and risk
 
management,
 
particularly
 
regarding
 
cybersecurity
 
and outsourcing
 
risks. It
 
was suggested
 
that
initiatives could be considered to address
 
these observations
 
and ensure alignment with HoldCo/Bank strategic
 
goals.
To
 
enhance
 
understanding
 
in
 
these
 
areas,
 
presentations
 
at
 
the
 
Board
 
and
 
Board
 
Committees
 
level,
 
along with
 
targeted
external training and internal sessions,
 
will continue to play a central role
 
in strengthening the Board’s
 
expertise.
5.12
 
Directors’ Induction and Continuous Professional
 
Development
 
In accordance
 
with the
 
Directors’
 
Induction
 
and Continuous
 
Professional
 
Development
 
Process,
 
Mr.
 
Evangelos Kotsovinos,
who joined
 
the Board
 
in 2024,
 
underwent a
 
comprehensive
 
Induction Program
 
designed to achieve
 
several
 
key objectives,
as outlined in Section B8.
Upon his appointment, Mr. Kotsovinos:
Received
 
a
 
Manual
 
of
 
Obligations
 
detailing
 
his
 
main
 
responsibilities
 
towards
 
the
 
Supervisory
 
Authorities
 
and
HoldCo/Bank, including local regulations
 
and Board procedures.
Attended meetings
 
and presentations
 
by Key
 
Executives
 
of HoldCo/Bank,
 
providing
 
a comprehensive
 
overview
 
of
the organization.
As
 
part
 
of
 
the
 
continuous
 
professional
 
development
 
framework,
 
in
 
2024,
 
Board
 
members
 
participated
 
in
 
formal
 
training
sessions on:
Challenger Banks and the Competitive
 
Landscape
Developments and challenges in the
 
new AML supervisory framework
Corporate Sustainability Reporting Directive
 
(CSRD)
Additionally, Board
 
members engaged in in-house meetings and discussions on Strategy,
 
Business Planning, and Budgeting.
They
 
received
 
regular updates,
 
reports, and
 
presentations
 
from
 
senior management
 
on operational
 
and strategic
 
targets,
market developmen
 
ts, and updates on risk, audit, compliance, financial, human resources,
 
legal, and regulatory matters.
Board members
 
also received
 
regular and ad-hoc
 
research and
 
economic bulletins from
 
Eurobank's Economic
 
Analysis and
Financial Markets Research.
6.
Board Committees
The Boards
 
of HoldCo and
 
Eurobank are
 
assisted in carrying
 
out their
 
duties by Board
 
Committees, to which they
 
delegate
specific responsibilities.
The HoldCo/Bank Board
 
Committees include:
Audit Committees (ACs)
Board Risk Committees (BRCs)
Remuneration
 
Committees (RemCos)
Nomination Committee (NomCo)
Bank Board Digital & Transformation
 
Committee (BDTC)
 
 
 
 
 
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6.1
Governance and Operations
 
of Board Committees
6.1.1
Board Committees’ members
The members of HoldCo/Bank
 
Board Committees are appointed by the respective
 
Board, following
 
a recommendation from
the NomCo and in accordance with the
 
applicable legal and regulatory framework.
The tenure
 
of Committee members
 
coincides with the
 
tenure of the
 
respective Board,
 
with the option
 
for renewal.
 
However,
total service on the
 
Committees must not exceed nine (9) years.
6.1.2
Board Committees’ Terms
 
of Reference (ToR)
The
 
ToR
 
of each
 
Board
 
Committee outlines
 
its purpose,
 
responsibilities,
 
and modus
 
operandi.
 
It is
 
reviewed
 
annually and
revised if necessary unless
 
significant changes require an
 
earlier revision. The ToR is approved by the Board and
 
made publicly
available on the HoldCo or Bank website.
6.1.3
Board Committees’ meetings
The minimum number of annual meetings
 
for each Board Committee is defined in its ToR.
Only
 
Committee
 
members
 
have
 
the
 
right
 
to
 
attend
 
meetings,
 
though
 
other
 
individuals,
 
such
 
as
 
Management
 
members,
external auditors, and
 
external advisors, may
 
be invited when
 
appropriate and
 
necessary.
 
The number
 
of invitees is kept
 
to
a minimum to preserve the
 
efficiency and effectiveness
 
of the meeting.
Members
 
may
 
attend
 
meetings
 
remotely
 
via
 
video
 
or
 
audio
 
conference.
 
A
 
mandatory
 
minimum
 
attendance
 
requirement
applies,
 
as
 
set
 
out
 
in
 
the
 
Board
 
and
 
Board
 
Committees’
 
Attendance
 
Policy
 
(please
 
refer
 
to
 
the
 
relevant
 
section
 
in
 
this
Statement).
6.1.4
 
Quorum in the Board Committees’
 
Meetings
A quorum is established when more than half of the
 
Committee members are present or represented,
 
provided that at least
three (3) members are present, including the Chairperson or, in the case of HoldCo/Bank ACs and BRCs,
 
the Vice Chairperson.
Each Committee member
 
may validly represent
 
only one other
 
Committee member.
 
Representation cannot
 
be assigned to
individuals outside the Committee.
6.1.5
Board Committees’ Decisions
Resolutions are validly adopted by an absolute majority of
 
the members present
 
or represented.
In the event
 
of a tie, the
 
Chairperson (or in their
 
absence, the Vice
 
Chairperson for
 
HoldCo/Bank ACs and BRCs)
 
or the most
senior Independent
 
Non-Executive Director
 
present (based
 
on tenure)
 
for HoldCo/Bank
 
RemCos, NomCos, and
 
Bank BDTC,
has the casting vote.
The Board is informed
 
whenever
 
an AC decision is not reached unanimously.
Minutes may be drawn up and signed by circulation by
 
all Committee members, which is equivalent to a valid decision, even
if no formal meeting takes place.
6.1.6
Board Committees’ Secretary and Minutes
Each
 
HoldCo/Bank
 
Board
 
Committee
 
appoints
 
its
 
Secretary,
 
who
 
reports
 
to
 
the
 
Group
 
Company
 
Secretariat
 
and
collaborates with the
 
Committee Chairperson and other
 
relevant parties.
The Secretary is responsible
 
for:
Recording the proceedings
 
and decisions of the Committee meetings.
Listing the names of attendees and documenting action
 
plans and follow-ups.
Issuing extracts of minutes as required.
Disseminating decisions, actions, and follow
 
-ups to the relevant parties.
6.1.7
Board Committees’ Performance
 
Evaluation
The performance
 
of Board Committees is evaluated annually, in line with the Board and
 
Board Committees Evaluation Policy
(please refer to the
 
relevant section in this Statement).
6.2
Audit Committee
 
The primary function
 
of the HoldCo/Bank Audit Committee
 
(AC) is to assist the respective
 
Board in discharging its oversight
responsibilities primarily relating to:
the
 
review
 
of the
 
adequacy of
 
the
 
Internal Control
 
and Risk
 
Management
 
systems and
 
the
 
compliance
 
with rules
and regulations monitoring process,
4
 
HoldCo/Bank ACs’ Terms
 
of Reference may be
 
found at the
 
HoldCo/Bank websites (
www.eurobankholdings.gr
 
&
www.eurobank.gr
).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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the
 
review
 
of
 
the
 
financial
 
reporting
 
process
 
and
 
satisfaction
 
as
 
to
 
the
 
integrity
 
of
 
the
 
HoldCO’s
 
Financial
Statements, also taking into account the provisions
 
of L. 5164/2024,
the External Auditors’ selection,
 
performance and independence,
the effectiveness
 
and performance
 
of the Internal Audit and of the Compliance
 
function.
 
In addition, in the context
 
of AC’s responsibility to safeguard External Auditors’ independence, the AC ensures that
 
the nature
of non-audit services, prior to their being undertaken
 
by the External Auditors, has been reviewed
 
and approved as required
and that there
 
is proper
 
balance between
 
audit and non-audit work
 
in accordance
 
with Group’s
 
/ Bank’s policy on
 
External
Auditors’ Independence.
6.2.1
AC Membership/Composition
The HoldCo/Bank’s ACs are Committees
 
consisted exclusively by Board
 
members and their compositions have
 
been approved
by the General
 
Meetings of the Shareholders (as per the
 
legal framework),
 
following the
 
recommendation of the
 
NomCos to
the
 
Boards.
 
The
 
Chairperson
 
of the
 
Committees
 
is appointed
 
by
 
the
 
members
 
of the
 
Committees,
 
while the
 
Committee’s
members may also appoint a Vice
 
Chairperson.
 
All AC members have
 
sufficient knowledge in the
 
field of HoldCo/Bank’s activities and the
 
necessary skills and experience
 
to
carry out their
 
duties and meet the requirement
 
of established knowledge and experience in auditing and/or accounting.
The ACs consist of five (5)
 
independent non-executive Directors of
 
the Board. In particular, the HoldCo/Bank’s AC composition
is outlined below:
AC Chairperson:
Burkhard Eckes,
Non-Executive Independent Director of the
 
Board
AC Vice-Chairperson:
Jawaid Mirza,
Non-Executive Independent Director of the
 
Board
AC Members:
Irene Rouvitha Panou,
Non-executive Independent Director of the
 
Board
Rajeev Kakar
,
Non-Executive Independent Director of the
 
Board
Alice Gregoriadi,
Non-Executive Independent Director of the
 
Board
It
 
is
 
noted
 
that
 
in
 
line
 
with
 
the
 
provisions
 
of
 
article
 
44
 
of
 
law
 
4449/2017,
 
as
 
in
 
force,
 
and
 
further
 
to
 
the
 
decision
 
of
 
the
HoldCo/Bank’s
 
Annual
 
General
 
Meetings
 
of
 
Shareholders
 
as
 
of
 
23.07.2024
 
regarding
 
the
 
recomposition
 
of
 
the
 
Audit
Committees and more specifically regarding their type, composition and term of office; and the BoDs’ decision of 23.07.2024
regarding the membership of the AC, following the relevant recommendations by the NomCos of28.05.2024, the ACs decided
on their constitution and on the
 
appointment of their Chairman.
 
Compared to
 
the previous
 
ACs’ composition
 
and following
 
the recomposition
 
of the
 
ACs on
 
23.07.2024,
 
the ACs’
 
members
increased
 
from
 
four
 
(4) to
 
five
 
(5) members,
 
with Ms.
 
Alice
 
Gregoriadi
 
being the
 
new
 
member
 
of the
 
ACs.
 
In addition,
 
Mr.
Burkhard
 
Eckes
 
(previously
 
Vice-Chairperson
 
of
 
the
 
ACs)
 
swapped
 
his
 
AC
 
status
 
with
 
Mr.
 
Jawaid
 
Mirza
 
(previously
Chairperson of the ACs) and
 
was appointed Chairperson
 
of the ACs, while Mr. Jawaid
 
Mirza was appointed
 
Vice-Chairperson
of the ACs.
6.2.2
AC Meetings
The
 
HoldCo/Bank’s ACs
 
meet at
 
least eight
 
(8) times
 
per year
 
or more
 
frequently,
 
as circumstances
 
require, report
 
on their
activities to the HoldCo/Bank’s Boards on a quarterly basis and submit the minutes of their meetings and the annual Activity
Reports (before their
 
submission to the HoldCo/Bank Shareholders’
 
Annual General Meeting) to the HoldCo/Bank’s
 
Boards.
 
Apart
 
from
 
the
 
AC
 
members,
 
the
 
BRC’s
 
members
 
may
 
also
 
attend
 
AC
 
sessions
 
when
 
common
 
issues
 
are
 
discussed
 
(e.g.
compliance risk
 
assessment).
 
The
 
Chairperson of
 
the
 
AC
 
may also
 
invite to
 
the
 
meetings other
 
executives
 
of the
 
Group
 
or
external advisors or experts, as deemed appropriate.
6.2.3
Attendance to the AC Meetings
During 2024 the attendance details for
 
the Audit Committee were
 
as follows:
Company
Meetings
Average
 
ratio
 
of
Directors’ attendance
2024
2023
2024
2023
HoldCo
15
17
97%
100%
Bank
 
14
16
98%
100%
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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The Directors’
 
individual attendance rates at the
 
AC meetings in 2024 were
 
the following:
Name
Eurobank Holdings AC
Eurobank AC
Eligible to attend
Attended in person
(# and %)
Eligible to
attend
Attended in person
(# and %)
Burkhard Eckes,
AC Chairperson
15
14
93%
14
14
100%
Jawaid Mirza,
 
AC Vice-Chairperson
15
15
100%
14
14
100%
Irene Rouvitha Panou,
AC member
15
15
100%
14
14
100%
Rajeev Kakar,
 
AC member
15
14
93%
14
13
93%
Alice Gregoriadi,
AC member
7
7
100%
7
7
100%
It is noted
 
that in 2024,
 
Mr. B.
 
Eckes provided
 
representation
 
proxy for
 
his missed meeting
 
in HoldCo’s
 
AC and Mr.
 
R. Kakar
provided representation proxies for his missed meetings
 
in HoldCo/Bank’s ACs, leading
 
their overall attendance rate (physical
and under representation) at
 
100% in HoldCo/Bank’s ACs.
6.2.4
AC’s Performance
 
Evaluation
At
 
the
 
2024
 
self-evaluation
 
conducted
 
by
 
the
 
AC,
 
its
 
members
 
expressed
 
satisfaction
 
with
 
the
 
committee's
 
structure,
effectiveness
 
and
 
leadership.
 
They
 
commented
 
on
 
the
 
AC's
 
efficient
 
use
 
of
 
time
 
and
 
scheduling
 
and
 
the
 
well-structuring
meetings that
 
ensure
 
critical issues
 
are addressed
 
appropriately.
 
The
 
Chairperson of
 
the
 
AC
 
was praised
 
for
 
his ability
 
to
ensure continuity and strong guidance during the transition and to encourage critical discussions and inclusive participation.
The
 
evaluation
 
also
 
highlighted
 
opportunities
 
for
 
further
 
enhancement
 
Members
 
suggested
 
expanding
 
the
 
Committee’s
mandate
 
to
 
include
 
sustainability
 
oversight,
 
given
 
its
 
growing
 
importance
 
in
 
regulatory
 
and
 
strategic
 
discussions.
Strengthening
 
coordination
 
with subsidiary
 
audit committees
 
and addressing
 
cybersecurity
 
and data
 
privacy with
 
regular
updates and
 
improved
 
controls
 
were
 
also highlighted as
 
possible priorities.
 
Finally,
 
leveraging
 
technology and
 
analytics to
enhance risk identification, mitigation,
 
and audit processes remains another
 
focus area
6.2.5
ACs’ Activity in 2024
For 2024, ACs
 
have amongst others:
Eurobank Holdings
Decided on their constitution/reconstitution
 
and the appointment of their
 
Chairman.
Reviewed and approved
 
the Compliance Mandate.
Approved the
 
annual plans of Internal Audit and Compliance and monitored their
 
progress.
Reviewed
 
and
 
discussed
 
reports
 
related
 
to
 
Internal
 
Audit
 
and
 
Compliance,
 
including
 
quarterly
 
reports
 
from
 
the
Internal Audit and Compliance functions.
Discussed the progress
 
of actions taken to resolve
 
Internal Audit findings.
Received updates on various internal
 
control, legal, and regulatory
 
issues.
Ensured that an annual evaluation of the System of
 
Internal Controls (SIC) for 2023 was performed and documented
by Internal Audit. This report, along with the AC’s assessment, was further
 
submitted to the Board of Directors (BoD)
and subsequently to the Bank of Greece (BoG) as required.
In line with
 
the BoG Governors
 
Act 2577/2006,
 
acknowledged the
 
annual Group
 
Compliance report
 
on compliance
activities for 2023. This
 
report, along with the AC’s
 
assessment, was further
 
submitted to the BoD and subsequently
to BoG as required.
During
 
the
 
first
 
quarter
 
of
 
2024,
 
discussed
 
and
 
submitted
 
to
 
the
 
Board
 
Risk
 
Committee
 
(BRC)
 
and
 
BoD
 
for
acknowledgment, the independent triennial Evaluation
 
of the System of Internal Controls
 
(SIC) conducted by Grant
Thornton (Independent Evaluation) in accordance
 
with BoG Act 2577/2006. The Independent Evaluation,
 
along with
the AC’s assessment,
 
was submitted to BoG as required.
Reviewed and submitted to the
 
BoD for approval
 
the revised Related
 
Party Transactions
 
Policy.
Reviewed
 
and,
 
depending
 
on
 
the
 
case,
 
ratified,
 
approved,
 
or
 
approved
 
and
 
submitted
 
to
 
the
 
BoD
 
for
approval/information:
o
The revised
 
MiFID II Product Governance
 
Policy.
o
The Group
 
Anti-trust Compliance Policy.
o
The revised
 
Policy for Reporting Illegal or
 
Unethical Conduct or Violations
 
of European Union Law.
o
The revised
 
Anti-Bribery and Corruption Policy.
o
The Policy
 
for the Prevention
 
and Detection of Market Abuse.
o
The Insider Dealing Guideline.
 
 
 
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o
The revised
 
Conflict of Interest Policy.
o
The revised
 
Code of Conduct and Ethics.
In the context of
 
the Policy for Reporting Illegal or Unethical Conduct
 
or Violations of European Union Law, approved
and submitted to the BoD for
 
approval the appointment
 
of the Report Receiving & Monitoring Officer
 
(RRMO) and
the assistant RRMO.
Discussed financial results with Management, Internal
 
Audit, and External Auditors.
Reviewed and cleared the financial
 
statements and other financial reports
 
and trading updates
 
prior to their release.
Discussed with
 
Management the
 
implementation
 
of corrective
 
actions to recommendations
 
made by
 
Internal and
External Auditors and Regulatory Authorities.
Assessed
 
the
 
effectiveness,
 
objectivity,
 
and
 
independence
 
of
 
the
 
External
 
Auditors
 
for
 
the
 
financial
 
year
 
2023,
discussed the
 
results of
 
their evaluation
 
with Management
 
and Internal
 
Audit, and communicated
 
the final
 
results
to the Board and the
 
External Auditors.
Proposed
 
to the
 
Board
 
and the
 
Annual General
 
Meeting (AGM)
 
the
 
appointment
 
of the
 
External Auditors
 
for
 
the
financial year 2024.
Discussed and approved the
 
Global Group Audit and Assurance
 
Fees for
 
2024.
Approved
 
the External
 
Auditors’ Independence
 
Policy and monitored,
 
in line with
 
this policy,
 
the non-audit services
provided by the
 
External Auditor in 2024.
Reviewed and approved
 
the updated External Auditors Tendering
 
Policy and Procedure.
Reviewed:
o
The eligibility of audit firms for
 
the statutory audit versus IT delivery
 
sourcing for strategic
 
IT projects.
o
The five-year
 
rolling plan (2025-2029) regarding the
 
eligibility of audit firms for the statutory audit of Eurobank
Ergasias
 
Services
 
and Holdings
 
Group,
 
as well
 
as potential
 
conflicts of
 
interest
 
with
 
eligible
 
audit firms.
 
This
review was conducted in accordance with Greek Law 4449/2017,
 
EU Regulation 537/2014, and the requirements
of the
 
International
 
Code of
 
Ethics for
 
Professional
 
Accountants issued
 
by the
 
International
 
Ethics Standards
Board for Accountants (IESBA).
Initiated the External Auditors’
 
tendering process for
 
the Group statutory audit of 2027.
Assessed the
 
performance
 
of the
 
Internal Auditor
 
and the
 
Head of
 
Compliance/Anti-Money
 
Laundering Reporting
Officer for
 
2023.
Received updates on the
 
progress of the Annual Budget.
In accordance with the provisions
 
of Law 2533/1997,
 
reviewed reports
 
on substantial stock transactions by HoldCo’s
Directors and General
 
Managers that meet the
 
criteria set in Law 2533/1997 and notified the Board.
Approved and submitted to the
 
Board for further
 
submission to the AGM the
 
annual AC Activity Report for 2023.
Discussed the Annual AC Plan for
 
2025.
Participated in Board Risk Committee
 
(BRC) meetings, during which discussions included:
o
Accounting policies, including hedge accounting policy.
o
Progress reports on the
 
Corporate Sustainability Report Directive
 
(CSRD) Program Implementation.
o
Various
 
risks, including non-financial risks, climate-related
 
and environmental
 
risks, and the Environmental
 
and
Social Governance
 
(ESG) Strategy.
Eurobank
Decided on its constitution/reconstitution and the
 
appointment of its Chairman.
Reviewed and approved
 
the revised Compliance
 
Mandate.
Jointly with the
 
BRC, discussed and
 
further submitted to the BoD
 
for discussion the Business Risk
 
Assessment Exercise
(AML, CFT,
 
Sanctions) and the Compliance Risk Assessment.
Approved
 
and further
 
submitted to
 
the
 
BoD for
 
information
 
the
 
annual
 
and triennial
 
Plans of
 
Internal
 
Audit and
Compliance and monitored their
 
progress.
Reviewed
 
and discussed
 
regular
 
and ad
 
hoc reports
 
with information
 
relating
 
to the
 
System of
 
Internal
 
Controls,
including
 
quarterly
 
reports
 
from
 
Group
 
Internal
 
Audit,
 
Group
 
Compliance,
 
the
 
Operational
 
Risk
 
Sector,
 
Clients
Relations Office,
 
etc.
Received updates on various legal and regulatory
 
issues.
Discussed extensively AML issues, including the legal
 
and regulatory framework
 
for the EU’s Anti-Money
 
Laundering
Authority (AMLA) along with the respective
 
implementation timeline for
 
Eurobank.
Discussed various Group Compliance issues,
 
including the Compliance Transformation
 
Project.
Ratified the scoping memo and approved
 
the external advisor (i.e., EY) for
 
the review of Group
 
IA’s Risk Assessment
and Audit
 
Planning Methodology (External Review). Subsequently, after its
 
completion, the AC approved the External
Review and the respective
 
action plan.
 
 
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Discussed
 
the
 
quality
 
assessment
 
of
 
the
 
Group
 
Internal
 
Audit
 
activities,
 
covering
 
the
 
operations
 
of
 
the
 
entire
Eurobank
 
Group
 
in
 
Greece
 
and
 
its
 
subsidiaries
 
abroad,
 
against
 
the
 
Internal
 
Audit
 
Standards,
 
conducted
 
by
 
an
external advisor (i.e.,
 
Ernst & Young (EY)). EY
 
identified 12 improvement opportunities, and
 
the AC approved an action
plan for their implementation.
In line with the BoG Act
 
2577/2006, ensured that an annual evaluation of the System of Internal Controls for the year
2023 was performed and documented by the Internal Audit Group. This report, along with the AC’s assessment,
 
was
further submitted to the
 
BoD and subsequently to the BoG as required.
During the
 
1Q 2024 AC
 
meeting, discussed and
 
further
 
submitted to the
 
Board Risk
 
Committee (BRC) and
 
BoD for
acknowledgment,
 
the
 
independent
 
triennial
 
Evaluation
 
of
 
the
 
System
 
of
 
Internal
 
Controls
 
(SIC)
 
per
 
BoG
 
Act
2577/2006 conducted by Grant Thornton (Independent Evaluation). The Independent Evaluation, along
 
with the AC’s
assessment of the evaluation,
 
was submitted to the Bank of Greece (BoG) as required.
In line with the BoG Governors
 
Act 2577/2006, reviewed
 
the annual Group Compliance Sector’s reports
 
on AML and
compliance activities of the Bank for the year 2023. These reports, along with the AC’s own assessment, were
 
further
submitted to the Board and the
 
BoG.
Reviewed and submitted to the
 
BoD for approval
 
the revised Related
 
Party Transactions
 
Policy.
Reviewed
 
and,
 
depending
 
on
 
the
 
case,
 
approved
 
or
 
approved
 
and
 
further
 
submitted
 
to
 
the
 
BoD
 
for
approval/information:
o
The revised
 
MiFID II Product Governance
 
Policy
o
The new MiFID II
 
Marketing Communications Policy
o
The revised
 
Appropriateness Assessment Policy
o
The revised
 
Inducements Policy
o
The revised
 
Client/Investor Categorization Policy
o
The revised
 
Suitability Assessment Policy
o
The AML/CFT and Sanctions Policy
o
The Group
 
Anti-trust Compliance Policy
o
The revised
 
Policy for Reporting Illegal or
 
Unethical Conduct or Violations
 
of European Union Law
o
The revised
 
Anti-Bribery and Corruption Policy
o
The Policy
 
for the Prevention
 
and Detection of Market Abuse
o
The Insider Dealing Guideline
o
The revised
 
Code of Conduct and Ethics
o
The revised
 
Conflict of Interest Policy
o
The Order
 
Execution Policy
In
 
the
 
context
 
of
 
the
 
Policy
 
for
 
Reporting
 
Illegal
 
or
 
Unethical
 
Conduct
 
or
 
Violations
 
of
 
European
 
Union
 
Law
(mentioned
 
above),
 
approved
 
and further
 
submitted to
 
the
 
BoD for
 
approval
 
the
 
Report Receiving
 
& Monitoring
Officer (RRMO) and the
 
Assistant RRMO.
Discussed with Management, Internal Audit, and External Auditors issues relating
 
to the financial results.
Discussed/approved
 
(depending
 
on the
 
case)
 
various
 
Group
 
Internal
 
Audit issues,
 
including
 
its staffing,
 
strategy,
budget, and training.
Received an
 
update regarding
 
the gap
 
assessment performed
 
through interviews,
 
workshops, and documentation
analysis by an external
 
consultant (i.e., PwC) for
 
the evaluation
 
of the readiness
 
of Eurobank’s
 
Group Internal
 
Audit
function to conform with
 
Global International Audit Standards
 
(GIAS).
Strengthened its monitoring of the
 
effectiveness
 
of the IA functions of subsidiaries (in Greece
 
and abroad).
Reviewed and cleared
 
the consolidated financial statements.
Discussed with
 
Management the
 
implementation
 
of corrective
 
actions to recommendations
 
made by
 
Internal and
External Auditors and Regulatory Authorities.
Assessed
 
the
 
effectiveness,
 
objectivity,
 
and
 
independence
 
of
 
the
 
External
 
Auditors
 
for
 
the
 
financial
 
year
 
2023,
discussed the
 
results of
 
their evaluation
 
with Management
 
and Internal
 
Audit, and communicated
 
the final
 
results
to the Board and the
 
External Auditors.
Approved the
 
External Auditors’ Bank Group Audit and Assurance
 
Fees for
 
2024.
Proposed
 
to
 
the
 
Board
 
and
 
the
 
Annual
 
General
 
Meeting
 
of
 
Shareholders
 
for
 
approval
 
the
 
appointment
 
of
 
the
External Auditors for the
 
financial year 2024.
Approved
 
the External
 
Auditors’ Independence
 
Policy and
 
monitored, in line
 
with this Policy,
 
the non-audit services
provided by the
 
External Auditor in 2024.
Received an update on the
 
External Auditor’s tendering process
 
for the Group
 
statutory audit of 2027.
Assessed the performance
 
of the Chief Audit Executive
 
and the General
 
Manager Head of Group Compliance/Anti-
Money Laundering Reporting Officer.
Monitored
 
the
 
memberships
 
and
 
the
 
modus
 
operandi
 
of
 
the
 
Audit
 
Committees
 
of
 
the
 
banking
 
subsidiaries,
 
as
required, and reviewed
 
their Activity Reports.
 
 
 
 
 
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Approved banking subsidiaries’
 
AC Chairs appointed during 2024.
Discussed key Audit Committee issues with the
 
Chairpersons of banking subsidiaries.
In
 
accordance
 
with
 
the
 
provisions
 
of Law
 
2533/1997,
 
the
 
Audit Committee
 
reviewed
 
reports
 
on substantial
 
stock
transactions of
 
the Bank’s Directors
 
and General
 
Managers that met
 
the criteria
 
set in Law 2533/1997
 
and notified
the Board.
Approved and notified the Board for further submission to
 
the Annual General Meeting the annual
 
AC Activity Report
for 2023.
Discussed the Annual AC Plan for
 
2025.
At the BRC meetings that
 
the AC members
 
participated in, discussions included progress
 
reports for the
 
Corporate
Sustainability Report Directive
 
(CSRD) Program Implementation,
 
risk issues such as operational
 
risk, IT security risk,
and climate-related
 
and environmental
 
risk, the
 
MREL plan,
 
and the
 
Environmental
 
and Social
 
Governance
 
(ESG)
Strategy.
It is noted that
 
in accordance
 
with the
 
Law 4449/2017 as
 
in force,
 
the HoldCo/Bank
 
ACs submit an
 
annual activity report
 
to
their
 
Shareholders’
 
Annual General
 
Meeting on
 
the
 
issues dealt
 
with by
 
the
 
ACs during
 
the
 
previous
 
year,
 
also including
 
a
description of the sustainability policy followed
 
by each entity.
The 2024 HoldCo/Bank ACs
 
Activity Reports which are also part of the
 
2024 HoldCo/Bank Annual Financial Reports, refer
 
to
the AC activity during 2024, the
 
issues addressed and the sustainability policy.
6.3
Board Risk Committee
 
The purpose of the
 
HoldC/Bank’s Board Risk Committee (BRC) is to assist the Board
 
in the following
 
risk-related issues:
 
to advise and support BoD regarding
 
the monitoring of overall
 
actual and future risk appetite and strategy,
 
taking
into account all types of risks to ensure that they are in line with the
 
business strategy,
 
objectives, corporate
 
culture
and values
 
to provide BoD with recommendations
 
on necessary adjustments to the
 
risk strategy
to assist BoD in overseeing the
 
implementation of risk strategy
 
and the corresponding limits set
to oversee the implementation of the strategies for capital and liquidity management as well as for all material risks
of the
 
Group, as
 
identified through
 
the Risk
 
Identification and
 
Materiality Assessment
 
(RIMA) process
 
and listed in
the relevant RIMA report, in
 
order to assess
 
their adequacy against the
 
approved risk appetite and
 
strategy. Material
risk types include financial and
 
non-financial risks, indicatively
 
credit risk, market risk,
 
liquidity risk, interest
 
rate risk
and credit spread risk in the banking book, counterparty
 
risk, operational
 
risk, climate risk, country risk, reputational
risks, conduct risk, risks stemming from strategic projects
to
 
oversee
 
the
 
progress
 
made
 
to
 
enhance
 
resolvability
 
in
 
accordance
 
with
 
the
 
requirements
 
of
 
the
 
Resolution
Authorities (for Bank BRC only).
to review a
 
number of possible scenarios,
 
including stressed scenarios,
 
to assess how the
 
risk profile would
 
react to
external and internal events
to oversee
 
the
 
alignment between
 
all material
 
financial products
 
and services
 
offered
 
to clients
 
and the
 
business
model and risk strategy. The
 
BRC should assess the risks associated with the offered
 
financial products and services
and take
 
into account
 
the
 
alignment
 
between the
 
prices
 
assigned to
 
and the
 
profits
 
gained from
 
those products
and services (for Bank BRC only)
to provide advice on the appointment of external consultants that BoD may decide to engage for advice or support
to assess the
 
recommendations
 
of internal
 
or external
 
auditors and follow
 
up on
 
the appropriate
 
implementation
of measures taken
to ensure that an appropriate risk management framework has been developed which is embedded in the decision-
making process (e.g. new products and services introduction,
 
risk adjusted pricing, internal risk models, risk adjusted
performance measures
 
and capital allocation)
to define the risk management principles and ensure that there are the appropriate
 
methodologies, modeling tools,
data sources and sufficient and competent staff
 
to identify, assess, monitor and mitigate risks
 
to
 
set,
 
approve
 
and
 
oversee
 
the
 
implementation
 
of
 
the
 
risk
 
culture,
 
core
 
values
 
and
 
expectations
 
regarding
 
all
material risks.
6.3.1
BRC Membership/Composition
The BRCs
 
consist of five (5)
 
independent non-executive Directors.
 
The Chairperson
 
qualifies as independent member
 
with a
solid experience
 
in commercial
 
banking and preferably
 
risk and/or Non-Performing
 
Exposures management
 
and is familiar
with the Greek and international
 
regulatory framework.
 
The appointment of the Chairperson
 
and the Vice-Chairperson shall
go through the
 
NomCos’ proposal process
 
and approved by
 
the Board.
5
HoldCo/Bank BRCs’ Terms of Reference
 
may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
 
&
www.eurobank.gr
).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The BRCs’ composition is outlined
 
below:
BRC Chairperson:
Rajeev Kakar,
Non-Executive Independent Director of the
 
Board
BRC Vice-Chairperson:
 
John Arthur Hollows,
Non-executive Independent Director of the Board
BRC Members:
Cinzia Basile,
 
Non-Executive Independent Director of the
 
Board
Burkhard Eckes,
Non-Executive Independent Director of the
 
Board
Evangelos Kotsovinos
, Non-executive Independent Director of the
 
Board
It
 
is noted
 
that
 
during
 
2024
 
and following
 
NomCos’
 
recommendations
 
for
 
the
 
recomposition
 
of
 
the
 
HoldCo/Bank’s
 
BoDs
Committees, the HoldCo/Bank’s BoDs decided on30.05.2024,
 
28.06.2024 and
 
23.07.2024,the
 
following:
to
 
appoint
 
Messrs.
 
Burkhard
 
Eckes
 
and
 
Evangelos
 
Kotsovinos
 
as
 
new
 
BRC
 
members,
 
in replacement
 
of
 
Ms.
 
Alice
Gregoriadi and Mr. Bradley
 
Paul Martin respectively.
Mr. John Arthur Hollows to
 
swap his
 
BRC status with
 
that of Ms.
 
Cinza Basile, i.e.
 
Mr. John Arthur Hollows to
 
undertake
the
 
position
 
of BRC’s
 
Vice
 
Chair (previously
 
held
 
the
 
position
 
of BRC’s
 
member)
 
whereas
 
Ms. Alice
 
Gregoriadi
 
to
undertake the position
 
of BRC’s member (previously
 
held the position of BRC’s Vice
 
Chair).
6.3.2
BRC Meetings
The
 
BRC
 
meets
 
at
 
least
 
ten (10)
 
times
 
per
 
year
 
and the
 
Chairperson
 
updates
 
the
 
BoD
 
members
 
on the
 
material
 
matters
covered
 
by the Committee during the previous
 
period (if any) at the quarterly
 
meetings of the BoD.
 
Apart from
 
the BRC
 
members, the
 
AC’s members
 
may also attend
 
BRC sessions when
 
common issues are
 
discussed (i.e. on
operational
 
risk matters,
 
on IT
 
security and
 
cyber risks).
 
The
 
Chairperson of
 
the
 
BRC may
 
also invite
 
to the
 
meetings other
executives of the
 
Group or external advisors or experts, as deemed
 
appropriate.
6.3.3
Attendance to the BRC Meetings
During 2024, attendance details for
 
the Board Risk Committee were
 
as follows,
 
Company
Meetings
Average ratio of
Directors’ attendance
2024
2023
2024
2023
HoldCo
 
12
12
95%
100%
Bank
 
12
13
95%
100%
The Directors’
 
individual attendance rates at the
 
BRC meetings in 2024 were the
 
following:
Name
Eurobank Holdings
BRC
Eurobank BRC
Eligible to attend
Attended in person
(# and %)
Eligible to
attend
Attended in
person
(# and %)
Rajeev Kakar,
BRC
Chairperson
12
11
92%
12
11
92%
John Arthur Hollows,
 
BRC Vice-Chairperson
12
11
92%
12
11
92%
Cinzia Basile,
BRC member
12
12
100%
12
12
100%
Burkhard Eckes,
 
BRC member since 23.07.2024
5
5
100%
5
5
100%
Evangelos Kotsovinos,
BRC member since 23.07.2024
5
4
80%
5
4
80%
Bradley Paul L. Martin,
BRC member until 23.07.2024
7
7
100%
7
7
100%
Alice Gregoriadi,
BRC member until 23.07.2024
7
7
100%
7
7
100%
It is noted
 
that in 2024, Messrs.
 
Rajeev Kakar, John Arthur Hollows and Evangelos
 
Kotsovinos provided representation proxies
for their
 
missed meetings in HoldCo/Bank’s
 
BRCs, leading their
 
overall
 
attendance rate
 
(physical and under
 
representation)
at 100% in HoldCo/Bank’s BRCs.
6.3.4
BRCs’ Performance
 
Evaluation
The 2024
 
self-evaluation conducted
 
by the
 
HoldCo/Bank BRCs indicates
 
overall
 
satisfaction among
 
its members
 
regarding
the
 
Committee's leadership,
 
participation,
 
and the
 
robustness
 
of discussions.
 
Members of
 
the
 
BRCs expressed
 
satisfaction
 
 
 
 
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with
 
the
 
Chairperson’s
 
preparedness
 
and
 
ability
 
to
 
guide
 
discussions.
 
Additionally,
 
members
 
of
 
the
 
BRCs
 
are
 
also
 
well-
prepared for
 
meetings, ensuring meaningful participation
 
in discussions.
he evaluation also highlighted opportunities for further enhancement. In particular, enhancements in meeting materials were
noted, scoring 4.80,
 
yet further
 
improvements
 
were
 
recommended in
 
areas such
 
as market
 
risk reporting
 
and non-financial
risk oversight, particularly operational
 
and cybersecurity risks.
Strengthening
 
oversight
 
of
 
subsidiaries
 
was
 
identified
 
as
 
a
 
priority
 
too,
 
similarly
 
to
 
the
 
Audit
 
Committee.
 
Members
highlighted specific areas, such as
 
credit, concentration, and merger
 
-related risks in Cyprus. Sensitivity
 
analyses on consumer
lending profitability and the euro’s
 
impact on the Bulgarian market were
 
also recommended. Cybersecurity governance
 
and
operational
 
resilience
 
emerged
 
as focus
 
areas, with
 
calls for
 
annual deep-dive
 
sessions and
 
greater
 
use of
 
data analytics
and stress testing
 
to improve
 
risk identification
 
and mitigation.
 
Coordination with
 
the Audit
 
Committee remained
 
effective
but saw a slight decline in its score, moving from 4.80 to 4.60.
6.3.5
BRCs’ Activity in 2024
For 2024, the
 
BRCs have, amongst others:
Eurobank Holdings
Monitored the
 
Group’s
 
overall
 
actual and
 
future
 
risk appetite
 
and strategy,
 
ensuring alignment
 
with the
 
business
strategy, objectives,
 
corporate culture, and values of the
 
Group, while considering all types of risks.
Approved various
 
regulatory and risk-related reports,
 
policies, and frameworks,
 
including:
o
Internal Capital & Liquidity Adequacy Assessment Processes
 
(ICAAP/ILAAP)
o
Capital Adequacy Statements (CAS) and Liquidity Adequacy Statements
 
(LAS)
o
Risk Identification and Materiality Process
 
(RIMA) Report
o
Group Recovery
 
Plan
Approved the
 
Group Chief Risk Officer
 
(GCRO) Annual Report.
Approved
 
the
 
Group
 
Risk
 
and
 
Capital
 
Strategy,
 
the
 
Risk
 
Appetite
 
Framework
 
(RAF),
 
and
 
the
 
Risk
 
Appetite
Statements (RAS), including the RAS dashboard.
Eurobank
Monitored
 
Eurobank’s
 
overall
 
actual
 
and
 
future
 
risk
 
appetite
 
and
 
strategy,
 
ensuring
 
that
 
all
 
types
 
of
 
risks
 
were
aligned with the institution’s
 
business strategy,
 
objectives, corporate
 
culture, and values.
Oversaw both qualitative
 
and quantitative aspects of credit, market,
 
liquidity, and operational
 
risks.
Reviewed
 
Information
 
and
 
Communication
 
Technology
 
(ICT)
 
Risk and
 
Security,
 
including Cyber
 
Security,
 
Physical
Security, and Fraud
 
Detection.
Approved various
 
regulatory and other
 
reports, risk policies, and frameworks,
 
including:
o
Non-Performing Exposures
 
(NPE) Targets
 
submission for 2024-2026 and the
 
NPE management strategy.
o
Liquidity Report.
o
Counterparty and Issuer Risk Report.
o
Interest Rate Risk in the Banking Book
 
/ Credit Spread Risk in the Banking Book.
o
Market Risk Developments
 
Report.
o
Group Operational
 
and Non-Financial Risk Report.
o
Asset Quality Monthly and Quarterly Update.
o
Impairment Results: Quarterly Update.
o
New Disbursements Performance
 
Report.
o
Forbearance
 
Report.
o
Quarterly NPE & Securitizations Performance
 
Update Report.
o
Risk Appetite Dashboard.
o
Bank’s Macro Hedging Strategy Updates.
o
BCBS239 Project, including:
-
Scope of Application and Inventory of Material
 
Risk Reports.
-
Definition of Compliance.
-
Overarching
 
Risk Reporting Framework.
-
Risk Data Aggregation
 
and Risk Reporting (RDARR) Validation
 
Governance Arrangements.
-
Initial Version of the
 
RDARR Validation
 
Framework.
o
Large Groups and Hyper Groups
 
– Degrouping Policy
 
Amendments.
o
Presentations of Large Groups,
 
including METLEN, DEI, GEK, among others.
 
 
 
 
 
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o
Leveraged
 
Transactions Update
 
& Dashboard.
o
Corporate & Investment
 
Banking (CIB) Industry Sectors Update.
o
International Subsidiaries Monitoring,
 
including key risk indicators,
 
the BRC Chairman’s
 
Annual Activity Report,
and the approval of BRC Chairs
 
appointed during 2024.
BRC meetings where
 
AC members were
 
also invited, discussing and approving the following
 
issues:
o
Resolvability Progress Report.
o
Group Chief Risk Officer
 
Succession Plan.
o
Notification for
 
breach of Risk Appetite Statements (RAS) thresholds,
 
specifically:
-
Level 1 KRI: "Operational
 
Risk Losses Ratio" (RAS 47).
-
Level 2 KRI: "Conduct Risk Exposure" (RAS 51), "Regulatory Compliance
 
Risk Exposure" (RAS 52).
o
Hellenic Bank Risk Assurance Analysis.
o
Minimum Requirement for
 
Own Funds and Eligible Liabilities (MREL) Issuance Plan & Targets.
o
Resolvability Self-Assessment Report.
o
Environmental and Social Governance
 
(ESG) Strategy.
o
Key Climate Risk & Environmental
 
(CR&E) Risk Monitoring Indicators & Pillar 3 Benchmarking.
o
Fit-for-55 Climate Risk Stress Test
 
Results.
o
Anti-Money Laundering (AML) Validation
 
– Onboarding and Transaction
 
Monitoring (SIRON).
o
Corporate Sustainability Reporting Directive
 
(CSRD) Governance Gap Analysis Status
 
Update.
o
Double Materiality Impact – Overview.
o
Discussion of the Digital Operational
 
Resilience Act (DORA) Gap Assessment & Results.
o
Semi-Annual Update by the Responsible BoD Member
 
for Climate-Related and Environmental
 
Risks.
6.4
Remuneration Committee
 
The
 
HoldCo/Bank’s
 
Boards
 
have
 
delegated
 
to
 
the
 
respective
 
RemCos
 
the
 
responsibilities
 
(a)
 
to
 
provide
 
specialized
 
and
independent advice for matters relating
 
to remuneration
 
policy and its implementation at HoldCo/Bank Group
 
level and for
the
 
incentives
 
created
 
while
 
managing
 
risks,
 
capital
 
and
 
liquidity,
 
(b)
 
to
 
safeguard
 
the
 
proper
 
exercise
 
of
 
its
 
duties
 
and
responsibilities,
 
the
 
efficient
 
alignment
 
of
 
the
 
personnel’s
 
remuneration
 
with
 
the
 
risks
 
the
 
HoldCo/Bank
 
undertakes
 
and
manages and the required alignment between
 
the HoldCo/Bank and the Group,
 
and (c) to approve or propose
 
for approval
all exposures of
 
Key Management
 
Personnel
 
and their relatives
 
(spouses, children, siblings).
 
The Non-Executive
 
Directors of
HoldCo/Bank have the
 
responsibility to approve
 
and periodically review
 
HoldCo/Bank’s remuneration
 
policy and oversee
 
its
implementation both at
 
Bank and Group level.
The
 
implementation
 
of the
 
HoldCo/Bank remuneration
 
policy
 
is in
 
line with
 
the
 
provisions
 
of Laws
 
4261/2014
 
and Bank
 
of
Greece Executive Committee’s
 
Act 231/2024.
The HoldCo/Bank RemCo is also responsible
 
to:
determine
 
the
 
remuneration
 
system for
 
the
 
members
 
of the
 
Board
 
of Directors
 
and the
 
senior
 
executives
 
and to
make
 
a
 
relevant
 
recommendation
 
on
 
them
 
to
 
the
 
Board
 
of
 
Directors,
 
which
 
decides
 
on
 
them
 
or
 
to
 
make
recommendations to the
 
General Meeting, where
 
required,
propose
 
to
 
the
 
Non-Executive
 
Directors
 
of
 
the
 
HoldCo/Bank’s
 
BoD
 
for
 
their
 
approval
 
the
 
goals
 
and
 
objectives
relevant
 
to
 
the
 
HoldCo/Bank’s
 
CEO
 
remuneration
 
and
 
evaluate
 
his/her
 
performance
 
in
 
light
 
of
 
these
 
goals
 
and
objectives,
guide and monitor the external remuneration
 
consultant (if hired) and ensure that it receives
 
appropriate reporting
from him/her.
 
In addition, HoldCo/Bank RemCo ensures that the external consultant is referred
 
in the HoldCo/Bank’s
annual
 
report
 
of
 
the
 
year
 
hired
 
and/or
 
completed
 
his/her
 
work,
 
together
 
with
 
a
 
statement
 
of
 
any
 
possible
relationship between him/her
 
and the HoldCo/Bank or with members
 
of the HoldCo/Bank’s Board individually.
6.4.1
RemCos Membership/Composition
The HoldCo/Bank RemCos consists of five
 
(5) independent non-executive Directors.
In
 
the
 
event
 
that
 
the
 
Chairperson
 
of
 
the
 
Bank’s
 
Board
 
is
 
a
 
member
 
of
 
the
 
RemCos,
 
she/he
 
cannot
 
participate
 
in
 
the
determination of his/her
 
remuneration.
6
HoldCo/Bank RemCos’ Terms of Reference
 
may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
 
&
www.eurobank.gr
).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The HoldCo/Bank RemCos’
 
composition is outlined below:
RemCo Chairperson:
Cinzia Basile,
Non-executive Independent Director of the
 
Board
 
Members:
Jawaid Mirza,
Non-Executive Independent Director of the
 
Board
 
Alice Gregoriadi,
 
Non-Executive Independent Director of the
 
Board
 
Irene Rouvitha Panou,
Non-Executive Independent Director of the
 
Board
John Arthur Hollows,
Non-Executive Independent Director of the
 
Board
It
 
is noted
 
that
 
during
 
2024
 
and following
 
NomCos’
 
recommendations
 
for
 
the
 
recomposition
 
of
 
the
 
HoldCo/Bank’s
 
BoDs
Committees, the HoldCo/Bank’s BoDs decided on 30.05.2024,
 
28.06.2024 and 23.07.2024:
to appoint Ms.
 
Irene Rouvitha Panou as new
 
RemCos’ member in replacement of Mr. Geroge Chryssikos who
 
decided
not to pursue
 
renewal of
 
his term
 
to the
 
new HolDCo/Bank
 
BoDs (that were
 
appointed by the
 
HoldCo/Bank AGMs
of 23.07.2024)
 
and Mr. John Arthus Holl
 
ows as new RemCos’ member
 
Following
 
the
 
decision
 
of the
 
discontinuation
 
of Vice
 
Chair’s
 
role
 
on the
 
BoDs and
 
certain
 
committees (including
HoldC/Bank
 
RemCos)
 
upon
 
the
 
conclusion
 
of
 
Mr.
 
Georgios
 
Chryssikos’
 
term,
 
Mr.
 
Jawaid
 
Mirza
 
(previous
 
Vice-
Chairperson of
 
HoldCo /
 
Bank RemCos)
 
to be
 
appointed in
 
RemCos as
 
member.
 
The
 
Chair’s responsibilities
 
to be
assumed by the most senior
 
independent non-executive directors present at meetings
 
in the Chair’s absence.
6.4.2
RemCos meetings
HoldCo/Bank RemCos meet at least twice a year.
6.4.3
Attendance to the RemCo meetings
During 2024 the attendance details for
 
the Remuneration
 
Committees were as follows:
Company
Meetings
Average ratio of
Directors’ attendance
2024
2023
2024
2023
HoldCo
11
12
100%
97%
Bank
 
11
12
100%
98%
It is noted that
 
in 2024, representation
 
proxies were
 
provided for
 
all missed meetings
 
in HoldCo/Bank RemCos,
 
leading the
overall
 
attendance rate (physical and under
 
representation) at 100% in HoldCo/Bank
 
RemCos.
6.4.4
RemCo’s Performance
 
Evaluation
The
 
2024
 
self-evaluation
 
conducted
 
by
 
RemCos’
 
members
 
reflects
 
overall
 
satisfaction
 
with
 
the
 
Committees’
 
leadership,
preparedness, and agenda management. RemCos’ members demonstrate strong preparedness and active engagement and
these attributes contribute significantly to the Committees’ ability to
 
make informed decisions and provide meaningful input.
 
The
 
evaluation
 
also
 
highlighted
 
opportunities
 
for
 
further
 
enhancement.
 
Members
 
noted
 
the
 
need
 
for
 
improved
 
material
quality, timelier submissions, and deeper
 
discussions on remuneration
 
policies. The Committee’s skillset was also highlighted
as an area
 
for
 
possible improvement,
 
with recommendations
 
to include
 
more HR
 
expertise to
 
address complex
 
challenges
and better align the Committee's work with
 
Eurobank’s strategic
 
objectives.
Talent
 
retention emerged
 
as a priority,
 
with members
 
suggesting less reliance
 
on monetary rewards
 
and greater
 
emphasis
on
 
career
 
development
 
and
 
linking
 
incentives
 
to
 
growth.
 
Additionally,
 
strengthening
 
governance
 
at
 
subsidiaries
 
was
recommended to ensure alignment with
 
Group-level
 
objectives.
6.4.5
RemCos' Activity in 2024
For 2024, RemCos’
 
have amongst others:
Eurobank Holdings
Proposed to the Board
 
of Directors (BoD) for approval
 
the revised RemCo Terms
 
of Reference.
Reviewed and proposed
 
to the Non-Executive Directors
 
for approval the
 
Remuneration
 
Policy of the HoldCo.
Reviewed and proposed to the Board and the Annual General Meeting (AGM) for approval
 
the Remuneration Policy
for Directors.
Reviewed and proposed to the
 
Non-Executive Directors for approval
 
the Group Annual Base Salary Framework
 
and
the Annual Base Salary Framework
 
for Top
 
Management Roles.
 
 
 
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Reviewed and proposed to the
 
Non-Executive Directors for approval
 
the Variable
 
Remuneration
 
- Key Performance
Indicators (KPIs) & Key Risk Indicators
 
(KRIs) and the Group Variable
 
Remuneration
 
Pool.
Reviewed and approved
 
the Material Risk Takers’
 
List and the Remuneration
 
Disclosures for 2023.
Discussed the remuneration
 
policy implementation at the
 
Group level.
Discussed the
 
Remuneration
 
Policy
 
Review
 
– Follow
 
-up (for
 
the
 
years
 
2022 and
 
2023), conducted
 
by
 
the
 
Internal
Audit Group.
Proposed to the
 
Board and AGM
 
for approval
 
the Board
 
and Board Committees’
 
Fees for
 
Non-Executive Directors
of the HoldCo (Actual Fees
 
2023 & Estimated Fees 2024).
Proposed to the Board
 
and AGM for approval
 
the Remuneration
 
Report for the financial
 
year 2023.
Proposed to the Board
 
and AGM for approval:
o
The distribution of net profits
 
to senior management and employees.
o
Approvals in accordance
 
with Article 86 of Law 4261/2014.
Proposed to the
 
Non-Executive Directors
 
of the Bank
 
for approval
 
the CEO’s
 
Performance
 
Evaluation for
 
2023 and
the CEO’s Financial and Non-Financial Objectives for
 
2024.
Approved the
 
Remuneration
 
Disclosures for 2023.
Reviewed and proposed
 
to the Board for
 
approval the Board
 
and Board Committees’ Attendance Policy.
Reviewed the
 
implementation of the Board
 
and Board Committees’ Attendance Policy.
Depending on
 
the
 
case, approved
 
or proposed
 
to the
 
Non-Executive
 
Directors for
 
approval
 
various remuneration
issues and borrowing requests.
Received updates on:
o
Initiatives supporting employees
 
on the lowest salary levels.
o
The annual pension component.
o
The Benefits Policy.
o
The Voluntary
 
Exit Scheme effectiveness.
Discussed the Top
 
Management Remuneration
 
Benchmarking Project.
Discussed the Annual RemCo Plan for
 
2025.
Eurobank
Proposed to the Board
 
of Directors (BoD) for approval
 
the revised RemCo Terms
 
of Reference.
Reviewed and proposed
 
to the Non-Executive Directors
 
for approval the
 
Remuneration
 
Policy of the Bank.
Reviewed and proposed to the Non-Executive
 
Directors for approval the
 
Group Annual Base Salary Framework and
the Annual Base Salary Framework
 
for Top
 
Management Roles.
Reviewed and proposed to the
 
Non-Executive Directors for approval
 
the Variable
 
Remuneration - Key
 
Performance
Indicators (KPIs) & Key Risk Indicators
 
(KRIs) and the Group Variable
 
Remuneration
 
Pool.
Reviewed and approved
 
the Material Risk Takers’
 
List and the Remuneration
 
Disclosures for 2023.
Discussed the remuneration
 
policy implementation at both
 
the Bank and Group levels.
Discussed the
 
Remuneration
 
Policy
 
Review
 
– Follow
 
-up (for
 
the
 
years
 
2022 and
 
2023), conducted
 
by the
 
Internal
Audit Group.
Proposed to the Board and Annual General Meeting (AGM) for approval
 
the Board and Board Committees’ Fees for
Non-Executive Directors of the
 
Bank (Actual Fees 2023 & Estimated Fees
 
2024).
Proposed to the Board
 
and AGM for approval:
o
The distribution of net profits
 
to senior management and employees.
o
Approvals in accordance
 
with Article 86 of Law 4261/2014.
Proposed to the
 
Non-Executive Directors
 
of the Bank
 
for approval
 
the CEO’s Performance
 
Evaluation for
 
2023 and
the CEO’s Financial and Non-Financial Objectives for
 
2024.
Reviewed the
 
implementation of the Board
 
and Board Committees’ Attendance Policy.
Discussed and
 
further
 
submitted to
 
the Board
 
for
 
information
 
the implementation
 
of the
 
Group Subsidiary
 
Board
Remuneration
 
Policy across the
 
Group during 2023.
Depending on
 
the
 
case, approved
 
or proposed
 
to the
 
Non-Executive Directors
 
for
 
approval
 
various remuneration
issues
 
related
 
to
 
international
 
subsidiaries,
 
including
 
the
 
remuneration
 
framework,
 
performance-related
 
variable
remuneration,
 
and remuneration
 
increases.
Depending on
 
the
 
case, approved
 
or proposed
 
to the
 
Non-Executive Directors
 
for
 
approval
 
various remuneration
issues and borrowing requests.
Received and reviewed
 
the annual updates from the
 
RemCo Chairpersons of the Group’s
 
banking subsidiaries.
 
 
 
 
 
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Approved the
 
appointment of a new RemCo Chairperson in the
 
Group’s banking subsidiaries.
Received updates on:
o
Initiatives supporting employees
 
on the lowest salary levels.
o
The annual pension component.
o
The Benefits Policy.
o
The Voluntary
 
Exit Scheme effectiveness.
Discussed the Top
 
Management Remuneration
 
Benchmarking Project.
Discussed the Annual RemCo Plan for
 
2025.
6.5
Nomination and Corporate Governance
 
Committee
 
Eurobank
 
Holdings
 
and the
 
Bank’s Boards
 
have
 
delegated
 
to the
 
NomCos the
 
responsibilities
 
(a)
 
to lead
 
the
 
process
 
for
Board and
 
Board Committees
 
appointments, including
 
the
 
identification,
 
nomination
 
and recommendation
 
of candidates
for appointment
 
to the Board,
 
(b) to consider matters
 
related to the
 
Board’s adequacy,
 
efficiency and effectiveness
 
and (c)
review
 
the
 
Group’s
 
corporate
 
governance
 
policies,
 
procedures
 
and
 
arrangements.
 
The
 
Committees
 
were
 
renamed
Nomination and Corporate Governance
 
Committees in order to accurately
 
reflect their expanded purpose.
The NomCo, in carrying
 
out its duties, is accountable to the Board.
In particular, among others,
 
the NomCo is responsible:
 
at least
 
annually and
 
in accordance
 
with Board
 
and Board
 
Committees Evaluation
 
Policy,
 
to assess
 
the structure,
size, composition and performance
 
of the BoD and make recommendations
 
to the BoD with regard
 
to the need for
its renewal and/or any other
 
changes it considers appropriate,
 
at least annually and in accordance with Board
 
and Board Committees Evaluation Policy,
 
to assess the knowledge,
skills, experience and contribution of individual Board members
 
and of the Board collectively and report
 
to the BoD
accordingly,
in
 
the
 
context
 
of
 
Board
 
and
 
Board
 
Committees
 
Evaluation
 
Policy
 
implementation,
 
to
 
determine
 
the
 
evaluation
parameters
 
based
 
on
 
best
 
practices
 
and
 
ensure
 
the
 
effectiveness
 
of
 
the
 
evaluation
 
of
 
the
 
Board,
 
the
 
individual
evaluation
 
of
 
Non-Executive
 
Directors,
 
including
 
the
 
Chair,
 
the
 
succession
 
plan
 
of
 
the
 
Chief
 
Executive
 
and
 
the
members
 
of the
 
Board, the
 
targeted composition
 
of the
 
Board
 
of Directors
 
in relation
 
to the
 
strategy
 
and Board
Nomination Policy,
to play a leading role in the nomination process and the design of the succession plan for the members of the Board
and senior management,
to review at least once every
 
two years and recommend
 
for the
 
approval of the BoD the
 
BoD Nomination Policy,
 
to ensure that the nomination process, as this is defined in
 
the BoD Nomination Policy, is clearly defined and applied
in a transparent manner
 
and in a way that ensures its effectiveness,
to
 
ensure
 
that
 
there
 
is
 
adequate,
 
step-wise
 
succession
 
planning
 
for
 
Board
 
members
 
so
 
as
 
to
 
maintain
 
an
appropriate
 
level of
 
continuity and organizational
 
memory at
 
Board level,
 
especially when
 
dealing with
 
sudden or
unexpected absences or departures of Board
 
members,
to monitor
 
the
 
Board succession
 
planning in
 
order
 
to ensure
 
the
 
smooth succession
 
of the
 
members
 
of the
 
Board
with their gradual
 
replacement in order
 
to avoid the lack of management,
to ensure that
 
the succession
 
framework
 
takes into account
 
the findings
 
of the
 
evaluation of
 
the Board
 
in order
 
to
achieve the
 
necessary changes
 
in composition
 
or skills and
 
to maximise the
 
effectiveness
 
and collective
 
suitability
of the Board,
to review at least annually
 
and always before the initiation of the CEO
 
succession process the qualifications required
for
 
the
 
position of
 
the
 
CEO, to
 
ensure
 
that there
 
is a
 
viable pool
 
of internal
 
and external
 
candidates
 
and also
 
to
ensure that
 
the CEO
 
is involved
 
in all the
 
areas of CEO
 
Succession Plan,
 
including the
 
assessment of
 
the nominees
for his/her position,
 
as he deems appropriate,
to ensure that the CEO is involved in the succession planning process of the senior executives
 
at the level of the CEO
minus one, including the assessment of nominees for
 
the said positions.
As far as
 
NomCos of subsidiaries
 
are concerned, neither the HoldCo NomCo nor
 
the Eurobank NomCo replace them. However,
the
 
Eurobank
 
NomCo has
 
the
 
overall
 
responsibility to
 
oversee
 
that the
 
NomCos of
 
subsidiaries comply
 
with its
 
standards,
modus operandi and governance
 
framework.
7
HoldCo/Bank NomCos’ Terms of Reference
 
may be found at the HoldCo/Bank websites (
www.eurobankholdings.gr
 
&
www.eurobank.gr
).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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6.5.1
NomCo Membership/Composition
The NomCo consists of
 
five (5) non-executive Directors, four (4)
 
of whom are
 
independent Directors, including
 
the Chairperson
who may not serve as the
 
Chairperson of the Remuneration
 
Committee.
 
The NomCo composition is outlined below:
NomCo Chairperson:
Irene Rouvitha Panou,
Non-Executive Independent Director of the
 
Board
 
Members:
George Zanias,
 
Non-Executive Director of the
 
Board
Jawaid Mirza,
Non-Executive Independent Director of the
 
Board
Rajeev Kakar,
Non-Executive Independent Director of the
 
Board
Burkhard Eckes,
Non-Executive Independent Director of the
 
Board
It
 
is noted
 
that
 
during
 
2024
 
and following
 
NomCos’
 
recommendations
 
for
 
the
 
recomposition
 
of
 
the
 
HoldCo/Bank’s
 
BoDs
Committees, the HoldCo/Bank’s BoDs decided on 30.05.2024,
 
28.06.2024 and
 
23.07.2024:
 
to appoint Mr.
 
George Zanias as new
 
NomCos’ member,
 
in replacement
 
of of Mr.
 
Geroge Chryssikos
 
who decided
not to pursue
 
renewal of
 
his term
 
to the
 
new HolDCo/Bank
 
BoDs (that were
 
appointed by the
 
HoldCo/Bank AGMs
of 23.07.2024).
Following
 
the
 
decision
 
of the
 
discontinuation
 
of Vice
 
Chair’s
 
role
 
on the
 
BoDs and
 
certain
 
committees (including
HoldC/Bank
 
NomCos)
 
upon
 
the
 
conclusion
 
of
 
Mr.
 
Georgios
 
Chryssikos’
 
term,
 
Mr.
 
Jawaid
 
Mirza
 
(previous
 
Vice-
Chairperson of
 
HoldCo /
 
Bank NomCoCos)
 
to be
 
appointed in
 
NomCos as member.
 
The
 
Chair’s responsibilities
 
to
be assumed by the most senior
 
iNED present at meetings in the Chair’s absence.
6.5.2
NomCo Meetings
NomCo meets at least twice a year.
 
6.5.3
Attendance to the NomCo meetings
During 2024 the attendance details for
 
the NomCo were
 
as follows:
Company
Meetings
Average ratio of
Directors’ attendance
2024
2023
2024
2023
HoldCo
10
11
98%
100%
Bank
 
10
11
98%
100%
Directors’ individual attendance rates
 
at the NomCo meetings in 2024 were
 
the following:
Name
Eurobank
Holdings
NomCo
Eurobank NomCo
Eligible
to
attend
Attended in
person
(# and %)
Eligible
to
attend
Attended in
person
(# and %)
Irene Rouvitha Panou, NomCo
Chairperson
10
10
100%
10
10
100%
Geroge Zanias, NomCo member
 
since 23.07.2024
4
4
100%
4
4
100%
Jawaid
 
Mirza,
 
NomCo
 
Vice-Chairperson
 
until
 
23.07.2024
 
and
NomCo member since 23.07.2024
10
9
90%
10
9
90%
Rajeev Kakar
10
10
100%
10
10
100%
Burkhard Eckes, NomCo member
 
since 23.07.2024
4
4
100%
4
4
100%
Bradley Paul L. Martin, NomCo member
 
until 23.07.2024
6
6
100%
6
6
100%
It
 
is
 
noted
 
that
 
in
 
2024,
 
Mr.
 
Jawaid
 
Mirza
 
provided
 
representation
 
proxies
 
for
 
their
 
missed
 
meetings
 
in
 
HoldCo/Bank’s
NomCos, leading their overall
 
attendance rate (physical
 
and under representation)
 
at 100% in HoldCo/Bank’s NomCos.
6.5.4
NomCos’ Performance
 
Evaluation
The
 
2024
 
self-evaluation
 
conducted
 
by
 
the
 
NomCos
 
indicates
 
overall
 
satisfaction
 
among
 
its
 
members
 
regarding
 
the
Committees’
 
structured
 
approach,
 
thorough
 
discussions,
 
and
 
balanced
 
composition.
 
NomCos’
 
members
 
believe
 
that
 
the
 
 
 
 
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Committees foster
 
a collaborative
 
and inclusive
 
environment,
 
enabling high
 
levels
 
of participation
 
and open
 
expression of
views. The Chairperson
 
of NomCos is reported to be commendable for
 
her dedication and effective
 
guidance.
 
The
 
evaluation
 
also
 
highlighted
 
opportunities
 
for
 
further
 
enhancement.
 
Areas
 
requiring
 
ongoing
 
focus
 
included
 
senior
executive
 
succession
 
planning
 
and
 
talent
 
retention.
 
The
 
Committee
 
emphasized
 
maintaining
 
leadership
 
continuity
 
and
resilience across
 
the Group.
 
Enhancing diversity also
 
remains a central
 
effort
 
at both the
 
Board and the
 
Management level,
with a focus on attracting
 
candidates with diverse
 
backgrounds, experiences,
 
and perspectives.
6.5.5
NomCos’ Activity in 2024
For 2024, NomCos have
 
amongst others:
Eurobank Holdings
Proposed to the Board
 
of Directors (BoD) for approval
 
the revised NomCo Terms
 
of Reference.
Reviewed the
 
Board and Board Committees' 2023 self-evaluation and the Board’s overall
 
effectiveness assessment
for
 
further
 
update to
 
the Board.
 
Additionally,
 
reviewed
 
and acknowledged
 
the Action
 
Plan for
 
the BoD
 
Evaluation
2023.
Discussed and proposed to the Board for
 
approval the new
 
composition of the Board Committees and other
 
Board
and Board Committees’ matters.
In view of
 
the BoD’s tenure
 
renewal in 2024,
 
reviewed
 
the nomination
 
process and
 
proposed to
 
the Board
 
and the
AGM for approval
 
the new BoD and AC members.
Reviewed and proposed
 
to the Board for
 
approval various governance
 
and nomination policies, including:
o
CEO Succession Planning Policy.
o
Board of Directors Diversity
 
Policy.
o
Key Function Holders
 
Selection and Appointment Policy.
o
Group Governance
 
Policy.
o
External Engagements Policy.
o
Board and Board Committees Evaluation Policy.
o
C-Level Succession Planning Policy.
o
Senior Management Selection and Appointment
 
Policy.
o
Board Nomination Policy
 
(also proposed to the BoD and AGM
 
for approval).
Received an update on the
 
HoldCo Group Organizational
 
Chart.
Proposed to the Board
 
for approval
 
the Internal Governance
 
Control Manual.
Reviewed
 
and
 
proposed
 
to
 
the
 
Audit
 
Committee
 
and
 
the
 
Board
 
for
 
approval
 
the
 
2023
 
Corporate
 
Governance
Statement.
Received quarterly updates on governance
 
-related audit issues.
Discussed various governance
 
-related issues, including:
o
Overview of key
 
ESG rating agencies (with a focus
 
on the "G" element).
o
Compliance Risk Assessment (CRA) related
 
to the Corporate Governance
 
Framework.
o
Review of the Group's
 
Internal Governance
 
Framework.
Reviewed, discussed, and approved
 
(depending on the case) various succession
 
planning issues, including:
o
CEO Succession Plan.
o
C-Level Succession Planning.
o
Succession planning for the
 
Group CRO.
Approved external
 
engagements for Board
 
members.
Reviewed the
 
independence of the Independent Non-Executive
 
Directors.
Reviewed the
 
attendance of Directors at the
 
Board and Board Committees.
Discussed the NomCo Annual Plan for
 
2025.
Eurobank
Proposed to the Board
 
of Directors (BoD) for approval
 
the revised NomCo Terms
 
of Reference.
Reviewed the
 
Board and Board Committees' 2023 self-evaluation and the Board’s overall
 
effectiveness assessment
for
 
further
 
update to
 
the Board.
 
Additionally,
 
reviewed
 
and acknowledged
 
the Action
 
Plan for
 
the BoD
 
Evaluation
2023.
Discussed and proposed to the Board for
 
approval the new
 
composition of the Board Committees and other
 
Board
and Board Committees’ matters.
 
 
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In view of
 
the BoD’s tenure
 
renewal in 2024,
 
reviewed
 
the nomination
 
process and
 
proposed to
 
the Board
 
and the
AGM for approval
 
the new BoD and AC members.
Reviewed and proposed
 
to the Board for
 
approval various governance
 
and nomination policies, including:
o
CEO Succession Planning Policy.
o
Board of Directors Diversity
 
Policy.
o
Key Function Holders
 
Selection and Appointment Policy.
o
Group Governance
 
Policy.
o
External Engagements Policy.
o
Board and Board Committees Evaluation Policy.
o
C-Level Succession Planning Policy.
o
Senior Management Selection and Appointment
 
Policy.
o
Board Nomination Policy.
Reviewed and proposed
 
to the BoD for approval
 
top management changes (General Manager
 
level and above).
Was
 
informed
 
about the
 
organizational
 
chart of
 
Eurobank
 
and the
 
organizational
 
changes of
 
a functional
 
nature
approved by the
 
CEO during the past year.
Proposed to the Board
 
for approval
 
the Internal Governance
 
Control Manual.
Received quarterly updates on governance
 
-related issues.
Discussed various governance
 
-related issues, including:
o
Overview of key
 
ESG rating agencies (with a focus
 
on the "G" element).
o
Compliance Risk Assessment (CRA) related
 
to the Corporate Governance
 
Framework.
o
Review of the Group's
 
Internal Governance
 
Framework.
o
Annual implementation report of the
 
Group Governance
 
Policy by Eurobank’s
 
banking subsidiaries.
Discussed and/or
 
approved
 
various issues
 
regarding significant
 
subsidiaries, including
 
the
 
selection of
 
candidates
as Board members of the
 
Group’s significant subsidiaries.
Received and reviewed
 
the annual updates from the
 
NomCo Chairpersons of the Group’s
 
banking subsidiaries.
Reviewed, discussed, and approved
 
(depending on the case) various succession
 
planning issues, including:
o
CEO Succession Plan.
o
C-Level Succession Planning.
o
Succession planning for the
 
Group CRO.
Approved external
 
engagements for Board members
 
and General Managers/Executive
 
Board (ExBo) members who
are not Board members.
Approved promotions
 
to the Eurobank
 
hierarchical
 
level of General
 
Manager.
Reviewed the
 
independence of the Independent Non-Executive
 
Directors.
Reviewed the
 
attendance of Directors at the
 
Board and its Committees.
Discussed talent development and mobilization
 
practices within Eurobank.
Discussed the NomCo Annual Plan for
 
2025.
6.5.6
Board of Directors Diversity
 
As of 31.12.2024, the representation of the female gender on the Board
 
complied with the provisions of Greek Law, as outlined
in the HoldCo/Bank Board Diversity Policy (please refer to
 
the relevant section in this
 
Statement), which mandates a
 
minimum
25% representation.
 
In cases
 
where
 
the result
 
includes a fraction,
 
the percentage
 
is rounded
 
down to
 
the
 
previous
 
integer.
This
 
confirms
 
that
 
the
 
HoldCo/Bank
 
is
 
successfully
 
meeting
 
its
 
diversity
 
objectives,
 
particularly
 
regarding
 
gender
representation on the
 
Board.
6.5.7
Senior Management Diversity
 
The Bank/HoldCo
 
has taken significant steps
 
to enhance gender diversity
 
and support career
 
growth for
 
women executives,
creating a pipeline of eligible female professionals
 
for the Executive
 
Committee and Board.
A key initiative is the annual C-Level Succession Planning exercise,
 
which aims to improve the underrepresented
 
gender ratio
in
 
the
 
successors’
 
pool.
 
In
 
the
 
2024
 
succession
 
planning
 
exercise,
 
29%
 
of
 
the
 
total
 
successors’
 
pool
 
were
 
women,
demonstrating a strong commitment
 
to gender diversity at senior levels.
Additionally,
 
the Bank
 
actively participates
 
in initiatives
 
such as
 
"The
 
Boardroom"
 
in Greece,
 
which supports
 
senior female
leaders
 
aspiring
 
to
 
become
 
Board
 
members
 
in
 
major
 
organizations.
 
By
 
sponsoring
 
such
 
initiatives,
 
the
 
Bank
 
encourages
employees and clients to pursue leadership roles.
 
 
 
 
 
 
 
 
 
 
 
 
 
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The Bank
 
has also launched
 
the third
 
season of the
 
Women
 
in Banking (WiB)
 
programme,
 
following
 
the successful
 
previous
seasons.
 
WiB
 
is
 
a
 
talent
 
programme
 
designed
 
to
 
empower
 
women
 
within
 
Eurobank,
 
helping
 
them
 
advance
 
to
 
higher
leadership
 
roles,
 
drive
 
transformative
 
change,
 
and advocate
 
for
 
an inclusive
 
work
 
environment.
 
The
 
collaboration
 
among
participants from the
 
first, second, and third seasons, with
 
200 mentors and mentees, has created
 
a strong WiB Community
within Eurobank.
The
 
Bank’s
 
Human
 
Resources
 
unit
 
continues
 
to
 
explore
 
additional
 
measures
 
to
 
enhance
 
diversity
 
at
 
senior
 
management
levels within the
 
Bank/HoldCo. In 2024, Eurobank
 
introduced:
C-1
 
succession
 
planning,
 
complementing
 
C-Level
 
succession
 
planning,
 
focusing
 
on key
 
roles
 
reporting
 
to General
Managers and BU Management teams, while also emphasizing gender diversity.
As
 
part
 
of
 
its
 
ESG
 
Strategy,
 
a
 
DE&I
 
awareness
 
training
 
programme
 
for
 
all
 
managers
 
in
 
the
 
Bank
 
to
 
reinforce
inclusivity.
6.6
Board Digital & Transformation
 
Committee
 
The
 
Bank’s Board
 
Digital &
 
Transformation
 
Committee (BDTC)
 
is a
 
consultative
 
body that
 
reviews
 
proposals
 
and gives
 
its
strategic advice and guidance on
 
such proposals related to
 
the Group’s digital, innovation, transformation and cybersecurity,
in
 
order
 
to
 
contribute
 
in
 
achieving
 
the
 
vision
 
and
 
strategic
 
goals
 
of
 
the
 
Bank.
 
The
 
BDTC,
 
in
 
carrying
 
out
 
its
 
duties,
 
is
accountable to the Bank Board.
6.6.1
BDTC Membership / Chairmanship
The BDTC consists of five (5) Directors of whom one
 
(1) executive and (4) independent
 
non-executives.
 
The BDTC composition
is outlined below:
BDTC Chairperson:
Alice Gregoriadi,
Non-Executive Independent Director of the
 
Board
Members:
Cinzia Basile,
 
Non-Executive Independent Director of the
 
Board
John Arthur Hollows,
Non-Executive Independent Director of the
 
Board
Evangelos Kotsovinos,
Non-Executive Independent Director of the
 
Board
Stavros Ioannou,
Executive Director of the
 
Board
It
 
is
 
noted
 
that
 
during
 
2024
 
and
 
following
 
Bank
 
NomCo’s
 
recommendations
 
for
 
the
 
recomposition
 
of
 
the
 
Bank’s
 
BoD
Committees,
 
the
 
Bank’s BoD
 
decided
 
on 30.05.2024,
 
28.06.2024 and
 
23.07.2024
 
a) to
 
appoint Ms.
 
Cinzia
 
Basile as
 
new
BDTC’s member,
 
in replacement
 
of Mr.
 
Jawaid Mirza (previous
 
BDTC’s
 
member), b)
 
to appoint Mr.
 
Evangelos Kotsovinos
 
as
new BDTC’s
 
member,
 
in replacement
 
of Rajeev
 
Kakar (previous
 
BDTC’s
 
Vice Chairperson)
 
and c) the
 
Vice Chair’s
 
role
 
to be
discontinued on the BoD and certain committees (including BDTC)
 
upon the conclusion of Mr. Georgios
 
Chryssikos’ term and
The Chair’s responsibilities to be assumed by the
 
most senior independent non-executive director present at meetings in the
Chair’s absence.
6.6.2
BDTC Meetings
BDTC meets at least twice
 
a year and as each time required, also considering that
 
the annually held Strategy
 
Away Day is a
forum
 
in
 
which
 
relevant
 
digital
 
and
 
transformation
 
strategic
 
matters
 
are
 
also
 
discussed,
 
while
 
minutes
 
are
 
kept
 
for
 
all
meetings.
 
6.6.3
BDTC Attendance Rate
During
 
2024,
 
BDTC
 
held
 
four
 
(4)
 
meetings
 
and
 
the
 
ratio
 
of
 
attendance
 
was
 
100%
 
(vs.
 
three
 
(3)
 
meetings
 
with
 
ratio
 
of
attendance was 94% in 2023).
8
Bank BDTC Terms
 
of Reference may be found at the Bank websites (
www.eurobank.gr
).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The Directors’
 
individual attendance rates at the
 
BDTC meetings in 2023
 
were the
 
following:
Name
Eurobank ‘s BDTC
Eligible to
attend
Attended in
person
(# and %)
Alice Gregoriadi,
BDTC Chairperson
4
4
100%
 
John Arthur Hollows,
BDTC member
4
4
100%
Cinzia Basile,
BDTC member
 
since 23.07.2024
1
1
100%
Evangelos
 
Kotsovinos,
 
BDTC
 
member
 
since
23.07.2024
 
1
1
100%
Stavros Ioannou,
BDTC member
4
4
100%
 
Rajeev
 
Kakar,
BDTC
 
Vice
 
Chairperson
 
until
23.07.2024
3
3
100%
 
Jawaid Mirza
 
BDTC member
 
until 23.07.2024
3
3
100%
6.6.4
BDTC Performance
 
Evaluation
The
 
2024 evaluation
 
of the
 
BDTC
 
highlights opportunities
 
to enhance
 
its effectiveness.
 
While the
 
Committee has provided
valuable
 
insights,
 
feedback
 
suggests
 
a
 
need
 
for
 
more
 
outcome-driven
 
discussions
 
and
 
a
 
stronger
 
focus
 
on
 
high-impact
initiatives.
 
Non-committee
 
members
 
emphasized
 
the
 
importance
 
of
 
fostering
 
dynamic
 
exchanges
 
on
 
emerging
 
digital
opportunities, while some Committee members noted areas
 
for improvement in strategic focus,
 
leadership engagement, and
meeting structures, particularly regarding
 
major projects.
To strengthen
 
its impact, aligning the
 
Committee’s activities more
 
closely with Eurobank’s
 
digital transformation
 
objectives
is essential,
 
supported by
 
a phased
 
strategy
 
and clear
 
deliverables.
 
Members highlighted
 
the
 
importance of
 
leveraging
 
AI
and data
 
to drive
 
innovation,
 
enhance efficiency,
 
and improve
 
customer experience
 
while ensuring robust
 
governance
 
and
ethical AI use. Structural refinements, including more focused discussions and streamlined agendas, were also recommended
to enhance the Committee’s
 
effectiveness.
6.6.5
BDTC’s Activity in 2024
In 2024,
 
the BDTC
 
proposed its
 
Terms
 
of Reference
 
(ToR)
 
for
 
BoD approval.
 
Throughout
 
the year,
 
the Committee
 
reviewed
updates on the Eurobank
 
Transformation
 
and the Digital Key Performance
 
Indicators (KPIs) Dashboard.
Additionally,
 
the
 
Committee
 
examined
 
the
 
status
 
of
 
Generative
 
AI,
 
the
 
Core
 
Banking
 
System
 
in
 
Eurobank,
 
and
 
new
collaboration
 
and
 
communication
 
tools.
 
It
 
was
 
also
 
updated
 
on
 
International
 
Technology
 
/
 
Digital
 
Initiatives
 
in
 
new
geographies,
 
toured
 
Eurobank’s
 
new
 
premises
 
in
 
Nea
 
Ionia
 
(Campus
 
Project),
 
and
 
noted
 
progress
 
on
 
innovation
 
and
customer experience
 
initiatives.
7
Management Committees
As there is neither a regulatory requirement
 
nor a business necessity, the CEO has not established committees at the HoldCo
level.
At the Bank level, however,
 
the CEO establishes committees as needed to
 
assist in fulfilling his duties
 
and responsibilities. The
most
 
significant
 
committees
 
include
 
the
 
Executive
 
Board,
 
the
 
Strategic
 
Planning
 
Committee,
 
the
 
Management
 
Risk
Committee, the Group Asset and Liability Committee, the Central Credit Committees (I & II), the Troubled
 
Assets Committee,
the Products and Services
 
Committee (PSC), and the Environmental,
 
Social & Governance
 
(ESG) Management Committee.
7.1
Management Committees’ Policy
The
 
Bank
 
has
 
implemented
 
the
 
Management
 
Committees’
 
Policy,
 
which
 
defines
 
the
 
framework
 
and
 
general
 
principles
governing
 
the
 
establishment,
 
dissolution,
 
and
 
operation
 
of
 
a
 
Management
 
Committee
 
(MCo).
 
This
 
policy
 
aligns
 
with
international
 
corporate
 
governance
 
best practices
 
and regulatory
 
requirements,
 
where
 
applicable.
 
It
 
also establishes
 
the
minimum requirements for
 
each MCo’s Terms
 
of Reference (ToR).
According to the Management Committees’
 
Policy:
The
 
establishment
 
of
 
each
 
MCo
 
is
 
formally
 
announced
 
through
 
a
 
Management
 
Act,
 
which
 
clearly
 
defines
 
the
purpose, composition,
 
and Chairperson
 
of the
 
Committee. This
 
Management Act
 
is signed
 
by the
 
CEO and, where
applicable, by the responsible
 
Deputy CEO or General Manager.
The
 
MCo’s
 
ToR
 
are
 
approved
 
by
 
the
 
CEO
 
and
 
define,
 
among
 
other
 
aspects,
 
the
 
modus
 
operandi,
 
including
 
the
frequency
 
of
 
meetings,
 
quorum
 
requirements,
 
and
 
decision-making
 
process.
 
The
 
ToR
 
are
 
reviewed
 
regularly
 
and
revised as needed, with any updates also re
 
quiring the CEO’s approval.
 
 
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Individuals who
 
are not
 
MCo members
 
or the
 
MCo Secretary—such
 
as Board
 
members,
 
Bank or
 
Group subsidiary
officers, or external auditors/consultants—may be invited to attend all
 
or part of an
 
MCo meeting, depending on the
topics under discussion. These individuals do not have voting rights, and their attendance is determined by the MCo
Chairperson.
The
 
MCo
 
Secretary,
 
appointed
 
when
 
the
 
MCo
 
is
 
established
 
and
 
stated
 
in
 
the
 
Management
 
Act,
 
supports
 
the
Chairperson in ensuring
 
the effective
 
operation
 
of the
 
MCo. The
 
Secretary’s responsibilities
 
include maintaining an
annual
 
meeting
 
calendar,
 
coordinating
 
logistics,
 
recording
 
attendance,
 
ensuring
 
quorum
 
requirements
 
are
 
met,
documenting meeting minutes and resolutions, and issuing extracts of decisions. Additionally,
 
the Secretary notifies
responsible managers about relevant discussions
 
or actions required.
Each MCo
 
is required
 
to define
 
evaluation
 
criteria based
 
on its
 
ToR
 
and to
 
assess its
 
performance
 
annually.
 
If the
Chairperson
 
identifies
 
concerns
 
related
 
to
 
the
 
scope
 
or
 
functioning
 
of
 
the
 
MCo,
 
an
 
earlier
 
evaluation
 
may
 
be
conducted.
The CEO
 
has the discretion
 
to dissolve
 
an MCo at any
 
time, with
 
the dissolution
 
formally communicated
 
through a
Management Act.
7.2
Executive Board (ExBo)
7.2.1
CVs of ExBo members (other
 
than BoD members)
The composition of the Executive Board (ExBo), excluding the Executive Members of the Board of Directors who are also ExBo
members, is summarized
 
below.
 
The CVs
 
of Mr.
 
F.
 
Karavias (CEO),
 
Mr. S. Ioannou
 
(Deputy CEO), and Mr.
 
K. Vassiliou
 
(Deputy
CEO) are presented in
 
the Board of Directors section. Short
 
biographical details of the remaining ExBo
 
members are provided
below.
Christos Adam-General Manager,
 
Group Risk Management, Group
 
Chief Risk Officer (Group
 
CRO)
-
Year of birth: 1958
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 287,792
Mr.
 
Adam has
 
been
 
Group
 
CRO
 
since
 
November
 
2013
 
and he
 
has
 
served
 
within
 
the
 
Eurobank
 
Group
 
as Deputy
 
General
Manager
 
(2005-2013),
 
Head
 
of
 
Group
 
Credit
 
Control
 
Sector
 
(1998-2013)
 
and
 
Senior
 
Account
 
Officer
 
&
 
Senior
 
Manager,
Corporate Division (1990-1997). In the
 
past Mr. Adam worked
 
in ANZ Grindlays Greek Branch, he had the position of Account
Manager in the Corporate
 
Division.
He
 
holds
 
an
 
MBA
 
in
 
Finance
 
from
 
the
 
University
 
of
 
Michigan,
 
Ann
 
Arbor,
 
USA,
 
with
 
full
 
scholarship
 
from
 
the
 
Fulbright
Foundation and a Degree
 
in Economics with Honors from the School
 
of Economics & Political Sciences, University
 
of Athens.
Thanasis Athanasopoulos-General
 
Manager Group Compliance, Group
 
Chief Compliance Officer
-
Year of birth: 1973
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 313,087
In the
 
past, Mr.
 
Athanasopoulos has served
 
as Chief Audit
 
Executive of
 
the Alpha
 
Bank Group
 
and Vice
 
President -
 
Audit &
Risk Review of the Mellon Financial Corporation.
He
 
holds
 
a BSc,
 
Business Administration
 
from
 
the
 
Athens
 
University
 
of Economics
 
and
 
Business,
 
a MSc,
 
Banking from
 
the
University of Reading, a
 
MSc, Economic History
 
from the London School of
 
Economics and he is
 
certified as a Fellow Chartered
Accountant of ICAEW,
 
as a Fellow of the
 
International Compliance Association
 
and a Certified Director (IDP) by INSEAD.
Iakovos Giannaklis-Deputy
 
Chief Executive Officer,
 
Head of Retail & Digital Banking of Eurobank
 
SA
-
Year of birth: 1971
-
Nationality: Hellenic
-
Number of shares in Eurobank
 
Holdings: 217,592
He is also
 
the Vice-Chairman in the Board of Directors of
 
Worldline Merchant Acquiring Greece S.A. In the past, Mr. Giannaklis
held
 
BoD
 
positions
 
in
 
the
 
following
 
entities
 
of Eurobank
 
Group:
 
Eurobank
 
FPS
 
Loans
 
and Credits
 
Claim
 
Management
 
SA
(2018-2019),
 
Eurobank
 
Household
 
Lending
 
Services
 
SA
 
(2016-2018),
 
Eurobank
 
Asset
 
Management
 
MFMC
 
(2014-2017)
 
and
Eurobank Business Services (2009-2017). He
 
also held the following posts
 
in Eurobank: Head of
 
Retail Banking General Division
(2016-2023),
 
Head
 
of
 
Branch
 
Network
 
General
 
Division
 
(2014-2016),
 
Head
 
of
 
Branch
 
Network
 
Commercial
 
Development
Sector (2014), and Head of Branch Network Sector (2009-2014).
He has also been
 
a member
 
of the
 
BoDs of Eurolife
 
FFH Group
 
Holdings, General
 
Insurance and
 
Life Insurance
 
(2021-2023).
Mr Giannaklis also
 
served as Group Deputy General Manager, Retail and
 
Digital, Growth and Transformation in Bank Muscat,
Oman (2023)
 
 
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He holds
 
an MBA from
 
the
 
University of
 
Indianapolis, USA
 
and a BA
 
in Business
 
Administration,
 
from the
 
City University
 
of
Seattle, USA.
Tasos Ioannidis-General
 
Manager Markets,
 
Eurobank SA
-
Year of birth: 1968
-
Nationality: Hellenic
 
-
Number of shares in Eurobank
 
Holdings: 311,015
 
In the
 
past Mr.
 
Ioannidis has
 
served
 
as General
 
Manager,
 
Head of
 
Markets
 
& Asset
 
Management (July
 
2019 -
 
June 2024),
General
 
Manager,
 
Head of
 
Global
 
Markets
 
& Treasury
 
(April 2015
 
- July
 
2019), Deputy
 
General
 
Manager,
 
Head of
 
Global
Markets
 
& Treasury
 
(October
 
2013 -
 
March 2015),
 
Deputy General
 
Manager,
 
Group
 
Treasurer
 
(April 2009
 
- October
 
2013),
Deputy General
 
Manager,
 
Group Head
 
of Trading
 
(March 2007
 
- April
 
2009).
 
He has also
 
served
 
Member of
 
the BoD,
 
ERB
Hellas PLC (August 2006 - June 2022), Member of the BoD, ERB Hellas Ltd (Cayman Islands) (August 2006
 
- December 2022),
as Member
 
of the
 
BoD, Eurobank
 
Asset Management
 
MFMC (May 2015
 
- September
 
2017), Chairman of
 
the BoD,
 
Eurobank
ERB MFMC,
 
former
 
TT ELTA
 
MFMC (February
 
2014 -
 
September
 
2015), Member
 
of the
 
BoD, Global
 
Asset Management
 
SA
(June 2006 - December 2009), and Member
 
of the BoD, Portfolio
 
Investment SA (June 2002 - April 2003).
He holds
 
a MSc
 
in Shipping,
 
Trade
 
and Finance
 
from
 
Cass Business
 
School,
 
London, UK
 
and a
 
BSc,
 
School
 
of Mechanical
Engineering from the
 
National Technical
 
University of Athens.
Apostolos Kazakos-General
 
Manager, Group
 
Strategy,
 
Eurobank SA
-
Year of birth: 1972
-
Nationality: Hellenic
 
-
Number of shares in Eurobank
 
Holdings: 269,681
 
Mr.
 
Kazakos has
 
also served
 
as CEO of
 
Eurobank Telesis
 
Finance,Deputy CEO
 
of Eurobank
 
Equities, the
 
investment banking
and brokerage
 
arm of
 
Eurobank
 
Group
 
(May 2010
 
– August
 
2013), Assistant
 
General
 
Manager,
 
Head of
 
Group
 
Strategy
 
&
Investment Relations,
 
National Bank
 
of Greece
 
(August 2014 –
 
March 2015),
 
General
 
Manager and Head
 
of the
 
Investment
Banking,
 
Restructuring
 
& Capital
 
Investment
 
Division,
 
General
 
Bank, Piraeus
 
Group
 
(September
 
2013
 
 
July
 
2014), Senior
Executive and eventually
 
Head of the Investment
 
Banking Division,
 
Eurobank Equities
 
and Telesis
 
Bank (January 1998 – May
2010).
He holds an MSc in International Securities, Investment and Banking, International Securities Market Association (ISMA) from
the
 
University
 
of
 
Reading,
 
UK
 
and
 
a
 
Degree
 
in
 
Accounting,
 
Faculty
 
of
 
Administration
 
&
 
Finance
 
from
 
the
 
International
University of Greece.
Harris Kokologiannis
 
-General Manager,
 
Group Finance, Group
 
Chief Financial Officer (Group
 
CFO), Eurobank SA
-
Year of birth: 1967
-
Nationality: Hellenic
 
-
Number of shares in Eurobank
 
Holdings: 287,215
Mr. Kokologiannis
 
joined Eurobank
 
in January 2008
 
as Head of Group
 
Finance and Control
 
until his appointment
 
as Group
CFO in July 2013.
 
He has
 
served
 
as Audit
 
Supervisor,
 
Deloitte (Tax,
 
Audit, Management
 
Consultant), Group
 
CFO (Lafarge
 
Cement
 
- Heracles
General Cement Company),
 
Director of Finance and Control
 
(L’Oreal
 
Hellas), Group Financial Manager (PLIAS Group).
He is a Chartered
 
Accountant in UK,
 
member of
 
the Chartered
 
Institute of Management
 
Accountant (C.I.M.A.),
 
UK. He holds
an
 
MBA
 
from
 
the
 
University
 
of
 
Warwick
 
(UK)
 
and
 
a
 
BA
 
in
 
Business
 
Management
 
and
 
Organization
 
from
 
the
 
School
 
of
Economics and Business Science (ASOEE).
 
Michalis
 
Louis-Chief
 
Executive
 
Officer
 
(CEO)
 
&
 
Executive
 
Board
 
Member
 
of
 
Hellenic
 
Bank
 
Public
 
Company
 
Limited
 
&
Executive Committee Member of Eurobank
 
S.A.
-
Year of birth: 1962
-
Nationality: Cypriot
-
Number of shares in Eurobank
 
Holdings: 391,402
Mr.
 
Louis has
 
also served
 
as Head
 
of International
 
Activities General
 
Division (2014-2024)
 
& Group
 
Private Banking
 
(2019-
2024), CEO of Eurobank
 
Cyprus Ltd (2007-2024), Member of
 
the BoD of Eurobank
 
Private Bank Luxembourg
 
SA (2014-2024)
and Member of the Supervisory Board
 
(SB) of Eurobank Bulgaria AD (2015-2024).
Additionally,
 
he
 
was
 
a
 
Member
 
of
 
various
 
Committees
 
within
 
Eurobank
 
Group
 
and
 
served
 
on
 
the
 
Boards
 
of
 
multiple
subsidiaries abroad owned by
 
Eurobank Group.
Earlier
 
in
 
his
 
career,
 
he
 
held
 
Senior
 
Management
 
roles
 
at
 
Laiki
 
Bank
 
of
 
Cyprus
 
and
 
at
 
an
 
HSBC
 
subsidiary
 
in
 
New
 
York,
specializing in Corporate Finance.
 
 
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He holds a B.A in Accounting Studies from Ealing College, London, and an M.Sc. in Corporate
 
Finance & Accounting from the
London School of Economics.
Natassa Paschali-General Manager,
 
Group Human Resources General
 
Division, (Group CHRO),
 
Eurobank SA
-
Year of birth: 1972
-
Nationality: Greek
-
Number of shares in Eurobank
 
Holdings: 130,859
Mrs.
 
Paschali
 
is
 
the
 
Group
 
Chief
 
Resources
 
Officer
 
(Group
 
CHRO),
 
since
 
June
 
2018.In
 
the
 
past
 
she
 
has
 
served
 
within
 
the
Eurobank Group as Head of People Engagement (January 2017
 
– June 2018), Head
 
of HR, Eurobank Private Bank Luxembourg
SA (parallel assignment), Luxembourg (May 2014
 
– May 2017),
 
Head of HR
 
Line Management, Wholesale Banking (2008-2016).
 
She also
 
held positions
 
in Citigroup
 
-
 
Citibank International
 
Plc as
 
Head of
 
HR –
 
Vice President,
 
Global Corporate
and Investment
 
Banking Group,
 
(July 2006
 
– June
 
2008) and
 
Head of
 
Training
 
& Development
 
– Assistant
 
Vice
 
President,
Consumer Banking Group, (February
 
2004 – July 2006)
She
 
holds
 
a
 
MSc
 
in
 
Industrial
 
Relations
 
and
 
Personnel
 
Management
 
from
 
the
 
London
 
School
 
of
 
Economics
 
and
 
Political
Science (1995-1996)
 
and a BA in English
 
Language and Literature
 
from the
 
University of
 
Athens, School
 
of Philosophy (1991-
1995).
Ioannis Serafeimidis-General
 
Manager, Retail Banking Strategy
 
& Growth, Chief Retail
 
Growth Officer,
 
Eurobank SA
-
Year of birth: 1973
-
Nationality: Hellenic
 
-
Number of shares in Eurobank
 
Holdings:
214,271
Mr Serafimidis
 
is also a
 
Non-Executive member
 
of the
 
BoDs in, Eurolife
 
FFH Insurance
 
Group Holdings
 
SA (since
 
July 2023),
Eurolife FFH Life
 
Insurance SA (since July 2023) and Eurolife
 
FFH General Insurance
 
SA (since July 2023).
In the past Mr. Serafeimidis
 
has served as Head of Retail Banking Channels, General
 
Manager
 
(2023-2024), Head of Branch
Network, General
 
Manager (2019-2023),
 
Executive Director
 
and Head
 
of Retail
 
Banking, Postbank,
 
Sofia (2014-2019),
 
Head
of Branch
 
Network, Postbank,
 
Sofia (2011-2014),
 
Senior Executive
 
Manager and
 
Head of
 
Small Business
 
Banking, Bancpost,
Bucharest (2008-2011), as well as other significant posts in Eurobank’s Branch Network, which he joined in 2002 after a 4 year
incumbency in KPMG Management Consulting in Athens.
He holds an MSc in
 
International Relations from London School of Economics (UK) and
 
a BSc in Economics
 
from the University
College London (UK).
Mrs. Veronique
 
Karalis,
 
Deputy Group
 
Company Secretary,
 
serves
 
as the
 
Secretary
 
of the
 
ExBo and
 
reports
 
to the
 
Group
Company Secretariat.
The ExBo manages the
 
implementation of Group’s
 
strategy in line with the
 
Board’s guidance.
 
The ExBo meets on a weekly
 
basis or ad hoc when necessary.
 
The
 
ExBo
 
is
 
in
 
quorum
 
and
 
meets
 
validly
 
when
 
half
 
of
 
its
 
members
 
plus
 
one
 
are
 
present
 
or
 
represented
 
and
 
either
 
the
Chairperson or the longest-serving Deputy
 
CEO (if chairing)
 
is present. In
 
determining the number of members
 
for the quorum,
fractions, if any,
 
shall not be counted. The ExBo resolutions
 
require a majority vote.
 
The ExBo’s key
 
tasks and responsibilities are to:
manage the implementation
 
of the Group’s
 
strategy, in line
 
with the BoD’s guidance
draw up the annual budget and the
 
business plan
approve
 
issues
 
concerning
 
the
 
Group’s
 
strategic
 
choices
 
(e.g.
 
partnerships,
 
share
 
capital
 
increase,
 
issuing
convertibles
 
and/or
 
launching
 
debt
 
issuance
 
programs,
 
mergers,
 
acquisitions
 
or
 
disposals,
 
the
 
formation
 
of
 
joint
ventures, creation
 
or dissolution of special purpose vehicles,
 
dividend distribution and all other
 
investments or non-
material disinvestments
 
by the
 
Group etc.), ensuring
 
these being in
 
line with the
 
approved
 
Group’s
 
strategy,
 
if the
issue under discussion is less than or equal to €40 million. In case though:
 
a.
the issue under discussion exceeds
 
€ 40 million,
b.
a decision of the Board is obligatory
 
by Law or by the Bank’s contractual
 
commitments,
c.
it is deemed necessary
 
by the
 
SPC, taking into account the
 
complexity and nature
 
of the strategic
 
choices
under discussion, the issues concerning
 
the Group’s
 
strategic choices are
 
approved by the
 
Board following
a relevant proposal by the
 
SPC (as per its Terms
 
of Reference)
monitor the
 
performance
 
of each business
 
unit and country
 
against budget and ensure
 
corrective
 
measures are
 
in
place wherever
 
required
decide on
 
all major
 
Group’s
 
initiatives
 
aiming
 
at transforming
 
the
 
business and
 
operating
 
model, enhancing
 
the
operating efficiency
 
and cost rationalization,
 
improving organizational
 
and business structure
ensure that adequate systems of internal controls
 
are properly
 
maintained
 
 
 
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review and approve
 
Bank’s Policies
 
and other governance
 
documents
 
that are related to its responsibilities and/or
are of critical importance to the
 
Bank,
 
review the
 
performance
 
of any Committee and /or individuals
 
to whom it has delegated
 
part of its responsibilities,
as approved
ensure adequacy of Resolution Planning governance,
 
processes and systems
 
hire and retain external consulting firms and approve
 
their compensation and terms
 
of engagement in accordance
with Bank’s policies and procedures
hire
 
and
 
retain
 
investment
 
banking
 
advisors,
 
and
 
approve
 
their
 
compensation
 
and
 
terms
 
of
 
engagement,
 
in
accordance with Bank’s policies and procedures,
 
where applicable
By
 
the
 
date
 
of
 
issuance
 
of
 
the
 
2024
 
Corporate
 
Governance
 
Statement,
 
ExBo’s
 
self-evaluation
 
for
 
2024
 
was
 
in
 
progress.
According
 
to ExBo’s
 
self-evaluation
 
for
 
2023,
 
it was
 
determined
 
that
 
its overall
 
performance
 
remained
 
strong
 
in all
 
areas
with a slight
 
decrease vs. last
 
year. Members of ExBo discussed
 
the following considerations: i) number of items
 
in the agendas
being excessive,
 
ii) Meetings’
 
agenda being
 
more
 
focused
 
on regulatory
 
and operational
 
and less
 
strategic
 
and business
oriented and iii) supporting material being lengthy and the
 
necessity of an executive summary.
7.3
Strategic Planning Committee
The primary purpose of the SPC is to support Management in planning, developing,
 
and implementing the Group’s
 
strategy.
Additionally,
 
the
 
SPC
 
is
 
responsible
 
for
 
recommending
 
certain
 
strategic
 
initiatives
 
to
 
the
 
Board
 
for
 
consideration
 
and
approval.
The key tasks and responsibilities
 
of the SPC are:
To
 
ensure
 
that
 
the
 
Group
 
establishes
 
a
 
well-defined,
 
planned
 
medium-term
 
strategy
 
aligned
 
with
 
the
 
Board’s
guidance and the approved
 
business plan.
To
 
review
 
the
 
key objectives
 
and goals
 
within the
 
framework
 
established by
 
the
 
Executive
 
Board’s annual
 
budget
and business plan, as well as major business initiatives, prior
 
to their submission for Board
 
approval.
To
 
review,
 
analyze,
 
and
 
deliberate
 
on
 
issues
 
concerning
 
the
 
Group’s
 
strategic
 
choices—such
 
as
 
strategic
partnerships,
 
capital
 
increases,
 
issuance
 
of
 
convertible
 
or
 
debt
 
instruments,
 
mergers/demergers,
 
acquisitions
 
or
disposals, joint ventures,
 
creation or dissolution
 
of special purpose vehicles, dividend distributions,
 
and other
 
major
investments or divestments—ensuring alignment with the approved
 
Group strategy.
 
The SPC will formulate relevant
proposals to the Board
 
if:
a)
The matter under discussion exceeds €40
 
million, while lower amounts
 
are approved by the Executive Board.
b)
A decision by the Board
 
is required by law or by the
 
Bank’s contractual commitments.
c)
The
 
SPC
 
deems Board
 
consideration
 
necessary
 
due to
 
the
 
complexity or
 
nature
 
of the
 
strategic
 
choices
under discussion.
To
 
submit proposals
 
to the
 
Board
 
for
 
approval
 
concerning
 
the
 
strategy
 
and budget
 
of the
 
property
 
portfolio,
 
as
outlined in the Service
 
Level Agreement
 
between Eurobank and Grivalia Management
 
Company.
To
 
submit
 
proposals
 
to
 
the
 
Board
 
for
 
approval
 
concerning
 
the
 
acquisition
 
or
 
disposal
 
of
 
assets,
 
excluding
repossessed
 
assets
 
(as
 
defined
 
in
 
the
 
Service
 
Level
 
Agreement
 
between
 
Eurobank
 
and
 
Grivalia
 
Management
Company), with a book value exceeding €10 million.
To
 
submit
 
proposals
 
to
 
the
 
Board
 
for
 
approval
 
regarding
 
the
 
disposal
 
of
 
repossessed
 
assets,
 
as
 
defined
 
in
 
the
Service Level Agreement between Eurobank and Grivalia Management Company, with a
 
gross book value exceeding
€20 million.
To
 
maintain
 
and
 
implement
 
all
 
necessary
 
measures
 
for
 
regulatory
 
and
 
internal
 
capital
 
management,
 
ensuring
sufficient
 
coverage
 
for
 
all
 
risk
 
types,
 
including
 
strategic,
 
reputational,
 
and
 
other
 
non-quantifiable
 
risks,
 
to
consistently meet capital requirements
 
.
 
To review
 
and assess all major Group initiatives aimed at
 
transforming the
 
business and operating model.
 
To regularly
 
monitor the Group's strategic
 
and key performance
 
indicators, including a segmental perspective.
 
To review
 
and, when necessary, make recommendations
 
to the Board on any other matters
 
of strategic significance
to the Group.
The SPC meets on a weekly
 
basis or ad hoc, when necessary.
 
The
 
SPC is
 
in quorum
 
and meets
 
validly when
 
a) half
 
of its
 
members
 
plus one
 
are present
 
(fractions
 
are excluded
 
from the
computation),
 
provided
 
that
 
at least
 
three
 
members
 
are present
 
and b)
 
SPC’s Chairperson
 
or the
 
longest serving
 
Deputy
CEO in attendance,
 
entitled to chair the Committee, is present.
 
Decisions are passed by majority vote. In
 
case of a tie of votes, SPC’s Chairperson has the casting vote.
 
If SPC’s Chairperson
is absent, the longest serving Deputy CEO in attendance,
 
entitled to chair the Committee, has the casting vote.
 
9
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
 
 
 
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By
 
the
 
date
 
of
 
issuance
 
of
 
the
 
2024
 
Corporate
 
Governance
 
Statement,
 
SPC’s
 
self-evaluation
 
for
 
2024
 
was
 
in
 
progress.
According
 
to
 
SPC’s
 
self-evaluation
 
for
 
2023,
 
it was
 
determined
 
that
 
its
 
overall
 
performance
 
and
 
all
 
the
 
specific
 
areas
 
of
evaluation
 
i.e. the
 
profile and
 
composition, the
 
organization
 
and administration
 
and the
 
key tasks
 
and responsibilities,
 
are
strong.
 
7.4
Management Risk Committee
The main responsibility of the MRC is to oversee
 
the risk management framework
 
of Eurobank S.A. (“the
 
Bank”). As part of its
responsibility,
 
the
 
MRC
 
facilitates
 
reporting
 
to
 
the
 
BRC
 
on
 
the
 
range
 
of
 
risk-related
 
topics
 
under
 
its
 
purview.
 
The
 
MRC
proactively
 
supports the
 
Group
 
CRO to
 
identify material
 
risks, in
 
addition
 
to those
 
identified independently
 
by the
 
Group
CRO and the
 
Group Risk
 
Management General
 
Division, and to
 
promptly escalate
 
them to
 
the BRC
 
and assists the
 
Group
CRO
 
in
 
ensuring
 
that
 
the
 
necessary
 
policies
 
and
 
procedures
 
are
 
in
 
place
 
to
 
prudently
 
manage
 
risk
 
and
 
to
 
comply
 
with
regulatory requirements.
 
As part of its responsibility, the
 
MRC, facilitates reporting to the
 
BRC on the range of risk-related
 
topics under its purview.
The
 
MRC understands
 
and evaluates
 
risks, addresses
 
issues, promotes
 
the
 
implementation
 
of risk
 
policies
 
and informs
 
the
BRC
 
of
 
the
 
Group’s
 
risk
 
profile.
 
Furthermore,
 
the
 
MRC
 
assists
 
the
 
BRC
 
in
 
defining
 
risk
 
management
 
principles
 
and
methodologies, thereby ensuring that the Group’s risk management framework contains processes for identifying,
 
measuring,
monitoring, mitigating and reporting the current
 
risk profile against its risk appetite, limits and performance
 
targets.
 
Specific responsibilities performed
 
by the MRC are relevant
 
to the following
 
areas:
Alignment of Business Plan with Risk Appetite
 
Provisioning
Risk monitoring, reporting and remediation
Stress Testing Programme
Regulatory required Stress Tests
 
(EBA / ECB)
Group ICAAP and ILAAP
Group Recovery
 
Plan
Internal Model approval, results
 
monitoring and reporting
BCBS 239 – Risk Data Aggregation and Risk Reporting (RDARR)
Resolution Planning
Reporting
Significant Risk Transfer
 
(SRT)
The
 
MRC achieves
 
quorum when
 
at least
 
five of
 
its members,
 
including the
 
Chairman, are
 
present. Selected
 
attendees can
be invited to the
 
MRC meetings, when
 
the topics
 
for discussion
 
fall under
 
their remit
 
or they
 
have the
 
requisite expertise
 
to
constructively participate. The
 
finalized minutes are distributed to the MRC and BRC members.
 
By the date
 
of issuance of the
 
2024 Corporate
 
Governance
 
Statement, MRC’s self-evaluation
 
for 2024
 
was in progress.
 
For
2023, it was determined that its overall
 
performance and all the
 
specific areas of evaluation i.e. the profile
 
and composition,
the organization
 
and administration and
 
the key
 
tasks and responsibilities, are
 
strong. Members reviewed
 
key points raised
by the
 
self-assessment exercise,
 
noting that
 
the main
 
issues concern
 
members’
 
attendance and participation,
 
the length
 
of
the
 
meeting
 
and
 
the
 
agenda
 
as
 
well
 
as
 
the
 
timely
 
submissions.
 
Members
 
exchanged
 
opinions
 
on
 
how
 
to
 
improve
 
the
committee
 
and
 
agreed
 
on
 
the
 
need
 
to
 
educate
 
the
 
presenters
 
to
 
be
 
short
 
and
 
concise
 
so
 
as
 
to
 
allow
 
more
 
time
 
for
questions/discussion.
 
7.5
Group Asset and Liability Committee (G-ALCO)
 
G-ALCO’s primary mandate is to:
a)
formulate, propose, approve,
 
implement and monitor – as the case may be
 
- the Group’s i) liquidity position and risk
profile and its funding strategies and policies
 
ii) interest rate guidelines and interest
 
rate risk profile and policies iii)
Capital
 
investments
 
-
 
as
 
well
 
as
 
FX
 
exposure
 
and
 
hedging
 
-
 
strategy
 
iv)
 
Group’s
 
business
 
initiatives
 
and/or
investments that
 
affect the
 
bank’s capital, market
 
and liquidity risk profile.
 
Further,
 
to approve
 
at a first stage, and
recommend
 
to BRC
 
for
 
final approval
 
the
 
respective
 
country limits
 
and the
 
relevant
 
policy/methodology
 
(special
attention is given for
 
the approval/monitoring of
 
the limits for
 
countries where Eurobank
 
has a local presence).
b)
approve
 
or propose
 
– as the case
 
may be - changes
 
to these policies
 
that conform
 
to the
 
Bank’s risk appetite and
levels
 
of exposure
 
as determined
 
by the
 
Board Risk
 
Committee (and
 
BoD as
 
the
 
case may
 
be) and
 
Management,
while complying with the framework
 
established by regulatory/supervisory
 
authorities.
G-
 
ALCO
 
responsibility
 
is
 
to
 
also
 
review
 
the
 
overall
 
liquidity
 
positions
 
and
 
developments
 
of
 
the
 
Group
 
on
 
a
 
country-by-
country level. In this
 
context, international subsidiaries’ ALCOs should report on
 
monthly basis material country developments
10
Information regarding current composition and short biographical details of its
 
members may be found at the Bank’s
 
website (www.eurobank.gr).
11
Information regarding current composition and short biographical details of its
 
members may be found at the Bank’s
 
website (www.eurobank.gr).
 
 
 
 
 
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and decisions (reflected in respective country ALCO minutes) to G-ALCO,
 
based on the above principles and their respective
regulatory/supervisory authorities’
 
instructions and guidelines.
The key tasks and responsibilities
 
of G-ALCO are the
 
following:
Regarding
 
the
 
approval
 
of
 
general
 
policies
 
and
 
guidelines,
 
compliance
 
with
 
regulatory
 
requirements,
 
review
 
of
activities/investments, risks & exposures:
Formulate, propose and/or modify - as
 
appropriate - guidelines and
 
pricing policies for deposit
 
and loan interest
rates for
 
the Group, as well
 
as review and approve
 
business proposals for pricing loans
 
and deposits.
Regularly review,
 
adapt/modify - as
 
may be required
 
– and approve
 
on an annual
 
basis (or
 
ad-hoc if needed)
the
 
Group’s
 
internal Funds
 
Transfer
 
Pricing (FTP)
 
policies and
 
FTP annual
 
budget/business plan
 
guidelines,
 
in
order
 
to
 
reflect
 
current
 
market
 
developments
 
and
 
business
 
objectives.
 
With
 
regards
 
to
 
International
Subsidiaries,
 
local
 
FTP
 
policy
 
is
 
reviewed,
 
adapted/modified,
 
approved
 
by
 
local
 
ALCOs
 
and
 
presented
 
for
approval/acknowledgement
 
to G-ALCO whenever
 
it is deemed necessary.
 
Review
 
International
 
subsidiaries’
 
Capital
 
investments,
 
FX
 
exposures
 
and
 
hedging
 
strategies,
 
and
 
approve
related actions as may be required.
Review and
 
approve
 
the Market
 
& Counterparty
 
Risk policy
 
and the
 
relevant KRIs
 
and the
 
RAS framework
 
for
market and counterparty risks before
 
their submission to BRC/BoD.
Be informed of the MREL requirement and the MREL issuance plan following its approval by the BRC; review and
approve individual MREL instruments’ wholesale
 
issuance and related costs in the context of the approved
 
plan
and MREL targets. Similar intra-group requirements by International Subsidiaries are separately assessed when
they arise.
Approve the
 
liquidity-related resolution
 
deliverables prior
 
to their submission to the SRB/NRA.
Approve the
 
implementation of MREL and liquidity options
 
within the context of the Group’s
 
Recovery Plan.
Review
 
ERB/Group material
 
market risks
 
and exposures
 
across investment
 
portfolios
 
(AC, FVOCI
 
etc) and
 
risk
dimensions
 
(e.g.,
 
interest
 
rate
 
risk,
 
liquidity/currency
 
mismatch)
 
as
 
may
 
be
 
identified
 
by
 
Markets
 
&
 
and/or
GMCRS, and recommend actions as may be required.
Approve Markets’
 
new trading & investment
 
activities for the
 
bank’s own books (Trading,
 
FVOCI, AC).
 
Review
 
on annual
 
basis country
 
exposures/limits and
 
sovereign
 
exposure/limits (as
 
per Sovereign
 
Risk Policy);
approve
 
new
 
Country and/or
 
Sovereign
 
limits when
 
proposed
 
and modify
 
existing Country
 
and/or Sovereign
limits as/when
 
appropriate.
 
Any Country
 
Limit increases
 
approved
 
by G-ALCO
 
also require
 
BRC approval.
 
G-
ALCO
 
should allocate
 
country
 
limits between
 
exposures
 
in state
 
bonds/treasury
 
bills and
 
exposures
 
in credit
facilities to state controlled
 
entities.
Within the
 
context of the
 
approved
 
investment framework
 
for corporate/FI
 
bond portfolio,
 
review the
 
relevant
portfolio
 
limits
 
annually.
 
Review
 
and
 
approve
 
(prior
 
to
 
Group’s
 
formal
 
commitment)
 
business
 
proposals
 
for
planned
 
soft
 
underwriting
 
commitments.
 
Review
 
and
 
clear
 
hard
 
underwriting
 
commitments;
 
to
 
note,
 
these
would also require prior approval
 
by the appropriate
 
Credit Committees as per existing Credit policies.
Regarding Liquidity Risk
Within the
 
scope of the Group’s
 
Liquidity Risk Policy,
 
i) monitor the implementation of
 
the Asset Encumberance
policy and
 
the
 
execution
 
of the
 
Contingency Funding
 
Plan process,
 
as may
 
be required,
 
ii) establish,
 
monitor,
propose and approve
 
- as may be required - actions for the
 
maintenance of adequate liquidity buffers
 
in order
to withstand liquidity stress (or
 
alternatively,
 
adverse liquidity) events
 
and comply (as possible) with regulatory
requirements and internal thresholds
 
or targets.
Ensure
 
that
 
the
 
Group
 
Liquidity
 
Risk
 
policy
 
is
 
properly
 
coordinated,
 
integrated
 
and
 
updated
 
 
as
 
may
 
be
required
 
and
 
in
 
compliance
 
with
 
the
 
relevant
 
regulatory
 
framework,
 
and
 
market
 
practices
 
-
 
across
 
Group
entities.
Review planned/projected liquidity profile and performance,
 
monitor regulatory liquidity risk ratios (LCR, NSFR);
review wholesale funding strategies
 
and initiatives, and approve
 
related actions for the
 
Bank/Group.
 
Report
 
the
 
Bank’s
 
liquidity
 
position,
 
projections
 
and
 
risks,
 
recommend
 
actions
 
related
 
to
 
liquidity
 
risk
management
 
as
 
may
 
be
 
required
 
to
 
the
 
Board
 
Risk
 
Committee
 
(BRC)
 
and
 
BoD),
 
and
 
implement
 
/
 
monitor
related BRC and/or BoD decisions.
Review regulatory liquidity ratios,
 
liquidity stress tests, and internal liquidity related warning indicators.
 
Review
material liquidity
 
risks; formulate,
 
approve,
 
and propose
 
to MRC
 
related stress
 
test scenarios.
 
Formulate
 
and
implement action
 
plans in case
 
regulatory liquidity ratios
 
and indicators’
 
evolution
 
(and/or stress tests
 
results)
may so require, in the context of the
 
Group’s policies,
 
risk appetite and regulatory framework.
Determine
 
the
 
appropriate
 
KRIs
 
and
 
related
 
framework
 
for
 
the
 
monitoring
 
of
 
liquidity
 
risk,
 
approve
 
the
proposed KRIs and framework
 
before their
 
submission to BRC and BoD.
 
 
 
 
 
 
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Review
 
and approve
 
the
 
periodic
 
funding
 
plan,
 
including
 
the
 
funding
 
plan which
 
is
 
prepared
 
for
 
the
 
ILAAP/
ICAAP
 
exercise,
 
and
 
take
 
its
 
results
 
into
 
consideration
 
in
 
its
 
decision
 
making
 
process
 
as
 
appropriate.
 
Also,
review and approve
 
the LCR restoration
 
plan and the related funding
 
plan, and any major changes to it.
Regarding Interest Rate Risk in the
 
Banking Book (IRRBB) and Credit Spread Risk in the
 
Banking Book (CSRBB), G-ALCO (as
delegated by
 
the
 
BoD and
 
BRC) has
 
the
 
overall
 
responsibility for
 
the
 
monitoring and
 
management of
 
said risks,
 
and clear
authority over the
 
units responsible for taking such risks.
 
More specifically,
 
G-ALCO’s tasks, authorities and responsibilities are
 
to:
Formulate
 
the
 
Group’s
 
IRRBB and
 
CSRBB Policies’
 
framework
 
and assumptions
 
(e.g., models,
 
stress scenarios
etc.) before its submission to BRC/BoD; review
 
and approve the
 
Group’s strategies
 
for managing relevant risks
 
Review
 
and
 
approve
 
the
 
Group’s
 
guidelines
 
for
 
the
 
systems
 
used
 
for
 
IRRBB
 
and
 
CSRBB
 
monitoring
 
and
assessment; further
 
propose to BRC for
 
final approval
Formulate the risk appetite and appropriate exposure limits
 
(RAF thresholds) for the IRRBB and
 
CSRBB; propose
for approval
 
to BRC and BoD;
 
Establish a comprehensive IRRBB and
 
CSRBB reporting and
 
monitoring framework to regularly assess the IRRBB
and
 
CSRBB
 
exposure
 
against
 
the
 
respective
 
limits
 
(as
 
they
 
are
 
established);
 
GMCRS
 
is
 
the
 
responsible
monitoring/reporting unit
Ensure
 
that
 
adequate
 
controls
 
and
 
procedures
 
are
 
in
 
place,
 
and
 
appropriate
 
management
 
actions
 
are
triggered, when set limits and early warnings levels
 
are breached
Evaluate the
 
performance,
 
and impact, of
 
risk management
 
strategies
 
applied to relevant
 
exposures (interest
rate, credit risk) on EVE and NII in the
 
context of the IRRBB/CSRBB Policy
 
and Management targets
Approve
 
the Economic Hedging
 
Framework
 
and propose its
 
approval to
 
BRC/BoD (also part of
 
the IRRBB
 
and
CSRBB Policy)
Define the
 
high-level risk
 
management strategy
 
on a periodic
 
basis - quarterly
 
or ad hoc as may
 
be required -
in the context of the Economic Hedging
 
Framework (established to hedge the bank’s interest rate risk and credit
risk exposures on a
 
portfolio basis). Further,
 
to monitor and
 
evaluate the outcome of hedging strategies, request
their extension or
 
termination, escalate
 
significant developments
 
to BRC/BoD, monitor the
 
RAF thresholds and
the effect
 
of hedging strategies on the
 
CAD ratio and Bank results.
Review
 
and
 
approve
 
proposals
 
to
 
use
 
new
 
products,
 
or
 
engage
 
in
 
new
 
activities
 
-
 
related
 
to
 
risk
 
taking
 
or
hedging strategies,
 
prior to
 
acquisition or
 
implementation,
 
to ensure
 
that the
 
resources
 
required
 
to establish
sound and effective IRRBB management of the product
 
or activity have been identified, the proposed activities
are in line with the institution’s overall
 
risk appetite and RAS, and that procedures to identify, measure,
 
monitor
and control
 
the risks
 
of the
 
proposed product
 
or activity have
 
been established.
 
It should be
 
ensured that
 
the
IRRBB characteristics of these
 
new products and activities are well
 
understood.
Approve major hedging or risk-taking initiatives
 
in advance of implementation. Ensure that positions related
 
to
internal risk transfers
 
between the non-trading
 
book and the trading
 
book are properly
 
documented.
Key reports reviewed
 
by G-ALCO:
Loans and Deposits evolutions
 
(Greece and International)
Deposits Structure (Core, Time
 
Deposits)
Deposit rates evolution
 
(per business unit) and market share evolution
 
(Greece)
LCR & NSFR evolution
 
on a monthly basis (at a Solo and Group level)
FTP budget/business plan guidelines and funding cost
Sources and Uses of funds at Group/country
 
level, secured funding report
Liquidity buffer analysis (Solo,
 
Group, and per country).
 
Liquidity stress tests
Liquidity risk analysis/sensitivities
Interest Rate Gap report
Market risk analytics reports (PV01 in FVOCI
 
and AC, VaR analysis, historical
 
simulation results and reporting of
the relevant
 
KRIs for MTM exposure
 
in OCI & AC,
 
evolution of
 
RWAs for
 
market risk, reports on
 
the level
 
of KRIs
related to market risk.
IRRBB reports:
 
sensitivity of
 
NII
 
and sensitivity
 
of EVE
 
per
 
regulatory
 
framework
 
(EBA IRRBB
 
guideline)
 
& per
internal framework
Greek sovereign
 
exposure report (internal and regulatory)
RWA movement
 
report
 
 
 
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Secured funding analysis report
Quarterly report on economic hedging positions
International subsidiaries’ liquidity buffers
 
and regulatory ratios
International subsidiaries’ FX net investment
 
hedging analysis
Annually / or more frequently if needed:
Internal or external auditors reports with reference
 
to G-ALCO areas of responsibility.
 
Regulatory Reports with reference
 
to G-ALCO areas of responsibility
G-ALCO convenes once
 
a month and/or whenever
 
required.
 
Required
 
quorum
 
for
 
G-ALCO
 
meetings
 
to
 
be
 
effective
 
is
 
six
 
members.
 
In
 
order
 
to
 
have
 
a
 
quorum
 
the
 
presence
 
of
 
its
Chairperson and a
 
minimum of three
 
(3) SPC members
 
is required.
 
Decisions on issues
 
are to be
 
taken by majority;
 
in case
of a tie
 
vote,
 
the issue
 
under discussion
 
is escalated
 
to ExBo.
 
Additionally,
 
under exceptional
 
circumstances,
 
decisions may
be taken by circulation,
 
which is equal to a decision of the G-ALCO, even
 
if no meeting has taken place. A relevant approval
memo is then issued by the
 
Secretary.
During 2023 an extensive review and update of G-ALCO’s
 
Terms
 
of reference
 
was performed, with the
 
process completed in
Q4
 
2023,
 
while
 
the
 
membership
 
composition
 
also
 
changed.
 
In
 
this
 
context,
 
the
 
committee’s
 
performance
 
review
 
was
extended to
 
include 2024
 
for completeness;
 
it was determined
 
that: i)
 
G-ALCO
 
members’
 
composition and
 
engagement is
well appropriate,
 
and the committee’s
 
performance
 
is well satisfactory
 
ii) the Committee continues
 
to function effectively
 
in
relation
 
to its
 
mandate
 
and responsibilities,
 
with
 
members
 
actively
 
engaging in
 
critical
 
discussions
 
during
 
meetings,
 
with
special focus
 
on topics regarding
 
key risk
 
and regulatory/supervisory
 
issues iii) in
 
light of the
 
complexity and importance
 
of
issues arising,
 
the
 
continued evolution
 
of the
 
regulatory
 
framework
 
and complexity,
 
and the
 
emergence
 
of additional
 
risk
considerations/requirements
 
or activities, G-ALCO
 
should continue to improve
 
its organizational
 
and operational
 
efficiency
and
 
further
 
increase
 
the
 
scheduled
 
frequency,
 
and/or
 
length
 
of
 
meetings
 
(as
 
possible),
 
as
 
may
 
be
 
required
 
to
 
remain
 
as
effective.
 
Said action was already implemented for
 
the 2025 scheduled meetings
 
plan.
7.6
Central Credit Committees
7.6.1
Central Credit Committee I
The main objective
 
of Central Credit Committee I (CCCI)
 
is to ensure the objective
 
credit underwriting of relevant
 
exposures
of Greek
 
corporate
 
performing
 
and private
 
banking clients,
 
in accordance
 
to the
 
Risk Appetite
 
Framework
 
and the
 
Credit
Policy Manual of the Bank and in a way that
 
balances credit risk and return on equity.
The
 
CCCI is
 
chaired by
 
an independent to
 
Business and
 
Risk Professional,
 
convenes at
 
least once
 
a week
 
and all meetings
are minuted. Decisions are taken unanimously. If unanimity is
 
not achieved, the credit request is escalated by the Chairperson
to the
 
next (higher)
 
approval
 
level requiring
 
a unanimous decision.
 
In case
 
of non-unanimity the
 
final decision
 
lies with
 
the
Management Risk Committee (MRC), by majority voting.
The
 
main duty
 
and responsibility
 
of the
 
CCCI
 
is to
 
assess
 
and approve
 
all credit
 
requests
 
for
 
clients in
 
the
 
Greek
 
related
corporate
 
performing
 
and
 
private
 
banking
 
portfolio
 
of
 
a
 
total
 
exposure
 
above
 
€50mio
 
and
 
unsecured
 
exposure
 
above
€35mio. For total exposure exceeding €75mio and unsecured exposure exceeding €50mio, additional approval
 
by the GCRO
is required, while for
 
total exposure exceeding €150mio and unsecured
 
exposure exceeding €100mio, additional approval
 
by
the CEO is required. Furthermore,
 
for exposures higher than
 
10% (or 20% for selected borrowers
 
where no single risk exists) of
the Bank’s regulatory
 
capital the additional
 
approval of
 
the Management
 
Risk Committee (MRC) is required.
 
Subsequently,
the final approval is granted
 
by the Board Risk Committee (BRC).
7.6.2
Central Credit Committee II
The main objective
 
of the Central Credit
 
Committee II (CCCII) is the same as for
 
the CCCI for
 
lower levels
 
of exposure.
 
The CCCII convenes
 
at least once a week and all meetings are
 
minuted. Decisions are taken unanimously.
 
If unanimity is not
achieved, the
 
request is escalated by the Chairperson
 
to the next approval
 
level.
The main duty
 
and responsibility of
 
CCCII is to
 
assess and
 
approve all credit requests for clients
 
in the Greek related
 
corporate
performing and private banking portfolio for total exposure from €20mio up to €50mio and unsecured exposure from €10mio
up to €35mio and retail exposures for
 
total limits above €3mio.
 
By the date of issuance of
 
the 2024 Corporate Governance Statement, Committee’s self-evaluation for 2024 was in progress.
12
Information regarding current composition and short biographical details of its
 
members may be found at the Bank’s
 
website (www.eurobank.gr).
 
 
 
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7.7
Troubled Assets Committee
The Troubled
 
Assets Committee
 
(TAC)
 
is established according
 
to the
 
regulatory provisions.
 
The main
 
purpose of TAC
 
is to
act as an independent
 
oversight
 
body, closely
 
monitoring the
 
Bank’s troubled
 
assets portfolio
 
and the
 
execution of its
 
NPE
Management Strategy.
 
The
 
Committee
 
meets
 
at
 
least
 
once
 
per
 
month
 
and/or
 
whenever
 
required
 
if
 
the
 
majority
 
of
 
the
 
members,
 
including
 
the
Chairperson, are
 
present. Decisions
 
are taken
 
by majority,
 
are minuted and
 
circulated as
 
appropriate.
 
The Chairman
 
has a
castin vote.
 
TAC
 
cooperates
 
with Group Risk
 
Management to reach
 
a mutual understanding and develop
 
an appropriate methodology
for
 
the evaluation
 
of the
 
risks inherent
 
in the
 
portfolio
 
management. TAC’s
 
propositions
 
regarding NPE
 
policy updates
 
are
submitted to the Board Risk Committee. In exceptional
 
circumstances, decisions may be taken by
 
circulation.
 
TAC’s main responsibilities
 
are to:
review internal reports
 
regarding troubled assets management
 
under the regulatory
 
provisions,
approve
 
the
 
available
 
forbearance,
 
resolution
 
and closure
 
solutions
 
by
 
loan
 
sub-portfolio,
 
and monitor
 
their
performance through
 
Key Performance
 
Indicators (KPIs),
define the criteria to assess the sustainability of credit
 
and collateral
 
workout solutions through
 
the design and
use of “decision trees”,
approve, monitor and assess pilot
 
modification programmes
 
and
supervise and provide guidance and
 
know-how to the respective troubled assets
 
units of Eurobank’s subsidiaries
abroad.
By the date of issuance of
 
the 2024 Corporate Governance Statement, Committee’s self-evaluation for 2024 was in progress.
For
 
2023,
 
the
 
evaluation
 
concluded
 
that
 
the
 
committee
 
operates
 
effectively,
 
in
 
the
 
areas
 
of
 
Profile
 
and
 
Composition,
Organization
 
&
 
Administration
 
as
 
well
 
as
 
regarding
 
the
 
Key
 
Tasks
 
and
 
Responsibilities.
 
However,
 
the
 
evaluation
 
also
identified that
 
while the
 
overall
 
quality and
 
quantity of
 
information
 
submitted related
 
to the
 
proposals for
 
assessment by
the TAC
 
members is adequate, there
 
is room for further
 
enhancement on providing more
 
details on the quantification of the
impact
 
and measurable targets as well as indicating the monitoring frequency of all new remedial/work-out proposals. Such
enhancements will benefit TAC
 
members make more informed
 
decisions.
 
7.8
Products & Services Committee (PSC)
 
The
 
Products
 
& Services
 
Committee (PSC)
 
is responsible
 
for
 
developing and
 
supervising the
 
governance
 
framework
 
for
 
the
products and
 
services offered
 
to Eurobank’s
 
clients in Greece
 
through the
 
physical and alternative
 
channels, in accordance
with the supervisory and regulatory
 
requirements. A governance
 
framework
 
assessing the financial and non-financial risks is
in place. The
 
PSC approves
 
all new products
 
& services
 
as well as
 
significant modifications
 
in existing ones. The
 
Committee
also implements a periodic review of all products and services,
 
according to their risk profile to determine their continuation,
modification or discontinuation. The
 
products and services of Remedial & Servicing Strategy are
 
excluded and are under the
responsibility of TAC
 
(Troubled
 
Assets Committee).
PSC convenes once a month and/or whenever
 
required.
 
The
 
PSC
 
is in
 
quorum
 
and
 
meets
 
validly
 
when
 
half of
 
its
 
members
 
plus
 
one
 
are
 
present
 
(fractions
 
are
 
excluded
 
from
 
the
computation).
 
For
 
quorum,
 
the
 
Chairperson
 
or
 
the
 
Vice-Chairperson
 
(in
 
case
 
of
 
Chairperson’s
 
absence)
 
should
 
be
 
also
present.
 
Decisions require,
 
as a minimum,
 
a majority vote
 
of 50%+1
 
of the
 
members present
 
in the
 
meeting and
 
are recorded
 
in the
meeting’s minutes.
 
In case of a tie vote, the
 
Chairperson or the Vice
 
-Chairperson (in case of Chairperson’s absence)
 
has the
casting
 
vote.
 
All members
 
of the
 
PSC have
 
equal voting
 
rights. In
 
case
 
of no
 
reaching a
 
decision
 
due to
 
disagreement
 
of
Members, the issue under
 
discussion is escalated to the Executive
 
Board (ExBo).
Additionally,
 
decisions may
 
be taken
 
by circulation,
 
which is
 
equal to
 
a decision
 
of the
 
Committee, even
 
if no meeting
 
has
preceded.
 
No
 
resolution
 
can
 
be
 
deemed
 
for
 
high
 
risks
 
products/services
 
by
 
circulation.
 
They
 
will
 
be
 
submitted
 
to
 
a
 
PSC
Meeting for discussion and approval
 
or rejection.
 
By the date of
 
issuance of the 2024
 
Corporate Governance Statement, Committee’s self-evaluation for 2024 was in progress.
According to the Committee’s 2023 self-evaluation, its
 
performance was assessed as very strong, it
 
functions effectively,
 
adds
substantially to the governance
 
model of the Bank and its Members demonstrate
 
a high level of commitment.
 
7.9
Sustainability Management Committee (SMC)
The
 
primary
 
mandate
 
of
 
the
 
SMC
 
is
 
to
 
provide
 
strategic
 
direction
 
on
 
sustainability
 
initiatives,
 
review
 
the
 
Sustainability
Strategy,
 
Net Zero
 
targets and transition
 
plans prior to approval,
 
integrate the
 
elements of the
 
Sustainability Strategy
 
into
13
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
14
 
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
15
 
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
 
 
 
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the
 
Bank’s
 
business
 
model
 
&
 
operations,
 
approve
 
changes
 
in
 
eligible
 
assets
 
of
 
Green
 
Bond
 
and
 
Sustainable
 
Finance
Frameworks,
 
regularly
 
measure
 
and
 
analyze
 
the
 
progress
 
of
 
the
 
Sustainability
 
Strategy
 
goals
 
and
 
performance
 
targets,
ensure
 
the
 
proper
 
implementation
 
of
 
Sustainability-related
 
policies
 
and
 
procedures,
 
in
 
accordance
 
with
 
supervisory
requirements and voluntary
 
commitments.
 
SMC
 
convenes
 
four
 
times
 
a year
 
and/or
 
ad hoc
 
when
 
necessary.
 
Other
 
Bank employees,
 
depending on
 
the
 
subject
 
to be
discussed, may be invited as deemed appropriate.
Required
 
quorum
 
for
 
SMC
 
meetings
 
to
 
be
 
effective
 
is
 
eight
 
members.
 
In
 
order
 
to
 
have
 
a
 
quorum,
 
the
 
presence
 
of
 
its
Chairperson and a minimum of seven (7) members is required. Decisions on issues are taken by majority.
 
In case of a tie vote,
the
 
Chairperson has
 
the
 
casting vote.
 
Whenever
 
a decision
 
of the
 
SMC is
 
not reached
 
unanimously,
 
this is
 
recorded
 
in the
minutes along
 
with the
 
opinion of
 
the minority.
 
All meetings
 
and decisions
 
are minuted
 
by the
 
Committee’s Secretary
 
and
Required
 
quorum
 
for
 
SMC
 
meetings
 
to
 
be
 
effective
 
is
 
eight
 
members.
 
In
 
order
 
to
 
have
 
a
 
quorum,
 
the
 
presence
 
of
 
its
Chairperson and a minimum of seven (7) members is required. Decisions on issues are taken by majority.
 
In case of a tie vote,
the
 
Chairperson has
 
the
 
casting vote.
 
Whenever
 
a decision
 
of the
 
SMC is
 
not reached
 
unanimously,
 
this is
 
recorded
 
in the
minutes along
 
with the
 
opinion of
 
the minority.
 
All meetings
 
and decisions
 
are minuted
 
by the
 
Committee’s Secretary
 
and
distributed to SMC members.
The evaluation highlighted the need to strengthen Committee’s oversight of sustainability training and awareness initiatives,
remuneration
 
practices that link Sustainability criteria
 
and the sustainability controls and procedures
 
in place.
7.10
 
Ethics Co
 
The
 
task of
 
the
 
Ethics Committee
 
is to
 
ensure
 
that
 
the
 
Eurobank
 
Group’s
 
Code of
 
Conduct &
 
Ethics as
 
well
 
as the
 
Bank’s
Statute
 
of
 
Internal
 
Service
 
is
 
observed,
 
to
 
interpret
 
and
 
constantly
 
enrich
 
it,
 
as
 
well
 
as
 
to
 
contribute,
 
generally,
 
to
 
the
formulation
 
of a code
 
of values with
 
which the
 
behaviour of the
 
officers
 
and personnel of
 
Eurobank,
 
as well as
 
that of third
persons that regularly collaborate
 
with the Bank, must comply. Adherence
 
to the rules of ethics contributes, on the one hand,
to
 
the
 
protection
 
of
 
dignity
 
and
 
personality
 
of
 
the
 
personnel,
 
and
 
on
 
the
 
other
 
hand,
 
to
 
the
 
good
 
reputation
 
and
 
the
protection of the
 
interests of the Bank.
The Ethics
 
Committee convenes
 
once a month,
 
if there
 
are issues to
 
be discussed or,
 
exceptionally,
 
more frequently,
 
in case
of an
 
emergency,
 
in a
 
place
 
and time
 
that
 
are
 
stated
 
in the
 
agenda. The
 
Ethics
 
Committee
 
may convene
 
either
 
with
 
the
physical presence of its members,
 
or by electronic means. The
 
Committee shall act unanimously.
By the date of issuance of
 
the 2024 Corporate Governance Statement, Committee’s self-evaluation for 2024 was in progress.
Ethics Committee’s performance
 
was evaluated for the
 
first time in February of 2023 and it was determined that
 
it functions
effectively,
 
especially in the
 
areas of Profile
 
& Composition as well
 
as Organization &
 
Administration.
 
The Ethics
 
Committee
encourages critical discussion and a healthy
 
challenging of corporate tisk culture.
8
Key Control
 
Functions
As part
 
of its
 
overall
 
system of
 
internal
 
controls,
 
HoldCo/Bank
 
have
 
established
 
a number
 
of dedicated
 
control
 
functions
whose
 
main
 
responsibility
 
is
 
to
 
act
 
as
 
independent
 
control
 
mechanisms
 
thus
 
reinforcing
 
the
 
control
 
structure
 
of
 
the
HoldCo/Bank. The most important functions
 
and their key responsibilities
 
are described below.
 
8.1
Internal Audit
 
8.1.1
Eurobank Holdings
Internal Audit
 
(IA) is
 
an independent,
 
objective
 
assurance
 
and consulting
 
function designed
 
to add
 
value and
 
improve
 
the
operations
 
of Eurobank
 
Holdings. IA
 
has adequate
 
organisation
 
structure
 
and appropriate
 
resources
 
to ensure
 
that it
 
can
fulfil its roles
 
and responsibilities.
 
Eurobank’s Group
 
Internal Audit (Group
 
IA) maintains a quality assurance
 
and improvement
 
programme
 
to ensure that
 
the
methodology is applied consistently and the objectives and responsibilities of Group IA are met.
 
Under the framework
 
of co-
operation
 
between
 
IA
 
and
 
Group
 
IA,
 
IA
 
assigns
 
the
 
assessment
 
of
 
the
 
effectiveness
 
of
 
internal
 
audit
 
activities
 
and
conformance with IIA Standards
 
to Group IA.
In order to safeguard its independence, IA reports
 
functionally to the Audit Committee and administratively
 
to the CEO. The
Board
 
has
 
delegated
 
the
 
responsibility
 
for
 
monitoring
 
the
 
activity of
 
the
 
IA
 
to
 
the
 
Audit Committee
 
of
 
the
 
HoldCo.
 
IA
 
is
headed
 
by
 
the
 
Chief
 
Internal
 
Auditor
 
(CIA)
 
who
 
is
 
appointed
 
by
 
the
 
Audit
 
Committee.
 
The
 
latter
 
also
 
assesses
 
the
 
CIA’s
performance.
The
 
mission of
 
IA is
 
to enhance
 
and protect
 
organisational
 
value by
 
providing
 
risk-based and
 
objective
 
assurance,
 
advice
and insight. The key assurance
 
and consulting responsibilities of IA are to:
provide
 
reasonable assurance
 
in the
 
form of
 
an independent opinion,
 
as to the
 
adequacy and effectiveness
 
of the
governance
 
and risk
 
and internal
 
control
 
framework
 
of HoldCo
 
and adherence
 
to the
 
risk appetite
 
framework.
 
In
order to form an opinion, IAU establishes and carries
 
out a programme of audit work (based
 
on the risk assessment
of the audit universe)
16
 
Information regarding current composition and short biographical details of its members may be found at the Bank’s website (www.eurobank.gr).
 
 
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assist
 
management
 
in
 
enhancing
 
the
 
system
 
of
 
internal
 
control
 
including
 
improvement
 
of
 
existing
 
policies
 
and
procedures
manage effectively
 
the internal audit process
 
and resources of IA
provide
 
any information
 
requested in
 
writing by
 
the Supervisory
 
Authorities and
 
co-operate
 
with them
 
in order
 
to
facilitate
 
their
 
work.
 
The
 
AC
 
and/or Management
 
shall
 
always be
 
advised regarding
 
information
 
provided
 
to the
Authorities
carry out any other
 
specific duties required by the
 
Regulatory Authorities and/or participate in projects
 
undertaken
by the Company
participate in Company’s projects in an assurance
 
or consulting capacity
liaise with
 
the
 
external
 
auditors and
 
other
 
assurance
 
providers
 
to share
 
information,
 
minimise any
 
duplication
 
of
effort and ensure
 
adequate coverage
 
of risks
assess the
 
adequacy and
 
effectiveness
 
of the
 
control
 
functions (such
 
as risk
 
management, compliance
 
or finance)
and involving judgment determine to what extent it is appropriate
 
to take account of the relevant work undertaken
by these functions
strive to maintain an open, constructive and cooperative
 
relationship with the
 
Supervisors.
8.1.2
Eurobank
Group Internal
 
Audit (Group IA)
 
is an independent, objective
 
assurance and
 
consulting function designed
 
to add value and
improve
 
the operations
 
of Eurobank
 
and its subsidiaries.
 
Group IA
 
has appropriate
 
organisational structure
 
and resources
to ensure that it can fulfil the
 
roles and responsibilities as described in relevant
 
regulations.
 
Group
 
IA
 
comprises
 
the
 
“Internal
 
Audit”,
 
the
 
“Forensic
 
Audit”, the
 
“International
 
Audit”
 
and
 
the
 
“Business
 
Monitoring
 
and
Organisational Support”.
 
IA also has
 
a Quality Assurance,
 
Standards and Methodology
 
(QA), to
 
assess the
 
effectiveness
 
of
the
 
Group’s
 
internal
 
audit
 
activities
 
and conformance
 
with
 
IIA
 
Standards.
 
QA
 
operates
 
as Centre
 
of Excellence
 
for
 
Audit
Standards
 
&
 
Methodology,
 
acting
 
as
 
an
 
advisor
 
to
 
IAG
 
Management
 
in
 
topics
 
related
 
to
 
quality
 
improvement
 
and
methodology.
 
In
 
addition,
 
the
 
Data
 
Analytics
 
Centre
 
of
 
Excellence
 
(DAnCoE)
 
of
 
Group
 
IA
 
aims
 
to
 
enhance
 
people
 
skills
towards data analytics, enabling the
 
generation
 
of data-driven insights and provide
 
valuable perspectives to Management
of the Group.
In order
 
to safeguard
 
its independence,
 
Group IA
 
reports functionally
 
to the
 
Audit Committee
 
and administratively
 
to the
CEO. The
 
Board has delegated
 
the responsibility
 
for monitoring
 
the activity
 
of the
 
Group IA
 
to the
 
Audit Committee of
 
the
Bank. Group IA is headed by the Group Chief Audit Executive (CAE) who is appointed
 
by the Audit Committee. The latter also
assesses the CAE’s performance.
The key assurance
 
and consulting responsibilities of Group IA are to:
provide
 
reasonable assurance
 
in the
 
form of
 
an independent opinion,
 
as to the
 
adequacy and effectiveness
 
of the
governance
 
and risk and internal
 
control framework
 
of Eurobank
 
and adherence
 
to the risk
 
appetite framework.
 
In
order to form an opinion, IAG establishes and carries
 
out a programme of audit work (based on the risk assessment
of the audit universe)
assist
 
Management
 
in
 
enhancing
 
the
 
system
 
of
 
internal
 
controls
 
including
 
improvement
 
of
 
existing
 
policies
 
and
procedures
manage
 
effectively
 
the
 
internal
 
audit
 
process
 
and
 
resources
 
of
 
both
 
IAG
 
and
 
the
 
Internal
 
Audit
 
departments
 
of
subsidiaries that
 
are reporting
 
directly to
 
IAG and
 
assess the
 
performance
 
of the
 
Group’s
 
internal audit
 
functions,
which have a direct reporting line
follow-up
 
to ascertain
 
that
 
appropriate
 
action
 
is taken
 
on reported
 
audit findings
 
within
 
agreed
 
deadlines
 
[Law
3016/02 & Law 4706/20]
attend Shareholders’
 
General Meetings [Law 3016/02 & Law 4706/20]
provide
 
any information
 
requested in
 
writing by
 
the Supervisory
 
Authorities and
 
co-operate
 
with them
 
in order
 
to
facilitate
 
their
 
work.
 
The
 
Audit
 
Committee
 
and/or
 
Management
 
shall
 
always
 
be
 
advised
 
regarding
 
information
provided to the Authorities
carry out
 
any other
 
specific duties required
 
by the Supervisory
 
Authorities and/or participate
 
in bank wide projects
undertaken by the
 
Bank
participate in Bank projects in an assurance
 
or consulting capacity
liaise with the Legal Services
 
and Group Human Resources General
 
Divisions and provide support to the
 
Ethics and
Operational Risk Legal
 
Cases Committees
liaise with
 
the
 
external
 
auditors and
 
other
 
assurance
 
providers
 
to share
 
information,
 
minimise any
 
duplication
 
of
effort and ensure
 
adequate coverage
 
of risks
assess the
 
adequacy and
 
effectiveness
 
of the
 
control
 
functions (such
 
as risk
 
management, compliance
 
or finance)
and involving judgment determine to what extent it is appropriate
 
to take account of the relevant work undertaken
by these functions
maintain an open, constructive and cooperative
 
relationship with the
 
Supervisors
 
 
 
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assist and advise Management
 
on the prevention
 
and detection of fraud
 
or defalcation
 
or unethical
 
practices and
undertake such special projects as required.
8.2
Risk Management
8.2.1
Eurobank Holdings
As part
 
of its
 
overall
 
system of
 
internal controls
 
HoldCo has
 
engaged in
 
a Service
 
Level
 
Agreement
 
(SLA) with
 
Eurobank
 
in
order to
 
receive
 
supporting and advisory
 
services in
 
all areas of
 
risk management (credit,
 
market, liquidity
 
and operational
risks) undertaken by the
 
Group.
 
The most important services
 
provided through
 
the above-mentioned
 
SLA are described below:
 
provision of advice on:
-
Identification, evaluation
 
and monitoring of credit risk,
-
Ensuring policy
 
and instructions
 
(strategy
 
and products)
 
recommended
 
by business
 
owners
 
and Servicers
 
are
aligned to applicable credit policy manual and regulatory
 
guidelines,
-
Standardization of procedures
 
and guidelines,
-
Update and maintenance of the risk strategic
 
framework
 
master document,
-
Participation in systemic bank consultation
 
committees,
-
Review new remedial
 
products and initiatives prior submission
 
to TAC
 
or approval
coordination of NPE related regulatory
 
reporting
provision
 
of
 
input
 
for
 
SSM
 
submission
 
and
 
3-year
 
business
 
plan,
 
monthly
 
MIS
 
actual
 
data
 
(including
 
Greek
 
and
International subsidiaries)
advising on identification, support/advise, recording
 
and evaluation of liquidity risks and financial monitoring
advising in the identification, assessment,
 
recording and monitoring of operational
 
risks (e.g. RCSA, events capture,
outsourcing etc.)
advising in the identification,
 
assessment, recording and monitoring of sustainability risk.
 
8.2.2
Eurobank
The
 
Group
 
Risk Management,
 
which is
 
headed
 
by
 
the
 
Group
 
Chief Risk
 
Officer
 
(GCRO), operates
 
independently from
 
the
business
 
units and
 
is responsible
 
for
 
the
 
identification,
 
assessment,
 
monitoring
 
and measurement
 
of the
 
risks the
 
Bank is
exposed to.
 
The
 
major types
 
of risk
 
managed by
 
Eurobank
 
are the
 
material risks,
 
identified through
 
the
 
Risk Identification
and Materiality Assessment (RIMA) process
 
and listed in the relevant RIMA report.
 
Material risk types include
 
financial and non-financial risks, indicatively
 
credit risk, market risk, liquidity
 
risk, interest rate
 
risk
and credit
 
spread risk
 
in the
 
banking book,
 
operational
 
risk, sustainability
 
risk, country
 
risk, reputational
 
risks, conduct
 
risk,
risks stemming from strategic projects.
 
The Group Risk Management comprises the Group Credit, the Group Credit Control,
 
the Group Credit Risk Capital Adequacy
Control, the Group Market
 
& Counterparty Risk, the Group Operational and Non-financial Risks, the Group Model Validation
& Governance,
 
the Group
 
Risk Management Strategy
 
Planning Operations
 
& Sustainability Risk, the
 
Risk Analytics and the
Supervisory Relations & Resolution
 
Planning
The
 
GCRO
 
serves
 
as a
 
pivotal
 
point for
 
the
 
risk management
 
functions.
 
Centralization
 
ensures
 
that
 
business targets
 
and
related growth
 
are combined with a risk conscious perspective,
 
thus ensuring that the approved
 
risk appetite is adhered to.
 
The
 
GCRO
 
develops
 
and formalises
 
the
 
Risk Appetite
 
Framework
 
(RAF),
 
defines the
 
Risk Appetite
 
Statements
 
(RAS),
 
and
submits them
 
to the
 
Board
 
Risk Committee
 
for
 
approval.
 
The
 
GCRO oversees
 
the
 
implementation
 
of the
 
frameworks
 
and
policies for the
 
identification, measurement
 
and management of risks.
The GCRO reviews and approves the risk policies before
 
their submission for approval to the BRC or to the BoD and oversees
their implementation thereafter.
 
The GCRO reports to the
 
BRC deviations from the
 
risk policies or potential conflict with the
approved risk strategy
 
and risk appetite.
 
The GCRO is responsible to provide to the BRC
 
adequate information, so that the Committee can properly assess and advise
the BoD on the Group’s risk
 
exposures / profile and
 
risk strategy. The GCRO oversees compliance with approved Risk Appetite
limits, and reports to the BRC the compliance status and any deviations,
 
as stipulated in the Risk Appetite Framework
 
(RAF).
Eurobank
 
has
 
a
 
well-established
 
strategy
 
and
 
clear
 
risk
 
management
 
objectives
 
that
 
has
 
to
 
deliver
 
through
 
core
 
risk
management processes and
 
methodologies. At a strategic
 
level, the risk management
 
objectives are to:
identify the new risks relevant
 
to the Group and assess their
 
materiality
assess the current
 
and emerging risks as an integral part of the
 
strategic planning process
17
 
The Supervisory Relations & Resolution Planning has a dual reporting line to both the Group CRO & the Group CFO
 
 
 
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provide opinion for
 
the Group Business Plan
 
regarding the risk perspective
 
on the overall
 
outcome and reliability of
the Plan
ensure that business plan is consistent with Eurobank’s
 
risk appetite
participate actively in decision-making processes
 
to ensure that risk considerations
 
are considered appropriately
optimize risk/return decisions, while establishing strong and
 
independent review
ensure that business growth
 
plans are properly supported by effective
 
risk infrastructure
manage risk profile to ensure that specific financial deliverables
 
remain possible under a range of adverse
 
business
conditions
assist senior executives to improve
 
the control
 
and co-ordination of risk taking across their
 
business
cultivate
 
a
 
robust
 
risk
 
culture
 
throughout
 
the
 
Bank,
 
encouraging
 
a
 
positive
 
attitude
 
towards
 
risk
 
management,
regulatory compliance and
 
the internal
 
control framework,
 
through strong
 
risk awareness and ownership,
 
where all
staff members consider
 
risk management as an integral part of their
 
everyday responsibilities
provide
 
the
 
framework,
 
procedures
 
and guidance
 
to enable
 
all employees
 
to manage
 
risk in
 
their
 
own areas
 
and
improve the
 
control and co-ordination
 
of risk taking across the Bank
advise and support Eurobank Holdings in risk
 
management according to the
 
agreed Service Level
 
Agreement (SLA)
between Eurobank Holdings
 
and Eurobank.
Risk
 
Management
 
along
 
with
 
Compliance
 
and
 
other
 
Units
 
are
 
involved
 
in
 
the
 
assessment
 
of
 
all
 
products
 
and
 
services
throughout their
 
lifecycle.
The Group
 
applies the elements of the Three
 
Lines of Defence Model for the
 
management of risk. The Three
 
Lines of Defence
Model
 
enhances
 
risk
 
management
 
and
 
control
 
by
 
clarifying
 
roles
 
and
 
responsibilities
 
within
 
the
 
organization.
 
Under
 
the
oversight
 
and
 
direction
 
of
 
the
 
Management
 
Body,
 
three
 
separate
 
lines
 
of
 
defence
 
are
 
necessary
 
for
 
effective
 
risk
management. In particular:
-
Line
 
1
 
-
 
Own
 
and
 
manage
 
risk
 
and
 
controls.
 
The
 
front-line
 
business
 
and
 
operations
 
are
 
accountable
 
for
 
this
responsibility as they own the
 
rewards and are the
 
primary risk generators.
-
Line 2 -
 
Monitor risk and
 
controls
 
in support of
 
Executive Management,
 
providing
 
oversight,
 
challenge, advice
 
and
group-wide direction. These
 
include the Risk Management and Compliance Units, among others.
-
Line 3
 
- Provide
 
independent assurance
 
to the
 
Board and
 
Executive
 
Management concerning
 
the
 
effectiveness
 
of
risk and control management. This
 
refers to Internal Audit.
8.3
Compliance
 
8.3.1
Eurobank Holdings
Eurobank
 
Holdings
 
Compliance
 
is
 
established
 
with
 
the
 
approval
 
of
 
the
 
Board
 
of
 
Directors
 
and
 
the
 
Audit
 
Committee
 
of
Eurobank Holdings. It is a permanent
 
function and independent from Eurobank
 
Holdings’ business activities so that conflicts
of interests are
 
avoided. In order
 
to safeguard
 
its independence, Eurobank
 
Holdings Compliance
 
reports functionally
 
to the
Audit Committee of Eurobank
 
Holdings
and for administrative
 
purposes to the
 
CEO
. The Audit
 
Committee in consultation
with the
 
NomCo, proposes
 
to the
 
Board for
 
approval
 
the
 
appointment, replacement
 
or dismissal
 
of the
 
Head of
 
Eurobank
Holdings Compliance. The performance
 
of the Head of Eurobank Holdings Compliance
 
is assessed on an annual basis by the
AC.
 
The
 
Head
 
of
 
Compliance
 
attends
 
all
 
AC
 
meetings
 
and
 
submits
 
quarterly
 
and
 
annually
 
reports
 
(per
 
regulatory
requirements) summarizing Compliance’s
 
activity and highlighting the main compliance issues.
Its
 
mission
 
is
 
to
 
promote,
 
within
 
Eurobank
 
Holdings,
 
an
 
organizational
 
culture
 
that
 
encourages
 
ethical
 
conduct,
 
and
 
a
commitment to compliance with laws and regulations
 
as well as global governance
 
standards.
 
The
 
main
 
objective
 
of
 
Eurobank
 
Holdings
 
Compliance
 
is
 
to
 
ensure
 
that
 
Eurobank
 
Holdings
 
has
 
established
 
an
 
adequate
system of
 
internal controls
 
that allows
 
it to
 
operate
 
in accordance
 
with the
 
ethical
 
set of
 
values contained
 
in its
 
"Code of
Conduct
 
and
 
Ethics"
 
and
 
in
 
compliance
 
with
 
applicable
 
laws,
 
regulations
 
and
 
internal
 
policies.
 
More
 
specifically,
 
for
 
the
regulatory topics within its scope of responsibilities, Eurobank
 
Holdings Compliance is mandated to:
raise compliance awareness
 
in Eurobank Holdings
provide
 
advice the
 
Board of
 
Directors and
 
Senior Management
 
on Eurobank
 
Holdings compliance
 
with applicable
laws, rules and standards and keeping them informed
 
of related developments
issue,
 
as
 
necessary,
 
policies
 
and
 
other
 
documents,
 
in
 
order
 
to
 
provide
 
guidance
 
to
 
staff
 
on
 
the
 
appropriate
implementation of applicable
 
laws, rules and standards as well as to assist the
 
business to develop and implement
regulatory compliant policies and procedures
review new activities and advise on potential
 
compliance risks
ensure that staff is adequately
 
trained about compliance issues
18
 
The administrative reporting line to the CEO does not entail any form of oversight over
 
Compliance. It is rather intended to facilitate the smooth
day to day administrative processes
 
 
 
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provide
 
support
 
and
 
challenge,
 
if
 
required,
 
the
 
business
 
line
 
management
 
regarding
 
the
 
effectiveness
 
of
 
the
compliance risk management activities
monitor
 
whether
 
staff
 
applies
 
effectively
 
the
 
internal
 
processes
 
and
 
procedures
 
aimed
 
at
 
achieving
 
regulatory
compliance
monitor through appropriate
 
procedures
 
staff adherence
 
to internal policies and the
 
"Code of Conduct and Ethics"
and identify fraudulent activity
monitor
 
timely
 
submission
 
of
 
reports
 
to
 
Competent
 
Authorities
 
and
 
report
 
any
 
delays
 
and
 
fines
 
for
 
any
 
alleged
breaches of regulations to the
 
AC
fulfil any statutory responsibilities and liaise with regulators
 
and external bodies on compliance issues.
8.3.2
Eurobank
Group Compliance
 
is established with
 
the approval
 
of the
 
Board of
 
Directors and
 
the Audit
 
Committee of Eurobank.
 
It is a
permanent function
 
and independent from
 
the Bank’s
 
business activities
 
so that
 
conflicts of interests
 
are avoided.
 
In order
to safeguard
 
its independence, Group
 
Compliance reports functionally
 
to the
 
Board of Directors
 
through Audit
 
Committee
of the Bank
 
and for administrative
 
purposes
 
to the CEO.
 
The Audit Committee
 
in consultation with
 
the NomCo
 
proposes
to the Board
 
for approval
 
the appointment,
 
replacement or
 
dismissal of the
 
Group Chief
 
Compliance Officer
 
(Group CCO).
The performance
 
of the Group CCO is assessed on an annual basis by the AC. The Group CCO attends all Audit Committee’s
meetings and submits quarterly and annual reports (per regulatory
 
requirements) summarising Group
 
Compliance’s activity
and highlighting the main compliance issues.
Its mission is
 
to promote,
 
within Eurobank
 
and its subsidiaries
 
(Eurobank group),
 
an organizational
 
culture that
 
encourages
ethical conduct through
 
integrity and a commitment
 
to compliance with
 
laws and regulations
 
as well
 
as the application
 
of
international governance
 
standards.
 
The
 
main
 
objective
 
of
 
Group
 
Compliance
 
is
 
to
 
ensure
 
that
 
the
 
Eurobank
 
group
 
has
 
established
 
an
 
adequate
 
system
 
of
internal controls that allows
 
it to operate in accordance
 
with the ethical set of values contained in its “Code of Conduct and
Ethics” and
 
in compliance
 
with applicable
 
laws, regulations
 
and internal
 
policies, as
 
well as
 
international
 
best practices.
 
In
brief, for the
 
regulatory topics within its scope of responsibilities, Group
 
Compliance is mandated to:
raise compliance awareness
 
throughout the Eurobank
 
group,
provide
 
advice to
 
the
 
Board of
 
Directors
 
and Senior
 
Management on
 
compliance
 
with applicable
 
laws, rules
 
and
standards and keep them informed
 
of related developments,
issue policies, procedures and other documents such as compliance manuals, internal codes of conduct & ethics and
practice guidelines in order to provide guidance to
 
staff on the appropriate implementation of applicable laws, rules
and
 
standards
 
as
 
well
 
as
 
to
 
assist
 
the
 
business
 
to
 
develop
 
and
 
implement
 
regulatory
 
compliant
 
policies
 
and
procedures,
review new activities and advise on potential
 
compliance risks,
ensure
 
that
 
staff
 
is
 
adequately
 
trained
 
and
 
frequently
 
updated
 
about
 
compliance
 
issues
 
by
 
designing
 
training
programs and co-operating
 
with HR for their
 
implementation,
 
ensure the development
 
of a robust compliance risk identification
 
and assessment framework,
 
provide support and
challenge, if required, the
 
business line management
 
regarding the effectiveness of the compliance risk
 
management
activities,
coordinate compliance risk management actions
 
performed
 
by other business
 
units,
monitor
 
and
 
test
 
whether
 
staff
 
applies
 
effectively
 
the
 
internal
 
processes
 
and
 
procedures
 
aimed
 
at
 
achieving
regulatory
 
compliance
 
and report
 
to the
 
relevant
 
Business Units
 
any potential
 
breaches
 
in order
 
for
 
the
 
latter
 
to
proceed with the
 
required improvem
 
ents,
monitor staff
 
adherence
 
to internal policies
 
and the
 
"Code of Conduct
 
and Ethics" and
 
identify potential
 
breaches
or fraudulent activity,
monitor
 
timely
 
submission
 
of
 
reports
 
to
 
Competent
 
Authorities
 
and
 
report
 
any
 
delays
 
and
 
fines
 
for
 
any
 
alleged
breaches of regulations to the
 
AC,
fulfil any statutory responsibilities and liaise with regulators
 
and external bodies on compliance issues,
supervise,
 
monitor,
 
coordinate
 
and
 
evaluate
 
the
 
activities
 
of
 
the
 
Compliance
 
Officers
 
of
 
the
 
Bank’s
 
local
 
and
international subsidiaries in order
 
to ensure compliance with Eurobank
 
group standards.
The scope of activities of Group
 
Compliance covers the
 
following core
 
regulatory topics:
Financial Crime
 
including laws
 
and regulations
 
on Anti
 
Money Laundering
 
(AML) and
 
Countering
 
the
 
Financing of
Terrorism
 
(CFT)
 
and legislation
 
aimed
 
at
 
combatting
 
Tax
 
evasion
 
such
 
as FATCA
 
and
 
CRS
 
(tax compliance).
 
The
scope
 
includes
 
the
 
provision
 
of
 
timely
 
and
 
accurate
 
responses
 
to
 
requests
 
arising
 
from
 
regulatory
 
and
 
judicial
authorities for
 
the lifting of
 
banking secrecy or
 
freezing of assets and co-operation
 
with them.
 
Financial Crime also
19
 
The administrative reporting line to the CEO does not entail any form of oversight over
 
Group Compliance. It is rather intended to facilitate the
smooth day to day administrative processes
 
 
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includes
 
anti
-bribery
 
and
 
anti-corruption
 
legislation.
 
The
 
Eurobank
 
Audit
 
Committee
 
in
 
consultation
 
with
 
the
Eurobank NomCo proposes to the Board for approval the appointment, replacement, or dismissal of the Anti-Money
Laundering Reporting Officer
 
of Eurobank, who may be the same
 
person as the Group
 
CCO, and his/her Deputy
 
Conduct related regulations, including:
 
o
market
 
Conduct
 
related
 
regulation
 
regarding
 
the
 
provision
 
of
 
investment
 
products
 
and
 
services
 
to
 
clients
including
 
laws
 
and
 
regulations
 
on
 
Market
 
Manipulation,
 
Insider
 
Trading,
 
Unlawful
 
disclosure
 
of
 
inside
information and other
 
financial crimes,
o
Internal Conduct
 
and Ethics,
 
including monitoring
 
adherence
 
with the
 
Group Code
 
of Conduct and
 
Ethics and
its related policies, Conflicts of Interest,
 
insider dealing and manging the Ethics Hotline
o
customer
 
conduct
 
laws
 
and
 
regulations
 
(including,
 
inter
 
alia,
 
dormant
 
accounts
 
legislation,
 
BoG’s
 
Code
 
of
Conduct for loans, the Payment
 
Services Directive
 
and the Deposit Guarantee scheme).
 
Group
 
Compliance
 
has
 
an
 
overlay
 
role
 
over
 
the
 
regulatory
 
framework
 
concerning
 
personal
 
data
 
protection,
 
corporate
governance, prudential regulation
 
(credit market, liquidity and operational
 
risk), information & IT security,
 
cyber security risk,
outsourcing
 
and
 
Sustainability
 
Framework.
 
In
 
this
 
context
 
Group
 
Compliance
 
performs
 
a
 
high-level
 
monitoring
 
through
compliance risk assessments and monitoring of the
 
alignment of the Bank’s activities with regulatory
 
requirements.
The scope of activities can be expanded with the
 
approval of the
 
AC.
8.4
Personal Data Protection
 
8.4.1
Eurobank Holdings
In the
 
context of Personal
 
Data Protection,
 
Eurobank Holdings
 
has entrusted the
 
following
 
functions to
 
the Bank’s
 
Personal
Data Protection
 
Unit with the support of Legal where
 
needed:
consultation and advice regarding the
 
drafting of privacy notices for the
 
customers, employees, shareholders
 
of the
HoldCo and/ or persons with voting
 
rights and their representatives
 
in the HoldCo meetings and committees,
provision of drafts
 
of privacy policies, cookies policies and cookies management
 
tool for the
 
HoldCo's website,
provision of advice in handling
 
requests and complaints of data subjects,
provision
 
of
 
advice
 
for
 
incident
 
and
 
data
 
breach
 
management
 
and
 
notifications
 
to
 
the
 
competent
 
authority,
 
if
required,
provision of advice on GDPR policies
 
and related guidelines.
8.4.2
Eurobank
Personal Data Protection
 
Unit assists the Data Protection
 
Officer (DPO) in performing
 
his duties in an independent manner.
Key tasks include:
issues relevant guidelines on GDPR requirements
 
and provides relevant advice
 
to involved Units,
provides advice, where requested, for
 
the appropriate technical and organizational measures
 
to be implemented to
ensure compliance with the
 
principles of privacy by design and privacy by default,
provides advice regarding
 
the content of privacy notices,
provides advice on the
 
appropriate handling of the
 
GDPR requests and/or complaints,
upon request, provides
 
advice regarding
 
the categorization
 
of the
 
third parties,
 
in accordance
 
with the
 
GDPR and
any
 
other
 
applicable
 
data
 
protection
 
legislation
 
(controller/
 
joint
 
controller/processor/
 
sub-processor),
 
and
 
the
relevant privacy terms to be signed,
provides advice to the Incident Management Team on whether the incident must be reported to the data
 
protection
authority,
provides advice, where
 
requested, as regards the performance
 
of Data Protection
 
Impact Assessments,
provides advice where
 
requested as regards the maintenance
 
of the Register of Processing
 
Activity.
9
System of Internal Controls
9.1
Principles of Internal Controls
The
 
Group
 
has established
 
a robust
 
System
 
of Internal
 
Controls
 
that
 
aligns with
 
international
 
best practices
 
and
 
utilizes
COSO terminology.
 
This system is designed to provide reasonable assurance regarding
 
the achievement of objectives
 
in key
categories:
Efficient
 
and Effective
 
Operations:
 
The
 
Group's
 
internal
 
controls
 
ensure
 
that
 
operations
 
are
 
conducted efficiently
and effectively,
 
promoting productivity and optimal
 
resource utilization.
Reliability and Completeness
 
of Financial and
 
Management Information: Internal controls are in place to ensure that
financial and management information
 
is reliable, accurate, and complete. This
 
helps in making informed decisions
and maintaining transparency.
 
 
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Compliance
 
with
 
Applicable
 
Laws
 
and
 
Regulations:
 
The
 
Group
 
emphasizes
 
compliance
 
with
 
all
 
relevant
 
laws,
regulations, and
 
industry standards. Internal
 
controls are
 
designed to ensure
 
adherence
 
to legal requirements
 
and
mitigate regulatory risks.
The key principles
 
that underpin the Group’s
 
System of Internal Controls are
 
as follows:
Control
 
Environment:
 
The
 
control
 
environment
 
serves
 
as
 
the
 
foundation
 
for
 
all
 
internal
 
control
 
components.
 
It
includes factors such as management's integrity
 
and ethical values, recruitment and training policies, organizational
structure,
 
and
 
delegation
 
of
 
authority.
 
These
 
elements
 
contribute
 
to
 
a
 
strong
 
control
 
consciousness
 
among
employees.
Risk
 
Management:
 
The
 
Group
 
recognizes
 
the
 
importance
 
of
 
risk
 
management
 
in
 
its
 
operations.
 
It
 
implements
mechanisms
 
to
 
identify,
 
assess,
 
and
 
manage
 
risks
 
that
 
may
 
impact
 
the
 
achievement
 
of
 
objectives.
 
The
 
risk
management framework
 
is dynamic and evolves
 
to address new and emerging
 
risks.
Control Activities: Internal control
 
activities are documented in policies and procedures
 
that ensure safe operations
and
 
accurate
 
record-keeping.
 
Segregation
 
of
 
duties
 
is
 
a
 
crucial
 
organizational
 
measure
 
to
 
enhance
 
control
effectiveness,
 
ensuring that key functions
 
such as approval, dealing, administration,
 
and controlling are
 
separated.
Information and Communication:
 
Effective information
 
and communication channels are established to ensure
 
that
relevant
 
information
 
is
 
identified,
 
captured,
 
and
 
communicated
 
in
 
a
 
timely
 
manner.
 
This
 
includes
 
internal
communication
 
within
 
the
 
organization
 
and
 
external
 
communication
 
with
 
stakeholders
 
such
 
as
 
regulators,
shareholders, and customers.
Monitoring:
 
The
 
Group
 
conducts
 
ongoing
 
monitoring
 
of
 
activities
 
as
 
part
 
of
 
its
 
operations.
 
This
 
includes
 
regular
management and supervisory activities, internal audits, and independent evaluations of the internal control system.
Internal
 
control
 
deficiencies
 
are
 
reported
 
and
 
escalated
 
as
 
necessary,
 
with
 
major
 
issues
 
reported
 
to
 
top
management, the Audit Committee, and the
 
Board.
Additionally,
 
the
 
efficiency
 
of
 
the
 
internal
 
control
 
system
 
is
 
independently
 
evaluated
 
every
 
three
 
years
 
by
 
a
 
third-party
auditing firm, in accordance with regulatory requirements.
 
The evaluation report
 
is assessed by competent bodies within the
Group and submitted to regulatory authorities for
 
review and acknowledgment.
9.2
Characteristics of the System of Internal Controls
 
(SIC)
HoldCo and Eurobank have established key characteristics of their System of Internal Controls (SIC), which are indicative and
not restrictive. These
 
characteristics include:
Code of
 
Conduct: There
 
is a
 
defined Code
 
of Conduct
 
along with
 
processes
 
for
 
monitoring its
 
implementation
 
to
ensure ethical conduct and adherence
 
to standards.
Organizational
 
Chart: An approved
 
organizational chart
 
is in place,
 
depicting the
 
hierarchy
 
and functions
 
of each
sector/department clearly defined to ensure effective
 
management.
Audit Committee: The composition and function
 
of the Audit Committee are outlined to oversee
 
financial reporting
and compliance.
Strategic
 
Planning:
 
A
 
description
 
of
 
strategic
 
planning
 
processes
 
is
 
provided,
 
including
 
development,
implementation, and periodic
 
evaluation of strategic objectives.
Action Plans: Long-term
 
and short-term action
 
plans for
 
important activities are
 
established, with
 
periodic reports
and identification of deviations
 
along with justifications.
Articles
 
of
 
Association:
 
The
 
Articles
 
of
 
Association
 
are
 
complete
 
and
 
up-to-date,
 
reflecting
 
the
 
objectives
 
and
operations of the
 
entity.
Directorates and Departments: Tasks of directorates, departments, and job
 
descriptions are defined to
 
ensure clarity
in roles and responsibilities.
Policies
 
and
 
Procedures:
 
Policies
 
and
 
procedures
 
for
 
important
 
operations
 
are
 
documented,
 
including
 
internal
controls for
 
risk management.
Compliance
 
Processes:
 
Processes
 
for
 
compliance
 
with legal
 
and regulatory
 
frameworks
 
are
 
established to
 
ensure
adherence to laws and regulations.
Risk Assessment
 
and Management:
 
Processes
 
for
 
risk assessment
 
and
 
management
 
are
 
in place
 
to identify
 
and
mitigate risks effectively.
Financial
 
Information
 
Integrity:
 
Processes
 
ensure
 
the
 
integrity
 
and
 
reliability
 
of
 
financial
 
information
 
through
accurate reporting and controls.
Executive
 
Performance
 
Evaluation:
 
Processes
 
for
 
recruitment,
 
training,
 
delegation,
 
targeting,
 
and
 
evaluation
 
of
executive performance
 
are outlined.
Information
 
Systems
 
Security:
 
Processes
 
for
 
the
 
security,
 
adequacy,
 
and
 
reliability
 
of
 
information
 
systems
 
are
established to safeguard data.
Personnel
 
and Asset
 
Protection:
 
Processes
 
are
 
in place
 
to safeguard
 
personnel
 
and assets,
 
ensuring security
 
and
protection.
 
 
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Reporting and
 
Communication:
 
Reporting lines
 
and communication
 
channels within
 
and outside
 
the organization
are described for effective
 
information flow.
Monitoring
 
and
 
Evaluation:
 
Mechanisms
 
are
 
established
 
for
 
monitoring
 
and
 
evaluating
 
the
 
efficiency
 
and
effectiveness
 
of processes regularly.
Independent Evaluation: There
 
is a process
 
for periodic
 
evaluation of the
 
adequacy and efficiency
 
of the SIC
 
by an
independent auditor to ensure objectivity.
Environmental
 
Policies:
 
Policies
 
for
 
environmental
 
management
 
and
 
other
 
ESG
 
factors
 
are
 
recorded
 
to
 
address
sustainability and social responsibility.
These policies and procedures are part of
 
the corporate governance system's assessment and are regularly reviewed
and updated to align with best practices and regulatory
 
requirements.
9.3
Evaluation of the System of Internal Controls
The Bank's AC is responsible for annually reviewing and evaluating the adequacy of the Internal Control
 
System (ICS) of both
the Bank and its subsidiaries.
 
This evaluation
 
is based on data and information
 
provided by
 
the Group
 
Internal Audit (IA) of
the Bank, external auditors' findings and remarks,
 
as well as feedback from
 
supervisory authorities. The
 
AC utilizes oversight
and reporting
 
mechanisms
 
established
 
with
 
the
 
Audit
 
Committees
 
of the
 
Bank's Subsidiaries
 
to ensure
 
a comprehensive
assessment.
Similarly, the
 
HoldCo's AC is
 
tasked with reviewing
 
and evaluating the
 
adequacy of the
 
Internal Control
 
System (ICS) of the
HoldCo itself. This evaluation is conducted based on
 
relevant data and information from the Internal Audit (IA) of the HoldCo,
findings
 
and
 
remarks
 
from
 
external
 
auditors,
 
and
 
feedback
 
from
 
supervisory
 
authorities.
 
The
 
AC
 
ensures
 
a
 
thorough
assessment of the HoldCo's ICS to uphold
 
standards of governance
 
and compliance.
9.4
Independent Evaluation of the HoldCo/Bank
 
System of Internal Controls
In March 2024, Grant Thornton
 
presented the scope, findings, and methodology
 
of their Independent triennial Evaluation
 
of
the
 
HoldCo/Bank
 
System
 
of
 
Internal
 
Controls
 
(SIC)
 
to
 
the
 
HoldCo/Bank
 
AC
 
members,
 
as
 
per
 
the
 
Bank
 
of
 
Greece
 
Act
2577/9.3.2006 (BoG Act).
Based
 
on
 
the
 
procedures
 
conducted
 
and
 
the
 
evidence
 
gathered,
 
there
 
were
 
no
 
indications
 
that
 
the
 
SIC,
 
at
 
the
 
time
 
of
assessment, was not compliant in all material aspects with
 
the requirements
 
of the BoG Act.
Grant Thornton
 
identified 21 observations
 
during their
 
assessment, categorized
 
as 16 low-risk
 
observations
 
and 5 medium-
risk observation
 
related
 
to the
 
IT issues
 
in Eurobank
 
Equities, and
 
7 recommendations
 
for
 
improvement.
 
Management
 
will
take appropriate actions
 
in response to these observations.
9.5
Corporate Governance
 
System Assessment in accordance with
 
article 4 par. 1 of Law 4706/2020
In compliance with
 
Article 4, Paragraph
 
1 of Law 4706/2020
 
(the Law),
 
the HoldCo
 
and Bank Boards of
 
Directors (BoDs) are
responsible
 
for
 
designating and
 
overseeing
 
the
 
implementation
 
of the
 
corporate
 
governance
 
system (CGS)
 
as outlined
 
in
Articles 1 to
 
24 of the
 
Law.
 
Additionally,
 
the BoDs
 
must monitor and
 
evaluate the
 
application and
 
effectiveness
 
of the
 
CGS
at least every three
 
(3) financial years, taking necessary actions to address any deficiencies.
Given that the Law came into force on 17.7.2021,
 
the Hellenic Capital Market Commission (HCMC) specified
 
that the maximum
reporting period for
 
the first CGS review should extend from
 
17.7.2021
 
to 31.12.2024. It also required that the
 
2024 Corporate
Governance Statement
 
include a relevant reference
 
to this review.
In this context, the HoldCo and Bank NomCos reviewed
 
the CGS for the reporting
 
period and updated the HoldCo and Bank
BoDs accordingly. The
 
review concluded that HoldCo and Bank have taken all necessary actions to fully comply with the Law,
as no gaps were identified.
Furthermore,
 
in
 
line
 
with
 
supporting
 
work
 
related
 
to
 
the
 
Corporate
 
Governance
 
Framework,
 
performed
 
both
 
by
 
external
parties
 
and
 
internally,
 
HoldCo
 
and
 
Bank
 
have
 
taken
 
proactive
 
measures
 
to exceed
 
the
 
Law’s
 
provisions,
 
enhancing
 
their
processes and practices for more efficient
 
governance. In this regard, HoldCo and Bank have effectively
 
addressed identified
issues and implemented recommendations
 
for improvement
 
provided by
 
external parties, including
 
regulators and external
advisors.
10
Sustainability
10.1
Sustainability Approach
Eurobank
 
supports the
 
transition
 
towards
 
a sustainable
 
economy
 
and considers
 
sustainability and
 
climate
 
change as
 
an
opportunity. A key strategic
 
objective is to adapt the Bank’s business and operation in a way that addresses climate change
challenges,
 
accommodates
 
social
 
needs
 
within
 
its
 
business
 
model
 
and
 
safeguards
 
prudent
 
governance
 
for
 
itself
 
and
 
its
counterparties,
 
in
 
accordance
 
with
 
supervisory
 
initiatives,
 
and
 
following
 
international
 
standards
 
and
 
best
 
practice.
 
The
Bank’s commitment
 
to address
 
climate change
 
is expressed
 
through quantified
 
objectives,
 
such as its
 
detailed action
 
plan
to align its operations, lending and investment
 
portfolios to reach
 
Net Zero by 2050.
Eurobank
 
has expressed
 
the
 
sustainability aspect
 
of its
 
business through
 
the
 
lens of
 
Impact generation.
 
The
 
Sustainability
Strategy
 
has
 
been
 
defined
 
in
 
a
 
holistic
 
approach
 
across
 
two
 
pillars
 
of
 
impact:
 
the
 
operational
 
impact
 
arising
 
from
 
its
 
 
 
 
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operational
 
activities and
 
footprint,
 
and the
 
financed
 
impact resulting
 
from
 
the
 
Bank’s lending
 
and investing
 
activities to
specific
 
sectors
 
and
 
clients.
 
These
 
two
 
pillars
 
of
 
impact
 
aim
 
to
 
capture
 
the
 
essence
 
of
 
the
 
Bank’s
 
business
 
effect
 
on
 
the
climate, the protection
 
of the natural environment,
 
its contribution to addressing societal challenges at large, the prosperity
of its
 
own
 
people,
 
its contribution
 
to raising
 
business
 
capacity
 
in the
 
markets
 
where
 
the
 
Bank operates,
 
and the
 
internal
processes that build and secure
 
the confidence of its stakeholders.
 
Eurobank has designed, approved
 
and currently implements the
 
Sustainability Strategy including targets and commitments
along the two key pillars:
A. Operational Impact Strategy
 
The
 
Operational
 
Impact
 
Strategy
 
defines
 
the
 
Bank’s
 
operational
 
sustainability
 
priorities
 
and
 
objectives,
 
and
 
is
 
deployed
along three strategic pillars, each of which is supported by
 
a specific objective, commitments and targets:
Environmental
 
Impact:
 
Minimising
 
negative
 
impact
 
in
 
its
 
operations
 
to
 
promote
 
environmental
 
stewardship
 
and
attain climate neutrality.
Societal Impact: Providing a diverse and inclusive environment
 
for its people and clients, while fostering sustainable
development and prosperity
 
for the benefit of society.
Governance
 
and Business Impact: Focusing
 
on building ESG awareness,
 
internally and across
 
its value chain, while
intensifying its efforts for
 
ethics and transparency
B. Financed Impact Strategy
The Bank’s Financed
 
Impact Strategy
 
sets targets and commitments
 
addressing the
 
impact arising from the
 
Bank’s lending
and investing activities to specific sectors and clients and focuses on:
Clients’ engagement and awareness to adapt their
 
business so as to address climate change challenges.
Actions for supporting clients in their
 
transition efforts
 
towards a more sustainable economic environment.
Enablers and tools, such as frameworks
 
and products, to underpin sustainable financing.
 
Assessment and management of sustainability material
 
exposures and risks.
10.2
Sustainability Policies & Frameworks
Eurobank has
 
taken action
 
towards updating
 
its Sustainability Policy
 
Framework,
 
to outline the
 
approach for
 
adherence
 
to
applicable regulatory
 
requirements
 
and voluntary
 
initiatives
 
as well
 
as adopted standards
 
and guidelines,
 
thus enabling
 
a
contemporary
 
and
 
continuously
 
updated
 
approach
 
towards
 
Sustainability,
 
in
 
line
 
with
 
international
 
best
 
practice.
 
The
Sustainability
 
Policy
 
Framework
 
sets
 
the
 
foundation
 
towards
 
the
 
integration
 
of
 
Sustainability
 
principles
 
into
 
Eurobank’s
business model and operations.
Focusing
 
on the social
 
aspect of Sustainability,
 
Eurobank has
 
taken actions
 
that outline
 
its corporate
 
values, principles and
commitments by issuing the
 
Human Rights Statement, the
 
Diversity, Equity
 
and Inclusion Policy as well
 
as the Policy
 
against
Harassment and Violence in Workplace. In order to further enhance its
 
efforts against Harassment and Violence in Workplace,
the
 
Bank has
 
introduced
 
a relevant
 
focused
 
training
 
program
 
to all
 
employees.
 
This
 
approach
 
outlines
 
zero-tolerance
 
for
various
 
types
 
of
 
violation
 
and
 
discrimination
 
as
 
well
 
as
 
for
 
the
 
equal
 
opportunities
 
with
 
fairness
 
and
 
meritocracy
 
and
irrespective of gender, nationality,
 
age or other traits throughout the entire employee life cycle (i.e. recruitment and selection,
learning, performance,
 
talent and career development,
 
reward management).
Moreover,
 
Eurobank
 
has
 
developed
 
and
 
implements
 
three
 
guiding
 
frameworks,
 
defining
 
the
 
approach
 
and
 
criteria
 
for
classifying its financing and investing activities as sustainable:
its
 
Sustainable
 
Finance
 
Framework
 
(SFF),
 
which
 
supports
 
the
 
identification
 
of
 
sustainable/green
 
financing
opportunities
 
and
 
provides
 
a
 
clear
 
and
 
comprehensive
 
methodology
 
for
 
classifying,
 
monitoring
 
and
 
reporting
sustainable financing.
its Green
 
Bond Framework.
 
The
 
Framework,
 
which has
 
been
 
externally
 
reviewed
 
by
 
an established
 
second-party
opinion provider,
 
facilitates
 
the
 
financing of
 
projects
 
that
 
will deliver
 
environmental
 
benefits to
 
the
 
economy and
support Bank’s business strategy and vision,
its
 
Sustainable
 
Investment
 
Framework,
 
which
 
describes
 
the
 
Bank’s
 
potential
 
sustainable
 
investment
approaches/strategies
 
and
 
the
 
process
 
for
 
selection
 
of
 
eligible
 
investments,
 
based
 
on
 
criteria
 
observed
 
in
international market practices,
 
frameworks
 
and guidelines.
The above-mentioned
 
frameworks
 
enable the Bank to pursue economic growth
 
in line with sustainable criteria.
These
 
frameworks
 
are
 
complemented
 
by
 
the
 
adopted
 
Environmental
 
Policy,
 
Energy
 
Management
 
Policy
 
and
 
Water
Management Policy,
 
aiming to protect
 
the environment
 
in all aspects of
 
its operations.
 
In line with
 
these policies,
 
the Bank
applies certified management systems, in accordance
 
with international standards,
 
such as an Environmental Management
System (ISO 14001, EMAS) and an Energy Management System (ISO 50001).
 
 
 
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10.3
Stakeholders engagement and double materiality
 
assessment
 
An integral
 
part of Eurobank's
 
approach to
 
Sustainability is
 
to foster
 
strong relationships
 
of trust, cooperation
 
and mutual
benefit with all stakeholders affected
 
by its activities, directly or indirectly.
 
Eurobank promotes two
 
-way communication and
develops ongoing dialogue with stakeholders,
 
to be able to actively meet the expectations, concerns and issues raised by all
its stakeholders.
 
A more
 
detailed presentation
 
of the
 
cooperation
 
framework,
 
expectations
 
and means
 
of communication
and response for each stakeholder
 
group is included in the Annual Report 2023 – Business & Sustainability.
In
 
2023,
 
Eurobank
 
marked
 
the
 
early
 
adoption
 
and
 
implementation
 
of
 
the
 
Double
 
Materiality
 
Assessment,
 
highlighting
 
a
critical turning
 
point in
 
its sustainability
 
path under
 
the new
 
European Sustainability
 
Reporting Standards
 
(ESRS), which
 
is
the key process used to define the Annual
 
Report 2023 –
 
Business & Sustainability
 
content. In this
 
context, the Bank identified,
assessed, prioritized
 
and validated the
 
Environmental,
 
Social and Governance
 
(ESG) impacts arising
 
from its
 
activities and
also assessed risks and opportunities that
 
may have material
 
financial influence on Eurobank,
 
throughout its value
 
chain. In
this context, Eurobank has adopted a forward
 
-thinking approach by incorporating
 
the concept of Double Materiality into its
operational and financed activities. The methodology was
 
carried out in 4
 
phases, namely i.
 
Understanding the organization’s
context and value chain, ii. Identifying impacts, risks
 
and opportunities (IROs), iii. Assessing impacts, risks and
 
opportunities,
and iv. Prioritizing
 
and validating material topics and IROs. As per
 
the final stage of the double materiality
 
and as informed
by the results of the impact and financial materiality assessment
 
process, a list of topics was prioritized as material, which in
turn formed
 
the
 
basis for
 
determining
 
the
 
contents of
 
the
 
Annual Report
 
2023 –
 
Business &
 
Sustainability,
 
as well
 
as the
disclosures of relevant key
 
performance
 
indicators. Further
 
details regarding the
 
aforementioned
 
process and its results
 
are
embedded in the Annual Report 2023 – Business & Sustainability.
Governance
Sustainability
 
at
 
Eurobank
 
is
 
deployed
 
across
 
a
 
Governance
 
structure
 
that
 
addresses
 
both
 
regulatory
 
requirements
 
and
voluntary
 
commitments.
 
Board
 
oversight
 
with respect
 
to the
 
Sustainability Strategy
 
is addressed
 
through
 
the
 
inclusion
 
of
sustainability items in the Board Meetings agenda, as per international best practice. The
 
Group applies the elements of the
Three Lines of Defense
 
(3LoD) model for the
 
management of Sustainability risks and aspects. The
 
3LoD model enhances risk
management
 
and
 
control
 
by
 
clarifying
 
roles
 
and
 
responsibilities
 
within
 
the
 
organization.
 
Eurobank’s
 
Sustainability
Governance model
 
ensures that the management
 
of relevant Sustainability risks is integrated
 
into the Bank’s Three
 
Lines of
Defense.
 
Additionally,
 
the
 
Group
 
Senior
 
Sustainability
 
Officer
 
(GSSO)
 
plays
 
a
 
key
 
role
 
in
 
leading
 
and
 
coordinating
 
the
Group’s
 
sustainability initiatives,
 
reporting directly to
 
the senior
 
management and Board
 
for sustainability matters
 
and the
Group
 
Sustainability
 
Coordination
 
Office
 
serves
 
as
 
the
 
Secretary
 
of
 
the
 
Sustainability
 
Management
 
Committee.
 
The
Sustainability Governance
 
structure aims
 
to further
 
enhance effective
 
oversight of
 
sustainability matters
 
at Management
 
/
Board level, support the
 
roll out of its Sustainability Strategy
 
and the integration
 
of Sustainability risks.
 
In that context,
 
the Group
 
Sustainability Risk (GSR)
 
is responsible for
 
managing and monitoring Sustainability
 
risks, for
 
the
implementation of the
 
Climate related and Environmental
 
risks roadmap, designing, along with Business
 
and Risk Units, the
Financed Impact Strategy and monitoring
 
of its implementation thereof. Moreover,
 
the Eurobank Holdings / Eurobank Boards
have
 
assigned an
 
executive
 
member
 
as the
 
responsible
 
Board Member
for
 
climate and
 
environmental
 
risks
. This
 
member
provides
 
updates to
 
the
 
Board
 
Risk Committees
 
(BRC) at
 
least semi-annually.
 
As outlined
 
in their
 
Terms
 
of Reference,
 
the
BRC is responsible for overseeing
 
(among others) sustainability issues, including sustainability risks.
A
 
dedicated
 
Sustainability
 
Management
 
Committee
 
(SMC)
 
complements
 
the
 
Sustainability
 
Governance
 
model.
 
The
 
SMC
provides strategic
 
direction on sustainability
 
initiatives, reviews
 
the Sustainability Strategy,
 
Net Zero
 
targets and transition
plans
 
prior
 
to
 
approval,
 
integrates
 
the
 
elements
 
of
 
the
 
Sustainability
 
Strategy
 
and
 
the
 
Net
 
Zero
 
commitments,
 
into
Eurobank’s
 
business
 
model
 
and
 
operations,
 
approves
 
changes
 
in
 
eligible
 
assets
 
of
 
Green
 
Bond
 
and
 
Sustainable
 
Finance
Frameworks,
 
regularly
 
measures
 
and analyzes
 
the
 
progress
 
of the
 
Sustainability Strategy
 
goals and
 
performance
 
targets,
ensures
 
the
 
proper
 
implementation
 
of
 
Sustainability-related
 
policies
 
and
 
procedures,
 
in
 
accordance
 
with
 
supervisory
requirements and voluntary
 
commitments.
A dedicated
 
Group Sustainability
 
Unit (GSU)
 
is responsible
 
for
 
managing and
 
coordinating
 
sustainability strategy
 
related
issues, for the development of action plans
 
for the Bank's Net Zero portfolio strategies, as well as for monitoring
 
sustainability
performance
 
and coordinating
 
sustainability-linked
 
activities that
 
enhance
 
the
 
Group’s
 
Impact. In
 
this context,
 
the
 
Unit is
responsible for
 
facilitating the
 
development
 
of the
 
Sustainability data
 
framework
 
to coordinate
 
and prepare
 
external and
internal
 
Sustainability-related
 
reports.
 
Finally,
 
Group
 
Sustainability
 
Risk
 
is
 
responsible
 
for
 
managing
 
and
 
monitoring
sustainability risks,
 
for
 
acting as
 
a PMO
 
office
 
for
 
implementing the
 
sustainability risks
 
roadmap,
 
and for
 
designing, along
with the GSU and Business Units, and monitoring the
 
Financed Impact Strategy.
10.4
Reporting and Transparency
HoldCo/Bank
 
issues
 
its
 
Annual
 
Report
 
 
Business
 
&
 
Sustainability
 
with
 
a
 
view
 
to
 
fully
 
inform
 
its
 
stakeholders
 
about
 
its
performance
 
in
 
the
 
sustainable
 
development
 
pillars
 
(economy,
 
society,
 
environment).
 
The
 
publication
 
is
 
prepared
 
in
accordance with the Global Reporting Initiative (GRI) Standards (2021), applying the reporting principles (accuracy, balance,
clarity,
 
comparability,
 
completeness,
 
sustainability
 
context,
 
timeliness,
 
verifiability).
 
This
 
reporting
 
approach
 
aims
 
at
providing comprehensive
 
and transparent information
 
to stakeholders, relates
 
to Eurobank’s response to their
 
expectations
and interests, and invests in continuously promoting open dialogue with them.
 
Through the
 
Report, Euroban/HoldCo provide
full
 
disclosure
 
on
 
sustainability
 
impacts
 
such
 
as
 
environmental
 
performance,
 
energy
 
and
 
emissions,
 
social
 
impact
 
and
corporate governance, information regarding the
 
Bank’s initiatives, while addressing
 
all material stakeholder interests across
 
 
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the sustainability spectrum.
 
The Annual
 
Report - Business &
 
Sustainability is accessible
 
to all interested
 
parties through
 
the
corporate website. Additionally,
 
besides the sustainability reporting frameworks of the
 
GRI sectoral supplement on Financial
Services, the SASB Commercial
 
Banks Standard, as well as the Athens
 
Stock Exchange (ATHEX) ESG Reporting Guide (2024)
have been considered,
 
while the materiality
 
assessment was conducted in
 
accordance with
 
the ESRS standards.
 
This report
also incorporates the 10 Principles of the United Nations Global Compact (UNGC), as well as the Accountability AA1000 2018
Principles. The sustainability-related
 
disclosures in the report are assured
 
by a competent assurance provider
 
in accordance
with the AA1000 Assurance Standard (version
 
3) and related Principles for inclusivity, materiality,
 
responsiveness and impact,
as per
 
the
 
independent
 
auditor’s
 
Limited Assurance
 
Report which
 
is disclosed
 
as part
 
of the
 
Annual Report
 
– Business
 
&
Sustainability.
 
In addition, the
 
Holdco/Bank reports
 
disclosures as required
 
by the
 
EU Taxonomy
 
(Regulation (EU)
 
2020/852
of
 
the
 
European
 
Parliament
 
and
 
of
 
the
 
Council).
 
Specifically,
 
upon
 
reviewing
 
its
 
business
 
activities,
 
to
 
align
 
taxonomy
reporting with its core activities, provides the key performance
 
indicators (KPIs) and other disclosure requirements
 
related to
its dominant financial undertakings as laid down in Article 10 of the Art. 8 Delegated Act. Furthermore, in the context of Pillar
III disclosures on ESG risks, Holdco/Bank discloses sustainability risk information on a semi-annual basis. Moreover,
 
Eurobank
is publishing its Task Force
 
on Climate-related Financial Disclosures (TCFD) Climate - related & Environmental Risk Report on
an
 
annual
 
basis.
 
Also,
 
the
 
Bank's
 
GHG
 
financed
 
emissions
 
for
 
loans,
 
bonds
 
and
 
shares
 
positions,
 
following
 
the
 
PCAF
methodology,
 
were disclosed.
 
Furthermore,
 
the
 
Bank’s
 
environmental
 
and
 
energy
 
management
 
performance,
 
with
 
respect
 
to
 
the
 
improvement
 
of
 
its
operational
 
footprint,
 
is monitored
 
through
 
specific indicators
 
and associated
 
targets
 
disclosed also
 
in the
 
Environmental
Report (EMAS). This constitutes an environment and energy monitoring and self-improvement tool, in line with commitments,
regulated by
 
applicable standards,
 
audited & verified
 
by independent
 
third party.
 
Within
 
the EMAS
 
Report framework,
 
the
Bank discloses the Green House
 
Gas emissions record in
 
line with the ISO 14064
 
standard, as verified by external
 
independent
party and in line with the provisions
 
of the national Climate
 
Law.
 
Moreover,
 
Holdco/Bank actively
 
participates in
 
internationally
 
recognized Sustainability ratings
 
to highlight the
 
continuous
improvement
 
in
 
its
 
environmental,
 
social
 
and
 
governance
 
performance,
 
upgrade
 
the
 
relevant
 
disclosures,
 
and
 
further
enhance investor confidence in its practices.
 
11
Other information
 
required by Directive
 
2004/25/EU
The elements c), d), f), h), and i) of paragraph 1, Article 10 of
 
Directive 2004/25/EC of the European Parliament and the Council
have been
 
incorporated
 
into elements
 
c), d),
 
e), g),
 
and h)
 
of Article
 
4, Paragraph
 
7 of
 
Law 3556/2007.
 
These
 
elements are
included
 
and referenced
 
in the
 
Report
 
of the
 
Directors,
 
of which
 
the
 
present
 
Corporate
 
Governance
 
Statement
 
forms
 
an
integral part.
 
 
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SUSTAINABILITY STATEMENT
Index to the Sustainability Statement ................................
 
................................
 
................................
 
................................
 
................................
 
.............Page
1.
 
General information
1.1
 
Basis for preparation ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
............. 2
1.2
 
Disclosures in relation to specific circumstances ................................
 
................................
 
................................
 
................................
 
..................... 2
1.3
 
Governance
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
.
 
2
1.4
 
Strategy - Company,
 
business model and stakeholder engagement ................................
 
................................
 
................................
 
......... 12
1.5
 
Materiality analysis and results according to the
 
concept of double materiality ................................
 
................................
 
................ 21
2.
 
Environmental information
2.1
 
Disclosures under Article 8 of Regulation (EU) 2020/852 ................................
 
................................
 
................................
 
................................
 
.
 
35
2.2
 
Climate change
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
...................... 38
2.3
 
Biodiversity and ecosystems ................................
 
................................
 
................................
 
................................
 
................................
 
........................... 58
2.4
 
Integration of sustainability in risk management ................................
 
................................
 
................................
 
................................
 
................ 60
2.5
 
Sustainable financing and investment offerings
 
................................
 
................................
 
................................
 
................................
 
.................. 65
3.
 
Social information
3.1
 
Own workforce ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
........................ 72
3.2
 
Consumers and end-users ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
88
3.3
 
Fostering innovation ................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
............ 94
3.4
 
Financial inclusion
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
................
 
100
4.
 
Governance information
4.1
 
Business conduct
 
................................
 
................................
 
................................
 
................................
 
................................
 
................................
 
.................. 106
4.2
 
Data security and customer privacy
 
................................
 
................................
 
................................
 
................................
 
................................
 
............
 
112
APPENDIX – Disclosures under Article 8 of Regulation (EU) 2020/852 ................................................................
 
................................
 
................. 116
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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1
 
General Information
1.1
 
Basis for Preparation
General basis for preparation of sustainability statements [BP-1]
This sustainability statement for the fiscal year ended 31 December 2024, has been prepared on a consolidated basis.
 
The scope of the statement covers the same scope of consolidation as the Financial Statements.
 
For the purpose
 
of this sustainability statement
 
the below definition is
 
incorporated: the Eurobank Holdings
 
Group (the Group)
consists mainly of Eurobank S.A. (Eurobank or Bank) and its subsidiaries (the Eurobank or Bank Group).
This sustainability statement
 
covers the upstream
 
and downstream value
 
chain to the
 
following extent: The upstream
 
value
chain includes key suppliers such as those providing IT
 
hardware, office supplies, energy, and capital, as well as the regulatory
and voluntary
 
frameworks provided
 
by bodies
 
like the
 
European Central
 
Bank (ECB),
 
the European
 
Banking Authority
 
(EBA),
and the
 
Single Resolution Board
 
(SRB). The
 
downstream
 
value
 
chain
 
includes
 
Eurobank's
 
corporate
 
and
 
retail
 
clients
 
who
benefit from financing, investment banking, advisory services, and leasing solutions.
 
The value chain
 
has been
 
considered in
 
the materiality assessment
 
to identify material
 
impacts, risks, and
 
opportunities by
evaluating the key activities and stakeholders
 
in both the upstream and downstream
 
segments, including the environmental
and social impacts of suppliers and
 
customers. Moreover, Eurobank’s policies, actions, and targets extend
 
to Eurobank’s value
chain
 
as
 
far
 
as
 
suppliers,
 
corporate
 
and
 
retail
 
clients,
 
ensuring
 
sustainability
 
considerations
 
are
 
integrated
 
into
 
decision-
making processes for financing, capital
 
markets, and real estate. Finally,
 
when disclosing metrics, upstream data
 
on supplier
performance and
 
downstream data
 
related to
 
customer engagement
 
in sustainable
 
financing has
 
been considered
 
along
with assessments of Sustainability risks tied to both the upstream and downstream sectors.
1.2
 
Disclosures in relation to specific circumstances
 
[BP-2].
Eurobank has adopted the
 
following
 
time-horizons as defined in ESRS 1 : 6.4 Definition of short-, medium
 
-
 
and long-term for
reporting purposes:
for
 
the
 
short-term
 
time
 
horizon:
 
the
 
period
 
adopted
 
by
 
the
 
undertaking
 
as
 
the
 
reporting
 
period
 
in
 
its
 
financial
statements.
for the medium-term time horizon: from the end of the short-term reporting period defined above up to 5 years; and
 
for the long-term
 
time horizon: more than 5 years.
1.3
Governance
1.3.1
The role
 
of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
Eurobank
 
Holding’s
 
/
 
Eurobank’s
 
Board
 
of
 
Directors
 
(BoD)
 
is
 
comprised
 
of
 
3
 
executive
 
members,
 
and
 
10
 
non-executive
members.
 
The
 
members
 
of
 
the
 
Board
 
of
 
Directors
 
and
 
relevant
 
Committees
 
possess
 
experience
 
relevant
 
to
 
the
 
sectors,
products and geographic locations
 
of the undertaking:
Summary of Board Experience and Skills Matrix
Name
Position
Link to the Board of Directors CVs
Georgios Zanias
Chairperson, Non-Executive Director
Georgios Zanias CV
Fokion
 
Karavias
Chief Executive Officer
Fokion
 
Karavias CV
Kostas Vassiliou
Deputy Chief Executive Officer
Kostas Vassiliou
 
CV
Stavros Ioannou
Deputy Chief Executive Officer
Stavros Ioannou CV
Bradley Paul Martin
Non-Executive Director
Bradley Paul Martin CV
Rajeev Kakar
Non-Executive Independent Director
Rajeev Kakar CV
Alice Gregoriadi
Non-Executive Independent Director
Alice Gregoriadi CV
Jawaid Mirza
Non-Executive Independent Director
Jawaid Mirza CV
Rena Rouvitha Panou
Non-Executive Independent Director
Rena Rouvitha Panou CV
Cinzia Basile
Non-Executive Independent Director
Cinzia Basile CV
Burkhard Eckes
Non-Executive Independent Director
Burkhard Eckes CV
John Arthur Hollows
Non-Executive Independent Director
John Arthur Hollows CV
Evan Kotsovinos
Non-Executive Independent Director
Evan Kotsovinos CV
For more information,
 
please refer to Corporate
 
Governance Statement
 
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Board of Directors and Board
 
Committees - Eurobank Holdings and Eurobank
Directors
Board of
Directors
Audit
Committee
Board Risk
Committee
Nomination
and
Corporate
Governance
Committee
Remuneration
Committee
Board Digital
and
Transformation
Committee
(1)
Gender
Nationality
Georgios
Zanias
Chairperson,
Non-
Executive
Director
Member
Male
Hellenic
Fokion
 
Karavias
Chief
Executive
Officer
Male
Hellenic
Kostas
Vassiliou
Deputy Chief
Executive
Officer
Male
Hellenic
Stavros
Ioannou
Deputy Chief
Executive
Officer
 
Member
Male
Hellenic
Bradley Paul
Martin
Non-
Executive
Director
Male
Canadian
Rajeev Kakar
Non-
Executive
Independent
Director
Member
Chairperson
Member
Male
Indian
Alice
Gregoriadi
Non-
Executive
Independent
Director
Member
Member
Chairperson
Female
Hellenic
Jawaid Mirza
Non-
Executive
Independent
Director
Vice
Chairperson
Member
Member
Male
Canadian
Rena Rouvitha
Panou
Non-
Executive
Independent
Director
Member
Chairperson
Member
Female
Cypriot
Cinzia Basile
Non-
Executive
Independent
Director
Member
Chairperson
Member
Female
Italian
Burkhard
Eckes
Non-Executive
Independent
Director
Chairperson
Member
Member
Male
German
John Arthur
Hollows
Non-Executive
Independent
Director
Vice
Chairperson
Member
Member
Male
British
Evan
Kotsovinos
Non-Executive
Independent
Director
Member
Member
Member
Male
Hellenic
Total Number
of Members
13
5
5
4
5
5
(1)
 
Eurobank SA
As
 
presented
 
above,
 
Eurobank
 
Holding’s
 
Board
 
is
 
comprised
 
of
 
3
 
female
 
board
 
members,
 
and
 
10
 
male
 
board
 
members.
Female
 
representation
 
as mandated
 
by the
 
Greek Corporate
 
Governance
 
Law 4706/2020
 
is set
 
at a
 
minimum 25%
 
of the
total board membership.
 
In cases of a fraction, the
 
percentage is rounded
 
to the previous integer.
 
For
 
a BoD
 
comprising 13
 
members,
 
this translates
 
to 3.25,
 
which, after
 
rounding
 
down,
 
means at
 
least 3
 
female
 
members.
Currently,
 
Eurobank
 
is compliant with
 
this requirement,
 
as its Board
 
includes 3 female
 
members: Ms.
 
Rena Rouvitha
 
Panou,
Ms. Cinzia Basile, and Ms. Alice Gregoriadi.
 
Moreover,
 
62% of the
 
total BoD members
 
are independent. The
 
executive BoD members
 
are representing
 
the employees
 
of
the Group in the
 
Board of Directors.
Sustainability Governance
Eurobank
 
Group has
 
established the
 
Sustainability Management Committee
 
(Sustainability ManCo -
 
SMC). The
 
purpose of
the Sustainability ManCo is to:
provide strategic
 
direction on sustainability initiatives,
 
review and approve
 
the Sustainability Strategy,
 
Net Zero targets and transition
 
plans,
 
 
 
doc1p92i0
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ensure
 
that
 
the
 
elements
 
of
 
the
 
Sustainability
 
Strategy
 
and
 
the
 
Net
 
Zero
 
commitments
 
are
 
integrated
 
into
 
the
Group’s business model & operations,
approve changes in eligible assets of Green
 
Bond and Sustainable Finance Frameworks,
 
regularly measure and analyze the
 
progress of the Sustainability Strategy
 
goals and performance
 
targets,
 
ensure the proper
 
implementation of sustainability-related
 
policies and procedures,
 
in accordance with
supervisory requirements and voluntary
 
commitments.
The
 
Committee
 
includes
 
senior
 
management
 
roles
 
such
 
as
 
the
 
Deputy
 
CEO,
 
Group
 
Chief
 
Operating
 
Officer
 
(COO)
 
&
International Activities (Chairperson),
 
Deputy CEO, Head of Corporate & Investment
 
Banking, Deputy CEO, Head of Retail &
Digital Banking, Group Chief Risk Officer,
 
Group Senior Sustainability Officer,
 
Group Chief Financial Officer,
 
Group Chief HR
Officer
 
and
 
several
 
other
 
senior
 
leaders
 
from
 
Legal
 
Services,
 
Strategy,
 
Markets,
 
International
 
Activities,
 
Compliance,
 
and
Marketing
 
& Corporate
 
Communications
 
Group
 
units.
 
The
 
Group
 
Senior
 
Sustainability
 
Officer
 
(GSSO)
 
plays a
 
key
 
role
 
in
leading and coordinating
 
the Group’s
 
sustainability initiatives,
 
reporting directly
 
to the
 
senior management
 
and Board
 
for
sustainability matters and the Group Sustainability Coordination
 
Office serves as the Secretary
 
of the Sustainability ManCo.
Sustainability
 
ManCo’s
 
responsibilities
 
are
 
clearly
 
outlined
 
in
 
the
 
Terms
 
of
 
Reference,
 
which
 
guide
 
its
 
work,
 
including
approving
 
and monitoring
 
Sustainability Strategy,
 
Net Zero
 
commitments, targets,
 
action and
 
transition
 
plans, as
 
well
 
as
Sustainability
 
Frameworks
 
(e.g.
 
Green
 
Bond
 
Framework)
 
and
 
Policies,
 
ensuring
 
that
 
sustainability-related
 
projects
 
and
initiatives align with Sustainability Strategy
 
targets, objectives, Net Zero
 
commitments and sustainability-related KPIs.
Sustainability
 
at
 
Eurobank
 
is
 
deployed
 
across
 
a
 
Governance
 
structure
 
that
 
addresses
 
both
 
regulatory
 
requirements
 
and
voluntary
 
commitments. Board
 
oversight,
 
with respect
 
to the
 
Sustainability Strategy,
 
is addressed
 
through
 
the
 
inclusion of
sustainability items in
 
the Board
 
Meetings agenda, as
 
per international
 
best practice.
 
The Group’s
 
Governance
 
structure is
introducing and defining the roles and responsibilities in relation to sustainability risks, embedding
 
regulatory guidelines and
market practices.
Additionally,
 
the
 
Group
 
applies
 
the
 
Three
 
Lines
 
of
 
defense
 
model,
 
which
 
clarifies
 
the
 
roles
 
of
 
each
 
line
 
in
 
managing
sustainability risks. This model,
 
through structured policies, further delineates duties across each line, ensuring
 
that each body
and individual within the organisation
 
has a defined responsibility for managing sustainability impacts, mitigating risks and
leveraging opportunities within their operational
 
scope. The Sustainability Governance structure aims to further enhance the
effective
 
oversight
 
of
 
sustainability
 
matters
 
at
 
Management/Board
 
level,
 
through
 
direct
 
reporting
 
lines.
 
The
 
GSSO
 
as
represented in the
 
chart, along with the
 
Senior Risk Executive
 
Officer,
 
co-manages Group Sustainability Risk,
 
which involves
coordinating sustainability efforts and ensuring the
 
integration of sustainability principles
 
across the organisation. The GSSO
plays a
 
critical
 
role
 
in embedding
 
sustainability into
 
the
 
Group’s
 
strategic
 
decision-making,
 
ensuring that
 
sustainability is
considered in policies and operational
 
strategies.
 
Eurobank
 
enhanced
 
its sustainability
 
Governance
 
model and
 
supported the
 
roll
 
out of
 
its Sustainability
 
Strategy
 
and the
integration of sustainability risks.
Enhanced Governance Structure
 
and Committees:
Oversight
 
of
 
sustainability
 
risks
 
at
 
management
 
body
 
level
 
through
 
allocation
 
of
 
responsibilities
 
to
 
Board
 
and
management
 
committees.
 
Specifically,
 
Chairman
 
of
 
the
 
SMC
 
is
 
the
 
Deputy
 
Chief
 
Executive
 
Officer,
 
Group
 
Chief
Operating Officer
 
(Group COO) & International Activities.
A Board Member has been appointed as the overall
 
responsible for climate-related
 
and environmental risks.
Establishment
 
of
 
2
 
Committees
 
that
 
supplement
 
the
 
governance
 
arrangements
 
on
 
sustainability
 
risk,
 
i.e.
Sustainability Management Committee and Climate Risk Stress Test
 
Committee.
 
 
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Appointment of Group Senior Sustainability Officer
 
to lead the Group’s
 
sustainability initiatives.
Integration of Sustainability Risk Management
 
across the 3 lines:
Dedicated
 
teams within
 
the
 
CIB
 
and Retail
 
Banking Units
 
for
 
overseeing
 
sustainability and
 
sustainable financing
activities.
 
Automated process established
 
to assess and classify sustainable financing opportunities.
 
Group
 
Sustainability
 
Unit
 
responsible
 
for
 
managing
 
and
 
coordinating
 
sustainability
 
strategy
 
related
 
issues,
 
the
development
 
of
 
action
 
plans
 
for
 
the
 
Group’s
 
Net
 
Zero
 
portfolio
 
strategies,
 
as
 
well
 
as
 
monitoring
 
sustainability
performance
 
and coordinating sustainability-linked
 
activities that enhance
 
the Group’s
 
Impact. In this
 
context, the
Unit is responsible for facilitating the
 
development of the Sustainability data framework
 
to coordinate and prepare
external and internal sustainability-related
 
reports.
 
Group
 
Sustainability Risk
 
responsible
 
for
 
managing and
 
monitoring
 
sustainability
 
risks,
 
acting as
 
PMO
 
office
 
for
implementing
 
the
 
sustainability
 
risks
 
roadmap
 
and
 
monitoring
 
the
 
Sustainability
 
Strategy,
 
and
 
preparing
 
and
maintaining the Bank’s Sustainability risk
 
management policies, processes and methodologies, in collaboration with
the Group Sustainability Unit, Business
 
and Risk Units.
 
Intensive training on sustainability,
 
sustainable finance and sustainability risk topics to Group personnel.
The roles
 
and responsibilities of the key governance
 
bodies / committees / units-functions are outlined below.
Supervisory bodies:
Eurobank Holdings / Eurobank
 
Board of Directors (BoDs/Boards)
 
Eurobank Holdings
 
/ Eurobank
 
Boards’ role
 
is to offer
 
entrepreneurial leadership
 
to the Group
 
in the context of prudent
 
and
effective
 
controls
 
facilitating
 
the
 
assessment
 
and
 
management
 
of
 
risks.
 
The
 
Boards,
 
establish
 
the
 
Group’s
 
strategic
objectives, ensure the
 
availability of essential financial and human resources for the
 
Group to fulfil its purpose, and evaluate
management
 
performance.
 
The
 
Boards
 
define
 
the
 
Group’s
 
values
 
and
 
standards,
 
ensuring
 
that
 
its
 
responsibilities
 
to
shareholders and others
 
are acknowledged and
 
fulfilled. All members
 
of the Boards
 
are required
 
to act in the
 
best interests
of the Group, aligning with their legal
 
duties. The Eurobank Holdings
 
/ Eurobank Boards have assigned an executive
 
member
as the Board Member responsible
 
for climate-related
 
and environmental risks. As part of its duties, this member
 
updates, at
least on
 
a semi-annual
 
basis,
 
the
 
Eurobank
 
Holdings /
 
Eurobank
 
Board
 
Risk Committees
 
(BRC), which,
 
in accordance
 
with
their
 
Terms
 
of Reference,
 
are
 
responsible
 
for
 
overseeing
 
(among others)
 
the
 
sustainability
 
risks.
 
As per
 
international
 
best
practices,
 
effective
 
Board
 
oversight
 
with
 
respect
 
to
 
the
 
Group’s
 
Sustainability
 
Strategy
 
is
 
also
 
safeguarded
 
through
 
the
regular inclusion of Sustainability items in the agendas of Board
 
Meetings.
 
Eurobank Holdings / Eurobank
 
Board Risk Committee (BRC)
The Eurobank Holdings / Eurobank Board Risk
 
Committee (BRC), among
 
others, oversees the implementation of the strategies
for capital and liquidity management, as well as for all material
 
risks of the Group, including sustainability risks, as identified
through the
 
Risk Identification
 
and Materiality
 
Assessment (RIMA)
 
process and
 
listed in the
 
relevant RIMA
 
report, to assess
their
 
adequacy
 
against
 
the
 
approved
 
risk
 
appetite
 
and
 
strategy.
 
In
 
addition,
 
the
 
BRC
 
determines,
 
among
 
others,
 
the
principles which govern risk management
 
(including sustainability risks) across the
 
Group in terms of identifying, measuring,
monitoring, controlling and mitigating risks. To
 
this end, the Committee approves
 
risk principles, risk policies, risk procedures
and risk methodologies,
 
and the
 
Specific Risk
 
Management Frameworks
 
and policies
 
(e.g. Sustainability Risk
 
Management
Policy)
Audit Committee
In
 
line
 
with
 
the
 
stipulation
 
of
 
the
Law
 
5164
 
(Article
 
43),
 
Audit
 
Committee
 
(AC)
 
has
 
been
 
entrusted
 
with
 
additional
responsibilities concerning the
 
submission and assurance
 
of the Sustainability Statement.
 
The Audit Committee
 
informs the
Board of
 
Directors about
 
the outcome
 
of the
 
statutory audit
 
and the
 
assurance
 
of the
 
sustainability statement.
 
It explains
how these
 
processes
 
contributed to the
 
integrity of the
 
financial and sustainability
 
information
 
and clarifies the
 
role
 
of the
Audit Committee during this process
 
Management bodies:
Eurobank Management
 
Risk Committee (MRC)
 
The
 
Eurobank
 
Management
 
Risk
 
Committee
 
(MRC)
 
is
 
responsible
 
for
 
overseeing
 
the
 
risk
 
management
 
framework
 
of
Eurobank. As part of its responsibilities, the MRC facilitates reporting to the BRC on a wide range of risk-related topics under
its purview,
 
including sustainability
 
risks. The
 
MRC ensures
 
that material
 
risks are
 
identified and promptly
 
escalated to
 
the
BRC and
 
that the
 
necessary policies
 
and procedures
 
are in
 
place to
 
prudently manage
 
risk and
 
to comply
 
with regulatory
requirements.
Eurobank Sustainability Management
 
Committee (Sustainability ManCo-SMC)
 
The
 
Eurobank
 
Sustainability
 
ManCo
 
provides
 
strategic
 
direction
 
on
 
sustainability
 
initiatives,
 
reviews
 
the
 
Sustainability
Strategy,
 
Net Zero
 
targets and
 
transition
 
plans prior
 
to approval,
 
ensures that
 
the
 
elements of
 
the Sustainability
 
Strategy
and the
 
Net Zero
 
commitments are
 
integrated into
 
the Group’s
 
business model &
 
operations,
 
approves
 
changes in eligible
assets
 
of
 
Green
 
Bond
 
and
 
Sustainable
 
Finance
 
Frameworks,
 
regularly
 
measures
 
and
 
analyzes
 
the
 
progress
 
of
 
the
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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Sustainability
 
Strategy
 
goals
 
and
 
performance
 
targets
 
and
 
ensures
 
the
 
proper
 
implementation
 
of
 
sustainability-related
policies and procedures, in accordance with supervisory requirements
 
and voluntary commitments. It is chaired by the Board
Member responsible for climate
 
-related and environmental
 
risks.
Eurobank Climate Risk Stress
 
Test Committee (CRSTC)
 
The
 
Eurobank
 
Climate
 
Risk
 
Stress
 
Test
 
Committee
 
(CRSTC)
 
is
 
responsible
 
for
 
designing
 
and
 
executing
 
the
 
Group’s
 
CRST
Programme,
 
as
 
well
 
as
 
for
 
coordinating
 
all
 
activities
 
relating
 
to
 
Climate
 
Risk
 
Stress
 
Testing,
 
including
 
risk
 
identification,
scenario design
 
and stress
 
test execution,
 
and reviewing
 
and challenging
 
the output
 
at each
 
stage of
 
the
 
process
 
prior to
escalating to the Executive
 
Board.
Administrative bodies:
Group Senior Sustainability Officer
 
(GSSO)
 
The
 
Group
 
Senior
 
Sustainability
 
Officer
 
(GSSO)
 
is
 
responsible
 
for
 
leading
 
and
 
coordinating
 
the
 
Group’s
 
sustainability
initiatives, for both Operational and Financed Impact. GSSO
 
manages the Group Sustainability, co-manages, as
 
a secondary
reporting line,
 
along with
 
the Senior
 
Risk Executive
 
Officer
 
the Group
 
Sustainability Risk,
 
coordinates Sustainability
 
Center
of Excellence of
 
CIB and Retail and oversees
 
the sustainability programs
 
of international
 
subsidiaries. The role
 
of the GSSO
is to foster
 
a deep understanding
 
of sustainability principles
 
and practices
 
across the
 
organisation by
 
building a culture
 
of
sustainability
 
and
 
collaborating
 
together
 
with
 
senior
 
management
 
to
 
embed
 
sustainability
 
into
 
the
 
Group’s
 
strategic
decision-making processes. GSSO secures and allocates resources effectively
 
to support the Group’s sustainability initiatives
and advocates
 
for
 
necessary
 
investments
 
in sustainability
 
projects
 
and technologies.
 
GSSO serves
 
as the
 
liaison between
the
 
Group
 
and Market/External
 
Stakeholders,
 
closely monitoring
 
industry trends,
 
regulatory
 
changes and
 
best practices
 
in
sustainability and ensuring that the Group
 
remains at the forefront
 
of sustainability innovation and compliance.
Group Sustainability Unit
 
The
 
Group
 
Sustainability Unit
 
acts as
 
a custodian
 
of Sustainability
 
Principles and
 
Culture to
 
enhance the
 
Group’s
 
Impact,
and
 
as
 
a
 
cross-functional
 
coordinator
 
to
 
ensure
 
alignment
 
on
 
sustainability
 
issues
 
and
 
interdependencies,
 
as
 
well
 
as
compliance
 
with
 
relevant
 
existing and
 
upcoming
 
regulations.
 
Specifically,
 
the
 
Group
 
Sustainability
 
Unit
 
is responsible
 
for
managing
 
and
 
coordinating
 
sustainability
 
strategy
 
related
 
issues,
 
ensuring
 
alignment
 
of
 
subsidiaries'
 
programs
 
with
 
the
Group's
 
overall
 
sustainability
 
strategy
 
and
 
goals,
 
supporting
 
their
 
implementation
 
efforts.
 
The
 
Group
 
Sustainability
 
Unit
coordinates
 
the
 
development
 
of
 
action
 
plans
 
for
 
the
 
Group’s
 
Net
 
Zero
 
portfolio
 
strategies
 
and
 
ensures
 
the
 
aligned
development of corresponding plans for subsidiaries. It directs the actions of the Bank's units and subsidiaries
 
on sustainable
financing matters and provides advisory support on broader sustainability issues. The Unit facilitates the development of the
Sustainability data framework and promotes sustainability knowledge and culture. Furthermore, it coordinates and prepares
external and internal sustainability-related reports
 
in line with
 
applicable standards/regulations, in cooperation with involved
subject-matter
 
responsible
 
Units,
 
while
 
it
 
is
 
responsible
 
for
 
the
 
UNEP
 
FI
 
PRB
 
implementation.
 
Being
 
responsible
 
for
 
the
oversight of the Bank’s overall
 
sustainability performance, its key roles
 
include the centralized management of Sustainability
Ratings,
 
seeking
 
continuous
 
improvement
 
in
 
related
 
scores.
 
The
 
Group
 
Sustainability
 
Unit
 
also
 
manages
 
the
 
ISO
Management
 
Systems under
 
the
 
related
 
provisions
 
of equivalent
 
policies
 
and the
 
Sustainability Strategy,
 
supporting also
the
 
development
 
/ maintenance
 
of ISO
 
Management Systems
 
at Group
 
level,
 
where
 
applicable. It
 
collects, calculates
 
and
reviews
 
data,
 
in
 
line
 
with
 
the
 
associated
 
certified
 
ISO
 
Management
 
Systems,
 
while
 
it
 
also
 
ensures
 
implementation
 
of
corresponding initiatives (e.g. operational
 
net zero transition, energy
 
self-production, energy and emission monitoring, green
building certifications, recycling
 
and circular economy management).
Business Units
 
The Business Units –
 
Corporate and Investment Banking, and
 
Retail Banking –
 
are primarily involved in executing
 
all portfolio-
related
 
sustainable
 
activities,
 
including
 
the
 
implementation
 
of
 
the
 
Financed
 
Impact
 
Strategy.
 
Key
 
responsibilities
 
are
classified, inter alia, under the following
 
3 main categories:
 
1.
Sustainability Strategy
Executing and monitoring financed and specific
 
operational
 
sustainable goals and performance
 
targets in line
with the Net Zero
 
Strategy.
 
2.
Sustainable Financing/Funding and Investments
Identifying sustainable financing opportunities and designing relevant solutions
 
and sustainable products.
Performing the
 
sustainable financing assessment, in line with the
 
Sustainable Finance Framework.
Implementing and monitoring the Sustainable Investment
 
and Green Bond Frameworks.
3.
Sustainability Risk Management
 
Performing the
 
overall
 
ESG Risk Assessment.
 
Identifying and implementing mitigation action plans for
 
sustainability risks.
 
Eurobank has established dedicated functions, namely the Sustainability Center of Excellence (CoE), within the Business Units
(Corporate
 
& Investment
 
Banking and
 
Retail Banking)
 
which are
 
responsible for
 
assessing, managing
 
and monitoring
 
risk
levels
 
in all
 
risk categories,
 
including Sustainability
 
risks.
 
The
 
Head of
 
CIB
 
Sustainability
 
CoE is
 
responsible
 
for
 
overseeing
sustainable
 
financing
 
activities,
 
while
 
two
 
Retail
 
Banking
 
Sustainability
 
Coordinators
 
(Business
 
and
 
Individual
 
clients
respectively) are re
 
sponsible for organising and supporting sustainable-related
 
financing activities.
 
 
 
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Group Sustainability Risk (GSR)
The
 
GSR has
 
the
 
overall
 
responsibility
 
for
 
overseeing,
 
monitoring and
 
managing sustainability
 
risks. More
 
specifically,
 
the
GSR
 
prepares
 
and
 
maintains
 
the
 
Bank’s
 
Sustainability
 
risk
 
management
 
policies,
 
processes
 
and
 
methodologies,
 
in
collaboration
 
with the
 
Group Sustainability Unit
 
and the Business
 
and Risk Units. In
 
addition, it leads the
 
development and
implementation of the
 
Sustainability risk-related framework,
 
policies and processes, in coordination
 
with other
 
units, as well
as acts, monitors and reports
 
the progress
 
of the implementation
 
of the developed
 
Climate Risk action
 
plan and reports to
the Board for Sustainability risks matters. The GSR monitors and challenges involved stakeholders
 
as to setting the Financed
Impact Strategy
 
(including Net
 
Zero
 
targets),
 
as well
 
as monitors
 
the
 
Financed
 
Impact
 
Strategy
 
(including Net
 
Zero)
 
and
reports financial targets
 
and KPIs. The
 
GSR also leads the
 
2nd line independent sustainable
 
lending re-assessment process
against the
 
Sustainable
 
Finance
 
criteria,
 
including
 
the
 
characterization
 
of products
 
of the
 
Retail Portfolio
 
as sustainable.
Reviews
 
and confirms
 
the
 
ESG Risk
 
Assessment and
 
challenges the
 
mitigating actions
 
(as per
 
pre-determined
 
thresholds).
Furthermore,
 
the GSR
 
develops and
 
maintains the
 
Climate Risk
 
Stress Testing
 
Framework,
 
as well
 
as the
 
Scenario Analysis
and
 
Stress
 
Testing
 
methodologies,
 
and
 
coordinates
 
the
 
performance
 
of
 
sustainability
 
risk
 
scenario
 
analysis
 
and
 
relevant
stress test exercises at Group
 
level.
Group Compliance
 
Group Compliance’s key
 
roles and responsibilities include:
 
1.
Regulatory compliance
Monitors
 
the
 
regulatory
 
environment
 
and
 
emerging
 
trends
 
around
 
sustainable
 
financing
 
and
 
suggests
 
the
Group of the respective
 
changes/enhancements to the relevant
 
policies and documents regarding sustainable
financing offerings.
 
Issues a regulatory bulletin, which includes regulatory developments
 
and their impact on the Bank’s operation.
 
Monitors
 
the
 
alignment
 
of
 
the
 
Group’s
 
activities
 
with
 
applicable
 
laws,
 
rules,
 
regulations
 
and
 
standards,
including sustainable finance regulatory aspects.
 
2.
Compliance risk assessment
Designs appropriate risk assessment methodologies
 
for compliance risk.
Establishes a monitoring programme
 
for the relevant
 
activities within its area of responsibility.
Assesses conduct risk in relation to sustainability financing.
 
3.
Policy updates
 
Maintains the Bank’s conduct-related policies,
 
including their sustainability components.
 
4.
Product offering
 
monitoring
 
Provides advice and recommends
 
controls over
 
the Bank’s sustainability product offerings,
 
while it also checks
that
 
promotional
 
statements
 
do
 
not
 
misrepresent
 
products
 
or
 
services
 
offered
 
to
 
customers,
 
through
 
its
participation in the Products
 
and Services Committee and related processes.
 
Group Internal Audit (Group IA)
The
 
role
 
of
 
the
 
3rd
 
line
 
within
 
Eurobank’s
 
governance
 
and
 
organisational
 
structure
 
is
 
allocated
 
to
 
the
 
Group
 
IA,
 
for
 
the
independent
 
review
 
of
 
the
 
adequacy
 
and
 
effectiveness
 
of
 
the
 
internal
 
control
 
system.
 
The
 
Group
 
IA
 
mandate
 
covers
 
all
processes,
 
risks
 
and
 
mechanisms,
 
for
 
all
 
business
 
lines
 
and
 
internal
 
units.
 
In
 
recent
 
years,
 
the
 
Group
 
IA
 
has
 
recognised
sustainability internal controls
 
and the risk
 
management framework
 
as areas of focus
 
and has taken
 
several
 
initiatives and
actions within
 
its strategy.
 
These
 
aim to ensure
 
adequate coverage
 
of the
 
area, in
 
line with
 
the
 
Bank’s strategy,
 
as well
 
as
industry and regulatory developments.
 
Specifically, the
 
Group IA strategically
 
focuses on the Sustainability risks, building on the
 
following pillars:
 
Methodology/ Infrastructure
 
– The Management
 
of sustainability risks and the
 
Bank’s initiatives are recognised
 
as
a
 
separate
 
auditable
 
area,
 
subject
 
to
 
risk
 
assessment.
 
Furthermore,
 
climate-related
 
and
 
environmental
 
risk
 
is
recognised as
 
a separate
 
risk category,
 
assessed in all
 
relevant areas
 
of the
 
audit universe,
 
in line
 
with the
 
Bank’s
risk
 
taxonomy.
 
This
 
category
 
will
 
be
 
extended
 
to
 
cover
 
the
 
entire
 
spectrum
 
of
 
sustainability
 
risks,
 
in
 
line
 
with
respective developments
 
in the Bank’s risk definitions.
 
Resources
 
 
The
 
Group
 
IA
 
has
 
extended
 
its
 
pool
 
of
 
professional
 
qualifications/
 
certifications
 
to
 
the
 
area
 
of
sustainability, with two staff members certified in Sustainability/ESG and Climate
 
Risk through different professional
bodies to diversify
 
relevant expertise
 
and with additional
 
auditors planned to
 
pursue relevant
 
industry-recognised
professional
 
body
 
certifications
 
in
 
the
 
future.
 
This
 
comes
 
simultaneously
 
with
 
other
 
initiatives
 
in
 
place,
 
aimed
 
at
further upskilling through dedicated training sessions,
 
on-the-job upskilling (participation in and consultation on the
Bank’s
 
projects
 
and
 
initiatives
 
around
 
sustainability)
 
and
 
increased
 
awareness
 
(e.g.
 
Group
 
IA
 
ESG
 
Focus
 
Group
focused
 
at sharing
 
knowledge on
 
sustainable practices
 
and regulatory
 
initiatives). At
 
this stage,
 
the Group
 
IA has
opted
 
to
 
embed
 
the
 
right
 
mix
 
of
 
skills
 
and
 
knowledge
 
within
 
its
 
existing
 
organisational
 
structure,
 
given
 
the
multifaceted nature of sustainability risks, affecting all businesses and operations
 
of the Bank, to a siloed approach,
aiming at a holistic consideration
 
of the Bank’s sustainability risks.
 
Sustainability
/ Audit Universe Coverage and Audit Planning
 
– Following the infrastructure
 
steps described above,
since 2021, the Group IA has been carrying out several assignments around sustainability,
 
along with monitoring the
Bank’s initiatives in this
 
area on a risk-based approach.
 
Key areas of focus
 
include risk materiality,
 
governance
 
and
 
 
 
 
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strategy,
Sustainability risk management
 
framework,
 
product design and
 
offering,
 
reporting disclosures,
 
etc. These
initiatives
 
come in
 
addition to
 
the
 
existing coverage
 
by Group
 
IA in
 
sustainability areas,
 
such as
 
consideration
 
of
AML-perspectives in loan origination (governance
 
-social financing practices), review of compliance with the code of
conduct or market practice codes (governance operational
 
and financing practices) and relevant non-recurring and
forensic audit work.
For more
 
information regarding
 
the responsibilities
 
for impacts, risks
 
and opportunities of the
 
administrative,
 
management
and
 
supervisory
 
bodies,
 
please
 
refer
 
to:
 
“1.3.2
 
Information
 
provided
 
to
 
and
 
sustainability
 
matters
 
addressed
 
by
 
the
undertaking's administrative, management and supervisory bodies
 
[GOV-2]” and
 
1.5.1 Description of the processes to identify
and assess material impacts, risks and opportunities [IRO-1].
Alignment of the Remuneration
 
Policy with the
 
Group’s sustainability risks objectives
 
The
 
Group
 
has
 
established
 
a
 
Remuneration
 
Policy
 
that
 
is
 
applicable
 
to
 
all
 
Group
 
employees
 
and
 
covers
 
their
 
total
remuneration.
 
The Remuneration
 
Policy forms an integral part of the
 
Group’s corporate
 
governance practice.
 
It is developed
in accordance
 
with its operational
 
model, business strategy,
 
objectives and long-term
 
interests and incorporates
 
measures
to avoid
 
conflict of
 
interest. The
 
Remuneration
 
Policy
 
promotes sound
 
and effective
 
risk management.
 
It is
 
consistent with
the objectives of the Group’s business
 
and risk
 
strategy, corporate culture and values, risk
 
culture, with regard to
 
sustainability
risk factors,
 
including long-term
 
interests of
 
the Group
 
and the
 
measures used
 
to avoid
 
conflicts of interest,
 
while it should
not encourage excessive
 
risk-taking on behalf of the Group. It also ensures that remuneration
 
practices are aligned with the
overall
 
risk appetite, taking into
 
account all risks.
 
Moreover
 
it includes sustainability
 
risks, reputational
 
risks, as well
 
as risks
resulting from the
 
mis-selling of products. More specifically,
 
the Remuneration
 
Policy has been designed to:
 
Be consistent with and to promote sound and effective
 
risk management.
 
Stimulate behaviours consistent with sustainability risks approach.
 
Comply with the Group’s
 
voluntary commitments.
 
Its basic principles are to:
 
Be gender neutral and non-discriminatory in any aspect of its implementation.
Safeguard that remuneration
 
is sufficient to retain and attract
 
executives with appropriate
 
skill and experience.
 
Monitor that internal equity between all
 
Units is applied.
 
Avoid excessive
 
risk-taking, even in the
 
case of direct or indirect sustainability risks.
Link remuneration
 
with long-term performance.
The
 
Group’s
 
sustainability-linked
 
remuneration
 
integrates
 
the
 
achievement
 
of
 
components
 
/
 
targets
 
of
 
the
 
Group’s
Sustainability Strategy, Operational
 
and Financed impact, to incentivise management and
 
employees to contribute towards
their achievement.
Operating model
The Group
 
has identified, assessed and implements relevant action plans addressing
 
sustainability risks within the 3 lines.
Integration of Sustainability Risk
 
Management across the
 
3 lines
 
The Group’s
 
Sustainability Governance
 
structure introduces
 
and defines specific
 
roles
 
& responsibilities in
 
order to
 
support
the roll-out
 
of the Sustainability
 
Strategy and
 
the integration
 
of the
 
sustainability risks, through
 
the involvement
 
of various
key
 
stakeholders
 
(e.g.
 
Business
 
&
 
Risk
 
Units,
 
Committees
 
etc.)
 
across
 
the
 
three
 
Lines
 
of
 
defense,
 
embedding
 
regulatory
guidelines and market practices,
 
as follows:
1st Line:
 
Dedicated functions, namely the Sustainability Centers of
 
Excellence (CoE), within the Business Units
 
(Corporate & Investment
Banking and Retail
 
Banking) are responsible for
 
assessing, managing
 
and monitoring risk
 
levels in all
 
risk categories, including
Sustainability risks.
 
The
 
Head of
 
CIB Sustainability
 
CoE is
 
responsible
 
for
 
overseeing
 
sustainable financing
 
activities, while
two Retail
 
Banking Sustainability
 
Coordinators (Business
 
and Individual
 
clients respectively)
 
are responsible
 
for
 
organising
and supporting sustainable
 
-related financing
 
activities. In
 
addition, the
 
role
 
of the
 
Group Sustainability
 
Unit in the
 
1st Line
includes the
 
responsibility for
 
managing and coordinating
 
sustainability strategy
 
related issues,
 
the development
 
of action
plans for the Group's Net Zero portfolio strategies,
 
the facilitation of the Sustainability data framework
 
development, as well
as Sustainability Reporting, Environmental
 
& Energy
 
Reporting (EMAS Report, Greenhouse
 
Gases Emissions Report
 
per ISO
14064) and Sustainability
 
ratings.
 
The 1st
 
Line, in coordination
 
with other
 
Units, execute and
 
monitor financed,
 
and specific
operational
 
sustainable goals
 
and performance
 
targets based
 
on the
 
Group’s
 
Sustainability Strategy
 
and in
 
line with
 
the
Net Zero Strategy.
2nd Line:
 
Group Risk Management (GRM) is independent from the Business Units and
 
has full responsibility in setting the Risk Strategy
and Risk Appetite Framework, including Sustainability risks. Within GRM, the dedicated GSR has the overall
 
responsibility for
overseeing,
 
monitoring and
 
managing Sustainability
 
risks in
 
cooperation
 
with the
 
other
 
GRM Units,
 
as well
 
as with
 
Group
Compliance.
 
 
 
 
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3rd Line:
 
The Group Internal Audit (Group IA) independently reviews the adequacy and effectiveness of the internal control
 
framework
in place regarding
 
Sustainability risk management,
 
following
 
a risk-based approach
 
in line with
 
its Annual Risk Assessment
and Audit Planning Methodology.
ESG awareness and capacity building
 
Eurobank places a great
 
emphasis on building capacity among its employees, so they
 
are able to support its clients on their
sustainability journey
 
and their
 
green transition.
 
To
 
this end, in
 
addition to launching
 
sustainability initiatives
 
for its
 
clients,
Eurobank implements an ESG upskilling plan for
 
its employees. Eurobank’s ESG awareness
 
program regarding
 
sustainability
matters,
 
is
 
directed
 
to
 
all
 
of
 
the
 
Group's
 
personnel
 
-
 
employees
 
and
 
management.
 
Additionally,
 
the
 
Group
 
has
 
offered
training to stakeholders
 
from all
 
3 lines (i.e. business
 
units, risk management
 
units, Group
 
IA) regarding the
 
SFF,
 
to enhance
their
 
understanding.
 
Finally,
 
the
 
Group
 
conducts
 
training
 
sessions/seminars
 
tailored
 
to
 
its
 
supervisory
 
and
 
management
bodies, tailored to their specific areas of interes
 
t/expertise.
Specifically, the
 
following awareness
 
programmes
 
are in place:
Employee ESG awareness training
 
modules
 
Since 2022, the Group has
 
launched “ESG Thinking”, an ESG
 
awareness programme for employees, consisting of the following
modules:
 
Module 1
 
– ESG
 
and World:
 
Fundamentals
 
of ESG,
 
megatrends
 
and related
 
risk and
 
opportunities as
 
well
 
as the
importance of ESG within an organisation described
 
through business cases.
Module
 
2
 
 
ESG
 
and
 
the
 
Bank:
 
Key
 
drivers
 
of
 
ESG,
 
its
 
impact
 
on
 
the
 
banking
 
industry
 
and
 
the
 
ESG
 
regulatory
landscape. The ways in which the
 
Bank engages with sustainability through frameworks,
 
initiatives and products.
 
Module 3
– ESG and Me: Content aiming to cultivate an open and growth mindset when dealing with sustainability
issues by motivating employees
 
to take personal action through
 
practical steps personally and professionally.
Target
 
setting
The
 
Board of
 
Directors, Board
 
Committees, Management
 
Committees and
 
functions oversee
 
the setting
 
of targets
 
related
to material
 
impacts, risks,
 
and opportunities
 
through
 
a combination
 
of strategic
 
review,
 
decision-making,
 
and continuous
monitoring.
 
The
 
Sustainability Management
 
Committee (Sustainability
 
ManCo -
 
SMC) plays
 
a central
 
role
 
in this
 
process
 
by reviewing
the Sustainability Strategy,
 
providing strategic
 
direction on sustainability
 
initiatives, reviewing
 
and approving
 
the Net Zero
targets and transition plans, integrating the elements
 
of the Sustainability Strategy and the Net Zero commitments, into the
Group’s
 
business
 
model
 
&
 
operations,
 
while
 
also
 
ensuring
 
that
 
stakeholder
 
interests
 
and
 
expectations
 
are
 
met.
 
It
 
also
approves
 
changes in eligible
 
assets of Green
 
Bond and Sustainable
 
Finance Frameworks,
 
regularly measures
 
and analyses
the
 
progress
 
of
 
the
 
Sustainability
 
Strategy
 
goals
 
and
 
performance
 
targets,
 
ensure
 
the
 
proper
 
implementation
 
of
Sustainability-related policies and procedures, in accordance with
 
supervisory requirements and voluntary commitments. The
Committee further
 
approves
 
Sustainability-related reports,
 
including the Sustainability
 
Statement and Green
 
Bond Report,
among others.
 
Additionally,
 
the
 
Sustainability ManCo
 
reviews
 
and endorses
 
Sustainability-related
 
KPIs linked
 
to variable
remuneration
 
and
 
incentive
 
schemes,
 
prior
 
to
 
submission
 
to
 
the
 
Incentive
 
Plan
 
Committee.
 
Through
 
this
 
oversight,
 
the
Sustainability
 
ManCo
 
ensures
 
the
 
continuous
 
improvement
 
and
 
alignment
 
of
 
Sustainability-related
 
ISO
 
Management
Systems, including
 
ISO standards
 
in the
 
environmental
 
and energy
 
domains, ensuring
 
their
 
ongoing suitability,
 
adequacy,
and effectiveness.
Sustainability-related expertise
 
The Board
 
of Directors,
 
Board Committees,
 
Management Committees,
 
functions and
 
involved
 
units possess a
 
collective set
of skills and
 
expertise that
 
are crucial
 
for overseeing
 
sustainability matters.
 
At the
 
Board level,
 
Sustainability Management
Committee
 
(Sustainability
 
ManCo
 
-
 
SMC)
 
and
 
senior
 
management,
 
expertise
 
in
 
sustainability
 
is
 
represented
 
through
 
a
structured approach
 
that integrates
 
both in-house knowledge
 
and external expertise.
 
The SMC provides
 
strategic direction
on Sustainability -related initiatives, aligning them
 
with the Group’s
 
broader transformation
 
plan. The members
 
of the SMC,
including senior roles like the
 
Deputy CEO, Group Chief Operating Officer
 
(COO) & International Activities, Chief Risk Officer
(CRO),
 
and
 
Group
 
Senior
 
Sustainability
 
Officer
 
(GSSO),
 
are
 
responsible
 
for
 
ensuring
 
that
 
Sustainability
 
issues
 
are
 
fully
incorporated into the operations
 
and decision-making processes across the organisation.
 
Furthermore, the SMC reviews and
approves sustainability
 
training and awareness
 
initiatives. Moreover
 
the BoD ensures
 
that key individuals
 
across the
 
Group
are equipped with necessary expertise as it has
 
the oversight over training
 
and awareness initiatives as evidenced by its role.
This
 
structure
 
ensures
 
that
 
expertise
 
is
 
both
 
possessed
 
internally
 
and
 
is
 
accessible
 
externally,
 
empowering
 
the
 
Group
 
to
manage sustainability challenges effectively.
The
 
skills
 
and
 
expertise
 
present
 
within
 
the
 
Board
 
of
 
Directors,
 
Board
 
Committees,
 
Management
 
Committees,
 
units
 
and
functions are directly aligned
 
with the undertaking's material impacts,
 
risks, and
 
opportunities. For instance, the Sustainability
ManCo
 
is
 
tasked
 
with
 
overseeing
 
the
 
integration
 
of
 
sustainability
 
goals,
 
including
 
Net
 
Zero
 
Strategy
 
and
 
Sustainable
Financing activities, into the Group’s broader strategic objectives. The expertise of senior executives such as the Deputy CEO,
Group COO and
 
International Activities,
 
CRO and GSSO ensures
 
that Sustainability considerations
 
are embedded into the
 
 
 
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Group’s
 
daily operations,
 
enabling them to
 
address and manage the
 
material risks and
 
opportunities tied to sustainability.
The Business
 
Units (Corporate
 
& Investment
 
Banking, Retail Banking)
 
are actively
 
engaged in managing sustainability
 
risks
as
 
part
 
of
 
their
 
operations,
 
with
 
specific
 
responsibilities
 
assigned
 
through
 
the
 
Group
 
Sustainability
 
Unit,
 
responsible
 
to
manage and coordinate sustainability strategy related
 
issues. Through the
 
structure, these bodies ensure that sustainability
risks are appropriately assessed, monitored, and mitigated
 
at every level,
 
from operational
 
to strategic decision-making.
A
 
sustainability
 
awareness
 
training
 
was
 
conducted
 
for
 
the
 
Board
 
of
 
Directors,
 
enhancing
 
the
 
understanding
 
of
 
CSRD
Reporting requirements, including Double Materiality Assessment, EU Taxonomy,
 
and disclosure requirements among others.
Through
 
their participation
 
in this
 
training, the
 
Board of
 
Directors developed
 
a comprehensive
 
understanding of
 
the
 
CSRD
requirements
 
and
 
learned
 
how
 
to
 
consider
 
these
 
in
 
the
 
company’s
 
strategic
 
planning
 
and
 
long-term
 
growth
 
objectives
effectively
1.3.2
Information provided to and sustainability matters addressed by the undertaking's
 
administrative, management
and supervisory bodies [GOV-2]
The
 
Sustainability
 
Management
 
Committee
 
(SMC)
 
is
 
regularly
 
informed
 
about
 
material
 
impacts,
 
risks,
 
and
 
opportunities
through
 
multiple reporting
 
channels. Specifically,
 
the
 
SMC meets
 
quarterly
 
and/or on
 
an ad
 
hoc basis,
 
when necessary,
 
to
review
 
and
 
provide
 
strategic
 
direction
 
on
 
sustainability-related
 
issues,
 
including
 
material
 
risks
 
and
 
opportunities.
 
The
Committee reviews
 
and monitors
 
sustainability strategies,
 
action plans,
 
KPIs and
 
progress
 
towards sustainability
 
goals to
ensure
 
they
 
align
 
with
 
the
 
Group’s
 
objectives.
 
The
 
SMC
 
also
 
reviews
 
reports
 
on
 
sustainability
 
issues,
 
risk
 
management
processes, and performance
 
metrics, ensuring that decisions are
 
aligned with sustainability goals.
 
Impacts, Risks and Opportunities consideration
The SMC carefully
 
considers impacts, risks and opportunities when overseeing
 
the Group’s strategy.
 
The SMC plays a critical
role
 
in providing
 
strategic
 
direction
 
on sustainability
 
matters,
 
ensuring the
 
Sustainability Strategy
 
aligns with
 
the
 
Group’s
overall
 
Transformation
 
Plan. The
 
Committee is
 
involved
 
in the
 
approval
 
of action
 
plans, project
 
monitoring, and
 
reviewing
Sustainability-related
 
policies
 
and
 
frameworks.
 
Policies
 
affecting
 
internal
 
stakeholders
 
are
 
available
 
to
 
the
 
Eurobank’s
intranet, while those referring to external
 
stakeholders, such as the Group's
 
Code of Conduct
 
and Ethics, are
 
available through
corporate site.
 
Overall
 
the Group
 
ensures there
 
is a high level
 
of accountability in Policy
 
development
 
and implementation.
Policies are approved by the appropriate Governance bodies such as the Board of
 
Directors or specialized
 
committees, which
ensure that there
 
is alignment with the Group's
 
strategic goals and stakeholder
 
interests.
Additionally,
 
sustainability
 
risks
 
are
 
assessed
 
regularly,
 
ensuring
 
that
 
sustainability
 
factors
 
are
 
embedded
 
in
 
the
 
Group’s
strategic decisions, including sustainability targets,
 
major investments, and the
 
overall
 
risk management framework.
 
The Board Risk Committee plays a crucial role
 
in ensuring that the Group Risk Strategy
 
and Risk Appetite Framework inform
the business
 
plan and decision
 
-making, thus aligning
 
risk management
 
processes
 
with the
 
Group's broader
 
objectives and
actions. The
 
Committee considers
 
trade-offs
 
associated with
 
material sustainability
 
matters, for
 
example by
 
incorporating
sustainability-related
 
risks
 
and
 
opportunities
 
within
 
the
 
existing
 
risk
 
management
 
frameworks.
 
This
 
ensures
 
that
sustainability considerations
 
are evaluated alongside financial and operational
 
risks.
During the
 
reporting period,
 
the
 
Board
 
of Directors,
 
Board Committees,
 
Management Committees
 
and functions,
 
through
the
 
SMC, addressed
 
several
 
material
 
impacts, risks,
 
and opportunities.
 
Through
 
the
 
Double Materiality
 
Assessment
 
(DMA)
exercise, the SMC reviewed the Impacts, Risks, and Opportunities (IROs) that were identified as
 
material for the Group. These
IROs were assessed based on both
 
impact and financial materiality to ensure comprehensive
 
consideration.
 
For a detailed list of the Impacts, Risks,
 
and Opportunities (IROs) approved by the SMC, please refer to the respective section
of the Sustainability Statement, which outlines these
 
material issues in further
 
detail.
For
 
more information
 
regarding the
 
due diligence
 
process please
 
refer
 
to: 1.5.1
 
Description of
 
the processes
 
to identify and
assess material impacts, risks and opportunities [IRO-1]
1.3.3
Integration of sustainability-related
 
performance in incentive
 
schemes [GOV-3]
The
 
Group
 
has
 
established
 
a
 
Remuneration
 
Policy
 
that
 
is
 
applicable
 
to
 
all
 
Group
 
employees
 
and
 
covers
 
their
 
total
remuneration.
 
The
 
Remuneration
 
Policy
 
forms
 
an integral
 
part of
 
the
 
corporate
 
governance
 
practice
 
and is
 
developed
 
in
accordance
 
with
 
its
 
operational
 
model,
 
business
 
strategy,
 
objectives,
 
long-term
 
interests
 
of
 
the
 
Group
 
and
 
incorporates
measures to avoid conflict of interest.
 
The Remuneration
 
Policy promotes sound and effective risk management and is consistent with the objectives of the Group’s
business and risk strategy, corporate
 
culture, values and risk culture. It also considers sustainability risk factors, as well as the
long-term interests
 
of the
 
Group. Additionally,
 
it includes measures
 
to avoid conflicts
 
of interest
 
and should not
 
encourage
excessive
 
risk-taking on
 
behalf of the
 
Group. The
 
Group ensures
 
that remuneration
 
practices
 
are aligned
 
with their
 
overall
risk appetite, taking
 
into account all
 
risks, including sustainability
 
risks, reputational
 
risks, as well
 
as risks resulting
 
from the
mis-selling of products or services.
 
In addition, the
 
Remuneration
 
Policy has
 
been enhanced with
 
the establishment
 
of Variable
 
Remuneration
 
Framework,
 
Key
Performance
 
Indicators
 
(to balance
 
employees’
 
performance
 
and encourage
 
proper
 
conduct) and
 
Key
 
Risk Indicators
 
(to
promote sound and effective
 
risk management including sustainability risks) at Group/ Unit/ Individual level, as appropriate.
The
 
Variable
 
Remuneration
 
Framework
 
aims
 
at
 
providing
 
(i)
 
an
 
appropriate
 
balance
 
of
 
variable
 
remuneration
 
elements,
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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aligning the
 
interests
 
of employees,
 
shareholders
 
and other
 
stakeholders,
 
strengthening
 
the
 
Group’s
 
position as
 
a leading
European
 
bank and
 
(ii) effective
 
remuneration
 
practices
 
in compliance
 
with the
 
applicable regulatory
 
environment.
 
In this
context, Key Risk
 
Indicators are
 
set at Group
 
level, whereas
 
Eurobank underscores
 
the significance
 
of introducing more
 
Key
Risk Indicators linked to sustainability risks in the
 
following years.
More specifically,
 
the Remuneration
 
Policy has been
 
designed to (a) be consistent with
 
and to promote
 
sound and effective
risk management,
 
(b) stimulate
 
behaviours consistent with
 
sustainability risks approach,
 
as well
 
as (c) comply
 
with Group’s
voluntary
 
commitments.
 
Its
 
basic
 
principles
 
are
 
to
 
(a)
 
be
 
gender
 
neutral
 
and
 
non-discriminatory
 
in
 
any
 
aspect
 
of
 
its
implementation,
 
(b)
 
safeguard
 
that
 
remuneration
 
is
 
sufficient
 
to
 
retain
 
and
 
attract
 
executives
 
with
 
appropriate
 
skill
 
and
experience, (c) monitor that internal equity between all Units is applied, (d) avoid excessive
 
risk-taking with respect to direct
or indirect sustainability risks and (e) link remuneration
 
with long-term performance.
The
 
Group’s
 
sustainability-linked
 
remuneration
 
integrates
 
the
 
achievement
 
of
 
components
 
/
 
targets
 
of
 
the
 
Group’s
Sustainability Strategy, Operational
 
and Financed impact, to incentivise management and
 
employees to contribute towards
their achievement.
The
 
Remuneration
 
Committee
 
approves
 
any
 
incentive
 
scheme
 
both
 
at
 
Bank
 
and
 
Group
 
level,
 
while
 
the
 
Non-Executive
Members
 
of
 
the
 
BoD
 
approve
 
and
 
periodically
 
review
 
the
 
Remuneration
 
Policy
 
and
 
are
 
responsible
 
for
 
overseeing
 
its
implementation.
For the time being, the remuneration
 
of members of the administrative, management and supervisory bodies is not assessed
against GHG emission reduction targets, and thus
 
no percentage of this year’s
 
remuneration
 
is linked with the
 
achievement
of sustainability targets.
1.3.4
Description of the due diligence on sustainability
 
matters [GOV-4]
The
 
following
 
table shows
 
how and
 
where
 
the application
 
of the
 
main aspects
 
and steps
 
of the
 
due diligence
 
process
 
are
reflected in Eurobank Holding’s
 
Sustainability Statement:
Core elements of due diligence
Paragraphs
 
in the Sustainability
Statement
Description
a) Embedding due diligence in
governance, strategy
 
and business
model
2.5.1 Sustainable financing and investment
offerings
 
2.4.3 Policies related to the
 
integration of
sustainability in risk management [MDR-P]
2.2.1 Integration
 
of sustainability-related
performance in incentive
 
schemes [ESRS 2
GOV-3]
The Group
 
integrates sustainability into
its governance and strategy
 
through
frameworks
 
like the Climate Risk
Scorecard and Sustainable Finance
Framework,
 
ensuring these principles
guide decision-making.
b) Engaging with affected
stakeholders in all key
 
steps of the
due diligence
1.4.3 Stakeholder interest
 
and engagement
[SBM-2]
1.4.4 Material impacts, risks and
opportunities and their interaction
 
with
strategy and business model [SBM-3]
2.4.3 Policies related to the
 
integration of
sustainability in risk management [MDR-P]
The Group
 
engages stakeholders to
align business practices with
expectations, informing its materiality
assessment and relative policies.
c) Identifying and assessing adverse
impacts
2.4.3 Policies related to the
 
integration of
sustainability in risk management [MDR-P]
2.5.1 Sustainable financing and investment
offerings
The Group
 
conducted a DMA to
identify and assess adverse impacts,
focusing on both potential
 
and actual
effects on people and the
 
environment.
In addition, Eurobank uses the
 
RIMA
process and ESG Risk Assessment to
evaluate risks, applying enhanced due
diligence for high-risk clients.
d) Taking actions
 
to address those
adverse impacts
2.5.1 Sustainable financing and investment
offerings
 
The Group
 
implements action plans for
workforce
 
impacts and supports
financial inclusion through various
initiatives.
e) Tracking the
 
effectiveness
 
of
these efforts
 
and communicating
2.4.1. Integration
 
of Sustainability in risk
management
2.5.1 Sustainable financing and investment
offerings
 
The Group
 
ensures transparency
through risk management and internal
controls
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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1.3.5
Risk management and internal controls
 
over sustainability reporting [GOV
 
-5]
The
 
Group’s
 
risk
 
management
 
and
 
internal
 
control
 
system
 
concerning
 
Sustainability
 
Statement
 
reporting
 
covers
 
the
accuracy, completeness, and integrity of the data related
 
to Sustainability Statement reporting. It includes dry run exercises,
quality checks, workshops
 
with relevant
 
stakeholders,
 
and assumptions made when
 
direct data could
 
not be obtained
 
from
value chain
 
stakeholders
 
to ensure
 
the
 
accuracy and
 
integrity of
 
the
 
data. To
 
further
 
enhance this
 
process,
 
the
 
Group has
developed
 
a
 
comprehensive
 
Sustainability
 
Statement
 
reporting
 
process,
 
aligning
 
with
 
the
 
Corporate
 
Sustainability
Reporting Directive (CSRD)
 
requirements effective
 
from fiscal
 
year 2024. This
 
document establishes
 
a unified framework
 
for
data collection, quality assurance,
 
and reporting across all subsidiaries, ensuring
 
transparency and compliance.
In addition, the
 
relevant departments responsible for providing qualitative information are responsible for supplying
 
accurate
qualitative
 
information,
 
by
 
examining
 
the
 
provided
 
data
 
to
 
ensure
 
consistency
 
and
 
completeness.
 
The
 
reporting
 
process
outlines
 
clear
 
roles
 
and
 
responsibilities
 
for
 
data
 
and
 
content
 
owners
 
and
 
reviewers.
 
This
 
process
 
aims
 
to
 
reinforce
accountability
 
within
 
the
 
Group
 
and
 
foster
 
a
 
culture
 
of
 
continuous
 
improvement,
 
thereby
 
upholding
 
Group’s
 
enduring
commitment to environmental,
 
social, and governance (ESG) excellence.
Eurobank
 
adopted a risk
 
assessment approach
 
that incorporates
 
regular evaluations
 
of data completeness,
 
accuracy,
 
and
integrity.
 
To
 
prioritise
 
risks,
 
we
 
utilise
 
a
 
risk-based
 
approach,
 
considering
 
the
 
potential
 
impact
 
on
 
the
 
Sustainability
Statement
 
reporting
 
process.
 
The
 
CSRD
 
Operating
 
Committee
 
oversees
 
this
 
process,
 
ensuring
 
alignment
 
with
 
CSRD
standards and supporting continuous improvement.
The
 
main risks
 
identified
 
within
 
the
 
risk assessment
 
performed
 
are
 
data gaps
 
from
 
value
 
chain stakeholders,
 
accuracy
 
of
estimations,
 
and
 
timing
 
of
 
data
 
availability.
 
To
 
mitigate
 
these,
 
Eurobank
 
conducted
 
dry
 
run
 
exercises,
 
quality
 
checks,
workshops with
 
stakeholders,
 
and made necessary
 
assumptions to fill
 
data gaps. Eurobank
 
also conducted regular
 
reviews
to
 
ensure
 
the
 
coordination
 
of
 
data
 
collection,
 
consolidation,
 
and
 
verification
 
to
 
maintain
 
high
 
standards
 
of
 
quality
 
and
compliance.
The
 
outcomes
 
of the
 
risk assessment
 
and internal
 
controls
 
throughout
 
the
 
Sustainability Statement
 
reporting process
 
are
integrated into relevant internal functions
 
and procedures with regular
 
updates provided to the
 
Group Senior Sustainability
Officer and, if necessary,
 
to relevant Committees.
1.4
Strategy - Company,
 
business model and stakeholder engagement
1.4.1
Information on the
 
market position and strategy
 
of the company [SBM-1]
The
 
Group
 
offers
 
a
 
broad
 
range
 
of
 
financial
 
products
 
and
 
services,
 
including
 
corporate
 
and
 
investment
 
banking,
 
retail
banking
 
(personal
 
banking,
 
business
 
and
 
individual
 
banking),
 
wealth
 
management,
 
leasing,
 
factoring,
 
and
 
specialized
solutions such as shipping finance and syndicated debt solutions. In the reporting period, the Group has expanded its digital
transformation
 
efforts,
 
offering
 
services
 
like
 
digital
 
banking
 
solutions.
 
Moreover,
 
the
 
Group
 
has
 
increased
 
its
 
focus
 
on
financing
 
green
 
projects
 
and
 
promoting
 
ESG
 
(Environmental,
 
Social,
 
and
 
Governance)
 
criteria
 
in
 
its
 
products,
 
such
 
as
sustainability-linked loans, bridge financing programs for
 
energy efficiency projects,
 
financing for renewable energy
 
projects
and
 
other
 
activities
 
with
 
positive
 
environmental
 
and
 
social
 
impact.
 
Eurobank
 
serves
 
a
 
wide
 
range
 
of
 
customer
 
groups,
including
 
large
 
corporate
 
clients,
 
institutional
 
investors,
 
personal
 
banking
 
clients,
 
SMEs,
 
and
 
public-sector
 
entities.
Geographically,
 
the Group
 
is primarily active in Greece,
 
Cyprus, Bulgaria and Luxembourg. Furthermore,
 
it has made strides
in expanding its green financing services to support the
 
transition toward
 
sustainable business practices.
 
Eurobank’s sustainability-related
 
goals include financing the
 
transition to sustainable
 
energy,
 
enhancing the environmental
impact of
 
its clients,
 
and investing in
 
technologies that reduce carbon footprints. These goals will
 
be further enhanced through
the Group’s
 
Net Zero
 
Commitment to
 
the
 
Net Zero
 
Banking Alliance
 
(NZBA). In
 
addition, these
 
goals are
 
embedded in the
Group’s
 
core
 
strategy,
 
and
 
a
 
significant
 
portion
 
of
 
its
 
portfolio
 
focuses
 
on
 
renewable
 
energy
 
projects,
 
energy-efficient
technologies, and sustainability-linked financing. Eurobank’s commitment to sustainable finance also
 
includes driving growth
in digital services, which help reduce environmental impacts and promote green practices, aligning with the Group’s
 
broader
sustainability objectives.
Geographical area:
Headcount:
Bulgaria
3,859
Cyprus
2,768
Greece
6,058
Luxemburg
130
Sustainability Strategy
Eurobank
 
supports the
 
transition
 
towards
 
a sustainable
 
economy
 
and considers
 
sustainability and
 
climate
 
change as
 
an
opportunity.
 
A
 
key
 
strategic
 
objective
 
is
 
to
 
adapt
 
the
 
business
 
and
 
operation
 
in
 
a
 
way
 
that
 
addresses
 
climate
 
change
challenges,
 
accommodates
 
social
 
needs
 
within
 
its
 
business
 
model
 
and
 
safeguards
 
prudent
 
governance
 
for
 
itself
 
and
 
its
counterparties,
 
in accordance
 
with supervisory
 
initiatives,
 
and following
 
international
 
standards and
 
best practice.
 
To
 
this
end,
 
Eurobank
 
has
 
designed,
 
approved
 
and
 
is
 
currently
 
implementing
 
its
 
Sustainability
 
Strategy,
 
including
 
targets
 
and
 
 
doc1p101i0
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commitments, along two key pillars:
Operational Impact Strategy
 
(OIS)
 
and
Financed Impact Strategy (FIS)
, both of which
aim to address sustainability matters within the
 
context of the Group’s
 
business model and operations.
1.
Operational Impact Strategy
 
(OIS):
The
Operational Impact Strategy
 
(OIS) focuses on minimising
 
the operational environmental
 
footprint, ensuring that its own
activities are sustainable, and aligning its operations with climate and sustainability goals. The
 
key elements of this strategy
are:
Environmental
 
Impact
:
 
Minimising
 
negative
 
impact
 
of
 
Eurobank's
 
operations,
 
to
 
promote
 
environmental
stewardship with a clear goal of achieving climate neutrality.
 
Societal Impact
: Providing
 
a diverse
 
and inclusive
 
environment
 
for
 
Eurobank’s
 
people and
 
clients, while
 
fostering
sustainable development and prosperity
 
for the benefit of
 
society.
 
Governance & Business Impact
: Focusing on building sustainability awareness, internally and across its value
 
chain,
while intensifying Eurobank's efforts
 
for ethics and transparency.
The OIS is supported by a governance
 
structure of multiple project streams (one per
 
each commitment) and the supervisory
ESG/OIS Committee.
 
Progress
 
is regularly
 
reviewed
 
at the
 
Sustainability Management
 
Committee. Each
 
project
 
stream is
planned with
 
milestones, KPIs,
 
annual targets
 
and long-term
 
interim targets,
 
serving the
 
declared commitments,
 
spanning
over the
 
next decade. Links are established with Transformation
 
streams as well as corresponding ISO Management
 
System
standards, to
 
ensure substantiation
 
and certification
 
of activities,
 
validate target
 
setting and
 
measured
 
performance,
 
and
systematically monitor progress
 
through internal reviews
 
and external assurance.
2.
Financed Impact Strategy:
The
Financed Impact Strategy
 
focuses on foster
 
favorable economic,
 
social and environmental outcomes across
 
all aspects
of its
 
financing activities,
 
with
 
a commitment
 
to sustainability
 
and responsible
 
stewardship.
 
To
 
achieve
 
this objective,
 
the
Financed Impact Strategy is structured
 
around the following
 
4 strategic pillars:
Client
 
Engagement
 
and
 
Awareness
:
 
Helping
 
clients
 
transition
 
to
 
more
 
sustainable
 
business
 
models
 
by
 
raising
awareness of climate change challenges and opportunities.
Supporting
 
Clients
 
in
 
Transition
:
 
Facilitating
 
the
 
transition
 
of
 
clients
 
towards
 
sustainable
 
practices
 
by
 
offering
financing
 
solutions,
 
that
 
are
 
guided
 
by
 
the
 
financing
 
approaches
 
and
 
the
 
eligible
 
activities
 
of
 
the
 
Sustainable
Finance Framework.
 
goals and ambitions.
Enablers and Tools
 
for Sustainable
 
Financing
: Providing
 
frameworks,
 
tools, and
 
products to
 
underpin sustainable
financing
 
Assessment and Management of sustainability-Related Risks
: Identifying and managing the sustainability-related
risks within its loan and investment portfolios,
 
including assessing exposure to transition and physical risks linked to
climate change.
The Financed Impact Strategy
 
supports Eurobank's commitment to
sustainable financing
 
and ensuring that the Group’s
financial activities align with sustainability goals, such as reducing the
 
carbon footprint of financed
 
projects.
Main Challenges Ahead:
Both strategies face
 
several
 
challenges:
Operational Transition
: The
 
need of transition
 
to climate neutrality
 
in Eurobank’s
 
own operations
 
while managing
the associated
 
costs and risks.
 
This involves
 
transforming
 
internal processes
 
and aligning with
 
evolving
 
applicable
regulatory requirements
 
and voluntary initiatives as well
 
as adopted standards and guidelines enabling Eurobank’s
contemporary and continuously updated approach
 
towards Sustainability, in line
 
with international best practice.
Client
 
Transition
:
 
Assisting
 
clients
 
in
 
adapting
 
their
 
business
 
models
 
to
 
meet
 
sustainability
 
and
 
climate
 
change
objectives. This may involve addressing different levels of maturity, overcoming resistance to change, and
 
navigating
and aligning to complex regulatory requirements.
 
 
 
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Sustainability-related
 
Risks
:
 
Managing both
transition
 
risks
 
(e.g., changes
 
in market
 
and regulatory
 
conditions)
and
physical risks
 
(e.g., climate change
 
impacts such as
 
extreme weather)
 
that could
 
affect both
 
the Group’s
 
own
operations
 
and
 
the
 
sectors
 
in
 
which
 
it
 
invests
 
or
 
lends
 
to
 
is
 
dependent
 
on
 
data
 
availability
 
and
 
commitment
 
of
involved counterparties
 
and stakeholders
Alignment
 
with
 
Global
 
Standards
: Ensuring
 
full
 
compliance
 
with global
 
sustainability
 
standards,
 
climate-related
financial
 
disclosures
 
(such
 
as
TCFD
),
 
and
 
managing
 
the
 
increasing
 
demand
 
for
 
transparency
 
in
 
sustainability
reporting.
To overcome
 
these challenges, Eurobank
 
has implemented a series of strategic
 
initiatives:
Operational Impact Strategy
 
(OIS) key components
:
o
Operational efficiency
: Focus on energy efficiency,
 
reducing carbon emissions, towards the commitment to
achieve Net Zero in its
 
operations for Scope 1 & 2
 
by 2033 and
 
Scope 3 by
 
2050. Promotion of environmental
stewardship
 
by
 
accelerating
 
also
 
transition
 
towards
 
a
 
paperless
 
banking
 
network
 
and
 
preservation
 
of
natural resources,
 
as well as extending
 
circular economy practices.
 
Accommodation of social
 
needs within
its business
 
model and
 
safeguarding
 
prudent governance
 
for
 
itself and
 
its counterparties,
 
in accordance
with supervisory initiatives, and following
 
international standards and best practice.
o
The
 
OIS
 
is
 
supported
 
by
 
a
 
governance
 
structure
 
of
 
project
 
streams
 
per
 
each
 
commitment
 
and
 
the
supervisory ESG/OIS Committee. Regular review
 
of progress via milestones
 
and KPIs to ensure annual and
long-term sustainability
 
goals related
 
to Environmental,
 
Societal, and
 
Governance
 
& Business
 
Impact are
met. Progress is regularly
 
reviewed at the
 
Sustainability Management Committee.
Financed Impact Strategy (FIS) key
 
components
:
o
Sustainable Financing:
 
Development
 
of strategies
 
that
 
will
 
promote
 
the
 
green
 
transition
 
of the
 
Group’s
clients through sustainable financing.
o
Portfolio
 
alignment:
Gradual alignment of the Group’s portfolio
 
with sectoral transition pathways that are
aligned with the 1.5°C climate transition
 
scenario.
o
Net zero strategy:
 
Sectoral decarbonisation
 
targets covering
 
the Group’s
 
lending portfolios,
 
with phased
target-setting up to 2050.
In line with its commitment to address climate
 
change, the Group has joined
 
the Net-Zero
 
Banking Alliance (NZBA), a bank-
led, UN-convened
 
alliance of
 
banks worldwide,
 
reinforcing
 
its dedication
 
to aligning
 
its lending
 
and investment
 
portfolios
with net-zero
 
emissions by 2050 or sooner,
 
in line with the most ambitious targets set by
 
the Paris Climate Agreement.
The
 
Group has
 
started developing
 
sectoral,
 
financed emissions
 
reduction
 
targets based
 
on the
 
NZBA framework,
 
for some
of
 
the
 
most
 
carbon-intensive
 
and,
 
therefore,
 
most
 
relevant
 
and
 
impactful
 
sectors
 
and
 
portfolios.
 
The
 
Group
 
applies
established industry standards (e.g. NZBA, PCAF) and accredited science-based decarbonisation scenarios, in line with a 1.5-
degree Celsius objective by
 
2050.
1.4.2
Description of business model and value chain [42a-42c]
Upstream value chain
In
 
mapping
 
the
 
upstream
 
value
 
chain,
 
Eurobank
 
has
 
identified
 
the
 
key
 
activities
 
and
 
actors
 
involved
 
in
 
supporting
 
its
operations.
 
The
 
upstream
 
value
 
chain includes
 
suppliers
 
and stakeholders
 
that
 
provide
 
critical
 
inputs—both
 
non-financial
(e.g.
 
supply
 
of
 
goods
 
and
 
services)
 
and
 
financial—necessary
 
for
 
Eurobank’s
 
operations
 
to
 
function
 
effectively.
 
Given
 
the
complexity of
 
Eurobank’s
 
operations,
 
Eurobank
 
focuses
 
on direct
 
(Tier
 
1) suppliers
 
for
 
the
 
upstream side
 
of its
 
value chain.
These suppliers are identified as
 
having the most direct impact
 
on the Eurobank’s operations, providing capital, critical goods
and
 
services
 
such
 
as
 
IT,
 
real
 
estate
 
management,
 
energy,
 
and
 
shaping
 
the
 
surrounding
 
legal,
 
regulatory
 
and
 
voluntary
framework.
 
 
 
 
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Key Activities and Actors in the
 
upstream Value Chain:
Supply of Goods
 
and Services
- The
 
upstream value
 
chain for
 
Eurobank
 
consists of a
 
range of
 
suppliers providing
critical
 
goods
 
and
 
services.
 
These
 
include
 
suppliers
 
of
 
IT
 
hardware
 
and
 
software,
 
office
 
equipment,
 
paper,
 
and
consulting services.
Supply of Capital
- Eurobank
 
is also reliant
 
on upstream
 
capital providers
 
to maintain financial
 
liquidity and fund
its operations. This involves key activities such as deposit gathering, bond issuance, capital market transactions, and
other investor
 
-related activities.
Regulatory
 
and
 
Voluntary
 
Frameworks
-The
 
development
 
of
 
regulatory
 
and
 
voluntary
 
frameworks
 
is
 
a
 
critical
component of
 
Eurobank’s
 
upstream value
 
chain. Regulatory
 
bodies such
 
as the
 
European
 
Central
 
Bank (ECB),
 
the
European Banking Authority (EBA) and the Single
 
Resolution Board (SRB) provide
 
the regulatory frameworks
 
within
which Eurobank operates.
Downstream value chain
Eurobank
 
in
 
entities
 
downstream
 
from
 
the
 
reporting
 
organisation,
 
has
 
included
 
categories
 
such
 
as
 
customers,
 
receive
 
or
utilise the Eurobank’s products and services. Eurobank has established the boundary of its downstream value chain
 
to include
corporate and retail clients, but it does not extend to the
 
clients of those clients.
 
Key Activities and Actors in the
 
downstream Value
 
Chain:
Provision of Financing to Clients
 
-
Eurobank provides
 
loans to both corporate
 
and retail clients, funding a range of
business
 
activities.
 
This
 
includes
 
supporting
 
operational
 
needs
 
and
 
facilitating
 
growth
 
for
 
small
 
and
 
large
corporations while offering
 
financial solutions for
 
individual customers.
Capital Markets Activities
-
Eurobank provides
 
services related to investment
 
banking, instruments trading, mutual
fund
 
products,
 
institutional
 
asset
 
management,
 
private
 
banking
 
and
 
other
 
financial
 
advisory
 
services.
 
Eurobank
participates
 
in
 
market-making
 
and
 
advisory
 
roles
 
for
 
corporations,
 
financial
 
institutions,
 
and
 
governments,
promoting sustainable investments.
 
Real Estate
-
In addition to financing, Eurobank engages in construction, real estate properties operation
 
(including
those properties held
 
for the purpose of leasing) and other
 
real estate services.
 
Eurobank's Position
 
in the Value
 
Chain:
 
Eurobank is positioned as a central player in the financial services value chain, connecting a
 
diverse set of upstream suppliers
with downstream
 
customers.
 
Specifically,
 
key
 
activities in
 
its own
 
operations
 
include
 
Banking activities,
 
Global
 
Markets
 
&
Asset Management,
 
Investment
 
Property
 
& Real
 
Estate Management.
 
Its role
 
spans from
 
sourcing capital
 
and operational
inputs to providing
 
key financial
 
services and
 
products to both
 
corporate
 
and retail clients.
 
By fostering
 
sustainability in its
operations,
 
especially in sustainable
 
financing, Eurobank
 
is positioning
 
itself as a
 
leader in
 
promoting sustainable
 
business
practices within the
 
banking sector.
 
 
 
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1.4.3
Stakeholder interest and engagement
 
[SBM-2]
The Group
 
has developed a robust
Stakeholder Engagement Plan
 
as a core part of its materiality assessment. This
 
process
aligns
 
with
European
 
Sustainability
 
Reporting
 
Standards
 
(ESRS)
,
 
which
 
emphasise
 
the
 
importance
 
of
 
gathering
 
diverse
stakeholder
 
perspectives
 
to identify
 
impacts, risks,
 
and opportunities
 
(IROs) and
 
align business
 
practices
 
with stakeholder
expectations and sustainability objectives.
For
 
the
 
identification
 
and
 
mapping
 
of
 
its
 
stakeholders,
 
the
 
Group,
 
established
 
a
 
systematic
 
and
 
dynamic
 
process
 
in
 
the
context of the double materiality assessment
 
which involved the
 
following:
Stakeholder Engagement Disclosure
1.
Key Stakeholders
Eurobank has
 
identified and classified stakeholders
 
into three main
 
groups to ensure
 
effective
 
engagement across
various perspectives:
o
Primary/Affected Stakeholders
: Directly impacted by Eurobank’s
 
operations.
o
Secondary Stakeholders
: Indirectly affected
 
but influential in shaping Eurobank’s policies and operations.
o
ESG Experts
: Internal
 
and external
 
ESG experts
 
who own
 
the due
 
diligence and
 
stakeholder
 
engagement
process for
 
materiality assessment.
Key stakeholder
 
groups include:
o
Internal Stakeholders
: Board of Directors, Senior Management,
 
and Employees.
o
External Stakeholders
: Customers
 
and Clients, Business
 
Community, Civil
 
Society, Suppliers
 
and Partners,
Investors and Shareholders,
 
as well as Government
 
and Regulators.
2.
Engagement with Stakeholders
Eurobank engages with both
internal and external stakeholders
 
as part of its comprehensive impact and financial
materiality
 
assessments.
 
For
 
impact
 
materiality,
 
stakeholders
 
from
 
the
 
Group
 
are
 
engaged
 
to
 
understand
 
the
sustainability impacts across various entities and geographic
 
locations.
3.
Organisation of Stakeholder
 
Engagement
Engagement
 
is
 
organised
 
systematically
 
through
 
a
 
variety
 
of
 
methods
 
and
 
classified
 
into
Internal
 
and
External
Stakeholder Groups
:
o
Identification
 
and Classification
: Stakeholders
 
are identified
 
and categorized
 
based on
 
ESRS guidelines,
which include both “affected
 
stakeholders” and “users
 
of the Sustainability Statement.”
o
Engagement Methods
: Eurobank
 
employs electronic
 
questionnaires and
 
focus groups
 
to gather
 
feedback
from stakeholders. For impact materiality, online questionnaires are the primary
 
engagement method, while
focus groups are
 
used for financial materiality to assess sustainability-related
 
risks and opportunities.
o
Segmentation
 
by
 
Business
 
Areas
:
 
Engagement
 
activities
 
span
 
across
 
Eurobank’s
 
business
 
segments
 
to
ensure the inclusion of diverse
 
perspectives from each operational
 
area.
4.
Purpose of Engagement
The purpose of Eurobank’s stakeholder engagement is to establish open communication channels with stakeholders
to understand their needs and concerns
 
and integrate them into the
 
Group’s Sustainability Strategy.
Key priorities
 
for Eurobank’s
 
engagement include:
o
protection of their
 
personal data,
 
o
leveraging
 
new technologies to enhance service,
 
o
ensuring access to financial services,
 
o
respect for human rights and the
 
environment, and
 
o
upholding corporate culture
 
and governance values along
 
with adequate risk management practices.
5.
Consideration of Engagement
 
Outcomes
Eurobank integrates the feedback from stakeholders
 
into its decision-making processes to ensure that the identified
impacts,
 
risks,
 
and
 
opportunities
 
are
 
accurately
 
reflected
 
in
 
Group’s
 
Sustainability
 
Strategy.
 
Key
 
outcomes
 
are
validated
 
by
 
the
 
Sustainability
 
Management
 
Committee
 
to ensure
 
alignment
 
with
 
ESRS standards
 
and effective
incorporation into Eurobank’s
 
risk management and sustainability frameworks.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Furthermore,
 
Eurobank
 
promotes
 
two-way
 
communication
 
and
 
develops
 
ongoing
 
dialogue
 
with
 
internal
 
and
 
external
stakeholders,
 
to
 
be
 
able
 
to
 
actively
 
meet
 
the
 
expectations,
 
concerns
 
and
 
issues
 
raised
 
by
 
all
 
its
 
stakeholders.
 
Further
information and the
 
means of communication are
 
presented in the table below:
Stakeholder group
Cooperation framework
 
and
expectations
Means of communication
 
Board of Directors
BoD member assigned as
responsible for climate-related
and environmental risks at
Group level.
Communication
 
with the
 
Board of
 
Directors is
 
facilitaded through
 
regular
and
 
ad-hoc
 
meetings
 
as
 
well
 
as
 
Progress
 
reports.
 
Regular
 
and
 
ad-hoc
meetings
 
ensure
 
structured
 
updates,
 
while
 
addressing
 
urgent
 
matters.
Progress
 
reports
 
are
 
consistently
 
shared
 
to
 
provide
 
ongoing
 
insights
ensuring the BoD is well-informed at
 
all times.
Executive
Management
CEO-appointed Sustainability
Management Committee.
Sustainability-related issues
raised at ExBo level.
Communication with Executive management is maintained through regular
and ad-hoc meetings, along with periodic progress reports.
Investors,
Shareholders and
Investment
Community
Timely reporting of accurate
and complete information on
the Group’s performance
 
and
strategy.
The
 
Group
 
engages
 
in
 
ongoing
 
communication
 
with
 
its
 
investors
 
to
enhance
 
their
 
understanding
 
of
 
matters
 
that
 
may
 
be
 
relevant
 
to
 
them,
thereby
 
enabling them to
 
effectively exercise
 
their voting
 
rights and make
informed
 
investment
 
decisions.The
 
Group
 
organises
 
Annual
 
General
Meetings
 
and
 
Extraordinary
 
General
 
Meetings
 
οf
 
Shareholders
 
and
publishes information
 
in a continuous, regular and
 
timely manner (through
the Annual Reports, Financial Results and announcements on its corporate
websites) ensuring that stakeholders have easy access to essential
 
updates
and disclosures.
Employees
Timely information
 
on issues
concerning the Group, the
development and progress of
skills, as well as employee
engagement and benefits.
The
 
Group places
 
a strong
 
emphasis on
 
the
 
upskilling and
 
reskilling of
 
its
employees,
 
upholding
 
a
 
high
 
standard
 
of
 
professionalism
 
while
implementing
 
anti-discrimination
 
policies
 
to
 
create
 
an
 
inclusive
 
work
environment.
 
The
 
Group
 
provides
 
extensive
 
benefits
 
to
 
all
 
employees,
irrespective of gender,
 
age, or marital status. Frequent meetings, breakfast
gatherings,
 
and
 
various
 
events
 
promote
 
open
 
communication
 
between
management
 
and
 
staff
 
representatives.
 
Enhanced
 
communication
channels
 
like
 
HR4U
 
and
 
the
 
Connected
 
portal
 
ensure
 
responsiveness
 
to
employee
 
inquiries.
 
The
 
Group
 
promotes
 
work-life
 
balance,
 
social
 
and
environmental
 
awareness,
 
and
 
volunteering
 
and
 
implements
 
an
 
ESG
upskilling
 
plan
 
and
 
awareness
 
initiatives
 
for
 
employees
 
and
 
clients
 
to
support sustainability efforts.
Business Community
(including corporate
networks,
entrepreneurship,
industry associations,
financial institutions
and start-up
entrepreneurs)
Mutual cooperation and open
communication driven by
ensuring the interests of the
business community.
Showcasing and promoting new
businesses based on specified
criteria and transparent
procedures.
The Group
 
supports entrepreneurship, innovation, and
 
internationalization
through
 
strategic
 
initiatives
 
including
 
dialogue
 
with
 
professional
associations and collaborations.
Civil Society
(including
communities, NGOs,
the academic and
scientific community,
international
organisations, and
the Media)
Engaging 3rd parties in CSR
initiatives designed and
implemented by the Group
Responding to 3rd party actions
with a social cause
Cooperation with the
 
Media to
ensure optimum and effective
promotion of the
 
Group and
its products and services.
The
 
Group
 
engages
 
with
 
non-governmental
 
organisations,
 
to
 
maintain
transparent
 
communication
 
and
 
prompt
 
responses.
 
The
 
Group
 
also
encourages
 
organisations
 
to
 
take
 
part
 
in
 
corporate
 
social
 
responsibility
initiatives,
 
providing
 
support
 
through
 
sponsorships
 
and
 
donations.
Employee
 
volunteer
 
efforts
 
enhance community involvement.
 
Partnerships
with academic institutions promote innovation in CSR practices.
Customers and Clients
Responsible information,
customer service and provision
of products and services with a
deep sense of respect and
transparency.
The
 
Group places
 
customers at
 
the
 
centre of
 
its activities
 
and one
 
of its
purposes
 
is to
 
help
 
them
 
in the
 
transition
 
to a
 
more
 
sustainable future,
accompanying
 
them
 
on
 
their
 
journey
 
towards
 
decarbonisation,
 
offering
them
 
innovative
 
solutions
 
to
 
finance
 
their
 
investments
 
with
 
positive
environmental
 
and
 
social
 
impacts
 
and
 
managing
 
initiatives
 
that
 
better
respond to sustainability-related challenges. For
 
more information
 
on the
Bank’s communication channels with customers and clients please
 
refer to
section 3.2.2 Policies and Actions.
Government and
Regulators
Compliance and harmonisation
with the supervisory and
regulatory framework.
The
 
Group
 
supports
 
open
 
communication
 
(meetings,
consultation etc.)
 
with government
 
and regulators in
 
order to
facilitate data sharing and issue resolution.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Stakeholder group
Cooperation framework
 
and
expectations
Means of communication
 
Suppliers and Partners
Cooperation based on
transparent procedures
 
and
specified criteria to achieve
mutually beneficial
agreements.
Communication with third-
party partners, to investigate
further tailor-made business
offerings.
The
 
Group
 
provides
 
comprehensive
 
and
 
transparent
 
information
 
in
procurement
 
processes
 
to
 
its
 
suppliers,
 
ensuring
 
compliance
 
with
 
legal
requirements
 
in
 
labour
 
and
 
environmental
 
matters,
 
respecting
 
human
rights and
 
stimulating the
 
demand for
 
socially responsible
 
products and
services.
On
 
top,
 
Eurobank
 
implements
 
an
 
electronic
 
tendering
 
system
complemented by a supplier evaluation platform and procedure, ensuring
transparency and efficiency in supplier selection.
The Group’s understanding of the interests and views
 
of its
 
key stakeholders is shaped through its
 
comprehensive stakeholder
engagement and DMA processes. By engaging with a wide range of stakeholders, including customers, employees, investors,
business
 
community,
 
suppliers
 
and
 
partners,
 
regulators,
 
and
 
civil
 
society,
 
the
 
Group
 
gathers
 
crucial
 
insights
 
into
 
their
expectations
 
regarding
 
issues
 
such
 
as
 
environmental
 
sustainability,
 
governance,
 
human
 
rights,
 
and
 
access
 
to
 
financial
services.
 
These
 
insights are
 
integrated
 
into
 
the
 
Group’s
 
strategy
 
and business
 
model, ensuring
 
that
 
its
 
actions
 
align
 
with
stakeholder
 
needs. Additionally,
 
the materiality
 
assessment process
 
identifies the
 
actual and
 
potential positive,
 
as long as
negative impacts
 
of the
 
Group’s
 
activities on the
 
environment
 
and society,
 
guiding its
 
decision-making and
 
ensuring long-
term value creation for
 
all stakeholders.
Views and interests of affected
 
stakeholders
The views and interests of
 
affected stakeholders with regard to the Group’s sustainability-related impacts are communicated
to
 
the
 
Board
 
of
 
Directors,
 
Board
 
Committees,
 
Management
 
Committees
 
and
 
functions
 
through
 
a
 
structured
 
process.
Stakeholder engagement is integral to the Group’s materiality assessment, and
 
relevant insights gathered from both internal
and
 
external
 
stakeholders
 
are
 
reviewed
 
by
 
the
 
Sustainability
 
Management
 
Committee.
 
These
 
committees
 
oversee
 
the
sustainability
 
strategy
 
and
 
ensure
 
that
 
stakeholder
 
concerns
 
regarding
 
sustainability
 
impacts
 
are
 
incorporated
 
into
 
the
Group’s decision
 
-making processes.
 
The Board
 
of Directors (BoD) is
 
informed about
 
the interests
 
and views of stakeholders
through the
 
presentation of
 
the results
 
of the
 
DMA, which includes
 
an evaluation
 
of the
 
impacts identified by
 
both internal
and external stakeholders. The
 
BoD is regularly updated on the progress
 
and outcomes, ensuring that stakeholder
 
feedback
is integrated into the Group’s
 
strategy and operations.
1.4.4
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [SBM-3]
The Group
 
has conducted a comprehensive
 
materiality assessment
 
to identify its material
 
impacts, risks, and opportunities
in relation to sustainability. This process allows the Group to prioritise the sustainability
 
factors most pertinent to its
 
strategy,
business
 
model,
 
and
 
resource
 
allocation.
 
By
 
identifying
 
and
 
assessing
 
these
 
key
 
factors,
 
the
 
Group
 
ensures
 
that
 
its
sustainability initiatives are aligned with regulatory
 
standards and long-term business objectives. The
 
business model of the
Group
 
is primarily
 
focused
 
on delivering
 
financial services
 
to individual,
 
corporate,
 
and institutional
 
clients. Therefore,
 
the
material
 
impacts,
 
risks,
 
and
 
opportunities
 
identified
 
are
 
concentrated
 
in
 
the
 
provision
 
of
 
such
 
services.
 
The
 
table
 
below
outlines the outcomes
 
of the Group's impact materiality
 
assessment, presenting the identified material
 
impacts:
Sustainability matter
Description
Positive/
Negative
Type of
Impact
Location in
the value
chain
Time-
horizon
E1 Climate change -
Energy
Organisation implements measures to reduce energy
consumption, leading to enhanced efficiency in
operations.
Positive
Actual
Own
operations
Mid-term
E1 Climate change –
Energy
Organisation contributes to climate change through its
in-house operations that contribute to the
 
release of
emissions.
Negative
Actual
Own
operations
Short-term
S1 Own workforce -
Equal Treatment and
Opportunities for All
Organisation puts into action internal management
systems and initiatives that improve employees’
 
ability
to live free from gender / sexual / ethnic / racial
discrimination and ageism.
Positive
Actual
Own
operations
Short-term
S1 Own workforce -
Equal Treatment and
Opportunities for All
Organisation’s lack of established policies, measures
and actions increases the risk of discrimination incidents
within its operations, potentially impacting the
 
well-
being and morale of employees.
Negative
Potential
Own
operations
Short-term
S1 Own workforce –
Other work-related
rights
Organisation supports employees’ well-being through
providing satisfying and high-quality working
conditions, including adequate workspace and respect
of privacy.
Positive
Actual
Own
operations
Short-term
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Sustainability matter
Description
Positive/
Negative
Type of
Impact
Location in
the value
chain
Time-
horizon
G1 Business Conduct –
Corporate culture
Organisation achieves positive impacts by
implementing operational practices
 
and initiatives that
improve stakeholders’
 
ability to benefit from effective,
accountable, and inclusive institutions, thereby
promoting business ethics and integrity.
Positive
Actual
Own
operations,
Upstream,
Downstream
Short-term
G1 Business Conduct –
Corruption and
bribery
Organisation’s commitment to corporate
 
integrity is
strengthened through the
 
implementation of robust
anti-corruption and anti-bribery policies, promoting
 
a
culture of transparency and ethical behaviour.
Positive
Actual
Own
operations
Long-term
G1 Business Conduct –
Corruption and
bribery
Corruption-related incidents can result in operational
disruptions, redirecting resources towards crisis
management and adversely affecting the
Organisation’s day-to-day business activities.
Negative
Potential
Own
operations
Mid-term
G1 Business Conduct –
Protection of
whistleblowers
Organisation’s commitment to whistleblower
 
protection
positively impacts society, employees, customers,
 
and
shareholders, setting a precedent for ethical
 
behaviour
and fostering a secure environment where
 
misconduct is
timely identified and stopped.
Positive
Actual
Own
operations
Short-term
Data security and
customer privacy
Organisation implements internal management systems
and initiatives that protect stakeholders'
 
data privacy.
Positive
Actual
Own
operations,
Downstream
Mid-term
Data security and
customer privacy
Organisation’s improper
 
implementation of established
cybersecurity systems and processes results in incidents
of data breach and leaks of personal data.
Negative
Potential
Own
operations,
Downstream
Mid-term
E1 Climate change –
Climate change
adaptation
Organisation actively contributes to GHG reduction
ambitions and targets, set by the EU, regulations,
central governments,
 
and other bodies, through its
sustainable financings and integration of climate risk in
the risk management framework.
Positive
Actual
Own
operations,
Downstream
Long-term
E1 Climate change –
Climate change
adaptation
Organisation’s business strategy may encompass the
continuation of financing to carbon-intensive sectors.
Negative
Potential
Own
operations,
Downstream
Long-term
E1 Climate change –
Climate change
mitigation
Organisation implements a robust climate change
mitigation strategy aiming to minimise the
consequences of climate change for its portfolio.
Positive
Actual
Own
operations,
Downstream
Long-term
E1 Climate change –
Climate change
mitigation
Organisation’s portfolio
 
faces negative impacts due to
the absence of a climate change mitigation strategy.
Negative
Potential
Own
operations,
Downstream
Long-term
S4 Consumers and
end-users -
Information-related
Impacts for
Consumers and/or
End-users
Organisation provides to clients access to accurate,
relevant and high-quality secured information, fostering
transparency and promoting the
 
principles of
responsible banking.
Positive
Actual
Downstream
Short-term
Sustainable financing
and investment
offerings
Organisation provides sustainable finance products and
services that promote green
 
and social investments and
incentivise improvement of its clients’ ESG performance.
Positive
Actual
Downstream
Long-term
Integration of
Sustainability in risk
management
The ESG / climate risk assessment may require
additional effort by the
 
clients in order to provide
required ESG data and may result in additional
conditions to comply with for financial agreements.
Negative
Potential
Downstream
Mid-term
In the fiscal year 2024, Eurobank has not provided specific financial figures regarding the
 
current financial effects of material
risks and opportunities. The Bank has opted for
 
a phased-in approach to report these
 
anticipated financial effects,
 
aligning
with the initial reporting period
 
requirements under
 
the European Sustainability Reporting Standards
 
(ESRS).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The
 
table below
 
outlines the
 
outcomes of
 
the
 
Group's
 
financial materiality
 
assessment,
 
presenting the
 
identified risks
 
and
opportunities:
Sustainability matter
Description
Risk/
Opportunity
Location in
the value
chain
Expected time
horizons for
anticipated
financial effects
S1 Own workforce
 
-
Working conditions
Demonstrating commitment to exemplary working
condition expectations, such as offering adequate
compensation, promoting work-life balance,
 
and
ensuring workplace safety, can attract
 
and retain
employees.
Opportunity
Own
operations
Short-term
S1 Own workforce
 
-
Working conditions
Non-compliance with the modern workplace
expectations such as good working conditions, adequate
salaries, and workplace safety, can affect
 
employees'
motivation and performance,
 
leading to decreased
productivity.
Risk
Own
operations
Short-term
Fostering Innovation
Meeting evolving customer expectations and modern
lifestyle needs through utilising digital tools and
innovative services can improve
 
customer engagement.
Opportunity
Own
operations
Short-term
Fostering Innovation
Rapid technologic development in the banking sector
may pose competitive threats and risks if the
Organisation fails to adapt and innovate at the same
pace.
Risk
Own
operations
Mid-term
Data security and
customer privacy
Growing cybersecurity threats and cyber-attacks
targeting financial institutions, and their customer data
may compromise the Organisation’s
 
systems, networks
and sensitive information, leading to operational
disruptions and reputational harm.
Risk
Own
operations,
Downstream
Mid-term
E1 Climate change –
Climate change
adaptation/mitigation
Meeting climate objectives linked to legal, regulatory and
other stakeholders’
 
requirements for the Organisation’s
clients, entails the opportunity for the Organisation
 
to
finance the transition of its clientele.
Opportunity
Own
operations,
Downstream
Long-term
E1 Climate change –
Climate change
adaptation/mitigation
The actions required by the
 
Organisation’s clients to
address climate change mitigation and adaptation
requirements relating to impacts deriving from climate
change may impact the Organisation’s credit risk.
Risk
Own
operations,
Downstream
Long-term
E4
 
Biodiversity and
ecosystem - Direct impact
drivers of biodiversity loss
Biodiversity loss due to clients’ operations
 
may lead to
financial and reputational damage.
Risk
Downstream
Long-term
Sustainable financing and
investment offerings
 
Promoting green and social investments in line with
requirements to support climate transition and in
response to changing consumer preferences
 
enhances
the Organisation’s brand
 
reputation, attracting
sustainability conscious investors.
Opportunity
Own
operations,
Downstream
Long-term
Sustainable financing and
investment offerings
 
Evolving market preferences
 
and regulatory shifts may
impact the demand for sustainable finance, posing risks
to the Organisation’s existing product offerings.
Risk
Own
operations,
Downstream
Long-term
Integration of
Sustainability in risk
management
 
Integrating ESG in risk management in response to
evolving regulatory requirements
 
and business needs
improves the
 
Organisation’s resilience to sustainability-
related risks, safeguarding the Organisation
 
against
potential financial losses, strengthening its overall
 
risk
management framework.
Opportunity
Own
operations,
Downstream
Mid-term
Integration of
Sustainability in risk
management
 
Client hesitance or inability to meet sustainability
requirements may impact the Organisation’s
 
market
perception, potentially affecting
 
its competitive position
and leading to additional risks.
Risk
Own
operations,
Downstream
Mid-term
Financial inclusion
 
Contributing to financial inclusion aligns with social
impact goals, positively impacting brand reputation and
offering financing to underserved populations,
 
such as
students and geographically isolated communities.
Opportunity
Downstream
Mid-term
 
 
 
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Double materiality matrix:
1.5
Materiality analysis and results according to the
 
concept of Double Materiality
1.5.1
Description of the processes
 
to identify and assess material impacts, risks and opportunities [IRO-1]
Materiality assessment
 
is conducted
 
through
 
a comprehensive
 
process
 
that aims
 
to identify,
 
assess, prioritise
 
and monitor
both potential and
 
actual impacts on people
 
and the environment,
 
as well as risks
 
and opportunities that
 
may in turn have
a financial effect on the
 
organisation.
 
Phase 1 – Understanding of the business, value chain & related
 
activities
The first
 
step is to understand
 
Group’s
 
key business segments
 
and partners influenced
 
by and influencing those
 
operations.
Credit institutions are complex
 
entities that engage in
 
a wide range of
 
activities, varying significantly in
 
both scale and scope.
To effectively
 
evaluate these activities and include them within the context of DMA, value
 
chain boundaries were established.
Boundaries are applied to
 
the Upstream side of value
 
chain, that are limited to
 
direct Suppliers, as well as
 
to the downstream
side which includes
 
the Group’s customers. The focus areas for the materiality assessment are identified
 
and prioritised based
on the
 
potential significant
 
IROs. Business
 
activities and partners
 
are categorized
 
based on their
 
role
 
in the
 
value chain by
identifying whether they
 
operate upstream,
 
downstream, or within own operations.
 
The significant
 
activities across
 
Eurobank’s
 
value chain have
 
been systematically
 
mapped to relevant
 
ESRS Sectors as
 
part
of
 
an
 
extensive
 
value
 
chain
 
analysis.
 
This
 
mapping
 
encompassed
 
both
 
upstream
 
and
 
downstream
 
activities,
 
along
 
with
Eurobank's
 
own
 
operations,
 
while
 
carefully
 
considering
 
the
 
interconnections
 
between
 
ESRS,
 
rating
 
agencies
 
and
 
industry
specific standards. For this purpose, the
 
methodologies established by the
 
SASB Materiality Map and the MSCI ESG Industry
Materiality Map are utilised as
 
foundational tools to identify Sustainability issues. Expert judgment is
 
applied throughout this
process to ensure that the mappings are accurate and relevant. In the identification of potentially material sub-topics a peer
analysis of
 
major Greek
 
systemic banks
 
and foreign
 
banks operating
 
predominantly
 
within the
 
EU was
 
also incorporated.
The Risk
 
Identification and
 
Materiality Assessment
 
(RIMA) Framework
 
was also utilised in the
 
overall
 
process. RIMA
 
enables
Eurobank to systematically
 
build its risk inventory by identifying and evaluating both
 
current and potential risks.
 
Phase 2 – Stakeholder engagement and identification
 
of IROs
The materiality
 
assessment process,
 
in the second phase,
 
included comprehensive
 
consultation with affected
 
stakeholders
to understand how they may be impacted by the
 
organisation's activities. Stakeholders’
 
engagement is an integral part of
the
 
materiality assessment
 
process.
 
The
 
affected
 
stakeholders’
 
engagement is
 
central
 
to the
 
materiality assessment
 
and
therefore
 
it is critical to gather
 
and assess diverse stakeholder
 
perspectives to build a
 
balanced and comprehensive
 
set of
impacts, risks, and
 
opportunities (IROs).
 
Eurobank recognises
 
the importance
 
of a due
 
diligence processes
 
and thus plans
to develop such processes
 
and utilise its outcomes to inform
 
the materiality
 
assessment in the
 
future. Through
 
stakeholder
engagement, a wide range of diverse perspectives is gathered to identify and assess the full spectrum of impacts, risks, and
opportunities
 
(IROs).
 
Eurobank
 
considered
 
its stakeholder
 
groups
 
as well
 
as the
 
ESG
 
experts
 
and classified
 
them
 
in
 
the
following 3 categories:
 
i.
Primary/Affected stakeholders,
 
ii.
Secondary stakeholders,
iii.
ESG Experts
 
 
 
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The stakeholder engagement for impact materiality involved identifying and categorizing
 
stakeholders into two main
 
groups:
Internal
 
Stakeholders
 
(Board
 
of
 
Directors,
 
Senior
 
Management,
 
and
 
Employees)
 
and
 
External
 
Stakeholders
 
(Business
Community, Civil
 
Society, Customers
 
and Clients, Suppliers
 
and Partners,
 
Investors and Shareholders,
 
and Government
 
and
Regulators). To engage
 
these diverse
 
groups, electronic questionnaires
 
were circulated
 
via an online platform.
 
In the context of impact materiality ("inside-out" perspective) causal links between Eurobank’s
 
and its value chain’s practices
and their impacts on the environment
 
and society were assessed. First, the topics are contextualized to explain why they
 
are
relevant
 
to Eurobank
 
and its
 
value chain
 
from
 
an impact
 
perspective.
 
For
 
this purpose,
 
Eurobank
 
considers its
 
value chain
activities, prior
 
year
 
reporting,
 
as well
 
as other
 
sources
 
(e.g. peers,
 
indices).
 
Then,
 
for
 
those that
 
are
 
deemed
 
relevant,
 
the
impacts on society or the environment
 
are described. Finally, the
 
impacts are classified as:
 
actual or potential,
 
negative or positive impacts on people
 
or the environment,
 
over the
 
short, medium and long-term time horizon.
Impacts arising from Eurobank's operations
 
are considered negative, without factoring in the
 
potential effectiveness
 
of any
mitigation measures that
 
may be implemented.
 
Regarding financial materiality Eurobank engaged with internal stakeholders, who are representative of the whole Eurobank,
to assess
 
risks and
 
opportunities.
 
The
 
primary method
 
for
 
stakeholder
 
engagement was
 
through
 
dedicated
 
focus
 
groups,
designed
 
to
 
evaluate
 
the
 
potential
 
risks
 
and
 
opportunities
 
associated
 
with
 
sustainability.
 
Sustainability
 
risks
 
and
opportunities were
 
assessed based
 
on their
 
likelihood of
 
occurrence
 
and the
 
potential magnitude
 
of their
 
financial effects
over the
 
short, medium, and long term time horizons.
Risks and opportunities are associated with financial materiality ("outside-in"). First, the
 
topics are contextualized to explain
why
 
they
 
are
 
relevant
 
to
 
Eurobank
 
and
 
its
 
value
 
chain
 
from
 
a
 
financial
 
perspective
 
(i.e.
 
from
 
a
 
risk
 
and/or
 
opportunity
perspective).
 
For
 
this purpose,
 
the
 
identification
 
of impacts
 
was utilised
 
as a
 
starting point,
 
since the
 
financial materiality
assessment benefits from
 
the outcome
 
of the impact materiality
 
assessment. Eurobank
 
considered its value chain
 
activities,
prior year sustainability reporting
 
(e.g. Pillar 3, UNEP
 
FI), as well as other
 
sources (e.g. peers,
 
MSCI, etc.). Then,
 
for those that
are deemed
 
relevant, the
 
risks and/or
 
opportunities are
 
described in
 
the short,
 
medium, and
 
long-term time
 
horizon in line
with ESRS
 
definition. The
 
analysis is
 
risk-based and
 
hence
 
opportunities are
 
identified only
 
when there
 
is a direct
 
business
opportunity
 
linked
 
to
 
a
 
subject
 
that
 
does
 
not
 
result
 
from
 
mitigating
 
a
 
risk.
 
To
 
align
 
-to
 
the
 
extent
 
this
 
is
 
feasible-
 
this
identification process with Eurobank’s
 
existing risk management, the input of RIMA process is utilised. Moreover, the draft list
of ROs was subject to multiple iterations through discussions with
 
key internal stakeholders
 
involved in the broader
 
financial
risks and opportunities identification process
 
in Eurobank.
 
Phase 3 – Assessment of IROs
 
After
 
having identified
 
IROs, both
 
an impact
 
and a
 
financial materiality
 
assessment
 
takes
 
place
 
in the
 
third
 
phase of
 
the
process,
 
whereby
 
each of the
 
impacts, risks and
 
opportunities are
 
scored on
 
predefined scales
 
for severity,
 
magnitude and
likelihood, as appropriate.
A sustainability matter is
 
material from
 
an impact perspective
 
when it pertains to
 
the Group’s
 
material, actual or potential,
positive or
 
negative impacts
 
on people or
 
the environment
 
(environmental,
 
social and governance
 
matters) over
 
the short,
medium and long-term time horizons. It includes impacts
 
connected to Eurobank’s own operations and value chain, including
through its products and services,
 
as well as through its business relationships.
 
Impacts are assessed based on the following
criteria:
Severity
, which is composed of 3 elements:
 
o
Scale
: how grave the
 
negative impact is or how beneficial the
 
positive impact is for people or the
 
environment.
o
Scope
: how
 
widespread the
 
negative
 
or positive
 
impacts
 
are.
 
In the
 
case of
 
environmental
 
impacts, the
 
scope
may be understood as the
 
extent of environmental
 
damage or a geographical
 
perimeter.
 
In the case
 
of impacts
on people, the scope may be understood as the
 
number of people adversely affected;
 
and
o
Irremediable character
: whether and to what extent the negative impacts could be remediated, i.e., restoring the
environment or affected
 
people to their prior state.
Likelihood
 
The significance of positive impacts is assessed by stakeholders,
 
by considering the scale and scope of impacts, whereas the
severity of negative
 
impacts was assessed by considering their
 
scale, scope and irremediable
 
character.
 
For the
 
assessment
of
 
potential
 
impacts,
 
the
 
likelihood
 
factor
 
is
 
also
 
considered.
 
The
 
qualitative
 
thresholds
 
for
 
impact
 
assessment
 
were
established by applying experts’
 
judgment, in addition to
 
the application
 
of quantitative
 
thresholds. Consequently,
 
impacts
(positive and/or negative) with
 
an impact materiality score exceeding these
 
thresholds were
 
classified as material.
The financial materiality assessment
 
corresponds to the identification
 
of information that
 
is considered material for
 
primary
users
 
of
 
general-purpose
 
financial
 
reports
 
in
 
making
 
decisions
 
relating
 
to
 
providing
 
resources
 
to
 
the
 
entity.
 
Risk
 
and
Opportunities
 
are
 
assessed
 
based
 
on
 
severity
 
and
 
likelihood.
 
Similarly
 
to
 
the
 
impact
 
materiality
 
assessment,
 
Eurobank
developed
 
a scoring mechanism
 
by applying
 
thresholds
 
as cut-off
 
points. Eurobank
 
performed
 
the assessment
 
of risks and
opportunities, by
 
engaging internal
 
stakeholders
 
through
 
workshops
 
with
 
experts
 
from
 
Eurobank’s
 
key
 
business units.
 
The
outcome of stakeholder engagement
 
was a list of scored risks and opportunities.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Phase 4 – Materiality overview
 
In the
 
final step of
 
the process,
 
the Group
 
undertakes
 
a comprehensive
 
analysis of the
 
collected data,
 
prioritising impacts,
risks
 
and
 
opportunities
 
(IROs)
 
based
 
on
 
the
 
scores
 
obtained
 
through
 
structured
 
questionnaires
 
(Impact
 
Materiality
assessment)
 
and
 
targeted
 
focus
 
group
 
(Financial
 
Materiality
 
assessment).
 
Applying
 
these
 
scoring
 
mechanisms
 
allows
 
to
further separate
 
material and non-material impacts, risks and opportunities (IROs) and topics. A topic is material if it scores
‘high’ from an impact (positive, negative and/or both) and/or financial perspective (risk, opportunity and/or
 
both). Materiality
thresholds classify topics
 
as material in
 
terms of impact
 
materiality, financial materiality or in
 
case of both,
 
double materiality.
The
 
IROs assessed
 
to be
 
material
 
are then
 
grouped
 
and mapped
 
to a
 
topic/sub-topic in
 
order
 
to report
 
according to
 
the
corresponding Disclosure Requirements
 
of the relevant topic. The SMC approves
 
the proposed contents of the Sustainability
Statement that derive
 
from the results
 
of the DMA.
Strategic implication
The
 
DMA
 
strengthens
 
the
 
Group’s
 
commitment
 
to
 
responsible
 
risk
 
management,
 
fostering
 
robust
 
corporate
 
governance
practices while advancing sustainability goals. The
 
DMA process enables Eurobank
 
to effectively manage and leverage
 
risks
and opportunities
 
in a
 
way that
 
not only
 
supports its
 
financial
 
performance
 
but also
 
contributes to
 
positive
 
societal
 
and
environmental impacts.
 
Risk management is a key component of the Group's operations to achieve its strategic and business objectives. As such, the
Group has put in
 
place effective mechanisms to identify, monitor, and assess risks
 
promptly, evaluating their potential impact
on the
 
attainment
 
of corporate
 
objectives.
 
The
 
Risk Identification
 
and Materiality
 
Assessment (RIMA)
 
process
 
at Eurobank
plays a crucial role in managing
 
effectively risks preventing significant impacts on the Group's financial performance, capital,
liquidity,
 
and
 
business
 
objectives.
 
This
 
proactive
 
approach
 
helps
 
identify
 
emerging
 
risks,
 
especially
 
those
 
related
 
to
 
the
interconnected
 
nature
 
of sustainability
 
risks, which
 
are
 
integrated
 
into the
 
Group's
 
broader
 
risk management
 
framework.
Given the increasing recognition of both financial and non-financial impacts, Eurobank
 
takes a holistic approach to manage
sustainability risks, aligning these considerations
 
with other
 
risk types
 
within the organisation.
Eurobank also places a strong emphasis on managing social risks as part of its sustainable business strategy. The Group
 
has
adjusted
 
its
 
business
 
model,
 
strategy
 
and
 
processes,
 
as
 
well
 
as
 
its
 
financial
 
planning,
 
to
 
address
 
these
 
risks
 
effectively.
Additionally,
 
Eurobank
 
continuously assesses
 
its exposure
 
to governance
 
risks, recognising
 
that poor
 
governance
 
practices
by clients can
 
adversely
 
affect its
 
own operations.
 
To
 
mitigate this,
 
Eurobank
 
has implemented
 
robust internal
 
governance
arrangements and processes
 
that allow for effective
 
evaluation of governance
 
risks, both within its own operations and with
respect to its clients' governance performance.
 
This strategic focus
 
on sustainability not only helps Eurobank remain resilient
and
 
adaptable
 
in
 
a
 
fast-changing
 
business
 
environment
 
but
 
also
 
recognises
 
the
 
importance
 
of
 
identifying
 
material
opportunities as a crucial source of innovation and value
 
creation.
Eurobank
 
performed
 
its
 
DMA
 
in
 
accordance
 
with
 
the
 
European
 
Sustainability
 
Reporting
 
Standards
 
(ESRS)
 
as
 
an
 
early
adoption in 2023.
 
The corresponding
 
disclosures have
 
been included in
 
the 2023
 
Annual Report –
 
Business & Sustainability
(Sustainability Report)
 
. Eurobank
 
identified, assessed,
 
prioritised and
 
validated the
 
sustainability impacts
 
arising from
 
its
activities and assessed risks and opportunities that may have material
 
financial influence on Eurobank,
 
throughout its value
chain.
 
For
 
the
 
current
 
reporting
 
year,
 
the
 
Group
 
continues
 
to
 
adhere
 
to
 
ESRS,
 
ensuring
 
alignment
 
with
 
all
 
applicable
regulatory requirements.
 
For
 
more information
 
regarding
 
the
 
internal control
 
procedures
 
for
 
the identification
 
and assessment
 
of material
 
impacts,
risks,
 
and
 
opportunities,
 
please
 
refer
 
to:
 
1.3.2
 
Information
 
provided
 
to
 
and
 
sustainability
 
matters
 
addressed
 
by
 
the
undertaking's administrative,
 
management and supervisory bodies [GOV
 
-2].
1.5.2
 
Disclosure requirements in ESRS
 
covered by the
 
undertaking’s sustainability statement [IRO-2]
Through the DMA process,
 
Eurobank has determined that the
 
following topics are not material to Eurobank’s operations
 
and
value chain: ESRS E2 - Pollution,
 
E3 - Water
 
and Marine Resources, E5 - Resource
 
Use and Circular Economy,
 
S2 - Workers
 
in
the Value
 
Chain, and S3 -
 
Affected Communities.
 
This conclusion
 
reflects Eurobank’s
 
commitment to focusing
 
on areas with
the greatest impact and relevance
 
to its stakeholders and business.
The
 
table
 
below
 
presents
 
the
 
progress
 
made
 
on
 
implementing
 
the
 
provisions
 
of
 
the
 
European
 
Sustainability
 
Reporting
Standards:
Nr.
Description
Reference
Explanation
ESRS 2: General disclosures
BP-1
General basis for preparation
 
of the sustainability
statement
1.1 Basis for
 
Preparation
BP-2
Disclosures in relation to specific circumstances
1.2 Disclosures in relation to specific
circumstances
GOV-1
The role of the
 
administrative, management and
supervisory bodies
1.3.1 The
 
role of the administrative,
management and supervisory
bodies
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr.
Description
Reference
Explanation
GOV-2
Information provided
 
to and sustainability matters
addressed by the undertaking’s administrative,
management and supervisory bodies
1.3.2 Information provided to and
sustainability matters addressed by
the undertaking's administrative,
management and supervisory
bodies
GOV-3
Integration of sustainability-related performance
 
in
incentive schemes
1.3.3 Integration of sustainability-
related performance
 
in incentive
schemes [GOV-3]
GOV-4
Statement on due diligence
1.3.4 Description of the due diligence
on sustainability matters [GOV-4]
GOV-5
Risk management and internal controls over
sustainability reporting
1.3.5 Risk management and internal
controls over
 
sustainability
reporting [GOV-5]
SBM-1
Strategy, business model and value chain
1.4.1 Information
 
on the market
position and strategy of the
company [SBM-1]
SBM-2
Interests and views of stakeholders
1.4.3 Stakeholder interest and
engagement [SBM-2]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
1.4.4 Material impacts, risks and
opportunities and their interaction
with strategy and business model
[SBM-3]
Omission of anticipated financial
effects for the
 
first year of
preparation
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
1.5.1 Description of the
 
processes to
identify and assess material
impacts, risks and opportunities
[IRO-1]
IRO-2
Disclosure requirements in ESRS covered
 
by the
undertaking’s sustainability statement
1.5.2 Disclosure requirements in
ESRS covered by the
 
undertaking’s
sustainability statement [IRO-2]
MDR-P
Policies adopted to manage material sustainability
matters
Policies analyzed per respective
topic
MDR-A
Actions and resources in relation to material
sustainability matters
Actions analyzed per respective
topic
MDR-M
Metrics in relation to material sustainability matters
Metrics analyzed per respective
topic
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Targets analyzed per
 
respective
topic
ESRS E1: Climate change
GOV-3
Integration of sustainability-related performance
 
in
incentive schemes
Integration of sustainability-related
performance in incentive schemes
[ESRS 2 GOV-3]
E1-1
Transition plan for
 
climate change mitigation
Transition plan for
 
climate change
mitigation [E1-1]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Material impacts, risks and
opportunities and their interaction
with strategy and business model
[ESRS 2 SBM-3]
IRO-1
Description of the processes to identify and assess
material climate-related impacts, risks and
opportunities
Description of the processes to
identify and assess material
climate-related impacts, risks and
opportunities [ESRS 2 IRO-1]
E1-2
Policies related to climate change mitigation and
adaptation
Policies related to climate change
mitigation and adaptation [E1-2]
E1-3
Actions and resources in relation to climate change
policies
Actions and resources in relation to
climate change policies [E1-3]
E1-4
Targets
 
related to climate change mitigation and
adaptation
Targets
 
related to climate change
mitigation and adaptation [E1-4]
E1-5
Energy consumption and mix
Energy consumption & mix [E1-5]
E1-6
Gross Scopes 1, 2, 3 and Total GHG emissions
GHG Intensity based on net revenue
Gross Scopes 1, 2, 3 and Total GHG
emissions [E1-6]
E1-7
GHG removals and GHG mitigation projects financed
through carbon credits
GHG removals and GHG mitigation
projects financed through carbon
credits [E1-7]
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr.
Description
Reference
Explanation
E1-8
Internal carbon pricing
Not applicable
E1-9
Anticipated financial effects from material physical
 
and
transition risks and potential climate-related
opportunities
Phased-in provision
Omission of all information under
this sub-topic for the first year of
preparation
ESRS E4: Biodiversity and ecosystems
E4-1
Transition plan and consideration
 
of biodiversity and
ecosystems in strategy and business model
Information is disclosed in a manner that reflects the
 
application of
biodiversity matters for
 
the financial services sector.
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
IRO-1
Description of processes to identify and assess material
biodiversity and ecosystem-related impacts, risks,
dependencies and opportunities
E4-2
Policies related to biodiversity
 
and ecosystems
E4-3
Actions and resources related to biodiversity
 
and
ecosystems
E4-4
Targets
 
related to biodiversity and ecosystems
E4-5
Impact metrics related to biodiversity and ecosystems
change
E4-6
Anticipated financial effects from biodiversity
 
and
ecosystem-related risks and opportunities
ESRS S1: Own Workforce
SBM-2
Interests and views of stakeholders
Stakeholder interest and
engagement [SBM-2]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Material impacts, risks and
opportunities and their interaction
with strategy and business model
[ESRS 2 SBM-3]
S1-1
Policies related to own workforce
Policies related to own workforce
[S1-1]
S1-2
Processes for engaging with own workforce
 
and
workers’ representatives
 
about impacts
Processes for engaging with own
workforce and workers’
representatives about impacts [S1-
2]
S1-3
Processes to remediate negative
 
impacts and channels
for own workers
 
to raise concerns
Processes to remediate negative
impacts and channels for own
workforce to raise
 
concerns [S1-3]
S1-4
Taking action on material
 
impacts on own workforce,
and approaches to managing material risks and
pursuing material opportunities related to own
workforce, and effectiveness
 
of those actions
Action on material impacts on own
workforce, and approaches
 
to
managing material risks and
pursuing material opportunities
related to own workforce,
 
and
effectiveness of those actions [S1-4]
S1-5
Targets
 
related to managing material negative
impacts, advancing positive impacts, and managing
material risks and opportunities
Targets
 
related to managing
material negative impacts,
advancing positive impacts, and
managing material risks and
opportunities [S1-5]
S1-6
Characteristics of the undertaking’s employees
Characteristics of employees [S1-6]
S1-7
Characteristics of non-employee workers
 
in the
undertaking’s own workforce
Phased-in provision
Omission of all information under
this sub-topic for the first year of
preparation
S1-8
Collective bargaining coverage
 
and social dialogue
Phased-in provision
Omission of information about
own employees in non-EEA
countries for the first year of
preparation
S1-9
Diversity metrics
Diversity Metrics [S1-9]
S1-10
Adequate wages
Adequate Wages [S1-10]
S1-11
Social protection
Phased-in provision
Omission of all information under
this sub-topic for the first year of
preparation
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr.
Description
Reference
Explanation
S1-12
Persons with disabilities
Phased-in provision
Omission of all information under
this sub-topic for the first year of
preparation
S1-13
Training and skills development metrics
Training and skills development
metrics [S1-13]
Omission of all information under
this sub-topic for the first year of
preparation
S1-14
Health and safety metrics
Health and safety metrics [S1-14]
Omission of the data points on
cases of work-related ill-health
and on number of days lost to
injuries, accidents, fatalities and
work-related ill health and
 
reporting on non-employees for
the first year of preparation
 
of its
sustainability statement
S1-15
Work-life balance metrics
Training and skills development
metrics [S1-15]
Omission of
 
information under
this sub-topic for the first year of
preparation
S1-16
Remuneration metrics (pay gap and total
remuneration)
Remuneration metrics (pay gap and
total remuneration)
 
[S1-16]
S1-17
Incidents, complaints and severe human rights impacts
Incidents, complaints and severe
human right [S1-17]
ESRS S-4: Consumers and end-users
SBM-2
Interests and views of stakeholders
Stakeholder interest and
engagement [SBM-2]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Material impacts, risks and
opportunities and their interaction
with strategy and business model
[ESRS 2 SBM-3]
S4-1
Policies related to consumers and end-users
Policies related to consumers and
end-users [S4-1]
S4-2
Processes for engaging with consumers
 
and end-users
about impacts
Processes for engaging with
consumers and end-users about
impacts [S4-2]
S4-3
Processes to remediate negative
 
impacts and channels
for consumers and end-users to raise concerns
Processes to remediate negative
impacts and channels for consumers
and end-users to raise concerns [S4-
3]
S4-4
Taking action on material
 
impacts on consumers and
end-users, and approaches to managing material risks
and pursuing material opportunities related to
consumers and end-users, and effectiveness
 
of those
actions
Taking action on material
 
impacts
on consumers and end-users, and
approaches to managing material
risks, pursuing material
opportunities related to consumers
and end-users, and effectiveness of
those actions [S4-4]
S4-5
Targets
 
related to managing material negative
impacts, advancing positive impacts, and managing
material risks and opportunities
Targets
 
related to managing
material negative impacts,
advancing positive impacts, and
managing material risks and
opportunities [S4-5]
ESRS G1: Business conduct
GOV-1
The role of the
 
administrative, management and
supervisory bodies
The role of the
 
administrative,
management and supervisory
bodies [ESRS 2 GOV-1]
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of the processes to
identify and assess material
impacts, risks and opportunities
[ESRS 2 IRO-1]
G1-1
Business conduct policies and corporate culture
Business conduct policies and
corporate culture [G1-1]
G1-2
Management of relationships with suppliers
Not material
G1-3
Prevention and detection of corruption
 
and bribery
Prevention and detection of
corruption and bribery [G1-3]
G1-4
Incidents of corruption or bribery
Incidents of corruption or bribery
[G1-4]
G1-5
Political influence and lobbying activities
Not material
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr.
Description
Reference
Explanation
G1-6
Payment practices
Not material
Entity-specific: Integration of sustainability in risk management
GOV-1
The role of the
 
administrative, management and
supervisory bodies
The role of the
 
administrative,
management and supervisory
bodies [ESRS 2 GOV-1]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Material impacts, risks and
opportunities and their interaction
with strategy and business model
[ESRS 2 SBM-3]
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of processes to identify
and assess material impacts, risks
and opportunities [ESRS 2 IRO-1]
MDR-P
Policies adopted to manage material sustainability
matters
Policies related to the integration
 
of
sustainability in risk management
[MDR-P]
MDR-A
Actions and resources in relation to material
sustainability matters
Actions related to the integration
 
of
sustainability in risk management
[MDR-A]
MDR-M
Metrics in relation to material sustainability matters
Sustainability risk management
metrics [MDR-M]
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Sustainability risk management
targets [MDR-T]
Entity-specific: Sustainable financing and investment offerings
GOV-1
The role of the
 
administrative, management and
supervisory bodies
The role of the
 
administrative,
management and supervisory
bodies [ESRS 2 GOV-1]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Material impacts, risks and
opportunities and their interaction
with strategy and business model
[ESRS 2 SBM-3]
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of processes to identify
and assess material impacts, risks
and opportunities [ESRS 2 IRO-1]
MDR-P
Policies adopted to manage material sustainability
matters
Policies on sustainable financing
and investment offerings
 
[MDR-P]
MDR-A
Actions and resources in relation to material
sustainability matters
Actions on sustainable financing
and investment offerings
 
[MDR-A]
MDR-M
Metrics in relation to material sustainability matters
Metrics on sustainable financing
and investment offerings
 
[MDR-M]
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Targets on
 
sustainable financing
and investment offerings
 
[MDR-T]
Entity-specific: Fostering innovation
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Description of material impacts,
risks and opportunities and their
interaction with strategy
 
and
business model [SBM-3]
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of processes to identify
and assess material impacts, risks
and opportunities [ESRS 2 IRO-1]
MDR-P
Policies adopted to manage material sustainability
matters
Policies related to fostering
innovation [MDR-P]
MDR-A
Actions and resources in relation to material
sustainability matters
Actions related to fostering
innovation [MDR-A]
MDR-M
Metrics in relation to material sustainability matters
Fostering Innovation
 
metrics [MDR-
M]
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Fostering innovation
 
targets [MDR-
T]
Entity-specific: Financial inclusion
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Description of material impacts,
risks and opportunities and their
interaction with strategy
 
and
business model [SBM-3]
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr.
Description
Reference
Explanation
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of processes to identify
and assess material impacts, risks
and opportunities [ESRS 2 IRO-1]
MDR-P
Policies adopted to manage material sustainability
matters
Policies related to financial inclusion
[MDR-P]
MDR-A
Actions and resources in relation to material
sustainability matters
Actions related to financial inclusion
[MDR-A]
MDR-M
Metrics in relation to material sustainability matters
Financial inclusion metrics [MDR-M]
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Financial inclusion targets [MDR-T]
Entity-specific: Data security and customer privacy
GOV-1
The role of the
 
administrative, management and
supervisory bodies
The role of the
 
administrative,
management and supervisory
bodies [ESRS 2 GOV-1]
SBM-3
Material impacts, risks and opportunities and their
interaction with strategy
 
and business model
Description of material impacts,
risks and opportunities and their
interaction with strategy
 
and
business model [SBM-3]
IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
Description of processes to identify
and assess material impacts, risks
and opportunities [ESRS 2 IRO-1]
MDR-P
Policies adopted to manage material sustainability
matters
Policies related to data security and
customer privacy [MDR-P]
MDR-A
Actions and resources in relation to material
sustainability matters
Actions related to data security and
customer privacy [MDR-A]
MDR-M
Metrics in relation to material sustainability matters
Data security and customer privacy
metrics [MDR-M]
MDR-T
Tracking effectiveness
 
of policies and actions through
targets
Data security and customer privacy
targets [MDR-T]
The table below presents
List of datapoints in cross-cutting and topical standards
 
that derive from
 
other EU legislation
:
Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
ESRS 2 GOV-1 Board's gender
diversity paragraph
 
21 (d)
Indicator number 13 of
Table #1 of Annex 1
Commission Delegated
Regulation (EU)
2020/1816, Annex II
The role of the
administrative,
management
and
supervisory
bodies [ESRS 2
GOV-1]
ESRS 2 GOV-1 Percentage of
board members who are
independent paragraph 21 (e)
Delegated Regulation
(EU) 2020/1816, Annex II
The role of the
administrative,
management
and
supervisory
bodies [ESRS 2
GOV-1]
ESRS 2 GOV-4 Statement on
due diligence paragraph 30
Indicator number 10
Table #3 of Annex 1
1.3.4
Description of
the due
diligence on
sustainability
matters [GOV-
4]
ESRS 2 SBM-1 Involvement in
activities related to fossil fuel
activities paragraph 40 (d) i
"Indicators number 4
Table #1 of Annex 1
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453 ( 28 )
Table 1:
Qualitative
information on
Environmental
risk and Table 2:
Delegated Regulation
(EU) 2020/1816, Annex II
1.4.1
Information on
the market
position and
strategy of the
company
[SBM-1]
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
Qualitative
information on
Social risk
ESRS 2 SBM-1 Involvement in
activities related to chemical
production paragraph
 
40 (d) ii
Indicator number 9 Table
#2 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
1.4.1
Information on
the market
position and
strategy of the
company
[SBM-1]
ESRS 2 SBM-1 Involvement in
activities related to
controversial weapons
paragraph 40 (d) iii
Indicator number 14
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1818, Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
1.4.1
Information on
the market
position and
strategy of the
company
[SBM-1]
ESRS 2 SBM-1 Involvement in
activities related to cultivation
and production of tobacco
paragraph 40 (d) iv
Delegated Regulation
(EU) 2020/1818, Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
1.4.1
Information on
the market
position and
strategy of the
company
[SBM-1]
ESRS E1-1 Transition plan to
reach climate neutrality by
2050 paragraph 14
Regulation
(EU)
2021/1119,
Article 2(1)
Transition plan
for climate
change
mitigation [E1-
1]
ESRS E1-1 Undertakings
excluded from Paris-aligned
Benchmarks paragraph 16 (g)
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 1:
Banking book-
Climate Change
transition risk:
Credit quality of
exposures by
sector, emissions
and residual
maturity
Delegated Regulation
(EU) 2020/1818, Article
12.1 (d) to (g), and
Article 12.2
Transition plan
for climate
change
mitigation [E1-
1]
ESRS E1-4 GHG emission
reduction targets paragraph
34
Indicator number 4 Table
#2 of Annex 1
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 3:
Banking book –
Climate change
transition risk:
alignment
metrics
Delegated Regulation
(EU) 2020/1818, Article 6
Targets
related to
climate
change
mitigation and
adaptation
[E1-4]
ESRS E1-5 Energy consumption
from fossil sources
disaggregated by sources (only
high climate impact sectors)
paragraph 38
Indicator number 5 Table
#1 and Indicator n. 5
Table #2 of Annex 1
Energy
consumption
& mix [E1-5]
ESRS E1-5 Energy consumption
and mix paragraph 37
Indicator number 5 Table
#1 of Annex 1
Energy
consumption
& mix [E1-5]
ESRS E1-5 Energy intensity
associated with activities in
high climate impact sectors
paragraphs 40 to 43
Indicator number 6 Table
#1 of Annex 1
Energy
consumption
& mix [E1-5]
ESRS E1-6 Gross Scope 1, 2, 3,
and Total GHG emissions
paragraph 44
Indicators number 1 and
2 Table #1 of Annex 1
Article 449a;
Regulation (EU)
No 575/2013;
Commission
Implementing
Delegated Regulation
(EU) 2020/1818, Article
5(1), 6 and 8(1)
Gross Scopes
1, 2, 3 and
Total GHG
emissions [E1-
6]
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
Regulation (EU)
2022/2453
Template 1:
Banking book –
Climate change
transition risk:
Credit quality of
exposures by
sector, emissions
and residual
maturity
ESRS E1-6 Gross GHG
emissions intensity paragraphs
53 to 55
Indicators number 3
Table #1 of Annex 1
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 3:
Banking book –
Climate change
transition risk:
alignment
metrics
Delegated Regulation
(EU) 2020/1818, Article
8(1)
Gross Scopes
1, 2, 3 and
Total GHG
emissions [E1-
6]
ESRS E1-7 GHG removals and
carbon credits paragraph 56
Regulation
(EU)
2021/1119,
Article 2(1)
GHG removals
and GHG
mitigation
projects
financed
through carbon
credits [E1-7]
ESRS E1-9 Exposure of the
benchmark portfolio to
climate-related physical risks
paragraph 66
Delegated Regulation
(EU) 2020/1818, Annex II
Delegated Regulation
(EU) 2020/1816, Annex II
Phased-in
provision
"ESRS E1-9 Disaggregation of
monetary amounts by acute
and chronic physical risk
paragraph 66 (a)
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
paragraphs 46
and 47; Template
5: Banking book -
Climate change
physical risk:
Exposures subject
to physical risk.
Phased-in
provision
ESRS E1-9 Location of
significant assets at material
physical risk paragraph 66 (c)"
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
paragraphs 46
and 47; Template
5: Banking book -
Climate change
physical risk:
Exposures subject
to physical risk.
Phased-in
provision
ESRS E1-9 Breakdown of the
carrying value of its real estate
assets by energy-efficiency
classes paragraph 67 (c)
Article 449a
Regulation (EU)
No 575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
paragraph
34;Template
2:Banking book -
Climate change
transition risk:
Loans
collateralised by
Phased-in
provision
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
immovable
property - Energy
efficiency of the
collateral
ESRS E1-9 Degree of exposure
of the portfolio
 
to climate-
related opportunities
paragraph 69
Delegated Regulation
(EU) 2020/1818, Annex II
 
Phased-in
provision
ESRS E2-4 Amount of each
pollutant listed in Annex II of
the E- PRTR Regulation
(European Pollutant Release
and Transfer
 
Register) emitted
to air, water and soil,
paragraph 28
Indicator number 8 Table
#1 of Annex 1 Indicator
number 2 Table #2 of
Annex 1 Indicator number
1 Table #2 of Annex 1
Indicator number 3 Table
#2 of Annex 1
Not material
 
ESRS E3-1 Water and marine
resources paragraph
 
9
Indicator number 7 Table
#2 of Annex 1
Not material
 
ESRS E3-1 Dedicated policy
paragraph 13
Indicator number 8 Table
2 of Annex 1
Not material
 
ESRS E3-1 Sustainable oceans
and seas paragraph 14
Indicator number 12
Table #2 of Annex 1
Not material
 
ESRS E3-4 Total water recycled
and reused paragraph 28 (c)
Indicator number 6.2
Table #2 of Annex 1
Not material
 
ESRS E3-4 Total water
consumption in m3 per net
revenue on own operations
paragraph 29
"Indicator number 6.1
Table #2 of
Not material
 
ESRS 2- IRO 1 - E4 paragraph
16 (a) i
Indicator number 7 Table
#1 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
matters for
the financial
services
sector.
ESRS 2- IRO 1 - E4 paragraph
16 (b)
Indicator number 10
Table #2 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
matters for
the financial
services
sector.
ESRS 2- IRO 1 - E4 paragraph
16 (c)
Indicator number 14
Table #2 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
matters for
the financial
services
sector.
ESRS E4-2 Sustainable land /
agriculture practices or policies
paragraph 24 (b)
Indicator number 11 Table
#2 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
matters for
the financial
services
sector.
ESRS E4-2 Sustainable oceans
/ seas practices or policies
paragraph 24 (c)
Indicator number 12
Table #2 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
matters for
the financial
services
sector.
ESRS E4-2 Policies to address
deforestation paragraph
 
24 (d)
Indicator number 15Table
#2 of Annex 1
Information is
disclosed in a
manner that
reflects the
application of
biodiversity
matters for
the financial
services
sector.
ESRS E5-5 Non-recycled waste
paragraph 37 (d)
Indicator number 13
Table #2 of Annex 1
Not material
ESRS E5-5 Hazardous waste
and radioactive waste
paragraph 39
Indicator number 9 Table
#1 of Annex 1
Not material
ESRS 2- SBM3 - S1 Risk of
incidents of forced labor
paragraph 14 (f)
Indicator number 13
Table #3 of Annex I
Material
impacts, risks
and
opportunities
and their
interaction
with strategy
and business
model [ESRS 2
SBM-3]
ESRS 2- SBM3 - S1 Risk of
incidents of child labor
paragraph 14 (g)
Indicator number 12
Table #3 of Annex I
Material
impacts, risks
and
opportunities
and their
interaction
with strategy
and business
model [ESRS 2
SBM-3]
ESRS S1-1 Human rights policy
commitments paragraph 20
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
Policies
related to own
workforce
 
[S1-
1]
ESRS S1-1 Due diligence
policies on issues addressed by
the fundamental International
Labour Organisation
Conventions 1 to 8, paragraph
21
Delegated Regulation
(EU) 2020/1816, Annex II
Policies
related to own
workforce
 
[S1-
1]
ESRS S1-1 Processes and
measures for preventing
trafficking in human beings
paragraph 22
Indicator number 1 Table
#3 of Annex I
Policies
related to own
workforce
 
[S1-
1]
ESRS S1-1 Workplace accident
prevention policy or
management system
paragraph 23
Indicator number 1 Table
#3 of Annex I
Policies
related to own
workforce
 
[S1-
1]
ESRS S1-3
Grievance/complaints handling
mechanisms paragraph 32 (c)
Indicator number 5 Table
#3 of Annex I
Processes to
remediate
negative
impacts and
channels for
own workforce
to raise
concerns [S1-3]
ESRS S1-14 Number of fatalities
and number and rate of work-
related accidents paragraph
88 (b) and (c)
Indicator number 2 Table
#3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Health and
safety metrics
[S1-14]
ESRS S1-14 Number of days lost
to injuries, accidents, fatalities
or illness paragraph 88 (e)
Indicator number 3 Table
#3 of Annex I
Phased-in
provision
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
ESRS S1-16 Unadjusted gender
pay gap paragraph 97 (a)
Indicator number 12
Table #1 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Remuneration
metrics (pay
gap and total
remuneration)
[S1-16]
ESRS S1-16 Excessive CEO pay
ratio paragraph
 
97 (b)
Indicator number 8 Table
#3 of Annex I
Remuneration
metrics (pay
gap and total
remuneration)
[S1-16]
ESRS S1-17 Incidents of
discrimination paragraph 103
(a)
Indicator number 7 Table
#3 of Annex I
Incidents,
complaints
and severe
human right
[S1-17]
ESRS S1-17 Non-respect of
UNGPs on Business and
Human Rights and OECD
paragraph 104 (a)
Indicator number 10
Table #1 and
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818 Art 12 (1)
Incidents,
complaints
and severe
human right
[S1-17]
ESRS 2- SBM3 – S2 Significant
risk of child labour or forced
labour in the value chain
paragraph 11 (b)
Indicators number 12 and
n. 13 Table #3 of Annex I
Not material
ESRS S2-1 Human rights policy
commitments paragraph 17
Indicator number 9 Table
#3 and Indicator n. 11
Table #1 of Annex 1
Not material
ESRS S2-1 Policies related to
value chain workers paragraph
18
Indicator number 11 and
n. 4 Table #3 of Annex 1
Not material
ESRS S2-1 Non- respect of
UNGPs on Business and
Human Rights principles and
OECD guidelines paragraph 19
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Not material
ESRS S2-1 Due diligence
policies on issues addressed by
the fundamental International
Labor Organisation
Conventions 1 to 8, paragraph
19
Delegated Regulation
(EU) 2020/1816, Annex II
Not material
ESRS S2-4 Human rights issues
and incidents connected to its
upstream and downstream
value chain paragraph 36
Indicator number 14
Table #3 of Annex 1
Not material
ESRS S3-1 Human rights policy
commitments paragraph 16
Indicator number 9 Table
#3 of Annex 1 and
Indicator number 11 Table
#1 of Annex 1
Not material
ESRS S3-1 non-respect of
UNGPs on Business and
Human Rights, ILO principles or
and OECD guidelines
paragraph 17
Indicator number 10
Table #1 Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Not material
ESRS S3-4 Human rights issues
and incidents paragraph 36
Indicator number 14
Table #3 of Annex 1
Not material
ESRS S4-1 Policies related to
consumers and end-users
paragraph 16
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex 1
Policies
related to
consumers
and end-users
[S4-1]
ESRS S4-1 Non-respect of
UNGPs on Business and
Human Rights and OECD
guidelines paragraph 17
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Policies
related to
consumers
and end-users
[S4-1]
ESRS S4-4 Human rights issues
and incidents paragraph 35
Indicator number 14
Table #3 of Annex 1
Taking action
on material
impacts on
consumers
and end-users,
and
approaches to
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Disclosure Requirement and
related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU
Climate
Law
reference
Section
managing
material risks,
pursuing
material
opportunities
related to
consumers
and end-users,
and
effectiveness
of those
actions [S4-4]
ESRS G1-1 United Nations
Convention against Corruption
paragraph 10 (b)
Indicator number 15
Table #3 of Annex 1
Business
conduct
policies and
corporate
culture [G1-1]
ESRS G1-1 Protection of
whistle-blowers paragraph
 
10
(d)
Indicator number 6 Table
#3 of Annex 1
Business
conduct
policies and
corporate
culture [G1-1]
ESRS G1-4 Fines for violation of
anti-corruption and anti-
bribery laws paragraph 24 (a)
Indicator number 17
Table #3 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex
II)
Incidents of
corruption or
bribery [G1-4]
ESRS G1-4 Standards of anti-
corruption and anti-bribery
paragraph 24 (b)
Indicator number 16
Table #3 of Annex 1
Incidents of
corruption or
bribery [G1-4]
 
 
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2. Environmental Information
2.1 Disclosures pursuant to
 
Taxonomy
 
Regulation
Disclosure pursuant to Article 8 of EU of Taxonomy
 
Regulation (Regulation 2020/852)
The EU Taxonomy
 
Regulation (Regulation EU) 2020/852 of the European Parliament and of the Council was adopted in 2020
by the European
 
Parliament and represents
 
an important step for
 
the EU to achieve
 
the Paris
 
Agreement climate
 
neutrality
goals.
 
It
 
sets
 
out
 
the
 
criteria
 
to
 
establish
 
a
 
common
 
classification
 
system
 
for
 
sustainable
 
economic
 
activities.
 
The
 
EU
Taxonomy
 
Regulation
 
determines
 
whether
 
an economic
 
activity is
 
environmentally
 
sustainable and
 
requires
 
financial and
non-financial entities subject to the Non-Financial Reporting Directive
 
(NFRD) to disclose the alignment of their
 
activities.
 
Article 8 of the Taxonomy
 
Regulation prescribes that
 
undertakings subject to the Non-Financial Reporting Directive
 
(NFRD),
including financial undertakings,
 
publish to what
 
extent their
 
activities are
 
associated with
 
economic activities
 
that qualify
as environmentally sustainable under EU Taxonomy Regulation. Separate disclosures requirements
 
and extensive criteria are
in place for financial and non-financial undertakings under Article 8 of EU Taxonomy Regulation Delegated
 
Act (Commission
Delegated Regulation (EU) 2021/2178.
For the
 
years 2021 and 2022, financial undertakings
 
subject to NFRD were
 
required to disclose the
 
proportion of taxonomy-
eligible and
 
taxonomy non-eligible
 
activities related
 
to the
 
environmental
 
objectives
 
of climate
 
change adaptation
 
(CCA)
and climate change mitigation (CCM).
 
In 2023, two new Delegated
 
Acts issued by the European
 
Commission were
 
adopted:
The
 
Delegated
 
Regulation
 
2023/2485,
 
which
 
extends
 
the
 
number
 
of
 
eligible
 
activities
 
in
 
the
 
climate
 
change
adaptation and mitigation objectives.
 
The Delegated
 
Regulation 2023/2486,
 
which establishes the
 
technical screening criteria
 
for the
 
economic activities
of the remaining four
 
environmental objectives.
 
For
 
the current
 
year,
 
in accordance with
 
the requirements
 
of the EU
 
Taxonomy
 
Regulation and
 
related Delegated
 
Acts, this
report includes the alignment
 
of Eurobank’s activities with
 
all six environmental objectives.
 
However,
 
it should be noted that
the
 
alignment
 
data
 
for
 
the
 
four
 
additional
 
environmental
 
objectives
 
presented
 
below,
 
rely
 
on
 
alignment
 
KPIs
 
that
 
non-
financial undertakings have chosen to report on a voluntary
 
basis:
a.
Sustainable use and protection of water
 
and marine resources,
 
b.
Transition to a circular
 
economy,
 
c.
Pollution control
 
and prevention, and
 
d.
Protection and restoration
 
of biodiversity and ecosystems.
This
 
is
 
due
 
to
 
the
 
fact
 
that
 
non-financial
 
undertakings,
 
whose
 
prior-year
 
data
 
forms
 
the
 
basis
 
for
 
Eurobank’s
 
alignment
calculations, are required to report alignment for these objectives starting only from their 2024 disclosures, available in
 
2025.
In
 
such
 
case,
 
the
 
Group
 
used
 
the
 
"best
 
available
 
data"
 
approach,
 
aligning
 
its
 
reporting
 
methodologies
 
with
 
regulatory
recommendations for
 
handling incomplete or transitional data.
With
 
the gradual
 
adoption of
 
the new
 
Corporate
 
Sustainability Reporting Directive
 
(CSRD) by
 
large companies,
 
small and
medium
 
listed
 
companies
 
and
 
large
 
companies
 
outside
 
the
 
EU
 
with
 
significant
 
activity
 
in
 
the
 
EU,
 
the
 
Group's
 
KPIs
 
are
expected to improve as the
 
number of companies subject to this new directive
 
will increase.
Credit institutions publish the Green Asset Ratio (GAR), which determines the extent to which the Group’s assets finance and
are invested
 
in taxonomy-aligned
 
economic activities, that
 
is the
 
ratio
 
of the
 
Group's taxonomy
 
-aligned assets
 
to covered
assets (total assets excluding exposure to sovereigns,
 
central banks and the
 
trading portfolio).
 
Moreover,
 
as required by the
EU Taxonomy
 
Regulation, activities, to be taxonomy-aligned,
 
must meet the specific taxonomy criteria
 
and ensure that they
cause no significant harm to any of the other
 
environmental objectives
 
(DNSH) and meet minimum social safeguards (MSS).
Additional KPIs are required regarding
 
the off-balance
 
sheet exposures and specifically for
 
financial guarantees to financial
and non-financial undertakings (FinGuar KPI) and assets under management (AuM KPI).
Integration of Taxonomy
 
in the Group’s
 
business strategy,
 
operating model, products
 
and customers
In line with best established practices,
 
the Group has integrated
 
the requirements
 
of the EU Taxonomy
 
Regulation within its
processes with key
 
roles consisting of
client engagement in the context of ESG/ Risk Assessment and Sustainable
 
Finance Assessment,
 
establishment
 
and
 
monitoring
 
of sustainability
 
risk and
 
EU
 
Taxonomy
 
-related
 
KPIs
 
to ensure
 
alignment
 
with
 
risk
limits and sustainable financing strategy/targets as well
 
as
 
the development
 
of relevant disclosures.
As part of its Sustainability Strategy,
 
the Group is implementing
 
initiatives that
 
will, among others, enable
 
it to increase the
share of taxonomy-aligned assets in the
 
coming years:
Development of sectoral near, mid and long-term financed emissions reduction pathways, in line with science-based
decarbonisation pathways,
 
in alignment with the Group’s
 
Net Zero commitments.
Performing
 
perimeter
 
analysis of Taxonomy
 
-related
 
sectors, counterparties
 
and financings
 
affecting
 
the GAR
 
and
 
 
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developing action plans for
 
increasing Taxonomy
-aligned financings in the future.
Further
 
integrating
 
sustainability
 
risks and
 
sustainable
 
financing considerations
 
in the
 
business
 
planning process
(e.g., project budgeting and prioritisation),
 
to reflect the Group’s
 
business strategy and relevant
 
targets.
Committed to
 
being transparent
 
about its
 
approach
 
and to
 
ensure
 
that
 
decision-
 
making is
 
in line
 
with best
 
practices
 
in
environmental
 
protection
 
and
 
sustainability,
 
Eurobank
 
has
 
developed
 
guiding
 
frameworks,
 
defining
 
the
 
approach
 
and
criteria for classifying its financing and investing activities
 
as sustainable:
The Sustainable Finance Framework
Through
 
its Sustainable
 
Finance
 
Framework
 
(SFF), Eurobank
 
is able
 
to classify
 
sustainable
 
lending solutions
 
offered
 
to its
clients, specifying the
 
applied classification
 
approach and
 
the activities
 
defined as eligible
 
to access sustainable
 
financing.
The
 
purpose of
 
establishing the
 
SFF is
 
to provide
 
a clear and
 
comprehensive
 
methodology
 
for
 
classifying, monitoring,
 
and
reporting
 
sustainable
 
financing
 
in
 
line
 
with
 
the
 
Financed
 
Impact
 
Strategy.
 
The
 
SFF
 
has
 
drawn
 
from
 
international
 
best
practices
 
and is
 
based on
 
two key
 
guiding frameworks:
 
The
 
International
 
Capital Market
 
Association
 
(ICMA)
 
principles on
sustainable financing
 
(Green
 
Bond Principles,
 
Green Loan
 
Principles and
 
Sustainability-linked Bond
 
Principles) and the
 
EU
Taxonomy.
 
Eurobank will closely monitor the developments of
 
the EU Taxonomy, to update its SFF as
 
relevant. The SFF defines
two levels of transaction
 
alignment:
SFF alignment - Fulfilment of criteria dictated by
 
established market practice
 
EU
 
Taxonomy
 
alignment
 
-
 
Fulfilment
 
of
 
criteria
 
associated
 
with
 
each
 
of
 
the
 
EU
 
Taxonomy
 
assessment
 
steps
(substantial contribution, DNSH, MSS)
Through the dedicated
 
purpose financing approach (i.e. where the use of proceeds is not known)
 
the Eurobank assesses and
classifies financings / transactions as “Not SFF aligned”,
 
“SFF aligned” or “SFF & EU Taxonomy
 
aligned”.
For
 
general
 
purpose
 
financing
 
/
 
transactions
 
(i.e.
 
where
 
the
 
use
 
of
 
proceeds
 
is
 
not
 
known),
 
the
 
SFF
 
defines
 
two
 
other
approaches:
Company Business mix
 
- Financing to
 
companies that fulfil the eligibility green/ social
 
criteria and derive the majority
of their revenues
 
from eligible activities.
Sustainability-linked
 
loans
 
-
 
Financing
 
linked
 
to
 
ambitious
 
and
 
predefined
 
Sustainability
 
Performance
 
Targets
(SPTs).
To adequately
 
embed of sustainable financing and the SFF in its practices,
 
the Group has developed
 
governance structures
and functions as well as a digital tool (SFF assessment
 
tool) that facilitate
 
the day-to-day implementation
 
of the SFF.
The
 
SFF assessment
 
tool supports
 
the process
 
of assessing
 
the financings
 
/ transactions
 
against the
 
criteria defined
 
in the
SFF and
 
the
 
EU Taxonomy.
 
Through
 
the
 
SFF assessment
 
tool,
 
users categorise
 
financing to
 
the
 
applicable
 
eligible activity
and are guided through the assessment steps which involve substantiating alignment with the criteria of each step,
 
including
Taxonomy
 
alignment assessment (TSC, DNSH criteria,
 
MSS).
Approach for
 
the preparation
 
of disclosures relating to Article 8 of the
 
Taxonomy
 
Regulation
The preparation
 
of mandatory disclosure
 
in taxonomy eligibility and alignment
 
is based on the
 
prudential consolidation for
the
 
Group.
 
The
 
consolidation
 
is in
 
accordance
 
with the
 
supervisory
 
reporting of
 
institutions
 
according
 
to the
 
Commission
Implementing Regulation (EU) 2021/451 (FINREP).
 
The Group,
 
upon reviewing its business
 
activities, to map Taxonomy
 
reporting requirements
 
with its core activities, provides
the key
 
performance
 
indicators (KPIs)
 
and other
 
disclosure requirements
 
as laid down
 
in the
 
EU Taxonomy
 
Regulation and
the EU Taxon
 
omy Delegated Act.
 
For 2024, credit institutions
 
shall disclose:
The
 
aggregate
 
GAR for
 
covered
 
on-balance
 
sheet
 
assets and
 
the
 
breakdown
 
by environmental
 
objective
 
and by
type of counterparty.
 
The percentage
 
of their total assets that are
 
excluded from the numerator
 
and the denominator of the GAR.
 
A complementary ratio
 
on the level
 
of association with Taxonomy
 
-aligned economic activities of off
 
-balance sheet
exposures.
 
These
 
exposures
 
include
 
financial
 
guarantees
 
granted
 
by
 
the
 
financial
 
institution
 
and
 
assets
 
under
management.
 
As
 
per
 
EU
 
Taxonomy
 
Regulation
 
Delegated
 
Act,
 
the
 
calculation
 
of
 
KPIs
 
for
 
off-balance
 
sheet
exposures shall
 
consider financial
 
guarantees
 
granted by
 
the
 
credit institution
 
and assets
 
under management
 
for
guarantee and investee
 
non-financial undertakings. Other
 
off-balance sheet
 
exposures such as commitments
 
shall
be excluded from that calculation.
The application
 
of the
 
EU Taxonomy
 
differs
 
for general
 
purpose financing and specific
 
purpose financing (i.e.
 
‘known use of
proceeds’).
 
General purpose financing
For general
 
purpose financing, the Group uses counterparties’
 
reported eligibility and alignment information from
 
the latest
published taxonomy information.
 
Specifically for corporate
 
counterparties, the Group
 
uses actual information that has been
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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disclosed and collected by
 
its counterparties reporting
 
under NFRD up to the
 
2023 reporting year
 
and the CSRD
 
from 2023
onwards.
 
In
 
order
 
to
 
determine
 
which
 
companies
 
are
 
subject
 
to
 
NFRD,
 
an
 
assessment
 
is
 
carried
 
out
 
to
 
determine
 
that
 
all
 
of
 
the
following criteria are met; a) if the country of
 
incorporation of the counterparty is in the EU, and
 
b) whether the counterparty’s
is either
 
a listed
 
company,
 
a credit
 
institution,
 
or an
 
insurance
 
company,
 
and c)
 
whether
 
the
 
entity’s net
 
revenue
 
exceeds
€40m or its total assets exceed €20m and d) the counterparty
 
has over 500 employees.
 
The identification
 
of counterparties subject to NFRD and counterparties not subject to NFRD has been carried
 
out based on
internal customer segmentation
 
in the core banking systems as well
 
as external information.
 
The
 
Taxonomy
 
-aligned assets
 
presented include
 
the reported
 
alignment for
 
exposures to
 
non-financial companies
 
subject
to NFRD
 
based on
 
the
 
Turnover
 
and capital
 
expenditure
 
(CapEx) KPI
 
published
 
by
 
the
 
counterparties.
 
The
 
Taxonomy
 
KPI
operating
 
expenses
 
(OpEx)
 
is
 
not
 
used
 
for
 
assessing
 
Taxonomy
 
-aligned
 
activities,
 
in
 
accordance
 
with
 
EU
 
Taxonomy
Regulation
 
Delegated
 
Act For
 
financial undertakings
 
subject
 
to NFRD,
 
the
 
Group’s
 
exposures
 
have
 
been weighted
 
to the
counterparty’s proportion of Taxonomy
 
-aligned assets.
 
Financial and non-financial
 
undertakings that
 
do not
 
meet the
 
aforementioned
 
requirements
 
are identified
 
as non-subject
to NFRD. Undertakings that are not required to report under the EU Taxonomy regulation (non-NFRD) are not included in the
calculation of eligible and aligned assets since estimations are
 
not allowed in mandatory reporting. Therefore,
 
assets on the
Group’s
 
balance
 
sheet
 
to
 
non-NFRD
 
undertakings
 
are
 
not
 
assessed
 
for
 
taxonomy
 
eligibility.
 
Assets
 
of
 
non-NFRD
counterparties,
 
derivatives,
 
hedge
 
accounting
 
and
 
on-demand
 
interbank
 
loans
 
are
 
not
 
included
 
in
 
the
 
calculation
 
of
Taxonomy
 
-eligible and Taxonomy
 
-aligned assets.
 
Specific purpose financing
For
 
specific
 
purpose
 
financing
 
where
 
the
 
use
 
of
 
proceeds
 
is
 
known,
 
project-specific
 
KPIs
 
are
 
used
 
in
 
the
 
assessment
 
of
Taxonomy
 
-eligibility
 
and
 
Taxonomy
 
-alignment
 
to
 
the
 
extent
 
that
 
Taxonomy
 
eligibility
 
and
 
Taxonomy
 
alignment
 
can
 
be
demonstrated
 
for
 
the
 
underlying
 
transaction.
 
As
 
part
 
of
 
Eurobank’s
 
Sustainable
 
Finance
 
assessment
 
process,
 
we
 
assess
standalone
 
dedicated
 
purpose
 
financings
 
to
 
evaluate
 
alignment
 
with
 
the
 
EU
 
Taxonomy
 
requirements.
 
The
 
assessment
 
is
carried
 
out, based on available
 
documentary evidence
 
provided by
 
the counterparties,
 
required to
 
ensure adherence
 
to EU
Taxonomy
 
and
 
based
 
on
 
applicable
 
National
 
Legislation
 
in
 
specific
 
financing
 
cases
 
(i.e.
 
Resilience
 
and
 
Recovery
 
Fund
investments, which embed the
 
DNSH assessment).
Other matters
In relation
 
to households,
 
loans collateralised
 
by residential
 
real estate,
 
loans granted
 
for
 
renovation
 
purposes and
 
loans
granted with purpose to finance the purchase of
 
vehicles were assessed for taxonomy-alignment. The Group is also reporting
its exposure to economic activities related to fossil
 
gas and nuclear energy according
 
to Commission Delegated Regulation
(EU) 2022/1214, which
 
amended the
 
EU Taxonomy
 
Delegated Act.
 
Hence, the
 
taxonomy-non-eligible nuclear
 
energy related
activities
 
are
 
included
 
in
 
the
 
denominator
 
of
 
Eurobank’s
 
key
 
performance
 
indicators.
 
The
 
Group
 
also
 
uses
 
the
 
relevant
templates included in the Delegated Act to disclose information
 
for nuclear and fossil
 
gas related activities.
 
The Group’s
 
approach for
 
the disclosures
 
prepared as of 31 December
 
2024 reflects its understanding and
 
interpretation of
the EU Taxonomy
 
requirements and
 
is based on the
 
best effort
 
to adhere
 
to the applicable
 
regulations and new
 
regulatory
developments. In accordance with the European Commission guidance published in
 
December 2023 FAQs, no estimates were
included in the calculation of eligibility and alignment
 
for mandatory disclosures presented.
The
 
Group
 
continues
 
its
 
work
 
on
 
implementing
 
the
 
EU
 
taxonomy
 
requirements
 
and
 
further
 
enhancing
 
its
 
reporting
methodology to ensure transparency
 
and completeness of the information
 
disclosed as further
 
robust information
 
becomes
available from counterparties.
Results
The Group’s
 
total GAR based on turnover and total GAR based
 
on CapEx, as at year-end 2024 cover
 
the six climate-related
EU environmental objectives
 
and are presented in the summary below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Summary EU Taxonomy
 
KPIs
 
 
 
 
 
Million EUROS
Gross carrying
amount
Turnover
 
KPIs
Capex KPIs
Taxonomy
 
-eligible assets
17,868
24.6%
19,
 
408
26.7%
Taxonomy
 
-aligned assets
1,908
2.6%
2,658
3.7%
Assets
GAR-
 
Covered
 
assets
 
in
 
both
 
numerator
 
and
denominator
29,506
Assets
 
excluded
 
from
 
the
 
numerator
 
for
 
GAR
calculation (covered
 
in the denominator)
43,257
Total GAR assets
72,762
Total assets
102,567
Impairment for
 
loans and
 
advances at
 
amortised cost,
debt instruments
 
and other
 
adjustments, according
 
to
EU taxonomy methodology
(1,417)
Total
 
assets
 
according
 
to
 
the
 
consolidated
 
balance
sheet as at 31 December 2024
101,150
The reported main and additional
 
KPIs calculated on 31 December 2024 for
 
the Group, including the
 
reporting templates as
set out
 
in the
 
EU Taxonomy
 
Regulation, EU
 
Taxonomy
 
Regulation Delegated
 
Act and the
 
European Commission
 
FAQs,
 
are
presented in the Appendix.
 
Moreover,
 
comparative information
 
for 2023 is also reported, which
 
have been adjusted to reflect newly issued
 
guidance and
interpretations of the
 
existing EU taxonomy Regulation. The
 
adjustments aim to ensure that our disclosures are fully
 
aligned
with the latest regulatory
 
expectations, thereby
 
enhancing the transparency
 
and consistency of our reporting.
2.2
Climate change [E1]
2.2.1
Governance
Integration of sustainability-related
 
performance in incentive
 
schemes [ESRS 2 GOV-3]
Sustainability
 
at
 
Eurobank
 
is
 
deployed
 
across
 
a
 
Sustainability
 
Governance
 
structure
 
that
 
addresses
 
both
 
regulatory
requirements and voluntary
 
commitments. Board oversight
 
with respect to the Sustainability Strategy
 
is addressed through
the inclusion of Sustainability items in the
 
Board Meetings agenda, as per international
 
best practice.
The
 
Group
 
has updated
 
its
 
Governance
 
structure
 
by
 
introducing
 
and defining
 
the
 
roles
 
and responsibilities
 
in relation
 
to
climate
 
change
 
and
 
sustainability
 
risks,
 
embedding
 
regulatory
 
guidelines
 
and
 
market
 
practices.
 
The
 
Group
 
applies
 
the
elements
 
of the
 
three
 
lines of
 
defense
 
model for
 
the
 
management of
 
sustainability risks.
 
The
 
three
 
lines of
 
defense
 
model
enhances risk management and control
 
by clarifying roles and responsibilities within
 
the organisation.
The
 
Group
 
has
 
established
 
a
 
Remuneration
 
Policy
 
that
 
is
 
applicable
 
to
 
all
 
Group
 
employees
 
and
 
covers
 
their
 
total
remuneration.
 
The
 
Remuneration
 
Policy
 
forms
 
an
 
integral
 
part
 
of
 
the
 
Group’s
 
corporate
 
governance
 
practice
 
and
 
is
developed
 
in accordance
 
with
 
its
 
operational
 
model,
 
business
 
strategy,
 
objectives,
 
long-term
 
interests
 
of
 
the
 
Group
 
and
incorporates measures
 
to avoid conflict of interest.
 
The Remuneration
 
Policy promotes
 
sound and effective risk management
 
and is consistent with the objectives of the
 
Bank’s
business and
 
risk strategy,
 
corporate
 
culture
 
and values,
 
risk culture,
 
with regard
 
sustainability risk
 
factors,
 
including long
term interests
 
of the
 
Group and
 
the
 
measures
 
used to
 
avoid conflicts
 
of interest
 
and should
 
not encourage
 
excessive
 
risk-
taking on behalf of the Group.
The
 
Group
 
ensures
 
that
 
remuneration
 
practices
 
are
 
aligned
 
with
 
their
 
overall
 
risk
 
appetite,
 
taking
 
into
 
account
 
all
 
risks,
including sustainability
 
risks, reputational
 
risks, as
 
well as
 
risks resulting
 
from
 
the
 
mis-selling of
 
products.
 
More specifically,
the Remuneration
 
Policy has been designed in order
 
to:
Be consistent with and promote sound and effective
 
risk management.
Stimulate behaviours consistent with sustainability risks approach.
Comply with the Group’s
 
voluntary commitments.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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For the time being, the remuneration
 
of members of the administrative, management and supervisory bodies is not assessed
against GHG emission reduction targets, and thus
 
no percentage of this year’s
 
remuneration
 
is linked with the
 
achievement
of sustainability targets.
2.2.2
Strategy
Transition
 
plan for climate change mitigation
 
[E1-1]
 
The
 
Group
 
supports
 
the
 
transition
 
towards
 
a
 
sustainable
 
economy
 
and
 
considers
 
sustainability
 
and
 
addressing
 
climate
change as an opportunity. A key strategic
 
objective is to adapt the Group’s
 
business and operation in a way that addresses
climate change
 
challenges, accommodates
 
social needs
 
within its
 
business model
 
and safeguards
 
prudent governance
 
for
itself
 
and
 
its
 
counterparties,
 
in
 
accordance
 
with
 
supervisory
 
initiatives,
 
and
 
following
 
international
 
standards
 
and
 
best
practice.
 
Following
 
the
 
completion of
 
the
 
onboarding of
 
Hellenic Bank,
 
during 2024,
 
along with
 
the
 
upskilling achieved
 
for
the rest
 
of International
 
subsidiaries, the
 
Group aims to
 
align all entities’
 
Sustainability Strategies
 
to converge
 
to a Group-
wide Sustainability Strategy in both pillars.
To this
 
end, Eurobank
 
has designed, approved
 
and is currently
 
implementing the
 
Group’s Sustainability
 
Strategy,
 
including
targets and commitments, along two key
 
pillars:
Operational Impact
 
Strategy: Impact arising from
 
the Bank’s operational
 
activities and footprint in Greece
Financed Impact
 
Strategy:
 
Impact arising
 
from
 
the
 
Bank’s lending
 
and investing
 
activities to
 
specific sectors
 
and
clients
The
 
operational
 
impact
 
strategy
 
defines the
 
operational
 
sustainability priorities
 
and objectives.
 
The
 
strategy
 
is deployed
through
 
milestones and
 
KPIs that
 
support the
 
annual and
 
long-term
 
targets
 
set across
 
multiple
 
project
 
streams, and
 
key
pillars spanning over
 
the next
 
decade. The
 
operational
 
impact strategy
 
is developed
 
and deployed
 
along three
 
pillars, key
pillar of which is
 
the environmental
 
impact which aims at
 
minimizing negative
 
impact of Eurobank’s
 
operations
 
to promote
environmental stewardship
 
with a clear goal to attain climate neutrality.
The underlying target of
 
the environmental impact pillar is
 
the achievement of Net Zero emissions
 
from Eurobank’s operations
by 2033
 
for
 
Scope 1
 
& 2
 
emissions and
 
by 2050
 
for
 
Scope 3
 
emissions, with
 
2019 as
 
the
 
baseline year.
 
Τhe action
 
plan for
achieving this target and tracking the progress
 
against it, is informed by transition
 
pathways that are aligned with the
 
Paris
Agreement target of limiting global
 
warming to 1.5
o
 
C.
To
 
achieve its operational
 
Net Zero targets, the
 
Bank has identified the following
 
key decarbonisation
 
levers:
Promote energy
 
efficiency and self-generation
 
of electricity - Scopes 1 & 2:
o
Action
 
plan
 
to
 
reduce
 
emissions
 
from
 
its
 
operations
 
by
 
optimizing/upgrading
 
the
 
energy
 
efficiency
 
of
 
its
buildings. This
 
includes technical
 
interventions
 
(i.e. LED
 
light fixture
 
installations, minimum
 
energy
 
class of
 
A+
air
 
conditioning
 
and
 
heat
 
recovery
 
ventilation
 
systems)
 
as
 
well
 
as
 
system-level
 
building
 
upgrades
 
and
 
the
replacement of carbon-intensive
 
sources (i.e. heating oil).
 
o
Energy self-production
 
plan consisting of
 
rooftop photovoltaic
 
(PV) stations
 
installed on
 
Eurobank’s
 
buildings
and standalone PV parks developed on Eurobank
 
property.
o
Increase procurement
 
of electricity sourced by Renewable Energy
 
Sources (guarantees of origin).
Electromobility – Scope 1
o
Gradual increase
 
of the share
 
of plug-in/ electric vehicles
 
in Eurobank’s
 
fleet and installation
 
of EV recharging
infrastructure at buildings
 
Minimise business travel
 
– Scope 3
o
Measures to
 
reduce indirect
 
emissions associated
 
with transportation
 
and business
 
travel,
 
where
 
feasible, by
introducing alternative
 
methods such as teleconferencing
Transition to cloud
 
– Scopes 2 & 3
o
Initiative for transitioning to cloud computing which
 
will result in
 
the reduction of electricity usage
 
from physical
servers.
The targets
 
that have
 
been in place
 
for the
 
achievement
 
of the
 
operational
 
Net Zero
 
commitment for
 
Scope 1 &
 
2 by 2033
and for Scope 3 by 2050 commitment are
 
the following:
Establish a centralized web
 
-based Platform for
 
energy,
 
emissions and environmental Data
 
by 2025.
Implement energy self-production
 
activities:
o
Installation of roof-top PVs
 
on Eurobank buildings by 2024
o
Develop standalone PV parks by 2028
Electromobility: >25%
 
of leased vehicles to
 
be EV or hybrid (new
 
contracts) by 2024
 
and >75% of leased vehicles
 
to
be EV or hybrid (new contracts) by 2028.
Calculation of emissions savings due to data centre
 
modernization by 2024
Completion of the initiative
 
"Journey to Cloud" by 2025
100% of electricity consumed to be originated from RES by
 
2028
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Energy efficiency upgrade
 
of buildings that contribute to Scope 1 & 2 emissions by 2030
Increase the number of certified
 
green buildings in Eurobank's building portfolio
 
by 10 by 2030 (baseline 2023)
Acknowledge the Acharnes building
 
as a model environmental building by 2025
Monitor, certify,
 
disclose and optimize emissions of Scope 1,
 
Scope 2 and Scope 3 Operational in line with regulation
and all applicable categories of GHG Protocol
 
by 2025
Carbon credits (nature-based carbon removal projects
 
in line with SBTi) for the entirety of natural
 
gas emissions, up
to 3% of the total Bank emissions (Scope 1 & 2) by 2025
Develop Long-term Energy
 
Plan (including self-production and PPA
 
options) by 2025
Maintain and update
 
detailed Operational
 
Net Zero
 
Action Plan (SBTi
 
aligned, baseline year
 
2019) for
 
Scope 1 & 2
(Net-Zero by 2033) and for
 
Scope 3 (Net-Zero by 2050).
The
 
operational
 
Net Zero
 
action plan
 
is complemented
 
by milestones,
 
KPIs, annual
 
targets and
 
long-term
 
interim targets,
serving
 
the
 
declared
 
commitments.
 
Links
 
are
 
established
 
with
 
Transformation
 
streams
 
as
 
well
 
as
 
corresponding
 
ISO
Management System standards, to
 
ensure substantiation and certification of activities,
 
validate target setting
 
and measured
performance,
 
and systematically monitor progress
 
through internal reviews
 
and external assurance.
2024 was the third year of implementation
 
of Eurobank’s operational
 
impact strategy,
 
with the following
 
completed actions
demonstrating progress:
Update
 
of
 
the
 
operational
 
Net
 
Zero
 
Roadmap
 
and
 
transition
 
curves
 
with
 
2023
 
data,
 
in
 
line
 
with
 
the
 
transition
pathways that are aligned
 
with the Paris Agreement
 
target of limiting global warming to 1.5
o
 
C.
Verified operational
 
carbon footprint for
 
2023 as per ISO 14064, in line with National Climate
 
Law stipulations.
Considerable
 
reduction
 
of 5.04%
 
in purchased
 
electricity consumption,
 
reduction
 
of 10.16%
 
of equivalent
 
Scope 2
emissions and
 
reduction of
 
13.15%
 
of equivalent Scope
 
1 &2 emissions
 
(surpassing the
 
4.7% 2024 target)
 
in 2024,
compared to 2023.
97.96%
 
of total electricity consumed
 
in 2024 was sourced
 
from Renewable
 
Energy Sources
 
(certified guarantees
 
of
origin and self-production).
94.79%
 
of Eurobank's
 
leased
 
vehicles
 
are
 
plug-in/electric
 
(new
 
contracts),
 
as part
 
of its
 
efforts
 
to accelerate
 
the
complete replacement of its fleet with electric
 
or hybrid vehicles.
Additional chargers for
 
electric vehicles were installed in central
 
buildings.
Eurobank certified
 
its new Headquarters Building with LEED (Gold) and increased its certified
 
green buildings to 20
(LEED, BREEAM certifications).
Photovoltaic (PV) installations have been
 
completed under the Net
 
Metering principle in
 
the Nea Ionia
 
and Acharnes
buildings during 2023, Energy self-production
 
started in May 2024 in N. Ionia complex and in
 
July 2024 in Acharnes
building. Energy self-production
 
of 787.87
 
MWh from solar panels.
 
In 2024, the environmental
 
licensing process for
 
two PV standalone parks in central
 
Greece was initiated.
 
Completion of Eurobank’s Energy
 
profiling Report in the framework
 
of the development
 
of a long-term energy plan
for Bank’s building portfolio.
The Group recognises that the
 
most significant part of its impact
 
on climate arises from the financing it extends to its clients.
Therefore,
 
the
 
second
 
pillar
 
of
 
its
 
Sustainability
 
Strategy,
 
Financed
 
Impact
 
Strategy,
 
evolves
 
around
 
the
 
following
 
key
components:
Sustainable
 
financing:
 
Development
 
of
 
strategies
 
that
 
will
 
promote
 
the
 
green
 
transition
 
of
 
the
 
Group’s
 
clients
through sustainable financing.
Portfolio
 
alignment
:
Gradual alignment of
 
the Group’s
 
portfolio
 
with sectoral
 
transition pathways
 
that are aligned
with the 1.5°C climate transition
 
scenario.
Net Zero
 
strategy:
 
Sectoral
 
decarbonisation
 
targets covering
 
the
 
Group’s
 
lending portfolios,
 
with phased
 
target-
setting up to 2050.
In line with its commitment to address climate
 
change, the Group has joined
 
the Net-Zero
 
Banking Alliance (NZBA), a bank-
led, UN-convened
 
alliance of
 
banks worldwide,
 
reinforcing
 
its dedication
 
to aligning
 
its lending
 
and investment
 
portfolios
with net-zero
 
emissions by 2050 or sooner,
 
in line with the most ambitious targets set by
 
the Paris Climate Agreement.
 
As a
 
result,
 
the
 
Group
 
is now
 
taking the
 
next step
 
to identifying
 
and disclosing
 
its first
 
set of
 
sectoral
 
Net Zero
 
targets. In
doing so, it
 
aims to actively
 
support the
 
decarbonisation
 
policy agenda
 
and play a
 
pivotal
 
role
 
in channeling capital
 
flows
towards the
 
transition of key
 
sectors in the short,
 
medium and long-term time
 
horizons. Specifically,
 
the Group
 
has initiated
the process of developing sectoral, financed emissions reduction targets based on the NZBA
 
framework, for some of the most
carbon-intensive and, therefore,
 
most relevant and impactful sectors and portfolios.
 
It approaches its target setting process
on a
 
sector/portfolio basis, to factor in specific
 
elements of the climate
 
transition. It also adheres to
 
proven industry standards
(e.g. NZBA, PCAF) and accredited science-based decarbonisation
 
scenarios, in line with a 1.5
o
C objective by 2050.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Based
 
on
 
the
 
NZBA
 
framework,
 
the
 
Group
 
has
 
identified
 
its
 
priority,
 
carbon
 
intensive
 
sectors,
 
representing
 
a
 
significant
proportion of
 
its financed emissions,
 
and is developing
 
its 2030 emission
 
reduction targets.
 
The first
 
wave of sector
 
targets
will be finalised within 2025, including phased target setting up to 2050, and operationalization of its Net Zero 2030 targets.
 
The activity
 
of the
 
Group is
 
part of the
 
EU Paris-aligned
 
Benchmark activities. As
 
part of the
 
Pillar 3 disclosures,
 
the Group
discloses the counterparties in its portfolio that are excluded from the Paris Aligned Benchmark (Consolidated Pillar 3 Report
- 11.4.1 Template 1: Banking book - Climate
 
Change transition risk: Credit quality
 
of exposures by sector, emissions and
 
residual
maturity).
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [ESRS
 
2 SBM-3]
The Group
 
identifies and assesses sustainability-related
 
risks, including Climate-Related and Environmental
 
risks, within the
context of the Risk Identification and Materiality Assessment (RIMA) process,
 
which is performed at least on an annual basis,
or ad-hoc, if necessary. Through the RIMA process, the Group identifies material risks that could potentially have a significant
adverse impact on its financials, capital base, liquidity
 
position or business model, as well as
 
identifies any possible emerging
risks that
 
the
 
Group
 
might be
 
exposed to.
 
In this
 
context, the
 
Group
 
takes
 
into consideration
 
several
 
different
 
sources
 
to
identify new
 
risks, such as
 
the Single
 
Supervisory Mechanism
 
(SSM), the
 
Supervisory Priorities,
 
the EU
 
& national
 
legislation
changes, developments
 
in the
 
regulatory
 
landscape in
 
general,
 
along with
 
EBA Guideline
 
or Basel
 
Committee on
 
Banking
Supervision (BCBS) reports.
The
 
Group
 
has
 
identified
 
as
 
sustainability
 
risks,
 
the
 
risks
 
deriving
 
from
 
potential
 
loss
 
or
 
negative
 
impact
 
to
 
the
 
Group,
including loss/damage to physical assets, disruption
 
of business or system failures,
 
transition expenditures
 
and reputational
effects from
 
the adverse consequences
 
of climate change and environmental degradation.
As sustainability
 
risks interact
 
with other
 
risks and result
 
in both
 
direct distributional
 
impacts and
 
indirect macroeconomic
impacts,
 
the
 
Group
 
understands
 
that
 
careful
 
consideration
 
of the
 
cross-cutting
 
nature
 
thereof
 
is necessary
 
to ensure
 
the
appropriate implementation
 
of adaptation activities. Thus, the
 
Group considers sustainability risks as drivers
 
of existing risk
types, undertaking a holistic and systemic approach when examining the complex links between sustainability risks and
 
both
financial
 
and
 
non-financial
 
risks.
 
Eurobank
 
has
 
integrated
 
sustainability
 
risks
 
elements
 
into
 
its
 
existing
 
risk
 
management
processes, creating additional
 
procedures, policies
 
and tools so that these risks can be properly
 
identified and measured.
The
 
Group
 
has identified
 
the
 
risk drivers
 
related
 
to climate
 
change and
 
environmental
 
degradation,
 
through
 
internal
 
and
external sources
 
of knowledge, that
 
are most relevant
 
for the
 
business environment
 
in which it operates.
 
In this context, the
Group has identified the following
 
list of climate-related and environmental
 
risk drivers:
Climate-related risks
Transition
 
risk
 
Financial loss
 
that
 
can
 
result,
 
directly
 
or indirectly,
 
from
 
the
process
 
of
 
adjustment
 
towards
 
a
 
lower-carbon
 
and
 
more
environmentally
 
sustainable
 
economy.
 
This
 
transition
 
may
entail extensive behavioral,
 
policy and regulatory,
 
as well as
technological
 
changes,
 
to
 
address
 
mitigation
 
and
adaptation
 
requirements
 
relating
 
to
 
impacts
 
deriving
 
from
climate
 
change and
 
environmental
 
risks.
 
Depending on
 
the
nature,
 
speed,
 
and
 
focus
 
of
 
these
 
changes,
 
transition
 
risks
may pose varying
 
levels of
 
financial and reputational
 
risk to
organisations
Physical risk
Financial
 
impact
 
of
 
a
 
changing
 
climate,
 
including
 
more
frequent
 
extreme
 
weather
 
events
 
and
 
gradual
 
changes
 
in
climate, as well as the impact of environmental degradation,
such
 
as
 
air,
 
water
 
and
 
land
 
pollution,
 
water
 
stress,
biodiversity loss and deforestation
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Behavioural Changes
Behavioral
 
changes of consumers,
 
suppliers, employees
 
and
investors
 
could
 
trigger
 
shifts
 
in
 
supply
 
and
 
demand
 
for
certain
 
commodities,
 
products,
 
services
 
and
 
capital
 
as
climate-related
 
and
 
environmental
 
risks
 
and
 
opportunities
are
 
increasingly
 
taken
 
into
 
account.
 
Changing
 
client
 
or
community perceptions
 
of an
 
organisation’s
 
contribution to
or detraction from the transition
 
to a lower-carbon economy
and developments
 
aimed at halting
 
or reversing
 
damage to
nature,
 
can
 
all
 
result
 
in
 
decreased
 
revenue,
 
changes
 
in
 
the
revenue
 
mix
 
and
 
major
 
capex
 
requirements,
 
while
 
they
 
are
also
 
a
 
potential
 
source
 
of
 
reputational
 
risk
 
for
 
many
corporates.
Acute Hazards
Extreme weather
 
-related events
 
such as storms,
 
floods, fires
or
 
heatwaves
 
and
 
other
 
environmental
 
hazards
 
such
 
as
geologic events
 
or changes in ecosystem
 
equilibria (e.g., soil
pollution) that
 
may damage production/
 
operation
 
facilities
and disrupt value chains.
Policy & Regulatory Changes
The objectives of policy
 
actions and regulatory requirements
generally fall
 
into two categories:
1.
Policy
 
actions
 
that
 
aim
 
at
 
constraining
 
actions
 
that
contribute to the adverse
 
effects of climate change (e.g.,
implementing
 
carbon-pricing
 
mechanisms
 
to
 
reduce
greenhouse
 
gas
 
emissions,
 
energy
 
use
 
toward
 
lower
emission
 
sources)
 
and
 
environmental
 
degradation
 
(e.g.
restrictions
 
on water
 
consumption levels,
 
ban of
 
certain
environmentally damaging materials/chemicals).
2.
Policy
 
actions
 
that
 
seek
 
to
 
promote
 
adaptation
 
to
climate
 
change
 
(e.g.,
 
adopting
 
energy-efficiency
solutions,
 
encouraging
 
greater
 
water
 
efficiency
measures,
 
and
 
promoting
 
more
 
sustainable
 
land-use
practices)
 
and
 
environmental
 
degradation
 
(e.g.
 
more
efficient water management
 
practices).
Both the
 
nature and the
 
timing of policy changes
 
determine
the extent of the associated risk and its subsequent financial
impact.
 
Another
 
important
 
risk
 
is
 
litigation
 
or
 
legal
 
risk.
 
As
the
 
value
 
of loss
 
and damage
 
arising from
 
climate
 
change
and environmental
 
degradation
 
grows,
 
litigation risk
 
is also
likely to increase.
Chronic Hazards
Progressive
 
shifts, such as increasing temperatures,
 
sea level
rise, water
 
stress, biodiversity
 
loss, land use
 
change, habitat
destruction and
 
resource
 
scarcity.
 
This can
 
directly result
 
in,
for example, damage to property or reduced
 
productivity, or
indirectly
 
lead to
 
subsequent events,
 
such as
 
the
 
disruption
of supply chains
Technological
 
Changes
Technological
 
improvements
 
or innovations that support the
transition
 
to
 
a
 
lower-carbon,
 
energy
 
efficient
 
economic
system as well as
 
the substitution of products or services with
a lower / improved impact on nature or reduced dependency
on nature can have a significant impact on organisations, as
different
 
industries may encounter
 
difficulties in adapting to
technology
 
advancements
 
toward
 
greener
 
practices.
 
For
example, the development and use of
 
emerging technologies
such as renewable energy, battery storage, energy efficiency,
and
 
carbon
 
capture
 
and
 
storage
 
will
 
affect
 
certain
organisations,
 
their
 
production
 
and
 
distribution
 
costs,
 
and
ultimately the
 
demand for
 
their
 
products
 
and services
 
from
end
 
users.
 
The
 
timing
 
of
 
technology
 
development
 
and
deployment is also a key uncertainty in assessing technology
risk.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Environmental Risks
Water Scarcity
Water
 
scarcity
 
is
 
assessed
 
in
 
the
 
context
 
of
 
environmental
risk.
 
However,
 
environmental
 
risk
 
is
 
not
 
further
 
split
 
into
physical and transition hazards at this stage, due to a lack
 
of
appropriate
 
data
 
and
 
the
 
overall
 
early
 
stage
 
of
 
the
corresponding
 
environmental
 
risk
 
management
 
framework;
rather,
 
water
 
scarcity
 
assessment
 
embodies
 
both
components
 
altogether.
 
The
 
analysis
 
for
 
environmental
hazards
 
will
 
resemble
 
the
 
analysis
 
for
 
climate
 
risk
 
going
forward, as the
 
risk environment matures.
Biodiversity Loss
Biodiversity
 
loss
 
as
 
a
 
relevant
 
risk
 
for
 
its
 
operations.
Biodiversity loss is an average loss in biological diversity over
time and/or space that leads to a decline in the ability of the
natural
 
world
 
to generate
 
flows of
 
ecosystem services,
 
with
negative
 
economic
 
impacts
 
on
 
individuals,
 
households,
organisations and countries.
As the global financial sector is increasingly recognising the importance of understanding
 
and managing sustainability risks,
scenario
 
analysis
 
has
 
emerged
 
as
 
a
 
valuable
 
tool
 
for
 
assessing
 
the
 
potential
 
impacts
 
of
 
climate
 
change
 
on
 
financial
institutions.
 
Scenario
 
analysis enables
 
Eurobank
 
to
 
evaluate
 
its resilience
 
and adaptability
 
in
 
different
 
climate-related
 
scenarios.
 
The
methodological
 
approach adopted allows
 
to measure impacts,
 
based on different
 
scenarios and time
 
horizons (2030, 2040
and 2050). The study aims to enhance Group’s
 
understanding of climate-related risks, inform strategic
 
decision making, and
facilitate the integration
 
of climate considerations
 
into its risk management framework.
The
 
purpose
 
of
 
the
 
scenario
 
analysis
 
is
 
to
 
inform
 
the
 
Group
 
to
 
proactively
 
identify
 
potential
 
vulnerabilities,
 
seize
opportunities,
 
and align
 
its
 
business
 
strategies
 
with
 
the
 
transition
 
to a
 
low-carbon
 
economy.
 
The
 
integration
 
of
 
scenario
analysis,
 
plays a
 
crucial role
 
in shaping
 
its strategy,
 
by
 
providing
 
valuable
 
insights into
 
the
 
potential
 
impacts
 
of climate-
related risks and opportunities on its financial performance
 
and long-term sustainability.
Forward-looking
 
analysis is especially important,
 
but also challenging. Efforts
 
to mitigate and adapt
 
to climate change
 
are
without historical precedent,
 
and many aspects regarding
 
the timing and magnitude
 
of climate change in specific
 
contexts
are uncertain.
The
 
set of
 
scenarios
 
that are
 
utilised by
 
the
 
Group,
 
include four
 
representative
 
scenarios
 
by the
 
Network for
 
Greening the
Financial System
 
(NGFS) and
 
two Representative
 
Concentration
 
Pathways
 
(RCPs) climate
 
scenarios.
 
More specifically,
 
the
scenarios used are:
NGFS scenarios
Representative Concentration
 
Pathways (RCPs)
climate scenarios
1.
Orderly: Net Zero 2050
, where climate
 
policies involve early,
ambitious action and the impacts are
 
low for both physical
 
and
transition Risks
1.
RCP2.6,
 
that incorporates strong
 
climate
policies and limit the increase in average
global temperature
 
to below 2
o
C.
2.
Disorderly:
Delayed Transition
, in which climate policies are not
introduced until 2030 and the
 
outcome has a higher impact on
transition risk.
3.
Hot house word: Current
 
Policies
, with limited climate policies
and severe physical
 
risks and irreversible
 
changes, including
higher sea level
2.
RCP8.5,
implying strong climate changes
and the necessity of strong
 
adaptation to
the new conditions
4.
Too-little-too-late: Fragmented
 
World
, in which delayed and
divergent climate policy
 
ambition globally,
 
leads to elevated
transition risks due to the overall
 
ineffectiveness
 
of the
transition.
The scenario analysis informs
 
the Group’s strategy
 
and decision making. The results
 
which provide a comparison of financial
evolutions
 
by sectors and geographies
 
over
 
a range of scenarios
 
and time horizons, indicate
 
that Group’s
 
strategy remains
adaptive.
2.2.3
Impact, risk and opportunity management
Description of the processes to identify and assess material climate-related impacts, risks and
 
opportunities [ESRS 2 IRO-
1]
Eurobank identifies material impacts, risks,
 
and opportunities related to
 
climate—such as climate change
 
adaptation, climate
change mitigation and energy
 
—through a comprehensive
 
DMA. This approach integrates
 
industry benchmarks, stakeholder
insights, and financial relevance to ensure
 
a robust evaluation
 
of climate-related topics.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The impacts, risks and opportunities associated with
 
Climate change are displayed in the
 
table below:
Climate change adaptation
Impact
Positive
Actual
Eurobank
 
actively
 
contributes
 
to
 
GHG
 
reduction
 
ambitions
 
and
 
targets,
 
set
 
by
 
the
 
EU,
regulations, central
 
governments, and other
 
bodies, through its sustainable financings and
integration of climate risk in the
 
risk management framework.
Negative
Potential
Eurobank’s
 
business
 
strategy
 
may
 
encompass
 
the
 
continuation
 
of
 
financing
 
to
 
carbon-
intensive sectors.
Risk
The
 
actions
 
required
 
by
 
Eurobank’s
 
clients
 
to
 
address
 
climate
 
change
 
mitigation
 
and
adaptation
 
requirements
 
relating
 
to
 
impacts
 
deriving
 
from
 
climate
 
change
 
may
 
impact
Eurobank’s credit risk.
Opportunity
Meeting climate objectives linked to legal, regulatory and
 
other stakeholders’
 
requirements
for
 
Eurobank’s
 
clients, entails
 
the opportunity
 
for
 
Eurobank
 
to finance
 
the
 
transition
 
of its
clientele.
Climate change mitigation
Impact
Positive
Actual
Eurobank implements a robust
 
climate change mitigation strategy aiming to minimise
 
the
consequences of climate change for its portfolio.
 
Negative
Actual
Eurobank’s
 
portfolio
 
faces
 
negative
 
impacts
 
due
 
to
 
the
 
absence
 
of
 
a
 
climate
 
change
mitigation strategy.
Risk
The
 
actions
 
required
 
by
 
Eurobank’s
 
clients
 
to
 
address
 
climate
 
change
 
mitigation
 
and
adaptation
 
requirements
 
relating
 
to
 
impacts
 
deriving
 
from
 
climate
 
change
 
may
 
impact
Eurobank’s credit risk.
Opportunity
Meeting climate objectives linked to
 
legal, regulatory and other stakeholders’ requirements
for Eurobank’s
 
clients, entails
 
the opportunity
 
for Eurobank
 
to finance
 
the transition
 
of its
clientele.
Energy
Impact
Positive
Actual
Eurobank
 
implements
 
measures
 
to
 
reduce
 
energy
 
consumption,
 
leading
 
to
 
enhanced
efficiency in operations.
 
Negative
Actual
Eurobank
 
contributes to
 
climate change
 
through
 
its in-house
 
operations
 
that contribute
to the release of emissions.
Eurobank
 
has performed
 
an in-depth
 
analysis regarding
 
climate change
 
transition
 
and physical
 
risks within
 
the
 
context of
the Task
 
Force
 
on Climate-related Financial Disclosures (TCFD)
 
recommendations.
 
The
 
analysis
 
aims
 
to
 
enhance
 
Eurobank’s
 
understanding
 
of
 
sustainability
 
risks,
 
inform
 
strategic
 
decision-making,
 
and
facilitate
 
the
 
integration
 
of
 
climate
 
considerations
 
into
 
its
 
risk
 
management
 
framework,
 
as
 
well
 
as
 
to
 
inform
 
Eurobank’s
approach on identifying vulnerabilities,
 
seizing opportunities and aligning business strategies
 
within the context of the
 
Task
Force
 
on
 
Climate-related
 
Financial
 
Disclosures
 
(TCFD)
 
recommendations.
 
Please
 
refer
 
to
 
the
 
latest
 
TCFD
 
report
 
,
Group’s
“Climate - related & Environmental
 
Risk Report” “4.4 CR&E Risks Scenario Analysis” chapter
.
 
Transition
 
risk impacts
The Group explored 4 different
 
scenarios (stated in section 2.2.2.) as part
 
of its strategic planning and risk management with
time horizons up to 2050. The
 
overview of horizontal impacts includes
 
the following:
Overall,
 
the net impact on the economic activity (GDP) of Greece
 
is found to be small but negative in the long term
in all scenarios examined, compared with Hot House
 
World Scenario. However,
 
changes in the energy system in any
scenario examined
 
do not have
 
any critical impact
 
on the structural
 
growth drivers
 
of the economy
 
hence a stable
economic growth is projected
 
in all scenarios examined.
The low ambition scenarios
 
do not have any significant impact in the
 
short term.
Positive
 
impacts
 
are
 
brought
 
into
 
the
 
economy
 
mainly
 
through
 
energy
 
efficiency
 
improvements
 
as
 
these
 
are
characterized
 
by
 
high
 
multipliers
 
and
 
domestic
 
content.
 
Energy
 
efficiency
 
improvements
 
mainly
 
addresses
 
the
construction sector
 
(domestic capacity)
 
that is
 
characterized
 
by a
 
high output
 
and employment
 
multiplier.
 
Energy
efficiency improvements
 
also reduce the
 
dependency on imported fossil fuels and on electricity.
In the
 
high ambition
 
scenarios, the
 
Greek economy
 
is benefited from
 
reducing its
 
dependency on fossil
 
imports as
gradually its system is fully decarbonized.
 
However
 
increased penetration of RES
 
further burdens
 
the trade balance
as most of the equipment is imported.
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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The
 
impact on
 
household income
 
is mixed:
 
An increase
 
in employment
 
in high
 
value-added sectors
 
takes place
 
in
order to support the deployment
 
of clean energy technologies. A decrease in employment in brown
 
sectors leads to
skills shortage
 
and increasing
 
unemployment
 
in ages
 
where
 
upskilling –
 
reskilling
 
has low
 
potentials –
 
leading to
long term unemployment. The
 
impacts are highly contrasted among regions within Greece
 
although the net impact
is small.
The
 
key
 
sector
 
benefiting
 
in
 
the
 
high
 
ambition
 
scenarios
 
are
 
the
 
power
 
generation
 
utilities.
 
Significant
 
positive
effects
 
on
 
electricity
 
production
 
driven
 
by
 
the
 
electrification
 
of
 
the
 
energy
 
system
 
(despite
 
the
 
energy
 
efficiency
improvements
 
the
 
electrification
 
of
 
the
 
economy
 
is
 
significant
 
 
in
 
particular
 
through
 
the
 
electrification
 
of
 
the
transport sector the net demand for
 
electricity increases significantly).
Negative
 
impacts are
 
mainly driven
 
by
 
import requirements
 
(assuming
 
that
 
the
 
market
 
share
 
of Greece
 
in clean
energy
 
technologies
 
will
 
not
 
change
 
considerably
 
in
 
the
 
future
 
 
significant
 
share
 
of
 
the
 
equipment
 
required
 
to
decarbonize the energy
 
system is imported – PV,
 
wind turbines, electric vehicles, batteries).
Key outcomes from
 
the transition risk scenario
 
analysis include the following:
Low ambition scenarios in the short-term have moderate
 
impacts on GDP and sectoral production as carbon prices
do not increase much production costs but also provide
 
a weak signal for investments.
Too Little too late and Delayed
 
transition scenarios have
 
marginal virtually zero impact on the
 
short term.
Net zero 2050 is projected
 
to have significant contrasted sectoral
 
impacts both in the short and long term.
Services
 
are
 
benefited
 
to
 
the
 
extent
 
that
 
they
 
operate
 
supplementary
 
to
 
the
 
deployment
 
of
 
the
 
clean
 
energy
technologies (design, implementation, financing etc.). Services
 
are characterized by low dependency on energy
 
and
openness to trade hence
 
higher energy costs leave
 
the competitiveness of the
 
sector virtually unaffected.
The demand of clean technologies increases
 
with positive impact in their
 
production. Biofuels,
 
batteries, PV,
 
energy
saving equipment/ materials and
 
Wind are essential
 
for the
 
decarbonization of the
 
system. Cost maturity achieved
both in the Net Zero
 
2050 and Delayed Transition
 
Scenarios.
The higher
 
carbon price
 
in Emissions Trading
 
Scheme
 
- ETS (incl.
 
the extended
 
ETS, Transport
 
& Services)
 
Net Zero
and Delayed Transition imply negative impact on GHG intensive industries - when not sufficient measures
 
are taken
to mitigate international competitiveness.
Physical risk impacts
Eurobank
 
assesses
 
the
 
physical
 
climate
 
risks
 
related
 
to
 
its
 
clients’
 
activities
 
following
 
an
 
analytical
 
and
 
transparent
methodological approach,
 
considering both:
Chronic effects: impact on companies’ revenue or operating costs due to
 
the long-term changes in weather patterns.
Acute effects: damages to companies’ assets or
 
revenue losses attributed to extreme
 
weather
 
events.
To this end, the
 
Group utilises two Climate Scenarios
 
for the analysis of physical
 
impacts, namely
1.
 
RCP 2.6, which is a stringent mitigation scenario
 
with the aim to keep global
 
warming below 2ºC, consistent with
the goals of the Paris
 
Agreement
2.
RCP 8.5, which is a scenario
 
with weak and delayed
 
action for
 
reducing global GHG
 
emissions. It is a “reference”
 
or
worst-case
 
scenario
 
where
 
GHG emissions
 
keep increasing
 
throughout
 
the
 
whole century
 
as it
 
incorporates
 
weak
policies for
 
tackling climate
 
change. In
 
other
 
words,
 
it is
 
associated with
 
hot house
 
world
 
scenarios,
 
with average
temperature
 
increases exceeding 4°C.
Chronic risk effects
The
 
analysis of
 
chronic
 
effects
 
has been
 
performed
 
for
 
2030,
 
2040 and
 
2050
 
for
 
13 regions
 
in Greece.
 
The
 
Group
 
utilised
climate indicators that are considered as the drivers
 
of the potential chronic impacts of climate change on the companies of
the respective economic sectors, affecting either their operating costs or their revenues. In the context of
 
the present analysis,
these effects either
 
directly (due to the structure of the climate indicators used) or indirectly (through the input-output tables
of the
 
respective
 
economies or
 
other
 
econometric
 
models)
 
were
 
expressed
 
as percentage
 
changes in
 
the
 
turnover
 
of the
respective
 
businesses. At
 
the
 
final stage
 
of the
 
process,
 
specific thresholds
 
were
 
adopted as
 
regards
 
the
 
estimated losses
due to climate change, with a view the
 
related risks to be characterized
 
as negligible, low, medium,
 
high or very high.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Sector
 
2030
2040
2050
Agriculture
High
Very high
Very high
Construction
Negligible
Low
Low
Electricity Supply
Low
Low
Medium
Manufacturing
Low
Low
Low
Oil and Gas
Negligible
Negligible
Negligible
Real estate activities
Negligible
Negligible
Negligible
RES
Negligible
Negligible
Negligible
Transporting and Storage
Low
Low
Low
Water supply
Low
Low
Low
Wholesale and retail
Negligible
Negligible
Negligible
Acute risk effects
During the analysis of acute effects,
 
the Group takes
 
into consideration several
 
extreme phenomena, such as:
Fluvial floods (high-water levels in river
 
channels, causing dyke breach)
Pluvial floods (rainfall intensity exceeding
 
infiltration capacity)
Extreme heat
Wildfires
Water scarcity
Landslides
Coastal floods
The quantitative
 
analysis considers three main dimensions:
1.
Climate Hazards
2.
Exposure
3.
Vulnerability
The
 
climate
 
risk
 
attributed
 
to
 
each
 
extreme
 
phenomenon
 
under
 
consideration,
 
is
 
calculated
 
by
 
geographical
 
area
 
and
economic activity as the product of the three indicators formulated to evaluate the abovementioned
 
dimensions. Ultimately,
adopting appropriate thresholds,
 
this climate risk attributed
 
to acute effects
 
is characterized, similarly to chronic
 
effects, as
negligible, low,
 
medium, high, or very high.
 
Sector
Assessment
Agriculture
Negligible
Construction
Negligible
 
Electricity Supply
Low
Manufacturing
Negligible
Oil and Gas
Negligible
 
Real estate activities
Negligible
RES
Negligible
 
Transporting and Storage
Negligible
Water supply
Low
Wholesale and retail
Negligible
2.2.4
Policies & Actions
Policies related to climate change
 
mitigation and adaptation [E1-2]
Τhe Group
 
has adopted policies to manage material
 
impacts, risks, and opportunities related
 
to climate change mitigation
and adaptation
 
and the
 
environment.
 
Policies
 
affecting
 
internal
 
stakeholders
 
are
 
available to
 
the
 
Group's
 
intranet,
 
while
those referring
 
to external
 
stakeholders,
 
such as
 
the Group's
 
Code of
 
Conduct and Ethics,
 
are available
 
through
 
corporate
website.
 
Eurobank
 
is
 
committed
 
to
 
engaging
 
with
 
stakeholders
 
by
 
ensuring
 
a
 
high
 
level
 
of
 
accountability
 
in
 
policy
development
 
and
 
implementation.
 
Policies
 
are
 
approved
 
by
 
the
 
appropriate
 
Governance
 
bodies
 
such
 
as
 
the
 
Board
 
of
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Directors or specialized
 
committees, which ensure
 
that there
 
is alignment with
 
the Group's
 
strategic goals
 
and stakeholder
interests. The
 
relevant policies
 
are outlined in
 
the below
 
table as per the
 
Minimum Disclosure Requirements
 
with regards
 
to
policies (MDR-P) defined in ESRS 2.
Name of key policy
Addressed key areas of
 
policy
Relevant material identified
impact, risk or opportunity
Operational impact climate
 
change-related policies
Environmental & Energy
 
Management
Systems
- Energy management
- Energy assessment of facilities
- GHG emissions
- Environmental & Energy
 
targets
- Waste management
- Νatural resources
 
management
- Water resources
 
management
Energy
 
Climate change adaptation
Climate change mitigation
Energy Management Policy
 
Statement
-Energy performance
 
improvement
-Renewable energy
 
deployment
-Regulatory compliance
Energy
 
Climate change adaptation
Climate change mitigation
GHG emissions Inventory Report
 
- Energy management
- GHG emissions
- Operational GHG emissions
- Operational Net
 
Zero
Energy
 
Climate change adaptation
Climate change mitigation
Environmental Report
-Energy management
-Operational GHG emissions
-Operational Net
 
Zero
-Water consumption
-Solid Waste Management and
 
Recycling
-Noise
Energy
 
Climate change adaptation
Climate change mitigation
Water Management
 
Policy Statement
- Water resources
 
management
- Water consumption
-
Environmental Policy
 
Statement
-Energy management
-Climate change adaptation
-Climate change mitigation
-Impact of activities
Energy
Climate change adaptation
Climate change mitigation
Financed impact climate change-related
 
policies
Sustainable Finance Framework
-Renewable energy
 
deployment
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
 
Climate change mitigation
Sustainable Investment Framework
-Renewable energy
 
deployment
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
 
Climate change mitigation
Green Bond Framework
-Energy efficiency
-Renewable energy
 
deployment
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
 
Climate change mitigation
Sustainability Risk Management Policy
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
Climate change mitigation
Climate Risk Stress Test
 
Framework.
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
 
Climate change mitigation
Group Environmental
 
& Social Policy
-Climate change adaptation
-Climate change mitigation
Climate change adaptation
Climate change mitigation
Eurobank recognises
 
the interdependency
 
between impacts on
 
the environment,
 
as well as
 
the risks and
 
opportunities they
present.
 
As
 
such,
 
we
 
have
 
implemented
 
policies
 
that
 
cover
 
several
 
material
 
sustainability
 
matters,
 
including
 
matters
addressed by more than one topical ESRS.
 
The following
 
policies address more than one
 
sustainability matter.
The
 
overarching
Sustainability
 
Policy
 
Framework
 
outlines
 
the
 
approach
 
for
 
adherence
 
to
 
applicable
 
regulatory
requirements and voluntary
 
initiatives as well
 
as adopted standards and guidelines enabling Eurobank’s
 
contemporary and
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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continuously
 
updated
 
approach
 
towards
 
Sustainability,
 
in
 
line
 
with
 
international
 
best
 
practices.
 
The
 
Sustainability
 
Policy
Framework
 
sets the foundation
 
towards integration
 
of Sustainability into Eurobank’s business model
 
and operations.
The subject matter
 
of the operational
 
impact policies is outlined below:
The
Environmental
 
& Energy
 
Management
Systems outline
 
how the
 
various Environment
 
and Energy
 
policies of
 
Eurobank
interact,
 
as
 
well
 
as
 
environmental
 
management
 
practices,
 
responsibilities
 
and
 
targets.
 
These
 
ISO
 
certified
 
Management
Systems cover waste, natural resources,
 
water and energy systems management, GHG emissions, environmental
 
and energy
targets, obligations compliance, training and staff awareness of
 
Eurobank’s operations and upstream and downstream value
chain.
 
Eurobank
 
monitors
 
and
 
reviews
 
the
 
information
 
related
 
to
 
interested
 
parties
 
and
 
stakeholders
 
and
 
their
 
related
requirements,
 
defining a
 
specific
 
cooperation
 
framework
 
and communication
 
method
 
for
 
each
 
case.
 
Accountable
 
for
 
the
continuing
 
suitability,
 
adequacy
 
and
 
effectiveness
 
of
 
the
 
Environmental,
 
Energy
 
and
 
other
 
Sustainability-related
 
ISO
Management
 
Systems
 
are
 
the
 
Sustainability
 
Management
 
Committee,
 
the
 
Environmental
 
System
 
Manager,
 
the
Environmental Coordinators
 
and the Building Administrators.
 
The
Environmental Policy
 
Statement
 
outlines its commitment to the protection
 
of environment, seeking the optimum use of
natural resources,
 
mitigating its environmental impact, adapting to climate change, protecting biodiversity
 
and ecosystems,
and preventing waste pollution.
The
Energy
 
Management
 
Policy
 
Statement
outlines
 
its
 
commitment
 
to
 
responsible
 
energy
 
management
 
across
 
all
 
its
facilities, including branches and administration
 
buildings. Key objectives include the
 
continuous improvement of the
 
energy
performance
 
and the
 
Energy Management
 
System (EnMS), providing
 
the information
 
and resources
 
needed to achieve
 
the
goals
 
and
 
energy
 
objectives,
 
and
 
ensuring
 
compliance
 
with
 
applicable
 
legal/regulatory
 
requirements,
 
and
 
other
commitments of the Bank regarding energy use, energy
 
consumption and energy efficiency.
 
Eurobank aims to streamline the
energy use by minimising the energy costs, the environmental
 
impacts, and fossil fuel use, while promoting renewable energy
sources and maintaining business/operational goals and
 
a suitable working
 
environment for its employees. The policy applies
across Eurobank's operations,
 
focusing on enhancing energy efficiency and supporting the use of
 
energy-efficient equipment.
It is backed by
 
top management, which
 
is responsible for providing resources to implement and
 
improve energy performance.
 
The
Water Management Policy Statement
 
outlines its commitment to the responsible management of water use by seeking
the optimal use of natural
 
resources as part of the
 
overall
 
Environmental culture.
The
Environmental
 
Report
includes
 
an overview
 
of environmental
 
management
 
system and
 
an analysis
 
of environmental
performance. This report covers the operating context, the environmental legislation, targets and performance and personnel
training.
 
The
 
Report
 
applies
 
across
 
Eurobank's
 
operations,
 
focusing
 
on
 
communicating
 
about
 
energy
 
performance
 
and
setting targets.
 
Eurobank
 
recognises
 
the
 
importance
 
of engaging
 
in close
 
collaboration
 
and promoting
 
dialogue
 
with
 
all
stakeholders,
 
both
 
natural
 
and
 
legal
 
entities.
 
Accountable
 
for
 
the
 
implementation
 
of
 
the
 
Report
 
are
 
the
 
Sustainability
Management
 
Committee,
 
chaired
 
by
 
the
 
Deputy
 
Chief
 
Executive
 
Officer,
 
Group
 
Chief
 
Operating
 
Officer
 
(CΟΟ)
 
&
International Activities.
The
GHG emissions
 
Inventory Report
 
outlines the
 
best practices
 
implemented regarding
 
consistency and completeness
 
in
the calculation
 
of the
 
Bank’s greenhouse gas
 
(GHG) emissions for
 
all its facilities
 
in Greece.
 
It covers
 
100% of its operations
and has been prepared in accordance with
 
the requirements
 
of the ISO 14064-1:2018 standard.
To
 
follow
 
these policies,
 
the Bank
 
applies certified
 
management systems,
 
in accordance
 
with international
 
standards, such
as an Environmental Management System (ISO 14001, EMAS)
 
and an Energy Management System
 
(ISO 50001). Through these
certified management
 
systems, it monitors its performance
 
and minimises its carbon footprint.
The subject matter
 
of selected financed impact policies is outlined below:
The
Sustainable Finance Framework
 
outlines the
 
Group’s
 
sustainable lending solutions
 
offered
 
to its customers,
 
specifying
the applied classification
 
approach and the
 
activities defined as eligible to access sustainable financing (eligible green
 
and
social assets). The SFF scope encompasses a wide range of sustainable lending products, covering
 
both corporate and retail
banking portfolios. The
 
purpose of establishing the SFF is to provide a clear and comprehensive methodology
 
for classifying,
monitoring and reporting
 
sustainable financing.
 
Eurobank
 
has drawn
 
on internationally
 
recognised industry
 
guidelines and
principles for the development
 
of the SFF and is fully committed to being transparent
 
about its sustainability approach. The
Group Senior Sustainability Officer
 
(GSSO) holds the highest level of accountability for the
 
implementation and oversight
 
of
the policy within the
 
organisation.
The
Sustainable
 
Investment
 
Framework
 
policy
 
aims
 
to
 
guide
 
the
 
integration
 
of
 
ESG
 
factors
 
into
 
investment
 
decisions,
ensuring
 
alignment
 
with
 
long-term
 
sustainability
 
goals.
 
Its scope
 
includes
 
both
 
direct
 
and indirect
 
investments
 
across
 
all
sectors,
 
regions,
 
and
 
value
 
chains,
 
with
 
exclusions
 
in
 
areas
 
such
 
as
 
high-risk
 
fossil
 
fuels
 
and
 
activities
 
detrimental
 
to
biodiversity or
 
human rights. The
 
policy applies to
 
all stakeholders
 
involved
 
in the investment
 
process. Accountability
 
for its
implementation lies with the
 
organisation's Group Senior
 
Sustainability Officer (GSSO).
The
Green
 
Bond
 
Framework
 
outlines
 
the
 
principles
 
and
 
criteria
 
for
 
issuing
 
green
 
bonds
 
to
 
finance
 
environmentally
sustainable
 
projects
 
that
 
contribute
 
to
 
climate
 
change
 
mitigation
 
and
 
other
 
environmental
 
goals.
 
Its
 
general
 
objectives
include promoting
 
green investments,
 
while ensuring
 
transparency
 
and accountability in
 
the use
 
of proceeds.
 
The scope
 
of
the framework
 
covers both upstream
 
and downstream activities related to eligible projects, across
 
global geographies, with
exclusions for projects involving
 
fossil fuels, or other environmentally
 
harmful practices. Accountability for
 
its implementation
lies with the organisation's
 
Group Senior Sustainability Officer
 
(GSSO).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The
 
purpose
 
of
 
the
Sustainability
 
Risk
 
Management
 
Policy
is
 
to
 
provide
 
an
 
overview
 
and
 
a
 
common
 
understanding
 
of
Group’s
 
main
 
governance
 
arrangements,
 
as
 
well
 
as
 
tasks
 
performed
 
by
 
the
 
Group
 
Sustainability
 
Risk
 
(GSR)
 
unit,
 
in
 
the
context
 
of
 
Group’s
 
overall
 
Sustainability
 
risks
 
management
 
activities.
 
This
 
policy
 
additionally
 
covers
 
Group’s
 
main
Sustainability risks management pillars, lists the
 
key responsibilities of GSR for
 
the development
 
and implementation of the
Sustainability risk
 
framework and describes the quantitative and qualitative
 
sustainability risks measurement methodologies.
Ongoing dialogue with the Group’s
 
relevant stakeholders,
 
as well as close monitoring of the regulatory
 
framework
 
and best
market practices, ensure the establishment of a well-defined and robust Sustainability Risk
 
Management Policy.
 
Accountable
for
 
the
 
implementation
 
of the
 
policy
 
is GSR
 
and the
 
policy
 
is approved
 
by
 
Management
 
Risk Committee
 
and Board
 
Risk
Committee.
The
Group Climate
 
Risk Stress
 
Test
 
(CRST) Framework
 
accommodates a dedicated
 
governance
 
structure and
 
defines the
minimum requirements for designing, executing, approving, and applying
 
the climate risk stress test. The Framework provides
a transparent
 
and repeatable
 
process
 
for designing
 
and executing
 
the climate
 
risk stress
 
test, as well
 
as for
 
reporting and
evaluating stress test outcomes and determining management actions. The CRST Framework has been developed as per the
overall
 
Stress Testing
 
Policy of
 
the Group,
 
also taking into
 
account the
 
provisions
 
of the
 
ECB Guide on
 
climate-related and
environmental
 
risks and
 
the
 
requirements
 
of the
 
2022 ECB
 
Climate Risk
 
Stress
 
Test.
 
Additionally,
 
the
 
Framework
 
complies
with
 
other
 
best
 
practices
 
and
 
supervisory
 
requirements,
 
such
 
as
 
the
 
EBA
 
Guidelines
 
on
 
institutions’
 
stress
 
testing
(EBA/GL/2018/04).
The
Group
 
has
 
developed
 
an
Environmental
 
and
 
Social
 
Policy
 
that
 
sets
 
the
 
framework
 
of
 
general
 
principles
 
and
requirements
 
for
 
managing
 
environmental
 
and
 
social
 
issues.
 
Through
 
the
 
Environmental
 
and
 
Social
 
Policy,
 
the
 
Group
achieves and maintains compliance
 
with existing national
 
and international environmental and social
 
legislation/regulations,
as well as with its
 
commitments, through a standardised Environmental and Social (E&S) assessment approach. Furthermore,
the objective of the Policy
 
is, inter alia, to ensure timely and accurate reporting to the European Bank for Reconstruction and
Development (EBRD) concerning
 
the management of the
 
Group ESMS (Environmental
 
and Social Management System).
 
As part of its Environmental and Social Policy,
 
Eurobank maintains a list of activities that are excluded from
 
financing, in line
with the exclusion lists
 
of the EBRD. For all
 
financing transactions, the Group ensures that
 
its clients
 
demonstrate an organised
and
 
systematic
 
approach
 
to
 
E&S
 
risk
 
management
 
that
 
complies
 
with
 
applicable
 
local,
 
national
 
and
 
international
environmental,
 
health
 
and
 
safety,
 
and
 
labour
 
legislation
 
and
 
standards,
 
relevant
 
permits,
 
as
 
well
 
as
 
public
 
disclosure
requirements.
The material impacts,
 
risks and opportunities that the policies
 
are related to are referenced
 
above in the table.
 
Actions and resources in relation
 
to climate change policies [E1-3]
As climate
 
change has become
 
a key
 
threat
 
for
 
the planet
 
and its population,
 
the Group
 
has taken
 
on an active
 
role,
 
with
actions that benefit the environment, for this generation
 
and the generations to come. To this end, the Group’s Sustainability
Strategy entails commitments to achieve Net Zero both for its physical operations as well as its portfolio through sustainable
financing activities.
The actions taken in Eurobank
 
Group in Greece as a result of the
 
Eurobank’s Operational
 
Impact Strategy for
 
achieving Net
Zero operational
 
impact for Scope 1 & 2 by 2033 and for
 
Scope 3 by 2050, by decarbonization
 
lever,
 
are the following:
Promote energy efficiency
 
and self-generation of
 
electricity (Reduction of Scope 1 & 2 emissions)
o
Action
 
plan
 
to
 
reduce
 
emissions
 
from
 
its
 
operations
 
by
 
optimizing/upgrading
 
the
 
energy
 
efficiency
 
of
 
its
buildings. This
 
includes technical
 
interventions
 
(i.e. LED
 
light fixture
 
installations, minimum
 
energy
 
class of
 
A+
air
 
conditioning
 
and
 
heat
 
recovery
 
ventilation
 
systems)
 
as
 
well
 
as
 
system-level
 
building
 
upgrades
 
and
 
the
replacement of carbon-intensive
 
sources (i.e. heating oil).
o
Energy self-production
 
plan consisting of rooftop
 
photovoltaic
 
(PV) stations
 
installed on Eurobank’s
 
buildings
and standalone PV parks developed
 
on Eurobank property.
 
In 2023, 1,203 PV panels were
 
installed on the roof
of the Nea
 
Ionia complex and 376 PV
 
panels were
 
installed on the
 
roof of the
 
Acharnes building.
 
In 2024, the
self-production
 
of
 
energy
 
from
 
the
 
two
 
rooftop
 
PV
 
stations
 
started.
 
Specifically,
 
the
 
energy
 
self-production
started in May 2024 in N.Ionia complex and in July 2024 in
 
Acharnes building. The amount of energy produced
from the
 
rooftop PV stations
 
for 2024
 
is 647.35
 
MWh for
 
N.Ionia and 140.52
 
MWh for
 
Acharnes .
 
In 2024, the
environmental licencing
 
process for
 
two standalone PV
 
parks in central
 
Greece was initiated.
 
The approval
 
of
environmental terms and the
 
application for grid
 
connectivity are expected to be completed within 2025.
o
Increase procurement
 
of electricity sourced by Renewable Energy
 
Sources (guarantees of origin)
Eurobank’s actions regarding the
 
climate change, are strategically adapted and deployed across our subsidiaries in
Bulgaria,
 
Cyprus, and
 
Luxembourg.
 
For
 
example, actions
 
such as
 
the
 
upgrade
 
of branch
 
offices,
 
LED lighting
 
and
installation of latest
 
generation of HVAC system are implemented. Similar actions
 
are tailored to
 
address the specific
local contexts and regulatory environments, they remain firmly aligned with
 
our overarching corporate sustainability
objectives.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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As
 
part
 
of
 
the
 
EnMS,
 
Eurobank
 
communicates
 
the
 
"energy
 
identity"
 
of
 
its
 
branches
 
on
 
a
 
semiannual
 
basis.
 
The
evaluation of each branch's performance
 
is accomplished by utilising the following:
o
Ranking of the branches
 
in ascending order
 
considering the total
 
energy consumption and
 
normalized energy
consumption values using the branches surface area and the heating and cooling degree days, in order to take
the impact of meteorological
 
conditions on the energy
 
needs for heating and cooling.
o
The
 
annual change
 
in energy
 
consumption in
 
total and
 
normalized values
 
by surface
 
area. The
 
absolute and
percentage variation in energy
 
consumption per surface area
 
in relation to the average
 
index for all branches.
In addition, through
 
the EnMS, monitoring and
 
analysis of energy
 
consumption are conducted with
 
the objective
 
of
implementing
 
necessary
 
technical
 
interventions
 
and
 
management
 
solutions.
 
This
 
process
 
follows
 
a
 
structured
methodology
 
that
 
involves
 
documenting
 
the
 
expected
 
enhancements
 
in
 
energy
 
performance.
 
To
 
facilitate
 
this,
Eurobank
 
collaborates
 
with
 
an
 
Energy
 
Services
 
Company
 
(ESCO)
 
under
 
a
 
"Shared
 
Benefit
 
Energy
 
Performance
Contract" model, which operates
 
on the "Pay as you save"
 
principle.
Eurobank’s
 
objective
 
is
 
the
 
gradual
 
energy
 
upgrade
 
of
 
its
 
real-estate
 
portfolio
 
and
 
issuance
 
of
 
green
 
building
certifications, aiming to reduce
 
its environmental footprint.
 
It is shifting towards high-end, modern, environmentally
friendly
 
buildings,
 
given
 
that
 
such demonstrate
 
increased
 
marketability
 
and market
 
resilience
 
as well
 
as multiple
environmental and social benefits. The Bank is already upgrading prime assets into energy-efficient green buildings,
focusing
 
on
 
continuous
 
improvement
 
towards
 
sustainable
 
development.
 
Eurobank
 
has
 
chosen
 
green
 
building
certifications (LEED,
 
BREEAM, EDGE), aiming to validate the sustainability value of its assets and to demonstrate
 
its
sustainability performance.
Within
 
2024, the
 
new Headquarters
 
building (Omirou
 
& Stadiou)
 
has been
 
certified with
 
LEED Gold
 
(Leadership in
Energy
 
&
 
Environmental
 
Design)
 
and
 
increased
 
the
 
Bank’s
 
certified
 
green
 
buildings
 
to
 
20
 
(LEED,
 
BREEAM
certifications).
 
Certified properties have
 
been included in the 2023 SBC Yearbook
 
for Green Buildings.
 
Green buildings usually
 
encompass multiple nature
 
-based characteristics
 
fostering
 
the sustainable
 
transformation
of the built environment and enhancing the resiliency of the asset itself. Location and land use play a significant role
in
 
creating
 
sustainable
 
buildings
 
improving
 
access
 
to
 
low-carbon
 
transportation
 
options,
 
while
 
encouraging
walkability and reducing
 
dependence on
 
driving. Biodiversity
 
is also crucial
 
for the
 
health and
 
wellbeing of
 
people
and our planet. Green buildings promote the
 
protection of natural
 
habitats, encourage the
 
use of biodiverse native
plants
 
and
 
green
 
infrastructure,
 
and
 
minimise
 
the
 
impact
 
of
 
construction
 
on
 
ecosystems.
 
Efficient
 
utilisation
 
of
resources
 
water
 
is
 
essential
 
due
 
to
 
its
 
finite
 
nature,
 
and
 
green
 
buildings
 
play
 
a
 
crucial
 
role
 
in
 
preserving
 
and
protecting
 
this
 
invaluable
 
resource.
 
More
 
specifically,
 
encourage
 
a
 
holistic
 
approach
 
to
 
building
 
water
 
systems,
promoting
 
not only
 
water-efficient
 
strategies,
 
but also
 
reuse through
 
alternative
 
sources, improved
 
management,
and potable water quality considerations.
 
As of
 
December
 
2023,
 
the
 
Eurobank
 
Headquarters
 
were
 
relocated
 
to a
 
new
 
building in
 
the
 
Athens
 
city centre,
 
on
Omirou and
 
Stadiou Street.
 
The high
 
functional standards
 
and bioclimatic
 
features
 
of the
 
Eurobank
 
Headquarters
significantly improve
 
the environmental
 
impact compared to
 
the previous
 
Headquarters: The
 
2024 performance
 
of
the
 
new
 
Headquarters
 
compared
 
to the
 
previous
 
Headquarters
 
is: reduction
 
of GHG
 
emissions at
 
59.30%
 
(374.18
tCO
2
e),
 
reduction
 
of
 
electricity
 
consumption
 
at
 
56.48%
 
(667,385
 
kWh
 
)
 
and
 
reduction
 
of
 
energy
 
intensity
 
(per
employee) at 13.51% .
 
Electromobility (Reduction of
 
Scope 1 emissions)
Gradual
 
increase
 
of
 
the
 
share
 
of
 
plug-in
 
/electric
 
vehicles
 
in
 
Eurobank’s
 
fleet
 
and
 
installation
 
of
 
EV
 
recharging
infrastructure at Eurobank’s
 
buildings.
Minimise business travel (Reduction
 
of Scope 3 emissions)
Measures
 
to
 
reduce
 
indirect
 
emissions
 
associated
 
with
 
transportation
 
and
 
business
 
travel,
 
where
 
feasible,
 
by
introducing alternative
 
methods such as teleconferencing.
Transition
 
to cloud (Reduction of Scope 2&3 emissions)
Initiative
 
for
 
transitioning
 
to cloud
 
computing which
 
will
 
result
 
in the
 
reduction
 
of electricity
 
usage
 
from
 
physical
servers.
Management Systems & Buildings – Scopes 1, 2, 3
Eurobank
 
applies
 
certified
 
ISO
 
Management
 
Systems,
 
in
 
accordance
 
with
 
international
 
standards,
 
such
 
as
 
an
Environmental
 
Management
 
System (ISO
 
14001, EMAS)
 
and an
 
Energy
 
Management
 
System (ISO
 
50001) with
 
the
purpose
 
of
 
responsible
 
energy
 
management
 
in
 
all
 
the
 
Bank’s
 
facilities
 
(all
 
administration
 
buildings
 
/
 
branches,
covering 100% of its
 
operations). Implementing these systems has led
 
to significant reductions in
 
energy consumption
and greenhouse gas emissions. This aims to
 
minimise energy costs, the environmental impact of harmful greenhouse
gas emissions and fossil fuel depletion.
 
Eurobank has
 
verified its
 
greenhouse gas (GHG)
 
emissions in compliance
 
with ISO 14064-1,
 
which provides
 
a framework
 
for
quantifying and reporting GHG emissions and removals.
By implementing these initiatives, the Bank achieved 5.04% reduction
 
in purchased electricity consumption, 37.72% reduction
in Scope
 
1 emissions,
 
10.16%
 
reduction
 
in Scope
 
2 emissions
 
and 13.15%
 
reduction
 
in Scope
 
1 &
 
2 emissions
 
(surpassing the
4.7% 2024 target in 2024, compared to 2023).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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In order to achieve its Net-Zero
 
operational impact targets,
 
the Bank’s planned initiatives
 
are the following:
Maintain and update detailed Operational
 
Net Zero Action Plan
 
- SBTi aligned (baseline year
 
2019) for Scope 1 & 2
(Net-Zero by 2033) and for
 
Scope 3 (Net-Zero by 2050).
Implement
 
energy
 
self-production
 
activities. Energy
 
self-production
 
from
 
rooftop
 
PV stations
 
has already
 
started
during 2024 in
 
N.Ionia and Acharnes
 
buildings, while the
 
procedure
 
for the
 
development of
 
standalone PV Parks
 
is
in progress (long-term target:
 
Energy self-production
 
from standalone PV Parks by 2028).
Increase electromobility for
 
Eurobank’s leased vehicles
 
(new contracts)
Completion of the initiative
 
“Journey to Cloud” by 2025
Attain emissions savings due to data centre modernisation
Attain 100% of electricity consumed to be originated from RES by
 
2028
Perform energy
 
upgrade of buildings
Achieve green building certifications
Carbon credits (nature-based carbon removal projects
 
in line with SBTi) for the entirety of natural
 
gas emissions, up
to 3% of the total Bank emissions (Scope 1, 2) by
 
2025
Design long-term Energy Plan. In 2024, Eurobank’s
 
energy profiling report
 
was completed.
Specifically
 
for
 
2025,
 
in the
 
context of
 
its EMS
 
and based
 
on energy
 
consumption metrics,
 
Eurobank
 
plans to
 
perform
 
the
following technical
 
energy saving actions, to achieve
 
its energy saving targets:
Continuation of the following
 
actions at all the Eurobank Group’s
 
new branches and office
 
spaces in Greece, as well
as all areas where extensive
 
refurbishment works are
 
implemented:
o
installation of new LED technology light fixtures
o
installation of
 
VRF air
 
conditioning systems
 
and autonomous
 
air-conditioning units,
 
as well
 
as installation
 
of
air-cooled water air-conditioning systems, with
 
a minimum energy class of A+.
o
installation of a heat recovery
 
ventilation system.
Energy audits as part of renovation
 
works by engineers in the
 
Technical
 
Projects Unit.
The environmental licensing of standalone photovoltaic
 
parks is in progress and during 2025 the decision regarding
the approval of environmental
 
terms and the application
 
for grid connectivity is expected to be completed.
The
 
Group
 
has
 
integrated
 
its
 
Financed
 
Impact
 
Strategy
 
into
 
its
 
operations
 
and
 
has
 
made
 
significant
 
progress
 
towards
achieving its targets.
1.
Operationalized its Sustainable Finance
 
Framework
The
 
Group
 
has
 
developed
 
governance
 
structures,
 
processes
 
and
 
tools
 
that
 
integrate
 
identifying
 
sustainable
 
financing
opportunities, engaging with clients
 
on sustainable financing offerings
 
and the evaluating
 
financings against the
 
criteria of
the SFF into the day-to-day operations.
 
It has, therefore,
 
increased its capacity to deliver its sustainable financing targets.
Key
 
elements
 
include
 
the
 
introduction
 
of
 
dedicated
 
roles
 
for
 
guiding
 
relationship
 
managers
 
in
 
engaging
 
with
 
clients
 
on
sustainable financing as
 
part of the loan
 
origination processes, as well as an
 
automated tool that underpins the classification
and evaluation of financings against the approaches
 
and criteria of the SFF.
It
 
has
 
extended
 
the
 
sustainable
 
financing
 
approach
 
to
 
its
 
retail
 
business
 
banking,
 
leveraging
 
co-financing
 
programmes
focusing on sustainability, as
 
well as introducing dedicated
 
products tailored to meet specific market
 
needs
2.
Enhanced its capabilities for
 
the collection of sustainability risk
 
data
The
 
Group
 
is
 
continuously
 
enhancing
 
its
 
capabilities
 
for
 
the
 
collection
 
of
 
Sustainability
 
risk
 
data,
 
through
 
integration
 
of
additional
 
information
 
requirements
 
in
 
the
 
credit
 
process,
 
as
 
well
 
as
 
cooperating
 
with
 
third-party
 
data
 
providers.
 
It
 
has
implemented a
 
set of
 
tools for
 
identifying, measuring
 
and managing
 
sustainability risks,
 
including the
 
credit granting
 
and
monitoring processes.
 
These are used by
 
the involved
 
Units across the Group’s
 
both 1st and 2nd lines, with the
 
relevant tasks being performed
 
in a
collaborative
 
and efficient
 
way.
 
Having already
 
performed
 
an assessment
 
of sustainability
 
data
 
availability in
 
its internal
systems
 
against
 
regulatory
 
requirements
 
/
 
expectations,
 
the
 
Group
 
continues
 
to
 
enhance
 
its
 
sustainability
 
risk
 
data
aggregation capabilities
 
and IT infrastructure
 
accordingly,
 
while also using
 
appropriate
 
controls
 
and safeguards
 
to ensure
the
 
accuracy
 
and completeness
 
of the
 
compiled information.
 
The
 
Group
 
seeks to
 
further
 
improve
 
environmental
 
risk data
granularity, through
 
the allocation of detailed roles
 
and responsibilities for the purposes of sustainability data management
and
 
addressing
 
identified
 
data
 
needs
 
(i.e.,
 
engagement
 
with
 
external
 
data
 
providers,
 
development
 
of
 
methodological
approaches for
 
the estimation of required
 
information).
3.
Intensified engagement with its counterparties on sustainability
 
risk mitigation
Aiming to
 
facilitate
 
the
 
green
 
transition
 
of
 
its clients,
 
the
 
Group
 
has developed
 
a dedicated
 
approach
 
to increase
 
client
engagement and
 
awareness
 
regarding
 
environmental
 
risks. Besides
 
the
 
initiatives
 
launched
 
aiming to
 
build sustainability
literacy and capacity among
 
its clients (e.g. online events, articles and webinars,
 
digital academy for businesses), the
 
Group
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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also uses tools to engage with its counterparties in the context of its credit granting and asset management activities, so as
to understand their strategies
 
and mitigate their sustainability risks exposures.
4.
Introduced sustainable products
Eurobank
 
has developed
 
multiple products
 
that aim
 
to stimulate
 
sustainable growth,
 
including Renewable
 
Energy Systems
(RES) investments,
 
energy
 
saving programmes
 
for
 
residential buildings,
 
and debt
 
restructuring
 
programmes
 
for
 
vulnerable
groups. Going forward,
 
it plans to further develop
 
additional products dedicated to promoting
 
sustainable practices for
 
the
Retail portfolio.
5.
Achieved the sustainable financing
 
targets set as part of its financed impact strategy
For the
 
third consecutive year,
 
Eurobank achieved
 
the sustainable financing targets related
 
to its corporate portfolio,
 
set as
part of
 
its Financed
 
Impact Strategy.
 
New SFF-aligned
 
annual disbursements
 
exceeded the
 
20% target
 
of total
 
corporate
disbursements, while corporate sustainable
 
exposures increased from €2.18
 
billion in 2023 to €2.98 billion
 
in 2024, posting a
37% year-on-year growth.
More
 
information
 
on
 
the
 
Group’s
 
actions
 
on
 
climate
 
change
 
related
 
matters
 
are
 
detailed
 
in
 
the
 
chapters
 
“Sustainable
financing and investment offerings”
 
and “Integration of sustainability in risk management”.
2.2.5
Metrics & Targets
Targets
 
related to climate change mitigation and adaptation
 
[E1-4]
Through
 
its Sustainability Strategy,
 
the Group’s
 
overarching
 
climate-related
 
target for
 
its operational
 
impact is to
 
achieve
Net Zero emissions by 2033
 
for Scope 1 &
 
2 and by
 
2050 for Scope 3. The interim targets
 
supporting the Net Zero commitment
are the following:
Reduction in Electricity Consumption and Greenhouse Gas Emissions – Operations
 
in the Bank
 
Performance
2023
Target
2024 (%)
Target
value 2024
Performance
2024
Change (%)
Status
Target
2025 (%)
Target
value 2025
Reduction in
purchased
electricity
consumption
(ΜWh)
34,721
-5%
32,985
32,971
-5.04%
Target
achieved
-2%
(1)
33,070
(1)
Reduction of
Indirect GHG
Emissions Scope 1
& 2 (tCO
2
e)
20,807
-4.67%
19,835
18,070
-13.15%
Target
achieved
-2%
17,708
(1
)
The target of 2025 regarding -2% reduction in electricity consumption concerns the total
 
amount of electricity consumption including purchased
and self-generated electricity (amounted to 33,745 MWh in 2024)
The
 
targets concern
 
all Bank’s
 
office
 
buildings and
 
branches
 
and cover
 
100% of its
 
operations.
 
As presented
 
above,
 
during
2024 the electricity consumption
 
and Scope 1
 
& 2
 
emissions have been reduced and
 
the targets set for reduction
 
of purchased
electricity
 
consumption and of Scope 1 & 2 emissions for 2024 have
 
been achieved.
 
The Bank’s Financed Impact
 
Strategy evolves
 
based on the following
 
key components:
 
Portfolio
 
alignment
Gradual
 
alignment of
 
the
 
Group’s
 
portfolio
 
with sectoral
 
transition
 
pathways
 
that
 
are aligned
 
with the
 
1.5°C climate
transition scenario.
Net zero strategy
Sectoral decarbonisation targets
 
covering the
 
Group’s lending portfolios,
 
with phased target-setting up to 2050.
The Group
 
recognises that the
 
most significant part of
 
its impact on climate
 
arises from the
 
financing it extends to its
clients.
 
Therefore,
 
following
 
its
 
baselining
 
exercise
 
for
 
2022
 
 
the
 
most
 
complete
 
and
 
comprehensive
 
emissions
measurement it
 
has achieved so far
 
– it is now taking the
 
next step to identifying and disclosing its
 
first set of sectoral
Net Zero
 
targets. In doing
 
so, it aims to
 
actively support the
 
decarbonisation policy
 
agenda and play
 
a pivotal
 
role
 
in
channeling capital
 
flows towards
 
the
 
transition
 
of key
 
sectors in
 
the
 
short-, medium
 
-
 
and long-term.
 
Specifically,
 
the
Group
 
has
 
initiated
 
the
 
process
 
of
 
developing
 
sectoral,
 
financed
 
emissions
 
reduction
 
targets
 
based
 
on
 
the
 
NZBA
framework,
 
for some of the
 
most carbon intensive and, therefore,
 
most relevant and impactful sectors and portfolios.
 
It
approaches its target setting process on a sector/portfolio
 
basis, to factor in specific elements of the climate transition.
It
 
also
 
adheres
 
to
 
proven
 
industry
 
standards
 
(e.g.
 
NZBA,
 
PCAF)
 
and
 
accredited
 
science-based
 
decarbonisation
scenarios, in line with a 1.5 degree Celsius objective
 
by 2050.
Notably,
 
the Group,
 
in line with
 
its commitment
 
to address
 
climate change,
 
has joined the
 
NZBA, in order
 
to reinforce
its dedication
 
to aligning its
 
lending and investment
 
portfolios
 
with net-zero
 
emissions by
 
2050 or
 
sooner,
 
in line with
the
 
most
 
ambitious
 
targets
 
set by
 
the
 
Paris
 
Climate
 
Agreement.
 
The
 
Group
 
is proud
 
to join
 
leading
 
peers
 
from
 
the
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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banking
 
industry
 
in
 
its
 
effort
 
to reach
 
net
 
zero
 
emissions
 
by
 
2050
 
and looks
 
forward
 
to engaging
 
with
 
its
 
clients
 
to
support their
 
transition
 
plans.
 
Even
 
though
 
its operational
 
carbon
 
footprint
 
is very
 
limited compared
 
to its
 
financed
emissions,
 
it
 
is
 
also
 
setting
 
reduction
 
targets
 
for
 
operational
 
emissions
 
under
 
its
 
sphere
 
of
 
direct
 
control.
 
Its
 
target
setting approach builds on an overarching
 
framework
 
that has been guiding its analysis and decisions.
Based on the NZBA framework,
 
the group has identified its priority,
 
carbon intensive sectors, representing a significant
proportion of its financed emissions, and is developing
 
its 2030 emission reduction targets.
Sustainable financing
Development of strategies
 
that will promote
 
the green transition
 
of the Group’s
 
clients through sustainable financing.
 
The
 
Group’s
 
strategic
 
approach
 
is
 
to
 
support
 
the
 
green
 
transition
 
efforts
 
of
 
its
 
clients
 
through
 
direct
 
financing and
advisory solutions
 
for
 
capital
 
raising
 
to current
 
and potential
 
clientele. To
 
this end,
 
the
 
Eurobank
 
S.A.’s
 
sustainable
financing targets for Greece
 
are the following:
Portfolio
 
targets:
o
€2 billion in new green disbursements to businesses
 
by 2025 from a 2022 baseline
o
20% of the annual new corporate
 
disbursements to be classified as Green / Environmentally
 
sustainable
o
20% stock of green exposures by 2027 for
 
the Corporate portfolio.
o
Mobilise €2.25 billion total green RRF funds in the
 
Greek economy by 2026.
o
No new
 
investments
 
in fixed
 
income securities
 
(excluding exposures
 
in Sustainability
 
/ Green
 
Bonds) towards
the top 20 most carbon-intensive
 
corporates worldwide.
Sectoral targets:
o
35% of new disbursements in the Energy
 
sector to be directed to RES financing.
o
80% of new
 
disbursements related
 
to construction of new
 
buildings (CIB portfolio)
 
to be allocated
 
with EPC A
and above
o
20% of new disbursements
 
related to mortgage loans (excluding
 
"My Home") to be allocated
 
with EPC B+ and
above
o
Maintain the
 
same growth
 
in absolute
 
terms for
 
Retail Banking
 
new green
 
disbursements (or
 
more than
 
50%
increase vs. 2023).
Performance
 
against financed impact
 
targets is presented
 
in the chapter
 
“Sustainable financing and investment
 
offerings”.
Following
 
the completion
 
of the onboarding
 
of Hellenic Bank, during 2024,
 
along with the
 
upskilling achieved for
 
the rest
 
of
International
 
subsidiaries,
 
the
 
Group
 
aims
 
to
 
align
 
all
 
entities’
 
Sustainability
 
Strategies
 
to
 
converge
 
to
 
a
 
Group-wide
Sustainability Strategy in both
 
pillars.
Energy consumption & mix [E1-5]
According to the energy
 
review conducted in the context of the
 
EnMS implementation, the
 
Energy consumption at Eurobank
occurs from:
Burning of natural gas and oil for
 
heating
The use of diesel and -petrol
 
by vehicles used for
 
transporting materials between its buildings within
 
Attica,
The use of electricity for
 
the organisation’s
 
operations.
The
 
table
 
below
 
outlines
 
the
 
total energy
 
consumed
 
by
 
the
 
Group’s
 
operations,
 
along with
 
the
 
breakdown
 
of the
 
energy
sources used,
 
including the
 
share of
 
renewable and
 
non-renewable
 
energy.
 
By sharing this
 
information,
 
The
 
Group aims
 
to
provide
 
a clearer
 
understanding
 
of its
 
efforts
 
to manage
 
energy
 
usage, reduce
 
carbon
 
emissions,
 
and transition
 
to
 
more
sustainable
 
energy
 
practices
 
in
 
line
 
with
 
its
 
broader
 
environmental
 
goals.
 
The
 
table
 
below
 
details
 
the
 
Group’s
 
energy
consumption and mix for the
 
reporting period.
Unit
2024
Total energy
 
consumption and mix (including purchased or acquired electricity,
 
heat, steam, and cooling from
 
fossil
sources)
(1) Fuel consumption from coal and coal products
MWh
0
(2) Fuel consumption from crude oil and petroleum
 
products
 
MWh
5,450
2.1 Fuel consumption from
 
petrol
MWh
2,922
2.2. Fuel consumption from diesel
MWh
2,243
2.3. Fuel consumption from LPG (Liquefied Petroleum
 
Gas)
MWh
171
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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Unit
2024
Total energy
 
consumption and mix (including purchased or acquired electricity,
 
heat, steam, and cooling from
 
fossil
sources)
2.4 Fuel consumption from heating
 
oil
MWh
113
2.5 Fuel consumption from other
 
crude oil and petroleum products
MWh
0
(3) Fuel consumption from natural
 
gas
 
MWh
3,457
3.1
 
Fuel consumption from natural
 
gas
MWh
3,457
3.3 Fuel consumption from CNG (Compressed
 
Natural Gas)
 
MWh
0
(4) Fuel consumption from other
 
fossil sources
MWh
0
(5) Consumption of purchased or acquired electricity,
 
heat, steam, and cooling from fossil
sources
MWh
14,522
(6) Total energy
 
consumption from fossil sources
MWh
23,428
Share of fossil sources
 
in total energy consumption
%
36%
(7) Total energy
 
consumption from nuclear sources
MWh
4,862
Share of consumption from nuclear sources
 
in total energy consumption
%
7%
(8) Fuel consumption from renewable
 
sources, including biomass (also comprising industrial and
municipal waste of biologic origin), biofuels,
 
biogas, renewable hydrogen,
 
etc.
MWh
0
(9) Consumption of purchased or acquired electricity,
 
heat, steam, and cooling from renewable
sources
MWh
35,904
(10) The consumption of self-generated
 
non-fuel renewable energy
MWh
1,455
(11) Total renewable
 
energy consumption
MWh
37,359
Share of renewable sources
 
in total energy consumption
%
57%
Total energy
 
consumption
MWh
65,649
In 2024 the
 
Group’s total
 
energy consumption
 
reached 65,649
 
MWh. Renewable energy
 
consumption accounted for
 
37,359
MWh, which represents 57%
 
of the total
 
energy consumption,
 
while 4,862 MWh (7%) was from
 
nuclear sources (coming
 
from
Bulgaria’s
 
national
 
energy
 
mix)
 
and
 
the
 
remaining
 
36%
 
was
 
consumed
 
from
 
fossil
 
sources.
 
This
 
substantial
 
sourcing
 
of
renewable
 
energy
 
underscores
 
The
 
Group’s
 
dedication
 
to
 
reducing
 
its
 
carbon
 
footprint
 
and
 
advancing
 
its
 
sustainability
initiatives and will be the key
 
driver for
 
achieving annual reductions in the coming years.
The
 
above
 
consumptions
 
have
 
been
 
based
 
on
 
actual
 
consumption
 
data
 
for
 
a
 
10-month
 
period
 
of
 
2024,
 
while
 
for
 
the
remaining 2 months where actual data were not available,
 
due to timing
 
constraints, consumptions were extrapolated based
on the same period previous
 
years. Actual consumption data for the
 
Bank have been verified according to ISO 14064-1 while
the estimation methodolog
 
y
 
has been validated according to ISO14064-2 by an independent certification
 
body
Energy self-production
 
is a crucial element of Eurobank’s journey towards
 
Operational Net Zero.
 
The relevant project
 
stream
of the Operational
 
Impact Strategy includes 2 distinct self-production
 
initiatives:
Rooftop photovoltaic (PV) stations
 
installed on Eurobank buildings.
Standalone PV parks developed on Eurobank
 
property.
These initiatives are
 
implemented as cross-unit projects with the
 
support of dedicated consultants and with regular updates
to
 
Senior
 
Management.
 
The
 
energy
 
and
 
emission
 
benefits
 
of
 
these
 
projects
 
are
 
calculated
 
in
 
the
 
Operational
 
Net
 
Zero
transition path
 
to carbon neutrality for
 
Scope 1 & 2 by 2033, per the
 
respective commitments of Eurobank.
 
Furthermore, the
 
Group has produced 1,482 MWh of energy.
 
from renewable sources.
 
This includes energy produced
 
from PV
panels in Group’s operations
 
in Greece, Bulgaria, and Cyprus.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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Gross Scopes 1, 2, 3 and Total
 
GHG emissions [E1-6]
Eurobank is
 
committed to reducing
 
its environmental
 
footprint
 
and actively contributes
 
to the reduction
 
of greenhouse gas
emissions. As part of this
 
effort, the Bank closely monitors its operational emissions through the implementation
 
of a certified
Energy Management System (EnMS) in accordance
 
with the ISO 50001 standard.
In addition, the Bank applies the International Standard ISO 14064-1:2018 for the quantification and reporting of greenhouse
gas emissions (Category 1-6) as well as GHG removals. The
 
pertinent correspondence
 
with the International Standard
 
“GHG
Protocol Corporate
 
Accounting and Reporting Standard” (Scope 1, 2 & 3) is also mentioned.
In this
 
context, energy
 
consumption is
 
recorded
 
and allocated
 
as well
 
as the
 
direct and
 
indirect greenhouse
 
gas emissions
are calculated.
Direct emissions
 
(Scope 1) resulting
 
from the
 
Group’s
 
operations
 
reflect GHG emissions
 
released by
 
burning oil and natural
gas to heat
 
buildings (Direct
 
emissions from
 
stationary combustion),
 
the use
 
of diesel and
 
petrol
 
by the
 
Group owned
 
and
leased vehicles, the petrol used
 
to power the generators (Direct emissions from mobile
 
combustion) and the fugitive emissions
from
 
the
 
Group’s
 
air
 
conditioning
 
systems
 
and
 
the
 
automatic
 
extinguishing
 
systems
 
(Direct
 
fugitive
 
emissions
 
from
 
the
release of GHGs in anthropogenic systems).
Indirect emissions
 
are those
 
released by
 
the consumption
 
of electricity (Scope
 
2) as well
 
as other
 
indirect emissions
 
(Scope
3)
 
associated
 
with
 
employee
 
business
 
trips
 
(air
 
travel
 
and
 
hotel
 
stay)
 
and
 
employee
 
commuting,
 
waste
 
management,
emissions from
 
transportation
 
and distribution
 
of goods,
 
capital goods,
 
purchased good
 
and services,
 
emissions from
 
fuel
and energy related activities and emissions
 
from cloud computing usage have also been included.
When a
 
new category
 
is added,
 
the amount
 
for
 
that category
 
is added to
 
the previous
 
year to
 
normalise the
 
baselines for
comparison reasons. The
 
emissions from new
 
categories will also be included
 
in the operational
 
Net Zero for
 
Scope 1 & 2 by
2033 and for Scope 3 by 2050 project,
 
according to the SBTi methodology.
 
As per
 
emissions,
 
the
 
Eurobank
 
Group
 
in Greece
 
utilises emissions
 
conversion
 
coefficients
 
from
 
National
 
Inventory
 
Report
(NIR) Greece -2024, Renewable Energy Sources Operator & Guarantees of Origin (DAPEEP SA), Department for Environment,
Food &
 
Rural Affa
 
irs (UK- DEFRA)
 
(full set, version
 
1.0 of 2024), EXIOBASE
 
(2019 emission factors
 
for Greece),
 
BEIS (2021 and
2024
 
emission
 
factors
 
,
 
Greenview
 
(2022
 
emission
 
factors),
 
EPA
 
database
 
(2022
 
emission
 
factors)
 
and
 
Global
 
Warming
Potential (GWP) (2022 emission factors),
 
as needed for each specific case.
 
The Bank
 
verifies the
 
above greenhouse
 
gas (GHG) emissions
 
in compliance
 
with ISO
 
14064-1, which provides
 
a framework
for quantifying and reporting GHG emissions and removals.
The table below demonstrates
 
the breakdown
 
of the Group’s
 
Scope 1,2,3 emissions:
Total
 
Scope 1,2,3 emissions
Breakdown of Greenhouse Gas
 
emissions
2024
Gross Scope 1 GHG emissions (tCO
2
e)
3,421
Percentage of Scope 1 GHG emissions from
 
regulated emission trading
 
schemes
(%)
0%
Gross location-based
 
Scope 2 GHG emissions (tCO
2
e)
27,664
Gross market-based Scope 2
 
GHG emissions (tCO
2
e)
11,050
Total Gross
 
indirect
(2)
 
(Scope 3) GHG emissions (tCO
2
e)
75,301
1 Purchased goods and services
37,364
Cloud computing and data centre services
206.54
2 Capital goods
23,420
3 Fuel and energy-related Activities (not
 
included in Scope1 or Scope 2)
5,924
4 Upstream transportation and distribution
604
5 Waste generated
 
in operations
550
6 Business traveling
310
7 Employee commuting
7,127
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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Breakdown of Greenhouse Gas
 
emissions
2024
8 Upstream leased assets
0
9 Downstream transportation
0
10 Processing of sold products
0
11 Use of sold products
0
12 End-of-life treatment of sold
 
products
0
13 Downstream leased assets
0
14 Franchises
0
15 Investments
Please refer to financed emissions
table below
Total GHG emissions
 
(location-based) (tCO
2
e)
106,386
Total GHG emissions
 
(market-based) (tCO
2
e)
89,772
(2)
Eurobank Cyprus and Luxemburg is only included in investments emissions (Scope 3 Category 15)
In 2024, the Group’s
 
total operations-related
 
GHG emissions reached 89,772
 
tCO
2
e (market-based) with Scope 1 account
for 4%, Scope 2 (market-based)
 
13% and Scope 3 83%.
 
The
 
calculation
 
of the
 
Scope 1
 
and Scope
 
2 emissions
 
was made
 
using actual
 
data for
 
a 10-month
 
period and
 
estimated /
extrapolated
 
data
 
for
 
a 2-month
 
period.
 
Emissions
 
for
 
the
 
Bank’s operations
 
(including
 
the
 
assumptions
 
/ extrapolations
approach)
 
has
 
been
 
verified/validated
 
by
 
an
 
independent
 
certification
 
body
 
according
 
to
 
ISO14064-1
 
and
 
ISO
 
14064-2
respectively.
The
 
above
 
data
 
may be
 
modified due
 
to issuance
 
of new
 
version
 
of emissions
 
conversion
 
coefficients
 
(emissions
 
factors)
during
 
2025
 
from
 
the
 
Ministry
 
of
 
Environment
 
and
 
Energy,
 
due
 
to
 
the
 
new
 
climate
 
law
 
4936/2022
 
(Government
 
Gazette
105/A/ 27.05.2022),
 
for operations
 
in Greece, or relevant Laws in the
 
countries where the
 
Eurobank Group
 
operates.
The
 
location-based
 
method
 
reveals
 
what is
 
physically
 
emitted by
 
the
 
Group,
 
while the
 
market-based
 
approach
 
concerns
residual emissions
 
for
 
which the
 
Group
 
does not
 
procure
 
Guarantees
 
of Origin
 
(GO’s). 95.66%
 
of the
 
Bank’s operations
 
in
Greece
 
electric energy
 
will be
 
certified
 
from
 
Renewable
 
Sources
 
(Guarantees
 
of Origin
 
will be
 
acquired during
 
2025). The
Bank’s have an annual Guarantee of Origins (GOs) contract
 
with the electricity provider.
 
The
 
Group
 
has
 
identified
 
the
 
significant
 
Scope
 
3
 
categories
 
for
 
its
 
operational
 
impact,
 
by
 
considering
 
estimated
 
GHG
emissions
 
alongside
 
criteria
 
outlined
 
in
 
the
 
GHG
 
Protocol
 
Corporate
 
Value
 
Chain
 
(Scope
 
3).
 
This
 
identification
 
process
involved
 
factors
 
such
 
as
 
financial
 
spend,
 
influence,
 
transition
 
risks
 
and
 
opportunities,
 
and
 
stakeholder
 
perspectives.
 
The
categories include:
 
Employee commuting and homeworking
Business travel (air-travel
 
and hotel-stay)
Transportation
 
and Distribution
Purchased Goods and Services
Capital Goods
Fuel and Energy related activities
Waste disposal and Water
 
consumption
Cloud Computing Usage
Scope 3 emissions totaled
 
75,301 tCO
2
e for 2024.
 
When a new category
 
is added, the amount for
 
that category is
 
added to
the previous
 
year and the base year
 
to normalise the baselines for comparison
 
reasons.
Assumptions applied
Eurobank estimates
 
Scope 1, 2, and 3 emissions by
 
assuming that historical
 
consumption patterns can
 
predict future trends,
allowing
 
past
 
data
 
to
 
guide
 
current
 
and
 
future
 
emissions
 
estimates.
 
This
 
approach
 
presumes
 
consistency
 
in
 
usage
 
over
comparable
 
periods,
 
making
 
it
 
especially
 
useful
 
for
 
stable
 
operations.
 
In
 
the
 
absence
 
of
 
historical
 
data,
 
Eurobank
 
uses
average
 
consumption
 
from
 
the
 
current
 
year
 
to
 
project
 
future
 
usage,
 
assuming
 
that
 
current
 
performance
 
can
 
provide
 
an
accurate forecast.
 
Where feasible,
 
the Group
 
utilises primary / source
 
data for
 
the relevant
 
calculations, either
 
from its own
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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sources
 
or
 
by
 
acquiring
 
them
 
from
 
its
 
value
 
chain
 
stakeholders
 
(i.e.
 
suppliers).
 
When
 
those
 
are
 
not
 
available,
 
it
 
employs
estimations, assumptions and extrapolations
 
that produce
 
reasonable outcomes.
These assumptions
 
enable the
 
Eurobank Group
 
to maintain flexibility and accuracy
 
in its emissions estimation,
 
adapting to
varying
 
levels
 
of
 
data
 
availability.
 
By
 
doing
 
so,
 
the
 
Group
 
supports
 
its
 
sustainability
 
goals
 
and
 
ensures
 
compliance
 
with
environmental
 
reporting standards, providing
 
a comprehensive view of its environmental
 
impact.
Perimeter of Estimation
The emissions estimation
 
process covers
 
the entire Eurobank Group
 
and its subsidiaries, aligning with the perimeter
 
defined
in the Group's Sustainability Statement. This approach
 
ensures that all operations
 
and activities are considered, providing a
comprehensive view of Eurobank's
 
environmental impact and supporting its commitment
 
to sustainability.
Contractual instruments
Unit
2024
Contractual instruments used for
 
the purchase of bundled energy
 
with attributes about
energy generation
 
in relation to Scope 2 GHG emissions
MWh
32,282
In 2024 the
 
Bank continued
 
to purchase green energy from
 
Renewable Energy Sources (RES) with
 
Guarantees of Origin (GOs).
More specifically,
 
32,282 MWh of electricity was sourced from renewable
 
sources.
Regarding
 
its
 
financed
 
impact-related
 
Scope
 
3
 
emissions,
 
the
 
Group
 
calculates
 
and
 
discloses
 
its
 
financed
 
emissions
(category
 
15)
 
following
 
the
 
PCAF
 
methodology,
 
which
 
is
 
based
 
on
 
a
 
revenue-based
 
approach,
 
with
 
emission
 
factors
estimated
 
for
 
each
 
sector
 
and
 
country
 
through
 
a
 
multiregional
 
input-output
 
analysis
 
framework.
 
Note
 
that
 
reported
emissions from Group’s counterparties have
 
been used where available across Scope 1, 2 and 3. Where one or more reported
scope categories
 
were
 
not disclosed /
 
complete, the
 
Group has
 
incorporated
 
estimated emissions
 
according to its
 
internal
methodology,
 
in line with the PCAF standard.
 
More specifically,
 
the Group utilises a waterfall
 
approach for
 
the calculation of the
 
financed emissions:
To
 
the
 
extent
 
possible,
 
published
 
(reported)
 
emissions
 
of
 
the
 
counterparties
 
are
 
used.
 
(Option
 
1
 
 
Reported
emissions)
For sector D 35.11
 
physical activity based emissions are reported (Option
 
2 – Physical activity-based emissions)
In
 
all
 
other
 
cases
 
the
 
scope
 
1,
 
2
 
and
 
3
 
emissions
 
are
 
calculated
 
based
 
on
 
the
 
economic
 
activity
 
data
 
of
 
the
counterparty
 
(i.e.,
 
EUR
 
of
 
revenue)
 
and
 
appropriate
 
emission
 
factors
 
expressed
 
per
 
economic
 
activity
 
(e.g.,
tCO
2
e/million EUR output of the corresponding
 
sector). (Option 3 – Economic activity-based emissions.)
The Group
 
calculates and monitors its financed emissions for
 
the lending and investment portfolios
 
within its Banking Book,
while sectoral level financed emissions of its corporate lending portfolio,
 
is the key method for developing
 
targets to align its
portfolio with climate transition pathways and set
 
net zero targets. As
 
a key step
 
towards its commitment to
 
align its portfolio
with 1.5
o
aligned transition
 
pathways
 
and set
 
net zero
 
targets, the
 
Group
 
is in
 
the
 
process
 
of developing
 
the
 
first wave
 
of
sectoral financed emissions reduction
 
targets, covering the
 
Group’s lending portfolios,
 
with the ultimate objective
 
of setting
2030 targets for
 
the carbon intensive sectors of its portfolio
 
and reaching Net Zero by 2050.
Financed emissions
 
is the
 
most material
 
Scope 3 category
 
for
 
the Group,
 
accounting for
 
> 99% of
 
the total
 
emissions, and
are the basis for
 
its sectoral decarbonisation action
 
plan.
The Group
 
discloses financed emissions
 
for the
 
lending and investment
 
portfolio
 
based on counterparties'
 
scope 1, 2, and
 
3
emissions, which total 28.5
 
million tonnes of CO
2
 
equivalent (mtCO
2
e) for 2024.
 
It's noted that fluctuations
 
in total financed
emissions are expected as companies refine their
 
estimation methods and market practices
 
evolve.
Τhe table below presents the breakdown
 
of the Group’s total
 
financed emissions between lending and investment activities:
 
Emission covered exposure
 
(€mn)
Scope 1&2 (ktCO
2
e)
Scope 3 (ktCO
2
e)
Total emissions
 
(ktCO
2
e)
Lending
 
40,938
6,799
16,567
23,367
Corporate
29,364
6,440
16,567
23,007
Retail
11,574
359
-
 
359
Investments
23,155
2,647
2,470
5,117
Total
64,093
9,446
19,037
28,483
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The majority
 
of the
 
Group’s
 
financed emissions come
 
from its corporate
 
portfolio
 
lending, accounting for
 
c.81% of the
 
total,
while Scope 3 financed emissions account for c. 87%
 
of the total.
Emission covered
exposure (€mn)
Scope 1&2 (ktCO
2
e)
Scope 3 (ktCO
2
e)
Total emissions
(ktCO
2
e)
A - Agriculture
 
371
388
359
747
C - Manufacturing
 
4,446
1,975
10,140
12,115
D - Energy
 
2,800
1,200
216
1,416
F – Construction
 
1,065
63
694
757
G - Wholesale and retail trade
 
4,727
1,262
3,104
4,366
H - Transporting and storage
 
5,645
1,041
1,155
2,196
I – Accommodation
 
2,915
102
362
464
Other Sectors
 
7,396
409
537
946
Total
 
29,364
6,440
16,567
23,007
Regarding
 
the
 
corporate
 
portfolio,
 
lending
 
to the
 
manufacturing
 
sector has
 
the
 
biggest contribution,
 
c. 53%,
 
followed
 
by
wholesale and retail trade, c19%, and transportation,
 
c. 9%.
Total
 
GHG Emissions
ESRS Quantitative data / metric
Unit
2024
Total GHG emissions
 
(location-based)
 
tCO
2
e
28,589,386
Total GHG emissions
 
(market-based)
tCO
2
e
28,572,772
Total net revenue
(3)
mn €
3,341
(3)
In alignment with the “operating income”
 
as disclosed in the consolidated income statement.
In 2024, the Group’s GHG emissions amounted to
 
28.6 mn tCO
2
e with financed emissions contributing >99%
 
and operations-
related (Scope 1,2,3) emissions accounting for less than 1%.
Unit
2024
GHG intensity per net revenue
 
(location based)
tCO
2
e/ mn €
8,557
GHG intensity per net revenue
 
(market based)
tCO
2
e/ mn €
8,552
GHG removals and GHG mitigation projects
 
financed through
 
carbon credits [E1-7]
For
 
operations-related
 
emissions,
 
following
 
the
 
Science-Based
 
Targets
 
initiative
 
guidance,
 
90%
 
of
 
the
 
baseline
 
year’s
emissions will need to be reduced and the
 
remaining 10% will be removed
 
by purchasing Carbon Credits. Currently
 
there are
no plans
 
to include
 
Carbon Removals
 
across
 
Eurobank’
 
s value
 
chain (upstream
 
and downstream).
 
As for
 
Carbon Credits,
they
 
will
 
only
 
cover
 
the
 
remaining
 
10%
 
of
 
emissions,
 
complementing
 
Eurobank’s
 
carbon
 
reductions
 
across
 
its
 
value
 
chain.
Carbon
 
Credits
 
will
 
not
 
be
 
used
 
to
 
show
 
Carbon
 
Reductions
 
across
 
Eurobank’s
 
value
 
chain
 
and
 
they
 
will
 
not
 
impede
 
its
progress
 
towards
 
net-zero.
 
Eurobank’s
 
Carbon
 
Credits
 
are
 
purchased
 
from
 
credible
 
sources
 
that
 
follow
 
the
 
latest
 
quality
standards.
2.3
Biodiversity and ecosystems [E4]
 
2.3.1
Governance
Eurobank
 
acknowledges that
 
it currently
 
does not
 
have a
 
dedicated governance
 
structure in
 
place to
 
address biodiversity
conservation issues comprehensively. However,
 
recognising the increasing importance of
 
biodiversity in achieving sustainable
development and mitigating environmental risks, Eurobank is committed to developing a robust governance framework.
 
This
framework
 
will
 
include
 
clear
 
policies,
 
oversight
 
mechanisms,
 
and
 
accountability
 
structures
 
to
 
integrate
 
biodiversity
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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considerations into its decision
 
-making processes and business operations.
 
The development
 
of this governance
 
structure is
a priority, and Eurobank
 
aims to establish it within a defined timeframe to align with emerging
 
regulatory requirements and
stakeholder expectations.
 
Meanwhile, Eurobank engages regularly with its stakeholders,
 
including environmental organisations, regulators,
 
and clients,
to stay informed about biodiversity
 
issues and best practices.
2.3.2
Strategy
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [ESRS
 
2 SBM-3]
Based
 
on
 
the
 
capability
 
of
 
the
 
financial
 
sector
 
to
 
influence
 
the
 
sustainable
 
use
 
of
 
nature
 
through
 
its
 
business
 
activities,
Eurobank is already
 
taking appropriate steps to integrate
 
biodiversity loss in
 
its operations,
 
by developing a
 
corresponding
response
 
strategy and incorporating
 
relevant provisions
 
in its overall
 
strategy and risk management framework.
Eurobank
 
is currently
 
developing a
 
model for
 
integrating biodiversity
 
considerations
 
into its
 
overall
 
strategy,
 
ensuring that
its financing and investing activities do not have a negative effect
 
on biodiversity and ecosystems and while also promoting
activities that rehabilitate
 
and restore ecosystems.
 
Eurobank recognises
 
that its physical
 
operations
 
have minimal effect
 
on
biodiversity and is thus developing
 
a proportional approach.
Eurobank’s strategic
 
action plan around biodiversity
 
will evolve
 
around the following
 
elements:
Risk Assessment: Integrate comprehensive transaction assessments to identify
 
and understand biodiversity risks and
dependencies using tools like ENCORE.
Sector
 
Analysis:
 
Focus
 
on
 
high
 
and
 
medium-risk
 
sectors,
 
such
 
as
 
agriculture,
 
forestry,
 
water
 
supply,
 
mining,
 
and
energy,
 
and promote measures and financing that
 
mitigates biodiversity impacts.
Sustainable
 
Finance:
 
Promote
 
and
 
finance
 
activities
 
and
 
projects
 
that
 
support
 
biodiversity
 
conservation,
rehabilitation of ecosystems and sustainable use of natural
 
resources.
 
Considering the
 
complexity of assessing the
 
issue of biodiversity
 
as a risk driver
 
in relation
 
to Eurobank’s
 
business practices
and own operations, given the fact that the
 
relevant guidance in this field is currently under development, Eurobank is closely
following several
 
related initiatives
 
and continues to build its
 
skills and capacity,
 
so as to ensure
 
readiness to appropriately
address such risks, upon the availability of more granular
 
guidelines and methodologies in this respect.
To identify
 
business operations
 
impacting biodiversity,
 
the Group
 
conducted a thorough
 
loan portfolio
 
analysis (materiality
assessment) to identify the sectors most vulnerable
 
to biodiversity loss. Utilising the ENCORE tool (Exploring Natural
 
Capital
Opportunities, Risks,
 
and Exposure),
 
the
 
Group
 
analyzed sector-specific
 
dependencies and
 
impacts related
 
to biodiversity
loss.
 
The
 
ENCORE
 
tool
 
facilitates
 
the
 
assessment
 
of
 
dependencies
 
on
 
biodiversity
 
loss
 
by
 
exploring
 
the
 
ways
 
in
 
which
economic activities rely on ecosystem services and natural capital. Based on the results,
 
primary economic activities, such as
agriculture and
 
water supply,
 
are significantly
 
more dependent
 
on ecosystem
 
services
 
than other
 
economic activities,
 
such
as transportation.
 
This
 
is mainly
 
because the
 
production
 
of agricultural
 
products
 
heavily relies
 
on the
 
use of
 
groundwater,
surface water,
 
and animal pollination.
2.3.3
.
Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank
 
identifies
 
material
 
impacts,
 
risks, and
 
opportunities
 
related
 
to integration
 
of
 
sustainability in
 
risk management
through a comprehensive
 
DMA. This approach integrates
 
industry benchmarks, stakeholder insights, and financial relevance
to ensure a robust evaluation
 
of integration of sustainability in risk management impacts.
During our Double materiality
 
assessment, the
 
following risk
 
associated with Biodiversity
 
and ecosystems matters has
 
been
identified:
Direct impact drivers of biodiversity
 
loss
Risk
Biodiversity loss due to clients’ operations
 
may lead to financial and reputational damage.
2.3.4 Policies and Actions
Policies related
 
to the integration
 
of sustainability in risk management
 
[MDR-P]
 
Eurobank
 
has developed
 
a set of policies
 
to guide its actions
 
on biodiversity,
 
ensuring that
 
all business activities
 
align with
the Group's
 
commitment to biodiversity
 
conservation.
Eurobank is
 
committed to engaging with
 
stakeholders
 
by ensuring a
high level of
 
accountability in policy
 
development and implementation. Policies are approved by the appropriate Governance
bodies
 
such
 
as
 
the
 
Board
 
of
 
Directors
 
or
 
specialized
 
committees,
 
which
 
ensure
 
that
 
there
 
is
 
alignment
 
with
 
the
 
Group's
strategic goals and stakeholder
 
interests.
 
Eurobank main policies that
 
incorporate biodiversity
 
issues are:
Environmental Policy
 
Statement: Incorporates
 
biodiversity
 
considerations
 
into environmental
 
risk assessments
 
and
decision-making processes.
 
 
 
 
 
 
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Sustainable
 
Finance
 
Framework: Guides
 
the
 
Group
 
in
 
aligning
 
its
 
financial
 
activities
 
with
 
sustainability
 
goals,
including biodiversity
 
conservation by
 
defining specific criteria
 
for projects
 
that support biodiversity
 
and excluding
activities that might harm the environment.
Sustainable
 
Investment
 
Framework:
 
Guides
 
investment
 
decisions
 
to
 
support
 
long-term
 
environmental
 
and
 
social
sustainability, including biodiversity
 
conservation by developing
 
criteria for investments
 
that promote biodiversity.
For
 
more information
 
regarding the
 
dedicated policies
 
please refer
 
to: 2.2.4 Policies
 
& Actions
 
- Policies
 
related to
 
climate
change mitigation and adaptation [E1-2]
Actions related to
 
the integration
 
of sustainability in risk management
 
[MDR-A]
Based
 
on
 
the
 
capability
 
of
 
the
 
financial
 
sector
 
to
 
influence
 
the
 
sustainable
 
use
 
of
 
nature
 
through
 
its
 
business
 
activities,
Eurobank is already
 
taking appropriate steps to integrate
 
biodiversity loss in
 
its operations,
 
by developing a
 
corresponding
response
 
strategy
 
and
 
incorporating
 
relevant
 
provisions
 
in
 
the
 
risk
 
management
 
framework.
 
These
 
actions
 
have
 
been
embedded into the Group’s operating
 
model in order to ensure that the Group has established actions on an ongoing basis:
According
 
to the
 
Group’s
 
Exclusion
 
List, activities
 
prohibited
 
by
 
the
 
laws of
 
the
 
host
 
country or
 
international
 
conventions
concerning the protection
 
of biodiversity or cultural
 
heritage resources
 
are excluded from financing.
 
At
 
the
 
same
 
time,
 
the
 
ESG
 
Questionnaire
 
that
 
is
 
used
 
by
 
the
 
Group
 
in
 
the
 
context
 
of
 
the
 
borrowers’
 
creditworthiness
assessment includes, inter alia, dedicated questions aiming
 
to capture the biodiversity loss risk of the Group’s counterparties.
Furthermore, a qualitative
 
Risk Appetite Statement (RAS) has been introduced in relation
 
to the environmental risk posed to
biodiversity.
 
Based on its exclusion list, the Group shall refrain from financing activities prohibited by
 
host country legislation
or international conventions relating
 
to the protection
 
of biodiversity resources.
As
 
per
 
the
 
Responsible
 
Investment
 
Policy
 
document
 
of
 
Eurobank
 
Asset
 
Management
 
MFMC,
 
the
 
Company
 
integrates
sustainability
 
factors
 
into
 
the
 
investment
 
process.
 
In
 
particular,
 
the
 
sustainability
 
analysis
 
includes
 
the
 
assessment
 
of
environmental
 
criteria (e.g.
 
emissions of
 
greenhouse
 
gases, exposure
 
to fossil
 
fuel and
 
water
 
emissions) at
 
the
 
level
 
of the
companies in which the
 
funds and portfolios
 
invest. The
 
events or conditions
 
that may be responsible
 
for a negative
 
impact
on the return
 
of the fund/portfolio
 
include environmental
 
aspects (e.g. carbon emissions,
 
water pollution,
 
loss of biodiversity
or damage to ecosystem). The specific sustainability factors considered may vary, as they depend on the
 
specific investment
strategy followed
 
by each fund/portfol
 
io.
Also, through the Climate-Related & Environmental Risks’ Materiality Assessment
 
has as main
 
objective to outline the general
methodological approach
 
by which the Group
 
assessed the materiality of the
 
sustainability risks, including biodiversity
 
loss,
and to demonstrate the exercise's
 
results.
2.3.5 Metrics & Targets
Biodiversity metrics [MDR-M]
Eurobank is currently in the process
 
of developing and monitoring biodiversity risk indicators through the ENCORE tool which
classifies sectors
 
into five
 
levels:
 
Very
 
Low,
 
Low,
 
Medium, High,
 
and Very
 
High. To
 
enhance
 
its approach,
 
Eurobank
 
initially
created
 
a numerical five-level
 
scale, where
 
0 represents Very
 
Low, 1 represents
 
Low, 2 represents
 
Medium, 3 represents High,
and 4 represents Very High. For
 
each subsector, the maximum score from
 
each subcategory of ecosystem services presented
by the ENCORE tool was used. The average
 
of these maximum scores for each subcategory was then calculated,
 
followed
 
by
the average
 
per Level 1 NACE sector.
 
The final scores for
 
each Level 1 NACE sector were
 
categorized as follows:
0-1: Minor,
1-2: Low,
2-3: Medium,
3+: High.
Biodiversity targets [MDR-T]
Eurobank is currently
 
in the process of developing
 
specific targets related to biodiversity
 
conservation. This initiative
 
aims to
establish clear, measurable goals that will guide the Group's efforts in mitigating biodiversity risks and enhancing its positive
impact on ecosystems. By setting these targets, Eurobank seeks
 
to ensure accountability and transparency in its biodiversity
strategy,
 
aligning
 
its
 
operations
 
with
 
global
 
sustainability
 
standards
 
and
 
contributing
 
to
 
the
 
preservation
 
of
 
natural
resources for
 
future generations.
2.4
Integration of sustainability in risk
 
management [Entity-specific]
2.4.1
Governance
The role
 
of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
The Group applies a model of defined roles and responsibilities regarding
 
the management of Sustainability risks across the
Three lines of defense,
 
shaped by the European Central Group's Single Supervisory Mechanism (SSM) 13 expectations related
to climate-related and environmental
 
risksand considering all relevant guidelines
 
and regulatory requirements:
 
 
 
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1st line
 
The Business Units (CIB and Retail Banking) are responsible for assessing, managing and monitoring risk levels in all
risk
 
categories,
 
including
 
Sustainability
 
risks.
 
The
 
CIB
 
Sustainability
 
Center
 
of
 
Excellence
 
and
 
the
 
Retail
 
Banking
sustainability
 
coordinators,
 
are
 
responsible
 
for
 
undertaking
 
all
 
relevant
 
sustainability
 
and
 
sustainable
 
finance
activities. In addition, the role of the
 
Group Sustainability Unit in the 1st
 
line includes the responsibility for managing
and coordinating
 
sustainability strategy
 
related
 
issues, the
 
development
 
of action
 
plans for
 
the
 
Group's Net
 
Zero
portfolio
 
strategies,
 
the
 
facilitation
 
of
 
the
 
Sustainability
 
data
 
framework
 
development,
 
as
 
well
 
as
 
Sustainability
Reporting,
 
Environmental
 
& Energy
 
Reporting (EMAS
 
Report,
 
Greenhouse
 
Gases Emissions
 
Report
 
per
 
ISO14064)
and Sustainability ratings.
2nd line
 
The Group
 
Risk Management
 
(GRM) is independent
 
from the
 
Business Units and
 
is fully responsible
 
for setting
 
the
risk
 
strategy
 
and
 
risk
 
appetite
 
framework,
 
including
 
sustainability
 
risks.
 
Within
 
the
 
GRM,
 
a
 
dedicated
 
Group
Sustainability Risk
 
(GSR) unit
 
has been
 
established, with
 
the
 
overall
 
responsibility for
 
overseeing,
 
monitoring and
managing sustainability risks and sustainable financing
 
activities, in cooperation
 
with the
 
other
 
GRM Units, as well
as with Group Compliance.
3rd line
 
The Group
 
Internal Audit
 
(Group IA)
 
independently reviews
 
the adequacy
 
and effectiveness
 
of the
 
internal control
framework
 
in place regarding Sustainability risk management, following
 
a risk-based approach.
For more information,
 
please refer to: 1.3.1
 
The role
 
of the administrative,
 
management and supervisory bodies ESRS 2 GOV-
1]
The
 
GSR has
 
the
 
overall
 
responsibility
 
for
 
overseeing,
 
monitoring and
 
managing sustainability
 
risks. More
 
specifically,
 
the
GSR
 
prepares
 
and
 
maintains
 
the
 
Group’s
 
Sustainability
 
risk
 
management
 
policies,
 
processes
 
and
 
methodologies,
 
in
collaboration
 
with the
 
Group Sustainability Unit
 
and the Business
 
and Risk Units. In
 
addition, it leads the
 
development and
implementation of the
 
Sustainability risk-related framework,
 
policies and processes, in coordination
 
with other
 
units, as well
as acts, monitors and reports
 
the progress
 
of the implementation
 
of the developed
 
Climate Risk action
 
plan and reports to
the Board for Sustainability risks matters. In addition, the GSR reviews and challenges
 
the involved stakeholders as to setting
the Financed Impact
 
Strategy (including Net
 
Zero targets), as
 
well as monitors the
 
Financed Impact Strategy
 
(including Net
Zero) and reports financial targets and KPIs. The GSR also
 
leads the 2nd line independent sustainable lending
 
re-assessment
process against the Sustainable Finance Framework criteria, including the characterization
 
of products of the Retail Portfolio
as sustainable.
 
Reviews
 
and confirms
 
the
 
Risk Assessment
 
and challenges
 
the
 
mitigating
 
actions
 
(as per
 
pre-determined
thresholds). Furthermore,
 
the GSR develops and maintains the Climate Risk Stress Testing Framework, as well as the scenario
analysis
 
and
 
stress
 
testing
 
methodologies,
 
and
 
coordinates
 
the
 
performance
 
of
 
sustainability
 
risk
 
scenario
 
analysis
 
and
relevant stress test exercises
 
at Group level.
 
Also, Eurobank enhanced its Governance
 
Structure and Committees to support the integration
 
of Sustainability risks:
Oversight
 
of
 
sustainability
 
risks
 
at
 
management
 
body
 
level
 
through
 
allocation
 
of
 
responsibilities
 
to
 
Board
 
and
management
 
committees.
 
Specifically,
 
Chairman
 
of
 
the
 
SMC
 
is
 
the
 
Deputy
 
Chief
 
Executive
 
Officer,
 
Group
 
Chief
Operating Officer
 
(Group COO) & International Activities.
A Board Member is responsible for
 
climate-related and environmental
 
risks.
Establishment
 
of
 
2
 
Committees
 
that
 
supplement
 
the
 
governance
 
arrangements
 
in
 
sustainability
 
risk,
 
i.e.
Sustainability Management Committee and Climate Risk Stress Test
 
Committee.
Appointment of Group Senior Sustainability Officer
 
to lead the Group’s
 
sustainability initiatives.
For more information
 
please refer to :
1.3.1 The role
 
of the administrative, management and supervisory bodies [ESRS 2 GOV-
1]
2.4.2
Strategy
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [ESRS
 
2 SBM-3]
Eurobank’s strategy,
 
climate transition plan ( as described in Chapter: 2.2.2)
 
and business model are closely integrated with
its
 
Sustainability
 
Risk
 
Management
 
Framework,
 
which
 
includes
 
robust
 
risk
 
management
 
processes
 
and
 
tools.
 
Eurobank
actively
 
evaluates
 
the
 
impact
 
of
 
climate
 
scenarios
 
on
 
its
 
counterparties,
 
helping
 
to
 
identify
 
climate
 
transition
 
financing
opportunities while ensuring resilience
 
to evolving
 
environmental and
 
regulatory risks. This
 
integration
 
of sustainability into
the bank's
 
risk management
 
practices
 
strengthens
 
its competitive
 
position by
 
enabling proactive
 
engagement with
 
clients
on sustainability-related matters.
 
It also aligns with regulatory expectations (i.e.
 
SSM’s 13 expectations on the management
climate-related
 
and environmental
 
risks) and supports
 
the
 
identification and
 
mitigation
 
of potential
 
financial losses linked
to sustainability risks.
Eurobank’s
 
risk
 
management
 
tools
 
ensure
 
comprehensive
 
assessment
 
and
 
monitoring
 
of
 
sustainability
 
risks
 
across
 
its
portfolio. While the integration of sustainability
 
factors may require clients
 
to provide additional data
 
and meet sustainability
requirements,
 
these
 
measures
 
safeguard
 
Eurobank
 
against
 
potential
 
risks
 
that
 
could
 
affect
 
its
 
market
 
perception
 
and
business model.
 
By embedding
 
sustainability considerations
 
into its
 
risk management
 
processes,
 
Eurobank
 
not only
 
meets
regulatory
 
obligations
 
but
 
also
 
enhances
 
its
 
long-term
 
resilience
 
and
 
sustainability,
 
securing
 
a
 
competitive
 
edge
 
in
 
the
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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marketplace. This dual approach
 
of addressing risks and leveraging
 
opportunities ensures that Eurobank’s
 
strategy remains
aligned with both its business model and its commitment
 
to sustainable growth.
Sustainability Risk
 
management
 
accounts for
 
regulatory
 
guidelines and
 
expectations,
 
such as
 
ECB and
 
EBA guidelines
 
on
Climate-related environmental
 
risks, as well as the market practices. The
 
Group has developed an implementation roadmap
in alignment
 
with the
 
SSM’s 13 expectations
 
on climate-related
 
and environmental
 
risks. For
 
more information
 
please refer
to the
Consolidated Pillar 3 Report - 11.1.3
 
Risk Management
.
2.4.3
Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank
 
identifies
 
material
 
impacts,
 
risks, and
 
opportunities
 
related
 
to integration
 
of
 
sustainability in
 
risk management
through a comprehensive
 
DMA. This approach integrates
 
industry benchmarks, stakeholder insights, and financial relevance
to ensure a robust evaluation
 
of integration of sustainability in risk management impacts.
Nevertheless,
 
for
 
the
 
identification
 
and
 
assessment
 
of
 
sustainability
 
risk
 
management
 
the
 
Group
 
has
 
developed
comprehensive processes
 
that include RIMA,
 
Risk appetite framework,
 
and ICAAP.
 
For more
 
information, please
 
refer to the
Consolidated
 
Pillar
 
3
 
Report
 
-
 
11.1.3
 
Risk
 
Management
 
and
TCFD
 
Climate
 
-
 
related
 
&
 
Environmental
 
Risk
 
Report
 
(Risk
Management)
.
The impacts, risks and opportunities associated with the integration
 
of sustainability in risk management matters are shown
in the table below:
Integration of sustainability in risk
 
management
Impact
Negative
Potential
The ESG / climate risk assessment may require
 
additional effort by
 
the clients in
order to provide
 
required ESG data and may result in additional conditions
 
to
comply with for financial agreements.
 
Risk
Client hesitance or inability to meet sustainability requirements
 
may impact
Eurobank's market perception,
 
potentially affecting its competitive
 
position and
leading to additional risks.
Opportunity
Integrating ESG in risk management in response
 
to evolving regulatory
 
requirements
and business needs improves
 
Eurobank's resilience
 
to sustainability-related risks,
safeguarding Eurobank
 
against potential financial losses, strengthening its overall
risk management framework.
2.4.4
Policies and Actions
Policies related to the
 
integration of sustainability
 
in risk management [MDR-P]
 
Eurobank
 
has
 
incorporated
 
sustainability
 
risk
 
aspects
 
across
 
all
 
pillars
 
of
 
its
 
Risk
 
Management
 
Framework,
 
through
 
the
establishment of
 
comprehensive
 
policies and
 
processes.
 
It is
 
among the
 
Group’s
 
priorities to
 
identify,
 
assess, manage
 
and
mitigate relevant risks, with a view
 
towards ensuring alignment with its business strategy,
 
as well as regulatory and industry
developments.
Group Risk Management Framework
 
(RMF) and Sustainability Risk Management Policy
The Group
 
Risk Management Framework
 
defines the roles and responsibilities
 
of the Group Risk Management (GRM), which
is
 
independent
 
from
 
the
 
Business
 
Units
 
as
 
a
 
2nd
 
line,
 
having
 
full
 
responsibility
 
for
 
the
 
establishment
 
of
 
the
 
Group’s
 
Risk
Strategy and Risk Appetite
 
Framework, as well as for monitoring all risks assessed as
 
material through the Risk Identification
and Materiality Assessment (RIMA) process,
 
including climate-related and environmental
 
risks undertaken by the
 
Group. For
more information please
 
refer to the
Group’s “TCFD
 
Climate - related & Environmental
 
Risk Report
”.
In
 
accordance
 
with
 
relevant
 
supervisory
 
expectations
 
and
 
the
 
Group’s
 
enhanced
 
governance
 
operating
 
model
 
for
 
the
incorporation of
 
sustainability risks across
 
the Three
 
lines of defense, new
 
roles and responsibilities
 
regarding sustainability
risk management have
 
been embedded into the Group
 
Risk Management Framework.
 
In addition, Eurobank
 
has developed
its Sustainability
 
Risk Management
 
Policy,
 
which aims
 
at fostering
 
a holistic
 
understanding
 
of the
 
effects
 
of sustainability
risks
 
on
 
its
 
business
 
model,
 
as
 
well
 
as
 
supporting
 
decision-making
 
regarding
 
these
 
matters
 
and
 
providing
 
a
 
robust
governance under
 
its Risk Management Framework.
Collateral Valuation
 
Policy
Eurobank
 
has refined
 
its Collateral
 
Valuation
 
Policy
 
(CVP) to
 
specify accepted
 
collateral
 
types and
 
valuation
 
procedures,
while integrating assessments of climate-related
 
and environmental risks. This involves
 
collecting pertinent information
 
such
as Energy
 
Performance
 
Certificates
 
(EPCs)
 
and incorporating
 
forward-looking
 
estimates
 
of natural
 
hazards.
 
The
 
updated
Policy
 
will also
 
consider broader
 
climate-related
 
and environmental
 
factors, such
 
as waste
 
management and
 
accessibility,
to enhance valuation accuracy and risk management.
 
 
 
 
 
 
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Credit Policy Manual
The
 
Group’s
 
credit policy
 
manual has
 
been updated
 
to integrate
 
sustainability-related
 
risks by
 
incorporating
 
climate
 
and
environmental factors
 
into credit risk management practices,
 
aligning with the SSM's expectations.
Group Environmental
 
and Social Policy
In this
 
context, the
 
Group has
 
developed
 
an Environmental
 
and Social Policy
 
that sets
 
the framework
 
of general
 
principles
and requirements
 
for
 
managing environmental
 
and social
 
issues. Through
 
the
 
Environmental
 
and Social
 
Policy,
 
the
 
Group
achieves and maintains compliance
 
with existing national
 
and international environmental and social
 
legislation/regulations,
as well as with its commitments, through a standardised
 
E&S assessment approach. Furthermore,
 
the objective of the
 
Policy
is,
 
inter
 
alia,
 
to ensure
 
timely
 
and accurate
 
reporting
 
to
 
the
 
European
 
Bank for
 
Reconstruction
 
and
 
Development
 
(EBRD)
concerning the management
 
of the Group ESMS.
 
As part of its Environmental and Social Policy,
 
Eurobank maintains a list of activities that are excluded from
 
financing, in line
with the exclusion lists
 
of the EBRD. For all
 
financing transactions, the Group ensures that
 
its clients
 
demonstrate an organised
and
 
systematic
 
approach
 
to
 
E&S
 
risk
 
management
 
that
 
complies
 
with
 
applicable
 
local,
 
national
 
and
 
international
environmental,
 
health
 
and
 
safety,
 
and
 
labour
 
legislation
 
and
 
standards,
 
relevant
 
permits,
 
as
 
well
 
as
 
public
 
disclosure
requirements.
The ESMS process
 
consists of client/activity environmental and social risk screening,
 
risk assessment process, decision
 
of risk
control approach
 
and ongoing performance
 
monitoring.
Know-Your-Customer
 
(KYC) and Anti-Money Laundering/Terrorist
 
Financing (AML/TF) policies and processes
Eurobank has established Know
 
-Your-Customer
 
(KYC) and Anti-Money Laundering/Terrorist
 
Financing (AML/TF) policies and
standards, which
 
are designed
 
to provide
 
safeguards against,
 
inter alia,
 
fraud and
 
cooperation
 
with clients
 
with increased
financial crime risk (i.e. risk of involvement
 
in money laundering and terrorist
 
financing).
Within the scope of customer KYC profiling, Eurobank applies enhanced due diligence measures upon establishing a business
relationship and
 
when carrying
 
out transactions
 
with natural
 
or legal persons/entities who
 
are classified as
 
high-risk as per
Eurobank’s relevant
 
internal processes.
Climate Risk Stress Test
 
Framework
The
 
Framework
 
provides
 
a transparent
 
and repeatable
 
process
 
for
 
designing and executing
 
the
 
climate risk
 
stress test,
 
as
well as for reporting
 
and evaluating stress test outcomes and determining
 
management actions.
For more information,
 
please refer to
Consolidated Pillar 3 Report - 11.1.3 Risk Management
 
and
TCFD Report-
 
Sustainability
Risk Management Tools
 
& Processes
.
Actions related to the integration
 
of sustainability in risk management [MDR-A]
The Group has developed the following processes and tools for the monitoring and management of
 
sustainability risks. These
processes have been embedded into the
 
Group’s operating
 
model and are performed
 
on an ongoing basis in the context of
continuous sustainability risk management:
Risk Identification and Materiality Assessment
 
(RIMA) process
The Risk Identification and Materiality Assessment (RIMA) process sets the appropriate mechanisms to identify, measure and
monitor risks at
 
an early
 
stage, as well
 
as to manage
 
their potential
 
impact on the
 
achievement
 
of the
 
Group’s
 
objectives.
Through the
 
RIMA process, the Group
 
identifies material risks that could potentially have a significant adverse
 
impact on its
financials, capital base, liquidity position or business model, as well
 
as any exposure to possible emerging risks.
As sustainability risks
 
interact with other risks and result in direct
 
distributional impacts and indirect
 
macroeconomic impacts,
the
 
Group
 
understands
 
that
 
careful
 
consideration
 
of
 
the
 
cross-cutting
 
nature
 
thereof
 
is
 
necessary
 
to
 
ensure
 
the
 
optimal
implementation
 
of adaptation
 
activities. As
 
such, the
 
Group
 
considers
 
sustainability risks
 
as drivers
 
of existing
 
risk types,
undertaking
 
a
 
holistic
 
and
 
systemic
 
approach
 
when
 
examining
 
the
 
complex
 
links
 
between
 
sustainability
 
risks
 
and
 
both
financial
 
and
 
non-financial
 
risks.
 
Eurobank
 
has
 
integrated
 
sustainability
 
risk
 
elements
 
into
 
its
 
existing
 
risk
 
management
processes, creating additional
 
procedures, policies
 
and tools so that these risks can be properly
 
identified and measured.
Sustainability
Risk
Data
The
 
Group
 
recognises
 
the
 
importance
 
of
 
relevant
 
and
 
reliable
 
data
 
for
 
the
 
provision
 
of
 
meaningful
 
insights,
 
suitable
 
for
decision-making purposes. Having already performed an assessment of sustainability data availability in its internal systems
against
 
regulatory
 
requirements/expectations,
 
the
 
Group
 
continues
 
to
 
enhance
 
its
 
sustainability
 
risk
 
data
 
aggregation
capabilities and
 
IT infrastructure
 
accordingly,
 
while also using
 
appropriate
 
controls
 
and safeguards
 
to ensure
 
the accuracy
and
 
completeness
 
of
 
the
 
compiled
 
information.
 
The
 
Group
 
seeks
 
to
 
further
 
improve
 
sustainability
 
risk
 
data
 
granularity
through allocating detailed roles and responsibilities, for the purposes of
 
sustainability data management and implementing
approaches for
 
addressing data needs
 
(i.e. engaging with external
 
data providers,
 
developing methodological
 
approaches
for estimating required
 
information).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Risk appetite
The
 
Group
 
articulates its
 
risk appetite
 
through
 
a set
 
of qualitative
 
and quantitative
 
statements with
 
respect to,
 
inter alia,
solvency,
 
liquidity, profitability,
 
asset quality and
 
other
 
areas related
 
to material
 
risks. The
 
purpose of these
 
indicators and
thresholds
 
is
 
to
 
facilitate
 
the
 
assessment
 
of
 
whether
 
the
 
Group
 
is
 
operating
 
within
 
its
 
defined
 
risk
 
appetite
 
levels.
 
The
outcome of
 
this process
 
is the
 
Risk Appetite
 
Statements (RAS)
 
document, whereas
 
the principles,
 
process
 
and governance
aspects related to the
 
RAS are outlined
 
in the Risk
 
Appetite Framework (RAF). The RAS are complemented
 
by a set
 
of Business
Line Statements (BLS), which constitute operational
 
metrics (and limits) at the business level
 
where the risks are
 
undertaken.
Moody’s Risk Analyst (MRA) model
The Group’s MRA Model assesses the CIB borrowers’
 
credit profile based on qualitative and quantitative criteria. Specifically,
the “Risk of Adverse Events” criterion assesses a client’s vulnerability to adverse developments or business interruptions, fines,
litigation and negative publicity, stemming, among others,
 
from environmental parameters
 
and social issues (e.g. health and
safety of customers).
Climate Risk Scorecard
In line
 
with leading
 
market practices,
 
as well
 
as taking
 
into account
 
supervisory requirements/expectations
 
with regard
 
to
establishing an approach for further assessing clients with
 
higher climate risk exposure, the Group has
 
developed the Climate
Risk Scorecard for
 
considering climate-related and environmental
 
risks.
In this context, an assessment
 
process based
 
on the Climate
 
Risk Scorecard
 
is performed
 
for all new
 
financing transactions,
limit increases and limit renewals (existing and new clients), initially applied to the Group’s
 
Corporate & Investment Banking
(CIB)
 
portfolio.
 
The
 
Climate
 
Risk
 
Scorecard
 
comprises
 
a
 
modular
 
questionnaire
 
which
 
includes
 
targeted
 
climate
 
risk
 
and
sustainable financing related questions, both qualitative and quantitative, capturing the following key dimensions: transition
risk, taxonomy aligned activities,
 
physical risk, sustainable financing, emissions,
 
strategy,
 
climate & environmental
 
incidents,
transition-green technology.
 
Interbank ESG Questionnaire
In recent years, the banking sector has faced
 
increased regulatory focus on ESG matters. Banks are now required
 
to improve
their credit
 
risk assessment
 
processes
 
to better
 
identify and evaluate
 
climate-related
 
and environmental
 
risks. In response,
the Hellenic
 
Bank Association
 
(HBA) and
 
major Greek
 
banks have
 
launched an
 
initiative
 
to create
 
a unified
 
Interbank ESG
Questionnaire
 
for
 
their
 
clients. This
 
questionnaire
 
aims to
 
standardize the
 
assessment
 
of ESG
 
factors
 
across
 
Greek banks,
ensuring compliance with regulatory expectations and international guidelines (e.g., EBA Guidelines, ECB's
 
climate risk guide,
and TCFD recommendations).
 
This process has been adopted by
 
the Group’s
 
entities in Greece and Cyprus as of 2024.
ESG Risk Assessment
 
Eurobank
 
has
 
developed
 
an
 
ESG
 
Risk
 
Assessment
 
by
 
combining
 
its
 
Climate
 
Risk
 
Scorecard
 
with
 
the
 
Interbank
 
ESG
Questionnaire. This comprehensive
 
approach helps assess and classify the
 
Group's clients based on ESG criteria, in line with
regulatory requirements.
 
Eurobank
 
uses an internal
 
ESG Risk Scoring
 
method, resulting
 
in one of
 
three ESG
 
risk categories:
High, Medium, or Low.
 
This assessment informs
 
credit decisions, considering ESG risks,
 
potential mitigation actions,
 
and due
diligence. The overall
 
approach aligns with Eurobank's business strategy,
 
enhances ESG risk awareness, supports sustainable
financing, and ensures compliance with the
 
Group's risk appetite and credit policies.
 
This process has been fully
 
adopted by
the Group’s
 
relevant entities in Greece and is gradually
 
being introduced into other
 
countries.
In 2025,
 
the similar
 
processes
 
and tools
 
for
 
the
 
monitoring and
 
management of
 
sustainability risks
 
will be
 
incorporated
 
in
Cyprus and Bulgaria.
2.4.5
Metrics & Targets
Sustainability risk management metrics [MDR-M]
Through
 
the
 
processes
 
described
 
above,
 
the
 
Group
 
monitors
 
its
 
performance
 
on
 
sustainability
 
through
 
the
 
metrics
 
and
indicators demonstrating the
 
sustainability risk level of its counterparties.
 
In
 
addition,
 
key
 
indicator
 
for
 
the
 
Group
 
is
 
the
 
allocation
 
of
 
its
 
portfolio
 
to
 
high
 
climate
 
impact
 
sectors
 
and
 
clients.
 
The
respective distribution
 
for 2024 is
 
presented in the
 
table below.
 
No external body other
 
than internal assurance
 
is provided
for the below
 
information.
2024 exposure
Loan exposures to sectors with high transition
 
risk in Group’s portfolios
bn €
24.9
Bond and share exposures to sectors that highly contribute to climate
change
bn €
1.4
Exposures towards the
 
top 20 most carbon intensive counterparties globally
in Group’s trading and
 
banking portfolios
mn €
31
 
 
 
 
 
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Sustainability risk management targets [MDR-T]
The Group
 
has achieved its
 
key Risk
 
Appetite Statement (RAS)
 
for at
 
least 20% of the
 
annual new CIB
 
disbursements to be
classified
 
as
 
green
 
/
 
environmentally
 
sustainable
 
loans,
 
by
 
applying
 
the
 
methodology
 
and
 
criteria
 
set
 
in
 
the
 
Group’s
Sustainable Finance Framework,
 
which outlines the
 
eligible approaches
 
and activities that
 
can be classified
 
as sustainable,
demonstrating the Group’s
 
commitment towards green transition.
 
In addition, the Group has demonstrated progress
 
in against the following areas which have been set as qualitative targets:
Significant progress in the
 
integration of sustainability risks in its Three
 
lines of defense Model
Incorporation of climate risk elements in
 
the Remuneration Policy (Please refer to “Integration of sustainability-related
performance in incentive
 
schemes [ESRS 2 GOV-3]” for
 
more information)
Deployment
 
of
 
the
 
ESG
 
Questionnaire,
 
which
 
has
 
been
 
developed
 
at
 
interbank
 
level
 
with
 
the
 
coordination
 
of
 
the
Hellenic Bank Association
Integration
 
of
 
the
 
ESG
 
Risk
 
Assessment
 
process,
 
a
 
combination
 
of
 
the
 
internal
 
Climate
 
Risk
 
Scorecard
 
and
 
the
Interbank ESG Questionnaire
Assessment
 
of
 
sustainability
 
risks
 
through
 
Sectoral
 
Analysis
 
and
 
forward-looking
 
Scenario
 
Analysis,
 
as
 
part
 
of
 
the
TCFD report (For
 
more information please refer
 
to:
“ TCFD Climate-Related & Environmental
 
Risk Report”
 
)
Alignment of its Risk Appetite with the articulated
 
Sustainability Strategy
Incorporation of climate risk aspects in collateral
 
valuation
Publication of the TCFD
 
Climate-Related & Environmental Risk Report
Performance
 
of
 
training
 
sessions
 
for
 
its
 
employees
 
in
 
relation
 
to
 
Climate
 
Risk,
 
ESG
 
Risk
 
Disclosures
 
and
 
ESG
 
Risk
Assessment
Further
 
integrate
 
climate
 
risk
 
regulatory
 
requirements
 
into
 
its
 
business
 
strategy
 
and
 
risk
 
management
 
framework,
leveraging
 
on key initiatives:
o
Governance, policies
 
and control framework.
o
Climate risk modelling and data management.
o
Commercial strategies/sector
 
policies.
o
Eurobank S.A. and its subsidiaries aim
 
to implement climate risk and
 
environmental action plans by 2025. These
initiatives are designed to ensure full alignment
 
of policies, actions, and
 
strategies across Eurobank Greece and
its subsidiaries, fostering a cohesive
 
and unified approach to achieving organizational
 
objectives.
2.5
Sustainable financing and investment offerings
 
[Entity-specific]
2.5.1
Governance
The role
 
of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
Aiming to implement the Sustainability Strategy, the
 
Group has appointed a Group Senior Sustainability Officer responsible
for
 
the
 
implementation
 
of
 
the
 
Group’s
 
Sustainability
 
Strategy
 
and
 
engaging
 
the
 
following
 
committees
 
that
 
actively
contribute to
 
the
 
promotion
 
of sustainable
 
financings and
 
investment
 
offerings
 
and their
 
integration
 
into the
 
day-to-day
operations of the
 
Group:
Sustainability Management Committee (Sustainability
 
ManCo): Acts as
 
the final approval body, inter alia with
 
regards
to the inclusion
 
or substitution of
 
Eligible assets of the
 
Green Bond Portfolio,
 
and to the
 
update of the
 
annual Green
Bond Report.
 
The
 
Committee
 
approves
 
the
 
Sustainability
 
Frameworks
 
(e.g. Sustainable
 
Finance
 
Framework,
 
Green
Bond Framework,
 
Sustainability Policy Framework
 
and Sustainability Investment Framework)
Group
 
Asset
 
and
 
Liability
 
Committee
 
(G-ALCO):
 
Within
 
the
 
context
 
of
 
the
 
approved
 
investment
 
framework
 
for
corporate/FI bond portfolio,
 
reviews the relevant
 
portfolio limits annually.
As far
 
as the
 
Group Sustainability
 
Risk (GSR)
 
Unit is concerned,
 
it has the
 
overall
 
responsibility for
 
overseeing,
 
monitoring,
and
 
managing
 
sustainability
 
risks.
 
More
 
specifically,
 
the
 
GSR
 
leads
 
the
 
2nd
 
line
 
independent
 
sustainable
 
lending
 
re-
assessment process against
 
SFF criteria, including the characterisation
 
of retail portfolio
 
products as sustainable. Also, GSR
 
is responsible for the
 
assessment the sustainability features
 
of new loans/products according
 
to the SFF criteria.
Regarding the Business
 
Units CIB and Retail
 
Banking, are primarily involved
 
in executing all sustainable financing activities,
including
 
the
 
implementation
 
of
 
the
 
Financed
 
Impact
 
Strategy.
 
Key
 
responsibilities
 
are
 
classified,
 
inter
 
alia,
 
under
 
the
following
 
3 main categories:
1.
Sustainability
 
Strategy:
 
Executing
 
and
 
monitoring
 
financed
 
and
 
specific
 
operational
 
sustainable
 
goals
 
and
performance targets
 
in line with the Net Zero
 
Strategy.
2.
Sustainable
 
Financing/Funding
 
and
 
Investments:
 
Identifying
 
sustainable
 
financing
 
opportunities
 
and
 
designing
relevant
 
solutions
 
and
 
sustainable
 
products.
 
Performing
 
the
 
sustainable
 
financing
 
assessment,
 
in
 
line
 
with
 
the
Sustainable
 
Finance
 
Framework.
 
Implementing
 
and
 
monitoring
 
the
 
Sustainable
 
Investment
 
and
 
Green
 
Bond
Frameworks.
 
3.
Sustainability
 
Risk
 
Management:
 
Performing
 
the
 
ESG
 
Risk
 
Assessment
 
and
 
formulating
 
mitigation
 
action
 
plans,
where required.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Dedicated functions, namely the Sustainability Centers of
 
Excellence (CoE), within the Business Units
 
(Corporate & Investment
Banking and Retail
 
Banking) are responsible for
 
assessing, managing
 
and monitoring risk
 
levels in all
 
risk categories, including
Sustainability risks.
 
The
 
Head of
 
CIB Sustainability
 
CoE is
 
responsible
 
for
 
overseeing
 
sustainable financing
 
activities, while
two Retail
 
Banking Sustainability
 
Coordinators (Business
 
and Individual
 
clients respectively)
 
are responsible
 
for
 
organising
and supporting sustainable-related activities.
Also, Group Compliance’s key roles
 
and responsibilities regarding sustainable financing and investment offerings include the
Regulatory Compliance:
o
Monitors the regulatory environment
 
and emerging trends
 
around sustainable financing
 
o
Monitors the alignment of
 
the Group’s activities with applicable laws, rules,
 
regulations and standards, including
sustainable finance regulatory aspects.
2.5.2
Strategy
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [SBM-3]
The
 
Group
 
acknowledges
 
that
 
sustainable
 
development
 
is
 
key
 
to
 
prosperity.
 
To
 
this
 
end,
 
its
 
commitment
 
to
 
support
 
the
transition
 
to a
 
greener
 
economy by
 
offering
 
financing solutions
 
that foster
 
growth,
 
and sustainable
 
development
 
is at
 
the
core of its Financed Impact Strategy.
Leveraging
 
on tools and enablers, such as the Sustainable Finance Framework,
 
the Group’s strategic
 
approach is to support
the
 
achievement
 
of
 
the
 
sustainability
 
objectives
 
through
 
financing,
 
advisory
 
and
 
capital
 
raising
 
solutions
 
to
 
current
 
and
potential clientele.
Sustainable financing is at the
 
core of the
 
Bank’s Financed Impact Strategy,
 
guiding the approach
 
of offering
 
products and
services
 
that
 
support
 
green
 
transition
 
and
 
social
 
investments.
 
This
 
strategy
 
emphasises
 
driving
 
positive
 
sustainability
outcomes by
 
not only
 
financing projects
 
that contribute
 
to environmental
 
and social progress
 
but also incentivizing
 
clients
to improve
 
their sustainability performance.
 
Through
 
these sustainable financing
 
offerings,
 
the Group
 
seeks to create long-
term
 
value for
 
both
 
its stakeholders
 
and society,
 
aligning with
 
broader
 
climate
 
and social
 
goals.
 
By focusing
 
on financed
impact, Eurobank ensures
 
that its investments have
 
a measurable and positive
 
effect on sustainability.
In line with its commitment to address climate
 
change, the Group has joined
 
the Net-Zero
 
Banking Alliance (NZBA), a bank-
led, UN-convened
 
alliance of
 
banks worldwide,
 
reinforcing
 
its dedication
 
to aligning
 
its lending
 
and investment
 
portfolios
with net-zero
 
emissions by 2050
 
or sooner,
 
in line with
 
the most ambitious
 
targets set by
 
the Paris
 
Climate Agreement.
 
Key
enabler towards this commitment
 
is the promotion
 
of sustainable finance that will enable the
 
green transition of its clients.
However,
 
there are challenges associated
 
with sustainable finance, including the risk that
 
some products may not fully meet
globally recognised
 
sustainable finance
 
criteria, which could
 
lead to perceptions
 
of greenwashing
 
and damage Eurobank’s
credibility.
 
In addition,
 
evolving
 
market preferences
 
and regulatory
 
shifts may
 
impact the
 
demand for
 
sustainable finance,
posing risks to Eurobank’s current
 
product offerings.
 
Despite these risks, there
 
are clear opportunities for growth
 
by aligning
green
 
and
 
social
 
investments
 
with
 
climate
 
transition
 
requirements
 
and
 
changing
 
consumer
 
preferences.
 
This
 
approach
enhances Eurobank’s
 
brand
 
reputation,
 
attracts
 
sustainability-conscious
 
investors,
 
and positions
 
the
 
Group
 
as a
 
leader
 
in
responsible finance, ensuring that its business model
 
remains resilient and forward
 
-looking.
2.5.3
Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank
 
identifies
 
material
 
impacts,
 
risks,
 
and
 
opportunities
 
related
 
to
 
sustainable
 
financing
 
and
 
investment
 
offerings
through a comprehensive
 
DMA. This approach integrates
 
industry benchmarks, stakeholder insights, and financial relevance
to ensure a robust evaluation
 
of sustainable financing and investment offerings
 
impacts.
The
 
impacts, risks
 
and opportunities
 
associated with
 
sustainable financing
 
and investment
 
offerings
 
matters
 
are shown
 
in
the table below:
Sustainable financing and investment offerings
Impact
Positive
Actual
Eurobank provides
 
sustainable finance products and services
 
that promote green
 
and
social investments and incentivise improvement
 
of its clients’ ESG performance
 
.
Risk
Evolving market preferences
 
and regulatory shifts may impact the demand for
sustainable finance, posing risks to Eurobank's existing
 
product offerings.
Opportunity
Promoting green and social investments
 
in line with requirements to support climate
transition and in response to changing consumer
 
preferences
 
enhances Eurobank's
brand reputation, attracting
 
sustainability conscious investors.
 
 
 
 
 
 
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2.5.4
Policies and Actions
Policies on sustainable financing and investment
 
offerings [MDR-P]
The Group
 
has approved
 
and implements as
 
part of the
 
operationalization
 
its Sustainable Finance
 
Framework
 
(SFF), which
encompasses
 
a
 
wide
 
range
 
of
 
sustainable-green
 
lending
 
activities
 
and
 
supports
 
the
 
identification
 
and
 
classification
 
of
sustainable-green
 
financings,
 
covering
 
both
 
Corporate
 
and
 
Retail
 
banking
 
portfolios.
 
Eurobank
 
developed
 
its
 
SFF
 
in
accordance
 
with internationally
 
recognised industry
 
guidelines and
 
principles. In
 
addition, Eurobank
 
developed
 
and made
publicly
 
available
 
its
 
Green
 
Bond
 
Framework.
 
This
 
framework
 
facilitates
 
Eurobank
 
in
 
order
 
to
 
meet
 
its
environmental/sustainability commitments and finance
 
projects that will deliver environmental
 
benefits to the economy and
support Eurobank’s
 
business
 
strategy
 
and vision.
 
Furthermore,
 
Eurobank
 
approved
 
its Sustainable
 
Investment
 
Framework,
which outlines Eurobank’s available sustainable investment
 
approaches/strategies,
 
the selection of eligible investments
 
and
the monitoring
 
frequency of
 
the sustainable
 
portfolio
 
(the sustainable
 
portfolio
 
is part
 
of Eurobank’s
 
investment
 
portfolio).
Eurobank is
 
committed to engaging with
 
stakeholders
 
by ensuring a
 
high level
 
of accountability in policy
 
development
 
and
implementation. Policies
 
are approved
 
by the appropriate
 
Governance bodies such as
 
the Board of Directors
 
or specialized
committees, which ensure that there
 
is alignment with the Group's
 
strategic goals and stakeholder
 
interests.
More specifically:
 
Through
 
the
 
SFF
 
Eurobank
 
is
 
able
 
to
 
classify
 
sustainable
 
lending
 
solutions
 
offered
 
to
 
its
 
customers,
 
specifying
 
the
applied classification
 
approach
 
and the
 
activities defined
 
as eligible
 
to access
 
sustainable financing
 
(eligible green
and social assets).
 
The SFF scope encompasses a
 
wide range of sustainable
 
lending products, covering both wholesale
and retail
 
banking portfolios.
 
The
 
SFF also
 
incorporates
 
the
 
assessment process
 
of the
 
EU Taxonomy
 
for
 
which the
Group
 
pursues Taxonomy
 
-alignment
 
of financings
 
on a
 
best effort
 
basis.
 
The
 
purpose of
 
establishing the
 
SFF
 
is to
provide a clear
 
and comprehensive
 
methodology for
 
classifying, monitoring and reporting sustainable financing.
 
The
policy applies to all financial transactions, excluding certain activities deemed
 
incompatible with sustainability goals,
such as
 
fossil
 
fuel
 
extraction
 
or high
 
carbon-intensive
 
projects.
 
It covers
 
the
 
entire
 
value chain,
 
both
 
upstream
 
and
downstream.
 
Key
 
stakeholder
 
groups
 
affected
 
include
 
investors,
 
customers,
 
and
 
communities
 
within
 
operational
regions.
 
The
 
Group
 
Senior
 
Sustainability
 
Officer
 
(GSSO)
 
holds
 
the
 
highest
 
level
 
of
 
accountability
 
for
 
the
implementation and oversight
 
of the policy
 
within the
 
organisation. The
 
SFF draws from
 
guiding frameworks
 
such as
the LMA principles for loans – Green Loan Principles, Sustainability-Linked Loan Principles as well as the EU Taxonomy
Climate Delegated Act. For
 
more information please
 
refer to:
Sustainable Finance Framework
.
The Sustainable Investment Framework (SIF) aims to classifying investments as
 
sustainable based on
 
criteria observed
in
 
international
 
market
 
practices.
 
Eurobank’s
 
SIF
 
outlines
 
Eurobank’s
 
potential
 
sustainable
 
investment
approaches/strategies,
 
the process
 
for selecting
 
eligible investments,
 
as well
 
as the
 
monitoring frequency
 
regarding
the
 
sustainable portfolio.
 
Its scope
 
includes the
 
bond investment
 
portfolio,
 
for
 
both
 
direct and
 
indirect investments
across
 
all
 
sectors,
 
regions,
 
and
 
value
 
chains,
 
with
 
exclusions
 
in
 
areas
 
such
 
as
 
high-risk
 
fossil
 
fuels
 
and
 
activities
detrimental to biodiversity
 
or human rights. The
 
policy applies to all stakeholders
 
involved in
 
the investment
 
process.
Accountability for its implementation
 
lies with the organisation's
 
Group Senior Sustainability Officer
 
(GSSO).
 
The
 
Green
 
Bond Framework
 
(GBF)
 
assists Eurobank
 
in meeting
 
its environmental/
 
sustainability commitments
 
and
finance projects that will deliver
 
environmental benefits to the
 
economy and support its business strategy and vision.
The Green
 
Bond Framework
 
is developed
 
in accordance
 
with global
 
best practices
 
and standards and
 
considers EU
Taxonomy
 
eligibility criteria to classify potential investments as green.
 
The Framework
 
defines the eligible assets and
associated
 
criteria,
 
the
 
use
 
of
 
proceeds,
 
the
 
process
 
for
 
project
 
evaluation
 
and
 
selection,
 
the
 
management
 
of
proceeds,
 
as well
 
as the
 
relevant
 
reporting obligations.
 
Its general
 
objectives include
 
promoting
 
green investments,
while
 
ensuring
 
transparency
 
and
 
accountability
 
in
 
the
 
use
 
of
 
proceeds.
 
The
 
scope
 
of
 
the
 
framework
 
covers
 
both
upstream
 
and
 
downstream
 
activities
 
related
 
to
 
eligible
 
projects,
 
across
 
global
 
geographies,
 
with
 
exclusions
 
for
projects involving fossil fuels, or other environmentally
 
harmful practices. The Sustainability ManCo approves the GBF.
Accountability for
 
its implementation lies
 
with the
 
organisation's GSSO.
 
The Green
 
Bond Framework
 
has obtained a
Second Party
 
Opinion (
Green Bond Framework
 
-
 
Second Party Opinion
) for
 
its alignment with
 
the ICMA
 
Green Bond
Principles (GBP) and the EU Green Bond Standard (GBS).
 
)
For
 
more information
 
regarding
 
Policies
 
related
 
to Financial
 
Inclusion please
 
refer
 
to: “3.2.2: Policies
 
related
 
to consumers
and end-users [S4-1]”.
Actions on sustainable financing and investment offerings
 
[MDR-A]
The
 
Group
 
takes
 
key
 
actions
 
to
 
promote
 
sustainable
 
financing.
 
These
 
processes
 
have
 
been
 
embedded
 
into
 
the
 
Group’s
operating
 
model in
 
order to
 
ensure that
 
the Group
 
provides
 
continuous sustainable
 
financing and investment
 
offerings
 
on
an ongoing basis:
Net-Zero Banking Alliance (NZBA) Commitment
Key element of the Group’s NZBA commitment is the establishment of sectoral decarbonisation targets covering the Group’s
lending portfolios,
 
with phased
 
target-setting up
 
to 2050.
 
The
 
promotion
 
of sustainable
 
financing that
 
will enable
 
client’s
transition is the
 
key enabler towards achieving
 
those targets.
 
 
 
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Sustainable Finance Framework
Eurobank’s SFF defines four
 
classification approaches
 
for classifying its financing and investing activities as sustainable:
Dedicated-purpose
 
– Green/Social
 
loans:
Project-specific
 
loans or
 
financing instruments
 
whose use
 
of proceeds
 
is
100% directed
 
towards eligible
 
green /
 
social activities.
 
The
 
SFF defines
 
the eligible
 
activities (for
 
the wholesale
 
and
retail
 
portfolios)
 
along with
 
the
 
applicable
 
eligibility and
 
exclusionary
 
criteria
 
that
 
need
 
to be
 
fulfilled.
 
The
 
eligible
areas
 
and
 
activities
 
include
 
energy
 
efficiency,
 
renewable
 
energy,
 
clean
 
transportation,
 
green
 
buildings,
 
pollution
prevention and control, and circular economy regarding the
 
green activities, and economic inclusion, affordable basic
infrastructure,
 
access to
 
essential services,
 
affordable
 
housing, food
 
security and
 
sustainability regarding
 
the
 
social
activities.
General-purpose – Company
 
business mix:
Financing to companies that
 
fulfil the eligibility
 
green/social criteria and
derive their revenue
 
from eligible activities. Specifically, companies are
 
eligible under the business mix category when
they derive
 
a minimum predefined percentage of their
 
total revenue
 
from eligible activities.
General-purpose
 
 
Sustainability-linked
 
loans/facilities:
The
 
second
 
type
 
of
 
general-purpose
 
lending
 
adopted
relates
 
to Sustainability
 
Linked
 
Loans
 
(SLL). The
 
purpose of
 
SLLs
 
is to
 
enable and
 
accelerate
 
the
 
ESG
 
transition
 
of
clients. Through SLLs, Eurobank
 
provides ESG-related
 
incentives to its clients, by offering
 
products (loans, bond loans,
etc.) with terms
 
linked to ambitious
 
and predefined
 
Sustainability Performance
 
Targets
 
(SPTs).
 
The SPTs
 
are specific
targets that aim to improve
 
the ESG performance
 
of the client.
Recovery
 
and Resilience
 
Facility-based
 
approach:
Activities approved
 
through
 
the
 
Greek Recovery
 
and Resilience
Facility, contributing to the
 
green pillar.
Sustainable Finance Framework
 
Assessment Tool
Eurobank
 
has
 
developed
 
a
 
web-based
 
SFF
 
Assessment
 
Tool.
 
Integrated
 
within
 
its
 
core
 
systems,
 
for
 
the
 
CIB
 
portfolio,
 
to
underpin the classification and evaluation of sustainable/green
 
financing opportunities in a structural manner, as part of the
loan
 
origination
 
process.
 
The
 
SFF
 
Assessment
 
Tool
 
is delivered
 
through
 
an online
 
platform
 
a workflow
 
-based
 
application
which automates the process
 
of assessing the Group’s
 
financing solutions against the
 
criteria defined in the SFF.
 
Sustainable financing products
ESG programme for
 
hotels
Eurobank supports the
 
tourism industry's sustainability through two ESG programmes
 
for hotels:
1.
"Doing
 
Business
 
Sustainably
 
in
 
Tourism":
 
Offers
 
incentives
 
to
 
existing
 
hotel
 
borrowers
 
who
 
meet
 
sustainability
targets, catering to both
 
advanced and beginner hotels in ESG.
2.
“Constructing
 
Sustainably
 
in
 
Tourism":
 
Provides
 
incentives
 
for
 
new
 
hotel
 
projects
 
or
 
upgrades
 
that
 
meet
environmental construction standards.
ESG Deposits
Eurobank was the first Greek bank to offer ESG Deposits to its corporate clientele, and continues to offer this product,
allowing
 
its
 
clients
 
to
 
contribute
 
to
 
sustainable
 
development
 
projects.
 
The
 
amount
 
raised
 
from
 
ESG
 
Deposits
 
is
allocated to financing green and sustainability linked loans,
 
in agreement with Eurobank’s
 
SFF.
ESG-focused mutual criteria
Eurobank
 
has
 
introduced
 
the
 
LF
 
FoF
 
 
ESG
 
Focus,
 
a
 
mutual
 
fund
 
that
 
invests
 
in
 
shares
 
and
 
bonds
 
based
 
on
 
ESG
(Environmental,
 
Social, and Governance)
 
criteria. The
 
fund features
 
a diversified
 
portfolio
 
of equities and bonds that
adhere to ESG principles.
Green Mortgage Loans
Eurobank
 
has played
 
a key
 
role
 
in energy
 
-saving initiatives
 
in Greece,
 
, particularly
 
through
 
its participation
 
in the
Exoikonomo
 
programmes
 
since
 
2011,
 
which
 
support
 
the
 
energy
 
upgrade
 
of
 
private
 
homes.
 
In
 
2024,
 
the
 
Group
continued to solidify its
 
presence in green mortgage loans
 
by participating in Exoikonomo 2021, and Exoikonomo 2023
development
 
programmes
 
funded
 
by
 
the
 
EU's
 
Recovery
 
and Resilience
 
Facility.
 
The
 
programme
 
offer
 
interest
 
rate
subsidies, state
 
loan guarantees,
 
grants, and
 
other
 
support for
 
households making
 
green improvements
 
like energy
efficiency
 
upgrades
 
and
 
smart
 
home
 
automation.
 
For
 
those
 
not
 
eligible
 
for
 
Exoikonomo,
 
Eurobank
 
offers
 
a
 
Green
Mortgage
 
Loan
 
to
 
finance
 
energy-efficient
 
home
 
improvements,
 
such
 
as
 
installing
 
solar
 
panels
 
or
 
upgrading
insulation. Through
 
these efforts,
 
Eurobank
 
aims to help
 
Greece meet
 
its environmental
 
goals by
 
offering
 
accessible
green financing solutions for homeowners. In addition, initiatives related to the provision of green mortgage loans are
also in place in Group’s operations
 
in Bulgaria, as well as, in Cyprus.
Photovoltaic SB Loans
Eurobank offers
 
Photovoltaic SB
 
Loans to small businesses for
 
investing in renewable
 
energy,
 
specifically through
 
the
production
 
and sale
 
of energy
 
from photovoltaic
 
systems. Businesses
 
can choose
 
between a
 
loan or
 
leasing option,
with
 
the
 
loan
 
covering
 
up
 
to
 
80%
 
of
 
the
 
total
 
investment
 
costs,
 
including
 
infrastructure,
 
equipment
 
purchase
 
and
installation, site setup, and connection expenses.
Bridge Financing – Exoikonomo
Eurobank’s Bridge Financing - Exoikonomo
 
programme
 
provides a credit line to suppliers
 
and contractors working on
properties
 
under
 
the
 
Exoikonomo
 
 
Aftonomo
 
and
 
Exoikonomo
 
2021
 
programmes.
 
This
 
financing
 
helps
 
them
 
pre-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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finance their
 
work until
 
they are
 
paid through
 
the government
 
subsidies. Suppliers
 
can receive
 
up to 80%
 
or 100% of
the subsidy amount their customers
 
are eligible for,
 
regardless of whether
 
the customers use
 
Eurobank loans.
Our
 
actions
 
to
 
promote
 
sustainable
 
financing,
 
originally
 
developed
 
for
 
our
 
core
 
operations,
 
are
 
strategically
 
and
proportionally adapted and
 
deployed across
 
subsidiaries in Bulgaria, Cyprus, and Luxembourg.
 
For example, the
 
offering of
green lending such as Green home programmes, Green Car programme
 
s
 
for the purchase of new electric or hybrid cars, eco-
auto loans,
 
etc. While
 
these programs
 
are tailored
 
to address
 
the
 
specific local
 
contexts and
 
regulatory
 
environments,
 
we
are working towards achieving
 
a Group alignment.
ESG awareness and capacity building
Eurobank
 
is prioritising
 
the
 
development
 
of its
 
employees'
 
capabilities
 
to ensure
 
they
 
can effectively
 
assist clients
 
in their
sustainability efforts
 
and facilitate their
 
transition to green transition.
 
For more
 
information, please refer
 
to section 1.3.1.
 
The
role of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
Dedicated training sessions
 
to Business Units
Apart from the
 
general upskilling
 
programmes,
 
during the past
 
years the
 
Group has conducted
 
dedicated sessions tailored
to the requirements of specific business
 
units and functions, crucial
 
for delivering the Group’s strategy.
 
These sessions focused
on engaging with clients to enable their green transition
 
efforts and identifying
 
sustainable financing opportunities through
publicly available sources, such as company sustainability disclosures.
 
A
 
sustainability
 
awareness
 
training
 
was
 
conducted
 
for
 
the
 
Board
 
of
 
Directors,
 
enhancing
 
the
 
understanding
 
of
 
CSRD
Reporting requirements, including Double Materiality
 
Assessment, EU Taxonomy
 
and disclosure requirements among others.
Through
 
their participation
 
in this
 
training, the
 
Board of
 
Directors developed
 
a comprehensive
 
understanding of
 
the
 
CSRD
requirements
 
and
 
learned
 
how
 
to
 
consider
 
these
 
in
 
the
 
company’s
 
strategic
 
planning
 
and
 
long-term
 
growth
 
objectives
effectively
2.5.5
Metrics & Targets
Metrics on sustainable financing and investment offerings
 
[MDR-M]
The
 
corporate
 
portfolio
 
of
 
Eurobank.,
 
which
 
is
 
the
 
Group’s
 
key
 
entity
 
sustainable
 
stock
 
exposures
 
amount
 
to
 
 
2.98
 
bn
demonstrating
 
a 37%
 
year-on-year
 
growth,
 
in line
 
with the
 
Group’s
 
green stock
 
targets, while
 
annual disbursements
 
have
reached
 
the
 
respective
 
annua
 
target.
 
The
 
tables
 
below
 
present
 
the
 
allocation
 
of
 
sustainable
 
exposures
 
as
 
well
 
as
 
the
disbursed amounts within 2024:
Corporate Banking
Outstanding balance as of
31.12.2024 (mn €)
Disbursed amounts within
2024 (mn €)
Dedicated purpose financings
1,898
537
Renewable energy
1,429
419
Green buildings
230
75
Energy efficiency
192
-
Clean transportation
40
36
Pollution Prevention
 
& Control & Circular Economy
8
7
General purpose financings
1,088
736
Business mix
80
29
Sustainability-Linked Loans (SLL)
1,008
707
Total sustainable financing
2,986
1,273
For
 
further
 
information
 
regarding
 
Sustainability-Linked
 
Loans
 
(SLL),
 
please
 
refer
 
to
 
note
 
20
 
“Loans
 
and
 
advances
 
to
customers” of the
 
consolidated financial statements.
In relation to the retail
 
portfolio, the
 
balance as of the end of 2024 stands at € 182 mn, while € 100 mn were
 
disbursed within
2024.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Retail Banking
Outstanding balance as of
31.12.2024 (
mn €)
Disbursed amounts
within 2024 (
mn €)
Green mortgage loans
105
72
Energy renovation
 
loans
26
8
Bridge Financing - Exoikonomo
-
-
Electric vehicle loans
5
2
Photovoltaic SB loans
 
to small businesses and individuals
38
12
Net metering
1
-
Other dedicated
 
purpose sustainable loans to small businesses
7
5
Total sustainable financing
182
100
Regarding bond positions, as at 31.12.2024
 
the Bank held € 226 mn in Sustainability-Linked
 
Bonds.
Positions in green / sustainable bonds in
 
the Banking Book
Unit
Outstanding balance as of 31.12.2024
Positions in Sustainability-Linked Bonds
mn €
226
For
 
more
 
information
 
on
 
Sustainability-Linked
 
Bonds,
 
please
 
refer
 
to
 
note
 
22
 
“Investment
 
securities”
 
of
 
the
 
consolidated
financial statements.
Targets
 
on sustainable financing and investment offerings
 
[MDR-T]
As part of
 
the Group’s
 
ongoing efforts
 
to align its
 
business strategies
 
with global
 
sustainability goals,
 
the financed
 
impact
strategy is
 
underpinned by
 
clear targets
 
for
 
Eurobank’s
 
sustainable finance
 
and investment
 
offerings.
 
These
 
targets reflect
its dedication
 
to integrating
 
ESG factors
 
into our
 
financial services,
 
and they
 
guide its
 
approach
 
to funding
 
projects
 
that
have a positive impact on both society and the environment.
 
Through transparent
 
and measurable goals, we aim to support
the
 
transition
 
to a
 
more sustainable
 
economy while
 
delivering
 
responsible investment
 
opportunities for
 
Eurobank’s
 
clients.
Sustainable financing
 
targets are
 
based on
 
the
 
classification
 
approach
 
and/or eligible
 
activities described
 
by the
 
Group’s
SFF.
 
The table below demonstrates
 
Eurobank’s performance
 
against the targets set:
2024 Performance and progress
Portfolio
 
Targets
€2 billion in new green disbursements to businesses
 
by 2025
> € 2 bn as of 2024 - On track to meet target
20% of the annual new corporate
 
disbursements to be classified as
green
c. 21% - Annual target achieved
20% stock of green exposures by 2027 for
 
the corporate
 
portfolio
c. 16% - on track to achieve target
Mobilise €2.25 billion total green RRF funds in the
 
Greek economy
by 2026
c. € 2.1 bn - on track to achieve
 
target
No new investments in fixed income
 
securities (excluding exposures
in Sustainability / Green Bonds towards the top 20
 
most carbon-
intensive corporates worldwide.
0 new exposures – Target
 
maintained
Double annual disbursements of sustainability-linked loans
c. € 0.7 bn in SLL, disbursements, double in relation to
2023 – Annual target achieved
Sectoral targets
35%
 
of
 
new
 
disbursements
 
in
 
the
 
energy
 
sector
 
to
 
be
 
directed
 
to
(RES) financing
> 60% of sectoral disbursements towards RES
 
Annual target achieved
80% of
 
disbursements related
 
to the
 
construction of
 
new buildings
to be allocated to green buildings
100% of disbursements to construction of green
buildings – Annual target achieved
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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2024 Performance and progress
Retail Banking targets
Maintain the same growth
 
in absolute terms for
 
Retail Banking
new green disbursements (or more
 
than 50% increase vs. 2023)
More than € 100 million increase in our new
 
green
disbursements towards households and small
businesses – Annual target achieved
 
Once Group’s
 
Net-Zero Strategy
 
will be finalized, each subsidiary will
 
set its own specific
 
targets. This will
 
ensure that every
part
 
of
 
the
 
Group
 
effectively
 
contributes
 
to
 
our
 
overall
 
sustainability
 
goals
 
while
 
considering
 
their
 
unique
 
operational
contexts and challenges.
 
 
 
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3
Social information
3.1
Own workforce
 
[ESRS S1]
3.1.1
Strategy
 
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [ESRS
 
2 SBM-3]
The actual
 
and potential impacts
 
on own workforce
 
which have been
 
identified in the
 
course of the
 
DMA are connected
 
to
the
 
Group’s
 
strategy.
 
The
 
Group
 
has
 
committed
 
to
 
contributing
 
to
 
the
 
achievement
 
of
 
the
 
United
 
Nations
 
Sustainable
Development Goals (SDGs) and the
 
UN 2030 Agenda, as a signatory to the UN Global Compact since 2008, and by actively
promoting
 
its
 
fundamental
 
principles
 
and
 
applying
 
the
 
precautionary
 
approach.
 
In
 
this
 
context,
 
in
 
2022
 
a
 
new
 
holistic
Sustainability Strategy
 
was prepared,
 
that was
 
revised
 
in 2024,
 
the implementation
 
of which
 
is based
 
on two
 
main pillars
Operational Impact and Financed Impact. Key component of the Operational
 
Impact Strategy is Eurobank’s Societal Impact
that
 
focuses
 
on
 
providing
 
a
 
diverse
 
and
 
inclusive
 
environment
 
for
 
its
 
people
 
and
 
clients,
 
while
 
fostering
 
sustainable
development
 
and prosperity
 
for the
 
benefit of society.
 
The Societal
 
impact encompasses several
 
key commitments,
 
such as
embedding
 
a
 
diverse
 
and
 
inclusive
 
environment
 
by
 
2030,
 
cultivating
 
a
 
culture
 
of
 
wellbeing
 
by
 
2026.
 
These
 
key
 
strategic
commitments
 
address
 
material
 
IROs
 
of working
 
conditions,
 
other
 
work-related
 
rights, and
 
ensuring
 
equal
 
treatment
 
and
opportunities for all.
With regards
 
to material impacts, risks and opportunities, all people in own
 
workforce
 
who could be materially impacted by
business activities are in the scope of disclosures,
 
covering own operations
 
and the value chain.
The Group
 
recognises two distinct categories within its
 
workforce:
 
Employees
 
who are
 
directly employed
 
by the
 
organisation:
 
permanent, temporary,
 
full-time, part-time
 
employees,
as well as other
 
staff members such as trainees,
 
or those who have self-employed
 
status.
 
Non employees who are provided
 
by third party undertakings primarily engaged in employment
 
activities.
All
 
the
 
identified
 
negative
 
impacts
 
related
 
to
 
Eurobank’s
 
own
 
workforce
 
resulting
 
from
 
the
 
DMA
 
have
 
been
 
classified
 
as
potential.
 
Eurobank,
 
through
 
various
 
measures
 
and
 
mechanisms,
 
such
 
us
 
compliance
 
with
 
labor
 
laws
 
and
 
standards,
employee surveys, work
 
-life balance initiatives, diversity training
 
and awareness programs, ensures
 
that any related impacts
with widespread or systemic effects
 
will not be materialised.
 
Through
 
materiality assessment,
 
the magnitude
 
and scope of potential
 
and actual impacts
 
is taken into
 
consideration
 
and
are analyzed
 
further.
 
Identified impacts related
 
to Eurobank’s
 
own workforce
 
could only be
 
linked to
 
individual incidents of
discrimination or unethical behaviour.
Additionally,
 
the
 
Group
 
implements
 
a
 
range
 
of
 
actions
 
that
 
contribute
 
to
 
fostering
 
positive
 
outcomes
 
for
 
employees,
 
as
detailed below:
Actions promoting
 
positive impact of:
 
Implementing
 
internal
 
management
 
systems
 
and
 
initiatives
 
that
 
improve
 
employees’
 
ability
 
to
 
live
 
free
 
from
gender/sexual/ethnic/racial
 
discrimination and ageism.
Activities that contribute to material impacts:
 
Implementation
 
of Diversity,
 
Equity &
 
Inclusion
 
Policy:
 
the
 
policy ensures
 
that
 
all individuals,
 
regardless
 
of their
race, gender,
 
sexual orientation, age, disability, or background,
 
have equal access to opportunities and are treated
with respect and fairness.
 
Implementation
 
of Workplace
 
Violence
 
and Harassment
 
Policy:
 
the
 
policy outlines
 
behaviors that
 
are unethical,
provides
 
mechanisms
 
for
 
reporting and
 
corresponding
 
complaints, and
 
ensures that
 
all employees
 
work in
 
a safe
and respectful environment.
Establishment of
 
inclusivity and
 
diversity
 
Targets:
 
track
 
of progress
 
in order
 
to enhance
 
diversity
 
and inclusivity
within an organisation and in Top
 
Management.
The
 
Boardroom
 
initiative:
 
training
 
and networking
 
opportunities for
 
women
 
already in
 
managerial roles
 
so as
 
to
prepare them
 
for board positions.
Women
 
in
 
Banking
 
initiative:
 
programme
 
aimed
 
at
 
empowering
 
women
 
within
 
Eurobank
 
to
 
advance
 
to
 
higher
leadership
 
roles
 
through
 
mentoring,
 
interactive
 
workshops,
 
virtual
 
masterclasses,
 
gaming
 
and
 
various
 
engaging
activities.
Delivery
 
of
Workplace
 
Violence
 
& Harassment
 
virtual training
 
sessions
 
to all
 
Managers
 
of the
 
Group
 
in Greece
within 2024.
Implementation of
Inclusive Leadership virtual sessions
 
addressed to all Managers of the Group
 
in Greece
 
UN Women Empowerment Principles initiative
: Through the impactful community of “Women in Banking”, the Bank
embraces
 
the
 
7
 
Principles
 
of
 
Women’s
 
Empowerment
 
by
 
the
 
United
 
Nations
 
to
 
promote
 
gender
 
equality
 
in
 
the
workplace.
 
Women
 
in
 
Tech
 
initiatives:
 
webinars
 
in
 
cooperation
 
with
 
"Girls
 
in
 
Tech"
 
to
 
their
 
members
 
from
 
executives
 
of
Eurobank IT/Digital Unit
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Our actions to improve
 
employees’ ability to live
 
free from gender/sexual/eth
 
nic/racial discrimination and
 
ageism, originally
developed
 
for
 
our
 
core
 
operations,
 
are
 
strategically
 
adapted
 
and
 
deployed
 
across
 
subsidiaries
 
in
 
Bulgaria,
 
Cyprus,
 
and
Luxembourg. Examples
 
of relative
 
initiatives
 
are the
 
establishment of
 
Key Function
 
Holder Diversity
 
Policy
 
in Hellenic
 
Bank,
the
 
established mechanisms
 
of all
 
subsidiaries to
 
support appropriate
 
inclusion, etc.
 
While these
 
programs
 
are tailored
 
to
address
 
the
 
specific
 
local
 
contexts
 
and
 
regulatory
 
environments,
 
they
 
remain
 
firmly
 
aligned
 
with
 
Group’s
 
overarching
corporate sustainability objectives.
 
Scope of impact:
 
All employees, especially those who are more
 
vulnerable to discrimination incidents.
Actions promoting
 
positive impact of:
Supporting
 
employee’s
 
upskilling
 
and
 
well-being
 
by
 
providing
 
training
 
programs,
 
satisfying
 
and
 
high-quality
 
working
conditions, including adequate workspace
 
and respect of privacy.
Activities that contribute to material impacts:
 
Development
 
Plans
 
and
 
Improvement
 
Plan:
 
both
 
plans
 
are
 
designed
 
to
 
cultivate
 
employee
 
competencies
 
and
behaviours through
 
targeted training
 
and development
 
initiatives, aligning
 
their skillsets
 
with their
 
current roles
 
or
potential future positions.
Talent management
 
programme:
 
program that
 
aims at upskilling and reskilling the talent pool
 
Empowerment
 
programmes:
 
program
 
that empowers
 
employees,
 
so that
 
they
 
can assume
 
more demanding
 
roles
and improve their
 
leadership skills.
Occupational Health and Safety Management System: the
 
Group applies all measures required under
 
national and
EU legislation to ensure the
 
health and safety of its employees
myPROSPERITY: well-being program that aims to support employees facing daily
 
challenges in their personal, family
and professional environment.
o
Financial
 
well-being
 
initiative:
 
training
 
sessions
 
for
 
financially
 
responsible
 
decision
 
making
 
and
 
skills,
 
and
platform access providing
 
awareness and saving tips
o
Wellbeing podcasts and inspirational
 
talks
o
The Coach: on demand premium training
 
and wellness platform
 
o
Stress Management-
 
self-care sessions
Eurobank is committed to fully protecting and upholding the personal data rights of its employees, ensuring compliance with
the General
 
Data Protection
 
Regulation (GDPR).
Our actions
 
to protect
 
and uphold
 
the
 
personal
 
data rights
 
of Group’s
 
employees,
 
ensuring compliance
 
with the
 
General
Data Protection
 
Regulation (GDPR).,
 
originally developed
 
for our
 
core operations,
 
are strategically
 
adapted and deployed
across
 
subsidiaries
 
in Bulgaria,
 
Cyprus,
 
and Luxembourg.
 
While
 
these
 
programs
 
are
 
tailored
 
to address
 
the
 
specific
 
local
contexts and regulatory environments,
 
they remain firmly aligned with
 
our overarching
 
corporate sustainability objectives.
 
Scope of impact:
 
All employees
 
Actions promoting
 
positive impact of:
 
Generating direct,
 
indirect and induced jobs
 
across the value
 
chain, providing competitive
 
wages and benefits in alignment
with the
 
renumeration
 
policy,
 
while also
 
incorporating
 
Employee
 
Engagement
 
surveys
 
to quantify
 
employees’
 
opinions on
well-being.
Activities that contribute to positive impacts:
 
Supporting employees
 
and their
 
families:
 
a benefit
 
scheme
 
has been
 
in place
 
applying to
 
all its
 
employees
 
that
includes indicatively private healthcare and
 
life insurance, pension capital management
 
scheme through the Group’s
Occupational Fund, maternity benefits, discounted rates
 
for the
 
Group’s mortgage products
 
and services.
Gender pay gap analysis
WeSay 2023 survey: internal all-employee engagement survey to provide opinions on issues such as job
 
satisfaction,
employee engagement and wellbeing.
Scope of impact:
 
All employees
 
As part of the materiality
 
assessment, key risks
 
and opportunities that arise from
 
both the positive
 
and negative impacts of
own operations have been identified.
 
These include social factors,
 
as well as
 
those connected to
 
own workforce dependencies.
Equal Treatment
 
and Opportunities for All
Impact
Positive
Actual
Implementing
 
internal
 
management
 
systems
 
and
 
initiatives
 
that
 
improve
 
employees’
ability to live free from gender/sexual/eth
 
nic/racial discrimination and ageism.
 
Negative
Potential
Lack
 
of
 
established
 
policies,
 
measures
 
and
 
actions
 
increases
 
the
 
risk
 
of
 
discrimination
incidents within
 
Group’s
 
operations,
 
potentially
 
impacting
 
the
 
well-being
 
and morale
 
of
employees.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Other work-related rights
Impact
Positive
Actual
Supporting employee’s
 
well-being through
 
providing
 
satisfying and
 
high-quality working
conditions, including adequate workspace
 
and respect of privacy.
Working conditions
Risk
Non-compliance with the modern workplace expectations such as good working conditions, adequate
salaries,
 
and
 
workplace
 
safety,
 
can
 
affect
 
employees'
 
motivation
 
and
 
performance,
 
leading
 
to
decreased productivity.
Opportunity
Demonstrating commitment to exemplary working
 
condition expectations, such as offering
 
adequate
salaries,
 
promoting
 
work-life
 
balance,
 
and
 
ensuring
 
workplace
 
safety,
 
can
 
attract
 
and
 
retain
employees.
The
 
environmental
 
pillar
 
of
 
the
 
Bank’s
 
Operational
 
Impact
 
Strategy
 
is
 
centered
 
around
 
reducing
 
carbon
 
emissions
 
and
achieving operational
 
net zero
 
by 2033.
 
Key drivers
 
in order to
 
achieve this
 
target are
 
energy efficiency
 
plans, transitioning
to
 
electromobility,
 
minimising
 
business
 
travel,
 
transitioning
 
to
 
cloud
 
services
 
as
 
well
 
as
 
becoming
 
a
 
paperless
 
banking
network. The
 
Bank’s operational
 
transition plan is not expected to have
 
material impacts on its employees.
The financed impact pillar of the Bank’s Sustainability Strategy focuses on aligning
 
the portfolio with 1.5
o
C sectoral transition
pathways (which
 
is also the
 
case for
 
subsidiaries’ portfolios)
 
through the
 
promotion
 
of sustainable
 
financing as well
 
as the
management
 
of
 
sustainability-related
 
risks.
 
Efforts
 
towards
 
those
 
areas
 
will
 
require
 
for
 
employees
 
to
 
gradually
 
focus
 
on
promoting
 
sustainable
 
financing
 
/
 
products
 
and
 
consider
 
client
 
sustainability
 
risks
 
in
 
their
 
day-to-day
 
activities.
 
These
aspects might entail upskilling which is expected to have a positive effect
 
on employees.
Eurobank
 
is a
 
signatory
 
to the
 
UN
 
Global
 
Compact
 
since
 
2008,
 
and is
 
committed
 
to
 
respecting,
 
actively
 
supporting
 
and
promoting
 
the
 
10 fundamental
 
principles relating
 
to human
 
rights, labour
 
rights, protection
 
of the
 
environment
 
and anti-
corruption.
 
Eurobank
 
is committed to
 
upholding the
 
highest standards
 
of human rights
 
and ethical
 
conduct throughout
 
its
operations
 
and supply chain. Based on its Code
 
of Conduct and Ethics and Human Rights
 
Statement, the
 
Group adheres
 
to
upholding
 
the
 
highest
 
standards
 
of
 
human
 
rights
 
and
 
ethical
 
conduct
 
throughout
 
its
 
operations
 
and
 
supply
 
chain.
 
It
 
is
ensured there
 
are no operations at
 
significant risk of incidents of forced
 
labor, compulsory labor and child labor.
 
Conducting the materiality assessment,
 
the main types of people of own workforce
 
who are or could be negatively affected
have
 
been identified.
 
Some
 
employees
 
may be
 
at greater
 
risk of
 
harm. To
 
gain this
 
insight, the
 
materiality
 
assessment
 
is
informed
 
by Diversity,
 
Equity,
 
and Inclusion
 
Policy,
 
which identifies as
 
vulnerable
 
groups those
 
that may
 
experience gender
or age
 
discrimination, people
 
with disabilities
 
and LGBTQ
 
individuals. “Equal
 
Treatment
 
and Opportunities
 
for
 
All” related
risks
 
and
 
opportunities
 
could
 
result
 
from
 
impacts
 
and
 
dependencies
 
on
 
those
 
vulnerable
 
group
 
of
 
people
 
within
 
own
workforce.
 
3.1.2
Policies & Actions
Policies related to own
 
workforce
 
[S1-1]
Eurobank
 
has adopted
 
policies
 
to manage
 
its material
 
impacts, risks,
 
and opportunities
 
related
 
to its
 
own workforce
 
and
disclose them in accordance with the minimum reporting requirements laid out in the Minimum Disclosure Requirements with
regards to poli
 
cies (MDR-P) as defined in
 
ESRS 2.
Eurobank is
 
committed to engaging with stakeholders
 
by ensuring a high
level
 
of accountability
 
in policy
 
development
 
and implementation.
 
Policies
 
are
 
approved
 
by
 
the
 
appropriate
 
Governance
bodies
 
such
 
as
 
the
 
Board
 
of
 
Directors
 
or
 
specialized
 
committees,
 
which
 
ensure
 
that
 
there
 
is
 
alignment
 
with
 
the
 
Group's
strategic goals and stakeholder
 
interests.
The Group
 
is committed to opposing all forms
 
of discrimination, inequality,
 
and human rights violations,
 
actively promoting
individuality
 
in
 
line
 
with
 
its
 
Diversity,
 
Equity
 
&
 
Inclusion
 
Policy
 
and
 
Human
 
Rights
 
Statement.
 
It
 
ensures
 
that
 
all
 
policies,
procedures,
 
and
 
human
 
resource
 
management
 
practices
 
are
 
guided
 
by
 
a
 
deep
 
respect
 
for
 
human
 
rights,
 
fostering
 
an
environment
 
where
 
diversity
 
and equity
 
are
 
recognised
 
and celebrated.
 
Through
 
the
 
implementation
 
of inclusive
 
policies,
commitments, and
 
mechanisms, the
 
Group reinforces
 
its dedication
 
to human rights
 
within its workforce,
 
in alignment with
the UN Guiding Principles on
 
Business and Human Rights,
 
the ILO Declaration on Fundamental Principles and Rights at
 
Work,
and the OECD Guidelines for
 
Multinational Enterprises.
Eurobank prioritises respect to human rights in line with the UN Guiding Principles on
 
Business and Human Rights. The Group
avoids causing or contributing to adverse human rights impacts through
 
its own operations
 
and business relationships. As a
signatory of the UN Global Compact since 2008, Eurobank actively supports the 10 principles related to human rights, labour
rights, environmental protection, and anti-corruption, reporting on these issues
 
annually in its
 
Sustainability Report. Eurobank
and
 
Postbank
 
are
 
also
 
signatories
 
of
 
the
 
UNEP
 
FI
 
Principles
 
for
 
Responsible
 
Banking,
 
publicly
 
disclosing
 
self-assessment
reports
 
as
 
part
 
of
 
their
 
commitment
 
to
 
responsible
 
banking
 
practices.
 
Additionally,
 
Eurobank
 
adheres
 
to
 
banking
 
labor
agreements in Greece
 
and the other
 
countries and participates in various organisations
 
promoting sustainable growth
 
and
responsible
 
entrepreneurship,
 
including the
 
Steering
 
Committee for
 
Sustainability,
 
Governance
 
and Green
 
Banking of
 
the
Hellenic Bank Association.
 
 
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Eurobank’s
 
Human Rights
 
Statement
 
applies across
 
its value
 
chain, encompassing
 
employees,
 
customers,
 
and suppliers.
 
A
key priority is ensuring all employees are treated with respect and
 
dignity, promoting fairness through
 
the exclusion of forced
and
 
child
 
labour,
 
equitable
 
compensation,
 
reasonable
 
working
 
hours,
 
and
 
upholding
 
freedom
 
of
 
association
 
and
 
data
privacy.
 
With
 
customers,
 
Eurobank
 
fosters
 
a relationship
 
of trust,
 
offering
 
fair
 
and transparent
 
services
 
while encouraging
feedback through
 
accessible complaint procedures.
 
The
 
Βank prioritises clear,
 
customized communication,
 
and compliance
with regulatory standards, enhancing customer
 
experience. In supplier relations,
 
Eurobank engages with those whose values
align
 
with
 
its
 
commitment
 
to
 
human
 
rights,
 
labour
 
rights,
 
and
 
environmental
 
standards.
 
The
 
Βank’s
 
Procurement
 
Policy
ensures
 
suppliers meet
 
local and
 
international
 
regulatory
 
requirements.
 
When human
 
rights violations
 
are
 
identified in
 
its
value chain, Eurobank takes immediate corrective action in collaboration with authorities, reinforcing its dedication to ethical
business practices and sustainable development.
Forced Labour,
 
Child Labour, and Human Trafficking
Eurobank maintains a strict policy against all forms
 
of forced labour,
 
child labour, and human trafficking.
 
The Bank prohibits
these practices both within its own operations and across its supply
 
chain. This commitment ensures that Eurobank’s business
practices
 
align with
 
ethical
 
standards,
 
promoting
 
human
 
rights and
 
dignity in
 
all
 
aspects of
 
its operations.
 
By
 
upholding
these
 
principles,
 
Eurobank
 
contributes
 
to
 
a
 
fairer
 
and
 
more
 
just
 
workplace
 
environment
 
and
 
ensures
 
that
 
its
 
business
relationships adhere
 
to high ethical and legal standards.
Wellbeing and Health & Safety
The Group is committed to maintaining
 
the highest standards of Occupational Health and Safety, recognising the well-being
of its employees as a critical asset
 
and driver of growth. In line with national and European legislation, health and safety risks
are proactively
 
assessed and
 
managed, ensuring
 
a safe
 
environment
 
for
 
employees,
 
customers,
 
visitors, and
 
stakeholders.
The Group
 
sets clear annual
 
objectives, regularly
 
monitor performance,
 
and encourages
 
continuous improvement.
 
Through
innovative
 
crisis response
 
plans, regular health
 
check-ups, employee
 
training, and
 
ongoing safety assessments,
 
a culture
 
of
safety is promoted. The
 
main goal is to establish a benchmark in the banking sector for
 
health and safety.
 
The Group
 
applies all measures required under
 
national and EU legislation to ensure the
 
health and safety of its employees,
customers and associates. At the
 
same time, the
 
Bank applies a Health and Safety Management
 
System (HSMS), as per the
ISO 45001:2018 international standard
 
on Occupational Health and
 
Safety. In this context, Eurobank implements a
 
prevention
and
 
safety
 
programme
 
for
 
its
 
employees
 
through
 
various
 
initiatives.
 
Eurobank’s
 
Occupational
 
Health
 
and
 
Safety
 
System
covers all its employees
 
and activities.
Certain employees are designated as Safety Coordinators and
 
Deputy Safety Coordinators. The responsibilities of the Safety
Coordinator and the Deputy Safety Coordinator
 
include their obligation to immediately notify the
 
competent officers of any
work-related risks and submit regular written reports regarding the current situation at the premises they are responsible for.
Diversity and Inclusion
The Group has committed to fostering a culture of diversity and inclusion and has adopted the “
Diversity, Equity & Inclusion
in Eurobank”
policy to
 
ensure
 
compliance
 
with human
 
rights standards,
 
mitigate
 
discrimination,
 
and foster
 
a diverse
 
and
inclusive workplace.
The
 
objectives of
 
the Diversity,
 
Equity,
 
and Inclusion
 
(DEI) policy
 
are focused
 
on creating
 
a diverse,
 
equitable, and
 
inclusive
workplace
 
where
 
all
 
employees
 
have
 
equal
 
opportunities,
 
feel
 
respected,
 
and
 
can
 
thrive.
 
The
 
Group
 
aims
 
to
 
build
 
a
representative
 
workforce,
 
free
 
from
 
discrimination,
 
and promote
 
transparent
 
processes
 
that
 
foster
 
talent and
 
clarity.
 
The
Group is committed to strengthening
 
an inclusive culture where
 
individuals feel they
 
belong and are empowered
 
to be their
authentic selves.
 
Inclusive leadership
 
is key,
 
and the
 
leaders are
 
accountable for
 
creating an
 
environment
 
that supports
 
all
employees.
 
With
 
a zero
 
-tolerance
 
policy for
 
harassment
 
and discrimination,
 
a safe,
 
healthy,
 
and flexible
 
work environment
that prioritises employee
 
well-being is ensured. Externally,
 
the Group focuses
 
on creating a positive societal impact through
education, employment opportunities, and social initiatives, while promoting diversity in marketing and communications and
ensuring ethical, non-discriminatory banking services.
The DEI
 
policy outlines clear
 
and specific commitments
 
to support individuals from
 
groups at
 
particular risk of
 
vulnerability,
ensuring an inclusive, equitable, and supportive environment for all employees. The
 
policy focuses on the following key
 
areas:
Gender
 
Equity
 
 
The
 
organisation
 
is
 
committed
 
to
 
advancing
 
gender
 
equality
 
through
 
targeted
 
programs
 
such
 
as
 
the
"Women
 
in
 
Banking
 
-
 
Leadership
 
Acceleration
 
Program"
 
and
 
through
 
successful
 
engagement
 
with
 
Bloomberg’s
 
Gender
Equality Score
 
evaluation.
 
Additionally,
 
initiatives
 
like
 
"the
 
Boardroom"
 
are designed
 
to promote
 
female
 
representation
 
in
leadership and decision-making roles,
 
ensuring women have equal opportunities for
 
career advancement.
Parents and Families
 
– The organisation
 
recognises the diverse
 
needs of families, offering
 
an extensive range of benefits to
support parents, regardless of gender,
 
age, or marital status.
Age Diversity
 
– The
 
policy promotes
 
the strengths
 
of different
 
generations
 
in the workforce,
 
ensuring that knowledge,
 
skills,
and experience are transferred
 
effectively.
People
 
with
 
Disabilities
 
 
The
 
organisation
 
is
 
committed
 
to
 
creating
 
an
 
inclusive
 
workplace
 
that
 
values
 
all
 
employees,
offering equal opportunities for
 
advancement, learning, and fair compensation.
 
 
 
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LGBTQ+
– The
 
policy ensures a safe,
 
respectful, and inclusive
 
environment for
 
LGBTQ+ employees,
 
with protections
 
against
discrimination and harassment.
The policy applies to Eurobank
 
Services and Holdings S.A., its subsidiaries (international and in Greece),
 
shareholders, Board
members,
 
directors,
 
representatives,
 
employees,
 
as well
 
as to
 
all interactions
 
with customers,
 
visitors, agents,
 
contractors,
suppliers, investors, external service
 
providers, business associates and the
 
communities in which it operates.
The
 
Nomination
 
& Corporate
 
Governance
 
Committee is
 
responsible
 
for
 
monitoring and
 
assessing on
 
an annual
 
basis the
effectiveness
 
of the DEI Policy.
The policy is readily accessible to all potentially affected stakeholders,
 
as well as to those responsible for its implementation,
through the Groups'
 
official website.
Eurobank prioritises mutual respect, dignity, and professionalism, ensuring that all employees treat the Group, its clients, and
colleagues
 
with
 
respect
 
and
 
integrity.
 
The
 
Group
 
values
 
diversity
 
and
 
fosters
 
an
 
inclusive
 
environment
 
that
 
welcomes
individuals regardless
 
of age, gender,
 
ethnicity, religion,
 
disability, or
 
other
 
personal characteristics.
 
Eurobank is
 
committed
to equal employment
 
opportunities, meritocracy,
 
and fair
 
treatment for
 
all staff.
 
It upholds
 
the principles
 
of understanding
and
 
cooperation,
 
encouraging
 
diverse
 
opinions
 
and
 
supporting
 
a
 
culture
 
free
 
from
 
discrimination,
 
harassment,
 
or
intimidation.
 
The
 
Group
 
has
 
a
 
zero-tolerance
 
policy
 
for
 
such
 
behaviours
 
and
 
provides
 
clear
 
channels
 
for
 
reporting
 
any
concerns,
 
including
 
through
 
managers,
 
HR,
 
compliance,
 
or a
 
dedicated
 
hotline.
 
Staff
 
are
 
encouraged
 
to speak
 
up
 
if they
suspect any unethical conduct or regulatory issues.
Furthermore, the
 
Group’s commitment to diversity
 
and inclusion aligns with its values and is reflected in its
Code of Conduct
and Ethics
. The
 
Code applies
 
to every
 
staff member,
 
irrespective
 
of segment,
 
level
 
or job
 
description, as
 
a daily
 
reference
manual. All senior management have the
 
duty to communicate the values of Eurobank
 
and inspire all employees under their
responsibility. The
 
Code is distributed to 100% of the staff members, including the
 
Board Members, as well as any individuals
who offer advisory services
 
or are employed based on fixed- term or project
 
employment agreements. With
 
reference
 
to the
Code of
 
Conduct and
 
Ethics,
 
staff
 
members
 
confirm having
 
read
 
and accepted
 
the
 
Code
 
through
 
an electronic
 
platform.
Compliance
 
and the
 
relevant
 
auditing bodies
 
of Eurobank
 
are
 
responsible
 
for
 
monitoring and
 
implementing
 
the
 
Code
 
of
Conduct and Ethics.
Respect for human dignity
 
is at the core of
 
Eurobank’s workplace culture, and the Group adopts a
 
strict zero-tolerance stance
against
 
violence,
 
harassment,
 
and
 
sexual
 
harassment.
 
Any
 
employee
 
who
 
experiences
 
or
 
witnesses
 
such
 
incidents
 
is
encouraged to report them promptly
 
through available communication
 
channels. All reported incidents are treated with the
utmost seriousness, confidentiality, and respect, with
 
a thorough investigation
 
and disciplinary action if necessary.
 
Eurobank
strives to
 
maintain a
 
safe
 
and respectful
 
environment
 
where
 
all associates
 
are protected
 
from
 
any form
 
of harassment
 
or
violence.
The
 
Policy against Violence
 
and Harassment
applies to a wide range of individuals associated with Eurobank. It includes all
members of the Group's staff, regardless of the type of employment contract they hold, whether permanent, temporary, fixed
term, or open-ended. Additionally, it covers
 
individuals working under project contracts,
 
independent service agreements, or
salaried mandates. The
 
policy also extends to employees
 
contracted by third
 
-party service providers
 
who work on behalf of
Eurobank,
 
as
 
well
 
as
 
those
 
participating
 
in
 
training
 
programs,
 
such
 
as
 
interns,
 
apprentices,
 
and
 
volunteers.
 
It
 
applies
 
to
members of Eurobank's staff
 
even if their work contract
 
has expired, and it also covers candidates seeking employment
 
with
the
 
Group.
 
To
 
ensure
 
transparency
 
and
 
accessibility,
 
the
 
policy
 
is
 
readily
 
available
 
to
 
all
 
staff,
 
candidates,
 
and
 
other
stakeholders through
 
the corporate
 
website.
 
The
 
Committee
 
against
 
Workplace
 
Violence
 
and
 
Harassment
 
is
 
entrusted
 
with
 
the
 
oversight
 
and
 
implementation
 
of
 
this
policy, ensuring that its provisions
 
are effectively
 
carried out across
 
the organisation.
 
Processes for
 
engaging with own workforce
 
and workers’ representatives
 
about impacts [S1-2]
In alignment with
 
the Sustainability Policy
 
Framework,
 
Eurobank engages
 
with its employees.
 
More specifically,
 
it prioritises
employee upskilling and reskilling, maintains professionalism,
 
and enforces anti-discrimination
 
policies to foster an inclusive
workplace.
 
The
 
Group
 
offers
 
comprehensive
 
benefits
 
for
 
employees
 
regardless
 
of
 
gender,
 
age,
 
or
 
marital
 
status.
 
Regular
meetings,
 
breakfast
 
sessions,
 
and
 
events
 
facilitate
 
dialogue
 
between
 
management
 
and
 
staff
 
representatives.
 
Enhanced
communication
 
channels
 
like
 
HR4U
 
and
 
the
 
Connected
 
portal
 
ensure
 
responsiveness
 
to
 
employee
 
inquiries.
 
The
 
Group
promotes work
 
-life balance,
 
social and environmental
 
awareness, and
 
volunteering
 
and implements an
 
ESG upskilling plan
and awareness initiatives for
 
employees and clients to support sustainability efforts.
The
 
perspectives
 
of
 
employees
 
inform
 
the
 
Group’s
 
decisions
 
and
 
activities
 
aimed
 
at
 
managing
 
the
 
actual
 
and
 
potential
impacts
 
on
 
them.
 
Employees
 
participate
 
in
 
stakeholder
 
engagement
 
as
 
part
 
of
 
the
 
annual
 
DMA,
 
which
 
enables
 
the
understanding of
 
their concerns
 
and priorities.
 
The
 
material topics
 
identified through
 
this engagement
 
are then
 
taken into
account and
 
inform
 
the
 
Group’s
 
policies, actions,
 
and targets.
 
This ensures
 
that the
 
issues that
 
matter
 
most to
 
employees
are addressed in the
 
decision-making processes.
 
Furthermore,
 
the engagement occurs
 
directly with employees,
 
through the
completion
 
of
 
questionnaires
 
on
 
potential
 
material
 
impacts,
 
risks,
 
and
 
opportunities.
 
The
 
Sustainability
 
Management
Committee is responsible for
 
overseeing the
 
DMA process and
 
approve
 
the proposed
 
contents of the Sustainability-related
reports,
 
that
 
derive
 
from
 
the
 
results
 
of
 
the
 
DMA.
 
The
 
assessment
 
of
 
engagement
 
effectiveness
 
is
 
measured
 
with
 
the
participation rate.
 
 
 
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The Group ensures
 
that the workforce’s
 
insights actively shape its decisions and guide its activities aimed at managing both
the actual
 
and potential impacts.
 
The engagement
 
occurs directly with
 
the employees
 
as well as
 
with their
 
representatives.
Eurobank fosters
 
the dialogue
 
with its own employees
 
and the engagement
 
with employees
 
is an ongoing process
 
with the
means of communication presented in bullets
 
below:
 
Sustainable dialogue with employee representatives
 
at company and industry level.
 
Staff-Management communication
 
via regular meetings, breakfast
 
with the Management and events.
 
Communication through
 
the HR4U contact centre.
 
Connected, the Bank’s internal portal.
 
Axiopoio, & Senior Management Performance
 
Feedback modern
 
employee performance
 
assessment system.
 
Upskilling and Reskilling of Employees.
 
Social and environmental issues awareness
 
campaigns (TeamUp
 
Employee Volunteering
 
Team).
 
myPROSPERITY wellbeing programme.
 
360
o
 
Informative & awareness
 
internal communication campaigns.
Improving
 
employee
 
engagement
 
is
 
a
 
crucial
 
goal
 
for
 
Eurobank,
 
seeking
 
to
 
enhance
 
productivity,
 
foster
 
a
 
positive
 
work
environment
 
and retain
 
top talent.
 
In pursuit
 
of this
 
objective,
 
the
 
Group
 
has extended
 
its efforts
 
aiming at
 
engaging
 
its
workforce
 
through
 
various
 
initiatives
 
and
 
communication
 
campaigns.
 
These
 
meticulously
 
crafted
 
initiatives
 
leverage
 
all
available communication channels, including Viber messages,
 
screensavers, emails, videos, intranet and more. By prioritising
employee engagement with
 
360-degree communication initiatives,
 
Eurobank demonstrates
 
its commitment to cultivating a
supportive and motivating work
 
environment, conducive
 
to individual and organisational success
In response
 
to the
 
above,
 
Eurobank
 
has conducted
 
an internal
 
all-employee
 
engagement
 
survey.
 
The
 
WeSay
 
survey,
 
that
took place in
 
2023, was conducted
 
fully digitally seeking employees’
 
opinions on various
 
issues concerning
 
the Group,
 
work
processes
 
and
 
the
 
work
 
environment
 
(such
 
as
 
compensation
 
and
 
benefits,
 
job
 
satisfaction,
 
employee
 
engagement
 
and
wellbeing, and corporate purpose). The survey involving all employees in
 
Greece and Cyprus was
 
completed with a
 
significant
participation rate
 
the Group.
 
The
 
survey findings
 
were
 
studied thoroughly,
 
and strengths
 
and areas
 
for
 
improvement
 
were
identified, shaping Eurobank’s next steps accordingly.
 
To communicate
 
its strategy and foster
 
2-way dialogue between the management
 
team and the employees,
 
Eurobank held
meetings with the Management,
 
with employees from
 
all divisions participating, as well
 
as 2 Senior Management meetings.
At
 
the
 
same
 
time,
 
aiming
 
to
 
foster
 
an
 
open
 
line
 
of
 
communication
 
with
 
the
 
regional
 
network,
 
4
 
onsite
 
visits
 
from
 
Retail
Management and 5 Top Management
 
roadshows took place
 
in regional markets across Greece.
People
 
Advisory
 
Committee
 
holds
 
the
 
operational
 
responsibility
 
to
 
ensure
 
review
 
and
 
evaluate
 
all
 
major
 
employee
engagement initiatives (employee
 
surveys, communication etc.)
Additionally,
 
the
 
Group
 
aligns its
 
actions with
 
corporate
 
values, principles
 
and commitments
 
by issuing
 
the
 
Human Rights
Statement,
 
the
 
DEI
 
policy
 
as
 
well
 
as
 
the
 
Policy
 
against
 
Harassment
 
and
 
Violence
 
in
 
Workplace.
 
Comprehensive
 
and
transparent
 
information
 
is
 
provided
 
throughout
 
engagement
 
with
 
all
 
business
 
partners
 
to
 
ensure
 
compliance
 
with
 
legal
requirements
 
in
 
labour
 
and
 
environmental
 
matters,
 
respect
 
for
 
human
 
rights,
 
and
 
the
 
promotion
 
of
 
demand
 
for
 
socially
responsible products and services.
Processes to remediate
 
negative impacts and channels for
 
own workforce
 
to raise concerns [S1-3]
In
 
case
 
of
 
negative
 
impacts
 
on
 
employees,
 
Eurobank
 
ensures,
 
through
 
grievance
 
mechanisms
 
and
 
its
 
illegal
 
or
 
Unethical
Conduct Policy,
 
that the appropriate
 
remediation actions
 
are taken.
 
Eurobank encourages
 
all stakeholders, including employees,
 
to report instances of potential or actual human rights impacts,
unethical conduct, or violations such as discrimination, harassment,
 
or intimidation. Eurobank has established clear channels
for
 
reporting,
 
including
 
branches,
 
the
 
website,
 
phone,
 
email,
 
and
 
in-person
 
communication.
 
Employees
 
are
 
expected
 
to
uphold a safe, respectful, and inclusive work environment, and are encouraged to speak
 
up about concerns regarding ethical,
legal, or regulatory issues. Eurobank’s Policy of Reporting Illegal or
 
Unethical Conduct ensures that staff and third parties can
report misconduct without fear of retaliation,
 
fostering trust and protection.
 
The responsible
 
officer
 
for the
 
receiving and
 
monitoring of reports
 
(RRMO) is tasked
 
with providing
 
clear guidance
 
on how
to
 
submit
 
a
 
report,
 
receiving
 
and
 
confirming
 
receipt
 
of
 
the
 
report
 
within
 
seven
 
working
 
days,
 
and
 
performing
 
an
 
initial
assessment.
 
They
 
are
 
also
 
responsible
 
for
 
designating
 
the
 
appropriate
 
unit
 
or
 
person
 
to
 
handle
 
the
 
report,
 
ensuring
 
the
confidentiality
 
of
 
the
 
reporting
 
person’s
 
identity
 
and
 
any
 
third
 
parties
 
mentioned.
 
Additionally,
 
the
 
officer
 
monitors
 
the
progress
 
of the
 
investigation,
 
maintains regular
 
contact with
 
the
 
reporting person,
 
and ensures
 
that feedback
 
is provided
within a reasonable period, not exceeding three months
 
from the receipt confirmation. The officer also plans and coordinates
relevant training efforts
 
to support the process.
The
 
Board
 
of
 
Directors
 
is
 
responsible
 
for
 
ensuring
 
the
 
existence
 
of
 
a
 
robust
 
framework
 
for
 
reporting
 
illegal
 
or
 
unethical
conduct, promoting
 
continuous improvement
 
of the
 
Policy,
 
committing to,
 
promoting
 
and practicing
 
a speak-up/listen-up
culture and ensuring the appointment of the
 
RRMO.
The Group encourages its workforce
 
to document incidents of
 
harassment, including actions taken to address them and prior
requests for assistance. The Group Human Resources, Group Compliance,
 
and Group Internal Audit
 
work together to examine
 
 
 
 
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grievances
 
or complaints,
 
ensuring a
 
prompt,
 
thorough,
 
and impartial
 
investigation
 
while
 
maintaining confidentiality
 
and
protecting
 
personal
 
data.
 
If
 
the
 
investigation
 
confirms
 
a
 
violation
 
of
 
the
 
Group’s
 
Policy
 
against
 
Workplace
 
Violence
 
and
Harassment,
 
the
 
responsible
 
Committee determines
 
appropriate
 
disciplinary measures,
 
taking suitable
 
and proportionate
action to prevent recurrence
 
of such incidents.
According to the
 
Policy for
 
Reporting Illegal or Unethical
 
Conduct, Eurobank
 
provides protection
 
against reprisal and keeps
confidential
 
the
 
identity
 
of
 
those
 
who
 
have
 
submitted
 
information
 
they
 
know
 
and
 
consider
 
to
 
be
 
accurate
 
and
 
true.
Additionally,
 
there
 
are
 
policies
 
in
 
place
 
to
 
prevent
 
any
 
form
 
of
 
retaliation
 
against
 
individuals,
 
including
 
workers'
representatives, utilising these channels. For
 
further reference,
 
applicable information has been disclosed in accordance with
ESRS G1-1 Business conduct policies and corporate
 
culture.
 
Action
 
on
 
material
 
impacts
 
on
 
own
 
workforce,
 
and
 
approaches
 
to
 
managing
 
material
 
risks
 
and
 
pursuing
 
material
opportunities related to own workforce,
 
and effectiveness
 
of those actions [S1-4]
Eurobank
 
has
 
formulated
 
action
 
plans
 
to effectively
 
manage
 
the
 
material
 
impacts,
 
risks
 
and opportunities
 
relating
 
to its
workforce,
 
which are consistent with ESRS 2 MDR-A. The following outlines a summarized description of the action plans and
allocated resources.
 
Eurobank has implemented the
 
following initiatives,
 
aimed at delivering
 
positive impacts to its own workforce.
 
Certifications
 
The Bank
 
consistently provides
 
a range of
 
learning solutions
 
to facilitate
 
employees achieve
 
certification/re
 
-certification
 
of
their
 
professional
 
competence
 
in
 
providing
 
investment
 
advice,
 
insurance
 
mediation,
 
mortgage
 
credit
 
and
 
small
 
business
banking. Over 1,500 new certifications
 
were recorded
 
in 2024, while more than 3,000 were
 
re-certified.”
 
Development Plans and Improvement
 
Plans
Career
 
development
 
holds
 
significant
 
importance
 
within
 
the
 
Group.
 
To
 
facilitate
 
this,
 
the
 
Group
 
uses
 
both
 
Development
Plans and
 
Improvement
 
Plans, which
 
encompass various
 
functionalities associated
 
with career
 
progression.
 
Through
 
these
mechanisms, employees
 
work with
 
their
 
managers to
 
create tailored
 
Development
 
Plans that
 
align with
 
their
 
professional
growth and
 
career aspirations.
 
Alternatively,
 
an Improvement
 
Plan can be crafted
 
to outline a strategic
 
path for
 
enhancing
performance
 
and addressing
 
areas
 
requiring
 
development.
 
Both
 
plans are
 
designed
 
to cultivate
 
employee
 
competencies
and
 
behaviours
 
through
 
targeted
 
training
 
and
 
development
 
initiatives,
 
aligning
 
their
 
skillsets
 
with
 
their
 
current
 
roles
 
or
potential future positions.
Talent management
 
programme
Eurobank
 
implements
 
a
 
structured
 
bank-wide
 
Talent
 
Management
 
Programme,
 
aiming
 
at
 
identifying,
 
developing
 
and
effectively
 
utilising a robust
 
talent pipeline
to deliver
 
business strategy.
 
During 2024, the
 
Group designed and
 
introduced a
new
 
segmentation
 
for
 
the
 
talent pool,
 
focusing
 
on mobility
 
as well
 
as structured
 
talent career
 
discussions. Through
 
these,
next career moves such as job swaps and various development
 
activities, like mentoring and job shadowing, were
 
offered to
career-oriented talents.
 
PROSPER Class of 2023 & 2024
In the context of developing
 
the Future
 
Leader pool recognised through
 
the Talent
 
Management process,
 
the Bank created,
in collaboration with
 
ALBA Graduate Business School, a unique Talent
 
Development experience
 
focusing on Leadership. The
program aims to provide
 
participants a modern educational
 
and developmental experience,
 
with opportunities for outside-
in perspectives,
 
interactivity,
 
networking,
 
practical
 
guidance
 
and useful
 
discussions with
 
experienced
 
academic professors
that will
 
empower
 
their out-of-the
 
-box thinking,
 
strategic
 
mindset and leadership
 
capabilities.
 
During 2024,
 
35 employees
completed the 2023 Class, while 36 participants joined the
 
2024 Class.
BeAPro in Banking Season
 
3
 
– Eurobank developed and launched the BeAPro talent
 
hiring program, targeting the Corporate
Investment
 
Banking, Wealth
 
Management
 
& Markets,
 
as well
 
as Risk
 
Management
 
Units, with
 
the
 
objective
 
of identifying
and retaining
 
high caliber
 
candidates with
 
1-3 years
 
of experience
 
and a
 
passion for
 
a career
 
in Banking.
 
The
 
assessment
framework
 
for this
 
program
 
was comprehensive,
 
utilising a mix of
 
hybrid assessment
 
tools and methodologies,
 
to maintain
high quality standards, enrich
 
candidate experience,
 
and ensure equitable practices.
 
A total number of
 
20 candidates have
been successful and will be joining Eurobank
 
through the
 
BeAPro in Banking Season 3talent program
 
in early Q1 2025.
Regarding employee
mobility
, the
Career Marketplace
 
intranet serves to inform internal talent about
 
available job openings
while also
 
providing
 
essential information
 
about potential
 
career
 
paths
 
within the
 
organisation.
 
Additionally,
 
it offers
 
tips
and best
 
practices
 
for
 
successfully
 
engaging in
 
the
 
internal
 
recruitment
 
process.
 
In 2024,
 
a total
 
of 82
 
job openings
 
were
posted on the Career Marketplace,
 
with 48% of job vacancies in Greece being filled internally.
 
Career Forums
 
– Eurobank has consistently demonstrated its commitment to the new generation
 
through various initiatives,
reinforcing
 
its
 
reputation
 
as
 
an
 
employer
 
of
 
choice.
 
The
 
Group
 
actively
 
participated
 
in
 
prominent
 
career
 
forums
 
across
Greece,
 
including the
 
Panorama
 
of Entrepreneurship
 
and Career
 
Development,
 
Career
 
Days
 
(Kariera.gr),
 
and Talent
 
Days
(hosted by
 
CollegeLink). Additionally,
 
Eurobank
 
engaged in
 
career
 
events organised
 
by leading
 
universities
 
in Greece,
 
such
as
 
the
 
Athens
 
University
 
of
 
Economics
 
and
 
Business,
 
the
 
University
 
of
 
Piraeus,
 
and
 
the
 
University
 
of
 
Macedonia,
 
among
others.
 
 
 
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Other Career
 
Events
 
– For
 
the 9
th
 
consecutive year,
 
Eurobank, in
 
collaboration
 
with the
 
Panorama of
 
Entrepreneurship and
Career Development, hosted the ‘Eurobank
 
Business Day’ on site career event. This initiative provided 60 young students and
graduates
 
from
 
various institutions
 
the
 
opportunity to
 
engage with
 
Eurobank
 
executives
 
and talented
 
employees,
 
gaining
insights
 
into
 
the
 
Group's
 
activities.
 
In
 
2024,
 
the
 
Eurobank
 
Business
 
Day
 
focused
 
on
 
Technology
 
and
 
Digital
 
streams,
highlighting the Group’s
 
innovative culture.
 
Succession planning
The Group’s C-Level
 
Succession Planning framework is assessed annually, following
 
a structured and comprehensive process,
according
 
to
 
the
 
guidelines
 
of
 
the
 
Group’s
 
Nomination
 
and
 
Corporate
 
Governance
 
Committee
 
as
 
well
 
as
 
its
 
Board
 
of
Directors. The Bank has a C-level
 
Succession Planning Policy in place to ensure
 
executive bench strength for
 
the C-level
 
roles
is aligned with the Group strategy, purpose and leadership culture, aiming to achieve business continuity
 
and growth. C-level
Succession Planning focuses on mobility of successors, while female representation is of
 
outmost importance. In 2024, female
successor
 
representation
 
increased
 
to
 
29%
 
at
 
C-Level.
 
Eurobank
 
also
 
introduced
 
targeted
 
career
 
discussions
 
with
 
high
potential internal successors, with
 
the discussion focusing
 
on progress and goals in their
 
current role,
 
career aspirations
 
and
development
 
areas. Key
 
radar
 
talented resources
 
were
 
identified and
 
will be
 
actively managed
 
through
 
the
 
Group
 
Talent
Mobilisation programme
 
launched in 2022.
Empower the Network
In 2024, the Group launched the “Empower the Network” project, aiming to
 
guarantee operational efficiency and at the same
time
 
offer
 
internal
 
advancement
 
opportunities
 
to
 
high
 
performing
 
and
 
high
 
potential
 
colleagues
 
of
 
the
 
Group’s
 
Branch
Network. More specifically,
 
29 Branch Managers, 13 Senior Relationship
 
Managers, and 5 Area Managers were
 
placed in the
relevant
 
positions.
 
Besides
 
internal
 
advancements
 
into
 
people
 
management
 
roles,
 
the
 
project
 
included
 
selective
 
external
hires as well. In total, 40 external candidates
 
joined the Group
 
through the program.
 
In this context,
 
replacement needs
 
were thoroughly
 
reviewed
 
in light of the
 
updated operational
 
model, and key
 
roles were
assessed accordingly.
 
The
 
selection
 
process
 
involved
 
a comprehensive
 
assessment
 
centre
 
and the
 
process
 
was concluded
with personalized feedback and career
 
discussions for all participants.
 
Wellbeing and work
 
-life balance
In 2023, Eurobank designed and introduced its first wellbeing programme, myPROSPERITY,
 
which aims to
 
support employees
facing daily
 
challenges in their
 
personal, family
 
and professional
 
environment.
 
The myPROSPERITY
 
support framework
 
was
designed to cultivate a more humancentric work environment and, therefore,
 
help employees listen and be heard, feel better
and lighten the burden they
 
carry in their
 
daily lives, aspiring to be a point of reference
 
for all Bank employees.
In this context, the myPROSPERITY programme
 
operates on 4 key
 
pillars:
Developing new habits that
 
help employees improve
 
their physical condition (For
 
my body).
Developing new
 
personal skills that
 
improve
 
their emotional
 
endurance,
 
whether
 
they are
 
single, partners,
 
parents
or caregivers of their
 
loved ones (For
 
my soul).
Supporting them in times when they are riddled with concerns and pressure, strengthening their ties with their social
environment, giving back and empowering
 
them (For
 
my community).
Providing a sense of security regarding
 
the management of their
 
financial future (For
 
my future).
The objective is to offer
 
fresh perspectives to uplift the mood, morale and physical wellbeing of employees,
 
thereby fostering
resilience. These
 
pillars centre
 
around themes
 
directly linked
 
to wellbeing
 
and mental health,
 
addressing everyday
 
stresses.
As part
 
of this
 
initiative,
 
employees
 
eagerly participated
 
in 11
 
online myPROSPERITY
 
Talks
 
delivered
 
during working
 
hours,
delving into contemporary topics.
 
Additionally, the employees had access to articles and
 
podcasts, via internal channels, that
not only
 
inspired and
 
informed
 
them,
 
but also
 
equipped them
 
with new
 
skills, empowering
 
them
 
to fortify
 
their
 
emotional
resilience.
Women in Banking (WiB)
 
As part
 
of its
 
commitment
 
to Diversity
 
and Inclusion,
 
the
 
Group
 
introduced
 
the
 
3rd Season
 
of Women
 
in Banking
 
(WiB)
 
in
2024, following
 
the highly
 
successful and
 
award-winning previous
 
two seasons. WiB
 
is a programme
 
aimed at empowering
women
 
within
 
Eurobank
 
to advance
 
to higher
 
leadership
 
roles,
 
drive
 
transformative
 
change
 
within
 
the
 
organisation,
 
and
advocate for
 
an inclusive and equitable work environment.
 
Designed by and addressed to talented women, this programme
integrates
 
mentoring
 
with
 
learning
 
through
 
interactive
 
workshops,
 
virtual
 
masterclasses,
 
gaming
 
and
 
various
 
engaging
activities.
 
The
 
initial two
 
seasons of
 
WiB
 
concluded with
 
resounding success,
 
encompassing 2,200 hours
 
of educational
 
programmes
and
 
980
 
hours
 
of
 
mentoring
 
sessions.
 
The
 
collaboration
 
among
 
participants
 
from
 
the
 
1st
 
and
 
2nd
 
cycles,
 
comprising
 
120
mentors and mentees,
 
culminated in the
 
formation of
 
a vibrant and
 
influential community within
 
Eurobank.
 
This community
aims to foster social connections, expand professional networks
 
within the Group, and enhance professional
 
growth through
knowledge
 
and
 
idea
 
exchange.
 
The
 
WiB
 
Community
 
has
 
already
 
undertaken
 
several
 
initiatives
 
with
 
the
 
objective
 
of
maintaining its active presence
 
and generating
 
a positive impact
 
on its members,
 
other
 
female colleagues
 
within Eurobank
and the broader
 
organisation.
 
 
 
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WiB not only
 
serves as a
 
cornerstone for
 
women’s empowerment,
 
but also plays a pivotal
 
role in championing
 
diversity and
inclusion,
 
cultivating
 
a
 
workplace
 
founded
 
on
 
acceptance
 
and
 
mutual
 
respect.
 
With
 
a
 
forward-looking
 
approach
 
and
unwavering
 
dedication,
 
the
 
WiB
 
community
 
is
 
spearheading
 
endeavors
 
to
 
empower
 
women
 
and
 
foster
 
a
 
more
 
inclusive
leadership landscape.
 
The abovementioned
 
initiatives are the ones in place with the wider spectrum, related to
 
the employees of the Greek entities.
There
 
are more initiatives implanted on a local level,
 
based on the specific characteristics and needs
 
of its entity.
In
 
2024,
 
Eurobank
 
signed
 
the
 
Women’s
 
Empowerment
 
Principles
 
(WEPs)
 
which
 
provide
 
essential
 
guidance
 
for
 
businesses
striving
 
to
 
promote
 
gender
 
equality
 
and
 
empower
 
women
 
within
 
the
 
workplace,
 
marketplace,
 
and
 
broader
 
community.
Established by
 
UN Women
 
and the
 
UN Global
 
Compact, these
 
principles are
 
informed
 
by international
 
labour and
 
human
rights standards, recognising that businesses play a critical
 
role in advancing gender equality and women's
 
empowerment.
 
Eurobank's
 
commitment to
 
these
 
principles transcends
 
mere
 
rhetoric; it
 
is integrated
 
into its Code
 
of Conduct and
 
reflects
the
 
organisation's
 
core
 
values.
 
With
 
a
 
steadfast
 
emphasis
 
on
 
empowering
 
women
 
and
 
enhancing
 
their
 
leadership
opportunities
 
within
 
the
 
Group,
 
Eurobank's
 
dedication
 
to
 
the
 
WEPs
 
represents
 
a
 
meaningful
 
step
 
towards
 
this
 
goal.
 
By
adopting the Women’s
 
Empowerment
 
Principles, the Group reaffirms
 
its unwavering commitment to fostering
 
a sustainable
and inclusive future for
 
its organisation, its employees,
 
and the wider community in which it operates.
 
Connected intranet
 
Eurobank’s internal
 
corporate intranet
 
serves as
 
a vital resource
 
for the
 
employees, keeping
 
them informed
 
on all strategic,
business,
 
HR
 
and
 
technology-related
 
matters.
 
It
 
is
 
a
 
digital
 
platform
 
that
 
promotes
 
the
 
Group’s
 
actions
 
and
 
initiatives,
providing
 
the
 
employees
 
with
 
immediate
 
access
 
to
 
important
 
information.
 
In
 
2024,
 
the
 
content
 
of
 
the
 
intranet
 
was
maintained and
 
updated, resulting
 
in 8,363
 
users visiting
 
Connected, and
 
on average,
 
users spent
 
several
 
minutes (06:50)
per session on the intranet. Additionally, to encourage internal social networking and the exchange of information and ideas,
the Yammer
 
platform is also available to the
 
employees.
The
 
effectiveness
 
of these
 
measures
 
is actively
 
tracked
 
through
 
regular
 
employee
 
feedback
 
surveys,
 
performance
 
metrics,
retention rates, alongside ongoing monitoring
 
of employee satisfaction
 
and engagement levels.
Additionally
 
in
 
order
 
mitigate
 
and
 
a
 
remediate
 
negative
 
impacts
 
on
 
its
 
workforce
 
stemming
 
from
 
Group’s
 
operations,
Eurobank have planned
 
the following
 
actions:
Work life balance
 
and mental health
 
Eurobank
 
extended
 
the
 
operating
 
times
 
and
 
days
 
of
 
the
 
existing
 
Mental
 
Health
 
Employee
 
Assistance
 
Helpline
 
for
 
all
 
its
employees, from
 
Monday to Sunday, including holidays, from 15:00 to 23:00.
 
The Helpline operates
 
completely confidentially
and without any financial burden. The dedicated
 
advisers from HELLAS EAP guide and support the Eurobank’s
 
employees on
a variety
 
of relevant
 
topics, such
 
as stress
 
management
 
at work,
 
emotional
 
resilience,
 
family
 
tensions or
 
addiction
 
issues.
Eurobank also offers:
 
Additional leave
 
on top of
 
the statutory
 
one, such as
 
childbirth leave
 
(pregnancy and post-partum)
 
and maternity
leave, with the option of
 
reduced working hours or accrued leave.
 
Leave for a child’s educational
 
-related school activities.
 
Paid
 
parental
 
leave,
 
minimum
 
2
 
weeks
 
more
 
than
 
the
 
legal
 
requirements,
 
unpaid
 
parental
 
leave,
 
paid
 
leave
 
for
single-parent
 
families,
 
paid
 
leave
 
to
 
adopt
 
a
 
child,
 
paid
 
parental
 
leave
 
for
 
parents
 
with
 
disabled
 
children,
 
paid
family/care leave
 
for medical rea
 
sons.
 
1 working hour less per day to employees
 
with certified disability equal to or more than 50%.
 
Measures to help employees keep
 
their schedule within their
 
working hours and promote their work
 
-life balance, i.e.
by sending out emails as reminders to clock out on time, in compliance with
 
regulatory requirements.
 
Hybrid Work
 
Model up
 
to 3
 
days from
 
home: 81%
 
of middle
 
or back-office
 
employees
 
have opted
 
for
 
Hybrid Work
Model via contractual agreement in accordance
 
with Eurobank's Hybrid Work
 
Policy.
The opportunity to the majority of employees to choose their working hours from a range of options, typically within
a 2-hour span, in order to better accommodate their
 
needs.
Learning initiatives regarding
 
violence and harassment
 
in the workplace
Eurobank
 
continually strives
 
to promote
 
a safe
 
and respectful
 
work environment.
 
Therefore,
 
a digital
 
learning programme
was implemented during 2023 for all Group employees in Greece, aiming to equip people with the necessary knowledge and
skills
 
to
 
identify,
 
prevent
 
and
 
properly
 
respond
 
to
 
instances
 
of
 
violence
 
and
 
harassment.
 
In
 
addition,
 
separate
 
virtual
workshops were
 
addressed to team managers,
 
to provide
 
them with practical
 
knowledge to prevent
 
such behaviours, while
amplifying the effort towards
 
nurturing an environment of mutual respect and dignity, where
 
no one tolerates harassment
 
in
any form.
Diversity, equity and inclusion
Discriminations based on nationality,
 
gender,
 
parental status, colour,
 
religion, health,
 
sexual orientation, etc. are
 
not in tune
with its principles and values. The Group
 
has adopted a zero-tolerance
 
approach, which applies to all staff and prohibits
 
all
forms of discrimination,
 
whether
 
direct or indirect.
 
It is also reflected
 
in contractual documents
 
adopted when entering
 
into
 
 
 
 
 
 
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relationships with third parties.
 
To this end, it has introduced
 
a Diversity, Equity and Inclusion
 
Policy and Workplace
 
Violence
and Harassment Policy.
Conducting the WeSay
 
2023 survey
As analyzed further
 
in section “Processes
 
for engaging with
 
own workforce
 
and workers’
 
representatives
 
about impacts [S1-
2]”, Eurobank
 
has implemented
 
the
 
initiative
 
“WeSay
 
2023 survey”
 
in order
 
to monitor
 
employee
 
satisfaction
 
and provide
opportunities for
 
feedback that will help
 
identify negative impacts, enabling proactive
 
intervention.
Eurobank
 
tracks
 
the
 
effectiveness
 
of these
 
measures
 
in practice
 
by
 
setting measurable
 
targets
 
relevant
 
to the
 
matters
 
of
employees’ well
 
-being, inclusivity, and diversity as presented
 
below:
 
Achieve
 
at
 
least
 
35%
 
gender
 
diversity
 
for
 
Top
 
Management
 
in
 
Greece
 
by
 
2030:
 
measures
 
the
 
increase
 
the
representation of women
 
in senior leadership positions within organisation
>20% of
 
employees
 
participating in
 
mental health
 
training
 
courses by
 
2025: tracks
 
the
 
improvement
 
of employee
well-being and the fostering
 
of a supportive workplace environment
Achieve an increase in wellbeing score
 
of people engagement survey: measures
 
various aspects of employees’ well-
being in the workplace.
 
The processes
 
of identification
 
of what action
 
is needed in
 
response to a
 
particular actual or
 
potential negative
 
impact on
own workforce
 
is informed
 
by the
 
Societal Impact
 
of the
 
Operational
 
Impact Strategy
 
and the
 
action plan
 
established as
part of its implementation. Eurobank continues to strengthen its capacity to identify and manage social risks stemming from
Employer Impact.
 
For more information
 
please refer to: 1.4.1
 
Information on the
 
market position and strategy
 
of the company [SBM-1]
To
 
address and
 
mitigate material
 
risks stemming
 
from
 
impacts and
 
dependencies on
 
the
 
workforce,
 
the
 
following
 
actions
have been initiated:
Comprehensive training
 
programs have
 
been implemented to enhance skill development
 
and reduce skill gaps.
Professional growth
 
opportunities have been launched to foster
 
career progression
 
and retain top talent.
Well-being initiatives have been rolled, including mental
 
health support, flexible working
 
arrangements, and wellness
programs.
An inclusive workplace
 
has been created by
 
establishing diversity and inclusion
 
policies and promoting
 
a culture of
respect and belonging.
3.1.3
Metrics & Targets
Targets
 
related to
 
managing material
 
negative impacts,
 
advancing positive
 
impacts, and managing
 
material risks
 
and
opportunities [S1-5]
Eurobank has set
 
measurable time
 
-bound outcome-oriented targets to
 
advance its commitments towards
 
its employees to
fostering a diverse
 
and inclusive internal environment
 
by 2030 and cultivating a culture of wellbeing by
 
2026.
Improve gender
 
diversity for Top
 
Management
Design a Generations Diversity
 
strategy proposal
Monitor, disclose and improve
 
Gender Pay Equity Gap
Maintain gender balance in workforce
 
and build on actions to promote STEM for
 
women
>20% of employees participating in mental
 
health training courses
 
by 2025
Investigate, specify and quantify the significant
 
aspects for employees’
 
wellbeing
Measure wellbeing score through
 
people engagement survey
Promote inclusive
 
management as part of the Culture shift initiative
The targets support and align with the core principles of
 
the Diversity, Equity and Inclusion (DEI) policy, emphasising diversity,
equity,
 
inclusion and
 
well-being across
 
the
 
organisation.
 
Eurobank
 
demonstrates
 
a long-term
 
commitment to
 
fostering
 
an
inclusive culture where all employees, regardless of gender, background, or identity, feel valued and
 
have equal opportunities.
The focus
 
on maintaining gender balance
 
in the workforce
 
and promoting STEM
 
for women
 
aligns with the DEI
 
policy’s goal
of
 
advancing
 
gender
 
equity.
 
Moreover,
 
the
 
commitment
 
to
 
inclusive
 
management
 
as
 
part
 
of
 
the
 
Culture
 
Shift
 
initiative
supports
 
the
 
development
 
of
 
an
 
inclusive
 
working
 
environment.
 
The
 
design
 
of
 
a
 
Generations
 
Diversity
 
strategy
 
proposal
further reflects
 
the company's commitment to fostering
 
an equitable and inclusive environment
 
that recognises the
 
value of
diverse
 
perspectives
 
across
 
all age
 
groups.
 
Monitoring and
 
improving
 
the
 
Gender
 
Pay
 
Equity Gap
 
ties directly
 
to the
 
DEI
policy's equity objectives, ensuring that compensation is fair and transparent.
 
Additionally, the targets focused
 
on workforce
well-being, including achieving an increase in wellbeing
 
score and offering
 
mental health training
 
to over 20% of employees
by 2025, underscore
 
the organisation's dedication
 
to the holistic well
 
-being of its employees.
Indicative achievements
 
against targets for 2024 are as follows:
 
Continuation of the “myProsperity” initiative (including inspirational talks by external experts), as part
 
of the Group’s
Wellbeing Framework.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Implementation of the
 
Culture Shift programme,
 
promoting new ways of collaboration
 
in the workplace.
Training
 
programmes
 
in place to
 
promote diversity
 
and inclusion, as well
 
as anti-harassment
 
principles, addressed
to all employees.
Completion of wellbeing initiatives to promote
 
mental health.
Design a full scope People
 
Engagement Survey,
 
including a wellbeing and
 
life-work-balance
 
section, planned to be
executed in Q1 2025.
The Sustainability
 
Strategy
 
defines the
 
Group’s
 
sustainability priorities
 
and objectives.
 
The Operational
 
Impact Strategy
 
is
deployed through milestones and KPIs that support the
 
annual and the long-term interim targets set across multiple project
streams,
 
spanning
 
over
 
the
 
next
 
decade.
 
It
 
is
 
developed
 
and
 
deployed
 
along
 
3
 
pillars
 
and
 
corresponding
 
corporate
objectives, supported by a governance structure of project streams (one per each commitment) and the supervisory ESG/OIS
Committee.
 
Progress
 
is
 
regularly
 
reviewed
 
at
 
the
 
Sustainability
 
Management
 
Committee.
 
Links
 
are
 
established
 
with
Transformation
 
streams
 
as
 
well
 
as
 
corresponding
 
ISO
 
management
 
system
 
standards,
 
to
 
ensure
 
substantiation
 
and
certification
 
of activities,
 
validate target
 
setting and measured
 
performance,
 
and systematically
 
monitor progress
 
through
internal reviews and external assurance. The Group plans to revisit and update its Sustainability
 
Strategy on an annual basis,
in line with best market
 
practices and regulatory
 
requirements. The
 
targets’ progress
 
will be monitored throughout
 
the year
to ensure that they are
 
met with a final evaluation at the
 
end of the period they
 
are set.
 
Equal Treatment
 
and Opportunities for
 
All, Other Work
 
-Related Rights, Workforce
 
Wellbeing, and Working
 
Conditions have
been
 
identified
 
as
 
material
 
topics
 
during
 
stakeholder
 
engagement
 
process.
 
The
 
commitment
 
to
 
fostering
 
a
 
diverse
 
and
inclusive
 
internal
 
environment,
 
alongside
 
cultivating
 
a
 
culture
 
of
 
wellbeing
 
are
 
informed
 
by
 
the
 
impacts,
 
risks
 
and
opportunities that are directly linked
 
to these topics.
Characteristics of employees
 
[S1-6]
In 2024, the Group’s
 
employees amounted to 12,833.
The following
 
table illustrates the
 
total number of employees
 
by headcount, offering
 
a breakdown by
 
gender, as permanent
employees,
 
temporary
 
employees,
 
non-guaranteed
 
hours
 
employees.
 
In
 
2024
 
12,785
 
employees
 
were
 
of
 
permanent
employment status,
while the female employees
 
represented 65.7% of the
 
total headcount.
Total in Head count
Employees as of 31.12.2024
Male
Female
Other
Not reported
Total
Total number
 
of permanent employees
4,396
8,389
-
-
12,785
Total number
 
of temporary employees
14
34
-
-
48
Total of non-guaranteed
 
hours employees
0
0
-
-
0
Total number
 
of employees (sum)
4,410
8,423
0
0
12,833
The following
 
tables present the employee distribution for the
 
Group’s countries of operation – Greece,
 
Bulgaria, Cyprus and
Luxemburg.
Specifically, Greece
 
accounted for c. 47% of the Groups
 
total headcount, with c. 57% female
 
employees. Bulgaria accounted
for c. 30%, Cyprus c. 21% and Luxemburg c.1%
 
of the Group’s total
 
headcount.
Greece
Employees as of 31.12.2024
Male
Female
Other
Not
reported
Total
Total number
 
of permanent employees
2,559
3,499
0
0
6,058
Total number
 
of temporary employees
0
0
0
0
0
Total of non-guaranteed
 
hours employees
0
0
0
0
0
Total number of
 
employees (sum)
2,559
3,499
0
0
6,058
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Bulgaria
Employees as of 31.12.2024
Male
Female
Other
Not
reported
Total
Total number
 
of permanent employees
784
3,075
0
0
3,859
Total number
 
of temporary employees
0
0
0
0
0
Total of non-guaranteed
 
hours employees
0
0
0
0
0
Total number of
 
employees (sum)
784
3,075
0
0
3,859
Cyprus
Employees as of 31.12.2024
Male
Female
Other
Not
reported
Total
Total number
 
of permanent employees
973
1,753
0
0
2,726
Total number
 
of temporary employees
11
31
0
0
42
Total of non-guaranteed
 
hours employees
0
0
0
0
0
Total number of
 
employees (sum)
984
1,784
0
0
2,768
Luxemburg
Employees as of 31.12.2024
Male
Female
Other
Not
reported
Total
Total number
 
of permanent employees
72
52
0
0
124
Total number
 
of temporary employees
3
3
0
0
6
Total of non-guaranteed
 
hours employees
0
0
0
0
0
Total number of
 
employees (sum)
75
55
0
0
130
A total
 
of 1,305 of
 
the Group’s
 
employees
 
departed during
 
the reporting
 
period resulting
 
to an employee
 
turnover
 
rate for
the reporting period
 
of 10.2%. The table below presents
 
the turnover
 
distribution and ratio for
 
2024:
Employees as of 31.12.2024
Group
Unit
Male
Female
Other
Not
reported
Total
Total number
 
of employees who have left
your entity during the reporting period
 
Head count
451
854
0
0
1,305
Total number
 
of employees
Head count
4,410
8,423
0
0
12,833
Rate of employee turnover
%
10.2%
10.1%
0
0
10.2%
In the data collection
 
process for
 
employee-related information,
 
all figures are reported in headcount
 
for the reporting
 
year
of 2024.
 
This approach
 
ensures
 
that all
 
relevant
 
personnel
 
metrics across
 
the
 
Group
 
are captured
 
and accounted
 
for
 
in a
consistent
 
manner.
 
The
 
data
 
is
 
meticulously
 
gathered
 
from
 
each
 
subsidiary,
 
ensuring
 
that
 
every
 
entity
 
within
 
the
 
Group
structure is
 
represented.
 
Once collected,
 
this data
 
is consolidated
 
by the
 
Group
 
Human Resources,
 
enabling a
 
unified and
holistic view of the workf
 
orce.
 
Collective bargaining coverage
 
and social dialogue [S1-8]
Eurobank
 
follows
 
a policy
 
of direct
 
communication with
 
its employees
 
as well
 
as through
 
labour unions.
 
The union
 
with the
largest
 
membership
 
is
 
officially
 
recognised
 
as
 
the
 
representative
 
body
 
for
 
employees
 
in
 
labour
 
negotiations
 
with
management.
 
Over
 
94.40%
 
of
 
Group’s
 
employees
 
are
 
covered
 
by
 
collective
 
bargaining
 
agreements
 
at
 
the
 
enterprise,
sectoral,
 
and
 
national
 
levels.
 
Management
 
actively
 
collaborates
 
with
 
the
 
unions,
 
supporting
 
scheduled
 
meetings
 
and
fostering
 
open dialogue
 
to monitor developments
 
within the
 
work environment.
 
Collective bargaining
 
agreements address
various issues
 
such as
 
health
 
and safety,
 
compensation,
 
working
 
hours and
 
flexibility,
 
training,
 
career
 
development,
 
equal
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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opportunities, absenteeism/leave/illness,
 
and insurance. In
 
line with Eurobank’s
 
internal policies,
 
employees' participation
 
in
trade union activities is a constitutional right, exercised
 
within the framework
 
of existing laws.
Legal trade union
 
activity does not affect
 
the employees’
 
employment status and
 
development in
 
any way, either
 
positively
or negatively. Employees can monitor and get
 
informed about their trade union rights, as
 
well as the activities
 
of associations,
through various communication channels of their Union and the Greek Federation
 
of Eurobank Employee Unions – OTOE
 
e.g.
websites, emails, notices, labour rights guides, codification
 
of collective agreements).
In addition, regarding
 
Group’s
 
operations
 
in Cyprus, the
 
Employers’
 
Association of Cyprus
 
Banks which covers
 
all the
 
banks
members of the Association of Cyprus Banks who have a Collective
 
Agreement with the same Trade
 
Union, is responsible for
industrial relation issues
 
and/or discussions for
 
the renewal
 
of the Collective
 
Agreement. Specifically,
 
Hellenic Bank engages
with Trade
 
Unions representing
 
its staff members
 
as part of its
 
ongoing stakeholder
 
engagement activities and
 
negotiates
for the settlement
 
of disputes arising from collective
 
agreement negotiations.
Social dialogue
Group
 
Unit
2024
Number of employees working in establishments with workers' representatives
Head count
6,971
Total Number
 
of employees
Head count
12,833
Total Employees
 
working in establishments with workers' representatives ratio
 
%
54.32%
Collective bargaining coverage
Group
 
Unit
2024
Number of employees covered
 
by collective bargaining agreements
Head count
12,114
Total Number
 
of employees
Head count
12,833
Total Employees
 
covered
 
by collective bargaining agreements
 
ratio
 
%
94.40%
Diversity Metrics [S1-9]
The Group is committed to fostering
 
equal opportunities for all employees, ensuring fair access to senior management
 
roles,
equitable salary structures, and merit-based evaluations and rewards.
 
Eurobank prioritises performance
 
and potential when
making decisions related to professional development, promotions, and career advancement. Eurobank’s
 
participation in the
Bloomberg Gender Equality Index for the third consecutive
 
year in 2024 highlights its ongoing dedication to responsible and
inclusive
 
growth.
 
This
 
involvement
 
underscores
 
the
 
company’s
 
focus
 
on
 
integrating
 
Diversity,
 
Equity,
 
and
 
Inclusion
 
(DEI)
principles, as well as broader
 
sustainability values, throughout its operations.
The
 
following
 
table
 
presents
 
the
 
gender
 
distribution
 
in
 
number
 
and
 
percentage
 
at
 
top
 
management
 
level.
 
As
 
top
management level is containing the
 
grade levels
 
of Executives and Senior Management within the
 
Group:
Employees in top management ratio
Group
Unit
Male
Female
Other
Not reported
Number of employees at top management
 
level
by gender
 
Head count
306
149
0
0
Percentage of employees
 
at top management
level by gender
%
67.3%
32.7%
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Distribution of employees by age group:
 
under 30 years old; 30-50 years
 
old; over 50 years old:
Total number of
 
employees by age
Group
Unit
under 30
years old
30-50 years
old
over 50
years old
Total
Number of employees during the
 
reporting
period
Head count
1,030
8,648
3,155
12,833
Percentage of employees
 
per age group
%
8.0%
67.4%
24.6%
100%
Adequate Wages [S1-10]
All of the Group’s
 
employees receive
 
adequate wages in compliance with the statutory
 
labour laws and salary practices in
place, applicable standard collective
 
and workplace agreements, as applicable
 
to each country of operation.
 
Training and skills
 
development metrics [S1-13]
Performance Management
In 2024,
 
Eurobank
 
continued to
 
implement the
 
Group
 
Performance
 
Management as
 
well
 
as Learning
 
Policies,
 
designed to
establish
 
a
 
transparent,
 
consistent
 
and
 
effective
 
framework
 
for
 
enhancing
 
employee
 
performance,
 
and
 
aligning
 
with
Eurobank’s strategic objectives
 
and values. This framework translates
 
the Group’s strategy
 
into practice by setting clear and
measurable
 
business
 
objectives
 
for
 
employees
 
and
 
promoting
 
a
 
cohesive
 
organisational
 
culture,
 
by
 
focusing
 
on
 
the
development of the
 
Group’s organisational
 
capabilities and qualitative competencies («how») across
 
all levels. Performance
Management
 
is
 
integrated
 
into
 
SAP
 
Success
 
Factors
 
for
 
enhanced
 
accessibility.
 
Both
 
tools
 
prioritise
 
development
 
and
emphasise continuous feedback, while for
 
Senior Managers, the
 
360 Feedback methodology
 
is applied.
 
The
 
percentage
 
of number
 
of employees
 
that
 
participated
 
performance
 
reviews
 
for
 
the
 
year
 
2024 was
 
93% for
 
the
 
male
employees
 
and 96% for
 
female employees.
 
In the
 
following
 
table the
 
percentage of
 
employees that
 
participated in
 
regular
performance and caree
 
r
 
development reviews
 
is presented, broken
 
down by gender.
 
Performance and career
 
development reviews
 
as of year-end
Group
Unit
Male
Female
Other
Not
reported
Total
Total number
 
of performance reviews
executed
Number
4,080
8,089
0
0
12,169
Total number
 
of performance reviews
agreed by the management
 
Number
4,081
8,092
0
0
12,173
Total number
 
of employees that
participated in regular performance
 
and
career development
 
reviews
Head Count
4,080
8,089
0
0
12,169
Total number
 
of eligible employees who
have been assessed for the
 
reporting year
Head Count
4,095
8,120
0
0
12,215
Total Number
 
of employees
 
Head Count
4,410
8,423
0
0
12,833
Eurobank
 
prioritises
 
learning and
 
development
 
as a
 
fundamental
 
aspect of
 
its operations
 
and overall
 
strategy.
 
Providing
equal learning opportunities for all employees—regardless of role, contract type (permanent, temporary, external associates,
contractors,
 
managers,
 
or
 
individual
 
contributors)—is
 
essential
 
for
 
enabling
 
skill
 
development
 
and
 
driving
 
sustainable
business outcomes.
 
This inclusive
 
approach
 
ensures that
 
every
 
team member
 
has the
 
resources
 
to grow
 
and contribute
 
to
the organisation’s long-term success. In 2024, Eurobank has consistently upheld its commitment to developing diverse talent,
fostering a culture of ongoing learning, and equipping its workforce
 
with the critical skills needed to drive
 
the organisation's
vision for Eurobank
 
2030.
 
Learning in numbers (2024):
 
588,469 learning hours Group-wide, including activities delivered
 
to temporary employees and contractors
 
47.4
 
average number
 
of training hours per male employee
45 average
 
number of training hours per female employee
45.9
 
average number
 
of training hours regarding the
 
Group’s employees
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Average
 
number of training hours per employee
 
and by gender is presented below.
 
Training hours per employee
 
and by gender as of year-end
Group
Unit
Male
Female
Other
Not
reported
Total
Training hours offered
 
to and completed
by employees
 
Hours
209,168
379,301
0
0
588,469
Total Number
 
of employees
 
Head Count
4,410
8,423
0
0
12,833
Average
 
number of training hours
Training
hours
47.4
45.0
0
0
45.9
Health and safety metrics [S1-14]
The Group
 
adheres
 
to all national
 
and EU regulations
 
to safeguard
 
the health
 
and safety
 
of its employees,
 
customers, and
partners.
 
Additionally,
 
Eurobank
 
has
 
implemented
 
a Health
 
and Safety
 
Management
 
System
 
in accordance
 
with
 
the
 
ISO
45001:2018
 
standard for
 
Occupational
 
Health and
 
Safety.
 
As part
 
of this,
 
Eurobank
 
runs a
 
comprehensive
 
prevention
 
and
safety
 
program,
 
featuring
 
a range
 
of initiatives
 
designed
 
to protect
 
its workforce.
 
The
 
scope of
 
Eurobank’s
 
Occupational
Health and Safety System encompasses all employees
 
and operations across
 
the Bank.
Health and safety templates present the
 
following information:
the percentage of people in its own
 
workforce who are covered
 
by the undertaking’s health and safety management
system based on legal requirements and/or recognised
 
standards or guidelines
the number and rate
 
of recordable work-related
 
accidents
the
 
number
 
of fatalities
 
as a
 
result
 
of work
 
-related
 
injuries &
 
work-related
 
ill health
 
of own
 
workforce
 
employees
(and other workers
 
working on the undertaking's sites)
o
Own workforce
 
covered by the
 
undertaking’s health and safety management
 
system ratio
Group
 
Unit
as of year-end
Number of employees in own workforce
 
who are covered
 
by the
undertaking’s health and safety management
 
system
 
Head Count
12,833
Total number
 
of employees in the undertaking’s
 
own workforce
Head Count
12,833
Percentage of employees
 
covered by
 
health and safety management system
%
100%
Work-related injuries and work
 
-related ill health
Group
Unit
Own workforce
 
-
Employees
Other workers working
on undertaking's site
Number of fatalities as a result of work
 
-related
injuries & work-related ill health
Number
0
0
Recordable work-related accidents ratio
Group
 
Unit
as of year-end
Number of recordable work
 
-related accidents
Number
21
Number of total hours worked
Hours
23,143,850
Rate of recordable work-related
 
accidents
Rate
0.91
All of Eurobank’s employees are covered by the
 
undertaking’s health and safety management system. Regarding the number
of fatalities as result of
 
work-related injuries and work-related ill health the number of
 
cases was 0
 
for both the own workforce
of the Group and the
 
other workers
 
working on the undertaking’s site.
 
For
 
the 2024, there
 
were 21
 
cases of recordable
 
work-related accidents,
 
and the rate
 
of work-related
 
accidents was at 0.91.
Regarding the
 
calculation of
 
the number
 
of total hours
 
worked, an
 
estimation has been
 
performed
 
based on the
 
normal or
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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standard hours
 
of work
 
for
 
the
 
entity’s own
 
workforce,
 
considering entitlements
 
to periods
 
of paid
 
leave
 
of absence
 
from
work.
Remuneration metrics
 
(pay gap and total remuneration)
 
[S1-16]
The
 
Group adopts
 
a unified
 
remuneration
 
management approach
 
and a
 
common pay
 
framework
 
across all
 
positions and
roles,
 
applying the
 
job evaluation
 
methodology
 
which links
 
pay to
 
role
 
accountability.
 
Therefore,
 
salary variation
 
depends
heavily on the distribution of the
 
two genders on the job matrix.
Gender
 
pay
 
gap,
 
is
 
defined
 
as
 
the
 
difference
 
of
 
average
 
pay
 
levels
 
between
 
female
 
and
 
male
 
employees,
 
expressed
 
as
percentage of the
 
average pay level
 
of male employees.
 
For the
 
year 2024, the gender
 
pay gap ratio was 36.1%
 
The annual total remuneration ratio
 
of the highest paid individual to
 
the median annual total remuneration for all employees
(excluding the highest-paid individual).
 
For the
 
year 2024, the annual remuneration
 
ratio was 60.0.
The
 
Group
 
has
 
established
 
a
 
competitive
 
remuneration
 
policy
 
in
 
order
 
to
 
attract,
 
engage
 
and
 
retain
 
its
 
employees.
 
The
Remuneration
 
Policy basic principles are to:
be gender neutral and non-discriminatory in any aspect of its implementation
safeguard that remuneration
 
is sufficient to retain and attract
 
executives with appropriate
 
skill and experience
monitor that internal equity between all
 
Units is applied
link remuneration
 
with long-term performance
The
 
continuous
 
monitoring
 
of
 
market
 
trends
 
and
 
best
 
practices
 
at
 
the
 
domestic
 
and
 
global
 
level
 
ensures
 
a
 
competitive
Remuneration
 
Policy that is governed
 
by transparency and internal
 
equity.
Contextual information
 
necessary to
 
understand the
 
data and
 
how the
 
data has
 
been compiled and
 
other
 
changes to the
underlying data that are to be considered.
 
Renumeration metrics
Group
 
2024
Gender pay gap ratio (%)
36.1%
The annual total remuneration
 
ratio of the
 
highest paid individual to the median annual
 
total
remuneration
 
for all employees
x60
Practicing an inclusive culture
 
and ensuring equity and opportunities for all, the Group
 
reports on both our median and
mean (average)
 
raw gender pay gaps, unadjusted by factors
 
such as role and responsibility.
Group
Mean
Median
Gender pay pap
36%
24%
These
 
metrics
 
provide
 
insights
 
into
 
gender
 
representation
 
in
 
various
 
roles,
 
often
 
highlighting
 
a
 
concentration
 
of
 
men
 
in
higher-seniority positions.
 
Aiming to further quantify the potential effect of the gender representation of employees in top management,
 
we calculated
the pay gap ratio of the
 
Group per total remuneration
 
quartiles of the Group employees,
 
while the 4th quartile also includes
the Group’s
 
higher-seniority positions.
The average
 
gender pay gap at a Group Level
 
based on the total remuneration
 
quartiles' table
Group Level
Mean
1st Quartile
6%
2nd Quartile
0%
3rd Quartile
2%
4th Quartile
22%
The
 
results
 
of
 
this
 
exercise
 
provide
 
evidence
 
that
 
the
 
main
 
driver
 
of
 
the
 
pay-gap
 
ratio
 
is
 
the
 
gender
 
representation
 
of
employees in higher-seniority
 
positions.
 
The
 
Group,
 
as part
 
of its
 
commitment to
 
diversity
 
and inclusion,
 
introduced
 
the 3rd
 
Season of
 
Women
 
in Banking
 
(WiB)
 
in
2024, following the
 
highly successful and award-winning previous
 
two seasons.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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WiB
 
is
 
a
 
programme
 
aimed
 
at
 
empowering
 
women
 
within
 
Eurobank
 
to
 
advance
 
to
 
higher
 
leadership
 
roles,
 
drive
transformative
 
change within the organisation,
 
and advocate for
 
an inclusive and equitable work environment.
 
WiB not
 
only serves
 
as a cornerstone
 
for women’s
 
empowerment
 
but also plays a
 
pivotal role
 
in championing diversity
 
and
inclusion,
 
cultivating
 
a
 
workplace
 
founded
 
on
 
acceptance
 
and
 
mutual
 
respect.
 
With
 
a
 
forward-looking
 
approach
 
and
unwavering
 
dedication,
 
the
 
WiB
 
community
 
is
 
spearheading
 
endeavors
 
to
 
empower
 
women
 
and
 
foster
 
a
 
more
 
inclusive
leadership landscape.
 
Moreover,
 
in
 
2024,
 
Eurobank
 
signed
 
the
 
Women’s
 
Empowerment
 
Principles
 
(WEPs)
 
which
 
provide
 
essential
 
guidance
 
for
businesses
 
striving
 
to
 
promote
 
gender
 
equality
 
and
 
empower
 
women
 
within
 
the
 
workplace,
 
marketplace,
 
and
 
broader
community.
 
Established by
 
UN Women
 
and the
 
UN Global
 
Compact, these
 
principles are
 
informed
 
by international
 
labour
and
 
human
 
rights
 
standards,
 
recognising
 
that
 
businesses
 
play
 
a
 
critical
 
role
 
in
 
advancing
 
gender
 
equality
 
and
 
women's
empowerment.
 
With
 
a
 
steadfast
 
emphasis
 
on
 
empowering
 
women
 
and
 
enhancing
 
their
 
leadership
 
opportunities
 
within
 
the
 
Group,
Eurobank's dedication to the WEPs represents a meaningful step towards this goal. By adopting the Women’s Empowerment
Principles, the Group reaffirms its unwavering commitment to fostering a sustainable and inclusive future for its
 
organisation,
its employees, and the wider
 
community in which it operates.
 
The abovementioned
 
initiatives are the ones in place with the wider spectrum, related to
 
the employees of the Greek entities.
There
 
are more initiatives implanted on a local level,
 
based on the specific characteristics and needs
 
of its entity.
Incidents, complaints and severe human right
 
[S1-17]
Eurobank complies with frameworks
 
such as UN Guiding Principles on Business and Human Rights and UN Global
Compact. Information regarding
 
the incidents, and complaints that occurred
 
during the 2024 reporting year
 
are illustrated
below:
Incidents, complaints and severe human rights
 
impacts
Group
 
Unit
as of year-end
Total number
 
of incidents of discrimination, including harassment, reported
in the reporting period
Number
10
Number of complaints filed through channels for
 
people in the organisation's
own workforce
 
to raise concerns (including grievance
 
mechanisms)
 
Number
17
Total amount of fines,
 
penalties, and compensation for damages as a result
of the incidents and complaints disclosed
Monetary Terms
0
Number of severe
 
human rights incidents
Number
0
An indication of how many of severe
 
human rights incidents are cases of
non-respect of the UN Guiding Principles on Business and Human Rights, ILO
Declaration on Fundamental
 
Principles and Rights at Work or OECD
Guidelines for Multinational Enterprises.
Number
0
Total amount of fines,
 
penalties, and compensation for damages as a result
of the incidents disclosed
Monetary Terms
0
Regarding the number of complaints
 
filled through official
 
channels, most of the cases relate
 
to staff complaints received
 
in
writing by HR. Those complaints
 
related to matters such as performance appraisal, training, staff transfer and organisational
structure. All
 
cases were
 
investigated as
 
per the
 
respective
 
policies of
 
the Group.
 
As a result,
 
the Group
 
had no amount
 
of
fines and
 
penalties as
 
result
 
of the
 
incidents and
 
complaints disclosed,
 
as well
 
as zero
 
number
 
of cases
 
related
 
to severe
human rights incidents.
3.2
Consumers and end-users [ESRS S4]
3.2.1
Strategy
Material impacts, risks and opportunities and their interaction
 
with strategy and business model [ESRS
 
2 SBM-3]
The actual
 
and potential
 
impacts on consumers
 
and/or End-users
 
which have
 
been identified in
 
the course
 
of the
 
DMA are
connected
 
to
 
Eurobank’s
 
strategy.
 
Eurobank
 
has
 
committed
 
to
 
contributing
 
to
 
the
 
achievement
 
of
 
the
 
United
 
Nations
Sustainable Development
 
Goals (SDGs)
 
and the
 
UN 2030
 
Agenda, as
 
a signatory
 
to the
 
UN Global
 
Compact since
 
2008,
and by actively
 
promoting its
 
fundamental principles and
 
applying the precautionary
 
approach. In this
 
context, in 2022 the
Group prepared
 
a new
 
holistic Sustainability
 
Strategy,
 
that was
 
revised
 
in 2024,
 
the implementation
 
of which
 
is based
 
on
two main pillars Operational and Financed Impact. Key components of the Operational Impact Strategy are Societal impact
and Governance & Business impact. There
 
have been set several
 
commitments to this end, such as the boost of accessibility
and inclusion for
 
customers as
 
well as external
 
ESG awareness. These
 
key strategic
 
commitments address
 
material IROs
 
of
responsible banking towards customers.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The types of consumers
 
and/or end-users who could be materially impacted by business
 
activities are:
consumers
 
and
 
end-users
 
who
 
are
 
highly
 
dependent
 
on
 
accurate
 
and
 
accessible
 
information
 
for
 
the
 
financial
products
All
 
the
 
identified
 
negative
 
impacts
 
related
 
to
 
Eurobank’s
 
consumer
 
and/or
 
end
 
users
 
resulting
 
from
 
the
 
DMA
 
have
 
been
classified as
 
potential. Eurobank,
 
through
 
various measures
 
and mechanisms,
 
such us
 
implementation
 
of Banking
 
Code of
Conduct,
 
development
 
of
 
simple
 
procedures
 
and
 
accessible
 
information
 
related
 
to
 
the
 
services
 
as
 
well
 
as
 
specialized
customer support departments, ensures that
 
any related impacts
 
with widespread or
 
systemic effects will not
 
be materialized.
 
Through
 
the
 
Responsible
 
marketing
 
and
 
communication
 
which
 
is
 
driven
 
by
 
its
 
human-centric
 
culture,
 
Eurobank
 
designs
products
 
and
 
services
 
tailored
 
to
 
the
 
individual
 
needs
 
of
 
its
 
customers.
 
With
 
a
 
view
 
to
 
optimising
 
the
 
messages
 
used
 
in
marketing campaigns, the
 
Group carries
 
out systematic market research
 
on each individual customer
 
category,
 
focusing on
both
 
quantitative
 
and
 
qualitative
 
features
 
that
 
highlight
 
the
 
trends
 
and
 
expectations
 
of
 
its
 
customers.
 
Using
 
adequate
Customer Relationship Management tools, it is able to propose or offer individual customers the
 
product or service that truly
meets their needs
Through
 
materiality assessment,
 
the magnitude
 
and scope of potential
 
and actual impacts
 
is taken into
 
consideration
 
and
are analyzed further.
 
Identified impacts related to consumers and/or end-users could be linked only to individual incidents of
restricted
 
access to information.
 
Eurobank
 
has
 
implemented
 
several
 
initiatives
 
to
 
enhance
 
accessibility
 
and
 
service
 
for
 
customers
 
with
 
disabilities.
 
Key
activities are described in the chapter “ESRS 3.5 Financial
 
inclusion”.
As part of the materiality assessment, key impact on customers
 
have been identified. This is presented in the following
 
table:
 
Information-related
 
Impacts for Consumers and/or End-users
Impact
Positive
Actual
Group provides
 
clients access to accurate, relevant
 
and high-quality secured
information, fostering
 
transparency and promoting
 
the principles of responsible
banking.
Conducting the
 
materiality
 
assessment,
 
the
 
main types
 
of customers
 
who are
 
or could
 
be negatively
 
affected
 
have
 
been
identified. Some
 
customers
 
may be
 
at greater
 
risk of
 
harm. To
 
gain this
 
insight, the
 
materiality
 
assessment is
 
informed
 
by
Diversity,
 
Equity,
 
and Inclusion
 
Policy,
 
which identifies as
 
vulnerable
 
groups elderly
 
people and people
 
with disabilities.
 
The
elderly are
 
more susceptible
 
to data
 
exploitation or
 
cybersecurity threats
 
due to
 
digital literacy
 
gaps. For
 
both vulnerable
groups
 
digital platforms
 
that
 
do not
 
adhere
 
to accessibility
 
standards (such
 
as WCAG)
 
could create
 
significant barriers
 
in
usage and overall
 
service.
3.2.2
Policies & Actions
Policies related to consumers
 
and end-users [S4-1]
Eurobank has
 
adopted policies to
 
manage its material
 
impacts, risks, and opportunities
 
related to its
 
consumer and/or end
users
 
and
 
disclose
 
them
 
in
 
accordance
 
with
 
the
 
minimum
 
reporting
 
requirements
 
laid
 
out
 
in
 
the
 
Minimum
 
Disclosure
Requirements with
 
regards to policies
 
(MDR-P) as defined in ESRS
 
2. Eurobank is
 
committed to engaging with
 
stakeholders
by
 
ensuring
 
a
 
high
 
level
 
of
 
accountability
 
in
 
policy
 
development
 
and
 
implementation.
 
Policies
 
are
 
approved
 
by
 
the
appropriate
 
Governance
 
bodies
 
such
 
as
 
the
 
Board
 
of
 
Directors
 
or
 
specialized
 
committees,
 
which
 
ensure
 
that
 
there
 
is
alignment with the Group's
 
strategic goals and stakeholder
 
interests.
Eurobank prioritises respect to human rights in line with the UN Guiding Principles on
 
Business and Human Rights. The Group
avoids causing or contributing to adverse human rights impacts through
 
its own operations
 
and business relationships. As a
signatory of the UN Global Compact since 2008, Eurobank actively supports the 10 principles related to human rights, labour
rights, environmental protection, and anti-corruption, reporting on these issues
 
annually in its
 
Sustainability Report. Eurobank
is also a founding signatory of the UNEP FI Principles
 
for Responsible Banking, publicly disclosing self-assessment reports as
part of its commitment to Human Rights as detailed in section 3.1.2.
Eurobank's
Code
 
of
 
Conduct
 
&
 
Ethics
regarding
 
customers
 
focuses
 
on
 
maintaining
 
transparency,
 
client
 
protection,
 
and
ethical behaviour. It ensures that clients receive clear, accurate, and comprehensive information
 
about products and services,
enabling them to make informed
 
decisions. Eurobank also
 
classifies clients according to legal categories to provide
 
tailored
protection, especially
 
for investment
 
-related transactions.
 
To uphold
 
high standards of professionalism,
 
Eurobank invests
 
in
continuous staff
 
training
 
and certification.
 
Additionally,
 
it emphasises
 
the
 
prevention
 
of conflicts
 
of interest
 
by prohibiting
staff from using their position
 
or internal information for personal gain
 
and ensuring
 
fair terms for all clients.
 
Staff are required
to seek compliance
 
approval for actions that may present
 
a conflict
 
of interest, reinforcing the Group's commitment to
 
ethical
conduct and transparency
 
in client relationships.
 
Compliance and the
 
relevant auditing bodies
 
of Eurobank
 
are responsible
for monitoring
 
and implementing
 
the Code
 
of Conduct and
 
Ethics. Through
 
the Governance
 
& Business impact
 
pillar of the
Sustainability Strategy,
 
and specifically,
 
the
 
commitment to
 
intensify ethics
 
and transparency
 
by 2025,
 
the
 
Group
 
has set
targets to attain Compliance Management Systems certifications,
 
including the following
 
certifications already
 
attained:
ISO 37002 – Whistleblowing Management System,
 
ISO 37001 – Anti-bribery Management System, and the
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ISO 9001 for Financial Crime Prevention
 
Services Certification.
The preparation
 
process for
 
ISO 37301 –Compliance Management Systems Certification
 
is scheduled to start within 2025.
The
Management of
 
Complaints Policy
 
follows
 
international best
 
practices
 
and is in
 
compliance with
 
the provisions
 
of the
Bank of Greece (Executive Committee’s Act 157/2019). The policy is ISO 9001 and ISO 10002 certified and aims to
 
provide fair,
transparent, and efficient solutions.
 
All complaints are treated equally,
 
with uniform procedures
 
applied while responses are
tailored to individual circumstances. Complaints can be
 
submitted through designated channels, and each case is
 
addressed
promptly to ensure resolution. The main objectives of
 
the policy are to enhance
 
customer satisfaction, improve service quality,
and
 
resolve
 
complaints
 
effectively
 
and
 
fairly.
 
Eurobank
 
Complaints
 
Management
 
is
 
responsible
 
for
 
submitting
 
the
Management of Complaints Policy and corresponding
 
statistics to BoG on an annual basis.
 
The
Sustainability Policy Framework
 
of Eurobank outlines the
 
commitments to supporting customers in their
 
transition to a
more sustainable future. A key
 
objective of this framework
 
is to assist customers in achieving their
 
decarbonization goals by
providing
 
innovative
 
financial
 
solutions
 
that
 
enable
 
investments
 
with
 
positive
 
environmental
 
and
 
social
 
impacts.
 
By
embedding
 
sustainability
 
principles
 
and
 
ESG
 
considerations
 
into
 
its
 
operations,
 
Eurobank
 
aims
 
to
 
address
 
emerging
sustainability
 
challenges
 
effectively.
 
Through
 
this
 
approach,
 
Eurobank
 
ensures
 
that
 
its
 
customers
 
have
 
access
 
to
 
the
necessary resources and expertise to navigate the complexities of sustainability. The Sustainability Management Committee
is responsible for
 
approving the
 
Sustainability Frameworks
 
(e.g. Sustainability Finance
 
Framework,
 
Green Bond Framework,
Sustainability Policy Framework
 
and Sustainability Investment Framework)
 
as well as other
 
sustainability-related Policies.
 
All the above-mentioned policies are readily accessible
 
to all
 
potentially affected stakeholders, as well as
 
to those responsible
for its implementation,
 
through the
 
corporate website.
Processes for
 
engaging with consumers and end-users about impacts [S4-2]
The Group
 
considers strengthening
 
its customer
 
relationships and
 
fostering
 
collaboration
 
as significant endeavors
 
and key
strategic
 
objectives.
 
Eurobank
 
engages with
 
its clients
 
through
 
responsible
 
information,
 
customer
 
service
 
and provision
 
of
products
 
and
 
services
 
with
 
a
 
deep
 
sense
 
of
 
respect
 
and
 
transparency
 
using
 
the
 
following
 
means
 
of
 
communication
 
and
response:
Processes for
 
engaging with customers:
1
Retail banking branch network and electronic
 
/ digital channels (ΑΤΜ, APS e-Banking, Eurobank
 
Mobile App, v-
Banking, Digital On boarding).
2
Expert relationship managers
 
(RMs) at branches and v-Banking (Personal
 
Banking, Retail Business Banking,
Expert RMs).
3
Operation of special purpose
 
branches: International
 
Branch (golden visa, non dom, etc. clients) Retail shipping
client branch and Legal Branch.
4
Private Banking network.
5
Dedicated Corporate Service
 
Centres.
6
24/7 customer call centre
 
via EuroPhone Banking for retail,
 
private and corporate customers
 
as well as via
dedicated EuroPhone International
 
Banking Line.
7
Economic reports and reviews on a regular
 
basis, by the analysts and economists of the
 
Eurobank Research team.
8
Ease of access via collaboration
 
with the Hellenic Post
 
(ELTA).
9
Publicly available information and communication
 
through eurobank.gr
 
and eurobankholdings.gr
10
Enhanced communication with
 
clients – video calls / click2chat / automated customer
 
appointment.
11
Automated customer journeys through
 
digital and alternative channels offering
 
a unique customer experience.
12
Οnline sales and lean processes to cover
 
client needs without physical presence.
13
Active customer input in market
 
research programs,
 
thus being part of customer propositions’
 
creation.
14
Social media channels.
15
Direct campaigning (viber,
 
email, sms).
16
Webinars and native articles
 
via Digital Academy for Business to boost business competitiveness
 
on its digital
transformation
 
journey.
17
Newsletters.
18
Business insight: external e-Newsletter,
 
excellent marketing tool to strengthen
 
relationships with customers
 
&
institutions, providing RBB ecosystems content and promoting
 
banking & non-banking added value services,
aiming to improve customer
 
loyalty & engagement.
19
Hosting of special conferences.
20
Retail Business Banking informational events
 
(BB Tourism, BB Health
 
Financing, etc).
21
Briefings with customer groups.
22
Non-banking services via wide network of selected
 
partners (Ecosystems).
23
Customer satisfaction
 
and NPS surveys.
24
Customer interviews based on Design Thinking
 
Methodology approach.
25
Centralised Complaints Management - Precise
 
responses to all incoming requests.
26
Customer Service Improvements.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Processes for
 
engaging with customers:
27
Initiatives for people
 
with disabilities.
28
Focus group
 
discussions with RBB RMs for identifying ESG expectations
 
of clients.
29
Limited Edition annual magazine to Private Banking clients.
30
Informative “Your
 
Personal Experts” podcasts to Personal
 
Banking clients.
31
Informative Client Events
 
fοr Private and Personal Banking Clients.
32
Informative Client Events
 
and Reports on Investments by Eurobank
 
Equities and Eurobank Asset Management
MFMC.
The perspectives
 
of consumers and/or end-users
 
inform Group’s
 
decisions and activities aimed
 
at managing the actual
 
and
potential impacts on them. Customers participate in stakeholder
 
engagement as part of the Double Materiality Assessment,
which enables the understanding of their concerns and priorities. The material topics identified through this engagement are
then taken
 
into account and inform
 
the Group’s
 
policies, actions, and targets.
 
This ensures
 
that the
 
issues that matter
 
most
to consumers
 
and end-users are
 
addressed in the
 
decision-making processes.
 
Furthermore,
 
the engagement
 
occurs directly
with
 
consumers
 
and/or
 
end-users,
 
through
 
the
 
completion
 
of
 
questionnaires
 
on
 
potential
 
material
 
impacts,
 
risk
 
and
opportunities.
Processes to remediate
 
negative impacts and channels for
 
consumers and end-users to raise concerns
 
[S4-3]
Eurobank
 
has
 
established
 
policies
 
and
 
mechanisms
 
that
 
enable
 
customers
 
to
 
raise
 
concerns
 
and
 
ensure
 
appropriate
remediation for
 
any negative impacts.
For
 
Eurobank,
 
the
 
relationship
 
and
 
cooperation
 
with
 
its
 
clients
 
is
 
a
 
primary
 
strategic
 
objective.
 
Aiming
 
at
 
honest
 
and
transparent
 
communication,
 
it
 
has
 
set
 
up
 
specific
 
processes
 
to
 
communicate
 
information
 
surrounding
 
its
 
products
 
and
services.
 
Through
 
its Customer
 
Complaints Policy
 
and ISO
 
certified
 
processes,
 
the
 
Group
 
handles its
 
customer
 
complaints
with
 
compassion,
 
while
 
performance
 
is
 
measured
 
by
 
pertinent
 
qualitative
 
indicators.
 
Aiming
 
to
 
strengthen
 
its
 
customer
relationships,
 
Eurobank
 
has launched
 
Customer
 
Excellence,
 
to enhance
 
customer
 
service
 
through
 
all points
 
of contact
 
and
secure relationships of trust.
Eurobank addresses customer complaints in a spirit of good cooperation, understanding and respect, always in pursuit of an
appropriate and mutually acceptable solution. All complaints are managed
 
with impartiality and sincere willingness to reach
a
 
fair
 
solution.
 
Eurobank
 
has
 
harmonized
 
its
 
Management
 
of
 
Complaints
 
Policy
 
with
 
the
 
Bank
 
of
 
Greece's
 
Executive
Committee Act No.
 
157/2019 and revised
 
it in accordance
 
with ISO 9001
 
and ISO 10002
 
standards to enhance
 
the handling
of customer complaints. This updated policy
 
aims to improve the
 
effectiveness
 
and responsiveness of Eurobank’s
 
complaint
resolution process. Furthermore,
 
the customer is informed that if he is not satisfied
 
with the proposed solution, he can contact
Hellenic Financial
 
Ombudsman. Performance
 
in terms
 
of these
 
actions is
 
measured
 
using qualitative
 
indicators
 
set by
 
the
Bank,
 
while
 
statistics
 
are
 
extracted,
 
which
 
are
 
reflected
 
in
 
reports
 
used
 
to
 
keep
 
Eurobank’s
 
Management
 
updated.
 
The
commitment
 
to
 
customer
 
service
 
and
 
the
 
sincere
 
interest
 
of
 
Eurobank
 
are
 
reflected
 
at
 
every
 
stage
 
of
 
this
 
complaint
management
 
process,
 
as customers
 
are
 
continuously kept
 
up to
 
date about
 
the
 
progress
 
of their
 
case.
 
At the
 
same
 
time,
communication
 
is
 
maintained,
 
to
 
a
 
sample
 
of
 
cases,
 
even
 
after
 
the
 
case
 
has
 
been
 
resolved,
 
to
 
determine
 
whether
 
the
customer was
 
satisfied with the
 
outcome, as well
 
as to receive
 
their comments
 
and feedback.
 
All the
 
information
 
is used to
identify
 
and
 
highlight
 
the
 
reasons
 
for
 
dissatisfaction
 
among
 
customers
 
and
 
to
 
recommend
 
improvements
 
in
 
terms
 
of
provision of better service
 
and prevention of any future
 
issues.
Eurobank
 
closely
 
monitors the
 
effectiveness
 
of its
 
remediation
 
actions
 
through
 
a range
 
of client
 
complaints performance
indicators, which are:
Customer satisfaction
 
rate
Complaints resolved within 2 business days: 50%
 
for 2024
Annual new complaints: annual decrease of 15.3% for 2024
Client cases received: 10,825
 
for 2024
Client cases resolved:
 
10,522 for 2024
Overall resolution
 
rate: 97.2%
 
for 2024
Paying
 
attention
 
to the
 
importance
 
of complaint
 
management,
 
oversight
 
of results
 
takes
 
place
 
on a
 
regular
 
basis by
 
the
Executive Board as well as a Board
 
level Committee.
Additionally, Eurobank
 
makes the most of customer
 
experience data (Voice
 
of Customer) from
 
all available sources, internal
and
 
external,
 
such
 
as
 
complaints,
 
surveys
 
etc.,
 
constantly
 
adding
 
new
 
sources
 
by
 
initiating
 
new
 
NPS
 
surveys
 
at
 
various
touchpoints (branches, e-Banking, Eurobank Mobile App,
 
v-Banking, ATMs, EuroPhone Banking) and
 
for major products. These
are analyzed and evaluated
 
to identify areas that
 
call for
 
improvement
 
and to take corrective
 
and preventive
 
measures, so
that
 
Eurobank
 
services
 
fully
 
meet
 
its
 
customers’
 
wishes
 
and
 
expectations.
 
Moreover,
 
to
 
better
 
monitor
 
results,
 
certain
qualitative indicators have
 
been identified and are regularly monitored. In 2024:
Over 149,000
 
customer evaluations on banking
 
experience were
 
collected through regular
 
measurements.
 
62,000 comments were
 
analysed, which helped improve
 
existing services and/or design new ones.
 
 
 
 
 
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Over
 
1,042 customers
 
were
 
personally contacted
 
to be
 
informed
 
about the
 
actions Eurobank
 
initiated about
 
their
comments.
 
The responsible
 
officer
 
for the
 
receiving and
 
monitoring of reports
 
(RRMO) is tasked
 
with providing
 
clear guidance
 
on how
to
 
submit
 
a
 
report,
 
receiving
 
and
 
confirming
 
receipt
 
of
 
the
 
report
 
within
 
seven
 
working
 
days,
 
and
 
performing
 
an
 
initial
assessment.
 
They
 
are
 
also
 
responsible
 
for
 
designating
 
the
 
appropriate
 
unit
 
or
 
person
 
to
 
handle
 
the
 
report,
 
ensuring
 
the
confidentiality
 
of
 
the
 
reporting
 
person’s
 
identity
 
and
 
any
 
third
 
parties
 
mentioned.
 
Additionally,
 
the
 
officer
 
monitors
 
the
progress
 
of the
 
investigation,
 
maintains regular
 
contact with
 
the
 
reporting person,
 
and ensures
 
that feedback
 
is provided
within a reasonable period, not exceeding three months
 
from the receipt confirmation. The officer also plans and coordinates
relevant training efforts
 
to support the process.
According to the
 
Policy for
 
Reporting Illegal or Unethical
 
Conduct, Eurobank
 
provides protection
 
against reprisal and keeps
confidential
 
the
 
identity
 
of
 
those
 
who
 
have
 
submitted
 
information
 
they
 
know
 
and
 
consider
 
to
 
be
 
accurate
 
and
 
true.
Additionally,
 
there
 
are policies
 
in place
 
to prevent
 
any form
 
of retaliation
 
against individuals,
 
including customers,
 
utilising
these
 
channels.
 
For
 
further
 
reference,
 
applicable
 
information
 
has
 
been
 
disclosed
 
in
 
accordance
 
with
 
ESRS
 
G1-1
 
Business
conduct policies and corporate culture.
 
Eurobank
 
also prioritises
 
cybersecurity,
 
personal data,
 
and the
 
resilience
 
of its
 
ICT systems
 
against evolving
 
cyber threats.
Cybersecurity strategy follows
 
a comprehensive Predict,
 
Prevent, Detect, and Respond framework.
 
Customers
 
may
 
contact
 
the
 
Data
 
Protection
 
Officer
 
for
 
any
 
matter
 
regarding
 
the
 
processing
 
of
 
their
 
personal
 
data.
Additionally, for the exercise of their rights, customers may
 
submit a
 
written request to
 
Retail Business Planning
 
and Customer
Excellence
 
Retail
 
Banking
 
Unit.
 
Eurobank
 
shall
 
use
 
its
 
best
 
endeavors
 
to
 
address
 
such
 
requests
 
within
 
thirty
 
(30)
 
days
 
of
receipt
.
Taking
 
action on
 
material impacts
 
on consumers
 
and end-users,
 
and approaches
 
to managing
 
material risks,
 
pursuing
material opportunities related to consumers and end-users,
 
and effectiveness
 
of those actions [S4-4]
Eurobank is actively addressing and preventing potential
 
negative impacts on consumers and end-users through the
 
various
actions, that
 
are carried
 
out throughout
 
the reporting
 
period and
 
concern
 
the execution
 
of action plans
 
in own
 
operations
as well as its clients, as part of downstream value chain
.
 
Enhancement
 
of
 
threat
 
intelligence
 
capabilities
 
through
 
use
 
of
 
state-of
 
the-art
 
technologies/services,
 
and
collaboration with
 
peers from other
 
banks, as well as the Hellenic Police
 
and the National Cyber Defense
 
Agency.
Strengthening of the cybersecurity
 
capabilities for new digital products/
 
services, teleworking and cloud technology
adoption, as well as to address the ever
 
-growing threats (i.e.
 
Ransomware) and maintain compliance with evolving
regulatory requirements.
Application
 
of
 
multi-tiered
 
Endpoint Protection
 
Detection
 
Response
 
protection,
 
filtered
 
emails
 
and
 
web
 
content,
DDoS protection and SIEM services
 
to detect suspicious activities.
Vulnerability
 
assessments and penetration testing
 
to identify and address weaknesses in IT systems.
Operating
 
according
 
to ISO
 
27001,
 
ISO 22301,
 
ISO 20000,
 
and ISO
 
27701 standards.
 
The
 
scope of
 
the
 
ISO
 
27001
certification has been extended
 
to also cover cloud computing operations.
IT security awareness training and phishing simulation
 
exercises to educate staff on
 
recognising security threats.
Ensures compliance
 
with Regulation
 
(EU) 2016/679
 
(GDPR), Law
 
4624/2019,
 
and relevant
 
Greek and
 
EU legislation
on personal data protection.
Takes
 
appropriate
 
measures to
 
inform data
 
subjects (e.g.,
 
customers) about
 
the processing
 
of their
 
personal data
in a clear, concise, and easily accessible manner.
Mandatory training for
 
all staff on personal data protection
 
(GDPR) and IT security issues.
Development
 
and
 
enforcement
 
of
 
comprehensive
 
frameworks
 
to
 
ensure
 
data
 
security
 
and
 
privacy,
 
including:
 
IT
Security Policy,
 
Cyber Security, Risk Management Methodology,
 
Policy on Data Classification.
Addresses
 
customer
 
complaints
 
with
 
cooperation,
 
understanding,
 
and
 
respect,
 
striving
 
for
 
mutually
 
acceptable
solutions.
Harmonized Management of Complaints Policy with Bank of Greece
 
Executive Committee Act No. 157/2019.
Updated
 
complaint management processes based
 
on international standards (ISO 9001,
 
ISO 10002).
Utilises customer experience data (Voice
 
of Customer) from various sources,
 
including complaints, surveys, and NPS
(Net Promoter
 
Score) surveys
 
at touchpoints such
 
as branches,
 
e-Banking, Eurobank
 
Mobile App, v-Banking,
 
ATMs,
and EuroPhone Banking.
Analyzes
 
and
 
evaluates
 
customer
 
feedback
 
to
 
identify
 
areas
 
for
 
improvement
 
and
 
implement
 
corrective
 
and
preventive
 
measures.
Adheres to the regulatory framework
 
and the Banking Code of Conduct, with control mechanisms in place to ensure
compliance.
Advertising
 
and promotional
 
campaigns
 
are
 
subject to
 
prior
 
authorization
 
by
 
relevant
 
Group
 
units, with
 
content
reviewed
 
for compliance.
 
 
 
 
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In order to track the
 
effectiveness
 
of these results, certain
 
quantitative and qualitative indicators
 
have been identified and
are regularly monitored. These
 
include client complaints performance indicators
 
as well as customer privacy and
information prote
 
ction indicators.
 
Actions that promote
 
positive impacts on data security and customer
 
privacy /information include various
 
actions, that are
carried out throughout
 
the reporting period
 
and concern the execution
 
of action plans in own operations
 
as well as its
clients, as part of the downstream value
 
chain.
Customer Excellence
 
initiative launched to deliver
 
outstanding service at all customer touchpoints and foster
 
trust-
based relationships.
Recognises excellent performance
 
and encourages front-office
 
visits to ensure all staff members
 
share a customer-
centric culture.
Provides customized information
 
to every customer,
 
ensuring transparent communication
 
about products and
services.
Established customer support departments
 
and both traditional
 
and online service networks.
Developed easy-to-understand procedures
 
and brochures to inform customers
 
accurately about products
 
and
services.
In order
 
to track
 
the effectiveness
 
of these
 
results, certain
 
quantitative and
 
qualitative indicators
 
have been
 
identified and
are
 
regularly
 
monitored.
 
These
 
include
 
customers
 
satisfaction
 
surveys
 
as
 
well
 
as
 
Net
 
Promoter
 
Score
 
(NPS)
 
metrics.
 
The
effectiveness
 
of
 
these
 
actions
 
and
 
initiatives
 
is
 
further
 
supported
 
by
 
the
 
Retail
 
Customer
 
Excellence
 
Committee,
 
which
 
is
made up of senior Group
 
executives and is tasked
 
with making decisions that
 
will produce
 
the desired outcomes
 
for quality
and customer service
 
issues.
The
 
process
 
regarding
 
identifying what
 
action
 
is
 
needed
 
and what
 
response
 
to a
 
particular
 
actual
 
or potential
 
negative
impact
 
on
 
consumers
 
and/or
 
end-users
 
is
 
characterised
 
by
 
ESG
 
Risk
 
Assessment.
 
Eurobank
 
continues
 
to
 
strengthen
 
its
capacity to identify and manage social risk stemming from client operations.
 
The approach to take action in relation to
 
specific material negative impacts on consumers and/or
 
end-users is characterised
by
 
proactively
 
identifying
 
and
 
addressing
 
risks
 
associated
 
with
 
product
 
design,
 
marketing,
 
and
 
sales,
 
with
 
a
 
focus
 
on
monitoring and mitigating potential negative outcomes. This includes ensuring that advertising and promotional campaigns
are
 
subject
 
to
 
prior
 
authorization
 
to
 
prevent
 
misleading
 
or
 
harmful
 
messaging,
 
as
 
well
 
as
 
taking
 
steps
 
to
 
monitor
 
and
mitigate
 
data privacy
 
risks Eurobank
 
continuously seeks
 
to improve
 
the
 
transparency
 
and fairness
 
of product
 
design and
marketing strategies to safeguard
 
the interests of consumers.
 
Processes
 
to provide
 
remedy in
 
the event
 
of material
 
negative
 
impacts are
 
available and effective
 
in their
 
implementation
and outcomes.
 
These
 
processes
 
include actively
 
seeking customer
 
feedback
 
through
 
customized communication
 
tools and
ensuring that customers receive direct and prompt information about any new deals or changes to the products and services
they choose.
Severe
 
human rights
 
issues and
 
incidents connected
 
to consumers
 
and/or end-users
 
have
 
not been
 
reported.
 
In 2024,
 
no
incidents of non-compliance with regulations and voluntary codes concerning product and service information,
 
and labelling
or marketing communications were
 
identified and, as a result, no fines or sanctions were imposed on the
 
Group.
 
Resources
 
allocated
 
to
 
the
 
management
 
of
 
material
 
impacts
 
engage
 
internal
 
functions
 
such
 
as
 
Risk
 
Management,
Compliance, IT
 
Security,
 
and Customer
 
Experience
 
departments, which
 
take actions
 
like
 
enhancing threat
 
intelligence
 
and
cybersecurity
 
measures,
 
conducting
 
staff
 
training
 
and
 
awareness
 
programs,
 
ensuring
 
compliance
 
with
 
international
standards, and monitoring customer satisfaction
3.2.3
Metrics & Targets
Targets
 
related to managing material negative
 
impacts, advancing positive impacts, and managing
 
material risks and
opportunities [S4-5]
Eurobank has established the
 
following qualitative
 
targets to meet its commitments to improving accessibility
 
and inclusion
for customers,
 
as well as raising external ESG awareness
 
by 2025:
Enhance accessibility initiatives
 
for services and products
 
targeted to underserved
 
social groups
Raise staff awareness and familiarity
 
on disabilities (through experiential training)
Enhance outreach to customers
 
on sustainability through the Digital Academy
Develop responsible banking mechanisms
 
to raise customers’
 
ESG awareness
 
Eurobank’s
 
targets
 
for
 
enhancing
 
external
 
ESG
 
awareness
 
as
 
well
 
as
 
accessibility
 
and
 
inclusion
 
for
 
customers
 
align
 
with
Sustainability Policy Framework and the principles outlined in
 
its Code of
 
Conduct & Ethics,
 
emphasising transparency, ethical
behaviour,
 
and professionalism.
 
By 2025, Eurobank
 
aims to enhance ESG
 
awareness for
 
customers, ensuring they
 
can make
informed
 
decisions,
 
which
 
promotes
 
transparency.
 
The
 
Bank
 
assists
 
stakeholders
 
to
 
assimilate
 
ESG
 
terminology,
opportunities and applicability.
 
Raising ESG awareness
 
for
 
external stakeholders,
 
and particularly
 
for clients,
 
is an integral
part of Eurobank’s
 
Sustainability Operational
 
Impact Strategy.
 
To this
 
end, Eurobank
 
actively supports Greek
 
businesses in
their transition to the
 
digital and sustainability model, through a series of Digital Academy
 
articles and webinars.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The Group also plans to develop responsible banking mechanisms to raise ESG awareness by providing
 
reliable information,
particularly
 
for
 
those
 
engaging
 
in
 
sustainable
 
investment
 
decisions.
 
By
 
focusing
 
on
 
vulnerable
 
groups,
 
equal
 
access
 
to
banking services
 
and strengthening
 
of inclusivity
 
are ensured.
 
Staff receives
 
experiential training
 
to provide
 
better quality
services to customers with
 
disabilities, reinforcing Eurobank’s
 
commitment to inclusivity.
 
Indicative achievements
 
against targets for 2024 are as follows:
 
Continuous improvement
 
of services and launch of additional inclusion initiatives
 
targeting specific social groups:
 
o
Services
 
now
 
include
 
sign
 
language
 
support
 
through
 
v-Banking
 
for
 
hearing-disabled
 
customers
 
and
 
Braille
documents and accessible PDFs for visually impaired customers. Additionally,
 
100% of ATMs have been adapted
to accessibility requirements (voice
 
guidance) while 92 branches are
 
equipped with ramps
o
Implementation
 
of
 
“Familiarity
 
with
 
disabilities”
 
training
 
sessions,
 
focused
 
on
 
Retail
 
banking
 
Networks
 
to
enhance accessibility and
 
inclusion for
 
customers. 1,900
 
employees have
 
been trained to
 
assist individuals with
disabilities
o
Inspirational talks by Eurobank's
 
Accessibility Ambassadors
o
Real Life Heroes Award
 
to a colleague who excelled in servicing clients with disabilities.
External ESG
 
awareness initiatives
 
for
 
clients, including
 
the
 
Digital Academy
 
series of
 
ESG webinars:
 
3 workshops
took place for “Sustainable Transition:
 
New prospects and new requirements”,
 
“Financing Sustainable Development
for SMEs” and “Interbank ESG
 
Questionnaire - Transition
 
from Theory
 
to Practice” with
 
441 clients participating.
The Sustainability
 
Strategy
 
defines the
 
Group’s
 
sustainability priorities
 
and objectives.
 
The Operational
 
Impact Strategy
 
is
deployed through milestones and KPIs that support the
 
annual and the long-term interim targets set across multiple project
streams,
 
spanning
 
over
 
the
 
next
 
decade.
 
It
 
is
 
developed
 
and
 
deployed
 
along
 
3
 
pillars
 
and
 
corresponding
 
corporate
objectives, supported by a governance structure of project streams (one per each commitment) and the supervisory ESG/OIS
Committee.
 
Progress
 
is
 
regularly
 
reviewed
 
at
 
the
 
Sustainability
 
Management
 
Committee.
 
Links
 
are
 
established
 
with
Transformation
 
streams
 
as
 
well
 
as
 
corresponding
 
ISO
 
management
 
system
 
standards,
 
to
 
ensure
 
substantiation
 
and
certification
 
of activities,
 
validate target
 
setting and measured
 
performance,
 
and systematically
 
monitor progress
 
through
internal reviews and external assurance. The Group plans to revisit and update its Sustainability
 
Strategy on an annual basis,
in line with best market practices,
 
and regulatory requirements.
 
Customers feedback
 
surveys, quantitative
 
data about changes
 
in users'
 
demographics and
 
courses completed per
 
training
and/or number
 
of participants
 
are exploited
 
in order
 
to track
 
effectiveness
 
of the
 
targets. Their
 
progress
 
will be monitored
throughout the
 
year to ensure that they
 
are met with a final evaluation
 
at the end of the period
 
they are set.
3.3
Fostering innovation
 
[Entity-specific]
 
3.3.1
Strategy
Description of material impacts, risks and opportunities and their
 
interaction with strategy
 
and business model [SBM-3]
Innovation
 
is
 
a
 
strategic
 
business
 
opportunity
 
for
 
Eurobank
 
in
 
relation
 
to
 
the
 
increase
 
of
 
positive
 
and
 
the
 
reduction
 
of
negative
 
impacts it
 
has identified.
 
Thus,
 
it places
 
great
 
emphasis in
 
creating
 
an environment
 
that
 
fosters
 
the
 
sustainable
growth
 
of small
 
and medium-sized
 
enterprises (SMEs)
 
both national
 
and international
 
and reinforces
 
the
 
outward-looking
potential of Greek companies with a view to promoting effective
 
entrepreneurship and improving the quality of key business
sectors through innovative services. Eurobank
 
is also promoting innovative channels for service delivery
 
and designing value-
adding solutions, tailor-made to its customer needs.
To
 
this end,
 
a key
 
component of
 
the
 
societal pillar
 
of the
 
Groups sustainability
 
strategy
 
focuses
 
on stimulating
 
innovative,
inclusive and youth-focused
 
entrepreneurship.
Eurobank’s mission
 
goes well beyond
 
its financial aspect and aims
 
to contribute to economic growth,
 
but also to enable an
inclusive and sustainable economic
 
model, one that champions innovation, supports
 
communities and generates widespread
prosperity.
Regarding the Governance
 
-related information
 
please refer to : 1.3 Governance.
3.3.2
Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Through the
 
DMA Eurobank has identified the
 
following material
 
risks and opportunities:
Fostering innovation
Risk
Rapid
 
technologic
 
development
 
in
 
the
 
banking
 
sector
 
may
 
pose
 
competitive
threats and risks if Eurobank
 
fails to adapt and innovate at the
 
same pace.
Opportunity
Meeting
 
evolving
 
customer
 
expectations
 
and
 
modern
 
lifestyle
 
needs
 
through
utilising digital tools and innovative services
 
can improve
 
customer engagement
The process
 
of assessing fostering innovation
 
applies across all regions where
 
Eurobank operates.
 
 
 
 
 
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3.3.3
Policies and actions
 
Policies related to fostering
 
innovation [MDR-P]
The Group’s
 
Sustainability Policy
 
Framework
 
is the underlying
 
policy describing its
 
strategic
 
objective to
 
adapt its business
and operations in a way that
 
accommodates social needs within its business model.
The Sustainability Policy
 
Framework
 
makes reference
 
to the significance
 
of fostering an
 
innovative environment
 
and its role
in the overall
 
sustainability strategy which includes its commitments and targets
 
of the societal pillar towards that
 
end.
Actions related to fostering
 
innovation [MDR-A]
Eurobank
 
is
 
an
 
innovator
 
when
 
it
 
comes
 
to
 
initiatives
 
and
 
Corporate
 
Social
 
Responsibility
 
(CSR)
 
activities
 
that
 
support
innovative entrepreneurship,
 
foster the
 
sustainable growth of small and medium
 
-sized enterprises (SMEs) both national
 
and
international
 
and
 
reinforce
 
the
 
outward-looking
 
potential
 
of
 
Greek
 
companies,
 
with
 
a
 
view
 
to
 
promoting
 
effective
entrepreneurship and improving
 
the quality of key business sectors through
 
innovative services.
Eurobank Next – Digital Growth
 
& Future Competitiveness
 
Eurobank
 
Next - Digital
 
Growth and
 
Future Competitiveness
 
is a strategic
 
initiative launched
 
in January 2024
 
under which
both the Innovation Center
 
and the GenAI Coordination Unit operate,
 
aspiring to be the driving force behind transformative
banking
solutions.
 
It
 
aims to
 
safeguard
 
the
 
Group’s
 
future
 
relevance
 
through
 
fostering
 
the
 
innovation
 
mindset
 
&
practice
across the Group while also
 
exploring
and exploiting
 
disruptive value propositions to
 
pursue growth & future competitiveness.
The
 
Innovation
 
Center’s
 
mission is
 
to provide
 
fast-paced,
 
focused
 
innovation
 
aligned with
 
Eurobank’s
 
broader
 
strategy
 
to
increase
 
profitability
 
and
 
efficiency.
 
With
 
its Innovation
 
&
 
UX
 
Labs,
 
Innovation
 
Center
 
fosters
 
both
 
entrepreneurship
 
and
intrapreneurship across Eurobank, and links the organisation with Fintech
 
companies to further elevate customer satisfaction.
The
 
team
 
scouted
 
more
 
than
 
50
 
startups
 
and
 
provided
 
recommendations
 
to
 
Business
 
Units
 
for
 
potential
 
opportunities,
resulting to
 
POCs or
 
partnerships.
 
Alongside this,
 
the
 
Unit constantly
 
monitors trends
 
and provides
 
market insights
 
across
the
 
Group
 
through
 
its
 
monthly
 
newsletter
 
and
 
quarterly
 
report.
 
Also,
 
it
 
forged
 
strategic
 
partnerships
 
with
 
International
Organisations
 
and platforms
 
to leverage
 
networks for
 
open innovation.
 
A Brainstorming
 
Session concept
 
was launched
 
to
accelerate
 
top-tier
 
ideas from
 
all business
 
units within
 
Eurobank
 
and customers
 
outside
 
Eurobank,
 
encouraging
 
collective
innovation in product development
 
through a dynamic, collaborative
 
approach.
Working in
 
tandem with
 
the Innovation
 
Center,
 
the GenAI
 
Coordination Unit
 
is responsible
 
for setting
 
Eurobank’s
 
strategic
ambition
 
in the
 
field
 
of Generative
 
AI
 
(GenAI).
 
The
 
unit focuses
 
on defining
 
use
 
cases
 
for
 
GenAI
 
across
 
the
 
organisation,
coordinating
 
the
 
various
 
stakeholders
 
involved,
 
and overseeing
 
the
 
deployment
 
of GenAI
 
technologies
 
in active
 
projects.
Their work ensures
 
the successful adoption and integration
 
of GenAI, aligning it with Eurobank's digital growth
 
ambitions.
While building
 
its operationalization
 
Framework,
 
the
 
GenAI Coordination
 
Unit is
 
working
 
closely with
 
all Business
 
units to
identify potential
 
Use Cases. To
 
this day,
 
one use
 
case is
 
launched into production,
 
six are
 
in pilot phase
 
and more
 
than 10
use cases
 
are being assessed and prioritised.
 
Further to the
 
above, with the
 
aim to strengthen competitiveness,
 
promote, support and integrate
 
Innovation at all levels
 
of
the Organisation's operation,
 
an Innovation Board was established
 
under the leadership of our
 
CEO. Its establishment is an
important step
 
towards
 
strengthening
 
the
 
culture
 
of innovation
 
and ensuring
 
the
 
Group’s
 
continuous
 
adaptation
 
to new
technological and business challenges.
egg - enter grow go
In the area of innovative entrepreneurship, Eurobank – in partnership with Corallia, a unit of
 
the Athena Research Centre that
implements
 
flagship
 
programmes
 
and
 
targeted
 
interventions
 
focusing
 
on
 
the
 
management
 
of
 
Clusters,
 
Incubators
 
and
Entrepreneurship
 
Programmes
 
– introduced
 
an initiative
 
in 2013:
 
the
 
egg –
 
enter grow
 
go. This
 
business accelerator
 
offers
entrepreneurs
 
an integrated
 
framework
 
of business
 
incubation,
 
acceleration,
 
and collaboration
 
among startups.
 
The
 
12th
cycle
 
commenced
 
in
 
2024,
 
continuing
 
to
 
support
 
innovative
 
businesses
 
in
 
3
 
key
 
areas:
 
extroversion,
 
financing
 
and
interconnection of businesses with
 
the global market.
In the
 
last 12
 
years, egg
 
has become
 
one of
 
the most
 
prominent business
 
acceleration
 
initiatives in
 
the country.
 
It has also
substantially
 
enhanced
 
its reputation
 
in Greece
 
and abroad,
 
and has
 
become
 
an industry
 
standard
 
in the
 
Greek
 
startup
ecosystem. Since
 
2019 egg
 
has been
 
consisting of
 
3 distinct
 
and complementary
 
entrepreneurship
 
support platforms:
 
egg
pre – acceleration,
 
egg Start-Up and egg Scale-Up.
egg
 
pre
 
 
acceleration
 
initiatives
 
aim
 
at
 
supporting
 
the
 
academic
 
community,
 
connect
 
research
 
and
 
innovation
 
with
entrepreneurship
 
and
 
support
 
groups
 
who
 
want
 
to
 
immerse
 
themselves
 
in
 
the
 
principles
 
of
 
entrepreneurship.
 
More
specifically, through
 
targeted pre-
 
acceleration
 
programs, egg provides
 
the academic community (undergraduate
 
students,
postgraduates, researchers,
 
teachers etc)
 
with mentoring,
 
guidance and training
 
to connect them
 
to entrepreneurship
 
and
the economic system.
More precisely,
 
egg launched in 2022 an
online acceleration
 
program
 
in collaboration with
 
ICC Hellas, their Cluster,
 
Female
Founders’
 
Startup, DUTH, and AUTH. This program saw the participation of eight female-led startups, achieving 100% female
representation. Building
 
on the success
 
and outcomes of this initiative,
 
egg introduced the
Female Entrepreneurship
 
– Mini
Acceleration
 
Program
 
in 2023, tailored
 
for female
 
researchers
 
and university students
 
in STEAM fields.
 
The program,
 
which
 
 
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was
 
delivered
 
twice
 
(2)
 
by
 
egg
 
in
 
2023,
 
is
 
a
 
multifaceted
 
approach
 
that
 
encompasses
 
mentorship,
 
skill-building
 
and
networking opportunities
 
tailored specifically
 
for female
 
researchers
 
and entrepreneurs in
 
Greek Universities
 
and Institutes.
It
 
empowers
 
women
 
to
 
overcome
 
barriers,
 
seize
 
opportunities and
 
flourish
 
in
 
their
 
respective
 
fields.
 
In
 
total,
 
48
 
research
teams participated in 2023, with women representing 67% of
 
the participants. Building on this success, in
 
2024, egg launched
a
Mini
 
Acceleration
 
Program
 
for
 
Researchers
.
 
This
 
iteration
 
of
 
the
 
program
 
followed
 
a
 
similar
 
structure,
 
providing
mentorship and
 
support to research
 
teams. A total
 
of 24 teams participated,
 
with 32%
 
female representation.
 
The primary
objective
 
was to
 
foster
 
research
 
and innovation
 
within universities,
 
helping participants
 
understand entrepreneurship
 
and
develop
 
their
 
entrepreneurial
 
ideas.
 
In
 
parallel,
 
egg,
 
in
 
collaboration
 
with
 
EBAN,
 
introduced
 
an
International
 
Pre
 
-
Acceleration
 
Program
,
 
offering
 
support,
 
guidance,
 
and
 
mentorship
 
to
 
8
 
international
 
startups.
 
This
 
program
 
focuses
 
on
helping startups expand their businesses
 
and establish a presence in Greece.
Tourism and Culture cluster
With egg –
 
enter grow
 
go as the administrator,
 
Eurobank supports
 
the first Greek
 
Cooperative
 
Innovation Cluster
 
in Digital
Technologies in the Tourism
 
and Culture Industries (Tourism and Culture Cluster). The main purpose of the Cluster is to secure
financial
 
viability
 
and
 
achieve
 
economies
 
of
 
scale
 
and
 
economies
 
of
 
scope
 
in
 
digital
 
applications
 
and
 
technologies
 
for
Tourism
 
and Culture. It
 
also fosters
 
an environment
 
of collaboration
 
and creativity and
 
encourages knowledge
 
sharing and
resource pooling among member companies, resulting in more efficient and sustainable practices. The initiative incorporates
innovative companies and other
 
organisations based in Greece that
 
promote innovation,
 
research and networking, and are
active in the wider digital tourism
 
technologies and ICT sector.
 
This approach aligns perfectly with the priorities set by the World Tourism Organisation (UNWTO)
 
and tourism organisations
globally.
 
The
 
objective
 
of
 
the
 
Cluster
 
is
 
to
 
digitise
 
tourism
 
and
 
cultural
 
products,
 
maximising
 
Greece’s
 
competitive
 
edge
through
 
the
 
use of
 
software
 
and digital
 
content technologies,
 
smart mobile
 
apps and
 
other
 
high-tech applications.
 
These
advancements
 
will offer
 
visitors new
 
and enhanced
 
travel
 
experiences,
 
aligning with
 
the
 
overarching
 
goal of
 
the
 
initiative.
Through the
 
integration of innovative
 
technologies, the Cluster
 
aims to modernise the tourism sector,
 
providing visitors with
tailored, cutting-edge
 
experiences,
 
while ensuring Greece’s
 
continued relevance
 
and competitiveness
 
in the
 
global tourism
market. The “Development of innovative technologies and new generation of digital applications in tourism and culture” R&D
programme
 
has
 
been
 
successfully
 
submitted
 
to
 
the
 
Innovation
 
Cluster
 
CfP
 
of
 
the
 
General
 
Secretariat
 
for
 
Research
 
&
Innovation, with a total budget of €2.8 million,
 
allocated to 6 ambitious collaborative
 
R&D projects from 13 companies.
Exportgate and extroversion
 
initiatives
 
Eurobank aims at actively contributing to the country’s economic growth and recognises the importance of entrepreneurship
as a major lever for the expansion of the Greek economy.
 
The Eurobank also focuses on supporting the extroversion
 
of Greek
businesses
 
by
 
encouraging
 
new
 
business initiatives.
 
With
 
the
 
support of
 
4 leading
 
Greek
 
export associations
 
(Panhellenic
Exporters Association, Greek International Business Association,
 
Exporters’ Association of Crete and SEV-Hellenic Federation
of Enterprises), Eurobank created
 
Exportgate, a pioneering international
 
web trade portal offering
 
networking opportunities
in the global market to Greek and
 
Cypriot companies and providing access to advanced tools for their international business
operations. With
 
more than 5,500 participating Greek
 
companies, it covers all major sectors of the
 
economy.
 
Exportgate members
 
have online
 
access to
 
information
 
for
 
over
 
1,000,000
 
partners located
 
in 200
 
countries. 2023
 
marked
the 10-year anniversary
 
since Exportgate’s launch and
 
Eurobank scheduled
 
a series of initiatives to celebrate
 
this significant
milestone
 
and
 
to
 
essentially
 
thank
 
its
 
valuable
 
partners
 
and
 
members
 
for
 
being
 
the
 
greatest
 
ambassadors
 
in
 
the
development
 
of its
 
extroversion
 
strategy.
 
Exportgate is
 
a member
 
of the
 
Trade
 
Club Alliance
 
(TCA)
 
network,
 
following
 
the
strategic agreement
 
between Eurobank
 
and Santander,
 
a leading bank in retail and corporate
 
banking registered in
 
Spain.
Supported by international banks
 
covering over 65% of global trade corridors, the
 
TCA is the first
 
e-business network enabling
its
 
members
 
to
 
identify
 
partners
 
easily,
 
quickly
 
and
 
reliably
 
around
 
the
 
globe
 
by
 
strongly
 
investing
 
in
 
advanced
 
AI
technologies. The network is still expanding, with the most recent integration in the market of China,
 
represented by the Bank
of China.
Additionally, there
 
is strong collaboration with Enterprise Greece,
 
the official investment, and trade promotion
 
agency of the
Greek State, aiming at
 
increasing export activity and
 
at attracting foreign investments. Through SEV’s extroversion
 
initiatives
(Export Ready Workshops and
 
Doing Business Events), SEV and
 
Eurobank have
 
established powerful
 
synergies offering
 
end-
to-end support to Greek businesses.
Growth Awards
 
Eurobank
 
established the
 
“Growth
 
Awards”
 
in 2016,
 
in partnership
 
with Grant
 
Thornton. The
 
aim was to
 
reward
 
companies
that combine high financial performance with a successful corporate history and
 
contribute to forming a new entrepreneurial
landscape and
 
work
 
culture
 
in Greece.
 
The
 
awards aspire
 
to become
 
one of
 
the
 
leading ways
 
of acknowledging
 
business
excellence and supporting the growth
 
of robust enterprises in Greece.
The
 
7 Growth
 
Awards
 
ceremonies
 
to date
 
have awarded
 
44 of
 
the most
 
robust
 
Greek enterprises.
 
More than
 
2,000 guests
attend the
 
award ceremony
 
every
 
year,
 
7 internationally
 
renowned
 
speakers
 
have been
 
hosted and
 
around 80
 
enterprises
apply annually. The
 
Award Committee consists of 20 distinguished individuals from the Greek
 
business and academic arena.
Digital Banking
Throughout 2024, Eurobank was fully committed to
 
continue delivering personalised and user-friendly digital
 
services, as part
of
 
its
 
digital
 
transformation,
 
investing
 
in
 
technological
 
infrastructure
 
and
 
human
 
resources,
 
and
 
supporting
 
all
 
users
 
in
 
 
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accessing
 
digital
 
solutions.
 
Eurobank
 
Group
 
Digital
 
Banking
 
leverages
 
its
 
expertise
 
to
 
provide
 
innovative,
 
data
 
driven
financial products
 
and services.
 
Placing customers
 
at the
 
center,
 
it delivers
 
simple, personalized
 
products and
 
ensures easy
access to
 
them.
 
Bringing technology
 
closer
 
to everyone,
 
it acts
 
as a
 
digital and
 
phygital
 
key enabler
 
and Eurobank’s
 
main
digital culture ambassador. 2
 
main aspects are identified in its digitisation journey:
 
1)
External
 
digitisation
 
 
Its
 
digital
 
footprint
 
through
 
web
 
and
 
mobile
 
banking,
 
websites
 
and
 
social
 
media
presence.
 
2)
Internal digitisation – Its simplified internal processes
 
through all customer
 
touchpoints.
Eurobank’s digital-first
 
approach has
 
led to a significant
 
expansion of its
 
digital portfolio,
 
offering
 
a range of
 
products and
services to enhance
 
customer experience
 
and address customer
 
needs as voiced directly
 
by them. The
 
main theme for
 
2024
involved
 
the
 
provision
 
of
 
new
 
digital
 
products
 
and
 
services
 
for
 
both
 
Individuals
 
and
 
Businesses
 
Key
 
digital
 
products
 
and
initiatives for 2024:
 
Group
 
Sales
 
Digital Onboarding:
 
a unique
 
in the
 
Greek
 
market,
 
digital service
 
allowing
 
companies
 
to digitalise
 
their
payroll process
 
while enabling their employees
 
to digital onboard their employers
 
payroll service,
New credit
 
products –
 
Introduced
 
personalised and pre
 
-advised products
 
with automated
 
credit decisions,
 
enabling a
seamless and fast digital experience.
 
Launched a market-first virtual credit card
 
Insurance products – Launched
 
additional general insurance
 
products via digital channels, such as Motor Insurance
 
and
Pet insurance products.
A new product offering
 
for teenagers: a virtual prepaid
 
issued by the parent/guardian
 
and used by the minor.
Digital offering for businesses – Introduced
 
online set up of Time Deposit deals with personalized options application for
POS facility, as well
 
as numerous digital tools for
 
the administration
 
of a company’s legal documentation.
 
These products
 
cater for the
 
everyday
 
needs of businesses, providing efficient financial solutions
 
to support their operations
and growth, alleviate
 
the need to visit a branch and save
 
valuable time.
In addition to these digital products, Eurobank
 
made notable advancements in 2024:
 
Expanded partnerships
 
in embedded
 
financing –
 
Launched
 
new
 
partnerships
 
with merchants
 
in embedded
 
financing.
This
 
initiative
 
enables consumers
 
to finance
 
their
 
online
 
purchases
 
directly
 
through
 
the
 
Group
 
when
 
shopping online,
streamlining the payment
 
process and enhancing convenience
 
for customers.
 
Enhanced
 
customer
 
service
 
features
 
 
Introduced
 
several
 
features
 
to
 
upgrade
 
the
 
customer
 
experience
 
and
 
save
customers
 
time from
 
visiting a
 
branch for
 
service requests,
 
such as
 
the addition
 
of a
 
new account
 
beneficiary and
 
the
ability to issue Certificates with a simple click of a button.
 
Open
 
Banking
 
 
Eurobank
 
made
 
further
 
progress
 
in
 
Open
 
Banking
 
by
 
offering
 
new
 
custom
 
added-value
 
APIs,
 
to
cooperating companies, in the
 
areas of onboarding, account and transactions
 
management etc
The Open Banking channel:
 
o
Served 150,000 customers
 
with 12,000,000 calls.
 
o
Increased transaction volume
 
to €171 million, up from 7M compared to 2023.
 
Eurobank’s
 
digital
 
initiatives
 
epitomise
 
a
 
strategic
 
commitment
 
to
 
harnessing
 
technology
 
for
 
delivering
 
cutting-edge
solutions
 
and
 
tailored
 
experiences
 
for
 
individuals
 
and
 
business
 
customers.
 
These
 
efforts
 
were
 
recognised
 
by
 
notable
distinctions.
 
In
 
2024,
 
Eurobank
 
was
 
honoured
 
as
 
«Best
 
Consumer
 
Digital
 
Bank
 
in
 
Western
 
Europe
 
for
 
2024»
 
for
 
the
 
5th
consecutive year,
 
by the esteemed US Global Finance magazine,
 
affirming its continuous excellence in digital banking on an
international
 
scale. Additionally,
 
during 2024
 
Eurobank
 
the
 
Eurobank
 
Mobile App
 
was ranked
 
1st in
 
the
 
App store
 
and iOS
among all other banks in Greece.
 
Digital and hybrid sales
 
– In 2024, the volume
 
of digital and hybrid sales increased significantly by 28% (in items) through:
Enriching product offering
 
across product categories
 
and segments, such as new credit products (personalized and pre-
advised loans), virtual credit card, virtual prepaid for teenagers,
 
“Salary Link” service (allowing employees to have salary
deposited into a Eurobank account), Motor & Pet
 
insurance products
Increasing traffic
 
and optimizing
 
journeys through
 
various digital
 
campaigns, promotions,
 
and events
 
for
 
a significant
number of digital
 
products. Additionally,
 
designing and making
 
the most of
 
new capabilities
 
to drive engagement
 
and
sales (e.g., personalized promo areas in e/m banking, lead generation
 
from eurobank.gr).
 
Designing
 
and
 
developing
 
new
 
hybrid
 
journeys
 
and
 
capabilities,
 
contributing
 
to
 
Eurobank’s
 
phygital
 
model.
 
Key
initiatives included
 
enhancements and
 
the addition
 
of new
 
products in
 
the Digital
 
Safebox (the
 
application is
 
initiated
at the
 
branch or through
 
telemarketing and completed
 
by the
 
customer via
 
e/m banking), guiding customers
 
to digital
channels during the “Book a Branch
 
appointment” process.
User experience
- The User
 
Experience (UX) team
 
prioritises the customer/user
 
in all Bank's operations.
 
UX Researchers
 
and
Designers work
 
to improve
 
the experiences
 
of both
 
customers
 
and staff
 
across various
 
channels and touchpoints,
 
applying
established design standards,
 
including accessibility considerations
 
and best practices.
 
To conduct
 
user research,
 
the team
utilises state-of-the-art
 
UX Lab
 
facilities,
 
employs
 
a variety
 
of methods
 
and custom
 
tools
 
(such as
 
user
 
interviews,
 
design
thinking, usability tests,
 
card sorting, tree testing).
 
This approach involves recruiting both external and internal users to
 
ensure
a holistic understanding of user needs and behaviours.
 
 
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The
 
UX
 
team
 
has
 
created
 
4
 
user
 
pools:
 
the
 
Digital
 
Community
 
(digital
 
banking
 
customers),
 
the
 
Digiators
 
(internal
 
staff),
Friends & Family, and Accessibility
 
for all (people with disabilities) to simplify processes
 
and efficiently gain insights.
During 2024, approximately
 
179 users, including users with disabilities,
 
were engaged in
 
31 research activities and testing
 
as
well as 326
 
users were
 
engaged in online
 
questionnaire for
 
9 projects.
 
User flows and
 
designs were
 
created for
 
117 projects.
It
 
also
 
implemented
 
design
 
systems
 
for
 
mobile
 
app,
 
e-banking,
 
eurobank.gr,
 
unify and
 
drive+
 
so as
 
to work
 
with
 
specific
design
 
standards,
 
patterns
 
and
 
components,
 
to
 
provide
 
consistent
 
experiences
 
and
 
efficiencies
 
to
 
the
 
design
 
and
development teams. Organised specialist accessibility training and experiential workshops for cross-functional collaborating
teams (25 hours).
Websites
 
- In
 
2024,
 
eurobank.gr
 
attracted
 
over
 
27.2
 
million visits
 
where
 
55% of
 
this traffic
 
originated
 
organically
 
through
search engines,
 
such as Google.
 
The year
 
also marked
 
a major technological
 
advancement with
 
a comprehensive
 
upgrade
to
 
the
 
Sitecore
 
infrastructure,
 
incorporating
 
features
 
like
Sitecore
 
Personalise
 
to
 
power
 
personalised
 
user
 
journeys.
Additionally,
 
ongoing improvements
 
to calculators
 
and interactive
 
tools were
 
implemented to enhance
 
the user
 
experience
and drive lead generation.
Social media
 
– With
 
11 active
 
channels on
 
different
 
platforms,
 
such as Facebook,
 
LinkedIn, Instagram,
 
TikTok
 
and YouTube,
Eurobank:
 
Recorded 334,951
 
interactions.
Produced content with 866 organic posts across
 
social media platforms.
 
Performed
 
community management, responding to 9,466
 
user comments
Community management
 
across
 
the
 
Eurobank’s
 
social media
 
channels helps
 
the
 
bank forge
 
better customer
 
relationships
within the
 
digital environment
 
but also
 
introduces
 
a new
 
approach
 
to the
 
bank-customer
 
relationship
 
and digital
 
sales. In
terms of interactions,
 
Eurobank ranked
 
1st on LinkedIn and
 
on TikTok
 
and 2nd on YouTube
 
across the
 
Greek banking sector.
The €pistrofi
 
loyalty
 
page on Facebook
 
was 1st in
 
interactions
 
and followers
 
growth
 
across the
 
Greek banking
 
sector.
 
Also,
Eurobank was the first bank to launch a TikTok series in Greece & create native content on TikTok,
 
adapting to the platform's
unique style and
 
user preferences.
 
Additionally,
 
it completely
 
transformed
 
its tone of
 
voice
 
for community
 
management on
TikTok,
 
ensuring it remains relevant and engaging to the
 
platform's audience.
Digital
 
Creative
 
Hub
 
 
Our
 
content
 
leading
 
team
 
with
 
dedicated
 
digital
 
copywriters
 
and
 
designers
 
responded
 
to
 
an
increased demand (+39%) for
 
digital content through 2,436
 
deliverables
 
for 597 projects
 
in Group Websites
 
(incl. Robochat,
chatBot features),
 
175 email campaigns, 93 digital channels product pages, flows
 
and microcopy projects.
Performance marketing
 
– Through digital advertising platforms, it helps business growth directly,
 
by supporting digital sales
in achieving their sales targets, and indirectly,
 
with marketing campaigns aiming at increasing brand
 
awareness. In 2024, 111
digital campaigns were
 
launched, reaching:
 
Over 4 million users
 
1 billion impressions
 
67.2
 
million video views
 
Approximately
 
16
 
million
 
clicks
 
Using
 
cookies
 
in
 
accordance
 
with
 
the
 
applicable
 
data
 
protection
 
legislation,
Eurobank continues to collect data from
 
user interactions
 
on its websites, to serve personalized
 
ad content.
Customer journeys and internal digitisation
 
– Eurobank continued to re-design and simplify
 
major customer journeys across
channels. Numerous
 
initiatives were carried
 
out across channels and segments, aiming to achieve customer
 
and operational
excellence through sustainable paths. As a
 
result, Eurobank achieved a Net Promoter Score (NPS)
 
over 40 in a
 
major customer
journeys.
 
Key highlights per journey:
 
Customer
 
onboarding
 
and
 
management
 
 
Made
 
it
 
easier
 
and
 
faster
 
for
 
customers
 
to
 
start
 
and
 
manage
 
their
relationship
 
with
 
it
 
through
 
physical
 
channels,
 
by
 
integrating
 
various
 
technologies
 
and
 
improvements,
 
such
 
us:
automating document submission and
 
e-kyc services, reducing customer signatures by 80%
 
and time-to service even
further.
 
Notably, for private clientele, it reduced signatures by 66%, as part of its commitment to excel on the wealth
management operation
 
spectrum.
 
 
Banking everywhere
 
– Empowered
 
its Relationship and
 
Branch Managers
 
to deliver
 
banking services
 
directly to its
clients, wherever
 
they may be, in
 
an effort
 
to boost service accessibility
 
and convenience.
 
From account opening to
card issuance, it is bringing the
 
Group to its customers’
 
doorsteps, with secure.
 
Lending journeys
 
– Reduced
 
time-to-cash even
 
further
 
less than
 
one and a
 
half days), aiming
 
to respond faster
 
to
customer
 
requests.
 
In
 
addition,
 
the
 
consumer
 
lending
 
process
 
achieved
 
remarkable
 
efficiency,
 
with
 
over
 
50%
 
of
applications seamlessly
 
progressing
 
without the
 
foureyes
 
principle, due to
 
automated checks.
 
Moreover,
 
Eurobank
maintained
 
a
 
robust
 
80%
 
automation
 
rate
 
on
 
credit
 
decision
 
procedure,
 
demonstrating
 
its
 
commitment
 
to
operational excellence and risk management. It
 
also recorded significant improvement in business financing,
 
leading
to
 
a
 
50%
 
reduction
 
in
 
time-to-cash
 
by
 
automating
 
credit
 
underwriting
 
(40%
 
in
 
simple
 
products)
 
and
 
contract
drafting
 
(90% automation).
 
As a
 
result,
 
within 2024
 
more than
 
1,000
 
businesses were
 
able to
 
proceed
 
in contract
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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signing on
 
the
 
same
 
day they
 
visited the
 
branch
 
to apply.
 
Similarly,
 
it implemented
 
automated credit
 
decision in
revolving loan
 
renewal, aiming to boost solution scalability.
Business Analytics & Customer Value
 
Management
 
In 2024,
 
Eurobank
 
continued to
 
advance its
 
data-driven transformation
 
strategy,
 
leveraging
 
advanced analytics
 
and data
integration
 
to enhance
 
efficiency
 
and deliver
 
personalization
 
at
 
scale.
 
Through
 
its
 
Campaign
 
Management
 
platform,
 
the
Business Analytics and Customer Value Management team
 
executed over 30,000 actions and facilitated
 
47 million customer
interactions, optimizing communication
 
across both digital and physical
 
channels.
 
Eurobank’s
 
commitment to
 
data-driven
 
transformation
 
is exemplified
 
by the
 
successful
 
development
 
and deployment
 
of a
Comprehensive
 
Recommendation
 
Engine,
 
which
 
combines
 
machine
 
learning
 
algorithms
 
with
 
business
 
rules
 
to
 
effectively
prioritise
 
business
 
objectives.
 
This
 
initiative
 
resulted
 
in
 
2.1
 
million
 
customers
 
receiving
 
at
 
least
 
one
 
personalized
recommendation, covering
 
87% of the transactional
 
customer base.
 
Additionally,
 
Eurobank significantly
 
improved
 
its anti-money
 
laundering (AML) detection
 
processes through
 
the application
of diverse machine learning techniques, achieving
 
a 20-fold increase in accuracy. The
 
integration of AML data with advanced
visualization tools further streamlined case investigations, supported by GenAI-generated text to
 
assist agents
 
in articulating
the outcomes of ML-driven
 
analyses.
 
Eurobank also enhanced system
 
integration and automation
 
by successfully connecting its Campaign Management
 
System
with the mobile
 
app, enabling real-time
 
data flow and always-on campaigns.
 
Notably,
 
more than 60% of
 
digital sales were
driven by the Campaign
 
Management Ecosystem, reflecting the
 
impactful use of business analytics and AI.
 
These
 
achievements
 
underscore
 
Eurobank’s
 
dedication
 
to
 
driving
 
business
 
growth
 
and
 
operational
 
efficiency
 
through
advanced analytics, automation, and robust
 
data integration strategies.
 
External ESG awareness
Eurobank has taken measures
 
to assist stakeholders to assimilate ESG terminology,
 
opportunities and applicability. Building
ESG awareness
 
for
 
external stakeholders,
 
and particularly
 
for
 
clients, is
 
an integral
 
part of
 
Eurobank’s
 
Operational
 
Impact
Strategy.
 
Digital
 
Academy
 
for
 
Business
 
Eurobank
 
actively
 
supports
 
Greek
 
businesses
 
in
 
their
 
digital
 
and
 
sustainability
transition,
 
through
 
a groundbreaking
 
CSR initiative,
 
constituting a
 
catalyst for
 
business transformation
 
and success.
 
Since
2019,
 
the
 
Digital
 
Academy
 
has
 
been
 
offering
 
a
 
transformative
 
learning
 
experience,
 
tailored
 
to
 
the
 
evolving
 
needs
 
of
businesses in
 
the
 
digital age.
 
With
 
a deep
 
commitment
 
to fostering
 
digital literacy,
 
innovation
 
and entrepreneurship,
 
the
Academy stands as a beacon of excellence
 
in capacity building.
The scope
 
of these
 
actions is to
 
consistently deliver
 
exceptional service
 
and leveraging
 
digital innovations.
 
The timeline
 
for
completing these actions is ongoing, reflecting Eurobank's
 
commitment to adapting to and fostering innovation.
3.3.4
Metrics & Targets
Fostering Innovation
 
metrics [MDR-M]
The metrics are reflecting the performance of Eurobank, which is the Group’s key entity.
 
The primary metrics used to evaluate
performance and effectiveness
 
in relation to the e-Banking and Eurobank Mobile
 
App, as well as the Digital and hybrid sales
include:
2023
2024
Use of digital channels
Use of digital
 
channels-
 
% of mobile
 
users exclusively
 
using Mobile
App for their transactions
 
with the Bank on a monthly basis
78%
78%
Transactions
Volume
 
of digital transactions in respect to transactions (excluding
withdrawals/deposits) from
 
all Eurobank channels
95%
96%
Value
 
of digital
 
transactions
 
in respect
 
to transactions
 
(excluding
withdrawals/deposits) from
 
all Eurobank channels
54%
54%
Percentage change in volume
 
of digital transactions
15%
21%
Percentage change in value of digital transactions
12%
26%
Statements
e-Statements produced
 
(million)
4.7
5.3
Additional savings from e-Statement
 
use (€)
1,154,000
620,000
egg Start-Up
 
Platform
 
- The
 
initiative
 
is aimed
 
at start-ups
 
and business
 
teams with
 
innovative
 
business ideas
 
at various
stages of
 
development:
 
pre-seed,
 
seed and
 
early stage.
 
It provides
 
support for
 
their
 
business ventures
 
and helps
 
them
 
to
 
 
 
 
 
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develop
 
and bring their
 
product or
 
service to
 
market faster.
 
Once business
 
teams set
 
up the
 
company that
 
will implement
their business plan, they gain
 
access to specific financial tools to obtain financing based on their
 
needs.
 
egg Scale-Up platform
 
– It is addressed
 
to businesses with
 
significant growth
 
potential, which are
 
looking to increase
 
their
growth
 
and
 
reach
 
the
 
next
 
round
 
of
 
financing
 
through
 
their
 
accelerated
 
expansion.
 
The
 
egg
 
 
enter
 
grow
 
go
 
business
accelerator
 
has left its entrepreneurial and social mark:
 
1,500 entrepreneurs have been hosted in egg premises
450 business teams have been participated in egg Platforms
220 business teams have created legal entities
96 startups are spin-offs from Universities
 
in Greece and abroad
€49.2 million revenues
 
from 159 egg alumni startups
€55.2 million from private investment
 
funds (Equity funding - Funds/Business Angels) in 76 egg startups
€3.3 million financing from Eurobank
 
to 51 egg startups (Eurobank Financing Tool)
over €12 million Eurobank’s
 
investment in egg over
 
the past 12 years
360 recruitments (part time/full
 
time job)
61 companies have filed patents
83 companies have participated in 17 business trips to 10 innovative
 
ecosystems abroad (Europe,
 
USA, Canada,
Middle East) through egg extroversion
 
program
€75,000 from Eurobank
 
in cash prizes
€100,000 donated to charities
130 synergies among egg alumni
45 female CEOs in the egg startups
26.4% in egg community are women
Since 2020, egg has co-organised 52 events.
Since 2019,
 
egg has sponsored 32 initiatives.
Fostering innovation
 
targets [MDR-T]
Through the
 
Social impact pillar of the Sustainability Strategy,
 
the Group has set targets to enhance
 
accessibility initiatives
for
 
services
 
and products
 
targeted
 
to underserved
 
social groups
 
and raise
 
staff
 
awareness
 
and familiarity
 
on disabilities
through
 
experiential training by 2025.
 
3.4
Financial Inclusion [Entity-specific]
 
3.4.1
Strategy
Description of material impacts, risks and opportunities and their
 
interaction with strategy
 
and business model [SBM-3]
Eurobank
 
considers financial
 
inclusion as
 
a core
 
aspect of
 
its strategy
 
and business
 
model and
 
approaches
 
it in
 
a twofold
manner.
 
Offering financing products that specifically relate to infrastructure and supported services, aiming to assist businesses grow
and become updated, boost their competitiveness.
Making
 
its
 
services,
 
assets,
 
resources
 
and
 
opportunities
 
accessible
 
to
 
all.
 
This
 
means
 
continuous
 
investment
 
in
 
banking
services friendly towards persons with
 
disabilities, but above all, training and awareness
 
for all on accessible banking issues.
To
 
this
 
end,
 
through
 
its
 
network,
 
Eurobank
 
aims
 
to
 
maintain
 
its
 
presence
 
in
 
remote
 
and
 
inaccessible
 
areas,
 
serving
populations having difficulty to physically
 
access banking services.
The Group has identified social
 
impact financing, which
 
relates to activities such
 
as education, upskilling health care, financial
inclusion, social
 
cohesion
 
and gender
 
equality, as
 
a key
 
focus area.
 
The Group
 
understands that
 
social risk management
 
is
crucial to ensure an effective
 
and sustainable business model and has, therefore,
 
taken actions to adjust its business model,
strategy and
 
processes,
 
as well
 
as its financial planning
 
to account for
 
risks arising from
 
social matters,
 
planning to further
enhance such activities in the foreseeable
 
future. Key strategy
 
to manage those risks is the promotion
 
of financial inclusion.
Financial Inclusion
 
is a
 
strategic
 
business opportunity
 
in relation
 
to the
 
increase of
 
positive and
 
the
 
reduction
 
of negative
impacts has
 
identified and
 
have worked
 
on these
 
in the
 
reporting period
 
by constantly
 
identifying innovative
 
channels for
service delivery
 
and designing value-adding solutions, tailor-made to its customer
 
needs.
Regarding the Governance
 
-related information
 
please refer to :
1.3 Governance.
3.4.2
Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Through the
 
DMA Eurobank has identified the
 
following material
 
opportunity related to financial inclusion:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Opportunity
Contributing
 
to
 
financial
 
inclusion
 
aligns
 
with
 
social
 
impact
 
goals,
 
positively
 
impacting
 
brand
reputation
 
and
 
offering
 
financing
 
to
 
underserved
 
populations,
 
such
 
as
 
students
 
and
geographically isolated communities.
The process
 
of assessing financial inclusion applies across all regions
 
where Eurobank
 
operates.
3.4.3
Policies related to financial inclusion
 
Policies related to financial inclusion
 
[MDR-P]
The Group’s
 
Sustainability Policy
 
Framework
 
is the underlying
 
policy describing its
 
strategic
 
objective to
 
adapt its business
and operations in a way that:
Addresses climate change challenges
Accommodates social needs within its business model, and
 
Safeguards prudent governance for
 
the Group and its counterparties, in accordance with supervisory initiatives and
following international
 
standards/ best practices.
The Sustainability Policy Framework makes explicit reference to the significance of financial
 
inclusion and its
 
role in the overall
sustainability
 
strategy
 
which
 
includes
 
its
 
commitments
 
and
 
targets
 
of
 
the
 
societal
 
pillar
 
for
 
boosting
 
accessibility
 
and
inclusion of customers by 2025.
In addition, in relation to the promotion
 
social finance, the Group has established the
 
Sustainable Finance Framework
 
which
defines
 
the
 
financing
 
approaches,
 
activities
 
and
 
criteria
 
that
 
need
 
to
 
be
 
met
 
in
 
order
 
for
 
financings
 
to
 
be
 
classified
 
as
sustainable. Specifically
 
for the
 
social pillar,
 
the Framework
 
sets out the
 
following
 
eligible activities and
 
associated criteria
that need to be met for
 
financings to contribute financial / economic inclusion purposes:
Activity
 
Eligibility Criteria
Exclusions
Employment generation
 
& Access to
financing
Infrastructure & other
 
projects that generate
 
local
employment
Microfinance & SME financing
Loans to
businesses in
excluded sectors
Equitable access to and control over
 
assets,
services, resources,
 
and opportunities
Financing to vulnerable groups
 
Financing of publicly accessible assets, services, and
resources
For more information
 
regarding Policies
 
related to Financial Inclusion please refer
 
to: “3.2.2: Policies related to consumers
and end-users [S4-1]” and 2.5.4
 
Policies and Actions.
Actions related to financial inclusion
 
[MDR-A]
Supporting small businesses and social finance
Eurobank
 
promotes
 
financing
 
products
 
that
 
specifically
 
relate
 
to
 
infrastructure
 
and
 
supported
 
services,
 
aiming
 
to
 
assist
businesses grow
 
and become
 
updated, boost
 
their
 
competitiveness,
 
and improve
 
the
 
quality of
 
the
 
products
 
and services
they offer.
 
These processes
 
have been embedded into the Group’s
 
operating model and are performed
 
on an ongoing basis
in the context of continuous financial inclusion:
Financing under InvestEU
 
RRF _GR under
 
the Member
 
State compartment
 
of the
 
InvestEU programme
 
for Greece,
funded by
 
the Recovery
 
and Resilience
 
Facility (RRF)
 
and in
 
line with
 
the
 
Recovery
 
and Resilience
 
Plan for
 
Greece
which targets actions in three areas
 
:
1.
Strengthening Competitiveness
 
"RRF GR SME Competitiveness" –RBB only
2.
Developing Innovation
 
& Digitalization "RRF GR Innovation
 
& Digitalization" (Not yet available CBN
 
& RBB)
3.
Sustainability
 
"RRF
 
GR
 
Sustainability"
 
(Not
 
yet
 
available
 
CBN
 
&
 
RBB)
 
with
 
the
 
Guarantee
 
of
 
the
 
European
Investment Fund (EIF). The funding available under the new (sub)programmes
 
is targeted at SMEs, to cover their
working
 
capital
 
needs
 
and/or
 
to
 
implement
 
investment
 
projects,
 
aimed
 
at
 
improving
 
their
 
competitiveness
including research & innovation,
 
sustainability, digitalisation and digital upgrading
 
of their operations.
Financing under
 
SME
 
Competitiveness
 
which benefits
 
from
 
support from
 
the
 
European
 
Union
 
under
 
the
 
InvestEU
Fund.
 
(RBB
 
only).
 
Through
 
InvestEU
 
SME
 
Competitiveness
 
Guarantee
 
Programme,
 
with
 
the
 
guarantee
 
of
 
the
European
 
Investment
 
Fund (EIF),
 
eligible enterprises
 
can access
 
liquidity with
 
reduced
 
collateral
 
requirements
 
and
favourable
 
pricing conditions to
 
cover their
 
working capital
 
needs and/or to implement
 
investment projects
 
aimed
at improving their
 
competitiveness.
EIB Funding (FIs 88311/2017,
 
89424/2018, 90866/2019) (Re-employment of funds for
 
CBN).
Standard facility
 
of EIB
 
Loan for
 
SMEs and
 
MidCaps, which
 
focuses
 
(for
 
at least
 
1/3) on
 
the
 
financing of
 
Final Beneficiaries
which promote youth
 
employment, in the context of the
 
EIB’s Jobs for Youth
 
Initiative.
SMEs and Midcaps that are financed for
 
“Jobs for Youth”
 
have an additional 20bps transfer
 
of financial advantage.
 
 
 
 
 
 
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Criteria for Jobs for
 
Youth Initiative:
o
In the
 
last 6
 
months it
 
has employed
 
at least
 
one young
 
person (5
 
for
 
MidCaps), or
 
in the
 
coming 6
 
months it
plans to
 
employ at least
 
one young person (5
 
for MidCaps), calculated from the signature date
 
of the On-lending
Agreement; it commits to keep the
 
young people in employment for
 
at least 1 year
o
In the last 6 months it has provided
 
a vocational training
 
or internship position to at least one young person
 
(5
for
 
MidCaps), or
 
in the
 
coming 6
 
months it
 
plans to
 
provide
 
a vocational
 
training
 
or internship
 
position to
 
at
least one young person
 
(5 for
 
MidCaps), calculated from
 
the signature
 
date of the
 
On-lending Agreement.
 
The
training/internship
 
has a duration
 
of at least
 
3 months and
 
is formalised
 
by an active
 
cooperation
 
agreement
with a technical school, university or public employment agency and/or is confirmed by a letter signed by one of
these
 
institutions
 
and/or
 
is
 
part
 
of
 
the
 
Final
 
Beneficiary’s
 
own
 
formalised
 
vocational
 
training
 
or
 
internship
programme,
 
and/or
o
In
 
the
 
last
 
6
 
months
 
it
 
has
 
participated
 
in
 
a
 
youth
 
entrepreneurship
 
programme
 
of
 
a
 
Non-Governmental
Organisation or educational
 
institution, or plans to participate in such programme
 
in the coming 6 months.
HDB Programs
Co-Financed Programs
TEPIX III (Co-financing rate 40%-60% HDB/ERB)
The Fund improves the
 
access to finance for all small and medium-sized enterprises (SMEs) and aims to support
 
and
develop
 
their business
 
activity,
 
so as to
 
cover
 
a wide range
 
of their
 
financing needs.
 
Furthermore,
 
the programme
aims to
 
enhance
 
the
 
productivity
 
of the
 
enterprises,
 
by
 
improving
 
their
 
processes
 
for
 
products
 
& services
 
and to
improve their
 
competitiveness.
Micro Agri (Co-financing rate
 
50%-50% HDB/ERB).
The
 
Fund aims
 
to provide
 
micro loans
 
for
 
investment purposes,
 
covering
 
investments in
 
agricultural sector,
 
as well
as in
 
investments
 
related
 
to the
 
processing
 
of agricultural
 
products
 
with
 
a final
 
product
 
that
 
is also
 
agricultural.
Working Capital may be granted
 
subject to and for the purposes of investment.
Business Growth Fund (Co-financing rate
 
HDB/ERB 40%-60%).
Green Loans Program
The Fund
 
aims to support SMEs
 
to meet
 
their investment
 
purposes in implementing
 
Green Transition
 
projects that
facilitate reducing emissions,
 
protect the environment
 
and reduce energy
 
consumption costs.
Digital Loans Program
The Fund aims to support SMEs to meet their
 
investment purposes, which are submitted via a business plan, in
order to digitize and digital upgrade their
 
operations, so as to increase
 
productivity, achieve
 
business growth and
create new jobs.
Guarantee Programs
TEPIX III
This Fund
 
was designed
 
by the
 
HDB to support
 
SMEs by
 
offering
 
them not
 
only the
 
necessary liquidity
 
and capital
for investments but also the ability to
 
reduce their financing costs. The zero guarantee fee, grace period, and interest
subsidy
 
make
 
financing
 
more
 
accessible,
 
while
 
revolving
 
credit
 
facility
 
provides
 
the
 
flexibility
 
that
 
SMEs
 
need
 
to
respond to the constantly changing market needs. Additionally, the investment and special purpose working capital
loans enable SMEs to implement their strategic
 
investments, expand, and enhance their
 
competitiveness.
Tameio
 
Eggyodosias TMEDE
The Fund aims
 
to enhance the
 
liquidity of SMEs of the
 
construction and engineering
 
sectors that wish to undertake
or have undertaken
 
the execution
 
of projects and/or
 
studies of public interest,
 
regardless of the
 
stage of execution
of the project or study, through the provision
 
of guarantees to the cooperative Credit Institutions providing
 
Working
Capital
 
Loans,
 
with
 
a
 
regular
 
maturity,
 
with
 
a
 
disbursement.
 
(RBB
 
only). Active
 
program
 
in
 
1st
 
semester
 
of
 
2024,
expected to be reactivated again
o
Tameio
 
Eggyodosias Kainotomias
 
finance innovative
 
SMEs, for
 
the implementation
 
of investment
 
projects, with
the aim of research and innovation,
 
through the
 
creation and implementation
 
of a new or significantly improved
product or a process,
 
a new marketing method
 
or a new organisational
 
method in business practices,
 
workplace
organisation. (RBB only). Active
 
program in 1st semester
 
of 2024, expected to be reactivated again.
DeLFI GF
It applies to existing and newly established Very
 
Small, Small, and Medium-sized Enterprises (SMEs) that have been
classified under a support scheme through
 
the new Development
 
Law 4887/2022. (RBB & CBN)
 
In the area of financial inclusion, there
 
also the following
 
actions:
Moving Education
 
Forward
 
- Professional
 
MSc on
 
Digital Transformation
: we
 
are covering
 
all the
 
expenses of
 
a
new MSc at the Athens University
 
of Economics and Business, and in this way, we are helping up to 25 young people
to study with very low fees in a field of high demand and enter the job market successfully.
 
We have also committed
to be hiring 10 of them each year.
Moving
 
Education
 
Forward
 
-
 
mprostagiatinpaideia.gr
:
 
we
 
are
 
funding
 
development
 
and
 
operation
 
of
 
a
 
digital
platform for connecting students with
 
the job market, though training
 
for hard and soft skills, counseling, mentoring
and internships.
 
 
 
 
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Moving Family Forward
- As part of Eurobank’s program
 
for addressing the
 
demographic problem,
 
focusing on the
country’s eastern borders,
 
we have
 
moved 75 europhone
 
banking. positions to
 
Evros and
 
Northern Aegean
 
Islands,
creating opportunities for young
 
people to work from home and have
 
their families there.
Moving
 
Family Forward
 
- Free IVF
 
to underprivileged
 
young couples: We
 
are supporting young
 
families who need
to have
 
an IVF
 
treatment in
 
order to
 
have a
 
baby.
 
In this
 
way we
 
give them
 
access to medical
 
infrastructures
 
and
services that they
 
would not be able to use otherwise.
 
50 kids have been born so far in this way.
Reviving savings culture
 
- we are
 
collaborating with
 
the Hellenic
 
Financial Literacy Institute
 
in order to help
 
young
children understand the concept of savings, through two sub-projects: Awarding student assays on
 
the International
Savings Day
 
– 31
st
of October,
 
and training teachers
 
on savings and
 
other
 
financial literacy
 
topics in order
 
to pass
this knowledge to their young
 
students.
Making banking accessible
Focusing
 
on customer
 
service, Eurobank
 
aims to
 
make its
 
services,
 
assets, resources
 
and opportunities
 
accessible to
 
all. To
this end,
 
through its branch network (266
 
branches), the Hellenic Post Office network (469
 
offices) and the self-service banking
terminal
 
network
 
(1,627
 
service
 
points), Eurobank
 
aims to
 
maintain its
 
presence
 
in remote
 
and inaccessible
 
areas,
 
serving
populations having difficulty to physically access
 
services, as well as people with disabilities.
 
100% ATM with voice
 
guidance
and
 
117
 
ATM
 
(10%)
 
for
 
wheelchair
 
access.
 
Through
 
the
 
Hellenic
 
Post
 
branches,
 
Eurobank
 
is
 
present
 
in
 
238
 
Municipal
Communities with
 
a population
 
of less
 
than 5,000
 
people, many
 
of whom
 
have
 
difficulty
 
accessing
 
services,
 
especially on
remote islands (e.g. Agathonisi, Anafi, Karpathos,
 
Nisyros, Tilos, Halki, Folegandros,
 
Amorgos, etc.). Additionally, in 242 areas
with a
 
population
 
less than
 
5,000
 
people, access
 
to services
 
is provided
 
via off
 
-site ATMs
 
(e.g. Agios
 
Efstratios,
 
Alonissos,
Symi, etc.). In 2024, the
 
number of ATMs
 
with deposit facilities
 
increased by 206,
 
as OffSite ATMs
 
with deposits were
 
added
and the old ELTA
 
ATM fleet was replaced.
 
The 52% of the
 
ATM fleet has already deposit
 
functionality.
With customer
 
service being a key priority,
 
Eurobank is also particularly aware
 
of the need to make its services
 
accessible to
people with disabilities
 
and takes all
 
the appropriate
 
measures.
Specialized banking personnel
 
in the innovative
 
v-Banking
service
 
are
 
continuously
 
trained
 
in
 
sign
 
language
 
to
 
guide
 
deaf
 
and
 
hard-of-hearing
 
customers
 
step-by-step
 
via
 
video
communication.
 
E-banking is
 
now accessible
 
to people
 
with visual
 
impairments,
 
mobility issues,
 
epilepsy,
 
dyslexia, hearing
loss, and more,
 
through continuous
 
accessibility audits and
 
improvements
 
based on WCAG
 
level
 
AA. Specifically,
 
font sizes
for text,
 
images, etc., have
 
been adjusted, as
 
well as colors
 
and contrast
 
ratios
 
between text
 
and backgrounds
 
to meet the
minimum contrast
 
ratio
 
of the
 
4.5:1 rule.
 
Navigation can
 
be done
 
via the
 
keyboard,
 
and the
 
code is
 
properly
 
structured
 
to
work
 
with
 
any
 
assistive
 
technology.
 
The
 
content
 
structure
 
facilitates
 
navigation
 
for
 
users
 
using
 
assistive
 
navigation
technologies, such as the correct
 
order of headings, texts, and various components using appropriate
 
HTML tags.
 
In
 
addition,
 
Eurobank
 
is
 
creating
 
conditions
 
for
 
seamless
 
banking
 
services
 
for
 
individuals
 
on
 
the
 
autism
 
spectrum.
 
In
collaboration
 
with Happy
 
Act, the
 
Group is
 
mapping the
 
environments
 
of future
 
branches
 
to identify conditions
 
and areas
that
 
can
 
serve
 
as
 
sensory
 
relief
 
spaces.
 
Additionally,
 
sensory
 
maps
 
and
 
social
 
stories
 
are
 
being
 
developed
 
and
 
will
 
be
available on interaction tables and the website, allowing customers and their companions to understand the conditions they
will encounter at the branch
 
in advance.
Eurobank also
 
offers
 
clients the
 
option to be served
 
in English at branches
 
and through
 
EuroPhone Banking,
 
while English is
also available
 
as an
 
option
 
at ATMs.
 
EuroPhone
 
Banking, v-Banking,
 
e-Banking and
 
the
 
Eurobank
 
Mobile
 
App contribute
significantly
 
to
 
customers
 
having
 
access
 
to
 
services.
 
The
 
Group’s
 
new
 
“Going
 
from
 
physical
 
to
 
phygital”
 
approach,
 
an
innovative mentality that combines physical
 
service with technology,
 
introduces a new perspective
 
in the Bank’s relationship
with its customers. Furthermor
 
e, the Retail International Customers One-Stop Hub offers
 
continuous support to non-resident
customers. As
 
it is referenced
 
in more detail
 
at section
 
3.4 Fostering
 
Innovation, Eurobank
 
Group Digital
 
Banking leverages
its expertise
 
to provide
 
innovative,
 
data driven
 
financial products
 
and services.
 
Placing customers
 
at the
 
centre,
 
it delivers
simple, personalized
 
products and
 
ensures easy
 
access to them.
 
Bringing technology closer
 
to everyone,
 
it acts as
 
a digital
and phygital key enabler
 
and Eurobank’s main digital culture
 
ambassador.
Our actions
 
to make
 
Eurobank’s
 
services,
 
assets, resources
 
and opportunities
 
accessible to
 
all consumers,
 
are strategically
adapted and
 
deployed
 
across
 
subsidiaries in
 
Bulgaria, Cyprus,
 
and Luxembourg.
 
Example of
 
relative
 
initiatives
 
are
 
Touch
Credit
 
and
 
Debit
 
Cards
 
designed
 
to
 
make
 
payments
 
more
 
accessible
 
to
 
visually
 
impaired
 
customers,
 
ATM/Branch
accessibility
 
for
 
people with
 
disabilities, responsible
 
individual in
 
each branch
 
to assist
 
people with
 
disabilities, etc.
 
While
these
 
programs
 
are tailored
 
to address
 
the
 
specific local
 
contexts and
 
regulatory
 
environments,
 
they
 
remain aligned
 
with
Eurobank’s ove
 
rarching sustainability objectives.
 
Moreover,
 
in 2024, Eurobank tried to improve
 
customer service and productivity
 
by:
 
Scheduling appointments
 
at all
 
Eurobank
 
branches
 
– Over
 
1,114,000
 
appointments were
 
scheduled throughout
 
the
year. The online appointment booking option (through eurobank.gr) became available towards the end of July 2023.
Τhe total appointments during the
 
whole year 2024 was 32%.
 
Increasing
 
the
 
time
 
relationship
 
managers
 
allocate
 
to
 
each
 
client
 
 
To
 
achieve
 
this,
 
Eurobank
 
implemented
 
2
changes:
 
o
The Eurobank
 
call centre answers
 
incoming calls to all branches, allowing for
 
faster and more efficient
 
service.
 
o
Branch
 
staff
 
between
 
10:00
 
 
13:00
 
focus
 
on
 
advisory
 
services
 
and
 
customers
 
can
 
carry
 
out
 
monetary
transactions exclusively with the use of self-service transaction
 
terminals. This has been implemented in 264 out
of 266 branches.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Launching the project Mobility – This project
 
allows offsite banking, as part of the Group’s
 
consulting approach and
the further
 
development of
 
its services. 1,400
 
officers have
 
offsite access during
 
their visit to a
 
customer’s premises,
to provide end-to-end services
 
for a specific range of banking transactions/products.
 
Enhancing digital and
 
hybrid offering with the Digital Safe Box
 
– This allows customers to
 
get even complex products
remotely, signing all necessary paperwork
 
through their e-Banking, in line with Eurobank’s
 
“bank everywhere”
 
vision.
The
 
Digital
 
Safe
 
Box
 
accounts
 
for
 
10-15%
 
of
 
product
 
sales,
 
for
 
available
 
product
 
categories,
 
while
 
numbers
 
are
growing, and a wider product
 
range is expected to be covered.
 
Eurobank has
 
an exclusive cooperation
 
agreement with
 
Hellenic Post (ELTA)
 
that allows
 
Eurobank’s customers
 
to enjoy core
banking services
 
through the
 
Hellenic Post
 
branch network.
 
With more
 
than 465 branches
 
and 116 ATMs
 
across Greece,
 
the
Hellenic
 
Post
 
branch
 
network
 
provides
 
extensive
 
nationwide
 
service,
 
both
 
in
 
urban
 
and
 
in
 
remote
 
areas,
 
where
 
banking
presence is limited or non-existent.
In
 
addition.
 
Eurobank’s
 
Telemarketing
 
is
 
an
 
alternative
 
channel
 
which
 
promotes
 
products
 
and
 
services
 
to
 
existing
 
Group
customers. The promotions
 
and targeted customers are selected in collaboration with 3 segments (IB, PB, SB). Telemarketing
offers
 
direct,
 
personal
 
and 2-way
 
communication.
 
The
 
sales
 
are
 
completed
 
over
 
the
 
phone,
 
digitally or
 
at
 
the
 
customer’s
place of choice. The main promotional products
 
are credit and debit cards, and simple bancassurance products. Information
is provided directly over
 
the
 
telephone or through referral
 
to the branch network.
In 2024, Eurobank received
 
three awards at the Diversity,
 
Equity & Inclusion Awards 2024 organised by the Diversity
 
Charter.
The
 
Eurobank
 
was recognised
 
for
 
its features
 
and services
 
aimed
 
at improving
 
the
 
experience
 
of people
 
with disabilities,
achieving high scores in the categories
 
of "Bank Strategy" and "Innovation/Creativity".
Diversity, Equity & Inclusion
 
Awards 2024 by Diversity
 
Charter:
o
Gold Award in "Mental Health
 
& Neurodiversity"
 
for initiatives supporting individuals on the
 
autism spectrum.
o
Silver
 
Award
 
in
 
"Disabilities/Chronic
 
Diseases"
 
for
 
comprehensive
 
efforts
 
to
 
improve
 
services
 
for
 
people
 
with
disabilities.
o
Silver Award
 
in "Physical Abilities" for initiatives
 
aiding individuals with mobility challenges.
National Customer Service
 
Awards 2024:
o
Excellence
 
Award
 
in
 
"Best
 
Outsourcing
 
Partnership":
 
Recognized
 
for
 
collaboration
 
with
 
The
 
Happy
 
Act,
enhancing accessibility in next-generation
 
branches for
 
individuals on the autism spectrum.
o
Best
 
Organisation
 
for
 
ESG
 
Factors
 
&
 
Practices
 
in
 
Customer
 
Service:
 
Recognised
 
for
 
its
 
innovative
 
practices
across
 
service
 
channels,
 
recognised
 
for
 
the
 
inclusion
 
of
 
customers
 
with
 
disabilities
 
through
 
technology,
 
and
noted for its systematic approach
 
to measuring
 
and leveraging
 
ESG practices.
Additionally, Eurobank
 
received three
 
awards at DEI Bite awards 2024.
 
The
 
Group
 
was recognised
 
for
 
projects
 
Mobility
 
& online
 
customer
 
appointment.
 
Eurobank's
 
adopts
 
the
 
human-centered
Phygital
 
model,
 
combining
 
technological
 
infrastructure
 
with
 
the
 
human
 
factor
 
to
 
provide
 
simple,
 
fast,
 
and
 
personalized
service. The
 
term Phygital is derived
 
from the combination
 
of physical and digital experiences and interactions.
Μοbility
o
Gold award in Digital Transformation
 
of Customer Experience
o
Silver award in Digital Transformation
 
of Business Model
Online Customer Appointment
 
o
Bronze award in Digital Transformation
 
of Business Model
3.4.4
Metrics & Targets
Financial inclusion metrics [MDR-M]
Supporting small businesses and social finance
With respect to SME support and social finance, Eurobank, which is the Group’s key entity, measures
 
its performance through
the financing amounts directed to through
 
relevant programs:
Outstanding balance as of
31.12.2024 (€ mn)
Disbursed amounts in 2024
(€ mn)
EIF – ESIF ERDF
20.7
-
Financing under the European
 
Commission’s EaSI
1.8
-
Hellenic Development Bank (HDB) TEPIX III
125.8
169.6
Business Growth Fund
13.4
1.4
EAT Micro
 
AGRI
0.8
0.5
Tamio
 
Eggiodosias EAT TMEDE
1.3
0.4
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Tamio
 
Eggiodosias Kenotomias
1.5
0.3
Mortgage Loans for Multichild families
 
in remote areas
0.8
0.8
“My Home”
44.3
31
Total
210.5
204
Making banking accessible
Through the
 
Hellenic Post branches,
 
Eurobank is present
 
in 238 Municipal Communities
 
with a population of
 
less than 5,000
people,
 
many
 
of
 
whom
 
have
 
difficulty
 
accessing
 
services,
 
especially
 
on
 
remote
 
islands
 
(e.g.
 
Agathonisi,
 
Anafi,
 
Karpathos,
Nisyros, Tilos,
 
Halki, Folegandros,
 
Amorgos, etc.). Additionally,
 
in 242 areas with a
 
population less than 5,000
 
people, access
to services is provided via off
 
-site ATMs (e.g. Agios Efstratios,
 
Alonissos, Symi etc.)
The following
 
metrics and actions demonstrate
 
Eurobank’s efforts
 
to serve people with disabilities:
100% ATM with voice
 
guidance and 117 ATM (10%) for
 
wheelchair access
Customers
 
with disabilities
 
receive
 
priority service
 
at all
 
branches,
 
where
 
appropriate
 
signage and
 
Braille
 
writing
are
 
provided
 
at
 
the
 
entrance,
 
and
 
managers
 
use
 
QR
 
codes
 
via
 
Nemo
 
Q
 
machines
 
to
 
ensure
 
maximum
 
priority.
Additionally,
 
priority
 
service
 
is
 
provided
 
through
 
Europhone
 
Banking,
 
where
 
keywords
 
such
 
as
 
"disability"
 
are
recognised
 
by the
 
voice
 
portal and
 
routed
 
to a
 
dedicated skill
 
set serviced
 
by specially
 
trained
 
agents, based
 
on
customer declaration.
92 branches
 
have access
 
ramps for
 
customers
 
with reduced
 
mobility,
 
all new
 
branches
 
feature
 
permanent ramps,
and 7 branches have detachable
 
ramps, with plans to expand to more branches
 
by 2025.
All transaction
 
documents are
 
emailed in a
 
format readable
 
by assistive
 
technologies, allowing
 
people with visual
impairments to read them immediately,
 
easily, and safely.
More
 
than
 
1117
 
ATMs
 
and
 
441
 
APS
 
are
 
installed
 
at
 
a
 
lower
 
height
 
to
 
serve
 
customers
 
in
 
wheelchairs
 
at
 
selected
branches, as detailed in the
 
Br./ATM
 
locator on Eurobank.gr.
 
People with visual impairment can receive
 
documents in Braille and statements in pdf that can
 
be read by assistive
technologies.
 
Eurobank’s innovative
 
v-Banking service
 
includes specialized banking
 
personnel trained
 
in sign language,
 
enabling
deaf
 
and
 
hard-of-hearing
 
customers
 
to
 
receive
 
comprehensive
 
assistance
 
through
 
video
 
communication.
 
This
service allows them to update their
 
information via e-banking without visiting a branch
 
and consult with experts on
complex issues, ensuring full access to banking services
 
from the comfort
 
of their home.
More than 1186 ATMs are equipped with voice guidance that gives instructions in private on how clients can perform
their transactions.
 
Continuous accessibility audits drive in improvements
 
based on WSAG 2.1
 
level AA in digital channels.
 
The website features
 
dedicated pages that provide
 
information on multiple service
 
options tailored to each type of
disability, and it offers
 
people with disabilities the
 
opportunity to communicate
 
their suggestions
 
to the bank
 
via a
special contact form.
Eurobank enhances awareness through educational programs attended by 1,827 employees, including online
 
courses
and experiential training, as well
 
as inspirational events involving
 
approximately 2,500 employees.
11 staff members have
 
participated in training on sign language.
Financial inclusion targets [MDR-T]
Through the
 
Societal impact pillar of the sustainability strategy,
 
and specifically, the
 
commitment to boost accessibility and
inclusion
 
for
 
customers
 
by
 
2025,
 
the
 
Group
 
has
 
set
 
targets
 
to
 
enhance
 
accessibility
 
initiatives
 
for
 
services
 
and
 
products
targeted
 
to underserved social groups and raise
 
staff awareness and familiarity on disabilities through experiential
 
training.
 
In
 
2025,
 
with
 
the
 
integration
 
of the
 
digital disability
 
card
 
into the
 
Bank's systems,
 
customers
 
with
 
disabilities
 
receive
 
the
highest
 
priority
 
in service
 
at
 
all branches.
 
Customers
 
with
 
disabilities are
 
able to
 
use their
 
debit or
 
credit
 
card
 
to receive
expedited
 
service
 
through
 
the
 
Nemo
 
Q
 
system,
 
provided
 
they
 
have
 
submitted
 
their
 
digital
 
disability
 
card.
 
Additionally,
Eurobank offers
 
exclusive benefits and discounts with
 
the Digital Disability Card.
 
These include the
 
Eurobank My Advantage
Blue privilege package, which is available free of charge for
 
2025 and 2026, and a preferential
 
interest rate of 1.85% for
 
one
year
 
on the
 
"Αποταμιεύω"
 
savings account
 
for
 
amounts up
 
to 5,000
 
euros,
 
compared to
 
the
 
current
 
interest
 
rate
 
of 0.30%.
These
 
initiatives are
 
part of
 
Eurobank's
 
broader
 
financial inclusion
 
targets, aiming
 
to provide
 
equitable access
 
to financial
services and benefits.
 
 
 
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4.
Governance Information
4.1
Business conduct [ESRS G1]
4.1.1
 
Governance
 
The role
 
of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
The
 
CEO has
 
administrative
 
oversight
 
of Board
 
of Directors,
 
through
 
the
 
Audit Committee,
 
which is
 
provided
 
with reports
from the
 
independent function of
 
Group Compliance.
 
Eurobank addressed
 
the role
 
of the administrative,
 
management and
supervisory
 
bodies
 
related
 
to
 
business
 
conduct
 
through
 
a
 
range
 
of
 
Board
 
Committees
 
that
 
support
 
Eurobank’s
 
strategy,
governance and regulatory
 
adherence:
Audit Committee
The
 
primary function
 
of the
 
Eurobank
 
Holdings and
 
Eurobank
 
Audit Committees
 
(ACs) is
 
to assist the
 
Board in
 
discharging
its oversight responsibilities primarily
 
relating to the:
Review
 
of the
 
adequacy of
 
the
 
Internal
 
Control
 
and Risk
 
Management
 
systems, and
 
compliance
 
with rules
 
and
regulations monitoring process.
Review of the financial reporting process
 
and satisfaction as to the
 
integrity of the Financial Statements.
External Auditor selection, performance
 
and independence.
Effectiveness and
 
performance
 
of the Internal Audit and of the Compliance
 
function.
In line with
 
the stipulation
 
of the
 
Law 5164 (Article
 
43), Audit Committee (AC)
 
has been entrusted
 
with additional
responsibilities concerning the
 
submission and assurance of the
 
Sustainability Statement
Board Risk Committee
The Eurobank
 
Holdings and Eurobank Board
 
Risk Committees (BRCs) assists the Board in risk issues and ensures
 
that:
The
 
monitoring of
 
the
 
overall
 
actual and
 
future
 
risk appetite
 
and strategy,
 
takes into
 
account all
 
types of
 
risks to
ensure that they
 
are in line with the business strategy,
 
objectives, corporate
 
culture and values of the institution.
The
 
risk management
 
framework
 
is appropriate
 
and integrated
 
in the
 
decision-making
 
process.
 
The
 
Committees
also define the risk management principles.
There
 
are suitable
 
methods,
 
tools, models
 
and data
 
sources
 
in place,
 
as well
 
as qualified
 
and competent
 
staff
 
to
identify, assess, monitor and mitigate risks.
A
 
range
 
of
committees
established
 
by
 
the
 
CEO
and
 
functions
 
support
 
Eurobank's
 
strategy,
 
governance,
 
and
 
regulatory
adherence.
 
Among these, key committees and functions
 
with roles in overseeing
 
business conduct include:
Executive
 
Board
: Manages
 
the
 
implementation
 
of the
 
group's
 
strategy
 
and
 
aligns operational
 
goals
 
with
 
Board
guidance, ensuring actions are conducted ethically
 
and transparently.
Ethics
 
Committee
:
 
Ensures
 
compliance
 
with
 
the
 
Code
 
of
 
Conduct
 
and
 
Ethics,
 
promoting
 
a
 
code
 
of
 
values
 
for
employees, officers,
 
and collaborators.
Regulatory
 
Matters
 
Committee
:
 
The
 
purpose
 
of
 
the
 
Regulatory
 
Matters
 
Committee
 
(RMC)
 
is
 
to uphold
 
ethical
practices and ensure the highest
 
standards of conduct by coordinating the actions required
 
to improve the Group’s
compliance
 
with
 
existing
 
or
 
new
 
regulatory
 
requirements.
 
In
 
this
 
context,
 
the
 
Committee actively
 
monitors
 
and
oversees projects
 
to address the impact of new regulatory
 
requirements as well
 
as control improvements
 
identified
by the Group’s
 
control functions, external
 
auditors, and regulators.
Group Compliance
: Plays
 
a critical
 
role
 
in upholding
 
regulatory compliance
 
and ethical
 
conduct standards
 
across
Eurobank’s
 
operations
 
by
 
ensuring
 
adherence
 
to
 
corporate
 
governance
 
standards
 
and
 
training
 
Eurobank’s
employees in the Code
 
of Conduct and Ethics.
Group
 
Internal
 
Audit
 
(Group
 
IA)
:
 
Independently
 
reviews
 
the
 
adequacy
 
and
 
effectiveness
 
of
 
the
 
internal
 
control
framework
 
in place regarding Sustainability risk related
 
areas.
Committee against
 
Violence
 
and Harassment
 
in Workplace:
The
 
main objective
 
of the
 
Committee is
 
to examine
and manage complaints
 
/ reports
 
concerning incidents
 
of violence
 
and harassment
 
at work,
 
as well
 
as to take
 
the
necessary, appropriate
 
and suitable measures on a case-by-case basis, to prevent and not reoccur
 
similar incidents
or behaviors.
The
 
expertise of
 
the
 
administrative,
 
management and
 
supervisory
 
bodies on
 
business conduct
 
matters
 
is ensured
 
through
Directors’ Induction
 
and Continuous
 
Professional
 
Development
 
Process.
 
All new
 
Board members
 
undergo a
 
comprehensive
Induction Program
 
designed to achieve several
 
key objectives.
 
Firstly, it aims to convey the
 
vision and culture of the HoldCo/Group.
 
Secondly, it covers
 
practical procedural
 
duties to ensure a smooth transition into
 
their roles.
 
Thirdly,
 
it
 
aims
 
to
 
expedite
 
their
 
productivity
 
by
 
reducing
 
the
 
time
 
needed
 
to
 
familiarize
 
themselves
 
with
 
their
responsibilities.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Fourthly,
 
it integrates them as valued members
 
of the Board.
 
Fifthly, it familiarizes
 
them with the HoldCo/Group's
 
organisational structure.
 
Lastly, it provides
 
an understanding of
 
the HoldCo/Group's
 
business, strategy,
 
market dynamics, relationships,
 
and
its people.
 
4.1.2 Impact, risk and opportunity
 
management
Description of the processes
 
to identify and assess material impacts, risks and opportunities [ESRS 2 IRO-1]
Eurobank identifies
 
material impacts, risks,
 
and opportunities related
 
to Governance
 
and Business Conduct practices
 
—such
as corporate
 
culture,
 
anti-corruption
 
and anti-bribery
 
measures,
 
and whistleblower
 
protection—through
 
a comprehensive
DMA.
 
This
 
approach
 
integrates
 
industry
 
benchmarks,
 
stakeholder
 
insights,
 
and
 
financial
 
relevance
 
to
 
ensure
 
a
 
robust
evaluation of governance
 
-related topics.
The material impacts
 
identified through our DMA exercise
 
are shown in the table below:
Corporate culture
Impact
Positive
Actual
Implementing operational
 
practices and initiatives
 
that improve
 
stakeholders’ ability
to benefit from effective,
 
accountable, and inclusive institutions, thereby
 
promoting
business ethics and integrity.
Corruption and bribery
Impact
Positive
Actual
Commitment to corporate integrity is strengthened
 
through the
 
implementation of
robust anti-corruption
 
and anti-bribery policies, promoting
 
a culture of transparency
and ethical behaviour.
 
Negative
Potential
Corruption-related
 
incidents can result in operational
 
disruptions, redirecting
resources towards
 
crisis management and adversely affecting
 
Eurobank’s day-today
business activities.
Protection of whistleblowers
Impact
Positive
Actual
Commitment to whistleblower
 
protection positively
 
impacts society, employees,
customers, and shareholders,
 
setting a precedent for ethical
 
behaviour and fostering
a secure environment where
 
misconduct is timely identified and stopped.
The
 
process
 
of assessing
 
governance
 
and business
 
conduct practices
 
applies across
 
all regions
 
where
 
Eurobank
 
operates,
and concerns staff
 
members, customers,
 
contractors, suppliers,
 
beneficiaries or other
 
persons or entities that
 
participate or
seek to participate in activities that involve
 
Eurobank.
 
As mentioned in Reporting of Illegal
 
or Unethical Conduct Policy Statement, all staff members and all concerned third parties
are encouraged to submit a report
 
regarding any incident of actual, attempted or reasonably
 
suspected illegal or unethical
behaviour which
 
affects
 
and/or may
 
be harmful
 
to Eurobank
 
and its
 
mission, Eurobank’s
 
staff members
 
or concerned
 
third
parties. This
 
process
 
may, indicatively
 
and not exhaustively,
 
refer
 
to incidents of
 
serious
 
misconduct or serious
 
violations
 
of
Eurobank’s
 
procedures,
 
policies,
 
guidelines
 
or
 
of
 
the
 
Code
 
of
 
Conduct
 
and
 
Ethics
 
or
 
anything
 
that
 
could
 
damage
 
the
reputation of Eurobank,
 
as well as any attempt to cover
 
up the above. It may also include violations
 
of laws and regulations
and various
 
forms of
 
criminal behaviour,
 
integrity violations
 
and/or unethical
 
behaviour including,
 
but not
 
limited to,
 
theft,
embezzlement, corruption, bribery, conflicts of interest, money laundering, abuse or improper use of
 
inside information, abuse
or improper use of Eurobank
 
property,
 
etc.
 
Group Compliance is responsible for the design, implementation, operation and improvement of the reporting system as well
as for the reporting
 
on the performance
 
of the reporting system to top management.
Business conduct policies and corporate
 
culture [G1-1]
In relation to Eurobank’s
 
policies on business conduct matters, in order
 
to develop, promote
 
and evaluate corporate culture,
Eurobank established
 
mechanisms for
 
identifying, reporting and investigating
 
concerns about behaviour
 
in contradiction of
Code of Conduct &
 
Ethics. Specifically, a series of measures and controls are established that include carrying out monitoring
exercises, using systems,
 
providing appropriate training to employees and
 
having an
 
appropriate body in place
 
which reviews
cases
 
relating
 
to the
 
Code by
 
control
 
and monitoring
 
while
 
also accommodating
 
reporting
 
from
 
internal
 
and/or external
stakeholders.
 
Group Compliance
 
is responsible for
 
reviewing and
 
revising relevant
 
policies regarding
 
the Business
 
Conduct.
Eurobank prioritises the interests of its key stakeholders, including customers, employees, investors, and the community, when
setting
 
policies.
 
The
 
Board
 
of
 
Directors
 
regularly
 
reviews
 
the
 
Group’s
 
operations
 
to
 
ensure
 
they
 
meet
 
stakeholder
expectations and
 
regulatory requirements.
 
Based on
 
their assessments,
 
the Board
 
approves
 
any necessary
 
policy changes
to align Eurobank's practices
 
with stakeholder needs
 
and values.
Eurobank
 
has
 
developed
 
policies
 
on
 
Anti-bribery
 
and
 
Corruption
 
consistent
 
with
 
the
 
United
 
Nations
 
Convention
 
against
corruption
 
and
 
protects
 
whistleblowers
 
through
 
internal
 
reporting
 
channels
 
such
 
as
 
Whistleblowing
 
Mechanism.
 
All
 
staff
 
 
 
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members are encouraged to raise issues of concern and speak up when they suspect potential wrongdoing or are faced with
conduct or situations that may raise
 
ethical, legal or regulatory concerns.
A Policy for Reporting Illegal or
 
Unethical Conduct is in
 
place and a
 
respective Policy Statement to facilitate its staff members
and
 
concerned
 
third
 
parties
 
to
 
submit
 
reports
 
 
through
 
recommended
 
internal
 
or
 
external
 
reporting
 
channels
 
 
on
 
any
actual, attempted or suspected fraud or other
 
unethical conduct, while eliminating any concerns that
 
their report may result
in adverse consequences for
 
themselves.
 
Eurobank
 
implemented
 
the
 
following
 
measures
 
to
 
protect
 
against
 
retaliation
 
on
 
employees
 
who
 
are
 
whistleblowers
 
in
accordance with the
 
applicable law transposing Directive
 
(EU) 2019/1937 of the European Parliament
 
and of the Council:
Zero
 
Tolerance
:
 
Eurobank
 
applies
 
a
 
strict
 
zero-tolerance
 
approach
 
to
 
any
 
instances
 
of
 
retaliation
 
against
whistleblowers,
 
ensuring
 
protection
 
for
 
those
 
reporting
 
fraud,
 
corruption,
 
money
 
laundering,
 
or any
 
conduct
 
that
could damage Eurobank’s reputation.
Confidentiality
 
Assurance
:
 
Eurobank
 
is
 
committed
 
to
 
maintaining
 
confidentiality
 
of
 
whistleblowers’
 
identities.
Reports
 
submitted
 
by
 
employees,
 
or
 
third
 
parties
 
are
 
kept
 
confidential,
 
as
 
long
 
as
 
the
 
information
 
provided
 
is
accurate and submitted in good faith.
Safe Reporting Environment
: Unit heads are required to foster a workplace
 
atmosphere where
 
employees feel safe
to report
 
issues. This
 
includes
 
encouraging
 
open
 
communication
 
and
 
ensuring
 
staff
 
feel
 
free
 
to express
 
concerns
without fear of adverse
 
consequences.
ISO certifications
: Surveillance for ISO certification
 
(37002) on the management of the Whistleblowing
 
System and
new ISO certification
 
(37001) on Anti-Bribery and Corruption
 
Management Systems.
Accessible Reporting Channels
: Eurobank provides
 
multiple reporting channels to report misconduct:
o
Email: Reports can be submitted to the dedicated email
 
address, ethicshotline@eurobank.gr.
o
Phone Hotline: A 24/7 phone line (+30 214 4058990) is available for
 
reporting concerns at any time.
o
Postal Mail: Reports
 
can also be
 
sent by mail
 
to the
 
Report Receiving and
 
Monitoring Officer
 
(RRMO) and the
Assistant RRMO.
Encouragement
 
to
 
Speak
 
Up
:
 
The
 
policy
 
actively
 
encourages
 
all
 
staff
 
to
 
voice
 
concerns
 
and
 
report
 
suspected
wrongdoing, particularly if they
 
encounter conduct that raises ethical,
 
legal, or regulatory questions.
Centralized Reporting
 
and Monitoring
: All reports,
 
regardless of the
 
internal party that
 
initially receives
 
them, are
forwarded
 
to the
 
Report Receiving
 
and Monitoring
 
Officer
 
(RRMO), and
 
the
 
Assistant RRMO,
 
ensuring consistent
handling and monitoring of reported issues.
Beyond the procedures to follow-up on reports by whistleblowers in
 
accordance with the applicable law
 
transposing Directive
(EU) 2019/1937, Eurobank investigates procedures
 
on business conduct
 
incidents, including incidents
 
of corruption and bribery,
promptly, independently and
 
objectively.
 
For more information,
 
refer to [G1-3].
In 2023,
 
a new
 
digital learning programme
 
on the
 
Code of Conduct
 
and Ethics
 
was carried
 
out
 
to all staff,
 
which included
corruption
 
and bribery
 
issues as
 
well,
 
that continued
 
in 2024
 
for
 
all the
 
newcomers
 
employees,
 
aiming to
 
raise
 
awareness
and cultivate
 
a strong
 
culture
 
of values
 
and integrity.
 
Additionally,
 
in 2024
 
the
 
updated
 
Code of
 
Conduct and
 
Ethics
 
was
distributed to all staff to raise awareness
 
and educate the employees.
Eurobank confirms that
 
is subject to legal requirements under
 
national law transposing Directive
 
(EU) 2019/1937 with regard
to the protection
 
of whistle-blowers.
 
Eurobank has in place the
 
following policies
 
with regard to business conduct:
Code of Conduct and Ethics
 
Anti-Bribery and Corruption Policy
 
Conflicts of Interest Policy
 
Policy for
 
Reporting Illegal or Unethical Conduct
 
Group Antitrust Compliance Policy
External Engagement Policy
Insider Dealing Guideline
Management of Complaints policy
Personal Data Protection
 
Policy
Eurobank’s
 
mission is
 
to promote
 
a sustainable
 
compliance
 
culture that
 
encourages
 
integrity through
 
ethical
 
conduct and
commitment
 
to
 
compliance
 
with
 
the
 
applicable
 
regulatory
 
framework
 
and
 
the
 
international
 
corporate
 
governance
standards.
Key actions taken to establish, develop
 
and promote corporate
 
culture include:
Expanding the
 
Compliance Risk Assessment
 
Framework,
 
including coordination
 
of the
 
Compliance risk assessment
activities in the areas of corporate
 
governance and data protection.
Introducing a Regtech solution for
 
regulatory analysis and preliminary impact assessment.
Further calibrating
 
the AML risk assessment process
 
and enhancing the AML transaction
 
monitoring system.
 
 
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Launching an
 
automated
 
ML/TF risk
 
assessment
 
mechanism
 
for
 
financial institutions/banks,
 
as well
 
as additional
scenarios in the correspondent
 
banking transaction monitoring system.
Developing scorecards
 
for financial institutions, and a monthly Power
 
BI activity report for correspondent
 
banking.
Offering continued support and monitoring the
 
implementation of the AML e2e
 
projects in Bulgaria and Cyprus.
Implementing further
 
actions to increase the effectiveness
 
of MiFID controls.
Participating
 
in an advisory
 
capacity in
 
a bank-wide
 
project for
 
advisory products
 
and services,
 
and in bank-wide
projects relating to bancassurance
 
business, deposit products and payment services.
Obtaining ISO surveillance (37002) on the
 
management of the Whistleblowing System.
Obtaining ISO certification (37001)
 
on the management of Anti-Bribery and Corruption
 
System.
Further
 
revising
 
the
 
Policy
 
for
 
Reporting
 
Illegal
 
or
 
Unethical
 
Conduct
 
and
 
appointing of
 
a
 
Report
 
Receiving
 
and
Monitoring Officer
 
responsible for
 
receiving and
 
monitoring of reports
 
received
 
through the
 
reporting channels
 
for
illegal or unethical conduct.
Revising the Code of Conduct and Ethics
 
Developing a compliance control
 
catalogue.
Continuing initiatives
 
for
 
developing
 
data
 
analytics capabilities
 
within
 
Group
 
Compliance
 
and granularity
 
of the
Compliance Risk Appetite Framework.
Finalising the GC skillset mapping and identifying development initiatives vis-à-vis the GC Target Operating
 
model.
Successfully completing digital learning
 
programmes – such as specialist
 
AML workshops by business
 
line, and digital
learning on Code of Conduct and Ethics – and completing of establishment of a dedicated space within Eurobank’s
intranet as part of the
 
awareness initiatives.
During 2024, the following
 
actions set by Group Compliance
 
were successfully
 
completed:
Maintaining the percentage of at least 65% of the Group Compliance staff members holding certifications
 
on issues
regarding money laundering and terrorist
 
financing, compliance, operational
 
risk and related topics.
Providing training
 
on the
 
Code of Conduct
 
and Ethics and
 
its complementary
 
policies to
 
at least 95%
 
of Eurobank
employees and executives.
Conducting training
 
sessions on consumer
 
protection
 
issues, payments
 
and consumer
 
credit, as part
 
of Eurobank’s
consumer protection
 
actions.
 
Updating the
 
Code of
 
Conduct and
 
Ethics,
 
the
 
Conflicts of
 
Interest
 
Policy,
 
the
 
Group
 
Antitrust Compliance
 
Policy
and public statements (Anti-bribery Corruption and Policy, External Engagement Policy,
 
Illegal or Unethical Conduct
Policy)
Providing training on antitrust
 
issues to relevant personnel.
 
Providing training on Consumer Protection
 
issues, aiming to raise awareness and cultivate a strong culture of
 
values
within the Group.
Training Conflict of Interest
 
to all staff.
Training Insider
 
Dealing Guideline - Market Abuse to all staff.
Introducing
 
Supplier Code
 
of Conduct
 
and Ethics
 
inviting the
 
Eurobank’s
 
Suppliers to
 
accept the
 
content and
 
terms of
 
the
Code. Code of
 
Conduct establishes clear
 
principles and
 
rules that must
 
be followed to ensure that the Eurobank’s partnerships
are built upon fundamental values such as integrity,
 
transparency,
 
and responsibility.
 
Regarding
 
2025,
 
Group
 
Compliance
 
intends
 
to
 
continue
 
maintaining
 
the
 
percentage
 
of
 
at
 
least
 
65%
 
of
 
the
 
Group
Compliance staff members
 
holding professional
 
certifications on issues
 
regarding money laundering
 
and terrorist financing,
compliance, operational
 
risk and
 
related
 
topics. Eurobank
 
can measure
 
this target
 
by tracking
 
the
 
percentage
 
of certified
staff
 
on
 
a
 
regular
 
basis.
 
By
 
achieving
 
this
 
target,
 
Eurobank
 
will
 
enhance
 
the
 
team's
 
expertise
 
and
 
improve
 
the
 
overall
compliance framework within the organisation.
 
Progress will be assessed regularly, with a final
 
evaluation at the end of 2025.
 
In addition, in order to track the effectiveness
 
of policies and actions in relation to the Business Conduct material matter,
 
the
following qualitative
 
indicators are used:
Provide
 
dedicated
 
training
 
courses
 
to
 
Eurobank’s
 
staff
 
on
 
Compliance-related
 
topics,
 
and
 
specific
 
training
 
on
consumer protection
 
issues, through e-learning solutions.
Assess the impact of the New
 
AML Package and design an action plan.
Implement a compliance risk assessment tool.
Have an external consultant independently assess the compliance
 
Risk Assessment (CRA) Methodology.
Expand the CRA perimeter to cover areas outside GC mandate, such as prudential regulations, information security,
outsourcing and sustainability framework.
Develop dedicated methodologies
 
for CFT and Sanctions Risk Assessments.
Update
 
the
 
existing
 
AML
 
Business
 
Risk
 
Assessment,
 
to
 
ensure
 
alignment
 
with
 
developments
 
and
 
regulatory
expectations.
 
 
 
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Review
 
end-to-end
 
the
 
Trade
 
Finance
 
Control
 
Framework
 
and
 
create
 
an
 
action
 
plan
 
for
 
further
 
enhancing
Eurobank’s controls
 
in Trade.
Use
 
AML
 
Analytics
 
for
 
achieving
 
efficiencies
 
(among
 
other
 
risk
 
mitigation
 
benefits)
 
as
 
well
 
as
 
infrastructure
improvements
 
in AML/CFT operations.
Continue the ongoing monitoring of Russian sanctions.
Obtain ISO certification
 
for AML Operations,
 
Anti-Bribery and Corruption and Compliance
 
Processes.
Implement the FATCA/CRS
 
Action Plan.
Continue the implementation
 
of further actions to increase
 
the effectiveness
 
of MiFID controls.
 
Provide advice and monitor Eurobank’s
 
compliance with the regulatory
 
framework.
 
Continue participating
 
in an
 
advisory capacity
 
in bank-wide
 
projects
 
relating to
 
bancassurance
 
business, deposit
products and payment services.
Support Eurobank’s
 
readiness initiatives
 
for
 
compliance with
 
upcoming regulations,
 
such as
 
the
 
Retail Investment
Strategy,
 
Consumer and Mortgage Credit Directives,
 
Payment Services Directive
 
III.
Update public statements.
Completed a
 
new digital learning
 
programme addressed to all staff
 
on conflicts
 
of interest and
 
a new digital
 
learning
programme
 
addressed to targeted staff on market
 
abuse.
Review all compliance policies at least once
 
per year as per AC guideline
The
 
scope
 
of
 
the
 
respective
 
key
 
actions
 
taken
 
and
 
successfully
 
achieved,
 
as
 
well
 
as
 
Eurobank
 
‘s
 
targets,
 
includes
 
all
 
the
activities across all regions that
 
Eurobank operates,
 
throughout the
 
value chain.
Prevention and detection
 
of corruption and bribery [G1-3]
The
 
Group
 
has implemented
 
the
 
following
 
procedures
 
aimed
 
at preventing,
 
detecting, and
 
addressing
 
any allegations
 
or
incidents of
 
corruption
 
and bribery
 
which are
 
outlined in
 
Anti-Bribery &
 
Corruption
 
Policy
 
Statement.
 
Group’s
 
policies are
developed to be consistent with the
 
United Nations Convention’s
 
principles against corruption.
 
Specifically, the
 
Group:
Has zero tolerance
 
to bribery and corruption.
Establishes and follows
 
effective
 
control procedures
 
to prevent or identify bribery and corruption.
Ensures the implementation
 
of a control program.
Evaluates suppliers in order
 
to mitigate the risk of
 
bribery and corruption.
 
The Supplier Code
 
of Conduct and Ethics
applies to
 
all Eurobank suppliers and
 
is a
 
guide to
 
clear principles and
 
rules to be
 
followed. (Supplier Code of Conduct
and Ethics) Includes anti-bribery terms are
 
also included in contractual documents.
Provides
 
efficient, confidential
 
reporting mechanisms
 
to staff
 
and encourages
 
their use
 
by providing
 
protection
 
to
individuals who report in good faith. Staff
 
are encouraged to report
 
bribery attempts by third parties.
Establishes mechanisms for
 
monitoring incidents of bribery.
Assists competent authorities in conducting investigations.
Adopts regular
 
risk assessment
 
mechanisms
 
of the
 
Group's
 
structures
 
and operations,
 
which it
 
oversees,
 
reviews,
adapts and revises.
In the context of the ongoing risk assessment,
 
a record of bribery complaints and/or incidents is maintained.
Records in
 
a formal
 
questionnaire the
 
minimum requirements
 
of Eurobank
 
towards third
 
parties regarding
 
bribery
issues.
Provides
 
ongoing
 
training
 
and
 
briefing
 
of
 
staff
 
on
 
the
 
prevention
 
and
 
identification
 
of
 
bribery
 
and
 
corruption
incidents.
On a
 
regular basis,
 
through
 
training
 
modules and
 
internal communication,
 
staff
 
awareness
 
is raised
 
on emerging
risks when dealing with cases of bribery and corruption.
 
Training is provided
 
to all new staff.
 
The
 
relevant
 
policy
 
is
 
reviewed
 
and
 
revised
 
every
 
year
 
by
 
Group
 
Compliance,
 
unless
 
legislative
 
changes
 
require
earlier revision.
Eurobank,
 
both
 
through
 
this Policy
 
and as
 
defined in
 
the
 
Policy
 
for
 
Reporting Illegal
 
or Unethical
 
Conduct encourages
 
the
reporting of bribery and corruption incidents by
 
both staff and third
 
parties. For this reason, it has established
 
a mechanism
for submitting and monitoring anonymous reports and protects
 
bona fide witnesses, as referenced
 
above in [G1-1].
Eurobank
 
has
 
clear
 
disciplinary
 
procedures
 
that
 
are
 
implemented
 
timely
 
and
 
fairly
 
for
 
all
 
staff
 
members,
 
irrespective
 
of
hierarchy.
 
Eurobank
 
reserves
 
the
 
right to
 
refer
 
cases to
 
the
 
police,
 
judicial and/or
 
supervisory
 
authority and
 
to bring
 
legal
action,
 
either
 
civil
 
and/or
 
criminal, against
 
those
 
involved
 
in
 
the
 
case.
 
It
 
may
 
also
 
take
 
disciplinary
 
actions
 
against
 
staff,
including dismissal. When cooperating with third parties,
 
natural or legal, a written
 
acceptance is obtained of their obligation
to prevent
 
and combat against bribery and corruption.
 
If cases of corruption are identified,
 
the cooperation
 
is denounced.
The Group
 
Compliance is responsible
 
for handling such
 
matters. Group
 
Compliance is an independent
 
function and reports
functionally
 
to
 
the
 
Board
 
of
 
Directors
 
through
 
the
 
Audit
 
Committee
 
and
 
for
 
administrative
 
purposes
 
to
 
the
 
CEO.
 
Group
Compliance supervises
 
the overall
 
compliance function
 
in the
 
Group. Within
 
this context,
 
the Compliance
 
Divisions/Units of
the Group in Greece
 
and abroad have a direct reporting line
 
to Group Compliance.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Eurobank
 
has
 
established
 
communication
 
channels
 
to
 
effectively
 
communicate
 
relevant
 
policies
 
and
 
make
 
them
 
easily
understandable for
 
those to whom they apply.
 
Policies affecting
 
internal stakeholders
 
are available to the
 
Group's intranet,
while those
 
refering
 
to external
 
stakeholders,
 
such as
 
the
 
Group's
 
Code of
 
Conduct, are
 
available through
 
Eurobank's
 
site.
These mainly include:
The
 
Anti-Bribery
 
and
 
Corruption
 
Policy
 
and
 
Anti-Bribery
 
and
 
Corruption
 
Policy
 
Statement,
 
which
 
applies
 
to
 
all
Eurobank
 
staff,
 
aims
 
to
 
prevent
 
instances
 
of
 
bribery
 
and
 
corruption,
 
and
 
promote
 
integrity
 
within
 
the
 
business
environment.
Ongoing Training and Awareness
 
to staff on preventing and
 
identifying bribery and corruption incidents.
Systematic Evaluation of Suppliers, includes anti-bribery
 
terms in contractual documents.
Corporate
 
website,
 
includes a
 
corporate
 
governance
 
section
 
that
 
clarifies for
 
all stakeholders
 
the
 
opportunity to
report a misconduct incident through mail or telephone.
 
Sustainability report, explains the mechanisms
 
to report a misconduct incident.
4.1.3.
 
Metrics & Targets
Incidents of corruption or bribery [G1-4]
The number of convictions
 
stands at zero, and no fines have
 
been imposed for violations
 
of anti-corruption and anti-bribery
laws, as shown in the table below.
 
ESRS Quantitative data / metric
2024
Number of convictions for violation
 
of anti-corruption and anti-
 
bribery laws
0
The amount (€) of fines for
 
violation of anti-corruption
 
and anti-bribery laws.
0
Eurobank implemented a comprehensive anti-bribery and anti-corruption policy, delineating clear procedures and standards
as outlined by the Anti-bribery & Corruption Policy and the Anti-bribery & Corruption
 
Policy Statement, as referenced
 
above.
All reports
 
are investigated,
 
and appropriate
 
disciplinary actions are
 
taken. In response
 
to any breaches
 
of anti-corruption
and
 
anti-bribery
 
procedures,
 
Eurobank
 
has
 
implemented
 
a
 
structured
 
disciplinary
 
process.
 
Specifically,
 
any
 
established
violations
 
of
 
the
 
provisions
 
of
 
the
 
Policy
 
may
 
be
 
reported
 
to
 
the
 
competent
 
Eurobank
 
bodies
 
and
 
can
 
even
 
lead
 
to
administrative
 
or
 
disciplinary
 
action,
 
including
 
the
 
staff
 
member’s
 
termination
 
of
 
employment.
 
When
 
breaches
 
in
 
anti-
corruption
 
and
 
anti-bribery
 
standards
 
are
 
identified,
 
the
 
internal
 
audit
 
team
 
undertakes
 
a
 
comprehensive
 
review
 
of
 
the
circumstances.
 
Also,
 
Eurobank
 
provides
 
ongoing
 
training
 
and
 
briefing
 
to
 
staff
 
on
 
preventing
 
and
 
identifying
 
bribery
 
and
corruption incidents. Through training modules and internal communication, staff awareness is
 
raised on emerging risks when
dealing with cases of bribery and corruption.
One of Eurobank’s
 
key initiatives
 
regarding anti-bribery
 
and corruption
 
is obtaining ISO
 
37001 certification
 
for Anti-bribery,
Corruption
 
and
 
Compliance
 
processes.
 
Achieving
 
ISO
 
certification
 
demonstrates
 
Eurobank’s
 
commitment
 
to
 
rigorous
international
 
standards
 
in
 
ethics
 
and
 
compliance
 
and
 
serves
 
as
 
a
 
benchmark
 
for
 
its
 
policies,
 
ensuring
 
they
 
align
 
with
recognised best practices for
 
preventing, detecting, and responding to bribery
 
and corruption risks.
As described above in
 
[G1-1], Eurobank is committed to
 
the maintaining high professional standards for its Group Compliance
staff
 
though
 
professional
 
certifications
 
and
 
ongoing
 
training,
 
which
 
among
 
others
 
covers
 
aspects
 
of
 
anti-bribery,
 
anti-
corruption, compliance,
 
and related areas. Within
 
2024, there were
 
no:
Confirmed incidents of bribery and corruption.
Confirmed incidents in which employees were
 
dismissed or disciplined for corruption.
Confirmed
 
incidents
 
where
 
contracts
 
with
 
business
 
partners
 
were
 
terminated
 
or
 
not
 
renewed
 
due
 
to
 
violations
related to corruption.
Public legal cases regarding corruption
 
brought against the organisation
 
or its employees.
Monetary
 
losses
 
from
 
business
 
ethics
 
violations
 
as
 
a
 
result
 
of
 
legal
 
proceedings
 
associated
 
with
 
insider
 
trading,
antitrust, anti-competitive behaviour,
 
market manipulation or malpractice.
These
 
metrics
 
show that
 
Eurobank
 
successfully
 
maintains zero
 
incidents related
 
to bribery,
 
corruption,
 
and business
 
ethics
violations,
 
thus
 
contributing
 
to
 
maintaining
 
a
 
transparent
 
corporate
 
culture
 
and
 
demonstrating
 
a
 
stable
 
commitment
 
to
compliance.
 
This
 
target
 
will
 
continue
 
to
 
be
 
upheld
 
in
 
2025,
 
with
 
performance
 
monitored
 
and
 
reviewed
 
regularly
 
through
Group Compliance. Regular review processes and monitoring ensure that
 
the metrics remain on track. No
 
significant changes
in metrics’
 
performance
 
were noted
 
in 2024, indicating
 
a consistent trend
 
that Eurobank
 
is well-positioned
 
to maintain this
target level in 2025.
Eurobank actively
 
tracks the
 
effectiveness
 
of its anti-bribery,
 
anti-corruption, and compliance
 
policies and actions to assess
and mitigate
 
material
 
sustainability-related
 
impacts,
 
risks, and
 
opportunities.
 
This
 
is conducted
 
through
 
the
 
independent
 
 
 
 
 
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function
 
of Group
 
Compliance
 
which tracks
 
incidents for
 
any breaches
 
or compliance
 
issues and
 
collects data
 
on training
participation rates,
 
certification renewals,
 
and the rate of compliance
 
-related issues identified and resolved.
In the reporting
 
year,
 
Eurobank undertook
 
several
 
key actions to strengthen
 
its anti-bribery and anti-corruption
 
efforts.
 
This
included enhancing
 
compliance
 
training programs
 
for
 
all staff,
 
evaluating suppliers
 
in order
 
to mitigate
 
the
 
risk of
 
bribery
and corruption, including
 
anti-bribery terms
 
in contractual documents,
 
reviewing and revising
 
the Anti-bribery
 
& Corruption
Policy
 
and encouraging
 
the
 
reporting
 
of bribery
 
and corruption
 
incidents
 
by
 
both
 
staff
 
and third
 
parties
 
through
 
various
channels. These actions will be maintained for
 
2025. These initiatives
 
are expected to reinforce
 
a culture of integrity, directly
contributing to Eurobank’s policy objectives of minimising corruption risks and
 
promoting transparency,
 
throughout the value
chain and across all regions where
 
Eurobank operates.
4.2
Data security and customer privacy [Entity-specific]
4.2.1. Governance
The role
 
of the administrative,
 
management and supervisory bodies [ESRS 2 GOV
 
-1]
Eurobank has embedded cybersecurity and data privacy within its core strategy
 
and business model. Eurobank has adopted
the
 
3
 
lines
 
model
 
to
 
ensure
 
that
 
risks
 
and
 
controls
 
are
 
properly
 
managed
 
on
 
an
 
ongoing
 
basis.
 
In
 
the
 
2nd
 
line,
 
a
 
Chief
Information
 
Security
 
Officer
 
(CISO)
 
has
 
been
 
appointed,
 
who
 
heads
 
Group
 
Corporate
 
Security
 
and
 
reports
 
directly
 
to
 
a
Deputy Chief Executive Officer
 
who sits on Eurobank’s Board of Directors (Board)
 
and Executive Board (ExBo). The CISO
 
also
regularly updates the ExBo, the Board
 
Risk Committee, and the Board to provide objective
 
assurance on the effectiveness
 
of
Eurobank’s cybersecurity
 
controls.
The Data
 
Protection
 
Officer
 
(DPO) heads Eurobank’s
 
Personal Data
 
Protection
 
Unit, acting and reporting
 
independently to
the Deputy CEO and keeping the
 
Executive Board and Board
 
Risk Committee informed of key
 
GDPR compliance issues. This
senior leadership structure reinforces
 
the importance of data protection
 
across the organisation.
Data
 
Protection
 
Officer
 
provides
 
among
 
others,
 
advice
 
on
 
digital
 
transformation
 
projects
 
and
 
new
 
services,
 
following
 
a
"privacy by
 
design" approach.
 
Eurobank
 
also conducts
 
regular
 
data privacy
 
impact assessments,
 
and ongoing
 
training
 
to
keep employees info
 
rmed about privacy requirements.
4.2.2 Strategy
Description of material impacts, risks and opportunities and their
 
interaction with strategy
 
and business model [SBM-3]
Cybersecurity risks continue to impact the financial industry around the world, as the number and complexity
 
of cyberattacks
have increased significantly.
 
Cyberattacks, digital fraud,
 
compromised customer data, and personal
 
data breaches are part
of today’s everyday reality, especially in the financial/banking sector, due to the evolution of new technologies, the increasing
use of digital channels
 
for financial transactions, and the increased sophistication of cyber criminals. Eurobank, its customers,
and its third-party service
 
providers cannot be
 
an exception to that.
As a
 
result
 
of the
 
increasing
 
number
 
and complexity
 
of cyber
 
threats
 
and as
 
a result
 
of the
 
IROs
 
mentioned
 
below,
 
data
security and customer privacy are critical areas for Eurobank’s
 
strategy and business model. The financial sector,
 
particularly
banks,
 
faces
 
cybersecurity
 
risks
 
such
 
as
 
“cyberattacks,
 
digital
 
fraud,
 
compromised
 
customer
 
data,
 
and
 
personal
 
data
breaches,”
 
all of which are now
 
daily realities due to“the evolution of new technologies, the increasing use of digital channels
for
 
financial
 
transactions,
 
and
 
the
 
increased
 
sophistication
 
of
 
cyber
 
criminals.”
 
These
 
risks
 
emphasise
 
the
 
importance
 
of
securing customer trust through
 
robust cybersecurity
 
measures and privacy safeguards.
Cybersecurity is a top priority, with Eurobank implementing a “multi-faceted defense approach” guided by a Predict, Prevent,
Detect,
 
and
 
Respond
 
framework.
 
Regarding
 
the
 
customer
 
privacy,
 
Eurobank
 
places
 
high
 
importance
 
on
 
personal
 
data
protection, not only to meet regulatory
 
requirements but as a cornerstone of good corporate
 
governance and trust-building
with clients and partners.
Through
 
integrated
 
efforts
 
in
 
cybersecurity
 
and
 
data
 
protection,
 
Eurobank’s
 
strategy
 
and
 
business
 
model
 
uphold
 
data
protection and customer privacy as a
 
priority, support regulatory compliance, and reinforce resilience against growing digital
threats, ultimately enhancing customer confidence and trust in
 
its digital services. Furthermore, Eurobank allocates adequate
current and future financial resources towards enhancing its cybersecurity strategy, ensuring the protection of customer data
and compliance with evolving
 
regulatory requirements.
4.2.3. Impact, risk and opportunity management
Description of processes to identify and assess
 
material impacts, risks and opportunities [ESRS 2 IRO-1]
Through the
 
DMA Eurobank has identified the
 
following material
 
impacts and risks:
Data security and customer privacy
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Impact
Positive
Actual
Implementation of internal management
 
systems and initiatives that protect
stakeholders’ data privacy.
Negative
Potential
Improper implementation
 
of established cybersecurity systems and processes
results in incidents of data breach and leaks of personal data.
Risk
Growing cybersecurity threats
 
and cyber-attacks targeting financial institutions,
and their customer
 
data may compromise Eurobank's systems,
 
networks and
sensitive information,
 
leading to operational disruptions
 
and reputational harm
The process
 
of assessing data security and customer privacy applies across
 
all regions where
 
Eurobank operates.
Policies related to data security
 
and customer privacy [MDR-P]
Eurobank has implemented comprehensive
 
policies to manage material sustainability matters concerning
 
data security and
customer privacy,
 
with a particular focus
 
on compliance with the
 
General
 
Data Protection
 
Regulation (GDPR). The
 
Personal
Data Protection
 
Policy outlines
 
key contents that
 
include the
 
procedures
 
for handling
 
personal data,
 
ensuring data subject
rights, and establishing clear protocols for
 
data breaches.
 
The protection
 
of personal data
 
is an important priority
 
for Eurobank,
 
not only because
 
of its statutory
 
obligation, but
 
also
because it recognises it
 
as a key element
 
of good corporate
 
governance
 
and responsibility,
 
as well as a key
 
part in building
relationships of trust with its clients and partners.
In this context, it continuously ensures that the necessary actions are taken for complying with Regulation (EU) 2016/679, Law
4624/2019 and other provisions
 
of the relevant Greek and EU legislation on personal
 
data. As part of its GDPR and personal
data protection
 
obligations, Eurobank
 
takes appropriate
 
measures to provide
 
information to
 
data subjects (e.g. customers)
relating to the processing
 
of their personal data in
 
a concise, transparent, intelligible
 
and easily accessible form, using clear
and
 
plain
 
language.
Its
 
main
 
privacy
 
notice,
 
available
 
both
 
online
 
and
 
in
 
branches,
 
outlines
 
details
 
such
 
as
 
data
 
types
collected, purposes for collection,
 
recipients, data retention periods,
 
and data subject rights. Eurobank’s main privacy notice
(Information on the
 
Processing of Personal
 
Data of Eurobank
 
pursuant to Regulation (EU) 2016/679 and the relevant
 
EU and
Greek legislation) is available online and in hard copy through
 
its branches. This privacy
 
notice includes information
 
on the:
i.
Type of personal data the
 
Bank collects and from which sources
 
ii.
Reason why the Bank collects data and for
 
which purpose
iii.
 
Recipients of the data subjects’ data
 
iv.
Whether the
 
Bank is entitled to transfer the
 
data subjects’ data to third countries (outside
 
the EEA)
 
v.
Length of time the Bank shall maintain the
 
data subjects’ personal data
 
vi.
Data subjects’ rights are with
 
regard to the protection
 
of their personal data
 
vii.
Way the data
 
subjects can exercise their
 
rights
 
viii.
Data Protection
 
Officer
ix.
Way the Bank protects
 
the data subjects’ personal
 
data.
 
The scope of this
 
policy covers all
 
operations
 
involving personal data
 
processing within
 
Eurobank, including digital products
and services, while ensuring that third
 
-party processors and joint controllers
 
are also adhere to these
 
standards. Eurobank’s
privacy policies are
 
regularly updated in line
 
with legislative
 
developments occur
 
and are integrated
 
into various customer-
facing documents to ensure transparency.
Eurobank respects various third-party standards and initiatives, including internationally
 
recognised frameworks such as ISO
27001, and ISO
 
27701. In developing
 
these policies,
 
Eurobank has
 
taken into consideration
 
the interests
 
of key
 
stakeholders,
including customers, employees, and regulatory
 
bodies. This stakeholder engagement ensures
 
that the policies are reflective
of broader societal expectations
 
and regulatory requirements.
Actions related to data security and customer
 
privacy [MDR-A]
Throughout
 
2024, Eurobank
 
continued to proactively
 
invest in up-to-date,
 
efficient and cost-effective
 
security technologies
and controls to address
 
the ever-growing
 
threats and the
 
evolving regulatory
 
requirements, to minimise
 
disruptions, and to
keep
 
systems
 
and
 
data
 
protected
 
from
 
unauthorised
 
or
 
unlawful
 
processing
 
and
 
against
 
accidental
 
loss,
 
destruction
 
or
damage.
 
This
 
proactive
 
approach
 
stance
 
aligns
 
with
 
the
 
Group’s
 
customer-centered
 
strategy
 
approach,
 
ensuring
 
secure
digital transactions while
 
building long-term customer
 
trust through transparency
 
and robust data
 
protection.
 
During 2024
Eurobank:
Continued to ensure its compliance with the evolving
 
regulatory and legal requirements.
Continued
 
to
 
strengthen
 
its
 
cybersecurity
 
capabilities
 
for
 
new
 
digital
 
products/
 
services,
 
teleworking
 
and
 
cloud
technology adoption,
 
as well
 
as to
 
address the
 
ever-growing
 
threats
 
(i.e. Ransomware)
 
and maintain
 
compliance
with
 
evolving
 
regulatory
 
requirements.
 
Continued
 
to
 
be
 
certified
 
and
 
operate
 
based
 
on
 
the
 
internationally
recognised
 
ISO
 
27001,
 
ISO
 
22301
 
and
 
ISO
 
20000
 
standards.
 
The
 
scope
 
of
 
the
 
ISO
 
27001
 
certification
 
covers
 
the
processing
 
of
 
personal
 
data
 
and
 
has
 
been
 
extended
 
to
 
also
 
cover
 
Eurobank’s
 
cloud
 
computing
 
operations.
Additionally,
 
Eurobank
 
has
 
achieved
 
the
 
ISO
 
27701
 
certification
 
for
 
its
 
Privacy
 
Information
 
Management
 
System
(PIMS), further
 
emphasising its commitment
 
to the
 
secure management
 
of personal
 
data and full
 
compliance with
data protection regulations,
 
including the General
 
Data Protection
 
Regulation (GDPR).
 
 
 
 
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Continuously educated
 
employees
 
and customers
 
on emerging
 
cyber threats
 
and online fraud
 
scams, with
 
various
methods.
Regularly performed risk assessments, penetration tests and vulnerability assessments, and timely addressed global
0-day cybersecurity vulnerabilities
 
on critical infrastructure.
 
Evaluated the cybersecurity posture
 
of outsourcers for
 
IT services.
 
Applied
 
multi-tiered
 
Endpoint
 
Protection
 
Detection
 
Response
 
protection,
 
filtered
 
emails
 
and
 
web
 
content,
 
DDoS
protection and SIEM services
 
to detect suspicious activities.
 
Continuously enhanced its
 
threat intelligence capabilities through use of state-of-the-art technologies/
 
services, and
collaboration with
 
peers from other
 
Banks, as well as the Hellenic Police
 
and the National Cyber Defence
 
Agency.
The scope
 
of these
 
actions includes
 
comprehensive
 
employee
 
and customer
 
training on
 
emerging
 
cyber threats
 
and online
fraud schemes.
 
The timeline
 
for completing
 
these actions
 
is ongoing, reflecting
 
Eurobank's commitment
 
to adapting to
 
the
evolving cybersec
 
urity landscape.
 
4.2.4 Metrics & Targets
Data security and customer privacy metrics
 
[MDR-M]
The primary metrics
 
used to evaluate
 
performance
 
and effectiveness
 
in relation
 
to the security
 
of transactions, information,
and personal data, as
 
well as the resilience of its
 
Information and Communication Technology
 
(ICT) systems against
 
the ever-
increasing and constantly changing cyber threats
 
include:
the management of cybersecurity
 
attacks
the occurrence
 
of data breaches involving personally
 
identifiable information (PII),
and business disruptions.
 
During 2024 the Group
 
successfully managed all cybersecurity attacks, and as such there
 
were:
 
No data breaches involving
 
personally identifiable information
 
(PII).
 
No business disruptions.
 
No monetary losses.
 
No cybersecurity incidents that needed to be reported
 
to Authorities.
No account holders affected
This
 
effective
 
management
 
demonstrates
 
Eurobank’s
 
commitment
 
to
 
maintaining
 
robust
 
cybersecurity
 
protocols
 
and
 
its
ability to mitigate risks effectively. In addition, 578 customer/data subject access requests were handled within the deadlines
set out in the
 
GDPR.
To support
 
these evaluations,
 
Eurobank has adopted
 
a comprehensive
 
methodology that
 
includes regular risk assessments,
penetration
 
tests,
 
and
 
vulnerability
 
assessments.
 
Throughout
 
2024,
 
Eurobank
 
regularly
 
performed
 
these
 
assessments
 
to
ensure
 
that
 
all
 
potential
 
vulnerabilities
 
were
 
identified
 
and
 
addressed
 
promptly.
 
This
 
methodology
 
is
 
based
 
on
 
the
assumption that the sophistication
 
of cyber threats is continually evolving, requiring
 
an adaptive and proactive approach to
cybersecurity
 
management.
 
Additionally,
 
we
 
focus
 
on
 
emerging
 
threats,
 
such
 
as
 
ransomware,
 
ensuring
 
that
 
Eurobank’s
metrics reflect the changing landscape
 
of cyber risks.
 
Validation
 
of Eurobank’s
 
metrics
 
is conducted
 
through
 
various external
 
bodies other
 
than Eurobank’s
 
assurance
 
providers.
Eurobank collaborates with industry experts and regulatory authorities to validate its cybersecurity performance metrics and
methodologies.
 
The involvement
 
of external entities
 
ensures that
 
Eurobank’s
 
metrics are
 
credible and aligned
 
with industry
standards.
 
This
 
collaboration
 
further
 
enhances
 
cybersecurity
 
posture
 
and
 
allows
 
us
 
to
 
remain
 
compliant
 
with
 
evolving
regulatory
 
requirements,
 
ensuring
 
that
 
Eurobank’s
 
performance
 
metrics
 
are
 
both
 
reliable
 
and
 
effective
 
in
 
measuring
 
its
success in cybersecurity.
 
Data security and customer privacy targets
 
[MDR-T]
For
 
2024, Eurobank
 
set a
 
target to
 
maintain zero
 
data breaches
 
involving
 
personally
 
identifiable information
 
(PII) and
 
no
business disruptions, which aligns with its objective of ensuring
 
customer trust and regulatory compliance.
 
The
 
scope of
 
these targets
 
encompasses all
 
cybersecurity incidents
 
and personal
 
data processing
 
within Eurobank,
 
as well
as those involving third-party
 
service providers.
 
The target is maintained an ongoing basis, aiming to continuously maintain
this performance
 
through ongoing assessments to ensure
 
relevance in the
 
face of evolving
 
cyber threats
Eurobank also
 
sets milestones such
 
as periodic risk
 
assessments, employee
 
training sessions, and
 
incident response drills
 
to
ensure that the targets
 
are met throughout
 
the year.
 
Key methodologies and approaches to measure progress against targets include penetration tests vulnerability assessments
and incident monitoring mechanisms.
 
Eurobank ensures
 
that its cybersecurity
 
targets are informed
 
by market
 
best practice
and regulatory requirements.
 
Stakeholders
 
are involved
 
in target setting through
 
regular communication
 
and training sessions
 
while their
 
input is sought
to
 
align
 
targets
 
with
 
customer
 
expectations
 
and
 
regulatory
 
compliance.
 
Throughout
 
2024,
 
Eurobank
 
has
 
not
 
made
 
any
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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significant
 
changes
 
to
 
its
 
targets;
 
however,
 
the
 
Group
 
remains
 
alert
 
to
 
the
 
evolving
 
circumstances
 
in
 
cybersecurity
 
and
regulatory environments.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
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APPENDIX - Disclosures under Article 8 of Regulation (EU) 2020/852
Reporting templates for the
 
years ended 31 December 2024 and 31 December
 
2023
0. Summary of KPIs to be disclosed by credit institutions
 
under Article 8 Taxonomy
 
Regulation for
 
the year ended 31 December
 
2024
Total environmentally sustainable
assets
¹
KPI
³
KPI
⁽⁴⁾
% coverage (over total
assets)
 
⁽⁵⁾
% of assets excluded from the numerator
of the GAR (Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded from the
denominator of the GAR
(Article 7(1) and Section 1.2.4
of Annex V)
Main KPI
Green asset ratio (GAR) stock
1,908
2.6
3.7
70.9
42.2
29.1
Total environmentally sustainable
activities
²
KPI
³
KPI
⁽⁴⁾
% coverage (over total
assets)
 
⁽⁵⁾
% of assets excluded from the numerator
of the GAR (Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded from the
denominator of the GAR
(Article 7(1) and Section 1.2.4
of Annex V)
Additional KPIs
GAR (flow)
589
3.7
6.5
31.4
N/A
N/A
Trading book
 
⁽⁶⁾
Financial guarantees
 
⁽⁷⁾
115
4.7
15.7
Assets under management
 
⁽⁷⁾
79
1.1
2.9
Fees and commissions income
 
⁽⁶⁾
(1)
 
Total environmentally
 
sustainable assets used for turnover
 
KPI. Total environmentally
 
sustainable assets used for Capex KPI amounts to EUR 2,658 million
(2) Total environmentally
 
sustainable assets used for turnover
 
KPI. Total environmentally
 
sustainable assets used for Capex KPI amounts to EUR 1,020 million
 
for GAR flow
(3) Based on the Turnover
 
KPI of the counterparty
(4) Based on the CapEx KPI of the counterparty
(5) % of assets covered by
 
the KPI over
 
Group’s total assets
(6) "Trading book"
 
and "fees and commissions income" KPIs shall apply from
 
FY2025 onwards
(7) Total environmentally sustainable assets used for turnover KPI. Total environmentally
 
sustainable assets used for Financial
 
guarantees - Capex KPI amounts to
 
EUR 386 million and for assets
under management is EUR 209 million.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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1.Assets for the calculation
 
of GAR - Turnover
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying
amount
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
 
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
28,809
17,150
1,905
1,409
15
140
123
3
0
2
2
Financial undertakings
4,332
1,095
127
0
9
17
18
0
0
0
3
Credit institutions
3,980
1,049
113
0
9
15
12
0
0
0
4
Loans and advances
958
230
38
0
1
1
1
0
0
0
5
Debt securities, including UoP
3,020
819
75
0
8
14
11
0
0
0
6
Equity instruments
2
0
0
0
0
0
0
0
7
Other financial corporations
352
46
14
0
0
2
6
0
0
0
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
0
16
of which insurance undertakings
5
2
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
5
2
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
20
Non-financial undertakings
6,138
2,282
1,752
1,383
6
123
105
3
0
2
21
 
Loans and advances
5,416
2,084
1,679
1,383
2
84
82
2
0
2
22
 
Debt securities, including UoP
705
194
71
0
4
40
22
0
0
0
23
 
Equity instruments
17
3
1
0
0
1
0
0
24
Households
18,338
13,773
26
26
0
0
0
0
0
0
25
of which loans collateralised by residential
 
immovable
property
12,316
12,316
22
22
0
0
0
0
0
0
26
of which
 
building renovation loans
2,115
2,115
0
0
0
0
0
0
0
0
27
of which motor vehicle loans
546
546
4
4
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
697
520
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
43,257
33
Financial and Non-financial undertakings
33,496
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
26,005
35
 
Loans and advances
23,806
36
of which loans collateralised by commercial
 
immovable
property
7,140
37
of which building renovation loans
33
38
 
Debt securities
1,977
39
 
Equity instruments
222
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
7,491
41
 
Loans and advances
4,641
42
 
Debt securities
2,761
43
 
Equity instruments
88
44
Derivatives
836
45
On demand interbank loans
251
46
Cash and cash-related assets
617
47
Other categories of assets (e.g. goodwill, commodities etc.)
8,057
48
Total GAR
 
assets
72,762
17,670
1,905
1,409
15
140
123
3
0
2
49
Assets not covered for GAR calculation
29,805
50
Central governments and Supranational
 
issuers
14,257
51
Central banks exposure
15,263
52
Trading book
285
53
Total assets
102,567
17,670
1,905
1,409
15
140
123
3
0
2
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
948
295
113
0
0
10
52
1
0
1
55
Assets under management
2,374
559
77
0
6
21
34
2
0
0
56
Of which debt securities
 
1,529
364
52
0
4
13
23
1
0
0
57
Of which equity instruments
345
81
18
0
1
8
11
1
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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1.Assets for the calculation
 
of GAR - Turnover
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources
 
(WTR)
Circular economy (CE)
Pollution (PPC)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
0
0
0
0
14
0
0
0
9
0
0
0
2
Financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
3
Credit institutions
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
0
0
0
0
0
0
0
0
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
14
0
0
0
9
0
0
0
21
 
Loans and advances
0
0
0
0
10
0
0
0
1
0
0
0
22
 
Debt securities, including UoP
0
0
0
0
3
0
0
0
8
0
0
0
23
 
Equity instruments
0
0
0
0
0
0
0
0
0
24
Households
0
0
0
0
25
of which loans collateralised by residential
 
immovable
property
0
0
0
0
26
of which
 
building renovation loans
0
0
0
0
27
of which motor vehicle loans
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
35
 
Loans and advances
36
of which loans collateralised by commercial
 
immovable
property
37
of which building renovation loans
38
 
Debt securities
39
 
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
41
 
Loans and advances
42
 
Debt securities
43
 
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR
 
assets
0
0
0
0
14
0
0
0
9
0
0
0
49
Assets not covered for GAR calculation
50
Central governments and Supranational
 
issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
14
0
0
0
9
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
3
0
0
0
0
0
0
0
55
Assets under management
0
0
0
0
3
0
0
0
9
0
0
0
56
Of which debt securities
 
0
0
0
0
0
0
0
0
2
0
0
0
57
Of which equity instruments
0
0
0
0
3
0
0
0
8
0
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
119
|
Page
 
1.Assets for the calculation
 
of GAR - Turnover
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
40
0
0
0
17,348
1,908
1,409
15
141
2
Financial undertakings
0
0
0
0
1,125
128
0
9
16
3
Credit institutions
0
0
0
0
1,074
114
0
9
15
4
Loans and advances
0
0
0
0
235
38
0
1
1
5
Debt securities, including UoP
0
0
0
0
839
76
0
8
14
6
Equity instruments
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
52
14
0
0
1
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
2
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
2
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
20
Non-financial undertakings
40
0
0
0
2,450
1,754
1,383
6
125
21
 
Loans and advances
40
0
0
0
2,217
1,681
1,383
2
86
22
 
Debt securities, including UoP
0
0
0
0
228
72
0
4
40
23
 
Equity instruments
0
0
0
4
1
0
0
24
Households
13,773
26
26
0
0
25
of which loans collateralised by residential
 
immovable
property
12,316
22
22
0
0
26
of which
 
building renovation loans
2,115
0
0
0
0
27
of which motor vehicle loans
546
4
4
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
520
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
35
 
Loans and advances
36
of which loans collateralised by commercial
 
immovable
property
37
of which building renovation loans
38
 
Debt securities
39
 
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
41
 
Loans and advances
42
 
Debt securities
43
 
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR
 
assets
40
0
0
0
17,868
1,908
1,409
15
141
49
Assets not covered for GAR calculation
50
Central governments and Supranational
 
issuers
51
Central banks exposure
52
Trading book
53
Total assets
40
0
0
0
17,868
1,908
1,409
15
141
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
350
115
0
0
12
55
Assets under management
0
0
0
0
606
79
0
6
22
56
Of which debt securities
 
0
0
0
0
389
53
0
4
13
57
Of which equity instruments
0
0
0
0
103
18
0
1
8
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
120
|
Page
 
1.Assets for the calculation
 
of GAR - Capex
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying
amount
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
 
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
28,809
18,752
2,653
1,409
55
394
61
5
0
2
2
Financial undertakings
4,332
1,244
194
0
10
31
14
1
0
0
3
Credit institutions
3,980
1,017
141
0
9
25
14
1
0
0
4
Loans and advances
958
191
38
0
1
1
1
0
0
0
5
Debt securities, including UoP
3,020
826
103
0
8
23
13
1
0
0
6
Equity instruments
2
0
0
0
0
0
0
0
7
Other financial corporations
352
226
53
0
1
6
0
0
0
0
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
0
16
of which insurance undertakings
5
2
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
5
2
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
20
Non-financial undertakings
6,138
3,736
2,432
1,383
45
363
46
4
0
2
21
 
Loans and advances
5,416
3,292
2,231
1,383
19
288
37
4
0
2
22
 
Debt securities, including UoP
705
438
197
0
27
74
8
0
0
0
23
 
Equity instruments
17
6
4
0
0
1
0
0
24
Households
18,338
13,773
26
26
0
0
0
0
0
0
25
of which loans collateralised by residential
 
immovable
property
12,316
12,316
22
22
0
0
0
0
0
0
26
of which
 
building renovation loans
2,115
2,115
0
0
0
0
0
0
0
0
27
of which motor vehicle loans
546
546
4
4
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
697
520
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
43,257
0
0
0
0
0
0
0
0
0
33
Financial and Non-financial undertakings
33,496
0
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
26,005
35
 
Loans and advances
23,806
36
of which loans collateralised by commercial
 
immovable
property
7,140
37
of which building renovation loans
33
38
 
Debt securities
1,977
39
 
Equity instruments
222
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
7,491
41
 
Loans and advances
4,641
42
 
Debt securities
2,761
43
 
Equity instruments
88
44
Derivatives
836
45
On demand interbank loans
251
46
Cash and cash-related assets
617
47
Other categories of assets (e.g. goodwill, commodities etc.)
8,057
48
Total GAR
 
assets
72,762
19,272
2,653
1,409
55
394
61
5
0
2
49
Assets not covered for GAR calculation
29,805
0
50
Central governments and Supranational
 
issuers
14,257
51
Central banks exposure
15,263
52
Trading book
285
53
Total assets
102,567
19,272
2,653
1,409
55
394
61
5
0
2
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
948
609
385
0
2
37
22
1
0
37
55
Assets under management
2,374
802
206
0
19
52
17
2
0
1
56
Of which debt securities
 
1,529
551
137
0
11
34
9
2
0
1
57
Of which equity instruments
345
131
57
0
7
17
6
0
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
121
|
Page
 
1.Assets for the calculation
 
of GAR - Capex
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources
 
(WTR)
Circular economy (CE)
Pollution (PPC)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
0
0
0
0
7
0
0
0
17
0
0
0
2
Financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
3
Credit institutions
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
0
0
0
0
0
0
0
0
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
7
0
0
0
17
0
0
0
21
 
Loans and advances
0
0
0
0
4
0
0
0
12
0
0
0
22
 
Debt securities, including UoP
0
0
0
0
3
0
0
0
5
0
0
0
23
 
Equity instruments
0
0
0
0
0
0
0
0
0
24
Households
0
0
0
0
25
of which loans collateralised by residential
 
immovable
property
0
0
0
0
26
of which
 
building renovation loans
0
0
0
0
27
of which motor vehicle loans
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
0
0
0
0
0
0
0
0
0
0
0
0
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
35
 
Loans and advances
36
of which loans collateralised by commercial
 
immovable
property
37
of which building renovation loans
38
 
Debt securities
39
 
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
41
 
Loans and advances
42
 
Debt securities
43
 
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR
 
assets
0
0
0
0
7
0
0
0
17
0
0
0
49
Assets not covered for GAR calculation
50
Central governments and Supranational
 
issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
7
0
0
0
17
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
3
0
0
0
0
0
0
0
55
Assets under management
0
0
0
0
3
0
0
0
4
0
0
0
56
Of which debt securities
 
0
0
0
0
1
0
0
0
1
0
0
0
57
Of which equity instruments
0
0
0
0
2
0
0
0
3
0
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
122
|
Page
 
1.Assets for the calculation
 
of GAR - Capex
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR- Covered assets in both numerator
 
and denominator
1
Loans and advances, debt securities and equity instruments
no HfT eligible for GAR calculation
40
0
0
0
18,888
2,658
1,409
55
395
2
Financial undertakings
0
0
0
0
1,269
195
0
9
30
3
Credit institutions
0
0
0
0
1,042
142
0
9
25
4
Loans and advances
0
0
0
0
195
38
0
1
1
5
Debt securities, including UoP
0
0
0
0
847
104
0
8
23
6
Equity instruments
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
226
53
0
0
5
8
 
of which investment firms
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
13
 
Loans and advances
0
0
0
0
0
0
0
0
0
14
 
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
15
 
Equity instruments
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
2
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
2
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
20
Non-financial undertakings
40
0
0
0
3,846
2,436
1,383
45
365
21
 
Loans and advances
40
0
0
0
3,385
2,235
1,383
19
290
22
 
Debt securities, including UoP
0
0
0
0
454
197
0
27
74
23
 
Equity instruments
0
0
0
7
4
0
0
24
Households
13,773
26
26
0
0
25
of which loans collateralised by residential
 
immovable
property
12,316
22
22
0
0
26
of which
 
building renovation loans
2,115
0
0
0
0
27
of which motor vehicle loans
546
4
4
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
30
Other local govemment
 
financing
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
520
0
0
0
0
32
Assets excluded from the numerator for
 
GAR calculation
(covered in the denominator)
0
0
0
0
0
0
0
0
0
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs)
 
not subject to NFRD
disclosure obligations
35
 
Loans and advances
36
of which loans collateralised by commercial
 
immovable
property
37
of which building renovation loans
38
 
Debt securities
39
 
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
41
 
Loans and advances
42
 
Debt securities
43
 
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR
 
assets
40
0
0
0
19,408
2,658
1,409
55
395
49
Assets not covered for GAR calculation
50
Central governments and Supranational
 
issuers
51
Central banks exposure
52
Trading book
53
Total assets
40
0
0
0
19,408
2,658
1,409
55
395
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
634
386
0
2
75
55
Assets under management
0
0
0
0
832
209
0
19
54
56
Of which debt securities
 
0
0
0
0
566
139
0
11
35
57
Of which equity instruments
0
0
0
0
143
58
0
7
18
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
123
|
Page
 
a
b
c
d
e
f
g
h
2. GAR sector information - Turnover
31 December 2024
Breakdown by sector - NACE 4 digits level (code and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable (CCM)
Mn EUR
Of which
environmentally
sustainable (CCM)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
1
B7 - Mining of metal ores
16
-
16
-
2
C10.6.1 - Manufacture
 
of grain mill products
0
0
0
-
3
C11 - Manufacture of beverages
5
-
5
-
4
C13.9.5 - Manufacture
 
of non-wovens and articles made
 
from non-wovens, except
 
apparel
1
1
1
-
5
C14.1.3 - Manufacture of other
 
outerwear
0
-
0
-
6
C15 - Manufacture of leather
 
and related products
2
-
2
-
7
C17 - Manufacture of paper and paper
 
products
4
0
4
-
8
C18.1.0 - Printing and service
 
activities related to printing
0
-
0
-
9
C19 - Manufacture of coke and refined
 
petroleum products
85
1
85
-
10
C19.2.0 - Manufacture of refined
 
petroleum products
767
10
767
-
11
C20.1.1 - Manufacture
 
of industrial gases
0
-
0
-
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
30
-
30
-
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
4
4
4
-
14
C21 - Manufacture of basic pharmaceutical
 
products and pharmaceutical preparations
22
-
22
-
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
25
-
25
-
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
12
0
12
-
17
C22.2.2 - Manufacture of plastic packing goods
10
-
10
2
18
C23 - Manufacture of other
 
non-metallic mineral products
87
4
87
-
19
C24 - Manufacture of basic metals
10
-
10
-
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
85
8
85
-
21
C24.2 - Manufacture of tubes, pipes, hollow
 
profiles and related fittings, of steel
8
2
8
-
22
C24.4.2 - Aluminium production
52
3
52
-
23
C24.4.4 - Copper production
61
1
61
-
24
C24.5.1 - Casting of iron
58
4
58
-
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
196
50
196
-
26
C27.5.1 - Manufacture
 
of electric domestic appliances
1
1
1
-
27
C28.9 - Manufacture of
 
other special-purpose machinery
18
-
18
-
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
53
4
53
-
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
0
0
0
-
30
C33.1.1 - Repair of
 
fabricated metal products
9
9
9
-
31
C33.1.2 - Repair of machinery
0
0
0
-
32
D35 - Electricity, gas, steam and air conditioning
 
supply
297
48
297
0
33
D35.1.1 - Production
 
of electricity
1,403
1,297
1,403
-
34
D35.1.3 - Distribution of electricity
355
-
355
-
35
D35.1.4 - Trade of
 
electricity
341
-
341
-
36
E38.3.2 - Recovery of sorted materials
2
0
2
-
37
F41.2.0 - Construction of residential and non-residential
 
buildings
1
-
1
-
38
F42 - Civil engineering
42
5
42
0
39
F42.2.2 - Construction of utility projects for electricity
 
and telecommunications
198
198
198
-
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
19
4
19
-
41
F43.2.9 - Other construction
 
installation
21
-
21
-
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
5
-
5
-
43
G45 - Wholesale and retail trade and
 
repair of motor vehicles and motorcycles
3
0
3
0
44
G45.1.1 - Sale of
 
cars and light motor vehicles
1
0
1
0
45
G45.1.9 - Sale
 
of other motor vehicles
2
0
2
-
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
4
0
4
0
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
1
-
1
-
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
4
-
4
-
49
G46.4.2 - Wholesale of clothing and footwear
7
-
7
-
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
23
-
23
-
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
8
-
8
-
52
G46.5.1 - Wholesale of computers,
 
computer peripheral equipment
 
and software
7
0
7
0
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and parts
11
-
11
-
54
G46.7 - Other specialised wholesale
1
-
1
-
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
319
36
319
-
56
G46.7.2 - Wholesale of
 
metals and metal ores
13
1
13
-
57
G46.7.7 - Wholesale of
 
waste and scrap
6
0
6
-
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
0
-
0
-
59
G47.1.9
 
- Other retail sale in non-specialised stores
28
5
28
-
60
G47.7.1
 
- Retail sale of clothing in specialised stores
12
0
12
0
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
1
-
1
-
62
H49 - Land transport and transport via
 
pipelines
8
7
8
-
63
H50.1.0 - Sea and coastal passenger
 
water transport
0
-
0
-
64
H51 - Air transport
25
-
25
-
65
H52.1 - Warehousing and storage
1
-
1
-
66
H52.2.1 - Service activities incidental to land
 
transportation
21
1
21
0
67
H52.2.3 - Service activities incidental to air transportation
402
6
402
-
68
I55 - Accommodation
3
-
3
-
69
I55.1.0 - Hotels and similar
 
accommodation
40
-
40
-
70
J61 - Telecommunications
23
0
23
-
71
J62.0 - Computer programming, consultancy
 
and related activities
9
-
9
-
72
J62.0.1 - Computer programming
 
activities
2
2
2
-
73
J62.0.3 - Computer facilities management
 
activities
2
-
2
-
74
K64.2.0 - Activities of holding companies
64
0
64
0
75
K64.9.1
 
- Financial leasing
3
-
3
-
76
K65.1.2 - Non-life insurance
0
-
0
-
77
K66.1.9 - Other
 
activities auxiliary to financial services, except
 
insurance and pension funding
9
-
9
-
78
L68 - Real estate activities
14
3
14
0
79
L68.1.0 - Buying and selling of own
 
real estate
116
19
116
-
80
L68.2.0 - Renting and operating of own or
 
leased real estate
89
7
89
-
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
71
10
71
-
82
M71.2.0 - Technical testing and analysis
2
0
2
-
83
M74.1.0 - Specialised design activities
0
-
0
-
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
0
0
0
-
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
10
0
10
0
86
N77.3.9
 
- Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
11
0
11
0
87
N81.2.2 - Other building and industrial cleaning activities
2
0
2
-
88
N82 - Office administrative,
 
office support and other
 
business support activities
3
-
3
-
89
Q86.1.0 - Hospital activities
57
-
57
-
90
R92 - Gambling and betting activities
392
-
392
-
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
0
0
0
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
124
|
Page
 
i
j
k
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n
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2. GAR sector information - Turnover
31 December 2024
Breakdown by sector - NACE 4 digits level (code and label)
Water and marine resources (WTR)
Circular economy (CE)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
1
B7 - Mining of metal ores
2
C10.6.1 - Manufacture
 
of grain mill products
3
C11 - Manufacture of beverages
4
C13.9.5 - Manufacture
 
of non-wovens and articles made
 
from non-wovens, except
 
apparel
5
C14.1.3 - Manufacture of other
 
outerwear
6
C15 - Manufacture of leather
 
and related products
7
C17 - Manufacture of paper and paper
 
products
8
C18.1.0 - Printing and service
 
activities related to printing
9
C19 - Manufacture of coke and refined
 
petroleum products
10
C19.2.0 - Manufacture of refined
 
petroleum products
11
C20.1.1 - Manufacture
 
of industrial gases
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
14
C21 - Manufacture of basic pharmaceutical
 
products and pharmaceutical preparations
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
17
C22.2.2 - Manufacture of plastic packing goods
18
C23 - Manufacture of other
 
non-metallic mineral products
19
C24 - Manufacture of basic metals
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
21
C24.2 - Manufacture of tubes, pipes, hollow
 
profiles and related fittings, of steel
22
C24.4.2 - Aluminium production
23
C24.4.4 - Copper production
24
C24.5.1 - Casting of iron
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
26
C27.5.1 - Manufacture
 
of electric domestic appliances
27
C28.9 - Manufacture of
 
other special-purpose machinery
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
30
C33.1.1 - Repair of
 
fabricated metal products
31
C33.1.2 - Repair of machinery
32
D35 - Electricity, gas, steam and air conditioning
 
supply
33
D35.1.1 - Production
 
of electricity
34
D35.1.3 - Distribution of electricity
35
D35.1.4 - Trade of
 
electricity
36
E38.3.2 - Recovery of sorted materials
37
F41.2.0 - Construction of residential and non-residential
 
buildings
38
F42 - Civil engineering
39
F42.2.2 - Construction of utility projects for electricity
 
and telecommunications
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
41
F43.2.9 - Other construction
 
installation
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
43
G45 - Wholesale and retail trade and
 
repair of motor vehicles and motorcycles
44
G45.1.1 - Sale of
 
cars and light motor vehicles
45
G45.1.9 - Sale
 
of other motor vehicles
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
49
G46.4.2 - Wholesale of clothing and footwear
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
52
G46.5.1 - Wholesale of computers,
 
computer peripheral equipment
 
and software
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and parts
54
G46.7 - Other specialised wholesale
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
56
G46.7.2 - Wholesale of
 
metals and metal ores
57
G46.7.7 - Wholesale of
 
waste and scrap
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
59
G47.1.9
 
- Other retail sale in non-specialised stores
60
G47.7.1
 
- Retail sale of clothing in specialised stores
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
62
H49 - Land transport and transport via
 
pipelines
63
H50.1.0 - Sea and coastal passenger
 
water transport
64
H51 - Air transport
65
H52.1 - Warehousing and storage
66
H52.2.1 - Service activities incidental to land
 
transportation
67
H52.2.3 - Service activities incidental to air transportation
68
I55 - Accommodation
69
I55.1.0 - Hotels and similar
 
accommodation
70
J61 - Telecommunications
71
J62.0 - Computer programming, consultancy
 
and related activities
72
J62.0.1 - Computer programming
 
activities
73
J62.0.3 - Computer facilities management
 
activities
74
K64.2.0 - Activities of holding companies
75
K64.9.1
 
- Financial leasing
76
K65.1.2 - Non-life insurance
77
K66.1.9 - Other
 
activities auxiliary to financial services, except
 
insurance and pension funding
78
L68 - Real estate activities
79
L68.1.0 - Buying and selling of own
 
real estate
80
L68.2.0 - Renting and operating of own or
 
leased real estate
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
82
M71.2.0 - Technical testing and analysis
83
M74.1.0 - Specialised design activities
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
86
N77.3.9
 
- Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
87
N81.2.2 - Other building and industrial cleaning activities
88
N82 - Office administrative,
 
office support and other
 
business support activities
89
Q86.1.0 - Hospital activities
90
R92 - Gambling and betting activities
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
125
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ab
2. GAR sector information - Turnover
31 December 2024
Breakdown by sector - NACE
 
4 digits level (code and label)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA
 
+ WTR + CE + PPC + BIO)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
to NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
to NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable
 
(CCM + CCA + WTR +
CE + PPC + BIO)
Mn EUR
Of which
environmentally
sustainable
 
(CCM + CCA + WTR +
CE + PPC + BIO)
1
B7 - Mining of metal ores
16
-
2
C10.6.1 - Manufacture
 
of grain mill products
0
0
3
C11 - Manufacture of beverages
5
-
4
C13.9.5 - Manufacture
 
of non-wovens and articles made from non-wovens,
 
except
apparel
1
1
5
C14.1.3 - Manufacture of other
 
outerwear
0
-
6
C15 - Manufacture of leather
 
and related products
2
-
7
C17 - Manufacture of paper and paper
 
products
4
0
8
C18.1.0 - Printing and service
 
activities related to printing
0
-
9
C19 - Manufacture of coke and refined
 
petroleum products
85
1
10
C19.2.0 - Manufacture of refined
 
petroleum products
767
10
11
C20.1.1 - Manufacture
 
of industrial gases
0
-
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
30
-
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
4
4
14
C21 - Manufacture of basic pharmaceutical products and pharmaceutical preparations
22
-
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
25
-
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
12
0
17
C22.2.2 - Manufacture of plastic packing goods
10
2
18
C23 - Manufacture of other
 
non-metallic mineral products
87
4
19
C24 - Manufacture of basic metals
10
-
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
85
8
21
C24.2 - Manufacture of tubes, pipes, hollow profiles and related
 
fittings, of steel
8
2
22
C24.4.2 - Aluminium production
52
3
23
C24.4.4 - Copper production
61
1
24
C24.5.1 - Casting of iron
58
4
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
196
50
26
C27.5.1 - Manufacture
 
of electric domestic appliances
1
1
27
C28.9 - Manufacture of
 
other special-purpose machinery
18
-
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
53
4
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
0
0
30
C33.1.1 - Repair of
 
fabricated metal products
9
9
31
C33.1.2 - Repair of machinery
0
0
32
D35 - Electricity, gas, steam and air conditioning
 
supply
297
48
33
D35.1.1 - Production
 
of electricity
1,403
1,297
34
D35.1.3 - Distribution of electricity
355
-
35
D35.1.4 - Trade of
 
electricity
341
-
36
E38.3.2 - Recovery of sorted materials
2
0
37
F41.2.0 - Construction of residential and non-residential
 
buildings
1
-
38
F42 - Civil engineering
42
5
39
F42.2.2 - Construction of utility projects for electricity and telecommunications
198
198
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
19
4
41
F43.2.9 - Other construction
 
installation
21
-
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
5
-
43
G45 - Wholesale and retail trade and repair of motor
 
vehicles and motorcycles
3
0
44
G45.1.1 - Sale of
 
cars and light motor vehicles
1
0
45
G45.1.9 - Sale
 
of other motor vehicles
2
0
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
4
0
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
1
-
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
4
-
49
G46.4.2 - Wholesale of clothing and footwear
7
-
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
23
-
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
8
-
52
G46.5.1 - Wholesale of computers, computer
 
peripheral equipment and software
7
0
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and parts
11
-
54
G46.7 - Other specialised wholesale
1
-
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
319
36
56
G46.7.2 - Wholesale of
 
metals and metal ores
13
1
57
G46.7.7 - Wholesale of
 
waste and scrap
6
0
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
0
-
59
G47.1.9
 
- Other retail sale in non-specialised stores
28
5
60
G47.7.1
 
- Retail sale of clothing in specialised stores
12
0
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
1
-
62
H49 - Land transport and transport via
 
pipelines
8
7
63
H50.1.0 - Sea and coastal passenger
 
water transport
0
-
64
H51 - Air transport
25
-
65
H52.1 - Warehousing and storage
1
-
66
H52.2.1 - Service activities incidental to land
 
transportation
21
2
67
H52.2.3 - Service activities incidental to air transportation
402
6
68
I55 - Accommodation
3
-
69
I55.1.0 - Hotels and similar
 
accommodation
40
-
70
J61 - Telecommunications
23
0
71
J62.0 - Computer programming, consultancy
 
and related activities
9
-
72
J62.0.1 - Computer programming
 
activities
2
2
73
J62.0.3 - Computer facilities management
 
activities
2
-
74
K64.2.0 - Activities of holding companies
64
0
75
K64.9.1
 
- Financial leasing
3
-
76
K65.1.2 - Non-life insurance
0
-
77
K66.1.9 - Other
 
activities auxiliary to financial services, except insurance
 
and pension
funding
9
-
78
L68 - Real estate activities
14
3
79
L68.1.0 - Buying and selling of own
 
real estate
116
19
80
L68.2.0 - Renting and operating of own or
 
leased real estate
89
7
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
71
10
82
M71.2.0 - Technical testing and analysis
2
0
83
M74.1.0 - Specialised design activities
0
-
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
0
0
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
10
0
86
N77.3.9 - Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
11
0
87
N81.2.2 - Other building and industrial cleaning activities
2
0
88
N82 - Office administrative, office support
 
and other business support activities
3
-
89
Q86.1.0 - Hospital activities
57
-
90
R92 - Gambling and betting activities
392
-
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
126
|
Page
 
a
b
c
d
e
f
g
h
2. GAR sector information - Capex
31 December 2024
Breakdown by sector - NACE 4 digits level (code and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable (CCM)
Mn EUR
Of which
environmentally
sustainable (CCM)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
1
B7 - Mining of metal ores
16
-
16
-
2
C10.6.1 - Manufacture
 
of grain mill products
0
0
0
-
3
C11 - Manufacture of beverages
5
0
5
-
4
C13.9.5 - Manufacture
 
of non-wovens and articles made
 
from non-wovens, except
 
apparel
1
1
1
-
5
C14.1.3 - Manufacture of other
 
outerwear
0
0
0
-
6
C15 - Manufacture of leather
 
and related products
2
0
2
-
7
C17 - Manufacture of paper and paper
 
products
4
0
4
-
8
C18.1.0 - Printing and service
 
activities related to printing
0
-
0
-
9
C19 - Manufacture of coke and refined
 
petroleum products
85
23
85
-
10
C19.2.0 - Manufacture of refined
 
petroleum products
767
179
767
-
11
C20.1.1 - Manufacture
 
of industrial gases
0
-
0
-
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
30
6
30
-
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
4
4
4
-
14
C21 - Manufacture of basic pharmaceutical
 
products and pharmaceutical preparations
22
-
22
-
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
25
-
25
-
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
12
0
12
-
17
C22.2.2 - Manufacture of plastic packing goods
10
-
10
2
18
C23 - Manufacture of other
 
non-metallic mineral products
87
24
87
-
19
C24 - Manufacture of basic metals
10
-
10
-
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
85
17
85
-
21
C24.2 - Manufacture of tubes, pipes, hollow
 
profiles and related fittings, of steel
8
3
8
-
22
C24.4.2 - Aluminium production
52
9
52
-
23
C24.4.4 - Copper production
61
4
61
-
24
C24.5.1 - Casting of iron
58
10
58
-
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
196
73
196
-
26
C27.5.1 - Manufacture
 
of electric domestic appliances
1
1
1
-
27
C28.9 - Manufacture of
 
other special-purpose machinery
18
-
18
-
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
53
10
53
-
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
0
0
0
-
30
C33.1.1 - Repair of
 
fabricated metal products
9
9
9
-
31
C33.1.2 - Repair of machinery
0
0
0
-
32
D35 - Electricity, gas, steam and air conditioning
 
supply
297
112
297
0
33
D35.1.1 - Production
 
of electricity
1,403
1,360
1,403
-
34
D35.1.3 - Distribution of electricity
355
-
355
-
35
D35.1.4 - Trade of
 
electricity
341
-
341
-
36
E38.3.2 - Recovery of sorted materials
2
0
2
-
37
F41.2.0 - Construction of residential and non-residential
 
buildings
1
-
1
-
38
F42 - Civil engineering
42
19
42
0
39
F42.2.2 - Construction of utility projects for electricity
 
and telecommunications
198
198
198
-
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
19
13
19
-
41
F43.2.9 - Other construction
 
installation
21
-
21
-
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
5
-
5
-
43
G45 - Wholesale and retail trade and
 
repair of motor vehicles and motorcycles
3
1
3
0
44
G45.1.1 - Sale of
 
cars and light motor vehicles
1
0
1
0
45
G45.1.9 - Sale
 
of other motor vehicles
2
1
2
-
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
4
1
4
0
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
1
-
1
-
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
4
-
4
-
49
G46.4.2 - Wholesale of clothing and footwear
7
1
7
-
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
23
-
23
-
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
8
-
8
-
52
G46.5.1 - Wholesale of computers,
 
computer peripheral equipment
 
and software
7
1
7
-
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and parts
11
-
11
-
54
G46.7 - Other specialised wholesale
1
-
1
-
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
319
187
319
-
56
G46.7.2 - Wholesale of
 
metals and metal ores
13
2
13
-
57
G46.7.7 - Wholesale of
 
waste and scrap
6
1
6
-
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
0
-
0
-
59
G47.1.9
 
- Other retail sale in non-specialised stores
28
14
28
-
60
G47.7.1
 
- Retail sale of clothing in specialised stores
12
-
12
-
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
1
-
1
-
62
H49 - Land transport and transport via
 
pipelines
8
6
8
-
63
H50.1.0 - Sea and coastal passenger
 
water transport
0
0
0
-
64
H51 - Air transport
25
0
25
-
65
H52.1 - Warehousing and storage
1
-
1
-
66
H52.2.1 - Service activities incidental to
 
land transportation
21
2
21
0
67
H52.2.3 - Service activities incidental to air transportation
402
20
402
-
68
I55 - Accommodation
3
-
3
-
69
I55.1.0 - Hotels and similar
 
accommodation
40
-
40
-
70
J61 - Telecommunications
23
-
23
-
71
J62.0 - Computer programming, consultancy
 
and related activities
9
0
9
0
72
J62.0.1 - Computer programming
 
activities
2
-
2
2
73
J62.0.3 - Computer facilities management
 
activities
2
0
2
-
74
K64.2.0 - Activities of holding companies
64
0
64
-
75
K64.9.1
 
- Financial leasing
3
-
3
-
76
K65.1.2 - Non-life insurance
0
-
0
-
77
K66.1.9 - Other
 
activities auxiliary to financial services, except
 
insurance and pension funding
9
0
9
-
78
L68 - Real estate activities
14
5
14
0
79
L68.1.0 - Buying and selling of own
 
real estate
116
58
116
-
80
L68.2.0 - Renting and operating of own or
 
leased real estate
89
17
89
-
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
71
32
71
-
82
M71.2.0 - Technical testing and analysis
2
0
2
-
83
M74.1.0 - Specialised design activities
0
-
0
-
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
0
0
0
-
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
10
2
10
0
86
N77.3.9
 
- Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
11
2
11
0
87
N81.2.2 - Other building and industrial cleaning activities
2
1
2
-
88
N82 - Office administrative,
 
office support and other
 
business support activities
3
0
3
-
89
Q86.1.0 - Hospital activities
57
0
57
-
90
R92 - Gambling and betting activities
392
-
392
-
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
0
-
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
127
|
Page
 
i
j
k
l
m
n
o
p
2. GAR sector information - Capex
31 December 2024
Breakdown by sector - NACE 4 digits level (code and label)
Water and marine resources (WTR)
Circular economy (CE)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
1
B7 - Mining of metal ores
2
C10.6.1 - Manufacture
 
of grain mill products
3
C11 - Manufacture of beverages
4
C13.9.5 - Manufacture
 
of non-wovens and articles made
 
from non-wovens, except
 
apparel
5
C14.1.3 - Manufacture of other
 
outerwear
6
C15 - Manufacture of leather
 
and related products
7
C17 - Manufacture of paper and paper
 
products
8
C18.1.0 - Printing and service
 
activities related to printing
9
C19 - Manufacture of coke and refined
 
petroleum products
10
C19.2.0 - Manufacture of refined
 
petroleum products
11
C20.1.1 - Manufacture
 
of industrial gases
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
14
C21 - Manufacture of basic pharmaceutical
 
products and pharmaceutical preparations
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
17
C22.2.2 - Manufacture of plastic packing goods
18
C23 - Manufacture of other
 
non-metallic mineral products
19
C24 - Manufacture of basic metals
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
21
C24.2 - Manufacture of tubes, pipes, hollow
 
profiles and related fittings, of steel
22
C24.4.2 - Aluminium production
23
C24.4.4 - Copper production
24
C24.5.1 - Casting of iron
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
26
C27.5.1 - Manufacture
 
of electric domestic appliances
27
C28.9 - Manufacture of
 
other special-purpose machinery
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
30
C33.1.1 - Repair of
 
fabricated metal products
31
C33.1.2 - Repair of machinery
32
D35 - Electricity, gas, steam and air conditioning
 
supply
33
D35.1.1 - Production
 
of electricity
34
D35.1.3 - Distribution of electricity
35
D35.1.4 - Trade of
 
electricity
36
E38.3.2 - Recovery of sorted materials
37
F41.2.0 - Construction of residential and non-residential
 
buildings
38
F42 - Civil engineering
39
F42.2.2 - Construction of utility projects for electricity
 
and telecommunications
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
41
F43.2.9 - Other construction
 
installation
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
43
G45 - Wholesale and retail trade and
 
repair of motor vehicles and motorcycles
44
G45.1.1 - Sale of
 
cars and light motor vehicles
45
G45.1.9 - Sale
 
of other motor vehicles
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
49
G46.4.2 - Wholesale of clothing and footwear
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
52
G46.5.1 - Wholesale of computers,
 
computer peripheral equipment
 
and software
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and parts
54
G46.7 - Other specialised wholesale
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
56
G46.7.2 - Wholesale of
 
metals and metal ores
57
G46.7.7 - Wholesale of
 
waste and scrap
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
59
G47.1.9
 
- Other retail sale in non-specialised stores
60
G47.7.1
 
- Retail sale of clothing in specialised stores
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
62
H49 - Land transport and transport via
 
pipelines
63
H50.1.0 - Sea and coastal passenger
 
water transport
64
H51 - Air transport
65
H52.1 - Warehousing and storage
66
H52.2.1 - Service activities incidental to land
 
transportation
67
H52.2.3 - Service activities incidental to air transportation
68
I55 - Accommodation
69
I55.1.0 - Hotels and similar
 
accommodation
70
J61 - Telecommunications
71
J62.0 - Computer programming, consultancy
 
and related activities
72
J62.0.1 - Computer programming
 
activities
73
J62.0.3 - Computer facilities management
 
activities
74
K64.2.0 - Activities of holding companies
75
K64.9.1
 
- Financial leasing
76
K65.1.2 - Non-life insurance
77
K66.1.9 - Other
 
activities auxiliary to financial services, except
 
insurance and pension funding
78
L68 - Real estate activities
79
L68.1.0 - Buying and selling of own
 
real estate
80
L68.2.0 - Renting and operating of own or
 
leased real estate
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
82
M71.2.0 - Technical testing and analysis
83
M74.1.0 - Specialised design activities
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
86
N77.3.9
 
- Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
87
N81.2.2 - Other building and industrial cleaning activities
88
N82 - Office administrative,
 
office support and other
 
business support activities
89
Q86.1.0 - Hospital activities
90
R92 - Gambling and betting activities
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
REPORT OF THE DIRECTORS / SUSTAINABILITY
 
STATEMENT
 
128
|
Page
 
q
r
s
t
u
v
w
x
y
z
aa
ab
2. GAR sector information - Capex
31 December 2024
Breakdown by sector - NACE
 
4 digits level (code and label)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA
 
+ WTR + CE + PPC + BIO)
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
to NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
to NFRD
Non-Financial corporates
 
(Subject to NFRD)
SMEs and other NFC not subject
 
to
NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable (CCA)
Mn EUR
Of which
environmentally
sustainable
 
(CCM + CCA + WTR +
CE + PPC + BIO)
Mn EUR
Of which
environmentally
sustainable
 
(CCM + CCA + WTR +
CE + PPC + BIO)
1
B7 - Mining of metal ores
16
-
2
C10.6.1 - Manufacture
 
of grain mill products
0
0
3
C11 - Manufacture of beverages
5
0
4
C13.9.5 - Manufacture of non-wovens
 
and articles made from non-wovens, except apparel
1
1
5
C14.1.3 - Manufacture of other
 
outerwear
0
0
6
C15 - Manufacture of leather
 
and related products
2
0
7
C17 - Manufacture of paper and paper
 
products
4
0
8
C18.1.0 - Printing and service
 
activities related to printing
0
-
9
C19 - Manufacture of coke and refined
 
petroleum products
85
23
10
C19.2.0 - Manufacture of refined
 
petroleum products
767
179
11
C20.1.1 - Manufacture
 
of industrial gases
0
-
12
C20.4.2 - Manufacture of perfumes
 
and toilet preparations
30
6
13
C20.5.9 - Manufacture
 
of other chemical products
 
n.e.c.
4
4
14
C21 - Manufacture of basic pharmaceutical products and pharmaceutical preparations
22
-
15
C21.2.0 - Manufacture of pharmaceutical
 
preparations
25
-
16
C22.2.1 - Manufacture of plastic plates,
 
sheets, tubes and profiles
12
0
17
C22.2.2 - Manufacture of plastic packing goods
10
2
18
C23 - Manufacture of other
 
non-metallic mineral products
87
24
19
C24 - Manufacture of basic metals
10
-
20
C24.1.0 - Manufacture of
 
basic iron and steel and of ferro
 
-alloys
85
17
21
C24.2 - Manufacture of tubes, pipes, hollow profiles and related
 
fittings, of steel
8
3
22
C24.4.2 - Aluminium production
52
9
23
C24.4.4 - Copper production
61
4
24
C24.5.1 - Casting of iron
58
10
25
C27.3.2 - Manufacture of other
 
electronic and electric wires and cables
196
73
26
C27.5.1 - Manufacture
 
of electric domestic appliances
1
1
27
C28.9 - Manufacture of
 
other special-purpose machinery
18
-
28
C29 - Manufacture of motor vehicles,
 
trailers and semi-trailers
53
10
29
C29.3.2 - Manufacture of other
 
parts and accessories for motor vehicles
0
0
30
C33.1.1 - Repair of
 
fabricated metal products
9
9
31
C33.1.2 - Repair of machinery
0
0
32
D35 - Electricity, gas, steam and air conditioning
 
supply
297
112
33
D35.1.1 - Production
 
of electricity
1,403
1,360
34
D35.1.3 - Distribution of electricity
355
-
35
D35.1.4 - Trade of
 
electricity
341
-
36
E38.3.2 - Recovery of sorted materials
2
0
37
F41.2.0 - Construction of residential and non-residential
 
buildings
1
-
38
F42 - Civil engineering
42
19
39
F42.2.2 - Construction of utility projects for electricity
 
and
telecommunications
198
198
40
F42.9.9
 
- Construction of other civil engineering
 
projects n.e.c.
19
13
41
F43.2.9 - Other construction
 
installation
21
-
42
F43.9.9
 
- Other specialised construction activities
 
n.e.c.
5
-
43
G45 - Wholesale and retail trade and
 
repair of motor vehicles and
motorcycles
3
1
44
G45.1.1 - Sale of
 
cars and light motor vehicles
1
0
45
G45.1.9 - Sale
 
of other motor vehicles
2
1
46
G45.3.0 - Sale of motor vehicle parts
 
and accessories
4
1
47
G46 - Wholesale trade, except of motor
 
vehicles and motorcycles
1
-
48
G46.3.6 - Wholesale of sugar and chocolate
 
and sugar confectionery
4
-
49
G46.4.2 - Wholesale of clothing and footwear
7
1
50
G46.4.6 - Wholesale of pharmaceutical
 
goods
23
-
51
G46.4.7 - Wholesale of furniture,
 
carpets and lighting equipment
8
-
52
G46.5.1 - Wholesale of computers,
 
computer peripheral equipment
 
and
software
7
1
53
G46.5.2 - Wholesale of electronic and telecommunications
 
equipment and
parts
11
-
54
G46.7 - Other specialised wholesale
1
-
55
G46.7.1
 
- Wholesale of solid, liquid and gaseous fuels
 
and related products
319
187
56
G46.7.2 - Wholesale of
 
metals and metal ores
13
2
57
G46.7.7 - Wholesale of
 
waste and scrap
6
1
58
G47 - Retail trade, except of motor vehicles
 
and motorcycles
0
-
59
G47.1.9
 
- Other retail sale in non-specialised stores
28
14
60
G47.7.1
 
- Retail sale of clothing in specialised stores
12
-
61
G47.7.8
 
- Other retail sale of new goods
 
in specialised stores
1
-
62
H49 - Land transport and transport via
 
pipelines
8
6
63
H50.1.0 - Sea and coastal passenger
 
water transport
0
0
64
H51 - Air transport
25
0
65
H52.1 - Warehousing and storage
1
-
66
H52.2.1 - Service activities incidental to land
 
transportation
21
2
67
H52.2.3 - Service activities incidental to air transportation
402
20
68
I55 - Accommodation
3
-
69
I55.1.0 - Hotels and similar
 
accommodation
40
-
70
J61 - Telecommunications
23
-
71
J62.0 - Computer programming, consultancy
 
and related activities
9
0
72
J62.0.1 - Computer programming
 
activities
2
2
73
J62.0.3 - Computer facilities management
 
activities
2
0
74
K64.2.0 - Activities of holding companies
64
0
75
K64.9.1
 
- Financial leasing
3
-
76
K65.1.2 - Non-life insurance
0
-
77
K66.1.9 - Other activities auxiliary
 
to financial services, except insurance and pension funding
9
0
78
L68 - Real estate activities
14
5
79
L68.1.0 - Buying and selling of own
 
real estate
116
58
80
L68.2.0 - Renting and operating of own or
 
leased real estate
89
17
81
L68.3.2 - Management of real estate on a fee
 
or contract basis
71
32
82
M71.2.0 - Technical testing and analysis
2
0
83
M74.1.0 - Specialised design activities
0
-
84
M74.9.0 - Other
 
professional, scientific and technical
 
activities n.e.c.
0
0
85
N77.1.1
 
- Renting and leasing of cars and light motor vehicles
10
2
86
N77.3.9 - Renting and leasing of other machinery,
 
equipment and tangible goods n.e.c.
11
2
87
N81.2.2 - Other building and industrial cleaning activities
2
1
88
N82 - Office administrative, office support and other business
 
support activities
3
0
89
Q86.1.0 - Hospital activities
57
0
90
R92 - Gambling and betting activities
392
-
91
S95.1.1 - Repair of
 
computers and peripheral
 
equipment
0
0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
129
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Turnover
 
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
 
assets in the
denominator)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
59.5
6.6
4.9
0.1
0.5
0.4
0.0
-
0.0
0.0
-
-
-
0.0
-
-
-
2
Financial corporations
 
25.3
2.9
-
0.2
0.4
0.4
0.0
-
0.0
-
-
-
-
0.0
-
-
-
3
Credit institutions
26.4
2.8
-
0.2
0.4
0.3
0.0
-
0.0
-
-
-
-
-
-
-
-
4
Loans and advances
24.0
3.9
-
0.1
0.1
0.1
0.0
-
0.0
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
27.1
2.5
-
0.3
0.5
0.4
0.0
-
0.0
-
-
-
-
-
-
-
-
6
Equity instruments
19.7
1.5
0.1
0.1
0.6
0.0
-
-
-
-
-
-
-
7
Other financial corporations
12.9
4.1
-
0.0
0.5
1.6
0.0
-
-
-
-
-
-
0.1
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
37.5
0.2
-
0.0
0.0
0.8
0.8
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
37.5
0.2
-
0.0
0.0
0.8
0.8
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
37.2
28.5
22.5
0.1
2.0
1.7
0.0
-
0.0
0.0
-
-
-
0.2
-
-
-
21
Loans and advances
38.5
31.0
25.5
0.0
1.5
1.5
0.0
-
0.0
-
-
-
-
0.2
-
-
-
22
Debt securities, including UoP
27.6
10.1
-
0.6
5.6
3.1
0.0
-
0.0
0.0
-
-
-
0.5
-
-
-
23
Equity instruments
20.0
7.9
-
0.9
4.9
0.0
-
-
-
-
0.0
-
-
24
Households
75.1
0.1
0.1
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
100.0
0.2
0.2
-
-
-
-
-
-
-
-
-
-
26
of which building renovation loans
100.0
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
100.0
0.8
0.8
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
74.6
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
24.3
2.6
1.9
0.0
0.2
0.2
0.0
-
0.0
-
-
-
-
0.0
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
130
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Turnover
 
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered
 
assets in the
denominator)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM
 
+ CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
0.0
-
-
-
0.1
-
-
-
60.2
6.6
4.9
0.1
0.5
39.6
2
Financial corporations
 
-
-
-
-
-
-
-
-
26.0
3.0
-
0.2
0.4
6.0
3
Credit institutions
-
-
-
-
-
-
-
-
27.0
2.9
-
0.2
0.4
5.5
4
Loans and advances
-
-
-
-
-
-
-
-
24.5
4.0
-
0.1
0.1
1.3
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
27.8
2.5
-
0.3
0.5
4.2
6
Equity instruments
-
-
-
-
-
-
20.2
1.5
0.1
0.1
0.0
7
Other financial corporations
-
-
-
-
-
-
-
-
14.6
4.1
-
0.0
0.3
0.5
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
38.3
1.0
-
0.0
0.0
0.0
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
38.3
1.0
-
0.0
0.0
0.0
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
0.1
-
-
-
0.7
-
-
-
39.9
28.6
22.5
0.1
2.0
8.4
21
Loans and advances
0.0
-
-
-
0.7
-
-
-
40.9
31.0
25.5
0.0
1.6
7.4
22
Debt securities, including UoP
1.2
-
-
-
0.0
-
-
-
32.4
10.2
-
0.6
5.6
1.0
23
Equity instruments
-
-
-
-
-
-
25.0
7.9
-
0.9
0.0
24
Households
75.1
0.1
0.1
-
-
25.2
25
of which loans collateralised by residential
immovable property
100.0
0.2
0.2
-
-
16.9
26
of which building renovation loans
100.0
-
-
-
-
2.9
27
of which motor vehicle loans
100.0
0.8
0.8
-
-
0.8
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
-
-
-
-
-
-
-
-
74.6
-
-
-
-
1.0
32
Total GAR assets
0.0
-
-
-
0.1
-
-
-
24.6
2.6
1.9
0.0
0.2
100.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
131
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Capex
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
 
assets in the
denominator)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
65.1
9.2
4.9
0.2
1.4
0.2
0.0
-
0.0
-
-
-
-
0.0
-
-
-
2
Financial corporations
 
28.7
4.5
-
0.2
0.7
0.3
0.0
-
0.0
-
-
-
-
0.0
-
-
-
3
Credit institutions
25.6
3.6
-
0.2
0.6
0.4
0.0
-
0.0
-
-
-
-
-
-
-
-
4
Loans and advances
19.9
3.9
-
0.1
0.1
0.1
0.0
-
0.0
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
27.4
3.4
-
0.3
0.8
0.4
0.0
-
0.0
-
-
-
-
-
-
-
-
6
Equity instruments
22.1
3.2
0.1
0.2
0.5
0.0
-
-
-
-
-
-
-
7
Other financial corporations
64.3
15.1
-
0.2
1.7
0.0
0.0
-
-
-
-
-
-
0.0
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
37.3
0.3
-
0.0
0.0
0.8
0.8
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
37.3
0.3
-
0.0
0.0
0.8
0.8
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
60.9
39.6
22.5
0.7
5.9
0.8
0.1
-
0.0
-
-
-
-
0.1
-
-
-
21
Loans and advances
60.8
41.2
25.5
0.3
5.3
0.7
0.1
-
0.0
-
-
-
-
0.1
-
-
-
22
Debt securities, including UoP
62.1
27.9
-
3.8
10.5
1.2
0.0
-
0.0
0.0
-
-
-
0.4
-
-
-
23
Equity instruments
37.4
26.2
0.1
2.1
3.5
-
-
-
-
-
0.0
-
-
24
Households
75.1
0.1
0.1
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
100.0
0.2
0.2
-
-
-
-
-
-
-
-
-
-
26
of which building renovation loans
100.0
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
100.0
0.8
0.8
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
74.6
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
26.5
3.6
1.9
0.1
0.5
0.1
0.0
-
0.0
-
-
-
-
0.0
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
132
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Capex
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered
 
assets in the
denominator)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM
 
+ CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
0.1
-
-
-
0.1
-
-
-
65.6
9.2
4.9
0.2
1.4
39.6
2
Financial corporations
 
-
-
-
-
-
-
-
-
29.3
4.5
-
0.2
0.7
6.0
3
Credit institutions
-
-
-
-
-
-
-
-
26.2
3.6
-
0.2
0.6
5.5
4
Loans and advances
-
-
-
-
-
-
-
-
20.3
4.0
-
0.1
0.1
1.3
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
28.1
3.4
-
0.3
0.8
4.2
6
Equity instruments
-
-
-
-
-
-
22.8
3.2
0.1
0.2
0.0
7
Other financial corporations
-
-
-
-
-
-
-
-
64.3
15.1
-
0.1
1.4
0.5
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
38.1
1.1
-
0.0
0.0
0.0
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
38.1
1.1
-
0.0
0.0
0.0
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
0.3
-
-
-
0.7
-
-
-
62.7
39.7
22.5
0.7
5.9
8.4
21
Loans and advances
0.2
-
-
-
0.7
-
-
-
62.5
41.3
25.5
0.3
5.4
7.4
22
Debt securities, including UoP
0.6
-
-
-
0.0
-
-
-
64.4
27.9
-
3.8
10.6
1.0
23
Equity instruments
-
-
-
-
-
-
40.9
26.2
0.1
2.1
0.0
24
Households
75.1
0.1
0.1
-
-
25.2
25
of which loans collateralised by residential
immovable property
100.0
0.2
0.2
-
-
16.9
26
of which building renovation loans
100.0
-
-
-
-
2.9
27
of which motor vehicle loans
100.0
0.8
0.8
-
-
0.8
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
-
-
-
-
-
-
-
-
74.6
-
-
-
-
1.0
32
Total GAR assets
0.0
-
-
-
0.1
-
-
-
26.7
3.7
1.9
0.1
0.5
100.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
133
|
Page
 
€ = Euro
 
m = million
 
bn = billion
4. GAR KPI flow - Turnover
 
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total eligible assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
53.5
11.9
5.8
0.0
1.4
1.6
0.1
-
0.1
0.0
-
-
-
0.1
-
-
-
2
Financial corporations
 
21.1
1.1
-
0.1
0.1
0.3
0.0
-
0.0
-
-
-
-
-
-
-
-
3
Credit institutions
21.1
1.1
-
0.1
0.1
0.3
0.0
-
0.0
-
-
-
-
-
-
-
-
4
Loans and advances
1.4
0.6
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
21.3
1.1
-
0.1
0.1
0.3
0.0
-
0.0
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
30.8
23.3
12.0
-
2.9
3.1
0.2
-
0.1
0.0
-
-
-
0.2
-
-
-
21
Loans and advances
30.5
24.7
13.3
-
2.3
2.7
0.2
-
0.1
0.0
-
-
-
0.2
-
-
-
22
Debt securities, including UoP
33.3
10.3
0.0
-
8.3
7.0
0.4
-
0.4
-
-
-
-
0.0
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Households
100.0
0.9
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
100.0
1.2
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
26
of which building renovation loans
100.0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
100.0
0.8
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
82.8
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
16.8
3.7
1.8
0.0
0.4
0.5
0.0
-
0.0
0.0
-
-
-
0.0
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
134
|
Page
 
€ = Euro
 
m = million
 
bn = billion
4. GAR KPI flow - Turnover
 
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM
 
+ CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
0.2
-
-
-
-
-
-
-
55.3
12.0
5.8
0.0
1.5
31.3
2
Financial corporations
 
-
-
-
-
-
-
-
-
21.3
1.1
-
0.1
0.1
5.0
3
Credit institutions
-
-
-
-
-
-
-
-
21.4
1.1
-
0.1
0.1
5.0
4
Loans and advances
-
-
-
-
-
-
-
-
1.4
0.6
-
-
-
0.0
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
21.5
1.1
-
0.1
0.1
5.0
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
0.3
-
-
-
-
-
-
-
34.3
23.5
12.0
-
3.0
15.3
21
Loans and advances
0.0
-
-
-
-
-
-
-
33.4
24.9
13.3
-
2.4
13.8
22
Debt securities, including UoP
3.3
-
-
-
-
-
-
-
43.6
10.7
0.0
-
8.7
1.5
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
24
Households
-
-
-
-
-
-
-
-
100.0
0.9
-
-
-
11.0
25
of which loans collateralised by residential
immovable property
-
-
-
-
-
-
-
-
100.0
1.2
-
-
-
7.9
26
of which building renovation loans
-
-
-
-
-
-
-
-
100.0
-
-
-
-
1.4
27
of which motor vehicle loans
-
-
-
-
-
-
-
-
100.0
0.8
-
-
-
1.3
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
-
-
-
-
-
-
-
-
82.8
-
-
-
-
0.1
32
Total GAR assets
0.0
-
-
-
-
-
-
-
17.4
3.7
1.8
0.0
0.5
100.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
135
|
Page
 
€ = Euro
 
m = million
 
bn = billion
4. GAR KPI flow - Capex
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total eligible assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
67.1
20.6
5.8
0.1
4.7
0.5
0.2
-
0.1
-
-
-
-
0.0
-
-
-
2
Financial corporations
 
19.5
2.0
-
0.2
0.1
0.2
0.0
-
0.0
-
-
-
-
-
-
-
-
3
Credit institutions
19.6
2.0
-
0.2
0.1
0.2
0.0
-
0.0
-
-
-
-
-
-
-
-
4
Loans and advances
1.8
1.2
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
19.7
2.0
-
0.2
0.1
0.2
0.0
-
0.0
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
59.1
40.8
12.0
0.2
9.6
0.9
0.3
-
0.2
-
-
-
-
0.0
-
-
-
21
Loans and advances
59.6
42.5
13.3
0.1
9.1
0.5
0.2
-
0.1
-
-
-
-
0.0
-
-
-
22
Debt securities, including UoP
54.7
25.4
-
0.3
13.8
4.4
1.5
-
1.5
-
-
-
-
0.0
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Households
100.0
0.9
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
100.0
1.2
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
26
of which building renovation loans
100.0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
100.0
0.8
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
82.8
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
21.1
6.4
1.8
0.0
1.5
0.2
0.0
-
0.0
-
-
-
-
0.0
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
136
|
Page
 
€ = Euro
 
m = million
 
bn = billion
4. GAR KPI flow - Capex
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM
 
+ CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total
assets covered
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
0.3
-
-
-
-
-
-
-
67.9
20.8
5.8
0.1
4.8
31.3
2
Financial corporations
 
-
-
-
-
-
-
-
-
19.9
2.0
-
0.2
0.1
5.0
3
Credit institutions
-
-
-
-
-
-
-
-
19.9
2.0
-
0.2
0.1
5.0
4
Loans and advances
-
-
-
-
-
-
-
-
1.8
1.2
-
-
-
0.0
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
20.1
2.0
-
0.2
0.2
5.0
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
0.5
-
-
-
-
-
-
-
60.6
41.2
12.0
0.2
9.8
15.3
21
Loans and advances
0.5
-
-
-
-
-
-
-
60.6
42.7
13.3
0.1
9.2
13.8
22
Debt securities, including UoP
1.2
-
-
-
-
-
-
-
60.4
27.0
-
0.3
15.3
1.5
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
24
Households
-
-
-
-
-
-
-
-
100.0
0.9
-
-
-
11.0
25
of which loans collateralised by residential
immovable property
-
-
-
-
-
-
-
-
100.0
1.2
-
-
-
7.9
26
of which building renovation loans
-
-
-
-
-
-
-
-
100.0
-
-
-
-
1.4
27
of which motor vehicle loans
-
-
-
-
-
-
-
-
100.0
0.8
-
-
-
1.3
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
 
-
-
-
-
-
-
-
-
82.8
-
-
-
-
0.1
32
Total GAR assets
0.1
-
-
-
-
-
-
-
21.3
6.5
1.8
0.0
1.5
100.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
137
|
Page
 
€ = Euro
 
m = million
 
bn = billion
5. KPI off-balance sheet
 
exposures-
 
Stock-
 
Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources
 
(WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
12.0
4.6
-
0.0
0.4
2.1
0.1
-
0.1
-
-
-
-
0.1
-
-
-
2
Assets under management
7.7
1.1
-
0.1
0.3
0.5
0.0
-
0.0
0.0
-
-
-
0.0
-
-
-
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.0
-
-
-
-
-
-
-
14.2
4.7
-
0.0
0.5
2
Assets under management
0.1
-
-
-
0.0
-
-
-
8.3
1.1
-
0.1
0.3
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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|
Page
 
€ = Euro
 
m = million
 
bn = billion
5. KPI off-balance sheet
 
exposures-
 
Stock-
 
Capex
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources
 
(WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
24.7
15.6
-
0.1
1.5
0.9
0.1
-
1.5
-
-
-
-
0.1
-
-
-
2
Assets under management
11.0
2.8
-
0.3
0.7
0.2
0.0
-
0.0
0.0
-
-
-
0.0
-
-
-
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.0
-
-
-
-
-
-
-
25.7
15.7
-
0.1
3.0
2
Assets under management
0.1
-
-
-
0.0
-
-
-
11.5
2.9
-
0.3
0.7
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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|
Page
 
€ = Euro
 
m = million
 
bn = billion
5. KPI off-balance sheet
 
exposures-
 
Flow-
 
Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources
 
(WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
5.2
1.8
-
0.0
0.3
1.6
0.0
-
-
-
-
-
-
0.0
-
-
-
2
Assets under management
22.8
3.2
-
0.2
1.2
1.5
0.1
-
0.0
0.0
-
-
-
0.5
-
-
-
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.0
-
-
-
0.0
-
-
-
6.8
1.8
-
0.0
0.3
2
Assets under management
0.2
-
-
-
0.0
-
-
-
25.1
3.3
-
0.2
1.2
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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140
|
Page
 
€ = Euro
 
m = million
 
bn = billion
5. KPI off-balance sheet
 
exposures-
 
Flow-
 
Capex
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources
 
(WTR)
Circular economy (CE)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
12.2
6.9
-
0.1
1.3
0.2
0.0
-
-
-
-
-
-
-
-
-
-
2
Assets under management
34.4
9.0
-
0.9
2.4
0.6
0.1
-
0.0
0.0
-
-
-
0.2
-
-
-
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
 
-balance
sheet assets)
31 December 2024
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL
 
(CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
 
sectors
(Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy relevant
sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets
funding taxonomy relevant
sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.0
-
-
-
0.0
-
-
-
12.5
6.9
-
0.1
1.3
2
Assets under management
0.1
-
-
-
0.0
-
-
-
35.5
9.2
-
0.9
2.4
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Template 1
 
Nuclear and fossil gas related activities for
 
2024
 
Row
Nuclear energy related activities
1.
The undertaking carries
 
out, funds or has exposures to research, development,
 
demonstration and
deployment of innovative electricity generation
 
facilities that produce
 
energy from nuclear
processes with minimal waste from the
 
fuel cycle.
YES
2.
The undertaking carries
 
out, funds or has exposures to construction and safe
operation of new
 
nuclear installations to produce electricity or process
 
heat,
including for the purposes of district heating or industrial processes
 
such as
hydrogen production,
 
as well as their safety upgrades,
 
using best available
technologies.
YES
3.
The undertaking carries
 
out, funds or has exposures to safe operation
 
of existing
nuclear installations that produce electricity or process
 
heat, including for the
purposes of district heating or industrial processes such as hydrogen
 
production
from nuclear energy,
 
as well as their safety upgrades.
YES
Fossil gas related activities
4.
The undertaking carries
 
out, funds or has exposures to construction or operation
of electricity generation facilities
 
that produce electricity using fossil
 
gaseous
fuels
YES
5.
The undertaking carries
 
out, funds or has exposures to construction, refurbishment,
and operation of combined heat/cool
 
and power generation
 
facilities using fossil
gaseous fuels.
YES
6.
The undertaking carries
 
out, funds or has exposures to construction, refurbishment
and operation of heat
 
generation facilities
 
that produce heat/cool
 
using fossil gaseous
fuels.
YES
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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m = million
 
bn = billion
Turnover KPI Tables
 
for 2024
Template 2 - Taxonomy
 
-aligned economic activities (denominator)
Row
Economic activities
Amount (in Million EUR) and proportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.26 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
0
0.0
0
0.0
-
-
2.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.27 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
3
0.0
3
0.0
-
-
3.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.28 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
110
0.2
110
0.2
-
-
4.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.29 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
5.
Amount and proportion of taxonomy-aligned economic activity EN
 
3 EN
referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
2
0.0
1
0.0
1
0.0
6.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.31 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
 
1,793
2.5
1,791
2.5
2
0.0
8.
Total applicable KPI
 
1,908
2.6
1,905
2.6
3
0.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
143
|
Page
 
€ = Euro
 
m = million
 
bn = billion
Template 3 -Taxonomy
 
-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.26 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the numerator of the applicable KPI
 
0
0.0
0
0.0
-
-
2.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.27 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
3
0.2
3
0.2
-
-
3.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.28 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
110
5.8
110
5.8
-
-
4.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.29 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
5.
Amount and proportion of taxonomy-aligned economic activity EN
 
3 EN
referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
2
0.1
1
0.0
1
0.1
6.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.31 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
 
1,793
94.0
1,791
93.9
2
0.1
8.
Total amount and proportion of taxonomy-aligned economic
activities in the numerator of the applicable KPI
 
1,908
100.0
1,905
99.8
3
0.2
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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|
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€ = Euro
 
m = million
 
bn = billion
Template 4 - Taxonomy
 
-eligible but not taxonomy-aligned economic activities
 
Row
Economic activities
Amount (in Million EUR) and proportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
1
0.0
1
0.0
-
-
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
9
0.0
9
0.0
-
-
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
11
0.0
7
0.0
-
-
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
176
0.2
164
0.2
-
-
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
94
0.1
60
0.1
1
0.0
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.31 of Annexes I and II to
Delegated EN 6 EN Regulation 2021/2139 in the denominator of
 
the
applicable KPI
1
0.0
1
0.0
-
-
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-
aligned economic activities not referred to in rows 1 to 6 above in the
denominator of the applicable KPI
 
15,593
21.4
15,523
21.3
119
0.2
8.
Total amount and proportion of taxonomy eligible but not taxonomy-
aligned economic activities in the denominator of the applicable KPI
 
15,885
21.8
15,765
21.7
120
0.2
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
145
|
Page
 
€ = Euro
 
m = million
 
bn = billion
Template 5 - Taxonomy
 
non-eligible economic activities
 
Row
Economic activities
Amount
(in Million
EUR)
%
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
 
-
-
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to
 
Delegated Regulation 2021/2139 in the
denominator of EN 7 EN the applicable KPI
-
-
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to
 
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
 
-
-
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
54,970
75.5
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
 
54,970
75.5
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
146
|
Page
 
€ = Euro
 
m = million
 
bn = billion
CapexKPI Tables for 2024
Template 2 - Taxonomy
 
-aligned economic activities (denominator)
Row
Economic activities
Amount (in Million EUR) and proportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.26 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
0.01
-
0.01
-
-
-
2.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.27 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
60
0.1
60
0.1
-
-
3.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.28 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
26
0.0
26
0.0
-
-
4.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.29 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
12.54
0.0
12.54
0.0
-
-
5.
Amount and proportion of taxonomy-aligned economic activity EN
 
3 EN
referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0.00
-
0.00
-
-
-
6.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.31 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
 
2,561
3.5
2,555
3.5
5
0.0
8.
Total applicable KPI
 
2,658
3.7
2,653
3.6
5
0.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
147
|
Page
 
€ = Euro
 
m = million
 
bn = billion
Template 3 -Taxonomy
 
-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.26 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the numerator of the applicable KPI
 
0.0
0.0
0.0
0.0
-
-
2.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.27 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
60
2.2
60
2.2
-
-
3.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.28 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
 
26
1.0
26
1.0
-
-
4.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.29 of Annexes I and II
 
to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
12.5
0.5
12.5
0.5
-
-
5.
Amount and proportion of taxonomy-aligned economic activity EN
 
3 EN
referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0.0
0.0
0.0
0.0
-
-
6.
Amount and proportion of taxonomy-aligned economic activity referred
to in Section 4.31 of Annexes I and
 
II to Delegated Regulation 2021/2139
in the denominator of the applicable KPI
-
-
-
-
-
-
7.
Amount and proportion of other taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
 
2,561
96.3
2,555
96.1
5
0.2
8.
Total amount and proportion of taxonomy-aligned economic
activities in the numerator of the applicable KPI
 
2,658
100.0
2,653
99.8
5
0.2
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
148
|
Page
 
€ = Euro
 
m = million
 
bn = billion
Template 4 - Taxonomy
 
-eligible but not taxonomy-aligned economic activities
 
Row
Economic activities
Amount (in Million EUR) and Pproportion
 
(the information is to be presented in monetary amounts and as
percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
0
-
0
-
-
-
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
-
-
-
-
-
-
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
0
-
0
-
-
-
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
100
0.1
100
0.1
0
0.0
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable
KPI
47
0.1
47
0.1
-
-
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned
economic activity referred to in Section 4.31 of Annexes I and II to
Delegated EN 6 EN Regulation 2021/2139 in the denominator of
 
the
applicable KPI
1
0.0
1
0.0
-
-
7.
Amount and proportion of other taxonomy-eligible but not
taxonomy-aligned economic activities not referred to in rows 1 to 6
above in the denominator of the applicable KPI
 
16,527
22.7
16,471
22.6
55
0.1
8.
Total amount and proportion of taxonomy eligible but not taxonomy-
aligned economic activities in the denominator of the applicable KPI
 
16,675
22.9
16,619
22.8
55
0.1
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
149
|
Page
 
€ = Euro
 
m = million
 
bn = billion
Template 5 - Taxonomy
 
non-eligible economic activities
 
Row
Economic activities
Amount
(in Million
EUR)
%
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
 
-
-
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated
 
Regulation 2021/2139 in the
denominator of the applicable KPI
-
-
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to
 
Delegated Regulation 2021/2139 in the
denominator of EN 7 EN the applicable KPI
-
-
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to
 
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
 
-
-
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
53,429
73.4
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
 
53,429
73.4
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
150
|
Page
 
€ = Euro
 
m = million
 
bn = billion
1.Assets for the
 
calculation of GAR - Turnover
Million EUR
Total [gross]
carrying
amount
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant
sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which environmentally
 
sustainable (Taxonomy
 
-aligned)
Of which environmentally
sustainable (Taxonomy
 
-aligned)
Of which environmentally sustainable
 
(Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
GAR- Covered assets in both
 
numerator and
denominator
1
Loans and advances, debt securities and
 
equity
instruments no HfT eligible for
 
GAR calculation
 
21,065
 
 
11,393
 
 
1,474
 
 
1,327
 
 
9
 
 
62
 
 
173
 
 
10
 
 
-
 
 
1
 
 
12,015
 
 
1,484
 
 
1,327
 
 
9
 
 
63
 
2
Financial undertakings
 
2,519
 
 
9
 
 
4
 
 
-
 
 
0
 
 
0
 
 
5
 
 
-
 
 
-
 
 
-
 
 
463
 
 
4
 
 
-
 
 
0
 
 
0
 
3
Credit institutions
 
2,447
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
446
 
 
-
 
 
-
 
 
-
 
 
-
 
4
 
Loans and advances
 
987
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
169
 
 
-
 
 
-
 
 
-
 
 
-
 
5
 
Debt securities, including UoP
 
1,451
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
275
 
 
-
 
 
-
 
 
-
 
 
-
 
6
 
Equity instruments
 
9
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
7
Other financial corporations
 
71
 
 
9
 
 
4
 
 
-
 
 
0
 
 
0
 
 
5
 
 
-
 
 
-
 
 
-
 
 
18
 
 
4
 
 
-
 
 
0
 
 
0
 
8
 
of which investment firms
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
9
Loans and advances
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
10
Debt securities, including UoP
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
11
Equity instruments
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
12
of which management companies
 
14
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
13
 
Loans and advances
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
14
 
Debt securities, including UoP
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
15
 
Equity instruments
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
0
 
 
-
 
 
-
 
 
-
 
16
of which insurance undertakings
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
2
 
 
-
 
 
-
 
 
-
 
 
-
 
17
Loans and advances
 
0
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
0
 
 
-
 
 
-
 
 
-
 
 
-
 
18
Debt securities, including UoP
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
2
 
 
-
 
 
-
 
 
-
 
 
-
 
19
Equity instruments
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
20
Non-financial undertakings
 
5,016
 
 
1,794
 
 
1,434
 
 
1,291
 
 
9
 
 
62
 
 
167
 
 
10
 
 
-
 
 
1
 
 
1,961
 
 
1,444
 
 
1,291
 
 
9
 
 
63
 
21
 
Loans and advances
 
4,286
 
 
1,663
 
 
1,377
 
 
1,291
 
 
2
 
 
56
 
 
95
 
 
1
 
 
-
 
 
-
 
 
1,758
 
 
1,378
 
 
1,291
 
 
2
 
 
56
 
22
 
Debt securities, including UoP
 
721
 
 
126
 
 
57
 
 
-
 
 
6
 
 
5
 
 
72
 
 
9
 
 
-
 
 
1
 
 
198
 
 
66
 
 
-
 
 
6
 
 
6
 
23
 
Equity instruments
 
9
 
 
5
 
 
0
 
 
0
 
 
0
 
 
0
 
 
-
 
 
-
 
 
5
 
 
0
 
 
0
 
 
0
 
24
Households
 
13,512
 
 
9,590
 
 
36
 
 
36
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
9,590
 
 
36
 
 
36
 
 
-
 
 
-
 
25
of which loans collateralised
 
by residential
immovable property
 
9,162
 
 
9,162
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
9,162
 
 
-
 
 
-
 
 
-
 
 
-
 
26
of which
 
building renovation loans
 
36
 
 
36
 
 
36
 
 
36
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
36
 
 
36
 
 
36
 
 
-
 
 
-
 
27
of which motor vehicle loans
 
392
 
 
392
 
 
-
 
 
-
 
 
-
 
 
-
 
 
392
 
 
-
 
 
-
 
 
-
 
 
-
 
28
Local governments financing
 
18
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
29
Housing financing
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
30
Other local govemment
 
financing
 
18
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
31
Collateral obtained
 
by taking possession:
residential and commercial immovable
properties
 
590
 
 
590
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
590
 
 
-
 
 
-
 
 
-
 
 
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
151
|
Page
 
€ = Euro
 
m = million
 
bn = billion
1.Assets for the
 
calculation of GAR - Turnover
Million EUR
Total [gross]
carrying
amount
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant
sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which environmentally
 
sustainable (Taxonomy
 
-aligned)
Of which environmentally
sustainable (Taxonomy
 
-aligned)
Of which environmentally sustainable
 
(Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
32
Assets excluded from the numerator
 
for GAR
calculation (covered
 
in the denominator)
 
38,795
 
33
Financial and Non-financial undertakings
 
28,901
 
34
SMEs and NFCs (other
 
than SMEs) not subject to
NFRD disclosure obligations
 
23,799
 
35
 
Loans and advances
 
21,576
 
36
of which loans collateralised
 
by commercial
immovable property
 
7,074
 
37
of which building renovation
 
loans
 
-
 
38
 
Debt securities
 
2,038
 
39
 
Equity instruments
 
185
 
40
Non-EU country counterparties not
 
subject to
NFRD disclosure obligations
 
5,102
 
41
 
Loans and advances
 
4,732
 
42
 
Debt securities
 
321
 
43
 
Equity instruments
 
49
 
44
Derivatives
 
897
 
45
On demand interbank loans
 
19
 
46
Cash and cash-related assets
 
502
 
47
Other categories of assets (e.g. goodwill,
commodities etc.)
 
8,476
 
48
Total GAR
 
assets
 
60,449
 
 
11,983
 
 
1,474
 
 
1,327
 
 
9
 
 
62
 
 
173
 
 
10
 
 
-
 
 
1
 
 
12,605
 
 
1,484
 
 
1,327
 
 
9
 
 
63
 
49
Assets not covered for
 
GAR calculation
 
20,715
 
50
Central governments
 
and Supranational
issuers
 
9,914
 
51
Central banks exposure
 
10,422
 
52
Trading book
 
379
 
53
Total assets
 
81,165
 
 
11,983
 
 
1,474
 
 
1,327
 
 
9
 
 
62
 
 
173
 
 
10
 
 
-
 
 
1
 
 
12,605
 
 
1,484
 
 
1,327
 
 
9
 
 
63
 
Off-balance sheet exposures
 
-Undertakings subject to
 
NFRD disclosure obligations
54
Financial guarantees
 
796
 
 
360
 
 
44
 
 
-
 
 
3
 
 
4
 
 
28
 
 
0
 
 
-
 
 
0
 
 
387
 
 
44
 
 
-
 
 
3
 
 
4
 
55
Assets under management
 
866
 
 
142
 
 
21
 
 
-
 
 
3
 
 
7
 
 
27
 
 
2
 
 
-
 
 
0
 
 
169
 
 
24
 
 
-
 
 
3
 
 
7
 
56
Of which debt securities
 
 
629
 
 
107
 
 
10
 
 
-
 
 
1
 
 
1
 
 
13
 
 
1
 
 
-
 
 
0
 
 
120
 
 
11
 
 
-
 
 
1
 
 
1
 
57
Of which equity instruments
 
237
 
 
35
 
 
11
 
 
-
 
 
2
 
 
6
 
 
14
 
 
1
 
 
-
 
 
0
 
 
49
 
 
13
 
 
-
 
 
2
 
 
6
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
152
|
Page
 
€ = Euro
 
m = million
 
bn = billion
1.Assets for the
 
calculation of GAR - Capex
Million EUR
Total [gross]
carrying
amount
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors
(Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which environmentally
 
sustainable (Taxonomy
 
-aligned)
Of which environmentally sustainable
(Taxonomy
 
-aligned)
Of which environmentally sustainable
 
(Taxonomy-
aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
GAR- Covered assets in both
 
numerator and
denominator
1
Loans and advances, debt securities and
 
equity
instruments no HfT eligible for
 
GAR calculation
 
21,065
 
 
12,469
 
 
2,081
 
 
1,327
 
 
26
 
 
78
 
 
333
 
 
7
 
 
-
 
 
1
 
 
13,251
 
 
2,088
 
 
1,327
 
 
26
 
 
79
 
2
Financial undertakings
 
2,519
 
 
19
 
 
18
 
 
-
 
 
1
 
 
0
 
 
4
 
 
-
 
 
-
 
 
-
 
 
472
 
 
18
 
 
-
 
 
1
 
 
0
 
3
Credit institutions
 
2,447
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
446
 
 
-
 
 
-
 
 
-
 
 
-
 
4
 
Loans and advances
 
987
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
169
 
 
-
 
 
-
 
 
-
 
 
-
 
5
 
Debt securities, including UoP
 
1,451
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
275
 
 
-
 
 
-
 
 
-
 
 
-
 
6
 
Equity instruments
 
9
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
7
Other financial corporations
 
71
 
 
19
 
 
18
 
 
-
 
 
1
 
 
0
 
 
4
 
 
-
 
 
-
 
 
-
 
 
26
 
 
18
 
 
-
 
 
1
 
 
0
 
8
 
of which investment firms
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
9
Loans and advances
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
10
Debt securities, including UoP
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
11
Equity instruments
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
12
of which management companies
 
14
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
13
 
Loans and advances
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
14
 
Debt securities, including UoP
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
15
 
Equity instruments
 
1
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
0
 
 
-
 
 
-
 
 
-
 
16
of which insurance undertakings
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
2
 
 
-
 
 
-
 
 
-
 
 
-
 
17
Loans and advances
 
0
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
0
 
 
-
 
 
-
 
 
-
 
 
-
 
18
Debt securities, including UoP
 
12
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
2
 
 
-
 
 
-
 
 
-
 
 
-
 
19
Equity instruments
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
20
Non-financial undertakings
 
5,016
 
 
2,860
 
 
2,027
 
 
1,291
 
 
25
 
 
78
 
 
329
 
 
7
 
 
-
 
 
1
 
 
3,189
 
 
2,034
 
 
1,291
 
 
25
 
 
78
 
21
 
Loans and advances
 
4,286
 
 
2,498
 
 
1,811
 
 
1,291
 
 
3
 
 
67
 
 
247
 
 
1
 
 
-
 
 
-
 
 
2,745
 
 
1,811
 
 
1,291
 
 
3
 
 
67
 
22
 
Debt securities, including UoP
 
721
 
 
357
 
 
216
 
 
-
 
 
21
 
 
11
 
 
82
 
 
6
 
 
-
 
 
1
 
 
440
 
 
222
 
 
-
 
 
21
 
 
11
 
23
 
Equity instruments
 
9
 
 
5
 
 
1
 
 
0
 
 
0
 
 
0
 
 
-
 
 
-
 
 
5
 
 
1
 
 
0
 
 
0
 
24
Households
 
13,512
 
 
9,590
 
 
36
 
 
36
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
9,590
 
 
36
 
 
36
 
 
-
 
 
-
 
25
of which loans collateralised
 
by residential
immovable property
 
9,162
 
 
9,162
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
9,162
 
 
-
 
 
-
 
 
-
 
 
-
 
26
of which
 
building renovation loans
 
36
 
 
36
 
 
36
 
 
36
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
36
 
 
36
 
 
36
 
 
-
 
 
-
 
27
of which motor vehicle loans
 
392
 
 
392
 
 
-
 
 
-
 
 
-
 
 
-
 
 
392
 
 
-
 
 
-
 
 
-
 
 
-
 
28
Local governments financing
 
18
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
29
Housing financing
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
153
|
Page
 
€ = Euro
 
m = million
 
bn = billion
1.Assets for the
 
calculation of GAR - Capex
Million EUR
Total [gross]
carrying
amount
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors
(Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which environmentally
 
sustainable (Taxonomy
 
-aligned)
Of which environmentally sustainable
(Taxonomy
 
-aligned)
Of which environmentally sustainable
 
(Taxonomy-
aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
30
Other local govemment
 
financing
 
18
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
31
Collateral obtained
 
by taking possession:
residential and commercial immovable
properties
 
590
 
 
590
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
-
 
 
590
 
 
-
 
 
-
 
 
-
 
 
-
 
32
Assets excluded from the numerator
 
for GAR
calculation (covered
 
in the denominator)
 
38,795
 
33
Financial and Non-financial undertakings
 
28,901
 
34
SMEs and NFCs (other
 
than SMEs) not subject to
NFRD disclosure obligations
 
23,799
 
35
 
Loans and advances
 
21,576
 
36
of which loans collateralised
 
by commercial
immovable property
 
7,074
 
37
of which building renovation
 
loans
 
-
 
38
 
Debt securities
 
2,038
 
39
 
Equity instruments
 
185
 
40
Non-EU country counterparties not
 
subject to
NFRD disclosure obligations
 
5,102
 
41
 
Loans and advances
 
4,732
 
42
 
Debt securities
 
321
 
43
 
Equity instruments
 
49
 
44
Derivatives
 
897
 
45
On demand interbank loans
 
19
 
46
Cash and cash-related assets
 
502
 
47
Other categories of assets (e.g. goodwill,
commodities etc.)
 
8,476
 
48
Total GAR
 
assets
 
60,449
 
 
13,059
 
 
2,081
 
 
1,327
 
 
26
 
 
78
 
 
333
 
 
7
 
 
-
 
 
1
 
 
13,841
 
 
2,088
 
 
1,327
 
 
26
 
 
79
 
49
Assets not covered for
 
GAR calculation
 
20,715
 
50
Central governments
 
and Supranational
issuers
 
9,914
 
51
Central banks exposure
 
10,422
 
52
Trading book
 
379
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
154
|
Page
 
€ = Euro
 
m = million
 
bn = billion
1.Assets for the
 
calculation of GAR - Capex
Million EUR
Total [gross]
carrying
amount
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors
(Taxonomy
 
-eligible)
Of which towards taxonomy
 
relevant sectors (Taxonomy
 
-eligible)
Of which environmentally
 
sustainable (Taxonomy
 
-aligned)
Of which environmentally sustainable
(Taxonomy
 
-aligned)
Of which environmentally sustainable
 
(Taxonomy-
aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
53
Total assets
 
81,165
 
 
13,059
 
 
2,081
 
 
1,327
 
 
26
 
 
78
 
 
333
 
 
7
 
 
-
 
 
1
 
 
13,841
 
 
2,088
 
 
1,327
 
 
26
 
 
79
 
Off-balance sheet exposures
 
-Undertakings subject to
 
NFRD disclosure obligations
54
Financial guarantees
 
796
 
 
462
 
 
152
 
 
-
 
 
4
 
 
6
 
 
25
 
 
0
 
 
-
 
 
-
 
 
487
 
 
152
 
 
-
 
 
4
 
 
6
 
55
Assets under management
 
866
 
 
287
 
 
116
 
 
-
 
 
3
 
 
11
 
 
22
 
 
1
 
 
-
 
 
0
 
 
309
 
 
116
 
 
-
 
 
3
 
 
11
 
56
Of which debt securities
 
 
629
 
 
205
 
 
64
 
 
-
 
 
1
 
 
3
 
 
12
 
 
0
 
 
-
 
 
0
 
 
217
 
 
64
 
 
-
 
 
1
 
 
3
 
57
Of which equity instruments
 
237
 
 
82
 
 
52
 
 
-
 
 
2
 
 
8
 
 
10
 
 
1
 
 
-
 
 
-
 
 
92
 
 
53
 
 
-
 
 
2
 
 
8
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
155
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Turnover
 
% (compared to total covered
 
assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of
total assets
covered
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
 
numerator
and denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for
 
GAR
calculation
54.1
7.0
6.3
0.0
0.3
0.8
0.0
-
0.0
57.0
7.0
6.3
0.0
0.3
34.8
2
Financial corporations
 
0.4
0.2
-
0.0
0.0
0.2
-
-
-
18.4
0.2
-
0.0
0.0
4.2
3
Credit institutions
-
-
-
-
-
-
-
-
-
18.2
-
-
-
-
4.0
4
Loans and advances
-
-
-
-
-
-
-
-
-
17.1
-
-
-
-
1.6
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
19.0
-
-
-
-
2.4
6
Equity instruments
-
-
-
-
-
-
14.0
-
-
-
0.0
7
Other financial corporations
13.2
6.0
-
0.5
0.4
7.6
-
-
-
25.2
6.0
-
0.5
0.4
0.1
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
8.6
-
-
-
-
0.0
13
Loans and advances
-
-
-
-
-
-
-
-
-
8.2
-
-
-
-
0.0
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
11.9
-
-
-
0.0
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
16.6
-
-
-
-
0.0
17
Loans and advances
-
-
-
-
-
-
-
-
-
8.2
-
-
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
156
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Turnover
 
% (compared to total covered
 
assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of
total assets
covered
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
16.6
-
-
-
-
0.0
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
35.8
28.
6
25.7
0.2
1.2
3.3
0.2
-
0.0
39.1
28.
8
25.7
0.2
1.2
8.3
21
Loans and advances
38.8
32.1
30.1
0.1
1.3
2.2
0.0
-
-
41.0
32.1
30.1
0.1
1.3
7.1
22
Debt securities, including UoP
17.5
7.9
-
0.9
0.7
10.0
1.3
-
0.1
27.5
9.2
-
0.9
0.8
1.2
23
Equity instruments
50.6
1.3
-
0.2
0.9
-
-
51.5
1.3
-
0.2
0.0
24
Households
71.0
0.3
0.3
-
-
-
-
-
-
71.0
0.3
0.3
-
-
22.4
25
of which loans collateralised
 
by residential
immovable property
100.0
-
-
-
-
-
-
-
-
100.0
-
-
-
-
15.2
26
of which building renovation
 
loans
100.0
100.
0
100.0
-
-
-
-
-
-
100.0
100.
0
100.0
-
-
0.1
27
of which motor vehicle loans
100.0
-
-
-
-
100.0
-
-
-
-
0.6
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
31
Collateral obtained
 
by taking possession:
residential and commercial immovable
properties
 
100.0
-
-
-
-
-
-
-
-
100.0
-
-
-
-
1.0
32
Total GAR assets
19.8
2.4
2.2
0.0
0.1
0.3
0.0
-
0.0
20.9
2.5
2.2
0.0
0.1
100.0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
157
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Capex
% (compared to total covered
 
assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of
total assets
covered
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both
 
numerator
and denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for
 
GAR
calculation
59.2
9.9
6.3
0.1
0.4
1.6
0.0
-
0.0
62.9
9.9
6.3
0.1
0.4
34.8
2
Financial corporations
 
0.8
0.7
-
0.0
0.0
0.2
-
-
-
18.7
0.7
-
0.0
0.0
4.2
3
Credit institutions
-
-
-
-
-
-
-
-
-
18.2
-
-
-
-
4.0
4
Loans and advances
-
-
-
-
-
-
-
-
-
17.1
-
-
-
-
1.6
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
19.0
-
-
-
-
2.4
6
Equity instruments
-
-
-
-
-
-
-
14.0
-
-
-
0.0
7
Other financial corporations
26.9
25.9
-
1.5
0.6
5.7
-
-
-
37.0
25.9
-
1.5
0.6
0.1
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
12
of which
 
management companies
-
-
-
-
-
-
-
-
-
8.6
-
-
-
-
0.0
13
Loans and advances
-
-
-
-
-
-
-
-
-
8.2
-
-
-
-
0.0
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
11.9
-
-
-
0.0
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
16.6
-
-
-
-
0.0
17
Loans and advances
-
-
-
-
-
-
-
-
-
8.2
-
-
-
-
-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
 
REPORT OF THE DIRECTORS / SUSTAINABILITY STATEMENT
158
|
Page
 
€ = Euro
 
m = million
 
bn = billion
3. GAR KPI Stock - Capex
% (compared to total covered
 
assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL
 
(CCM + CCA)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-eligible)
Proportion of total covered
 
assets funding taxonomy
relevant sectors (Taxonomy
 
-eligible)
Proportion of
total assets
covered
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered
 
assets funding
taxonomy relevant sectors (Taxonomy
 
-aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
16.6
-
-
-
-
0.0
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial corporations
57.0
40.
4
25.7
0.5
1.6
6.6
0.1
-
0.0
63.6
40.
5
25.7
0.5
1.6
8.3
21
Loans and advances
58.3
42.2
30.1
0.1
1.6
5.8
0.0
-
-
64.0
42.3
30.1
0.1
1.6
7.1
22
Debt securities, including UoP
49.6
29.9
-
2.9
1.5
11.4
0.8
-
0.1
61.0
30.8
-
2.9
1.5
1.2
23
Equity instruments
50.9
9.5
-
0.2
1.2
-
-
52.1
9.5
-
0.2
0.0
24
Households
71.0
0.3
0.3
-
-
-
-
-
-
71.0
0.3
0.3
-
-
22.4
25
of which loans collateralised
 
by residential
immovable property
100.0
-
-
-
-
-
-
-
-
100.0
-
-
-
-
15.2
26
of which building renovation
 
loans
100.0
100.
0
100.0
-
-
-
-
-
-
100.0
100.
0
100.0
-
-
0.1
27
of which motor vehicle loans
100.0
-
-
-
-
100.0
-
-
-
-
0.6
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
29
Housing financing
 
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
 
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0
31
Collateral obtained
 
by taking possession:
residential and commercial immovable
properties
 
100.0
-
-
-
-
-
-
-
-
100.0
-
-
-
-
1.0
32
Total GAR assets
21.6
3.4
2.2
0.0
0.1
0.6
0.0
-
0.0
22.9
3.5
2.2
0.0
0.1
100.0
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
AUDIT COMMITTEE ACTIVITY REPORT
 
1
|
Page
 
AUDIT COMMITTEE ACTIVITY REPORT FOR THE YEAR 2024
Purpose
1.
In
 
accordance
 
with
 
the
 
Law
 
4449/2017
 
as
 
amended,
 
the
 
Audit
 
Committee
 
(AC)
 
of
 
Eurobank
 
Ergasias
 
Services
 
and
Holdings S.A.
 
(Eurobank
 
Holdings or
 
HoldCo or
 
Company) should
 
submit an annual
 
report to
 
the Shareholders’
 
Annual
General
 
Meeting on the issues dealt
 
with by the
 
AC during the
 
previous year,
 
also including therein
 
a description of the
sustainability policy followed
 
by the entity.
2.
The current
 
2024 AC Activity Report of Eurobank
 
Holdings which is also part of the
 
2024 Annual Financial Report, refers
to the AC activity during
 
2024 and the issues addressed.
 
In addition, it
 
describes Eurobank Holdings’ sustainability policy.
3.
No deviations from the
 
AC’s Terms
 
of Reference (ToR)
 
have been identified.
AC Composition / Membership
4.
It is
 
noted that
 
in line
 
with the
 
provisions
 
of article
 
44 of
 
law 4449/2017,
 
as in
 
force,
 
and further
 
to the
 
decision of
 
the
HoldCo’s Annual General Meeting of Shareholders as of 23.07.2024 regarding the recomposition of the Audit Committee
and more specifically regarding its type, composition and term of
 
office; and the BoD’s decision of 23.07.2024
 
regarding
the
 
membership
 
of
 
the
 
AC,
 
following
 
the
 
relevant
 
recommendations
 
by
 
the
 
Nomination
 
and
 
Corporate
 
Governance
Committee (NomCo)
 
of 28.05.2024
 
and 26.06.2024,
 
the AC
 
decided on
 
its constitution
 
and on
 
the
 
appointment of
 
its
Chairman.
5.
Following
 
the
 
above,
 
the
 
AC
 
consists exclusively
 
of BoD
 
members,
 
five
 
(5) in
 
total,
 
all of
 
which are
 
independent non-
executive Directors, according to the provisions of article 9 of L. 4706/2020. In particular, the
 
AC consists of the following
members: 1.
 
Burkhard Eckes
 
(Chairperson of the
 
Audit Committee, independent non-executive
 
BoD member), 2.
 
Jawaid
Mirza (Vice
 
-Chairperson
 
of the
 
Audit Committee,
 
independent non-executive
 
BoD member),
 
3.
 
Irene
 
Rouvitha-Panou
(Audit
 
Committee
 
member,
 
independent
 
non-executive
 
BoD
 
member),
 
4.
 
Rajeev
 
Kakar
 
(Audit
 
Committee
 
member,
independent
 
non-executive
 
BoD
 
member),
 
and
 
5.
 
Alice
 
Gregoriadi
 
(Audit
 
Committee
 
member,
 
independent
 
non-
executive BoD member).
 
6.
All AC
 
members
 
have
 
sufficient knowledge
 
in the
 
field of
 
HoldCo
 
activities and
 
the
 
necessary
 
skills and
 
experience
 
to
carry out their duties and meet the requirement of established knowledge and experience in auditing
 
and/or accounting.
7.
Information
 
regarding
 
current
 
AC
 
composition
 
and
 
short
 
biographical
 
details
 
of
 
its
 
members
 
may
 
be
 
found
 
at
 
the
HoldCo’s website (www.eurobankholdings.gr).
 
Meetings Held During the Period
 
& Attendance
8.
During 2024, the Audit Committee held fifteen (15) meetings, while during
 
2023, the Audit Committee held seventeen (17)
meetings, including four (4) meetings
 
by circulation.
 
9.
The
 
average
 
ratio
 
of
 
attendance
 
at
 
the
 
meetings
 
by
 
the
 
AC
 
members
 
stood
 
at
 
97%
 
(2023:
 
100%).
 
The
 
AC
 
members
provided proxies for
 
all missed AC meetings, they were
 
eligible to attend.
10.
The quarterly
 
meetings were
 
attended in person and
 
the rest were
 
held via conference
 
calls. This practice
 
is allowed by
the AC ToR
 
and is consistent across all HoldCo’s
 
BoD Committees.
 
11.
The submissions for
 
the AC meetings have
 
become available to all BoD members through
 
the Diligent platform.
 
12.
The
 
BoD Chair
 
has regularly
 
attended the
 
AC meetings.
 
In addition,
 
all meetings
 
were
 
attended by
 
the
 
Internal Audit
(IA),
 
while
 
the
 
General
 
Manager
 
of
 
Group
 
Compliance
 
was attending
 
the
 
meetings
 
depending
 
on
 
the
 
subject
 
under
discussion.
13.
The
 
External
 
Auditor of
 
2023
 
and 2024
 
financial statements
 
(i.e.
 
KPMG) has
 
been
 
invited and
 
attended
 
meetings
 
as
required.
14.
The
 
AC
 
Chair updated
 
the
 
Board
 
members,
 
at the
 
quarterly meetings
 
of the
 
Board,
 
on the
 
material
 
matters
 
covered
during the AC meetings.
 
15.
In 2024,
 
the members
 
of the
 
AC have
 
been invited and
 
participated in
 
the Board
 
Risk Committee
 
(BRC) meetings
 
and
similarly
 
the
 
members
 
of
 
the
 
BRC
 
have
 
been
 
invited
 
and
 
participated
 
in
 
the
 
Audit
 
Committee
 
meetings
 
(joint
 
Audit
Committee and Board Risk Committee meetings) for
 
the discussion / approval
 
of items that fall under the
 
responsibility
of both
 
Committees.
 
More
 
specifically,
 
at
 
the
 
BRC
 
meetings
 
that
 
the
 
AC
 
members
 
have
 
participated,
 
among others,
accounting
 
policies
 
(including
 
hedge
 
accounting
 
policy),
 
progress
 
reports
 
for
 
the
 
Corporate
 
Sustainability
 
Report
Directive (CSRD) Program Implementation, various risks, (including
 
non-financial risks, climate
 
related and environmental
related risks) and the Environmental
 
and Social Governance
 
(ESG) Strategy have been discussed.
 
16.
The AC Chair had regular
 
private meetings with the Head of Internal
 
Audit, Head of Group Compliance and Group CFO
as well as the External Auditors.
17.
The AC Chair informed
 
the AC on his meeting with the
 
JST.
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
AUDIT COMMITTEE ACTIVITY REPORT
 
2
|
Page
 
Highlights of Issues of Importance during 2024
Internal Controls System and Risk Management
18.
The AC,
 
in accordance with
 
its Terms
 
of Reference,
 
reviews the
 
adequacy of the
 
Internal Control
 
and Risk Management
systems and the compliance with rules and regulations
 
of the monitoring process.
19.
In the context of the Independent Evaluation
 
of the System of Internal Controls:
During 1Q 2024
 
AC meeting,
 
the AC
 
discussed and further
 
submitted to the
 
Board Risk
 
Committee (BRC)
 
and
BoD for
 
acknowledgement,
 
the
 
independent triennial
 
Evaluation
 
of the
 
System of
 
Internal
 
Controls
 
(SIC) per
BoG Act
 
2577/9.3.2006
 
conducted by
 
Grant
 
Thornton
 
(Independent
 
Evaluation).
 
The
 
Independent Evaluation
along with AC’s assessment on the
 
evaluation were
 
submitted to Bank of Greece (BoG) as required.
It is
 
noted that
 
no findings of
 
High significance
 
were
 
identified during the
 
assessment, that
 
would fall
 
in the
 
category “Key
Findings” to be reported to the BoG.
 
Moreover,
 
at the same
 
AC meeting, the
 
AC discussed the
 
additional work performed
 
by Grant Thornton,
 
in the
context of
 
the
 
evaluation
 
of the
 
adequacy of
 
the
 
Internal Control
 
System (ICS),
 
following
 
the identification
 
of
the
 
need to
 
assess the
 
regulatory
 
compliance risk
 
management, in
 
the
 
context of
 
a) clarity
 
of responsibilities
between
 
different
 
Bank Units
 
within the
 
3 Lines
 
of Defense
 
Model and
 
b) the
 
consistency of
 
governance
 
and
aggregation of regulatory
 
compliance risk at the Board of
 
Directors level.
It is noted that the expanded
 
assessment did not reveal
 
any recommendations for
 
improvement.
20.
Further to the
 
above, throughout
 
the year 2024:
 
the AC Members
 
received update by
 
IA and Compliance and other
 
Bank Units as required, covering
 
matters of
the System of Internal Controls,
 
Risk Management, Compliance with rules and regulations
 
and legal issues.
significant weaknesses
 
in internal controls
 
and the progress
 
of actions taken
 
to address them,
 
were presented
in the Internal Audit
 
Activity Report and
 
several pending issues (including External
 
Auditors’ Management Letter)
were discussed with Management
 
and the AC ensured
 
that the time plans and deadlines
 
will be followed
 
up.
 
the
 
AC
 
acknowledged
 
the
 
annual
 
Internal
 
Audit
 
Evaluation
 
Report
 
of
 
the
 
System
 
of
 
Internal
 
Controls,
 
a
requirement
 
of the
 
Bank of Greece
 
Act 2577/9.3.2006.
 
The said
 
report along
 
with the
 
AC’s own
 
assessment of
the evaluation was
 
further submitted to the
 
BoD and subsequently to BoG in June 2024.
the AC reviewed
 
and submitted to the BoD for approval
 
the revised Related
 
Party Transactions
 
Policy.
in accordance with
 
the provisions
 
of Law 2533/1997,
 
the AC reviewed
 
reports on substantial stock transactions
performed
 
by the Company’s Directors and General
 
Managers in listed securities and notified the Board.
Internal Audit (IA)
21.
The Internal
 
Audit (IA) function of
 
HoldCo is independent (Internal
 
Audit has a functional
 
reporting line to the
 
AC and a
dotted
 
reporting
 
line
 
for
 
administrative
 
matters
 
to
 
the
 
CEO),
 
adequately
 
organized,
 
has
 
unrestricted
 
access
 
to
 
any
pertinent information and operates efficiently and effectively in compliance
 
with the Standards of
 
the Institute of
 
Internal
Auditors.
22.
During 2024, the AC:
received confirmation from
 
the Chief Internal Auditor (CIA) regarding
 
IA’s independence
 
for 2023.
discussed the performance
 
of the IA Annual Plan for 2023.
 
Received information
 
on the IA Medium term plan 2024-2026.
approved
 
and further
 
submitted to the
 
BoD for
 
information
 
the 2025
 
IA Annual Plan for
 
and the
 
3-year Audit
Plan (2025-2027).
monitored the progress
 
of the IA Audit Plan for 2024 through
 
the Activity Reports.
 
at the Quarterly AC
 
meetings, discussed the key
 
highlights of the IA Activity Reports (including the follow
 
-up of
the external auditors’ Management
 
Letter points).
 
Discussed the progress
 
of the actions for
 
the resolution
 
of IA findings.
Carried out the assessment
 
of the Internal Auditor’s performance
 
for 2023.
Compliance
 
23.
The
 
Compliance of
 
HoldCo is
 
a permanent
 
and independent
 
function (the
 
Head of
 
Compliance reports
 
functionally
 
to
the AC
 
and for
 
administrative
 
purposes to the
 
CEO of Holdings)
 
adequately organized,
 
has unrestricted
 
access to
 
any
pertinent information
 
and operates efficiently
 
and effectively.
24.
During 2024, the AC:
reviewed
 
and approved the
 
Compliance Mandate.
approved and further
 
submitted to the BoD for information
 
the 2025 Compliance Annual Plan.
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
AUDIT COMMITTEE ACTIVITY REPORT
 
3
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Page
 
at the
 
Quarterly
 
AC
 
meetings,
 
discussed the
 
key
 
highlights of
 
the
 
Compliance
 
Activity Reports,
 
including the
progress of the 2024
 
Compliance Annual Plan.
 
discussed and further submitted
 
to the BoD for discussion the
 
Ethics Hotline Reports received
 
during 2023.
reviewed
 
and
 
depending
 
on the
 
case,
 
ratified,
 
approved
 
or
 
approved
 
and
 
further
 
submitted to
 
the
 
BoD
 
for
approval /
 
information
 
a) the
 
revised MiFID
 
II Product
 
Governance
 
Policy,
 
b) the
 
Group Anti-trust
 
Compliance
Policy,
 
c) the
 
revised Policy
 
for Reporting
 
Illegal or Unethical
 
Conduct or Violations
 
of European
 
Union Law,
 
d)
the revised
 
Anti-Bribery and Corruption
 
Policy,
 
e) the Policy
 
for the
 
Prevention
 
and Detection of Market
 
Abuse,
f) the
 
Insider
 
Dealing Guideline,
 
g) the
 
revised
 
Conflict of
 
Interest
 
Policy,
 
h) the
 
revised
 
Code of
 
Conduct and
Ethics.
In
 
the
 
context
 
of
 
the
 
Policy
 
for
 
Reporting
 
Illegal
 
or
 
Unethical
 
Conduct
 
or
 
Violations
 
of
 
European
 
Union
 
Law
(mentioned above), approved and further
 
submitted to the BoD
 
for approval the Report Receiving & Monitoring
Officer (RRMO) and the
 
assistant RRMO.
In line with the BoG requirements, received
 
the Annual Group Compliance Report as per BoG
 
Act 2577/9.3.2006
(including
 
MiFID
 
report)
 
for
 
acknowledgement.
 
The
 
said
 
report
 
along with
 
the
 
AC’s
 
assessment
 
was
 
further
submitted to the BoD and subsequently to the BoG in June
 
2023.
Carried out the assessment
 
of the performance
 
of the Head of Compliance for
 
2023.
Financial reporting
 
25.
The
 
AC,
 
in
 
accordance
 
with
 
its
 
Terms
 
of
 
Reference,
 
monitors
 
the
 
financial
 
reporting
 
process
 
and
 
submits
recommendations
 
and
 
proposals
 
to
 
ensure
 
its
 
integrity.
 
In
 
addition,
 
it
 
supervises
 
and
 
assesses
 
whether
 
the
 
internal
controls
 
related
 
to financial
 
reporting are
 
adequate and
 
effective
 
and that
 
these
 
controls
 
are adjusted
 
to reflect
 
any
major changes in the risk profile of Holdings.
26.
During the AC meetings in 2024:
the
 
AC,
 
among
 
others,
 
reviewed
 
and
 
approved
 
the
 
quarterly
 
results,
 
semi-annual
 
and
 
annual
 
Accounts
 
and
Financial Statements, Annual General Meeting (AGM) matters and matters of the External auditors. In addition,
the AC reviewed
 
and proposed to the BoD for
 
approval the
 
Consolidated Pillar III report.
Group
 
Finance
 
made
 
presentations
 
on
 
issues
 
such
 
as
 
accounting
 
policies,
 
critical
 
accounting
 
estimates,
significant
 
one-off
 
items
 
impacting
 
the
 
Financial
 
Statements,
 
major
 
variations
 
between
 
periods,
 
important
disclosures,
 
significant issues with tax authorities, as well as Group
 
Control issues.
 
Group Legal Services presented
 
the Outstanding Significant Litigations and
 
Provisions.
IA performed
 
a high level
 
review of
 
material submitted
 
to the
 
AC for
 
the clearance
 
of the
 
financial results and
reported significant items to the AC
 
Chairman for his attention.
with regards
 
to the
 
monitoring of
 
the
 
Actual
 
vs Budget
 
Report, the
 
AC
 
received
 
quarterly
 
updates by
 
Group
Finance which were
 
subsequently submitted to the BoD for discussion.
 
The
 
AC
 
discussed
 
Group
 
Finance’s
 
planned
 
steps
 
to
 
improve
 
its
 
reporting
 
process
 
(increased
 
international
subsidiaries oversight) as requested
 
by the SSM.
External Auditors
27.
The
 
AC, in
 
accordance
 
with its
 
Terms
 
of Reference,
 
is responsible
 
for
 
the
 
selection, performance
 
and independence
 
of
the External
 
Auditors, KPMG. In addition,
 
the AC
 
reviews the
 
scope of audit work
 
and audit approach
 
and assesses the
process for
 
identifying and responding to key audit and internal control
 
risks.
28.
During the AC meetings in 2024:
KPMG presented its 2024
 
Audit Plan to the AC.
 
The AC
 
has also, in line with
 
its ToR,
 
reviewed
 
the Engagement
letter for the
 
2024 Statutory Audit of the Company.
KPMG presented and discussed with the
 
AC members a summary of audit work
 
done, major findings, including
a summary of unadjusted differences,
 
and other issues of importance.
29.
The
 
AC
 
has
 
received
 
the
 
2023
 
KPMG
 
Management
 
Letter
 
(ML)
 
and
 
has
 
discussed
 
the
 
issues
 
raised
 
with
 
KPMG
 
and
Management.
 
30.
The annual assessment of the External Auditors for
 
the 2023 audit was discussed by the AC members and Management.
At the
 
same AC
 
meeting, the
 
AC decided
 
to propose
 
to the
 
BoD for
 
approval and
 
subsequent recommendation
 
to the
Annual General Meeting of
 
shareholders for approval, the reappointment of KPMG as
 
statutory auditors for the separate
and consolidated Financial Statements of Eurobank
 
Holdings for the
 
financial year of 2024.
 
31.
The AC has discussed and approved
 
the Global Group
 
Audit and assurance Fees
 
of 2024.
 
32.
The AC
 
has received
 
the External
 
Auditors’ Independence written
 
confirmation, while it
 
monitored the
 
independence of
the
 
External
 
Auditors
 
through
 
the
 
Auditors
 
independence
 
monitoring
 
tool
 
submitted
 
quarterly
 
by
 
Group
 
Finance,
depicting
 
the
 
value
 
of
 
non-audit
 
services
 
provided
 
as
 
compared
 
to
 
the
 
limits
 
set
 
by
 
the
 
Group
 
External
 
Auditor’s
Independence Policy that was
 
also updated during 2024.
 
 
 
 
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
AUDIT COMMITTEE ACTIVITY REPORT
 
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33.
In
 
line
 
with
 
the
 
Group
 
External
 
Auditor’s
 
Independence
 
Policy,
 
the
 
AC
 
in
 
2024
 
reviewed
 
and
 
approved
 
all
 
non-audit
services including the audit assurance related work, ensuring that the independence limits are complied with. Among the
non-audit services
 
reviewed
 
and approved,
 
the
 
following
 
services,
 
exceeding €50k,
 
were
 
included: a)
 
Fairfax
 
Financial
Holdings (FFH) annual requirement on the reconciliation of IFRS
 
consolidated Total Equity and Profit & Loss to
 
U.S. GAAP,
for
 
the
 
year
 
ending
 
31.12.2023,
 
b)
 
Engagement
 
of
 
KPMG
 
by
 
Eurobank
 
Cyprus
 
for
 
advisory
 
services
 
to
 
support
 
with
transitioning
 
to the
 
Capital Requirements
 
Regulation (CRR)
 
III framework
 
c) engagement
 
of KPMG
 
Cyprus by
 
Hellenic
Bank for the
 
provision of
 
advisory services
 
for the
 
development of a
 
decarbonization strategy
 
and additional scope for
Climate Environmental
 
(CE) Risks
 
Action Plan
 
and d)
 
engagement of
 
KPMG for
 
Sales training
 
to the
 
Eurobank’s
 
Retail
Banking Networks’ employees.
 
34.
The AC reviewed
 
the services assigned to the
 
Big Audit Firms in 2023 vs 2024.
35.
The AC met
 
with the External Auditors (with and without Management’s
 
presence) to discuss issues related to the audit,
in addition to any significant issues related to the
 
External Auditors’ audit plan.
 
36.
The AC reviewed
 
the External Auditor’s Report and the Report on Key
 
Audit Issues.
37.
The AC reviewed
 
and approved the
 
updated External Auditors Tendering
 
Policy and Procedure.
38.
The AC reviewed
 
the services assigned to the
 
Big Audit Firms in 2023 vs 2024.
39.
The AC reviewed
 
a) the eligibility of audit firms for the statutory audit vs IT delivery sourcing for strategic IT projects
 
and
b) the 5-yr rolling
 
plan (for years 2025-2029) on the eligibility of audit firms for
 
the statutory audit of Eurobank Ergasias
Services
 
and Holdings
 
Group and
 
the
 
potential conflict
 
of interest
 
situations with
 
eligible audit
 
firms, based
 
on Greek
Law
 
4449/17
 
and
 
EU
 
Reg
 
537/14,
 
considering
 
also
 
requirements
 
of
 
the
 
International
 
Code
 
of
 
Ethics
 
for
 
Professional
Accountants of the International
 
Ethics Standards Board for
 
Accountants (IESBA).
40.
The
 
AC initiated
 
the External
 
Auditor’s tendering
 
process
 
for
 
the Group
 
statutory audit
 
of 2027.
 
in relation
 
to this,
 
the
AC,
 
during
 
the
 
internal
 
independence
 
assessment
 
process,
 
a)
 
approved
 
External
 
Auditor's
 
tendering
 
time-plan,
 
b)
reviewed
 
and approved
 
the eligible
 
audit firms, the
 
eligibility criteria as
 
well as information
 
for each
 
of the short-listed
eligible audit firms supporting their
 
eligibility and the initial letter
 
Request for Independence
 
(RfI) as sent to the eligible
audit
 
firms
 
and
 
c)
 
reviewed
 
and
 
approved
 
statements
 
of
 
independence
 
of
 
the
 
two
 
(2)
 
eligible
 
audit
 
firms
 
and
 
the
“Request for Proposal
 
[RfP]” (invitation to tender) as sent to the short-listed eligible
 
audit firms.
41.
The
 
AC
 
discussed
 
with
 
the
 
external
 
auditor
 
the
 
accounting
 
process
 
for
 
the
 
integration
 
with
 
Hellenic
 
Bank
 
(step
 
up
acquisition accounting).
42.
The AC discussed the
 
provision of limited assurance
 
review by the
 
external auditors for the
 
CSRD reporting.
AC’s Evaluation
43.
The
 
AC’s
 
performance
 
is
 
evaluated
 
annually
 
according
 
to
 
the
 
provisions
 
of
 
HoldCo’s
 
Board
 
and
 
Board
 
Committees
Evaluation
 
Policy.
 
According
 
to
 
the
 
AC’s
 
2024
 
self-evaluation,
 
the
 
AC
 
members
 
expressed
 
satisfaction
 
with
 
the
committee’s structure,
 
effectiveness
 
and leadership.
 
They
 
commented on
 
the
 
AC's efficient
 
use of
 
time and
 
scheduling
and the
 
well-structuring
 
meetings, ensuring
 
critical issues
 
are addressed
 
efficiently and
 
effectively.
 
The
 
Chairperson of
the AC was praised for his
 
ability to ensure continuity
 
and strong guidance during the
 
transition and to encourage critical
discussions and inclusive participation.
44.
However,
 
the evaluation
 
identified areas
 
for
 
improvement,
 
notably the
 
need for
 
better collaboration
 
between AC
 
and
BRC
 
on
 
overlapping
 
responsibilities
 
and
 
enhanced
 
oversight
 
of
 
external
 
auditors.
 
There
 
were
 
also
 
calls
 
for
 
better
alignment
 
with
 
evolving
 
regulatory
 
requirements
 
and enhanced
 
oversight
 
of subsidiaries
 
and emerging
 
risks
 
such
 
as
cybersecurity and compliance.
Other AC Matters
45.
The AC has reviewed
 
and proposed to the BoD for
 
approval its Terms
 
of Reference.
46.
The AC
 
has approved
 
and notified the
 
Board for
 
further
 
submission to the
 
Annual General
 
Meeting, the annual
 
Activity
Report for 2023.
47.
The AC has discussed its annual
 
Plan for 2025.
Sustainability Overview
48.
Eurobank
 
Holdings
 
supports
 
the
 
transition
 
towards
 
a
 
sustainable
 
economy
 
and
 
considers
 
sustainability
 
and
 
climate
change
 
as
 
an
 
opportunity.
 
A
 
key
 
strategic
 
objective
 
is
 
to adapt
 
its
 
business
 
and
 
operation
 
in
 
a
 
way
 
that
 
addresses
climate change challenges, accommodates
 
social needs within its
 
business model and safeguards
 
prudent governance
for
 
itself and its
 
counterparties,
 
in accordance
 
with supervisory
 
initiatives,
 
and following
 
international
 
standards/ best
practice. Adopting
 
a strategic
 
approach for
 
the management
 
of risks and the
 
identification of opportunities
 
in relation
to sustainability and climate change, the Bank
 
follows, and accelerates
 
where possible, a detailed roadmap
 
prioritizing
actions for
 
the
 
effective
 
management of
 
sustainability and
 
climate-related
 
& environmental
 
(CR&E) risks
 
in alignment
with
 
the
 
supervisory
 
expectations
 
included
 
at
 
the
 
ECB
 
Guide
 
on
 
Climate-Related
 
and
 
Environmental
 
Risks.
 
The
 
IA
 
is
informed
 
and
 
follows
 
up
 
on
 
the
 
Climate
 
Risk
 
Roadmap,
 
which
 
has
 
been
 
agreed
 
with
 
the
 
supervisor.
 
The
 
respective
developments are considered in IA
 
risk-based audit approach. In
 
this respect IA
 
issued in 2024
 
one consulting
 
assignment
 
 
EUROBANK ERGASIAS SERVICES AND HOLDINGS S.A.
AUDIT COMMITTEE ACTIVITY REPORT
 
5
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Page
 
report
 
(Pillar
 
III
 
disclosures
 
on
 
ESG
 
risks)
 
and
 
one
 
assurance
 
assignment
 
report
 
(Review
 
of
 
C&E
 
Risk
 
Management
Framework),
 
for which the AC
 
was also informed through
 
IA activity report.
49.
Eurobank
 
Holdings,
 
during
 
2024,
 
has
 
updated
 
its
 
Sustainability
 
Governance
 
structure
 
by
 
introducing
 
and
 
defining
specific
 
roles
 
and responsibilities
 
to further
 
support the
 
roll-out
 
of the
 
Sustainability
 
Strategy
 
and the
 
integration
 
of
Sustainability risks, through
 
the involvement
 
of various key
 
stakeholders,
 
embedding regulatory
 
guidelines and market
practices within the 3 Lines of Defense. To this end, Eurobank
 
Holdings in 2024 appointed its Group Senior Sustainability
Officer
 
(GSSO)
 
to lead
 
and
 
coordinate
 
sustainability
 
initiatives
 
for
 
both
 
operational
 
and
 
financed
 
impact,
 
reporting
directly to the
 
senior management and Board
 
for sustainability matters.
 
GSSO manages the Group
 
Sustainability Unit,
co-manages, as
 
a secondary
 
reporting line,
 
the
 
Group
 
Sustainability Risk
 
along with
 
the
 
Senior Risk
 
Executive
 
Officer
(primary reporting line). The AC for the year 2024, through the
 
monthly joined meetings with the BRC, has been informed
(and contributed) by the GSSO and/or the Senior Risk Executive Officer and/or the Head of the Group Sustainability Risk
for a significant number of topics as stated below:
-
Monthly monitoring of CSRD reporting project progress
 
(4 sessions during 2024)
-
Semi-annual update by the responsible BoD member
 
for climate-related
 
and environmental risks
 
-
Hellenic Bank’s status on management of sustainability and climate-related
 
& environmental (CR&E) risks
-
CR&E Risks' Materiality Assessment Key Updates
-
ERB Group Climate Risk Roadmap Progress
 
Update
-
Key areas of the Group
 
Climate Risk Stress Test
 
Framework
 
Update
………………….
 
Burkhard Eckes
AC Chairman
Athens, March 2025
doc1p252i3 doc1p252i4 doc1p252i2
CONSOLIDATED
FINANCIAL STATEMENTS
FOR THE YEAR ENDED
 
31 DECEMBER 2024
8 Othonos Str, Athens
 
105 57,
 
Greece
eurobankholdings.gr,
 
Tel.: (+30) 214 40 61000
General Commercial
 
Registry No: 000223001000
 
 
doc1p253i0 doc1p253i1
.
 
.
 
Index to the Consolidated Financial Statements ........................................................................................................................
 
Page
Consolidated Balance Sheet ................................................................................................................................
 
.....................................
 
1
Consolidated Income Statement ................................................................................................
 
..............................................................
 
2
Consolidated Statement of Comprehensive
 
Income ................................................................................................................................
 
3
Consolidated Statement of Changes in Equity ..........................................................................................................................................
 
4
Consolidated Cash Flow Statement .......................................................................................................................................................... 5
Notes to the Consolidated Financial Statements
1.
 
General information ................................................................................................
 
........................................................................
 
6
2.
 
Basis of preparation and material accounting
 
policies
 
.................................................................................................................... 6
2.1
 
Basis of preparation .........................................................................................................................................................................
 
6
2.2
 
Material accounting policies ..........................................................................................................................................................
 
10
3.
 
Critical accounting estimates and judgments
 
in applying accounting policies ..............................................................................
 
40
4.
 
Capital Management ................................................................................................................................
 
.....................................
 
49
5.
 
Financial risk management and fair value ................................................................................................
 
.....................................
 
52
5.2.1 Credit Risk ......................................................................................................................................................................................
 
54
5.2.2 Market risk
 
................................................................................................................................................................
 
.....................
 
88
5.2.3 Liquidity risk
 
................................................................................................................................................................
 
...................
 
93
5.2.4 Sustainability risks ................................................................
 
......................................................................................................... 96
5.3
 
Fair value of financial assets and liabilities ....................................................................................................................................
 
97
6.
 
Net interest income ..................................................................................................................................................................... 101
7.
 
Net banking fee and commission income ....................................................................................................................................
 
102
8.
 
Income from non banking services ..............................................................................................................................................
 
103
9.
 
Net trading income and gains less losses from investment
 
securities ........................................................................................ 103
10.
 
Other income/ (expenses) ........................................................................................................................................................... 104
11.
 
Operating expenses ..................................................................................................................................................................... 105
12.
 
Other impairments, risk provisions and restructuring costs ........................................................................................................
 
106
13.
 
Income tax ................................................................................................................................................................................... 106
14.
 
Earnings per share ................................................................................................................................................................
 
.......
 
110
15.
 
Cash and balances with central banks .........................................................................................................................................
 
111
16.
 
Cash and cash equivalents and other information
 
on cash flow statement
 
................................................................................
 
112
17.
 
Due from credit institutions
 
......................................................................................................................................................... 112
18.
 
Securities held for trading................................................................
 
............................................................................................
 
113
19.
 
Derivative financial instruments and hedge
 
accounting.............................................................................................................. 113
20.
 
Loans and advances to customers ............................................................................................................................................... 117
21.
 
Impairment allowance for loans and advances to
 
customers .....................................................................................................
 
121
22.
 
Investment securities
 
................................................................................................................................................................
 
...
 
123
 
 
doc1p253i0 doc1p253i1
.
 
.
 
23.
 
Group composition ......................................................................................................................................................................
 
126
23.1
 
Shares in subsidiaries
 
................................................................................................................................................................
 
...
 
126
23.2
 
Consolidation of Hellenic Bank group
 
.......................................................................................................................................... 129
23.3
 
Initiation of the merger process between Eurobank
 
Ergasias Services and Holdings S.A. and Eurobank S.A. ............................
 
133
24.
 
Investments in associates and joint
 
ventures
 
.............................................................................................................................. 134
25.
 
Structured Entities .......................................................................................................................................................................
 
136
26.
 
Property and equipment ................................................................................................
 
.............................................................
 
139
27.
 
Investment property ....................................................................................................................................................................
 
140
28.
 
Intangible assets .......................................................................................................................................................................... 142
29.
 
Other assets
 
................................................................................................................................................................
 
.................
 
143
30.
 
Disposal groups classified as held for sale and discontinued
 
operations ....................................................................................
 
143
31.
 
Due to central banks ....................................................................................................................................................................
 
144
32.
 
Due to credit institutions .............................................................................................................................................................
 
145
33.
 
Due to customers
 
................................................................................................................................................................
 
.........
 
145
34.
 
Debt securities in issue ................................................................................................................................................................
 
145
35.
 
Other liabilities ................................................................................................................................
 
............................................
 
147
36.
 
Insurance contract (assets)/liabilities and reinsurance
 
contract assets ......................................................................................
 
148
37.
 
Standard legal staff retirement
 
indemnity obligations (SLSRI) and termination benefits ...........................................................
 
150
38.
 
Share capital, share premium and treasury shares ................................
 
.....................................................................................
 
151
39.
 
Reserves and retained earnings
 
................................................................................................................................................... 153
40.
 
Share options
 
................................................................................................................................................................
 
...............
 
154
41.
 
Transfers
 
of financial assets
 
......................................................................................................................................................... 155
42.
 
Leases ................................................................................................................................................................
 
..........................
 
156
43.
 
Contingent liabilities and other commitments ............................................................................................................................ 157
44.
 
Operating segment information .................................................................................................................................................. 159
45.
 
Post balance sheet events ................................................................................................................................
 
...........................
 
164
46.
 
Related parties
 
................................................................................................................................................................
 
.............
 
164
47.
 
External Auditors ................................................................................................................................................................
 
.........
 
165
48.
 
Board of Directors
 
................................................................................................................................................................
 
........
 
166
APPENDIX – Disclosures under Law 4261/2014 ................................................................
 
...................................................................
 
167
 
 
 
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Consolidated Balance Sheet
 
.
1
|
Page
 
31 December 2024 Consolidated Financial Statements
31 December
2024
2023
Note
€ million
€ million
ASSETS
Cash and balances with central banks
15
16,131
10,943
Due from credit institutions
17
2,196
2,354
Securities held for trading
18
285
379
Derivative financial instruments
19
838
881
Loans and advances to customers
20
50,953
41,545
Investment securities
22
22,184
14,710
Investments in associates and joint ventures
24
203
541
Property and equipment
26
975
773
Investment property
27
1,404
1,357
Intangible assets
28
415
334
Deferred tax assets
13
3,780
3,991
Other assets
29
1,695
1,767
Assets of disposal groups classified as held for sale
30
91
206
Total assets
101,150
79,781
LIABILITIES
Due to central banks
31
-
3,771
Due to credit institutions
32
2,800
3,078
Derivative financial instruments
19
1,120
1,450
Due to customers
33
78,593
57,442
Debt securities in issue
34
7,056
4,756
Other liabilities
35
2,682
1,385
Total liabilities
92,251
71,882
EQUITY
Share capital
38
809
818
Share premium
38
1,145
1,161
Reserves and retained earnings
39
6,945
5,920
Total equity
8,899
7,899
Total equity and liabilities
101,150
79,781
 
Notes on pages
6
 
to
166
 
form an integral part of these consolidated financial statements.
 
 
 
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Consolidated Income Statement
 
.
2
|
Page
 
31 December 2024 Consolidated Financial Statements
Year ended 31 December
2024
2023
Note
€ million
€ million
Interest income
5,096
4,454
Interest expense
 
(2,589)
(2,280)
Net interest income
6
2,507
2,174
Banking fee and commission income
705
570
Banking fee and commission expense
(144)
(123)
Net banking fee and commission income
7
561
447
Income from non banking services
 
8
105
97
Net trading income/(loss)
9
94
71
Gains less losses from investment securities
9
13
57
Other income/(expenses)
10
61
68
Operating income
3,341
2,914
Operating expenses
11
(1,099)
(915)
Profit from operations before impairments,
 
risk provisions and restructuring costs
2,242
1,999
Impairment losses relating to loans and
 
advances to customers
21
(303)
(412)
Other impairments, risk provisions and related costs
12
(60)
(96)
Restructuring costs
12
(168)
(37)
Share of results of associates and joint ventures
24
161
88
Profit before tax from continuing operations
1,872
1,542
Income tax
13
(361)
(261)
Net profit from continuing operations
1,511
1,281
Net loss from discontinued operations
30
(7)
(153)
Net profit
1,504
1,128
Net profit/(loss) attributable to non controlling interests
56
(12)
Net profit attributable to shareholders
1,448
1,140
Earnings per share
-Basic earnings per share
 
14
0.40
0.31
-Diluted earnings per share
14
0.39
0.31
Earnings per share from continuing operations
-Basic and diluted earnings per share
14
0.40
0.34
Notes on pages
6
 
to
166
 
form an integral part of these consolidated financial statements.
 
 
 
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Consolidated Statement of Comprehensive Income
 
.
3
|
Page
 
31 December 2024 Consolidated Financial Statements
Year ended 31 December
2024
2023
€ million
€ million
Net profit
1,504
1,128
Other comprehensive income:
Items that are or may be reclassified subsequently to
 
profit or loss:
Cash flow hedges
- changes in fair value, net of tax
21
19
- transfer to net profit, net of tax
(22)
(1)
(21)
(2)
Debt securities at FVOCI
- changes in fair value, net of tax (note 22)
58
188
- transfer to net profit, net of tax (note 22)
(36)
22
(104)
84
Foreign currency translation
 
- foreign operations' translation differences
0
1
- transfer to net profit on the sale/liquidation of
 
foreign subsidiaries (note 23.1)
-
 
0
122
123
Associates and joint ventures
- changes in the share of other comprehensive
 
income, net of tax (note 24)
(9)
(9)
(4)
(4)
12
201
Items that will not be reclassified to profit or loss:
- Gains/(losses) from equity securities at
 
FVOCI, net of tax
(8)
18
- Actuarial gains/(losses) on post employment
 
benefit obligations, net of tax
(2)
(2)
- Changes in the share of other comprehensive income of
 
associates and Joint ventures, net of tax
1
0
(9)
16
Other comprehensive income
 
3
217
Total comprehensive
 
income attributable to:
Shareholders
- from continuing operations
1,458
1,371
- from discontinued operations
(7)
(15)
Non controlling interests
- from continuing operations
56
0
- from discontinued operations
-
 
(11)
1,507
1,345
Notes on pages
6
 
to
166
 
form an integral part of these consolidated financial statements
 
 
 
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Consolidated Statement of Changes in Equity
 
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4
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Page
 
31 December 2024 Consolidated Financial Statements
Share
 
capital
Share
 
premium
Reserves and
retained
earnings
Non
controlling
interests
Total
€ million
€ million
€ million
€ million
€ million
Balance at 1 January 2023
 
816
1,161
4,660
95
6,732
Net profit/(loss)
-
 
-
 
1,140
(12)
1,128
Other comprehensive income
-
 
-
 
216
1
217
Total comprehensive income for
 
the
 
year ended 31 December 2023
-
 
-
 
1,356
(11)
1,345
Changes in participating interest in subsidiaries
-
 
-
 
-
 
(83)
(83)
Share options plan
 
1
0
7
-
 
8
Purchase/sale of treasury shares
 
-
 
-
 
(100)
-
 
(100)
Other
-
 
-
 
(3)
-
 
(3)
1
0
(96)
(83)
(178)
Balance at 31 December 2023⁽¹⁾
818
1,161
5,920
0
7,899
Balance at 1 January 2024
818
1,161
5,920
0
7,899
Net profit
-
 
-
 
1,448
56
1,504
Other comprehensive income
-
 
-
 
3
0
3
Total comprehensive income for
 
the year ended 31 December 2024
-
 
-
 
1,451
56
1,507
Dividends (note 39)
-
 
-
 
(342)
-
 
(342)
Consolidation of Hellenic Bank group (note 23.2)
-
 
-
 
-
 
696
696
Changes in participating interest/consolidation percentage in
subsidiaries
-
 
-
 
(134)
(753)
(887)
Share options plan (note 40)
3
0
18
-
 
20
Purchase/sale and cancellation of treasury
 
shares (notes 38 and 39)
(12)
(16)
33
-
 
5
(9)
(16)
(426)
(56)
(507)
Balance at 31 December 2024⁽¹⁾
809
1,145
6,945
0
8,899
Note 38
Note 38
Note 39
(1)
 
The changes in equity do not sum to the totals provided due to rounding.
Notes on pages
6
 
to
166
 
form an integral part of these consolidated financial statements.
 
 
 
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Consolidated
 
Cash Flow Statement
 
.
5
|
Page
 
31 December 2024 Consolidated Financial Statements
Year ended 31 December
2024
2023
Note
€ million
€ million
Cash flows from continuing operating activities
Profit before income tax from continuing operations
1,872
1,542
Adjustments for :
Impairment losses relating to loans and advances to customers
21
303
412
Other impairments, risk provisions and restructuring costs
12
228
133
Depreciation and amortisation
11
135
120
Other (income)/losses οn investment securities
16
 
(123)
 
(70)
Valuation of investment property
10
 
(17)
 
(6)
Other adjustments
16
 
(253)
 
(153)
2,145
1,978
Changes in operating assets and liabilities
Net (increase)/decrease in cash and balances with central banks
 
(344)
104
Net (increase)/decrease in securities held for trading
125
 
(260)
Net (increase)/decrease in due from credit institutions
556
 
(447)
Net (increase)/decrease in loans and advances to customers
 
(3,476)
 
(1,517)
Net (increase)/decrease in other assets
 
(18)
158
Net (increase)/decrease in derivative financial instruments
 
 
(290)
 
(62)
Net increase/(decrease) in due to central banks and
 
credit institutions
 
 
(4,140)
 
(3,637)
Net increase/(decrease) in due to customers
6,166
1,730
Net increase/(decrease) in other liabilities
 
 
(286)
 
(313)
 
(1,707)
 
(4,244)
Income tax paid
 
(142)
 
(64)
Net cash from/(used in) continuing operating activities
296
 
(2,330)
Cash flows from continuing investing activities
Acquisition of fixed and intangible assets
26,27,28
 
(197)
 
(140)
Proceeds from sale of fixed and intangible assets
26,27
42
33
(Purchases)/sales and redemptions of investment securities
 
(1,807)
 
(1,287)
Acquisition of subsidiaries, net of cash acquired
23
5,500
 
(440)
Acquisition of holdings in associates and joint ventures, participations in capital increases
24
 
(284)
 
(73)
Disposal of subsidiaries, net of cash disposed
10,23,30
11
 
(425)
Disposal/liquidation of holdings in associates and joint ventures
24
-
 
3
Dividends from investment securities, associates and
 
joint ventures
16,24
20
15
Net cash from/(used in) continuing investing activities
3,285
 
(2,314)
Cash flows from continuing financing activities
(Repayments)/proceeds from debt securities in issue
16
1,860
1,048
Repayment of lease liabilities
42
 
(38)
 
(40)
Τransactions with non-controlling interests
 
(6)
-
 
Dividends Paid
 
(342)
-
 
(Purchase)/sale of treasury shares and exercise of share options
38
8
 
(99)
Net cash from/(used in) continuing financing activities
1,482
909
Net increase/(decrease) in cash and cash equivalents from continuing operations
5,063
 
(3,735)
Net cash flows from discontinued operating activities
 
-
 
148
Net cash flows from discontinued investing activities
-
 
44
Net cash flows from discontinued financing activities
 
-
 
 
(1)
Effect of exchange rate changes on cash and cash equivalents
-
 
1
Net increase/(decrease) in cash and cash equivalents from discontinued operations
-
 
192
Cash and cash equivalents at beginning of year
16
10,845
14,388
Cash and cash equivalents at end of year
16
15,908
10,845
Notes on pages
6
 
to
166
 
form an integral part of these consolidated financial statements.
 
 
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Notes to the Consolidated Financial Statements
 
.
6
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31 December 2024 Consolidated Financial Statements
1.
 
General information
Eurobank Ergasias Services and Holdings S.A.
 
(the Company
 
or Eurobank
 
Holdings), which
 
is the
 
parent
 
company of
 
Eurobank S.A.
(the
 
Bank)
 
and
 
its
 
subsidiaries
 
(the
 
Group),
 
consisting
 
mainly
 
of
 
Eurobank
 
S.A.
 
Group,
are active in retail, corporate and private
banking, asset management, treasury, capital markets and other services (note 44).
The Group operates mainly in Greece and in
Bulgaria, Cyprus and Luxembourg.
The Company is incorporated in Greece
,
 
with
 
its registered
 
office at
8 Othonos Street, Athens
105 57
 
and its shares are listed on the Athens
 
Stock Exchange.
These consolidated financial statements, which include the Appendix, were approved by the Board of
 
Directors on 7 March 2025. The
Independent Auditor’s Report of the Financial Statements
 
is included in the section E.I of the Annual Financial Report.
The website
 
address,
 
where the
 
annual
 
financial statements
 
of the
 
consolidated
 
non-listed
 
Company’s
 
subsidiaries are
 
uploaded,
along with the independent Auditors’ reports and the Board
 
of Directors’ Reports for these entities
 
is: www.eurobankholdings.gr.
2.
 
Basis of preparation and material accounting policies
The consolidated financial statements of the Group have been prepared on a
 
going concern basis and in
 
accordance with the material
accounting policies set out below:
2.1
 
Basis of preparation
The
 
consolidated
 
financial
 
statements
 
of
 
the
 
Group
 
have
 
been
 
prepared
 
in
 
accordance
 
with
 
International
 
Financial
 
Reporting
Standards
 
(IFRS) issued
 
by the
 
International
 
Accounting
 
Standards
 
Board
 
(IASB), as
 
endorsed by
 
the European
 
Union (EU),
 
and in
particular with those standards and interpretations, issued and
 
effective or issued and early adopted as
 
at the time of
 
preparing these
consolidated financial statements.
The consolidated
 
financial statements
 
are prepared
 
under the
 
historical
 
cost basis
 
except
 
for the
 
financial assets
 
measured at
 
fair
value through
 
other comprehensive
 
income, financial
 
assets and
 
financial liabilities
 
(including derivative
 
instruments) measured
 
at
fair-value-through-profit-or-loss
 
and investment property measured
 
at fair value.
The accounting policies for
 
the preparation of
 
the consolidated financial
 
statements of the
 
Group have been
 
consistently applied to
the years
 
2024 and
 
2023, after
 
taking into
 
account the
 
amendments in
 
IFRSs as
 
described in
 
section 2.1.1
 
(a) “New
 
and amended
standards
 
adopted
 
by the
 
Group
 
as of
 
1 January
 
2024”.
 
In addition,
 
where necessary,
 
comparative
 
figures
 
have
 
been adjusted
 
to
conform to changes in presentation
 
in the current year.
The preparation of financial
 
statements in accordance with IFRS
 
requires the use of
 
estimates and judgements that affect the
 
reported
amounts of
 
assets and liabilities
 
and disclosure
 
of contingent
 
liabilities at the
 
date of the
 
consolidated financial
 
statements,
 
as well
as
 
the
 
reported
 
amounts
 
of
 
revenues
 
and
 
expenses
 
during
 
the
 
reporting
 
period.
 
Although
 
these
 
estimates
 
are
 
based
 
on
management's best knowledge of current events
 
and conditions, actual results ultimately may differ
 
from those estimates.
The Group’s presentation
 
currency is the Euro (€) being the functional currency of the parent company. Except
 
as indicated, financial
information presented in Euro
 
has been rounded to the nearest million. The figures
 
presented in the notes may not sum precisely to
the totals provided due to rounding.
 
Going concern considerations
The annual financial
 
statements have been prepared on
 
a going
 
concern basis, as
 
the Board of
 
the Directors considered as
 
appropriate,
taking into consideration the following:
In 2024, despite the
 
challenging international environment,
 
the macroeconomic backdrop
 
was supportive in the
 
Group’s three
 
core
markets.
 
In particular,
 
the economies
 
of Greece,
 
Bulgaria
 
and Cyprus
 
remained in
 
expansionary territory,
 
overperforming
 
most
 
of
their European
 
Union (EU)
 
peers. According
 
to the
 
Hellenic Statistical
 
Authority (ELSTAT)
 
provisional
 
data, the
 
real GDP
 
of Greece
expanded by 2.3% on an annual basis in the first nine months of 2024 –versus
 
0.5% in the euro area (Eurostat)–
 
driven by household
consumption and
 
the buildup of
 
inventories.
 
The average
 
annual inflation
 
rate based
 
on the Harmonized
 
Index of Consumer
 
Prices
(HICP) decreased to 3.0% in 2024 from 4.2% in 2023, while the average monthly unemployment rate declined to 10.1% in 2024, from
11.1% in 2023,
 
dropping to a 15-year
 
low. In its Autumn Economic
 
Forecasts (November 2024), the European Commission
 
(EC) expects
real GDP in
 
Greece to grow
 
by 2.1% in 2024
 
and 2.3% in 2025
 
(2023: 2.3%). The HICP
 
growth rate
 
is expected to
 
decelerate to
 
2.4%
in 2025 and the unemployment rate to drop to
 
9.8%, respectively. On the fiscal front, the EC expects a primary
 
surplus of 2.9% of GDP
Notes to the Consolidated Financial Statements
 
.
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31 December 2024 Consolidated Financial Statements
 
 
 
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in 2024 and 2025, up from 2.1% of GDP in 2023.
 
The gross public debt-to-GDP ratio, following a sizeable increase in nominal GDP due
to the combination
 
of real GDP
 
growth and
 
inflation, is expected
 
to decline to
 
153.1% in 2024
 
and 146.8% in
 
2025, from 163.9%
 
in
2023.
According to the EC Autumn
 
Economic Forecasts, real
 
GDP growth in Bulgaria in 2024
 
is expected at 2.4%, with
 
a moderate increase
in 2025 to 2.9% (2023: 1.8%), while the HICP is forecast
 
to decrease to 2.5% in 2024 and to 2.3% in 2025 (2023: 8.6%). In
 
Cyprus, the
real GDP growth is forecast at 3.6%
 
and 2.8% in 2024
 
and 2025, respectively (2023: 2.5%), while
 
the HICP is estimated at
 
2.2% in 2024,
and 2.1% in 2025 (2023: 3.9%).
Growth in Greece as well as in Bulgaria and Cyprus is expected to receive a significant boost from EU-funded investment projects and
reforms. Greece shall receive in
 
total € 36 billion (€ 18.2 billion in grants and
 
€ 17.7 billion in loans) up to 2026 through the Recovery
and Resilience Facility (RRF), Next Generation EU (NGEU)’s
 
largest instrument, out of which € 18.2 billion (€ 8.6 billion in grants and €
9.6 billion
 
in loans)
 
had been
 
disbursed by
 
the EU
 
as of
 
the end
 
2024. A
 
further €
 
40 billion
 
is due
 
through EU’s
 
long-term budget
(MFF), out of which € 20.9 billion is to fund the National Strategic Reference
 
Frameworks (ESPA
 
2021–2027).
In 2024, the
 
Greek government
 
raised €
 
9.55 billion from
 
the international
 
financial markets
 
through the
 
Public Debt Management
Agency (PDMA) by issuing two new
 
bonds (a 10-year bond at a yield
 
of 3.478% in January and a 30-year
 
bond at a yield of 4.241% in
April),
 
and
 
re-opening
 
eleven
 
past
 
issues
 
with
 
maturities
 
of
 
5
 
and
 
10
 
years.
 
At
 
the
 
end
 
of
 
2024,
 
the
 
cash
 
reserves
 
of
 
the
 
Greek
government
 
stood
 
close
 
to
 
 
33
 
billion.
 
Following
 
a
 
series
 
of
 
sovereign
 
rating
 
upgrades
 
in
 
the
 
second
 
half
 
of
 
2023,
 
the
 
Greek
government’s
 
long-term
 
debt
 
securities were
 
considered
 
investment
 
grade
 
by
 
four
 
out of
 
the five
 
Eurosystem-approved
 
External
Credit Assessment Institutions (DBRS:
 
BBB(low), positive outlook, Fitch:
 
BBB-, stable outlook; Scope: BBB,
 
stable outlook; S&P: BBB-,
positive outlook), and one notch
 
below investment grade
 
by the fifth one, Moody’s
 
(Βa1, positive outlook) as of
 
31 December 2024.
On monetary policy developments, after
 
ten rounds of interest rate hikes
 
in 2022 and
 
in 2023 and
 
on the back
 
of an improved inflation
outlook, the European
 
Central Bank (ECB)
 
implemented five interest
 
rate cuts
 
from June 2024 to
 
January 2025, lowering
 
its deposit
facility rate by 125 basis points in total.
Regarding
 
the
 
outlook
 
for
 
the
 
next
 
12
 
months,
 
the
 
major
 
macroeconomic
 
risks
 
and
 
uncertainties
 
in
 
Greece
 
and
 
our
 
region
 
are
associated with: (a) the geopolitical tensions caused primarily by the war in Ukraine and the fragile situation
 
in the Middle East, their
implications regarding
 
regional and
 
global stability
 
and security,
 
and their repercussions
 
on the global
 
and the European
 
economy,
(b) an interruption or even a reversal of the disinflationary trend observed in the past 24 months and its impact on economic growth,
employment,
 
public finances,
 
household
 
budgets,
 
firms’
 
production
 
costs,
 
external
 
trade
 
and banks’
 
asset quality,
 
as
 
well
 
as
 
any
potential social and/or political ramifications this may entail, (c) the timeline of the potential further interest rate cuts by the ECB
 
and
the Federal
 
Reserve Bank,
 
as persistence
 
on high
 
rates for
 
longer may
 
keep exerting
 
pressure on
 
sovereign and
 
private
 
borrowing
costs and certain financial institutions’ balance
 
sheets, but early rate cuts entail
 
the risk of a rebound in inflation, (d) the prospect
 
of
Greece’s and
 
Bulgaria’s
 
major trade partners,
 
primarily the euro area,
 
remaining stagnant or
 
even facing a temporary
 
downturn, (e)
the elevated political and economic
 
uncertainty stemming from the international and
 
trade policy decisions of
 
the new administration
in the
 
United States,
 
(f) the
 
persistently
 
large current
 
account deficit
 
that seems
 
to become
 
once again
 
a structural
 
feature
 
of the
Greek economy,
 
(g) the absorption
 
capacity of the
 
NGEU and MFF
 
funds and
 
the attraction
 
of new
 
investments in
 
the countries
 
of
presence, especially in
 
Greece, (h) the effective and
 
timely implementation of the
 
reform agenda required to meet the
 
RRF milestones
and targets and to boost productivity,
 
competitiveness, and resilience and (i) the exacerbation of natural disasters due to the climate
change and their effect on GDP,
 
employment, fiscal balance and sustainable development
 
in the long run.
Materialization of the
 
above risks would have
 
potentially adverse effects
 
on the fiscal planning of the
 
Greek government, as
 
it could
decelerate the pace of
 
expected growth
 
and on the liquidity,
 
asset quality,
 
solvency and profitability of
 
the Greek banking sector.
 
In
this context,
 
the Group’s
 
Management and
 
Board are
 
continuously monitoring
 
the developments
 
on the macroeconomic,
 
financial
and geopolitical
 
fronts
 
as well
 
as the
 
evolution of
 
the Group’s
 
asset quality
 
and liquidity
 
KPIs and
 
have
 
maintained
 
a high
 
level of
readiness, so as to accommodate decisions, initiatives
 
and policies to protect the Group’s
 
capital, asset quality and liquidity standing
as well as the fulfilment, to the maximum possible degree, of its strategic and business goals in accordance with the business plan for
2025 - 2027.
In the
 
year ended
 
31 December 2024,
 
the net
 
profit attributable
 
to shareholders,
 
following the
 
inclusion of
 
Hellenic Bank group
 
in
the Company’s consolidated financial statements from the third quarter of 2024, amounted to € 1,448 million (2023:
 
€ 1,140 million).
The adjusted
 
net profit,
 
excluding a)
 
the €
 
121 million
 
restructuring costs
 
(after tax),
 
mainly related
 
to VES
 
(note 12),
 
b) the €
 
99.5
million gain arising
 
from the acquisition
 
of an additional
 
26.28% shareholding of
 
Hellenic Bank in
 
June 2024 (note
 
23.2), c) the €
 
19
million Bank’s contribution
 
(after tax) for the Greek state’s
 
program for school renovations
 
(note 11), d) the € 11 million impairment
 
Notes to the Consolidated Financial Statements
 
.
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31 December 2024 Consolidated Financial Statements
 
 
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release (after
 
tax)
 
relating
 
to the
 
project
 
“Leon” (note
 
21) and
 
e) the
 
€ 7
 
million net
 
loss from
 
discontinued
 
operations
 
(note
 
30)
amounted to € 1,484
 
million (2023: € 1,256 million),
 
of which € 709 million profit
 
was related to
 
the international operations
 
(2023:
€ 468 million profit). As at 31 December 2024, the Group’s Total
 
Adequacy Ratio (total CAD) and Common Equity Tier 1 (CET1) ratios,
including the
 
impact of
 
the distribution
 
of cash
 
dividend to
 
shareholders
 
approved
 
by the
 
AGM
 
in July
 
2024 and
 
the inclusion
 
of
Hellenic Bank group
 
in the Company’s
 
consolidated financial statements
 
,
 
stood at 19.5% (31
 
December 2023: 19.4%) and
 
16.8% (31
December
 
2023:
 
16.9%)
 
respectively.
 
Pro-forma
 
with
 
the
 
dividend
 
accrual
 
to
 
be
 
distributed
 
to
 
shareholders
 
in
 
2025
 
(subject
 
to
regulatory
 
approval),
 
the
 
completion
 
of
 
project
 
“Solar” as
 
well
 
as
 
the
 
confirmation
 
by
 
ECB,
 
of
 
the
 
significant
 
risk
 
transfer
 
(SRT)
recognition for
 
the “Leon” loan portfolio
 
and the project
 
“Wave VI”,
 
the total CAD
 
and CET1 ratios,
 
as of 31 December
 
2024, would
be 18.5% and 15.7% respectively (note 4).
With regard
 
to asset quality,
 
the Group’s
 
NPE formation, including
 
the impact of Hellenic Bank,
 
was positive by €
 
222 million during
the year
 
(fourth
 
quarter 2024:
 
€ 47
 
million positive),
 
(2023: €
 
138 million
 
positive). In
 
total, the
 
Group’s
 
NPE stock
 
stood
 
at €
 
1.5
billion, excluding
 
the €
 
0.2 billion
 
NPE of
 
Hellenic Bank
 
covered
 
by the
 
Asset Protection
 
Scheme (APS)
 
(31 December
 
2023: €
 
1.5
billion), driving
 
the NPE ratio
 
to 2.9% at
 
31 December 2024
 
(31 December 2023:
 
3.5%). Τhe
 
NPE coverage
 
ratio improved
 
to 88.4%
(31 December 2023: 86.4%) (note 20).
In terms of liquidity, as at 31 December 2024 the
 
Group deposits, including the impact of the Hellenic Bank consolidation that added
€ 15.8
 
billion, stood
 
at €
 
78.6 billion
 
(31 December
 
2023: €
 
57.4 billion),
 
leading the
 
Group’s
 
(net) loans
 
to deposits
 
(L/D) ratio
 
to
64.8% (31 December 2023:
 
72.3%). The funding from the
 
targeted long term refinancing operations of the ECB –
 
TLTRO III programme
was fully repaid
 
during the year (31
 
December 2023: € 3.8 billion)
 
(note 31), while the
 
Group’s debt
 
securities in issue, increased
 
by
€ 2.3 billion (note
 
25). As at 31
 
December 2024, the Bank’s
 
MREL ratio
 
at consolidated
 
level stands at
 
28.22% of RWAs,
 
higher than
the interim non-binding
 
MREL target
 
of 25.62% from
 
January 2025 (note 4).
 
The Group Liquidity
 
Coverage ratio
 
(LCR) has increased
to
 
188.2%
 
(31 December
 
2023:
 
178.6%).
 
In
 
the
 
context
 
of
 
the 2024
 
ILAAP
 
(Internal
 
Liquidity
 
Adequacy
 
Assessment
 
Process),
 
the
liquidity stress tests
 
results indicated
 
that the Bank has
 
adequate liquidity buffer
 
to cover the
 
potential outflows that
 
could occur in
all scenarios regarding the short term (1 month),
 
the 3-month and the medium-term horizon (1 year).
On 18 December
 
2024, the Board of Directors of
 
Eurobank Holdings decided the
 
initiation of the merger
 
process of Eurobank Holdings
with the Bank
 
through absorption of
 
the former by
 
the latter,
 
in order that
 
operational efficiencies
 
and a leaner group
 
structure be
achieved.
 
The merger is not
 
expected to have
 
any material effect
 
on the Group’s
 
financial position and will be
 
completed subject to
all necessary by Law approvals (note 23.3).
Going concern assessment
The Board of
 
Directors, acknowledging
 
the geopolitical, macroeconomic
 
and financial risks
 
to the economy
 
and the banking
 
system
and taking into account the above factors relating to (a) the idiosyncratic growth opportunities in Greece, Bulgaria and Cyprus
 
for this
and the next years, also underpinned by the
 
mobilisation of the EU funding mainly
 
through the RRF, and (b) the Group’s pre-provision
income generating capacity,
 
asset quality, capital
 
adequacy and liquidity position, has been satisfied
 
that the financial statements
 
of
the Group can be prepared on a going concern basis.
 
 
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Notes to the Consolidated Financial Statements
 
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2.1.1
 
New and amended standards and interpretations
(a) New and amended standards adopted by the Group as
 
of 1 January 2024
The following
 
amendments to
 
existing
 
standards
 
as issued
 
by the
 
IASB and
 
endorsed by
 
the EU,
 
that
 
are relevant
 
to
 
the Group’s
activities apply as of 1 January 2024:
IAS 1, Amendments, Classification of Liabilities as Current or Non-Current
 
and Non-current liabilities with covenants
The
 
amendments,
 
published
 
in
 
January
 
2020,
 
introduce
 
a
 
definition
 
of
 
settlement
 
of
 
a
 
liability,
 
while
 
they
 
make
 
clear
 
that
 
the
classification of liabilities as current or non-current should be based on rights that are in existence at the end of the reporting period.
In addition,
 
it is clarified
 
that the assessment
 
made at the
 
end of the
 
reporting period
 
for liabilities’ classification
 
is not affected
 
by
the expectations about events after the reporting period and whether an entity will exercise its right to defer settlement of a liability.
The Board also clarified that when classifying liabilities as current
 
or non-current, an entity can ignore only
 
those conversion options
that are classified as equity.
In October 2022, the IASB issued
 
Non-current Liabilities with Covenants
 
(Amendments to IAS 1)”
 
with respect to liabilities for
 
which
an entity’s
 
right to
 
defer
 
their settlement
 
for
 
at
 
least
 
12 months
 
after the
 
reporting
 
date,
 
is subject
 
to the
 
entity
 
complying with
conditions after
 
the reporting
 
period (“future
 
covenants”).
 
The amendments
 
specify that
 
covenants
 
to be
 
complied with
 
after the
reporting
 
date do
 
not affect
 
the classification
 
of debt
 
as current
 
or non-current
 
at the
 
reporting date.
 
However,
 
the amendments
require a company to disclose information
 
about these covenants in the notes to the financial statements.
The adoption of the amendments had no impact on the consolidated financial statements.
IFRS 16, Amendments, Lease Liability in a Sale and Leaseback
The amendments require a seller-lessee
 
to subsequently measure lease liabilities arising in a sale and
 
leaseback transaction in a way
that it does not recognise any amount of the gain or loss that relates to the right of use it retains. Any gains
 
and losses relating to the
full or partial termination of a lease continue to be recognised when they occur. The amendment does not change the accounting for
leases unrelated to sale and leaseback transactions.
The adoption of the amendments had no impact on the consolidated financial statements.
(b) New and amended standards not yet adopted by the Group
A number of new
 
standards and amendments
 
to existing standards
 
are effective
 
after 2024, as
 
they have not
 
yet been endorsed
 
by
the EU or have not been early applied by the Group. Those that may
 
be relevant to the Group are set
 
out below:
IFRS 18, Presentation and Disclosure in Financial Statements
 
(effective 1 January 2027, not yet endorsed by EU)
In April 2024, the IASB published
 
the new standard
 
IFRS 18 “Presentation
 
and Disclosure in Financial Statements”
 
which will replace
IAS 1 “Presentation of
 
Financial Statements”. The new standard sets out the
 
requirements for presentation and disclosures in financial
statements with focus
 
on the income statement and reporting of financial performance,
 
in order to ensure that financial statements
provide relevant information
 
that faithfully represents an entity’s
 
financial position, performance, and cash flows.
Specifically,
 
the
 
new
 
standard
 
contains
 
new
 
guidance
 
regarding
 
the
 
structure
 
of
 
the
 
income
 
statement,
 
as
 
well
 
as
 
disclosure
requirements for
 
Management-defined Performance
 
Measures (MPMs). In
 
addition, it provides
 
enhanced guidance on
 
aggregation
and disaggregation
 
of information on
 
the face of financial
 
statements and
 
in the notes,
 
while sets out general
 
requirements for
 
the
classification and presentation of assets, liabilities,
 
equity, income, and expenses.
The new standard
 
is effective
 
for annual periods
 
beginning on or
 
after January 1,
 
2027, with early
 
adoption permitted
 
and will also
apply to comparative information.
The Group is currently assessing the impact of IFRS 18 on its
 
consolidated financial statements.
IAS 21, Amendments, Lack of Exchangeability (effective
 
1 January 2025)
The
 
amendments
 
to
 
IAS 21”
 
The
 
Effects
 
of
 
Changes
 
in
 
Foreign
 
Exchange
 
Rates”,
 
specify how
 
an
 
entity
 
can
 
determine
 
whether
 
a
currency
 
is
 
exchangeable
 
into
 
another
 
currency
 
at
 
the
 
measurement
 
date,
 
and
 
the
 
spot
 
exchange
 
rate
 
to
 
use
 
when
 
it
 
is
 
not.
 
In
addition,
 
when
 
a
 
currency
 
is
 
not
 
exchangeable
 
an
 
entity
 
should
 
disclose
 
information
 
that
 
would
 
enable
 
users
 
of
 
its
 
financial
statements to understand
 
the related effects and risks as well as the
 
estimated rates and techniques used.
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
 
 
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The adoption of the amendments is not expected to impact the consolidated
 
financial statements.
IFRS 9
 
& IFRS
 
7, Amendments
 
to the
 
Classification and
 
Measurement of
 
Financial Instruments
 
(effective 1
 
January 2026,
 
not yet
endorsed by EU)
In May 2024,
 
the IASB issued “Amendments
 
to the Classification
 
and Measurement of
 
Financial Instruments
 
– Amendments to
 
IFRS
9 and IFRS 7”. The amendments clarify the requirements related to the derecognition
 
of financial liabilities settled through electronic
payment
 
systems,
 
provide
 
additional
 
guidance
 
for
 
the
 
SPPI
 
assessment
 
of
 
financial
 
instruments
 
with
 
contingent
 
features,
 
non-
recourse features,
 
as well as for transactions that are contractually
 
linked instruments.
Additionally, the amendments introduce disclosure requirements regarding
 
financial instruments with contingent features, as well as
for investment in equity instruments
 
designated at FVOCI.
The amendments are effective for
 
annual reporting periods beginning on or after 1 January 2026 with earlier application permitted.
The Group is currently assessing the impact of the amendments on its
 
consolidated financial statements.
Annual improvements to IFRSs - Volume
 
11 (effective 1 January 2026, not yet endorsed by EU)
In July 2024,
 
the IASB issued
 
amendments to several
 
IFRS standards,
 
which resulted
 
from the IASB’s
 
annual improvements
 
process.
This volume includes minor amendments to several standards
 
namely:
-IFRS 1 “First-time
 
Adoption of International
 
Financial Reporting Standards”
 
on Clarifications on hedge
 
accounting for first
 
-time
adopters,
-IFRS 7
 
“Financial Instruments:
 
Disclosures”
 
and its
 
accompanying
 
Guidance on
 
implementing IFRS
 
7
in disclosures
 
related
 
to
derecognition,
 
fair value and credit risk,
-IFRS 9
 
“Financial Instruments”
 
on clarifications
 
about lessee
 
derecognition
 
of lease
 
liabilities and
 
on definition
 
of transaction
price over the initial measurement of trade receivables,
-IFRS 10 “Consolidated Financial Statements”
 
on the determination of a 'De Facto Agent'
 
and
-IAS 7 “Statement of Cash-Flows” on definition of cost
 
method.
The adoption of the amendments is not expected to impact the consolidated
 
financial statements.
2.2
 
Material accounting policies
2.2.1
 
Consolidation
 
(i) Subsidiaries
Subsidiaries are all entities controlled by the Group. The Group controls an entity when it is exposed, or
 
has rights to, variable returns
from
 
its
 
involvement
 
with
 
the
 
entity,
 
and
 
has
 
the
 
ability
 
to
 
affect
 
those
 
returns
 
through
 
its
 
power
 
over
 
the
 
entity.
 
The
 
Group
consolidates an entity only when all the above three elements
 
of control are present.
Power over
 
the entity may
 
arise from voting rights
 
granted by equity
 
instruments such as shares
 
or,
 
in other cases, may
 
result from
contractual arrangements.
Where voting
 
rights are
 
relevant,
 
the Group
 
is deemed
 
to have
 
control
 
where it
 
holds, directly
 
or indirectly,
 
more than
 
half of
 
the
voting rights over
 
an entity,
 
unless there is evidence
 
that another investor
 
has the practical
 
ability to unilaterally
 
direct the relevant
activities.
The
 
Group
 
may
 
have
 
power,
 
even
 
when
 
it
 
holds
 
less
 
than
 
a
 
majority
 
of
 
the
 
voting
 
rights
 
of
 
the
 
entity,
 
through
 
a
 
contractual
arrangement
 
with
 
other
 
vote
 
holders,
 
rights
 
arising
 
from
 
other
 
contractual
 
arrangements,
 
substantive
 
potential
 
voting
 
rights,
ownership of the largest
 
block of voting rights in a situation
 
where the remaining rights are
 
widely dispersed (‘de
 
facto power’), or a
combination
 
of
 
the
 
above.
 
In assessing
 
whether
 
the
 
Group
 
has
 
de
 
facto
 
power,
 
it
 
considers
 
all
 
relevant
 
facts
 
and
 
circumstances
including
 
the
 
relative
 
size
 
of
 
the
 
Group’s
 
holding
 
of
 
voting
 
rights
 
and dispersions
 
of
 
holdings of
 
other
 
vote
 
holders
 
to
 
determine
whether the Group has the practical ability to direct
 
the relevant activities.
 
In assessing whether the
 
Group has the ability
 
to use its power
 
to affect
 
the amount of returns
 
from its involvement
 
with an entity,
the Group determines whether in
 
exercising its decision-making rights,
 
it is acting as an agent or
 
as a principal. The Group acts as
 
an
agent when it is engaged
 
to act on behalf and for
 
the benefit of another party,
 
and as a result does not
 
control an entity.
 
Therefore,
in
 
such
 
cases,
 
the
 
Group
 
does not
 
consolidate
 
the
 
entity.
 
In making
 
the
 
above
 
assessment,
 
the
 
Group
 
considers
 
the scope
 
of
 
its
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
 
 
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decision-making authority over the
 
entity, the
 
rights held by other
 
parties, the remuneration
 
to which the Group
 
is entitled from its
involvement, and its exposure to
 
variability of returns from other interests
 
in that entity.
The Group
 
has interests
 
in certain
 
entities which
 
are structured
 
so that
 
voting rights
 
are not
 
the dominant
 
factor
 
in deciding
 
who
controls the entity, such as when any voting rights
 
relate to administrative tasks only and the relevant activities are
 
directed by means
of contractual rights. In determining whether the Group
 
has control over such structured entities, it considers
 
the following factors:
The purpose and design of the entity;
Whether the
 
Group has
 
certain rights
 
that give
 
it the
 
ability to
 
direct the
 
relevant
 
activities of
 
the entity
 
unilaterally,
 
as a
result of existing contractual
 
arrangements that give it the power to govern
 
the entity and direct its activities;
In case another entity
 
is granted decision making
 
rights, the Group assesses whether
 
this entity acts as
 
an agent of the
 
Group
or another investor;
The existence of any special relationships
 
with the entity; and
The extent
 
of the Group’s
 
exposure to
 
variability of
 
returns from
 
its involvement
 
with the entity,
 
including its exposure
 
in
the most subordinated securitization notes issued by the entity as well as subordinated loans or other credit enhancements
that may be granted to the entity,
 
and if the Group has the power to affect such variability.
Information about the Group’s
 
structured entities is set out in note 25.
The Group reassesses whether it
 
controls an entity if facts
 
and circumstances indicate that there are
 
changes to one or
 
more elements
of
 
control.
 
This
 
includes
 
circumstances
 
in
 
which
 
the
 
rights
 
held
 
by
 
the
 
Group
 
and
 
intended
 
to
 
be
 
protective
 
in
 
nature
 
become
substantive upon
 
a breach of
 
a covenant
 
or default on
 
payments in a
 
borrowing arrangement,
 
and lead to
 
the Group having
 
power
over the investee.
Subsidiaries are
 
fully consolidated
 
from the
 
date on
 
which control
 
is transferred
 
to the Group
 
and are
 
no longer consolidated
 
from
the
 
date
 
that
 
control
 
ceases.
 
Total
 
comprehensive
 
income
 
is
 
attributed
 
to
 
the
 
owners
 
of
 
the
 
parent
 
and
 
to
 
the
 
non-controlling
interests even if this results
 
in the non-controlling interests having
 
a deficit balance.
In determining the proportion of profit or loss and changes in equity allocated
 
to the Group and non-controlling interests,
 
the Group
takes
 
into
 
account
 
current
 
ownership
 
interests,
 
also
 
including
 
in-substance
 
current
 
ownership
 
interests,
 
after
 
considering
 
the
eventual exercise
 
of any potential
 
voting rights
 
and other derivatives
 
that currently
 
give the Group
 
access to the returns
 
associated
with an ownership interest.
Changes in the
 
Group's ownership
 
interest in
 
subsidiaries that do
 
not result in
 
a loss of control
 
are recorded
 
as equity transactions.
Any difference between the consideration
 
and the share of the new net assets acquired is recorded directly in equity. Gains or losses
arising from disposals of
 
ownership interests that
 
do not result in a
 
loss of control
 
by the Group are
 
also recorded directly
 
in equity.
For disposals of ownership interests
 
that result in a loss of control, the Group derecognizes
 
the assets and liabilities of the subsidiary
and any related
 
non-controlling interest
 
and other components
 
of equity and
 
recognizes gains
 
and losses in
 
the income statement.
When
 
the
 
Group
 
ceases to
 
have
 
control,
 
any
 
retained
 
interest
 
in
 
the former
 
subsidiary
 
is re-measured
 
to
 
its
 
fair
 
value,
 
with
 
any
changes in
 
the carrying
 
amount recognized
 
in the
 
income statement.
 
The Group
 
considers
 
the eventual
 
exercise
 
of any
 
potential
voting
 
rights
 
and
 
other
 
derivatives
 
and
 
whether
 
they
 
currently
 
give
 
the
 
Group
 
access
 
to
 
the
 
returns
 
associated
 
with
 
a
 
retained
ownership interest, in determining
 
whether that ownership interest should
 
be derecognised or not.
Intercompany transactions,
 
balances and intragroup
 
gains on transactions between
 
Group entities are eliminated;
 
intragroup losses
are also eliminated unless the transaction provides
 
evidence of impairment of the asset transferred.
 
(ii) Business combinations
The purchase method of accounting is used to account for the acquisition of subsidiaries by the
 
Group. The consideration transferred
for an acquisition is measured at the fair value of the assets given, equity instruments
 
issued or exchanged and liabilities undertaken
at
 
the
 
date
 
of
 
acquisition,
 
including
 
the
 
fair
 
value
 
of
 
assets
 
or
 
liabilities
 
resulting
 
from
 
a
 
contingent
 
consideration
 
arrangement.
Acquisition related
 
costs are expensed
 
as incurred. Identifiable
 
assets acquired and
 
liabilities and contingent
 
liabilities assumed in a
business combination are measured initially at
 
their fair values at the
 
acquisition date irrespective of the
 
extent of any non-controlling
interest. Any previously held interest in
 
the acquiree is
 
remeasured to fair value
 
at the acquisition
 
date with any gain
 
or loss recognized
in the
 
income statement.
 
The Group
 
recognizes
 
on an
 
acquisition-by-acquisition basis
 
any non-controlling
 
interest
 
in the
 
acquiree
either at fair value or at the non-controlling
 
interest's proportionate share
 
of the acquiree's net assets.
Notes to the Consolidated Financial Statements
 
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The excess of the consideration
 
transferred, the
 
amount of any non-controlling
 
interest in the acquiree and
 
the acquisition-date fair
value of
 
any previous
 
equity interest
 
in the
 
acquiree over
 
the fair
 
value of
 
the identifiable
 
net assets
 
of the
 
subsidiary acquired,
 
is
recorded as
 
goodwill. If
 
this is
 
less than
 
the fair
 
value of
 
the net
 
assets of
 
the acquiree,
 
the difference
 
is recognized
 
directly in
 
the
income statement.
If the
 
initial accounting
 
for a
 
business combination
 
is incomplete
 
by the
 
end of
 
the reporting
 
period in
 
which it
 
occurs, the
 
Group
reports
 
provisional
 
amounts
 
for
 
the
 
items
 
for
 
which
 
the
 
accounting
 
is
 
incomplete.
 
Those
 
provisional
 
amounts
 
are
 
adjusted
retrospectively
 
during
 
the
 
measurement
 
period
 
to
 
reflect
 
the
 
new
 
information
 
obtained
 
about
 
the
 
facts
 
and
 
circumstances
 
that
existed at
 
the acquisition
 
date that,
 
if known,
 
would have
 
affected the
 
amounts recognized
 
at that
 
date. The
 
measurement period
adjustments, as
 
mentioned above,
 
affect accordingly
 
the amount
 
of goodwill
 
that was
 
initially recognized,
 
while the
 
measurement
period cannot exceed one year from
 
the acquisition date.
Commitments to
 
purchase non-controlling
 
interests
 
through derivative
 
financial instruments
 
with the
 
non-controlling
 
interests,
 
as
part of
 
a business
 
combination
 
are
 
accounted
 
for
 
as a
 
financial liability,
 
with no
 
non-controlling
 
interest
 
recognized
 
for
 
reporting
purposes.
 
The
 
financial
 
liability
 
is
 
measured
 
at
 
fair
 
value,
 
using
 
valuation
 
techniques
 
based
 
on
 
best
 
estimates
 
available
 
to
Management. Any difference between
 
the fair value of the financial liability upon initial recognition and the nominal non-controlling
interest's share of net assets is recognized as part of goodwill. Subsequent revisions to the valuation of the
 
derivatives are recognized
in the income statement.
Agreements to acquire or dispose shares in an entity that will be settled at a future date and will result in a business combination are
accounted for by the Group as executory contracts and not as derivatives, under the relevant accounting standards. The term of such
agreements
 
should
 
not
 
exceed
 
a
 
reasonable
 
period
 
normally
 
necessary
 
to
 
obtain
 
any
 
required
 
approvals
 
and
 
complete
 
the
transaction.
For
 
acquisitions
 
of
 
subsidiaries
 
not
 
meeting
 
the
 
definition
 
of
 
a
 
business,
 
the
 
Group
 
allocates
 
the
 
consideration
 
to
 
the
 
individual
identifiable assets and liabilities based
 
on their relative fair
 
values at the date of
 
acquisition. Such transactions or events
 
do not give
rise to goodwill.
A listing of the Bank’s subsidiaries is set
 
out in note 23.
(iii) Business combinations involving entities under common control
Pursuant to
 
IAS 8 ‘Accounting
 
Policies, Changes
 
in Accounting
 
Estimates and
 
Errors’,
 
since business
 
combinations between
 
entities
under common
 
control
 
are excluded
 
from the
 
scope of
 
IFRS 3
 
‘Business Combinations’,
 
such transactions
 
are accounted
 
for in
 
the
Group’s financial statements by using the pooling of interests method (also known as merger accounting), with reference to the most
recent pronouncements of other standard-setting bodies that use a similar conceptual framework and comply with the IFRSs general
principles, as well as accepted industry practices.
Under the
 
pooling
 
of interests
 
method, the
 
Group
 
incorporates
 
the assets
 
and liabilities
 
of the
 
acquiree
 
at their
 
pre-combination
carrying amounts from the highest level of
 
common control, without any
 
fair value adjustments. Any difference
 
between the cost
 
of
the transaction and the carrying amount of the net assets acquired
 
is recorded in Group's equity.
The Group accounts for the cost of such business combinations at the fair value of the consideration
 
given, being the amount of cash
or shares issued or if that cannot be reliably measured, the consideration
 
received.
Formation of a new Group entity to effect a business combination
Common control transactions that involve the formation of a new Group entity to effect a business combination by bringing together
two or more previously uncombined
 
businesses under the new Group entity
 
are also accounted for
 
by using the pooling of interests
method.
Other common control
 
transactions that involve
 
the acquisition of a single existing
 
Group entity or a single
 
group of businesses by
 
a
new entity formed
 
for this purpose
 
are accounted
 
for as capital
 
reorganizations,
 
on the basis that
 
there is no business
 
combination
and no substantive
 
economic change in
 
the Group. Under
 
a capital reorganization,
 
the acquiring entity
 
incorporates the
 
assets and
liabilities of the acquired
 
entity at their carrying
 
amounts, as presented
 
in the books of
 
that acquired entity,
 
rather than those
 
from
the highest level
 
of common control.
 
Any difference
 
between the cost
 
of the transaction
 
and the carrying amount
 
of the net assets
acquired is
 
recognized
 
in the
 
equity of
 
the new
 
entity.
 
Capital reorganization
 
transactions do
 
not have
 
any impact
 
on the
 
Group’s
consolidated financial statements.
Notes to the Consolidated Financial Statements
 
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(iv) Associates
Investments
 
in associates are
 
accounted for
 
using the equity
 
method of
 
accounting in the
 
consolidated financial
 
statements. These
are undertakings over which the Group exercises
 
significant influence but which are not controlled.
Equity accounting
 
involves recognizing
 
in the income
 
statement
 
the Group's
 
share of
 
the associate's profit
 
or loss for
 
the year.
 
The
Group's interest in the associate is carried
 
on the balance sheet at an amount that reflects its share of the net assets of the associate
and any
 
goodwill identified
 
on acquisition
 
net of any
 
accumulated impairment
 
losses. If the
 
Group's share
 
of losses of
 
an associate
equals or
 
exceeds its
 
interest
 
in the associate,
 
the Group
 
discontinues recognizing
 
its share
 
of further
 
losses, unless
 
it has incurred
obligations or made payments on behalf of the associate.
When the Group obtains
 
or ceases to have
 
significant influence, any
 
previously held or retained
 
interest in the
 
entity is remeasured
to its fair value, with any change in the carrying amount recognized in the income statement,
 
except in cases where an investment in
associate becomes
 
an investment
 
in a joint
 
venture where
 
no remeasurement
 
of the interest
 
retained is
 
performed and
 
use of the
equity method continues to apply.
(v) Joint arrangements
A
 
joint
 
arrangement
 
is
 
an
 
arrangement
 
under
 
which
 
the
 
Group
 
has
 
joint
 
control
 
with
 
one
 
or
 
more
 
parties.
 
Joint
 
control
 
is
 
the
contractually agreed sharing of control and exists only when decisions about relevant activities require the unanimous consent of the
parties sharing control. The Group evaluates
 
the contractual terms of joint arrangements
 
to determine whether a joint arrangement
is a joint operation or a joint venture.
 
All joint arrangements in which the Group has an interest
 
are joint ventures.
As
 
investments
 
in
 
associates,
 
the
 
Group's
 
interest
 
in
 
joint
 
ventures
 
is
 
accounted
 
for
 
by
 
using
 
the
 
equity
 
method
 
of
 
accounting.
Therefore, the accounting policy described
 
in note 2.2.1 (iv) applies also for joint ventures.
A listing of the Group's associates and joint ventures
 
is set out in note 24.
2.2.2 Foreign currencies
(i) Translation of foreign subsidiaries
Assets and liabilities of foreign
 
subsidiaries are translated
 
into the Group’s
 
presentation currency at
 
the exchange rates
 
prevailing at
each reporting
 
date whereas
 
income and expenses
 
are translated
 
at the average
 
exchange rates
 
for the
 
period reported.
 
Exchange
differences
 
arising from
 
the translation
 
of the
 
net investment
 
in a
 
foreign
 
subsidiary,
 
including exchange
 
differences
 
of monetary
items receivable or payable to the foreign
 
subsidiary for which settlement is neither planned nor likely
 
to occur that form part of the
net investment
 
in the
 
foreign
 
subsidiaries, are
 
recognized
 
in other
 
comprehensive income.
 
Exchange differences
 
from the
 
Group’s
foreign subsidiaries are released to
 
the income statement on their disposal.
(ii) Transactions in foreign currency
Foreign
 
currency
 
transactions
 
are
 
translated
 
into
 
the
 
functional
 
currency
 
using
 
the
 
exchange
 
rates
 
prevailing
 
at
 
the
 
dates
 
of
 
the
transactions.
 
Foreign
 
exchange
 
gains
 
and
 
losses
 
resulting
 
from
 
the
 
settlement
 
of
 
such
 
transactions
 
are
 
recognized
 
in
 
the
 
income
statement.
Monetary assets
 
and liabilities denominated
 
in foreign
 
currencies are translated
 
into the
 
functional currency
 
at the
 
exchange rates
prevailing at each reporting
 
date and exchange
 
differences are recognized
 
in the income statement,
 
except when deferred
 
in equity
as qualifying cash flow or net investment hedges.
Non-monetary assets and liabilities are
 
translated into the
 
functional currency at the exchange
 
rates prevailing
 
at initial recognition,
except for non-monetary items denominated
 
in foreign currencies that are measured at fair value
 
which are translated at the rate of
exchange at the date the fair value
 
is determined. The exchange differences
 
relating to these items are treated
 
as part of the change
in fair value
 
and are recognized
 
in the income statement
 
or directly in other
 
comprehensive income depending
 
on the classification
of the non-monetary item.
 
2.2.3 Derivative financial instruments and hedging
Derivative financial instruments that mainly include foreign exchange
 
contracts, forward currency agreements, currency
 
and interest
rate options (both written and purchased), as well as currency and
 
interest rate swaps are
 
initially recognized in the balance sheet at
Notes to the Consolidated Financial Statements
 
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fair value,
 
on the date
 
on which the
 
derivative contracts
 
are entered
 
into, and
 
subsequently are
 
re-measured at
 
their fair value.
 
All
derivatives are carried as assets when fair
 
value is positive and as liabilities when fair value is negative.
The principles
 
for the
 
fair value
 
measurement
 
of financial
 
instruments,
 
including derivative
 
financial instruments,
 
are described
 
in
notes 3.2 and 5.3.
Embedded derivatives
Embedded derivatives
 
are components
 
of hybrid
 
contracts
 
that also
 
include non-derivative
 
hosts with
 
the effect
 
that some
 
of the
cash flows of the combined instruments vary
 
in a way similar to stand-alone derivatives.
Financial
 
assets
 
that
 
contain
 
embedded
 
derivatives
 
are
 
recognised
 
in
 
the
 
balance
 
sheet
 
in
 
their
 
entirety
 
in
 
the
 
appropriate
classification category,
 
following the instruments’
 
assessment of their contractual
 
cash flows and
 
their business model as
 
described
in note 2.2.9.
On the other
 
hand, derivatives embedded in
 
financial liabilities, such
 
as bonds issued
 
by the Group, are
 
treated as separate derivatives
when their risks
 
and characteristics are
 
assessed not to
 
be closely related
 
to those of
 
the host contract
 
and the host
 
contract is not
carried
 
at
 
fair
 
value through
 
profit
 
or loss.
 
These embedded
 
derivatives
 
are
 
separated
 
in the
 
balance sheet
 
and
 
accounted
 
for
 
as
stand-alone derivatives measured at fair
 
value with changes in fair value recognized
 
in the income statement.
Derivatives held for hedge accounting
The use of derivative financial instruments is inherent
 
in the Group’s activities and aims principally at
 
managing risks effectively.
Accordingly,
 
the Group,
 
as part of
 
its risk management
 
strategy,
 
may enter
 
into transactions
 
with external
 
counterparties to
 
hedge
partially or fully exposure to interest rates,
 
foreign currency rates, equity prices and other market
 
factors that are generated
 
from its
activities.
The objectives of hedging with derivative financial instruments
 
include:
Reduce interest rate
 
exposure that is in excess of the Group’s
 
interest rate limits;
Manage efficiently
 
interest rate
 
risk and achieve
 
optimization and stabilization
 
of the evolution
 
of net interest
 
margin and
net interest
 
income by tracking
 
the evolution of
 
interest rates
 
and spreads and
 
hedging the changes
 
to the movements
 
of
the benchmark interest rates
 
represented by the prevailing reference
 
rates;
Manage the overall fair value
 
exposure on settled or unsettled (forward)
 
transactions
Reduce variability deriving from the fair value
 
changes of derivatives embedded in financial assets;
Manage future variable cash flows;
Reduce foreign currency risk or inflation
 
risk;
Reduce variability of the consideration to
 
be paid/received to acquire/sell a debt
 
security under a forward transaction,
Reduce accounting
 
exposure, i.e.
 
the variability
 
in the
 
Group’s
 
equity arising
 
from translating
 
a foreign
 
net investment
 
at
different exchange
 
rates.
Hedge accounting
The Group has elected,
 
as a policy choice permitted
 
under IFRS 9, to
 
continue to apply
 
hedge accounting in accordance
 
with IAS 39,
as endorsed by the European Union (IAS 39 “carve out'’). In 2023,
 
the Group introduced a new risk management strategy which is the
fair value hedging
 
of the core
 
deposits held in Greece
 
and Cyprus from
 
both retail and
 
wholesale portfolios. Accordingly,
 
the Group
applied for
 
the first
 
time the
 
provisions
 
of IAS
 
39 carve-out
 
that
 
enables entities
 
to designate
 
core
 
deposits as
 
hedged
 
items in
 
a
portfolio
 
hedge of
 
interest
 
rate
 
risk, as
 
further described
 
in the
 
sections below.
 
Under the
 
EU carve-out
 
version
 
of IAS
 
39, certain
requirements related
 
to hedge accounting
 
were removed,
 
in order to
 
facilitate (a)
 
the application of
 
fair value
 
hedge accounting
 
to
the macro-hedges
 
used for
 
structural hedges
 
including demand deposits
 
and (b) the
 
hedge effectiveness
 
assessment by
 
permitting
the use of bottom layer approach for
 
the determination of the fair value of hedged item,
 
attributable to interest
 
rate risk.
For
 
hedge
 
accounting
 
purposes,
 
the
 
Group
 
forms
 
a
 
hedging
 
relationship
 
between
 
a
 
hedging
 
instrument
 
or
 
group
 
of
 
hedging
instruments and a
 
related item or
 
group of items
 
to be hedged.
 
A hedging instrument
 
is a
 
designated derivative or group
 
of derivatives,
or a designated non-derivative financial asset or financial liability whose fair value or cash flows are expected to offset changes in the
fair value
 
or cash flows
 
of a designated
 
hedged item
 
or group of
 
items. Specifically,
 
the Group designates
 
certain derivatives
 
as: (a)
Notes to the Consolidated Financial Statements
 
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hedges of the exposure to changes in
 
the fair value of recognized assets or liabilities
 
on a single or
 
portfolio basis or unsettled forward
transactions,
 
or
 
unrecognized
 
firm
 
commitments
 
(fair
 
value
 
hedging),
 
(b)
 
hedges
 
of
 
the
 
exposure
 
to
 
variability
 
in
 
cash
 
flows
 
of
recognized assets
 
or liabilities or
 
unsettled forward
 
transactions, or highly
 
probable forecasted
 
transactions (cash
 
flow hedging) or,
(c) hedges of the
 
exposure to variability in the value of
 
a net investment in a foreign operation which is
 
associated with the translation
of the investment's net assets in the Group's
 
functional currency (net investment hedging).
In
 
order
 
to
 
apply
 
hedge
 
accounting,
 
specified
 
criteria
 
should
 
be
 
met.
 
Accordingly,
 
at
 
the
 
inception
 
of
 
the
 
hedge
 
accounting
relationship, the Group documents the
 
relationship between hedging instruments
 
and hedged items, as well as its risk management
objective
 
and
 
strategy
 
for
 
undertaking
 
various
 
hedge
 
transactions,
 
together
 
with
 
the
 
method
 
that
 
will
 
be
 
used
 
to
 
assess
 
the
effectiveness of the hedging
 
relationship. The Group also
 
documents its assessment, both
 
at inception of
 
the hedge and
 
on an ongoing
basis, of whether the
 
derivatives that are
 
used in the hedging transactions
 
are highly effective
 
in offsetting
 
changes in fair
 
values or
cash flows
 
of hedged
 
items and
 
whether the actual
 
results of
 
each hedge
 
are within
 
a range
 
of 80-125%.
 
If a relationship
 
does not
meet
 
the
 
abovementioned
 
hedge
 
effectiveness
 
criteria,
 
the
 
Group
 
discontinues
 
hedge
 
accounting
 
prospectively.
 
Similarly,
 
if
 
the
hedging
 
derivative
 
expires
 
or
 
is
 
sold,
 
terminated
 
or
 
exercised,
 
or
 
the
 
hedge
 
designation
 
is
 
revoked,
 
then
 
hedge
 
accounting
 
is
discontinued prospectively.
(i) Fair value hedging
The Group applies
 
fair value hedging
 
primarily to hedge exposures
 
to changes in the
 
fair value attributable
 
to interest
 
rate risk with
respect to the applicable benchmark rate
 
and currency risk.
Hedged items
The items that qualify for fair value hedge accounting
 
include financial assets and liabilities such as:
fixed rate investment
 
securities measured at AC or FVOCI,
fixed rate term deposits and debt
 
securities issued measured at amortized cost;
portfolios of
 
floating-rate
 
loans and
 
debt securities
 
with embedded
 
interest rate
 
options (such
 
as purchased
 
interest rate
floors) measured at AC;
portfolios
 
of
 
fixed
 
rate
 
amortizing
 
loans
 
(macro
 
hedging)
 
including
 
securitization
 
notes
 
issued
 
and
 
held
 
by
 
the
 
Group
measured at AC.
portfolios of liabilities (macro hedging) and more specifically demand deposits with interest
 
rates determined by the Group
and
 
announced
 
on
 
its
 
pricing
 
list
 
(sight/savings
 
deposit
 
rate)
 
that
 
are
 
identified
 
as
 
interest
 
rate-insensitive
 
liabilities
measured at
 
AC. More
 
specifically,
 
demand deposits
 
(sight or
 
savings) are
 
liabilities with
 
no contractual
 
maturity that
 
the
customers have the flexibility
 
to withdraw at any time. Despite
 
their contractual terms, and due to
 
their nature, part of the
demand
 
deposits
 
behaves
 
as
 
a
 
portfolio
 
of
 
longer-term
 
fixed
 
rate
 
liabilities,
 
as
 
they
 
remain
 
insensitive
 
to
 
interest
 
rate
movements. This part of demand deposits represents the core
 
deposits.
Hedge effectiveness assessment
The Group uses the regression analysis or the dollar-offset
 
method at inception (prospective measurement) and on
 
an ongoing basis
(retrospective measurement),
 
in order to assess
 
the effectiveness of
 
fair value hedges
 
on a single or portfolio
 
basis. Specifically,
 
the
regression analysis
 
is the
 
default method
 
of assessing
 
effectiveness
 
which applies
 
to all
 
single fair
 
value hedging
 
relationships
 
and
portfolios hedging of interest rate risk (macro-hedging) and demonstrates that there is
 
high historical and expected future correlation
between
 
the interest
 
rate
 
risk designated
 
as being
 
hedged
 
and
 
the interest
 
rate
 
risk of
 
the hedging
 
instrument.
 
If the
 
regression
coefficient of the equation,
 
that represents the effectiveness
 
ratio, ranges
 
between -0.8 to -1.25, the
 
hedge relationship is expected
to be
 
highly effective,
 
further supported
 
by the coefficient
 
of determination
 
(R2) which should
 
be greater
 
than 80%
 
to confirm
 
the
statistical
 
level of
 
high effectiveness.
 
For hedging
 
relationships, that
 
regression analysis
 
is not
 
available the
 
dollar-offset
 
method is
used, which
 
is a quantitative method that involves the comparison of the change in the fair value of the hedging instrument with the
change in the fair value
 
of the hedged item attributable
 
to the hedged risk. The above
 
comparison constitutes the dollar-offset
 
ratio
and should be within the range of 80% -125% for the hedge to be
 
highly effective.
The Group
 
may also
 
apply the
 
hypothetical derivative
 
method, an
 
approach to
 
the dollar
 
offset method,
 
where the
 
hedged risk
 
is
modelled through hypothetical
 
derivatives, which replicate
 
the embedded derivative. The
 
fair value of the hypothetical
 
derivative is
used
 
as
 
a proxy
 
for
 
the
 
net
 
present
 
value
 
of
 
the
 
hedged
 
future
 
cash
 
flows
 
against
 
which
 
changes
 
in
 
value
 
of
 
the
 
actual hedging
Notes to the Consolidated Financial Statements
 
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instrument are
 
compared to
 
assess effectiveness and
 
measure ineffectiveness.
 
Hedge ineffectiveness
 
may arise in
 
case of potential
differences in the critical terms between the hedged item and the hedging instrument such as maturity, interest rate
 
reset frequency
and discount curves as well as differences between
 
expected and actual cash flows.
In addition, for hedging relationships
 
where the critical terms
 
of the hedged item match
 
the ones of the hedging instrument
 
such as
coupon, maturity,
 
and payment frequency,
 
it is presumed that by construction, effectiveness
 
is expected to be highly effective.
The Group has identified the following sources of ineffectiveness:
Differences in the repricing frequency
 
of the hedged items and hedging instruments
The use of different interest
 
rate curves applied to discount the hedged items
 
and hedging instruments.
Fair value hedging adjustments and discontinuation of hedge
 
accounting
Changes in the fair value of derivatives that are designated and qualify as
 
fair value hedges are recorded in the income statement line
“net trading income/(loss)”
 
together with the changes
 
in the fair value
 
of the hedged assets
 
or liabilities that are
 
attributable to the
hedged risk
 
(fair value
 
hedging adjustments).
 
Fair value
 
hedging adjustments
 
to the
 
hedged items
 
measured at
 
amortised cost
 
are
recorded as
 
part of their
 
carrying value in
 
the balance sheet,
 
with the exception
 
of hedging adjustments
 
for portfolios
 
of fixed
 
rate
assets in the context of macro-hedging (see below).
The Group
 
discontinues hedge
 
accounting prospectively
 
in case the
 
hedging instrument
 
expires or
 
is sold, terminated
 
or exercised,
the hedge no
 
longer meets the
 
qualifying criteria for
 
hedge accounting, or
 
designation is revoked.
 
In such cases,
 
any adjustment
 
to
the carrying amount of
 
the hedged item, for which
 
the effective interest method is applied, is
 
amortized to profit or loss in
 
the income
statement
 
line
 
“interest
 
income”
 
over
 
the
 
remaining
 
period
 
to
 
maturity
 
with
 
amortization
 
commencing
 
no
 
later
 
than
 
when
 
the
hedged
 
item
 
ceases
 
to
 
be
 
adjusted
 
for
 
changes
 
in
 
its
 
fair
 
value
 
attributable
 
to
 
the
 
risk
 
being
 
hedged.
 
If
 
the
 
hedged
 
item
 
is
derecognised, the unamortised fair value adjustment
 
is recognised immediately in the income statement.
Portfolio hedging of interest rate risk (macro
 
-hedging)
With
 
reference
 
to
 
portfolio
 
hedging
 
of
 
interest
 
rate
 
risk,
 
a
 
dynamic
 
hedging
 
strategy
 
is
 
applied
 
according
 
to
 
which
 
the
 
Group
voluntarily designates and de-designates
 
the hedge relationship on a monthly basis.
For portfolios of financial assets, the Group determines the designated hedged amount by
 
identifying portfolios of homogenous fixed
rate assets based on their contractual interest rates, maturity and other risk characteristics. Assets within the identified portfolios are
allocated into
 
repricing time periods
 
based on their
 
repricing/maturity dates or
 
interest payment
 
dates with assumptions
 
made for
expected prepayments
 
and capital repayments.
 
The hedging instruments
 
are groups
 
of interest
 
rate swaps
 
replicating in
 
aggregate
the amortization
 
profile of
 
the assets
 
and designated
 
appropriately to
 
their repricing
 
time periods.
 
Following the
 
above allocation
into time buckets, the designated
 
hedged principal and the resulting percentage
 
of the asset portfolio hedged (hedge ratio)
 
for each
time bucket are determined.
For
 
the core
 
deposits’ portfolios,
 
the Group
 
determines
 
their aggregated
 
balances and
 
allocation
 
into
 
time buckets
 
by applying
 
a
modelled approach that is based
 
on regulatory standards. More specifically, the portfolio of core deposits to
 
be hedged is determined
by an internal
 
designated behavioral
 
model that utilizes
 
a number of
 
assumptions regarding
 
the behavior and
 
evolution of demand
deposits balances, which are assessed,
 
monitored and documented in accordance with the
 
Group’s risk management framework. The
approach
 
involves
 
the
 
allocation
 
of
 
demand
 
deposits
 
in
 
sub-categories
 
considering
 
their
 
nature,
 
i.e.
 
retail
 
and
 
wholesale,
 
their
idiosyncratic behavioral analysis per portfolio,
 
their sensitivity on interest rates and their withdrawal patterns
 
and expected maturity
profile
 
analyzed
 
in time
 
buckets
 
for
 
a maximum
 
period of
 
ten years.
 
Furthermore, the
 
model performs
 
a capacity
 
check per
 
time
bucket to ensure that there is sufficient hedge capacity on the hedged item amortizing profile, compared to the
 
hedging instruments’
profile in order to ensure that there is no
 
over hedge.
Against
 
this
 
modelled
 
interest
 
rate
 
exposure,
 
the
 
Group
 
then
 
uses
 
groups
 
of
 
interest
 
rate
 
swaps
 
with
 
maturity
 
up
 
to
 
ten
 
years,
designated as hedging
 
instruments, that receive
 
fixed interest rate and pay floating
 
interest rate based on
 
the benchmark rate
 
hedged.
The groups
 
of swaps
 
are staggered
 
to cover
 
different
 
periods in time
 
replicating in
 
aggregate the
 
estimated amortization
 
profile of
the hedged core deposits
 
per time bucket. Additionally, their volume is
 
re-assessed on a monthly
 
basis. Following the above
 
allocation
into time buckets,
 
the designated hedged principal
 
and the resulting percentage
 
of the portfolio hedged
 
(hedge ratio) for
 
each time
bucket are determined.
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For hedge effectiveness assessment purposes,
 
the regression analysis is
 
used to demonstrate that
 
there is high
 
historical and expected
future correlation between the
 
interest rate
 
risk designated as being hedged and the
 
interest rate
 
risk of the hedging instrument, as
described above.
Fair
 
Value
 
hedging
 
adjustments
 
do
 
not
 
affect
 
the
 
carrying
 
amount
 
of
 
the
 
hedged
 
assets
 
or
 
liabilities
 
pool,
 
but
 
instead
 
they
 
are
presented
 
as a
 
separate
 
line item
 
within balance
 
sheet lines
 
loans and
 
advances to
 
customers
 
and due
 
to customers
 
respectively.
Considering the designation and de-designation process for
 
a portfolio hedging of interest
 
rate risk is performed on a monthly
 
basis,
the hedging
 
adjustments are
 
recorded in
 
the income
 
statement
 
line “net
 
trading income/(loss)”,
 
begin amortization
 
on the month
they occur and are
 
amortized per bucket
 
on a straight
 
line basis, until the maturity
 
of the last designated
 
time bucket on
 
a straight
line basis.
Furthermore, the pool of hedging instruments is managed
 
dynamically and therefore when
 
new derivatives are added in the pool
 
of
hedging instruments, they are included in the
 
next period’s hedge assessment and consequently the change in
 
fair value in the month
of their inception affects the P&L. Similarly,
 
when existing swaps are de-designated,
 
either to improve expected hedge
 
effectiveness
or to be liquidated, the respective change in fair value from de-designation up to the next designation
 
or liquidation date, affects the
P&L.
(ii) Cash flow hedging
The Group applies cash flow hedging to hedge exposures to variability in cash flows primarily attributable to the interest rate risk and
currency risk associated with
 
a recognized asset or
 
liability or a highly probable forecast
 
transaction. Additionally,
 
cash flow hedging
may be applied to
 
hedge the variability of
 
the consideration to be
 
paid in order to
 
acquire assets under unsettled forward transactions
(All-In-One Cash flow hedge).
The items that qualify for cash flow hedging include recognized assets and liabilities such as variable rate deposits
 
or loans measured
at amortized cost, variable rate
 
debt securities in issue, foreign currency variable
 
rate loans and fixed or variable
 
rate debt securities
to be purchased
 
under unsettled forward
 
transactions. The interest
 
rate risk
 
with respect to
 
the applicable benchmark
 
rate may
 
be
hedged using
 
interest rate
 
swaps and
 
cross currency
 
swaps. The
 
foreign currency
 
risk may
 
be hedged
 
using currency
 
forwards and
currency swaps. The variability of the consideration to be paid to acquire assets
 
under unsettled forward transactions may be hedged
using debt securities under
 
forward transactions treated
 
as derivatives and considered eligible hedging instruments.
Furthermore, cash
 
flow hedging is
 
used for
 
hedging highly probable
 
forecast transactions
 
such as the
 
anticipated future
 
rollover of
short-term
 
deposits
 
or
 
repos
 
measured
 
at
 
amortized
 
cost.
 
Specifically,
 
the
 
forecast
 
variable
 
interest
 
payments
 
of
 
a
 
series
 
of
anticipated
 
rollovers
 
of these
 
financial liabilities
 
are aggregated
 
and hedged
 
as a
 
group with
 
respect to
 
changes in
 
the benchmark
interest rates, eliminating cash flow variability.
 
In addition, cash flow hedging applies to
 
hedges of currency risk arising from probable
forecasted sales of financial assets or
 
settlement of financial liabilities in foreign currency.
If the
 
hedged item
 
is documented
 
as a
 
forecast
 
transaction, the
 
Group
 
assesses and
 
verifies that
 
there is
 
a high
 
probability of
 
the
transaction occurring.
In order to assess the effectiveness
 
of cash flow hedges of interest
 
rate risk, the Group
 
uses regression analysis which demonstrates
that there is high
 
historical and expected future correlation between
 
the interest rate risk designated as
 
being hedged and the
 
interest
rate
 
risk of
 
the hedging
 
instrument. For
 
assessing the
 
effectiveness
 
of cash
 
flow hedges
 
of currency
 
risk and
 
debt securities
 
under
unsettled forward transactions,
 
the Group uses the dollar-offset
 
method as it is described in section (i) above.
The effective
 
portion of changes
 
in the fair
 
value of derivatives
 
that are designated
 
and qualify as cash
 
flow hedges is recognized
 
in
other comprehensive income whereas the ineffective portion is recognized in the income statement line “net trading income/(loss)”.
Amounts accumulated
 
in equity
 
are recycled
 
to the
 
income statement
 
in the
 
periods in which
 
the hedged
 
item will
 
affect profit
 
or
loss (for example, when the forecast
 
sale that is hedged takes place).
When a
 
hedging instrument
 
expires or
 
is sold,
 
or when
 
a hedge no
 
longer meets
 
the criteria
 
for hedge
 
accounting, the
 
cumulative
gain or loss existing in equity at that time remains
 
in equity until the hedged cash flows affect
 
the income statement.
When a forecast
 
transaction is
 
no longer
 
expected to
 
occur,
 
the cumulative
 
gain or
 
loss that was
 
reported in
 
equity is immediately
transferred to the income
 
statement.
Notes to the Consolidated Financial Statements
 
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(iii) Net investment hedging
The Group
 
applies net
 
investment
 
hedging to
 
hedge exposures
 
to variability
 
in the
 
value of
 
a net
 
investment
 
in foreign
 
operation
(including monetary items that form part of the net investment),
 
such as foreign subsidiaries, associates or other foreign
 
operations,
associated
 
with
 
the
 
translation
 
of
 
the
 
net
 
investment’s
 
carrying
 
amount
 
into
 
the
 
Group’s
 
presentation
 
currency.
 
Any
 
exchange
differences deriving from the translation
 
are deferred in OCI until the net investment
 
is disposed of or liquidated, at which time they
are recognized in the profit or loss.
The
 
foreign
 
currency
 
exposure
 
that
 
arises
 
from
 
the
 
fluctuation
 
in
 
spot
 
exchange
 
rates
 
between
 
the
 
net
 
investment’s
 
functional
currency and the Group’s presentation currency may be
 
hedged using currency swaps, currency
 
forward contracts and their economic
equivalents, as well as cash instruments.
The effectiveness of net investment
 
hedges is assessed with the Dollar-Offset Method
 
as described above for fair value hedge.
Hedges of
 
net investments
 
in foreign
 
operations
 
are accounted
 
for
 
similarly to
 
cash flow
 
hedges. Any
 
gain or
 
loss on
 
the hedging
instrument relating to
 
the effective portion of the
 
hedge is recognized in equity;
 
the gain or loss relating
 
to the ineffective portion
 
is
recognized in the income statement.
 
Gains and losses accumulated in equity are included in the income statement
 
when the foreign
operation is disposed of as part of the gain or loss on the disposal.
Derivatives not designated as hedging instruments for hedge accounting
 
purposes
Changes
 
in the
 
fair
 
value
 
of derivative
 
financial instruments
 
that
 
are
 
entered
 
into
 
for
 
trading purposes
 
or as
 
economic hedges
 
of
assets, liabilities or
 
net positions in
 
accordance with the Group’s hedging
 
objectives and risk
 
management policies that may
 
not qualify
for hedge accounting are recognized
 
in the income statement.
The fair
 
values of
 
derivative instruments
 
held for
 
trading, including
 
those entered
 
into as
 
economic hedges,
 
and hedge
 
accounting
purposes are disclosed in note 19.
2.2.4 Offsetting financial instruments
Financial
 
assets
 
and
 
liabilities
 
are
 
offset
 
and
 
the net
 
amount
 
is presented
 
in
 
the balance
 
sheet when,
 
and only
 
when,
 
the Group
currently
 
has a
 
legally enforceable
 
right to
 
set off
 
the recognized
 
amounts
 
and intends
 
either to
 
settle them
 
on a
 
net basis,
 
or to
realize the asset and settle the liability simultaneously.
2.2.5 Income statement
 
(i) Interest income and expense
Interest income and expense are recognized in the
 
income statement for all interest bearing financial instruments on an
 
accrual basis,
using
 
the effective
 
interest
 
rate
 
(EIR)
 
method. The
 
effective
 
interest
 
rate
 
is the
 
rate
 
that
 
exactly
 
discounts
 
estimated
 
future
 
cash
payments or receipts through the
 
expected life of the financial
 
instrument or, when appropriate, a shorter period to
 
the gross carrying
amount of the financial asset or to the amortized
 
cost of a financial liability. When
 
calculating the EIR for financial instruments
 
other
than purchased or originated credit-impaired, the Group estimates future cash flows considering all contractual terms of the financial
instrument
 
but does
 
not
 
consider
 
expected
 
credit
 
losses.
 
For
 
purchased
 
or originated
 
credit
 
impaired
 
(POCI) financial
 
assets,
 
the
Group
 
calculates
 
the
 
credit-adjusted
 
EIR,
 
which
 
is
 
the
 
interest
 
rate
 
that
 
upon
 
the
 
original
 
recognition
 
of
 
the
 
POCI
 
financial
 
asset
discounts the estimated future cash flows
 
(including expected credit losses) to the fair
 
value of the POCI asset.
The
 
amortized
 
cost
 
of
 
a
 
financial asset
 
or
 
liability
 
is
 
the
 
amount
 
at
 
which
 
it
 
is
 
measured
 
upon
 
initial
 
recognition
 
minus
 
principal
repayments, plus
 
or minus cumulative
 
amortization using
 
the EIR (as
 
described above)
 
and for
 
financial assets it
 
is adjusted
 
for the
expected credit loss allowance. The gross carrying amount of a
 
financial asset is its amortized cost before adjusting for ECL allowance.
The EIR calculation includes fees and points paid
 
or received that are an integral part
 
of the effective interest rate,
 
transaction costs,
and other premiums or discounts. Transaction costs include incremental costs that are directly attributable to the acquisition or issue
of a financial asset or liability.
The Group calculates interest
 
income and expense by applying the EIR to
 
the gross carrying amount of non
 
-impaired financial assets
(exposures in Stage 1 and 2) and to the amortized
 
cost of financial liabilities respectively.
For financial assets
 
that have
 
become credit-impaired
 
subsequent to
 
initial recognition (exposures
 
in Stage 3),
 
the Group calculates
interest income by applying the effective interest rate to the amortized cost of the financial asset (i.e. gross carrying amount adjusted
Notes to the Consolidated Financial Statements
 
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for the
 
expected credit
 
loss allowance).
 
If the
 
asset is no
 
longer credit-impaired,
 
then the EIR
 
is applied
 
again to
 
the gross
 
carrying
amount with the exception of POCI assets for
 
which interest income does not revert
 
to gross basis calculation.
For inflation-linked
 
instruments the
 
Group recognizes
 
interest
 
income and
 
expense by
 
adjusting the
 
effective interest
 
rate on
 
each
reporting period due
 
to changes in
 
expected future cash
 
flows, incorporating
 
changes in inflation
 
expectations over
 
the term of the
instruments.
 
The adjusted
 
effective
 
interest
 
rate
 
is applied
 
in order
 
to calculate
 
the new
 
gross carrying
 
amount on
 
each reporting
period.
Interest income
 
and expense are
 
presented separately
 
in the income statement
 
for all interest
 
bearing financial instruments
 
within
net interest income.
(ii) Fees and commissions
Fee and commission received
 
or paid that are
 
integral to the effective interest rate on a
 
financial asset or
 
financial liability are included
in the effective interest
 
rate.
Other
 
fee
 
and
 
commission
 
income
 
such
 
as
 
account
 
servicing
 
and
 
asset
 
management
 
fees
 
(including
 
performance
 
based
 
fees)
 
is
recognised
 
over
 
time
 
as
 
the
 
related
 
services
 
are
 
being
 
provided
 
to
 
the
 
customer,
 
to
 
the
 
extent
 
that
 
it
 
is
 
highly
 
probable
 
that
 
a
significant reversal
 
of the revenue
 
amount recognized
 
will not occur.
 
Transaction-based
 
fees such as
 
foreign exchange
 
transactions,
imports-exports, remittances,
 
bank charges and
 
brokerage
 
activities are recognised
 
at the point
 
in time when the
 
transaction takes
place. Other
 
fee
 
and
 
commission
 
expenses
 
relate
 
mainly
 
to
 
transaction
 
and service
 
fees,
 
which
 
are
 
expensed
 
as
 
the
 
services are
received.
In the case of a contract
 
with a customer that results
 
in the recognition of a financial
 
instrument in the Group’s
 
financial statements
which may
 
be partially
 
in the
 
scope of
 
IFRS 9
 
and partially
 
in the
 
scope of
 
IFRS 15,
 
the Group
 
first
 
applies IFRS
 
9 to
 
separate
 
and
measure the part of the contract that is in the scope of
 
IFRS 9 and subsequently applies IFRS 15 to the residual part.
2.2.6 Property, equipment and
 
Investment property
(i) Property and equipment
Property and equipment are measured at cost
 
less accumulated depreciation and any accumulated impairment
 
losses. Cost includes
expenditure that
 
is directly attributable
 
to the acquisition
 
of the asset. Subsequent
 
expenditure is recognized
 
in the asset's
 
carrying
amount only
 
when it
 
is probable
 
that
 
future economic
 
benefits will
 
flow to
 
the Group
 
and the
 
cost of
 
the asset
 
can be
 
measured
reliably. All other repair
 
and maintenance costs are recognized in
 
the income statement as incurred.
Depreciation is calculated
 
using the straight-line method
 
to write down the cost
 
of property and equipment,
 
to their residual values
over their estimated useful life as follows:
Land: no depreciation;
Freehold
 
buildings:
 
40-50
 
years
 
and
 
up
 
to
 
70
 
years
 
(for
 
specific
 
strategic
 
properties
 
constructed
 
or
 
heavily
 
renovated
according
 
to
 
the
 
best
 
practices
 
and
 
guidelines
 
of
 
sustainable
 
construction
 
and
 
renovation,
 
using
 
resilient
 
materials
 
and
designs);
Leasehold improvements: over the lease term or
 
the useful life of the asset if shorter;
Computer hardware and related
 
integral software: 4-10 years;
Other furniture and equipment: 4-20 years; and
Motor vehicles: 5-7 years.
 
(ii) Investment property
Property
 
held
 
for
 
rental
 
yields and/or
 
capital
 
appreciation
 
that
 
is not
 
occupied by
 
the
 
Group’s
 
entities
 
is classified
 
as
 
investment
property.
Investment
 
property
 
is
 
measured
 
initially
 
at
 
its
 
cost,
 
including
 
related
 
transaction
 
costs,
 
and
 
subsequently
 
at
 
fair
 
value
 
with
 
any
change therein recognized
 
in income statement
 
line ‘’other
 
income / (expenses)’’.
 
Subsequent expenditure
 
is charged to the asset’s
carrying amount only when it is probable that
 
future economic benefits associated with the
 
item will flow to the Group and the cost
of the
 
item can
 
be measured
 
reliably.
 
Such expenditure
 
includes enhancements
 
that increase
 
the value
 
of the
 
asset and
 
its future
Notes to the Consolidated Financial Statements
 
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income-earning
 
potential,
 
as well
 
as costs
 
to
 
comply with
 
environmental
 
and other
 
legal requirements.
 
Repairs
 
and maintenance
costs are recognized to
 
the income statement during the financial period in which they are
 
incurred.
Any gain
 
or loss
 
on disposal
 
(calculated as
 
the difference
 
between the
 
net proceeds
 
from disposal
 
and the
 
carrying amount
 
of the
asset) is recognized in income statement.
If an
 
investment
 
property
 
becomes
 
owner-occupied,
 
it is
 
reclassified
 
as
 
property
 
and equipment
 
and its
 
fair
 
value
 
at
 
the date
 
of
reclassification becomes its deemed cost. If an item of property and equipment becomes an investment property because its use has
changed, any resulting
 
decrease between the
 
carrying amount and the
 
fair value of this
 
item at the date
 
of transfer
 
is recognized in
income statement
 
while any resulting
 
increase, to the extent
 
that the increase
 
reverses previous
 
impairment loss for
 
that property,
is
 
recognized
 
in
 
income
 
statement
 
while
 
any
 
remaining
 
part
 
of
 
the
 
increase
 
is
 
recognized
 
in
 
other
 
comprehensive
 
income
 
and
increases the revaluation surplus within equity.
If a
 
repossessed asset
 
becomes investment
 
property,
 
any difference
 
between the
 
fair value
 
of the
 
property at
 
the date
 
of transfer
and its previous carrying amount is recognized
 
in income statement.
Reclassifications among own used, repossessed assets and
 
investment properties may occur when there is
 
a change in the
 
use of such
properties. Additionally,
 
an investment property
 
may be reclassified to ‘non-current
 
assets held for sale’ category
 
to the extent that
the criteria described in note 2.2.25 are met.
2.2.7 Intangible assets
(i) Goodwill
Goodwill
 
arising on
 
business
 
combinations
 
is included
 
in ‘intangible
 
assets’
 
and is
 
measured at
 
cost less
 
accumulated
 
impairment
losses.
Goodwill arising on acquisitions of associates and jointly controlled entities is neither disclosed nor tested separately for impairment,
but instead is included in ‘investments
 
in associates’ and ‘investments in jointly
 
controlled entities’.
(ii) Computer software
Computer software
 
is measured
 
at cost
 
less accumulated
 
amortisation
 
and accumulated
 
impairment losses.
 
Costs associated
 
with
the
 
maintenance
 
of
 
existing
 
computer
 
software
 
programs
 
are
 
expensed
 
as
 
incurred.
 
Development
 
costs
 
associated
 
with
 
the
production
 
of identifiable
 
assets controlled
 
by the
 
Group are
 
recognized
 
as intangible
 
assets when
 
they are
 
expected to
 
generate
economic benefits and can be measured reliably. Internally generated computer software assets are amortized using the straight-line
method over 4 to 15 years, except
 
for core systems whose
 
useful life may extend up to 20 years.
(iii) Other intangible assets
Other
 
intangible
 
assets
 
are
 
assets that
 
are
 
separable
 
or arise
 
from
 
contractual
 
or other
 
legal
 
rights
 
and are
 
amortized
 
over
 
their
estimated useful lives. These include intangible
 
assets acquired in business combinations.
Intangible assets that have an indefinite
 
useful life are not subject to amortization
 
and are tested annually for impairment.
 
2.2.8 Impairment of non-financial assets
(i) Goodwill
Goodwill is tested
 
for impairment annually
 
or more frequently
 
if there are
 
any indications that
 
impairment may have
 
occurred. The
Group considers
 
external information
 
such as prevailing
 
economic conditions, persistent
 
slowdown in financial markets,
 
volatility in
markets and changes in levels of market and exchange risk, an unexpected decline in an asset’s market value or market capitalization
being below the book value of equity, together
 
with a deterioration in internal performance
 
indicators, in assessing whether there is
any indication of impairment.
For the purpose of impairment testing,
 
goodwill acquired in a business combination
 
is allocated to each Cash
 
Generating Unit (CGU)
or groups of CGUs that are expected to
 
benefit from the synergies of the combination.
The Group impairment model compares the carrying
 
value of a CGU or
 
group of CGUs with its
 
recoverable amount. The carrying value
of a CGU is based on
 
the assets and liabilities of
 
each CGU. The recoverable
 
amount is determined
 
on the basis of the
 
present value
of the future
 
cash flows expected
 
to be derived
 
from the CGU or
 
group of CGUs.
 
The estimated future
 
cash flows are
 
discounted to
Notes to the Consolidated Financial Statements
 
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their present
 
value using a
 
pre-tax discount
 
rate that
 
reflects current
 
market assessments
 
of the time
 
value of money
 
and the risks
specific to the asset or CGU and the countries where the CGUs operate.
An impairment loss arises if the carrying amount of an asset or CGU
 
exceeds its recoverable
 
amount and is recognized in the
 
income
statement.
 
Impairment
 
losses
 
are
 
not
 
subsequently
 
reversed.
 
Gains
 
and
 
losses
 
on
 
the
 
disposal
 
of
 
an
 
entity
 
include
 
the
 
carrying
amount of goodwill relating to the entity sold.
Goodwill arising
 
in a business
 
combination is
 
not tested
 
for impairment
 
during the
 
measurement period
 
extending
 
up to
 
one year
from the acquisition date
 
that is allowed for
 
the completion of the
 
purchase accounting and
 
allocation of goodwill, unless
 
there has
been a triggering event
 
or changes in other
 
facts and circumstances,
 
suggesting that the acquired
 
goodwill might be impaired,
 
even
if the allocation process is not complete.
(ii) Other non-financial assets
Other non-financial assets, including property and equipment and other intangible assets, are assessed for indications of impairment
at each reporting date
 
by considering both external
 
and internal sources of information
 
such as a significant reduction
 
in the asset’s
value
 
and
 
evidence
 
that
 
the
 
economic
 
performance
 
of
 
the
 
asset
 
is
 
or
 
will
 
be
 
worse
 
than
 
expected.
 
When
 
events
 
or
 
changes
 
in
circumstances indicate
 
that the carrying amount may
 
not be recoverable,
 
an impairment loss is recognized
 
for the amount by which
the asset’s carrying
 
amount exceeds its recoverable
 
amount. The recoverable
 
amount is the higher of
 
an asset’s fair
 
value less costs
to
 
sell
 
and
 
value
 
in
 
use.
 
For
 
the
 
purposes
 
of
 
assessing
 
impairment,
 
assets
 
are
 
grouped
 
at
 
the
 
lowest
 
levels
 
for
 
which
 
there
 
are
separately
 
identifiable
 
cash
 
flows,
 
where
 
applicable.
 
Non-financial
 
assets,
 
other than
 
goodwill, for
 
which an
 
impairment
 
loss was
recognized in prior reporting periods, are reviewed
 
for possible reversal of such impairment at
 
each reporting date.
Impairment losses arising from the Group’s
 
associates and joint ventures are determined
 
in accordance with this accounting policy.
 
2.2.9 Financial assets
Financial assets - Classification and measurement
The
 
Group
 
classifies
 
financial
 
assets
 
based
 
on
 
the
 
business
 
model
 
for
 
managing
 
those
 
assets
 
and
 
their
 
contractual
 
cash
 
flow
characteristics.
 
Accordingly,
 
financial assets
 
on initial
 
recognition
 
are classified
 
into one
 
of the
 
following
 
measurement categories:
amortized cost, fair value through
 
other comprehensive income or fair value
 
through profit or loss.
Purchases and
 
sales of
 
financial assets
 
are recognized
 
on trade
 
date, which
 
is the
 
date the
 
Group commits
 
to purchase
 
or sell
 
the
assets. Loans originated by the Group are recognized
 
when cash is advanced to the borrowers.
Financial Assets measured at Amortized Cost (‘AC’)
The Group classifies and measures
 
a financial asset at AC only
 
if both of the following conditions
 
are met and is not designated
 
as at
FVTPL:
(a) The
 
financial asset
 
is held within
 
a business model
 
whose objective
 
is to
 
collect contractual
 
cash flows
 
(hold-to-collect business
model) and
(b) The
 
contractual
 
terms of
 
the financial
 
asset give
 
rise on
 
specified dates
 
to cash
 
flows that
 
are solely
 
payments of
 
principal and
interest on the principal amount outstanding
 
(SPPI).
These financial
 
assets are
 
recognized initially
 
at fair
 
value plus
 
or minus direct
 
and incremental
 
transaction costs
 
and fees
 
received
that are attributable to the acquisition of these assets, and are subsequently measured at amortized cost, using the effective interest
rate (EIR) method (as described in note 2.2.5 above).
Interest
 
income, realized
 
gains and
 
losses on derecognition,
 
and changes
 
in expected
 
credit losses
 
from assets
 
classified at
 
AC, are
included in the income statement.
Financial Assets measured at Fair Value through Other
 
Comprehensive Income (‘FVOCI’)
The Group classifies and measures a financial asset at FVOCI only if both of the following conditions are
 
met and is not designated as
at FVTPL:
(a) The financial asset
 
is held within a
 
business model whose objective
 
is achieved by both collecting
 
contractual cash flows and selling
financial assets (hold-to-collect-and-sell business
 
model) and
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(b) The contractual terms of the financial asset give rise on specified dates
 
to cash flows that are SPPI.
Financial
 
assets
 
that
 
meet
 
these
 
criteria
 
are
 
debt
 
instruments
 
and
 
are
 
measured
 
initially
 
at
 
fair
 
value,
 
plus
 
or
 
minus
 
direct
 
and
incremental transaction costs that
 
are attributable to the acquisition of these assets.
Subsequent
 
to
 
initial recognition,
 
FVOCI
 
debt
 
instruments
 
are
 
re-measured
 
at
 
fair
 
value
 
through
 
OCI, except
 
for
 
interest
 
income,
related foreign exchange gains
 
or losses and expected credit losses, which are recognized in the income statement.
 
Cumulative gains
and losses previously recognized in OCI are transferred from OCI to the income statement when the debt instrument is
 
derecognised.
Equity Instruments designated at FVOCI
The Group may make an irrevocable election to
 
designate an equity instrument at FVOCI.
 
This designation, if elected, is
 
made at initial
recognition
 
and on
 
an
 
instrument
 
by
 
instrument
 
basis.
 
Gains and
 
losses
 
on these
 
instruments,
 
including when
 
derecognized,
 
are
recorded
 
in
 
OCI
 
and
 
are
 
not
 
subsequently
 
reclassified
 
to
 
the
 
income
 
statement.
 
Dividends
 
received
 
are
 
recorded
 
in
 
the
 
income
statement.
Financial Assets measured at Fair Value through Profit
 
and Loss (“FVTPL”)
The
 
Group
 
classifies
 
and
 
measures
 
all
 
other
 
financial
 
assets
 
that
 
are
 
not
 
classified
 
at
 
AC
 
or
 
FVOCI,
 
at
 
FVTPL.
 
Derivative
 
financial
instruments
 
are measured
 
at FVTPL
 
with changes
 
in fair
 
value recognized
 
in the
 
income statement,
 
unless they
 
are designated
 
as
effective hedging instruments, where
 
hedge accounting requirements under IAS 39 apply (as described
 
in note 2.2.3 above).
Furthermore, a financial asset that meets the above conditions
 
to be classified at AC or FVOCI, may be irrevocably
 
designated by the
Group at
 
FVTPL at
 
initial recognition,
 
if doing
 
so eliminates,
 
or significantly
 
reduces an
 
accounting mismatch
 
that would
 
otherwise
arise.
Financial assets measured at FVTPL are initially recorded at fair value
 
and any unrealized gains or losses arising due to changes in fair
value are included in the income statement.
Business model and contractual characteristics assessment
The business model assessment
 
determines how the
 
Group manages a
 
group of assets
 
to generate cash
 
flows. That is,
 
whether the
Group's objective
 
is solely
 
to collect
 
contractual
 
cash flows
 
from the
 
asset, to
 
realize cash
 
flows from
 
the sale
 
of assets,
 
or both to
collect contractual cash flows and cash flows
 
from the sale of assets. In addition, the business model is determined after aggregating
the financial assets into groups (business lines) which are managed
 
similarly rather than at an individual instrument’s
 
level.
The business
 
model is
 
determined
 
by the
 
Group’s
 
key
 
management personnel
 
consistently
 
with the
 
operating
 
model, considering
how financial assets are managed
 
in order to generate cash flows, the objectives
 
and how performance of each
 
portfolio is monitored
and reported and any available information
 
on past sales and on future sales’ strategy,
 
where applicable.
Accordingly,
 
in making
 
the above
 
assessment, the
 
Group
 
will consider
 
a number
 
of factors
 
including the
 
risks associated
 
with the
performance of
 
the business model
 
and how those
 
risks are evaluated
 
and managed, the
 
related personnel
 
compensation, and the
frequency, volume
 
and reasons of past sales, as well as expectations about future
 
sales activity.
Types of business models
The Group’s business
 
models fall into three categories, which
 
are indicative of the key strategies
 
used to generate returns.
The
 
hold-to-collect
 
(HTC)
 
business model
 
has the
 
objective
 
to
 
hold
 
the financial
 
assets in
 
order
 
to
 
collect contractual
 
cash flows.
Financial
 
assets
 
classified
 
within
 
this
 
business
 
model
 
include
 
investment
 
securities,
 
due
 
from
 
banks
 
and
 
loans
 
and
 
advances
 
to
customers
 
including securitization
 
notes issued
 
by special
 
purpose entities
 
established
 
by the
 
Group
 
and recognized
 
in its
 
balance
sheet, which are measured
 
at amortized cost. Sales
 
within this model are monitored
 
per financial asset class and may
 
be performed
for reasons which are not inconsistent with this
 
business model. More specifically, sales of financial
 
assets due to credit deterioration,
as well as sales close to the maturity are considered consistent with the objective of hold-to-collect contractual cash flows regardless
of value
 
and frequency.
 
Sales for
 
other
 
reasons
 
may
 
be consistent
 
with the
 
HTC
 
model such
 
as liquidity
 
needs in
 
any
 
stress
 
case
scenario
 
or
 
sales
 
made
 
to
 
manage
 
high
 
concentration
 
level
 
of
 
credit
 
risk.
 
Such
 
sales
 
are
 
monitored
 
and
 
assessed
 
depending
 
on
frequency and value to conclude whether they are
 
consistent with the HTC model.
The
 
hold-to-collect-and-sell
 
business
 
model
 
(HTC&S)
 
has
 
the
 
objective
 
both
 
to
 
collect
 
contractual
 
cash
 
flows
 
and
 
sell
 
the
 
assets.
Activities such as liquidity management, interest
 
yield and duration are consistent with this
 
business model, while sales of assets are
Notes to the Consolidated Financial Statements
 
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integral to
 
achieving the objectives
 
of this business
 
model. Financial assets
 
classified within this
 
business model include
 
investment
securities which are measured at FVOCI, subject to meeting the SPPI assessment
 
criteria.
Other business models
 
include financial assets
 
which are managed
 
and evaluated
 
on a fair
 
value basis as
 
well as portfolios
 
that are
held for trading. This is a residual category for financial assets not meeting the criteria of the business models of
 
HTC or HTC&S, while
the collection of contractual cash flows may
 
be incidental to achieving the business models’ objective.
The Group’s
 
business models
 
are
 
reassessed
 
at
 
least
 
annually or
 
earlier,
 
if there
 
is a
 
sales’ assessment
 
trigger or
 
if there
 
are
 
any
changes in the Bank’s strategy
 
and main activities, as evidenced by the Bank’s
 
business plan, budget and NPE strategy.
Cash flow characteristics assessment
For a
 
financial asset
 
to be
 
measured at
 
AC or
 
FVOCI, its
 
contractual
 
terms must
 
give rise
 
on specified
 
dates to
 
cash flows
 
that
 
are
solely payments of principal
 
and interest (SPPI)
 
on the principal amount outstanding.
 
For the purpose of this
 
assessment principal is
defined as the
 
fair value of
 
the asset at
 
initial recognition and
 
interest as
 
the consideration
 
for the time
 
value of money,
 
credit risk,
other basic lending risks and a profit margin.
More
 
specifically,
 
at
 
initial
 
recognition
 
of
 
a financial
 
asset,
 
an
 
assessment
 
is performed
 
of whether
 
the
 
financial
 
asset
 
contains
 
a
contractual term that
 
could change the amount or timing
 
of contractual cash flows
 
in a way that it would
 
not be consistent with the
above
 
condition.
 
The
 
Group
 
considers
 
the
 
existence
 
of
 
various
 
features,
 
including
 
among
 
others,
 
contractually
 
linked
 
terms,
prepayment
 
terms,
 
deferred
 
interest-free
 
payments,
 
extension
 
and
 
equity
 
conversion
 
options,
 
terms
 
that
 
introduce
 
leverage
including index linked payments, as well
 
as environmental, social and governance linked features (ESG)
 
where the contractual interest
rate
 
is
 
adjusted
 
if
 
the
 
borrower
 
meets,
 
or
 
fail
 
to
 
meet
 
specific
 
sustainability
 
performance
 
targets.
 
Where
 
the
 
contractual
 
terms
introduce exposure to risk or volatility that are
 
inconsistent with a basic lending
 
arrangement, the related financial asset is considered
to have failed the SPPI assessment and will be measured
 
at FVTPL.
In addition, if a contractual feature could have an effect that is de-minimis on the contractual cash flows of the financial asset, it does
not affect
 
its classification. Moreover,
 
a contractual
 
feature is considered
 
as not genuine by
 
the Group, if
 
it affects
 
the instrument’s
contractual cash flows
 
only on the occurrence of an event
 
that is extremely rare,
 
highly abnormal and very unlikely
 
to occur.
 
In such
a case, it does not affect the instrument’s
 
classification.
Moreover,
 
for the securitization
 
notes issued by special
 
purpose entities and held
 
by the Group, the
 
cash flow characteristics
 
of the
notes and the
 
underlying pool of financial
 
assets as well
 
as the credit
 
risk inherent in
 
each securitization’s
 
tranche compared
 
to the
credit risk of all of the underlying pool of financial assets, are considered.
In case of
 
special lending arrangements such
 
as non-recourse loans,
 
in its assessment
 
of the SPPI
 
criterion, the Group considers
 
various
factors
 
such
 
as
 
the
 
nature
 
of
 
the
 
borrower
 
and
 
its
 
business,
 
the
 
pricing
 
of
 
the
 
loans,
 
whether
 
it
 
participates
 
in
 
the
 
economic
performance of the
 
underlying asset and
 
the extent to
 
which the collateral
 
represents all
 
or a substantial
 
portion of the borrower’s
assets. Moreover,
 
for non-recourse
 
loans, the Group
 
takes into
 
consideration the
 
borrower’s adequacy
 
of loss absorbing
 
capital by
assessing jointly the criteria of equity
 
sufficiency, Loan to
 
Value ratio (LTV),
 
the Average Debt Service Coverage
 
ratio (ADSCR) as well
as the existence of corporate
 
and personal guarantees.
In certain cases when
 
the time value of
 
money element is modified
 
in that the financial
 
asset’s interest
 
rate is periodically
 
reset but
the reset frequency
 
does not match
 
the tenor of
 
the interest
 
rate or when
 
a financial asset’s
 
interest rate
 
is periodically reset
 
to an
average of particular short-term and long-term
 
interest rates, a quantitative assessment is
 
performed (the “Benchmark Test”) in order
to determine whether the contractual cash
 
flows are SPPI.
In particular,
 
the Group
 
assesses the contractual
 
cash flows
 
of the “real
 
instrument”,
 
whose interest
 
rate is
 
reset with
 
a frequency
that does not match
 
the tenor of the
 
interest rate, and those of
 
the “benchmark instrument”, which are identical in
 
all respects except
that the tenor of the
 
interest rate
 
matches exactly the
 
interest period.
 
If the undiscounted cash
 
flows of the former
 
are significantly
different
 
from the
 
benchmark cash
 
flows due
 
to the
 
modified time value
 
of money
 
element, the
 
financial asset
 
does not
 
meet the
SPPI criterion. In its assessment, the Group considers
 
both the effect of the modified time value of money element
 
in each reporting
period
 
and
 
cumulatively
 
over
 
the
 
life
 
of
 
the
 
instrument.
 
This
 
is
 
done,
 
as
 
far
 
as
 
the
 
lifetime
 
of
 
the
 
instrument
 
is
 
concerned,
 
by
comparing
 
the
 
cumulative
 
projected
 
undiscounted
 
cash
 
flows
 
of
 
the
 
real
 
and the
 
benchmark
 
instrument,
 
and
 
for
 
each
 
quarterly
reporting period,
 
by comparing
 
the projected
 
undiscounted
 
cash flows
 
of the
 
two instruments
 
for that
 
quarterly reporting
 
period,
based on predefined thresholds.
Notes to the Consolidated Financial Statements
 
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The Group performs the SPPI assessment for its
 
lending exposures on a product basis for the
 
retail and part of the wholesale portfolio
where
 
contracts
 
are
 
of
 
standardized
 
form,
 
whereas
 
for
 
the
 
remaining
 
wholesale
 
portfolio,
 
securitization
 
notes
 
issued
 
by
 
special
purpose
 
entities,
 
either
 
established
 
by
 
the
 
Group
 
or
 
third
 
parties,
 
and
 
held
 
by
 
the
 
Group,
 
and
 
debt
 
securities
 
the
 
assessment
 
is
performed on an individual basis.
 
Derecognition of financial assets
The
 
Group
 
derecognizes
 
a
 
financial
 
asset
 
when
 
its
 
contractual
 
cash
 
flows
 
expire,
 
or
 
the
 
rights
 
to
 
receive
 
those
 
cash
 
flows
 
are
transferred in an outright sale in which substantially all risks and rewards of ownership have
 
been transferred. In addition, a financial
asset is derecognized
 
even if rights
 
to receive cash
 
flows are retained
 
but at the same
 
time the Group
 
assumes an obligation
 
to pay
the received cash flows without a material delay (pass through agreement) or when substantially all
 
the risks and rewards are neither
transferred
 
nor retained
 
but the Group
 
has transferred
 
control of
 
the asset. Control
 
is transferred
 
if, and
 
only if,
 
the transferee
 
has
the practical ability to sell
 
the asset in its entirety to
 
unrelated third party and is able to
 
exercise that ability unilaterally
 
and without
imposing additional restrictions on the transfer.
The main transactions that are subject to the above de-recognition
 
rules are securitization transactions, repurchase
 
agreements and
stock lending
 
transactions. In
 
the case of
 
securitization transactions,
 
in order
 
to assess the
 
application of
 
the above
 
mentioned de-
recognition
 
principles,
 
the
 
Group
 
considers
 
the
 
structure
 
of
 
each
 
securitization
 
transaction
 
including
 
its
 
exposure
 
to
 
the
 
more
subordinated
 
tranches
 
of
 
the
 
notes
 
issued
 
and/or
 
credit
 
enhancements
 
provided
 
to
 
the
 
special
 
purpose
 
entities,
 
as
 
well
 
as
 
the
securitization’s contractual
 
terms that may indicate that the Group retains control of the underlying assets. In the case of repurchase
transactions and stock lending, the assets transferred
 
are not derecognised since the terms of the transaction
 
entail the retention of
all their risks and rewards.
On derecognition of
 
a financial asset,
 
the difference
 
between the carrying
 
amount of the
 
asset and the sum
 
of (i) the consideration
received
 
(including
 
any
 
new
 
asset
 
obtained
 
less
 
any
 
new
 
liability
 
assumed)
 
and
 
(ii)
 
any
 
cumulative
 
gain
 
or
 
loss
 
that
 
had
 
been
recognized
 
in OCI
 
for
 
financial assets
 
at FVOCI,
 
is recognized
 
in income
 
statement,
 
except
 
for
 
cumulative
 
gains or
 
losses of
 
FVOCI
equity instruments which are not reclassified from OCI to
 
income statement at the date of
 
derecognition.
Modification of financial assets that may result in derecognition
In addition,
 
derecognition of
 
financial asset
 
arises when
 
its contractual
 
cash flows
 
are modified
 
and the
 
modification is
 
considered
substantial
 
enough
 
so
 
that
 
the
 
original
 
asset
 
is derecognized
 
and
 
a new
 
one
 
is
 
recognised.
 
Substantial
 
modifications
 
resulting
 
in
derecognition
 
may include
 
among others
 
change in
 
borrower,
 
change in
 
the asset’s
 
denomination
 
currency,
 
debt consolidation
 
of
unsecured exposure into a single new secured asset. The Group records the modified asset as a ‘new’ financial asset at fair value plus
any eligible transaction costs and the difference
 
with the carrying amount of the existing one is recorded in the income statement
 
as
derecognition gain or loss.
The Group may
 
modify the contractual
 
terms of a lending exposure
 
either as a concession granted
 
to a client facing
 
or that is about
to
 
face
 
financial
 
difficulties
 
or
 
due
 
to
 
other
 
commercial
 
reasons
 
such
 
as
 
changes
 
in
 
market
 
conditions,
 
competition
 
or
 
customer
retention.
In addition,
 
the Group
 
may occasionally
 
enter,
 
in the
 
context
 
of loans’
 
modifications, into
 
debt-for-equity
 
transactions.
 
These are
transactions where the terms of a lending exposure
 
are renegotiated and as a result,
 
the borrower issues equity instruments (voting
or no
 
voting) in
 
order to
 
extinguish part
 
or all
 
of its
 
financial liability
 
to the
 
Group. Such
 
transactions
 
may include
 
also exercise
 
of
conversion rights embedded into
 
convertible or exchangeable bonds
 
and enforcement of shares held as collateral.
In debt-for-equity transactions, the
 
modified loan is derecognized while the
 
equity instruments received in
 
exchange are recognized
at their fair value, with any resulting gain
 
or loss recognized in the Group’s
 
income statement.
 
2.2.10 Reclassifications of financial assets
The Group reclassifies a financial
 
asset only when it changes its business
 
model for managing financial assets. Generally,
 
a change in
the business model is expected to be rare and occurs when the Group either begins or ceases to perform an activity that is significant
to its operations; for
 
example, when a business
 
line is acquired, disposed of or
 
terminated. In the rare
 
event when there is
 
a change
to the existing business
 
models, the updated assessment
 
is approved by the Group’s
 
competent Committees and
 
the amendment is
reflected appropriately in the Group’s
 
budget and business plan.
Notes to the Consolidated Financial Statements
 
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Changes
 
in intention
 
related
 
to particular
 
financial assets
 
(even in
 
circumstances
 
of significant
 
changes in
 
market
 
conditions), the
temporary disappearance of
 
a particular market for
 
financial assets or a transfer
 
of financial assets between parts of the
 
Group with
different business models, are not
 
considered by the Group changes in business model.
The reclassification
 
is applied
 
prospectively
 
from the
 
reclassification
 
date,
 
therefore
 
previously
 
recognized
 
gains,
 
losses (including
impairment losses) or interest are not restated.
2.2.11 Financial liabilities
Financial liabilities - Classification and measurement
The Group
 
classifies its
 
financial liabilities
 
in the
 
following
 
categories: financial
 
liabilities measured
 
at amortized
 
cost and
 
financial
liabilities measured at fair-value-through
 
-profit-or-loss (FVTPL).
Financial liabilities at FVTPL comprise two sub categories: financial
 
liabilities held for trading and financial liabilities designated at fair-
value-through-profit-or-loss upon
 
initial recognition.
Financial liabilities
 
held for
 
trading, which
 
include short positions
 
of debt
 
securities (sold but
 
not yet
 
purchased), are
 
liabilities that
the Group
 
incurs principally
 
for
 
the purpose
 
of repurchasing
 
in the
 
near term
 
for
 
short term
 
profit
 
or in
 
the context
 
of economic
hedging strategies of groups of assets
 
and/or liabilities or net positions for which hedge accounting
 
is not applied.
Additionally,
 
the Group
 
may also,
 
at initial
 
recognition,
 
irrevocably designate
 
financial liabilities
 
at fair-value
 
-through-profit-or-loss
when certain criteria are met.
Financial liabilities held for trading or designated at FVTPL are initially recognized at fair value. Changes in fair value are recognized
 
in
the income statement, except
 
for changes in the fair value of liabilities designated
 
at fair-value-through-profit
 
-or-loss attributable to
changes in the
 
Group’s
 
own credit risk,
 
which are recognised
 
in OCI and
 
are not subsequently
 
reclassified to
 
the income statement
upon derecognition of the
 
liabilities. However, if such treatment creates or
 
enlarges an accounting mismatch
 
in the income
 
statement,
all gains or losses of this financial liability,
 
including the effects of changes in the credit risk, are recognized
 
in the income statement.
Derecognition of financial liabilities
A
 
financial
 
liability
 
is
 
derecognized
 
when
 
the
 
obligation
 
under
 
the
 
liability
 
is
 
discharged,
 
cancelled
 
or
 
expires.
 
When
 
an
 
existing
financial liability of the Group is replaced by another from the same counterparty on substantially different
 
terms, or the terms of an
existing liability are
 
substantially modified,
 
such an exchange
 
or modification is
 
treated as
 
an extinguishment of
 
the original liability
and the recognition of a new liability and any difference
 
arising is recognized in the income statement.
The Group considers
 
the terms to be
 
substantially different,
 
if the discounted present
 
value of the cash
 
flows under the new
 
terms,
including any fees paid net of any fees received and discounted using the original effective interest rate, is at least 10% different from
the discounted present value of the remaining
 
cash flows of the original financial liability.
If an
 
exchange
 
of debt
 
instruments
 
or modification
 
of terms
 
is accounted
 
for as
 
an extinguishment,
 
any costs
 
or fees
 
incurred are
recognized as part of
 
the gain or
 
loss on
 
the extinguishment. If
 
the exchange or modification
 
is not
 
accounted for as an
 
extinguishment,
any
 
costs
 
or fees
 
incurred
 
adjust the
 
carrying amount
 
of the
 
liability and
 
are amortized
 
over the
 
remaining
 
term
 
of the
 
modified
liability.
Similarly,
 
when
 
the
 
Group
 
repurchases
 
any
 
debt
 
instruments
 
issued
 
by
 
the
 
Group,
 
it
 
accounts
 
for
 
such
 
transactions
 
as
 
an
extinguishment of debt.
 
2.2.12 Fair value measurement of financial instruments
Fair
 
value
 
of
 
financial
 
instruments
 
is the
 
price
 
that
 
would
 
be received
 
to
 
sell
 
an
 
asset
 
or paid
 
to
 
transfer
 
a liability
 
in
 
an
 
orderly
transaction between market participants at the measurement date under
 
current market conditions in the principal
 
or, in its absence,
the most advantageous
 
market to
 
which the Group
 
has access at
 
that date.
 
The fair value
 
of a liability
 
reflects its non-performance
risk.
When available, the
 
Group measures the fair
 
value of an instrument
 
using the quoted price
 
in an active market
 
for that instrument.
A market
 
is regarded
 
as active
 
if transactions
 
for
 
the asset
 
or liability
 
take
 
place with
 
sufficient
 
frequency and
 
volume to
 
provide
pricing
 
information
 
on
 
an
 
ongoing
 
basis.
 
If
 
there
 
is
 
no
 
quoted
 
price
 
in
 
an
 
active
 
market,
 
then
 
the
 
Group
 
uses
 
other
 
valuation
Notes to the Consolidated Financial Statements
 
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techniques that maximize
 
the use of relevant
 
observable inputs and minimize
 
the use of unobservable
 
inputs. The chosen valuation
technique incorporates all of the factors
 
that market participants would take
 
into account in pricing a transaction.
The Group has elected to use mid-market pricing as
 
a practical expedient for fair
 
value measurements within a bid-ask spread.
The best evidence
 
of the fair value
 
of a financial instrument
 
at initial recognition
 
is normally the transaction
 
price, i.e. the fair
 
value
of the consideration given
 
or received unless
 
the Group determines
 
that the fair
 
value at initial
 
recognition differs from the transaction
price. In this case,
 
if the fair value is evidenced
 
by a quoted price in
 
an active market for an identical asset
 
or liability (i.e. Level 1 input)
or based on
 
a valuation
 
technique that
 
uses only data
 
from observable
 
markets, a
 
day one
 
gain or
 
loss is recognized
 
in the
 
income
statement.
 
On the
 
other hand,
 
if the
 
fair value
 
is evidenced
 
by a
 
valuation
 
technique that
 
uses unobservable
 
inputs, the
 
financial
instrument
 
is initially
 
measured at
 
fair value,
 
adjusted to
 
defer the
 
difference
 
between the
 
fair value
 
at initial
 
recognition and
 
the
transaction price (day
 
one gain or
 
loss). Subsequently the
 
deferred gain
 
or loss is amortized
 
on an appropriate
 
basis over the
 
life of
the instrument or released
 
earlier if a quoted
 
price in an active market
 
or observable market
 
data become available
 
or the financial
instrument is closed out.
All assets and liabilities for
 
which fair value is measured
 
or disclosed in the financial statements
 
are categorized
 
within the fair value
hierarchy based on the lowest
 
level input that is significant to the fair value
 
measurement as a whole.
For assets and
 
liabilities that are
 
measured at fair
 
value on a
 
recurring basis, the
 
Group recognizes
 
transfers
 
into and out
 
of the fair
value hierarchy levels at
 
the beginning of the quarter in which a financial instrument's transfer
 
was effected.
 
2.2.13 Impairment of financial assets
The
 
Group
 
recognizes
 
allowance
 
for
 
expected
 
credit
 
losses
 
(ECL)
 
that
 
reflect
 
changes
 
in
 
credit
 
quality
 
since initial
 
recognition
 
to
financial assets that are measured
 
at AC and FVOCI, including
 
loans, securitization notes issued by special
 
purpose entities established
by the Group, lease
 
receivables, debt securities, as well
 
as
 
financial guarantee contracts and loan
 
commitments. ECL are a probability-
weighted average estimate of credit losses that reflects the time value of money. Upon initial recognition of the financial instruments
in scope of the impairment policy,
 
the Group records a
 
loss allowance equal to 12-month ECL,
 
being the ECL that result from default
events
 
that
 
are
 
possible
 
within
 
the
 
next
 
twelve
 
months.
 
Subsequently,
 
for
 
those
 
financial
 
instruments
 
that
 
have
 
experienced
 
a
significant
 
increase
 
in
 
credit
 
risk
 
(SICR) since
 
initial
 
recognition,
 
a loss
 
allowance
 
equal
 
to
 
lifetime
 
ECL
 
is recognized,
 
arising
 
from
default
 
events
 
that are
 
possible over
 
the expected
 
life
 
of the
 
instrument.
 
If upon
 
initial recognition,
 
the financial
 
asset meets
 
the
definition of purchased or originated credit
 
impaired (POCI), the loss allowance is based on the change in
 
the ECL over the life of the
asset.
Loss allowances for
 
trade receivables
 
are always
 
measured at an
 
amount equal to
 
lifetime ECL. For
 
all other financial assets
 
subject
to impairment, the general three-stage
 
approach applies.
Accordingly,
 
ECL are recognized using a three-stage
 
approach based on the extent of credit deterioration
 
since origination:
Stage 1
 
– When
 
there is
 
no significant
 
increase in
 
credit risk
 
since initial
 
recognition of
 
a financial
 
instrument, an
 
amount
equal to 12-month ECL is
 
recorded. The 12 – month
 
ECL represent a portion of
 
lifetime losses, that result from default events
that are
 
possible within the
 
next 12
 
months after
 
the reporting
 
date and
 
is equal to
 
the expected
 
cash shortfalls
 
over the
life of the instrument
 
or group of instruments, due
 
to loss events probable
 
within the next 12 months.
 
Not credit-impaired
financial
 
assets
 
that
 
are
 
either
 
newly
 
originated
 
or
 
purchased,
 
as
 
well
 
as
 
assets
 
recognized
 
following
 
a
 
substantial
modification accounted for as a derecognition,
 
are classified initially in Stage 1.
Stage 2 – When
 
a financial instrument
 
experiences a SICR subsequent
 
to origination but
 
is not considered
 
to be in default,
it is included
 
in Stage 2.
 
Lifetime ECL
 
represent the
 
expected credit
 
losses that result
 
from all possible
 
default events
 
over
the expected life of the financial instrument.
Stage
 
3
 
 
Financial
 
instruments
 
that
 
are
 
considered
 
to
 
be
 
in
 
default
 
are
 
included
 
in
 
this
 
stage.
 
Similar
 
to
 
Stage
 
2,
 
the
allowance for credit losses captures
 
the lifetime expected credit losses.
POCI
 
-
 
Purchased
 
or
 
originated
 
credit
 
impaired
 
(POCI)
 
assets
 
are
 
financial
 
assets
 
that
 
are
 
credit
 
impaired
 
on
 
initial
recognition. They are not subject
 
to stage allocation and are always measured on
 
the basis of lifetime
 
expected credit losses.
Accordingly,
 
ECL are only recognized
 
to the extent that
 
there is a subsequent change
 
in the assets’ lifetime expected
 
credit
losses.
 
Any
 
subsequent
 
favorable
 
change
 
to
 
their
 
expected
 
cash
 
flows
 
is
 
recognized
 
as
 
impairment
 
gain
 
in
 
the
 
income
statement
 
even
 
if
 
the
 
resulting
 
expected
 
cash
 
flows
 
exceed
 
the
 
estimated
 
cash
 
flows
 
at
 
initial
 
recognition.
 
Apart
 
from
purchased
 
assets
 
directly
 
from
 
the
 
market
 
or
 
through
 
a
 
business
 
combination,
 
POCI
 
assets
 
may
 
also
 
include
 
financial
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instruments
 
that
 
are
 
considered
 
new
 
assets,
 
following
 
a
 
substantial
 
modification
 
accounted
 
for
 
as
 
a
 
derecognition
 
(see
section 2.2.9).
Definition of default
To determine the risk of default, the
 
Group applies a
 
default definition for accounting purposes, which
 
is consistent with the
 
European
Banking Authority
 
(EBA) definition
 
for non-performing
 
exposure
 
and regulatory
 
definition of
 
default
 
as applied
 
by the
 
Group on
 
1
January 2021 (refer
 
to note
 
5.2.1.2 (a)). The
 
accounting definition
 
of default
 
is also consistent
 
with the
 
one used for
 
internal credit
risk management purposes.
A financial asset
 
is credit-impaired
 
when one or
 
more events
 
that have
 
a detrimental
 
impact on the
 
estimated future
 
cash flows
 
of
that exposure have occurred:
The borrower faces a significant difficulty
 
in meeting his financial obligations.
There has been a breach of contract,
 
such as a default or unpaid amounts, above specified materiality
 
thresholds, for more
than 90 consecutive days.
The Group, for
 
economic or contractual
 
reasons relating to
 
the borrower’s financial
 
difficulty,
 
has granted to
 
the borrower
a concession(s) that the Group would not otherwise consider.
There is a probability that the borrower
 
will enter bankruptcy or other financial re-organization.
For POCI
 
financial assets,
 
a purchase
 
or origination
 
at a
 
deep discount
 
that reflects
 
incurred credit
 
losses is
 
considered a
detrimental
 
event. The
 
Group assesses
 
the deep
 
discount criterion
 
following a
 
principle -based
 
approach with
 
the aim
 
to
incorporate
 
all
 
reasonable
 
and
 
supportable
 
information
 
which
 
reflects
 
market
 
conditions
 
that
 
exist
 
at
 
the
 
time
 
of
 
the
assessment.
For debt securities, the Group determines the risk of default using an internal credit rating scale. The Group considers debt securities
as credit impaired if the internal rating of the issuer/counterparty
 
corresponds to a rating equivalent to "C" (Moody's ratin
 
g
 
scale) or
the external rating of the issuer/counterparty at
 
the reporting date is equivalent to “C” (Moody’s rating scale) and the internal rating
is not available.
Significant increase in credit risk (SICR) and staging allocation
Determining whether a loss
 
allowance should be based
 
on 12-month expected credit losses
 
or lifetime expected credit losses
 
depends
on whether
 
there has been
 
a significant
 
increase in credit
 
risk (SICR) of
 
the financial assets,
 
issued loan commitments
 
and financial
guarantee contracts,
 
since initial recognition.
At each reporting date, the Group performs an assessment as to whether
 
the risk of a default occurring over the remaining expected
lifetime of the exposure has increased significantly from the expected
 
risk of a default estimated at origination for
 
that point in time.
The
 
assessment
 
for
 
SICR
 
is
 
performed
 
using
 
both
 
qualitative
 
and
 
quantitative
 
criteria
 
based
 
on
 
reasonable
 
and
 
supportable
information
 
that is
 
available
 
without undue
 
cost or
 
effort
 
including forward
 
looking information
 
and macroeconomic
 
scenarios as
well as historical experience. Furthermore, regardless
 
of the outcome of the SICR assessment based on the above triggers, the credit
risk of a financial asset is deemed to have increased significantly
 
when contractual payments are more
 
than 30 days past due.
As a primary criterion
 
for SICR assessment, the Group compares
 
the residual lifetime probability of default (PD) at
 
each reporting date
to the residual lifetime PD for the same point
 
in time which was expected at the origination.
The Group
 
may also consider
 
as a SICR
 
trigger when the
 
residual lifetime
 
PD at each
 
reporting date
 
exceeds certain
 
predetermined
values. The criterion may be applied in order to
 
capture cases where the relative
 
PD comparison does not result to the identification
of SICR although the absolute value of PD is at levels which
 
are considered high based on the Group’s
 
risk appetite framework.
Internal credit risk rating
 
(on a borrower basis) is also used
 
as a basis for the identification
 
of SICR with regards to
 
lending exposures
of the
 
Wholesale portfolio.
 
Specifically,
 
the Group
 
takes
 
into consideration
 
the changes
 
of internal
 
ratings
 
by a
 
certain number
 
of
notches. In
 
addition, a watchlist
 
status is
 
also considered
 
by the Group
 
as a trigger
 
for SICR
 
identification. Internal
 
credit risk rating
models include borrower specific
 
information as well as, forward-looking information regarding the prospects
 
of the industry in
 
which
it operates. For securitization notes issued by special purpose entities established by the Group, the SICR assessment is performed by
considering
 
the
 
performance
 
of
 
the
 
underlying
 
assets,
 
where
 
the
 
level
 
of
 
their
 
expected
 
cash
 
flows
 
is
 
compared
 
to
 
the
 
carrying
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amount of the securitized notes.
 
In addition, the assessment of SICR for
 
debt securities is performed on an individual
 
basis based on
the number of notches downgrade in the internal
 
credit rating scale since the origination date.
Forbearance measures as monitored by the
 
Group are considered as a SICR trigger and thus the exposures are
 
allocated into Stage 2
upon
 
forbearance,
 
unless
 
they
 
are
 
considered
 
credit-impaired
 
or
 
the
 
net
 
present
 
value
 
of
 
their
 
cash
 
flows
 
before
 
and
 
after
 
the
restructuring exceed the threshold of 1%, in which cases they are classified
 
as Stage 3. Furthermore, regardless of the outcome of the
SICR
 
assessment
 
based
 
on
 
the
 
above
 
triggers,
 
the
 
credit
 
risk
 
of
 
a
 
financial
 
asset
 
is
 
deemed
 
to
 
have
 
increased
 
significantly
 
when
contractual payments are
 
more than 30 days past due.
Furthermore,
 
Management
 
may
 
apply
 
temporary
 
collective
 
adjustments
 
when
 
determining
 
whether
 
credit
 
risk
 
has
 
increased
significantly since initial
 
recognition on exposures
 
that share the same
 
credit risk characteristics
 
to reflect macro-economic
 
or other
factors which are
 
not adequately addressed by the
 
current credit risk models. These factors
 
may depend on information
 
such as the
type of the
 
exposure, counterparty’s
 
specific information
 
and the characteristics
 
of the financial instrument,
 
while their application
requires the application of significant judgment.
Transfers from Stage
 
2 to Stage 1
A financial asset,
 
which is classified to
 
Stage 2 due
 
to Significant
 
Increase in Credit
 
Risk (SICR), is reclassified
 
to Stage 1,
 
as long as
 
it
does not meet anymore any of the Stage 2 Criteria.
Where forbearance measures have been applied, the Group uses a probation period of two years,
 
in order to fulfill the requirements
for
 
a transfer
 
back to
 
Stage
 
1. If
 
at
 
the end
 
of that
 
period
 
the borrowers
 
have
 
made regular
 
payments
 
of
 
a significant
 
aggregate
amount, there are
 
no past due amounts
 
over 30 days and
 
the loans are neither credit
 
impaired, nor any other
 
SICR criteria are met,
they exit forborne status and are
 
classified as stage 1.
 
Transfers from Stage
 
3 to Stage 2
A financial
 
asset is
 
transferred
 
from Stage
 
3 to
 
Stage 2,
 
when the
 
criteria based
 
on which
 
the financial
 
asset was
 
characterized
 
as
credit impaired
 
are no
 
longer valid
 
and the
 
applicable probation
 
period for
 
the assets’
 
return in
 
non impaired
 
status, ranging
 
from
three to twelve months, has passed.
Criteria for grouping of exposures based on shared credit risk characteristics
The assessment
 
of loss allowance
 
is performed
 
either on an
 
individual basis or
 
on a collective
 
basis for
 
groups of similar
 
items with
homogeneous
 
credit
 
risk
 
characteristics.
 
The
 
Group
 
applies
 
the
 
same
 
principles
 
for
 
assessing
 
SICR
 
since
 
initial
 
recognition
 
when
estimating ECL on a collective or on an individual basis.
The
 
Group
 
segments
 
its
 
lending
 
exposures
 
on
 
the
 
basis
 
of
 
shared
 
credit
 
risk
 
characteristics
 
for
 
the
 
purposes
 
of
 
both
 
assessing
significant
 
increase
 
in
 
credit
 
risk
 
and
 
measuring
 
loan
 
loss
 
allowance
 
on
 
a collective
 
basis.
 
The
 
different
 
segments
 
aim to
 
capture
differences in PDs and in the rates
 
of recovery in the event of default.
The
 
shared
 
credit
 
risk
 
characteristics
 
used
 
for
 
the segmentation
 
of
 
exposures
 
include
 
several
 
elements
 
such
 
as: instrument
 
type,
portfolio
 
type,
 
asset
 
class,
 
product
 
type,
 
industry,
 
originating
 
entity,
 
credit
 
risk
 
rating,
 
remaining
 
term
 
to
 
maturity,
 
geographical
location of the borrower,
 
value of collateral to the financial asset, forbearance
 
status and days in arrears.
The Group
 
identifies individually
 
significant exposures
 
and performs
 
the ECL measurement
 
based on borrower
 
specific information
for both
 
retail and
 
wholesale portfolios.
 
This measurement
 
is performed
 
at a
 
borrower level,
 
hence the
 
criteria are
 
defined at
 
this
level, while both qualitative and quantitative
 
factors are taken
 
into consideration including forward
 
looking information.
For
 
the
 
remaining
 
retail
 
and
 
wholesale
 
exposures,
 
ECL
 
are
 
measured
 
on
 
a
 
collective
 
basis.
 
This
 
incorporates
 
borrower
 
specific
information,
 
collective historical
 
experience of
 
losses and
 
forward-looking information.
 
For debt
 
securities and
 
securitization notes
issued by
 
special purpose
 
entities established
 
by the
 
Group, the
 
measurement of
 
impairment losses
 
is performed
 
on an
 
individual
basis.
Measurement of Expected Credit Losses
The measurement of ECL is an unbiased probability-weighted average estimate of credit losses that reflects the time value of money,
determined by
 
evaluating a
 
range of
 
possible outcomes.
 
A credit
 
loss is
 
the difference
 
between the
 
cash flows
 
that are
 
due to
 
the
Group in
 
accordance with
 
the contractual
 
terms of
 
the instrument
 
and the
 
cash flows
 
that the
 
Group
 
expects to
 
receive (i.e.
 
cash
shortfalls)
 
discounted
 
at
 
the
 
original
 
effective
 
interest
 
rate
 
(EIR)
 
of
 
the
 
same
 
instrument,
 
or
 
the
 
credit-adjusted
 
EIR
 
in
 
case
 
of
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purchased
 
or
 
originated
 
credit
 
impaired
 
assets
 
(POCI).
 
In
 
measuring
 
ECL,
 
information
 
about
 
past
 
events,
 
current
 
conditions
 
and
reasonable
 
and
 
supportable
 
forecasts
 
of
 
future
 
conditions
 
are
 
considered.
 
For
 
undrawn
 
commitments,
 
ECL
 
are
 
calculated
 
as
 
the
present value
 
of the difference
 
between the contractual
 
cash flows due if
 
the commitment was
 
drawn and the
 
cash flows expected
to be received, while for financial guarantees ECL are measured
 
as the expected payments to reimburse the holder less any amounts
that the Group expects to receive.
The Group
 
estimates expected
 
cash shortfalls,
 
which reflect
 
the cash
 
flows expected
 
from all
 
possible sources,
 
including collateral,
guarantees
 
and other
 
credit enhancements
 
that are
 
part of
 
the contractual
 
terms and
 
are not
 
recognized
 
separately.
 
In case
 
of a
collateralized financial instrument,
 
the estimated expected cash flows related
 
to the collateral reflect the amount
 
and timing of cash
flows
 
that
 
are
 
expected
 
from
 
liquidation
 
less the
 
discounted
 
costs
 
of obtaining
 
and selling
 
the collateral,
 
irrespective
 
of
 
whether
liquidation is probable.
ECL are calculated
 
over the maximum contractual
 
period over which the
 
Group is exposed
 
to credit risk,
 
which is determined based
on the
 
substantive
 
terms of
 
the instrument,
 
or in
 
case of
 
revolving credit
 
facilities, by
 
taking into
 
consideration factors
 
such as
 
the
Group’s expected
 
credit risk management actions to mitigate
 
credit risk and past practice.
Receivables from customers arising from the Group’s activities other than lending, are presented under Other
 
Assets and are typically
short term. Therefore, considering that usually
 
there is no
 
significant financing component, the
 
loss allowance for such
 
financial assets
is measured at an amount equal to the lifetime expected
 
credit losses under the simplified approach.
ECL Key Inputs
The ECL calculations are based on the term structures
 
of the probability of default (PD), the loss given default
 
(LGD), the exposure at
default (EAD) and
 
other input parameters
 
such as the credit conversion
 
factor (CCF) and the
 
prepayment rate.
 
Generally,
 
the Group
derives these parameters from internally
 
developed statistical models and observed point
 
-in-time and historical data, leveraging the
existing infrastructure development
 
for the regulatory framework
 
and risk management practices.
The PD
 
represents the
 
likelihood of
 
default assessed
 
on the
 
prevailing economic
 
conditions at
 
the reporting
 
date, adjusted
 
to take
into account estimates of future economic
 
conditions that are likely to impact the
 
risk of default, over a given time horizon.
The Group uses Point in Time (PiT) PDs in order to remove any bias towards historical data thus aiming to reflect management’s
 
view
of the future as at the reporting date, incorporating
 
relevant forward looking information
 
including macroeconomic scenarios.
Two types of PD are used for
 
calculating ECL:
12-month PD, which
 
is the estimated probability
 
of default occurring within the
 
next 12 months (or over
 
the remaining life
of the financial asset if this is less than 12 months). It is used to calculate 12-month
 
ECL for Stage 1 exposures.
Lifetime PD, which is the estimated probability
 
of a default occurring over the remaining life of the financial asset. It is used
to calculate lifetime ECL for
 
Stage 2, Stage 3 and POCI exposures.
For debt securities,
 
PDs are obtained
 
by an international
 
rating agency using
 
risk methodologies that
 
maximize the use
 
of objective
non-judgmental variables and market data. The Group assigns internal credit ratings to each issuer/counterparty based on these PDs.
In case of counterparties for which no information
 
is available, the Group assigns PDs which are derived from
 
internal models.
The Exposure
 
at default
 
(EAD) is an
 
estimate of
 
the exposure
 
at a
 
future default
 
date, taking
 
into account
 
expected changes
 
in the
exposure after
 
the reporting date,
 
including repayments
 
of principal and interest
 
and expected drawdowns
 
on committed facilities.
The EAD includes both on and off balance sheet exposures. The on balance sheet exposure corresponds
 
to the total amount that has
been withdrawn and is due to be paid, which includes the outstanding
 
principal, accrued interest and any past
 
due amounts. The off
balance sheet exposure represents the credit
 
that is available to be withdrawn,
 
in excess of the on balance sheet exposure.
Furthermore, the CCF factor is used to
 
convert the amount of a credit facility and
 
other off-balance sheet amounts to an
 
EAD amount.
It is a modelled assumption
 
which represents a proportion
 
of any undrawn
 
exposure that is expected
 
to be drawn
 
prior to a default
event occurring.
In
 
addition,
 
the
 
prepayment
 
rate
 
is
 
an
 
estimate
 
of
 
early
 
prepayments
 
on
 
loan
 
exposure
 
in
 
excess
 
of
 
the
 
contractual
 
repayment
according to the repayment schedule and is expressed as a percentage applied to the EAD at each period, reducing the latter amount
accordingly.
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LGD represents the Group's expectation of the extent of loss on a
 
defaulted exposure and it is the difference between the contractual
cash flows due and
 
those that the Group
 
expects to receive including
 
any amounts from
 
collateral liquidation.
 
LGD varies by type
 
of
counterparty,
 
type and seniority of claim, availability of collateral or other credit support, and is usually expressed as a percentage of
EAD. The Group distinguishes
 
its loan portfolios into two
 
broad categories i.e. secured
 
and unsecured. The Group estimates
 
the LGD
component
 
using
 
cure
 
rates
 
that
 
reflect
 
cash
 
recoveries,
 
estimated
 
proceeds
 
from
 
collateral
 
liquidation,
 
estimates
 
for
 
timing
realization,
 
realization
 
costs,
 
etc.
 
Where
 
the
 
LGD’s
 
component
 
values
 
are
 
dependent
 
on
 
macro
 
 
economic
 
data,
 
such
 
types
 
of
dependencies are reflected by incorporating forward looking information, such as
 
forecasted price indices into the respective models.
The
 
estimation
 
of
 
the
 
aforementioned
 
component
 
values
 
within
 
LGD
 
reflects
 
available
 
historical
 
data
 
which
 
cover
 
a
 
reasonable
period, i.e. a full economic cycle.
For
 
debt
 
securities,
 
the
 
LGD
 
is
 
typically
 
based
 
on
 
historical
 
data
 
derived
 
mainly
 
from
 
rating
 
agencies’
 
studies
 
but
 
may
 
also
 
be
determined considering the existing and expected
 
liabilities structure of the obligor and macroeconomic environment.
Furthermore, the
 
seniority of
 
the debt
 
security,
 
any potential
 
collaterals
 
by the
 
obligor or
 
any other
 
type of
 
coverage is
 
taken
 
into
account for the calculation.
Forward-looking information
The
 
measurement
 
of
 
expected
 
credit
 
losses
 
for
 
each
 
stage
 
and
 
the
 
assessment
 
of
 
significant
 
increases
 
in
 
credit
 
risk
 
consider
information
 
about
 
reasonable
 
and
 
supportable
 
forecasts
 
of
 
future
 
events
 
and
 
macroeconomic
 
conditions.
 
The
 
estimation
 
and
application of forward-looking information
 
requires significant judgment.
The Group uses three macroeconomic scenarios (i.e. base, adverse and optimistic) to achieve the objective of
 
measuring ECL in a way
that reflects an unbiased and probability weighted outcome.
 
The baseline scenario represents the most likely scenario and is aligned
with the information used by the Group for
 
strategic planning and budgeting purposes.
The scenarios
 
are reflected
 
in the
 
risk parameters,
 
and, namely
 
12-month PD,
 
Lifetime PD
 
and LGD,
 
hence 3
 
sets of
 
each of
 
these
parameters are used, in line with the scenarios developed.
The Group then
 
proceeds to the
 
calculation of weights
 
for each scenario,
 
which represent
 
the probability of
 
occurrence for each
 
of
these
 
scenarios.
 
These
 
weights
 
are
 
applied
 
on
 
the
 
3 sets
 
of
 
calculations
 
of
 
the
 
parameters
 
in order
 
to
 
produce
 
a single
 
scenario
weighted
 
risk
 
parameter
 
value
 
which
 
is
 
subsequently
 
used
 
in
 
both
 
SICR
 
assessment
 
and
 
ECL
 
measurement.
 
ECL
 
calculation
incorporates
 
forward-looking
 
macroeconomic
 
variables,
 
including
 
GDP
 
growth
 
rates,
 
house
 
price
 
indices,
 
unemployment
 
rates,
interest
 
rates,
 
inflation,
 
etc.
 
In order
 
to
 
capture
 
material
 
non –
 
linearities
 
in the
 
ECL model,
 
in the
 
case of
 
individually
 
significant
exposures, the
 
Group considers
 
the relevance
 
of forward
 
looking information
 
to each
 
specific group
 
of borrowers
 
primarily on
 
the
basis of the business sector they belong and other drivers of credit risk
 
(if any).
Modified Financial Assets
In
 
cases
 
where
 
the
 
contractual
 
cash
 
flows
 
of
 
a financial
 
asset have
 
been
 
modified
 
and the
 
modification
 
is considered
 
substantial
enough (for the
 
triggers of derecognition,
 
refer to
 
Derecognition of Financial
 
assets in section 2.2.9
 
above), the modificati
 
on date is
considered
 
to
 
be
 
the
 
date
 
of
 
initial
 
recognition
 
for
 
impairment
 
calculation
 
purposes,
 
including
 
for
 
the
 
purposes
 
of
 
determining
whether a significant increase in credit risk has occurred. Such a modified asset is typically classified as Stage
 
1 for ECL measurement
purposes. However,
 
in some circumstances following a modification that results in derecognition of the original financial asset, there
may be evidence that the new financial asset is credit-impaired
 
at initial recognition, and thus, the financial asset is recognized
 
as an
originated credit-impaired financial asset (POCI).
In cases where the contractual
 
cash flows of a financial asset
 
have been modified and the
 
modification is not considered
 
substantial
enough, the Group recalculates the
 
gross carrying amount of the financial asset and
 
recognizes the difference
 
as a modification gain
or loss in the
 
income statement
 
and determines if
 
the financial asset’s
 
credit risk has
 
increased significantly
 
since initial recognition
by comparing the risk
 
of a default occurring
 
at initial recognition based
 
on the original unmodified contractual
 
terms and the risk
 
of
a default occurring at the reporting date, based
 
on the modified contractual terms.
Presentation of impairment allowance
For financial assets measured
 
at amortized cost, impairment
 
allowance is recognized as
 
a loss allowance reducing the
 
gross carrying
amount of the financial assets in the balance sheet. For debt instruments measured at
 
FVOCI, impairment allowance is recognized in
other comprehensive income and does not reduce the carrying amount of the debt instruments in the balance sheet. For off-balance
Notes to the Consolidated Financial Statements
 
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sheet financial items arising from lending activities, impairment allowance is presented in Other Liabilities. The respective ECL for the
above financial items is recognised within impairment
 
losses.
Write-off of financial assets
Where the
 
Group
 
has no
 
reasonable
 
expectations
 
of recovering
 
a financial
 
asset either
 
in its
 
entirety
 
or a
 
portion of
 
it, the
 
gross
carrying amount of that instrument is reduced directly,
 
partially or in full, against the impairment allowance. The amount written-off
is considered
 
as derecognized.
 
Subsequent
 
recoveries
 
of amounts
 
previously
 
written
 
off decrease
 
the amount
 
of the
 
impairment
losses in the income statement.
Financial assets that
 
are written
 
off could
 
still be subject
 
to enforcement
 
activities in order
 
to comply with
 
the Group’s
 
procedures
for recovery of amounts due.
2.2.14 Sale and repurchase agreements, securities lending and borrowing
(i) Sale and repurchase agreements
Securities sold subject to repurchase
 
agreements (repos) continue
 
to be recorded in the
 
Group's Balance Sheet as the Group
 
retains
substantially all risks
 
and rewards of
 
ownership, while the
 
liability to the counterparty
 
is included in amounts
 
due to other banks
 
or
due to customers, as
 
appropriate, and measured at
 
amortized cost. Securities purchased
 
under agreements to resell (reverse
 
repos)
are recorded
 
as loans
 
and advances
 
to other
 
banks or
 
customers, as
 
appropriate,
 
and measured
 
at amortized
 
cost. The
 
difference
between the
 
sale and repurchase
 
price in case
 
of repos
 
and the purchase
 
and resale
 
price in case
 
of reverse
 
repos is
 
recognized
 
as
interest and accrued over the period of the repo
 
or reverse repo agreements using the effective
 
interest method. .
(ii) Securities lending and borrowing
Securities lent to
 
counterparties against the receipt of
 
a fee continue to
 
be recognized in the
 
financial statements. Securities borrowed
are
 
recognized
 
as trading
 
liabilities when
 
sold to
 
third parties
 
and measured
 
at fair
 
value with
 
any
 
gains or
 
losses included
 
in the
income statement.
 
2.2.15 Leases
T
he Group enters into leases either
 
as a lessee or as a lessor.
 
At inception of a contract, the Group
 
assesses whether a contract is, or
contains, a lease.
(i) Accounting for leases as lessee
When the
 
Group
 
becomes the
 
lessee in
 
a lease
 
arrangement,
 
it recognizes
 
a lease
 
liability and
 
a corresponding
 
right-of-use
 
(RoU)
asset at the commencement of the lease term when the Group acquires
 
control of the physical use of the asset.
Lease liabilities are presented within Other liabilities and RoU assets within Property
 
and equipment and investment property.
 
Lease
liabilities are measured based on
 
the present value of
 
the future lease
 
payments over the lease term,
 
discounted using an incremental
borrowing rate. The interest
 
expense on lease liabilities is presented within net interest
 
income.
The lease liability is remeasured when there is a
 
change in future lease payments
 
arising from a change in an index or rate,
 
a change
in the Group’s estimate of
 
the amount expected to
 
be payable under a
 
residual value guarantee or if
 
the Group changes its
 
assessment
of
 
whether
 
it
 
will
 
exercise
 
a
 
purchase,
 
extension
 
or
 
termination
 
option.
 
When
 
the
 
lease
 
liability
 
is
 
remeasured
 
in
 
this
 
way,
 
a
corresponding
 
adjustment
 
is made
 
to the
 
carrying amount
 
of the
 
right-of-use
 
asset, or
 
is recorded
 
in profit
 
or loss
 
if the
 
carrying
amount of the right-of-use asset has been reduced to zero.
The RoU asset
 
is initially recorded
 
at an amount
 
equal to the lease liability
 
and is adjusted
 
for rent prepayments,
 
initial direct costs,
or lease incentives
 
received. Subsequently,
 
the RoU
 
asset is depreciated
 
over the
 
shorter of
 
the lease term
 
or the useful
 
life of
 
the
underlying asset, with the depreciation presented
 
within operating expenses.
When a lease
 
contains extension
 
or termination options
 
that the Group
 
considers reasonably
 
certain to
 
be exercised,
 
the expected
future lease payments or costs of early termination
 
are included within the lease payments used to calculate
 
the lease liability.
The Group has
 
elected not to
 
recognise right-of-use
 
assets and lease
 
liabilities for
 
leases of low-value
 
assets and short-term
 
leases.
The Group recognises the lease payments
 
associated with these leases as an expense on a straight-line basis
 
over the lease term.
Notes to the Consolidated Financial Statements
 
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(ii) Accounting for leases as lessor
At inception date of the lease, the Group, acting as a lessor,
 
classifies each of its leases as either an operating lease or a finance lease
based on whether the lease transfers
 
substantially all of the risks and
 
rewards incidental to the
 
ownership of the underlying asset. If
this is the case, then the
 
lease is a finance lease; if not,
 
then it is an operating
 
lease. As part of this assessment,
 
the Group considers
certain indicators such as whether the
 
lease is for the major part of the economic life of the asset.
Finance leases
At commencement date,
 
the Group derecognizes
 
the carrying amount
 
of the underlying assets held under
 
finance lease, recognizes
a receivable at
 
an amount equal to
 
the net investment
 
in the lease and recognizes,
 
in income statement,
 
any profit or
 
loss from the
derecognition
 
of the
 
asset and
 
the recognition
 
of the
 
net investment.
 
The net
 
investment
 
in the
 
lease is
 
calculated as
 
the present
value of the future lease payments in the same way
 
as for the lessee.
After
 
commencement
 
date,
 
the
 
Group
 
recognizes
 
finance
 
income
 
over
 
the
 
lease
 
term,
 
based
 
on
 
a
 
pattern
 
reflecting
 
a
 
constant
periodic rate of return on the lessor’s net investment in the lease. The
 
Group also recognizes income from variable payments that are
not included in the net
 
investment in the
 
lease. After lease commencement,
 
the net investment
 
in a lease is not remeasured
 
unless
the lease is modified or the lease term is revised.
Operating leases
The Group continues to recognize
 
the underlying asset and does not recognize a net
 
investment in the lease on the balance sheet or
initial profit (if any) on the income statement.
The Group recognizes
 
lease payments
 
from the lessees as
 
income on a
 
straight-line basis
 
or another systematic
 
basis considered as
appropriate.
 
Also it
 
recognizes
 
costs,
 
including depreciation,
 
incurred in
 
earning the
 
lease income
 
as an
 
expense. The
 
Group
 
adds
initial direct costs incurred in obtaining an operating
 
lease to the carrying amount of the underlying asset and recognizes those costs
as an expense over the lease term on the same basis as the lease income.
Subleases
The Group, acting as a
 
lessee, may enter into arrangements to sublease a
 
leased asset to a third
 
party while the original
 
lease contract
is in effect. The Group acts as both the lessee and lessor of the same underlying asset. The sublease is a separate lease agreement, in
which the intermediate lessor classifies the sublease as a finance lease or an operating
 
lease as follows:
if the head lease is a short-term lease, the sublease is classified as an operating
 
lease; or
otherwise,
 
the
 
sublease
 
is
 
classified
 
by
 
reference
 
to
 
the
 
right-of-use
 
asset
 
arising
 
from
 
the
 
head
 
lease,
 
rather
 
than
 
by
reference to the underlying asset.
 
2.2.16 Insurance and reinsurance contracts
Definition and classification of insurance and reinsurance contracts
IFRS 17 is applicable to insurance contracts, reinsurance contracts and investment contracts with discretionary participation features.
Insurance
 
contracts
 
are
 
contracts
 
under
 
which
 
the
 
Group
 
accepts
 
significant
 
insurance
 
risk
 
from
 
a
 
policyholder
 
by
 
agreeing
 
to
compensate the policyholder if a specified uncertain future event adversely affects the policyholder. The Group only issues insurance
contracts
 
(including unit-linked
 
contracts).
 
In making
 
this assessment,
 
all substantive
 
rights and
 
obligations, including
 
those arising
from law or regulation, are considered
 
on a contract-by-contract basis at
 
the contract issue date.
Insurance contracts
 
are classified as
 
direct participating
 
contracts or contracts
 
without direct participation
 
features. The
 
unit-linked
contracts
 
issued
 
by
 
the
 
Group
 
are
 
classified
 
as
 
direct
 
participating
 
contracts.
 
Such
 
contracts
 
allow
 
policyholders
 
to
 
participate
 
in
investment
 
returns
 
with
 
the
 
Group,
 
in
 
addition
 
to
 
compensation
 
for
 
losses
 
from
 
insured
 
risk.
 
These
 
contracts
 
are
 
substantially
investment service-related contracts where the return on the underlying portfolios of investment assets is shared with policyholders.
The Group
 
also holds
 
reinsurance contracts
 
that transfer
 
significant insurance
 
risk, or
 
are deemed
 
to transfer
 
significant insurance
risk,
 
since
 
they
 
transfer
 
to
 
the
 
reinsurer
 
substantially
 
all
 
the
 
insurance
 
risk
 
relating
 
to
 
the
 
reinsured
 
portions
 
of
 
the
 
underlying
insurance contracts.
Notes to the Consolidated Financial Statements
 
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Insurance
 
contracts
 
issued are
 
aggregated
 
at a
 
portfolio
 
level once
 
they are
 
subject to
 
similar risks
 
and are
 
managed together.
 
In
addition, reinsurance
 
contracts held
 
are grouped
 
into portfolios
 
by taking
 
into consideration
 
the nature
 
of the risk
 
and the
 
type of
reinsurance cover.
At initial recognition,
 
the Group segregates
 
contracts based
 
on when they were
 
issued. An annual cohort
 
contains all contracts
 
that
were issued within a 12-month period. Each annual cohort is then further disaggregated
 
into three groups of contracts: (a)
 
contracts
that are
 
onerous on initial
 
recognition; (b) contracts
 
that, on initial
 
recognition, have
 
no significant possibility
 
of becoming onerous
subsequently; and (c) any remaining contracts
 
in the annual cohort.
The composition of groups established at
 
initial recognition is not subsequently reassessed.
Recognition
The Group recognises groups of insurance contracts that it issues from the earliest of the following: (a) the beginning of the coverage
period
 
of
 
the group
 
of
 
contracts,
 
(b) the
 
date
 
when
 
the first
 
payment
 
from
 
a policyholder
 
in the
 
group
 
is due,
 
or
 
when
 
the
 
first
payment is received if there is no due date,
 
or (c) when the Group determines that a group of contracts
 
becomes onerous.
The Group
 
recognises a group
 
of reinsurance
 
contracts held
 
(a) if the
 
reinsurance contracts
 
provide proportionate
 
coverage, at
 
the
later
 
of the
 
beginning of
 
the coverage
 
period of
 
the group,
 
or the
 
initial recognition
 
of any
 
underlying contract,
 
or (b)
 
in all
 
other
cases, from the beginning of the coverage period
 
of the first contract in the group.
Measurement of insurance contracts issued
The carrying amount of a group
 
of insurance contracts at each reporting date is the
 
sum of the liability for
 
remaining coverage (“LRC”)
and the liability for incurred claims (“LIC”).
The LRC represents
 
the Group’s
 
obligation to
 
investigate
 
and pay
 
valid claims under
 
existing contracts
 
for insured
 
events that
 
have
not yet occurred (i.e. the obligation that
 
relates to the unexpired portion of the coverage
 
period).
The
 
LIC
 
includes
 
the
 
Group’s
 
liability
 
to
 
pay
 
valid
 
claims
 
for
 
insured
 
events
 
that
 
have
 
already
 
incurred,
 
other
 
incurred
 
insurance
expenses arising
 
from past
 
coverage
 
service and
 
the liability
 
for claims
 
incurred but
 
not yet
 
reported.
 
It also
 
includes the
 
Group’s
liability
 
to
 
pay
 
amounts
 
the
 
Group
 
is
 
obliged
 
to
 
pay
 
the
 
policyholder
 
under
 
the
 
contract,
 
including
 
repayment
 
of
 
investment
components, when a contract is derecognised.
Initial and subsequent measurement of contracts under the general
 
measurement model (“GMM”) and the variable fee approach
("VFA”)
Under the GMM
 
and the VFA,
 
the Group measures
 
a group of
 
contracts on
 
initial recognition as
 
the sum of the
 
expected fulfilment
cash flows (’FCF’’) and
 
the contractual service
 
margin (‘’CSM’’) representing
 
the unearned profit in
 
the contracts relating
 
to services
that will be provided
 
under the contracts.
 
The Group applies the
 
GMM approach to
 
its life insurance
 
contracts (except
 
its group life
contracts and other
 
life contracts
 
with coverage period
 
of one year or less) as
 
well as to reinsurance
 
contracts with coverage
 
period
over one year,
 
while the VFA approach is applied to life
 
insurance contracts in the unit-linked
 
portfolio.
FCF comprise
 
unbiased and
 
probability-weighted
 
estimates of
 
future cash
 
flows, an
 
adjustment to
 
reflect the
 
time value
 
of money
and the
 
financial risks
 
related to
 
future cash
 
flows, to
 
the extent
 
that the
 
financial risks
 
are not
 
included in the
 
estimates
 
of future
cash
 
flows,
 
plus
 
a
 
risk
 
adjustment
 
for
 
non-financial
 
risk.
 
The
 
Group
 
estimates
 
FCF
 
considering
 
a
 
range
 
of
 
scenarios
 
which
 
have
commercial substance and give a good representation of possible outcomes, considering all supportable information at the reporting
date
 
including
 
historic
 
evidence
 
and
 
information
 
about
 
trends.
 
The
 
cash
 
flows
 
from
 
each
 
scenario
 
are
 
probability-weighted
 
and
discounted
 
using
 
current
 
assumptions.
 
The
 
Group
 
estimates
 
certain
 
FCF
 
at
 
the
 
portfolio
 
level
 
or
 
higher
 
and
 
then
 
allocates
 
such
estimates to groups of contracts.
At the end of each reporting period, the Group updates the fulfilment cash flows for both LIC
 
and LRC to reflect the current estimates
of the amounts, timing and uncertainty of future cash flows,
 
as well as discount rates and other financial variables.
The Risk Adjustment (“RA”) for non-financial risk for a group of insurance contracts, determined separately from the other estimates,
is the compensation
 
required for
 
bearing uncertainty
 
about the amount
 
and timing of
 
the cash flows
 
that arises from
 
non-financial
risk. The RA also reflects the degree of diversification
 
benefit the Group includes when determining the compensation
 
it requires for
bearing that risk; and both favourable
 
and unfavorable outcomes, in
 
a way that reflects the Group’s
 
degree of risk aversion.
Notes to the Consolidated Financial Statements
 
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The Contractual Service Margin
 
(CSM) is a component of
 
the overall carrying amount
 
of a group of insurance
 
contracts representing
unearned profit the Group will recognise as it provides insurance contract services over the coverage
 
period. On initial recognition of
a group of insurance
 
contracts, if the total
 
of (a) the fulfilment cash flows,
 
(b) any cash flows arising
 
at that date and
 
(c) any amount
arising from
 
the derecognition
 
of any
 
assets or liabilities
 
previously recognised
 
for cash
 
flows related
 
to the group
 
(including assets
for insurance acquisition cash flows) is a net
 
inflow, the CSM is measured
 
as the equal and opposite amount of the net inflow,
 
which
results in
 
no gain
 
no loss,
 
arising on
 
initial recognition.
 
In the
 
case of
 
net outflow,
 
then the
 
group is
 
onerous. In
 
this case,
 
the net
outflow is recognised immediately as
 
a loss in profit or
 
loss. A loss
 
component is created to depict the
 
amount of the net cash
 
outflow,
which determines the amounts
 
that are subsequently
 
presented in profit
 
or loss as reversals
 
of losses on onerous
 
contracts and are
excluded from insurance revenue.
The CSM
 
of a
 
group of
 
insurance contracts
 
is recognised
 
in profit
 
or loss
 
to reflect
 
services provided
 
in each year.
 
Additionally,
 
the
amount of CSM at the end
 
of the reporting period is adjusted in
 
order to reflect the effect
 
of any new contracts
 
added to the group,
changes to
 
fulfilment cash
 
flows relating
 
to future
 
service, the amount
 
recognized as
 
insurance revenue
 
because of
 
the transfer
 
of
services in the period.
For reinsurance contracts held, the CSM amortization reflects
 
the level of service received and depends on the number of underlying
contracts in-force.
Experience
 
adjustments
 
relating
 
to
 
current
 
or
 
past
 
service are
 
recognized
 
in
 
profit
 
or
 
loss
 
as
 
part
 
of
 
insurance
 
service expenses.
Experience adjustments relating to future
 
service are included in the LRC by adjusting the CSM.
Measurement of contracts under the premium allocation approach
 
(PAA)
The premium allocation approach is an optional simplified
 
measurement model in IFRS 17 that is
 
available to insurance contracts that
meet the
 
eligibility criteria.
 
The Group
 
applies the
 
PAA
 
approach
 
to
 
substantially
 
all its
 
non-life
 
insurance
 
contracts,
 
to
 
group
 
life
insurance contracts
 
as well
 
as to
 
individual life
 
contracts
 
and reinsurance
 
contracts
 
with coverage
 
period of
 
one year
 
or less.
 
The
resulting LRC,
 
under the PAA
 
approach, is not
 
discounted to
 
reflect the
 
time value of
 
money and the
 
effect of
 
financial risk since
 
at
initial recognition of each group
 
of contracts, the expected time between providing each
 
part of the services
 
and the related premium
due date in no more than a year.
The
 
carrying
 
amount
 
of
 
the LRC
 
at
 
the
 
end of
 
each reporting
 
period
 
for
 
a group
 
of
 
contracts
 
that
 
is not
 
onerous,
 
represents
 
the
carrying amount
 
at the
 
start of
 
the reporting
 
period, plus
 
premiums received
 
in the
 
period, minus
 
insurance acquisition
 
cash flows
paid
 
in
 
the
 
period,
 
plus
 
any
 
amounts
 
relating
 
to
 
the
 
amortisation
 
of
 
the
 
acquisition
 
cash
 
flows
 
recognised
 
as
 
an
 
expense
 
in
 
the
reporting period, minus the amount recognised as insurance
 
revenue for the services provided in the period.
Applying the
 
PAA,
 
the insurance
 
revenue
 
for
 
the period
 
consists of
 
the amount
 
of expected
 
premium receipts
 
including premium
experience adjustments allocated to
 
the period.
Measurement of reinsurance contracts
 
held
The same accounting policies are applied as for insurance contracts
 
issued to measure a group of reinsurance contracts
 
held.
Insurance contracts – modification and derecognition
The Group derecognises insurance
 
contracts when the rights
 
and obligations relating to
 
the contract are extinguished (i.e.,
 
discharged,
cancelled or expired), or the contract is modified such that the modification results in (a) the contract being outside the scope of IFRS
17,
 
(b)
 
a different
 
insurance
 
contract
 
due to
 
separating
 
components
 
from
 
the host
 
contract,
 
(c) a
 
substantially
 
different
 
contract
boundary, or (d) the contract
 
being included in a different group of contracts.
On derecognition
 
of a
 
contract
 
from within
 
a group
 
of contracts,
 
the fulfilment
 
cash flows
 
allocated
 
to the
 
group are
 
adjusted
 
to
eliminate those that relate
 
to the rights
 
and obligations derecognised, the
 
CSM of the
 
group is adjusted
 
for the change
 
in the fulfilment
cash
 
flows
 
(except
 
where
 
such
 
changes
 
are
 
allocated
 
to
 
a
 
loss
 
component)
 
and
 
the
 
number
 
of
 
coverage
 
units
 
for
 
the
 
expected
remaining services is adjusted to reflect the coverage
 
units derecognised from the group.
When a modification
 
is not treated
 
as derecognition,
 
the Group recognises
 
amounts paid
 
or received for
 
the modification
 
with the
contract as an adjustment to the relevant
 
liability for remaining coverage.
Notes to the Consolidated Financial Statements
 
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Insurance service result
Insurance revenue reflects the consideration to which the Group expects to be entitled in exchange for the provision of coverage and
other services arising from a group of insurance contracts (excluding any investment components). For insurance contracts under the
Premium
 
allocation
 
approach,
 
insurance
 
revenue
 
is
 
based
 
on
 
the
 
expected
 
premium
 
of
 
the
 
period.
 
Insurance
 
service
 
expenses
comprise the incurred
 
claims and other incurred
 
insurance service expenses
 
(excluding any
 
investment components),
 
and losses on
onerous groups of contracts
 
and reversals of such losses.
Insurance finance income or expenses
Insurance finance income and expenses comprise the change in the carrying amount of the group of insurance contracts arising from
the effects of
 
the time value of
 
money,
 
financial risk and changes
 
therein. For VFA
 
contracts, changes
 
in the fair value
 
of underlying
items are recognised in insurance finance income or
 
expenses.
 
2.2.17
 
Income tax
Income tax consists of current and
 
deferred tax.
(i) Current income tax
Income tax payable
 
on profits, based on
 
the applicable tax
 
law in each jurisdiction
 
and the tax rate
 
enacted at the
 
reporting date, is
recognized as an expense in the period in which profits
 
arise.
(ii) Deferred tax
Deferred
 
tax
 
is
 
provided
 
in
 
full,
 
using
 
the
 
liability
 
method,
 
on
 
temporary
 
differences
 
arising
 
between
 
the
 
tax
 
base
 
of
 
assets
 
and
liabilities and their carrying amounts in the consolidated
 
financial statements. Deferred
 
tax assets and liabilities are measured
 
at the
tax rates that are expected to apply to the period when the asset is realized or the liability is
 
settled, based on tax rates (and tax laws)
that
 
have
 
been
 
enacted
 
or
 
substantively
 
enacted
 
by
 
the
 
balance
 
sheet
 
date.
 
The
 
principal
 
temporary
 
differences
 
arise
 
from
impairment/valuation
 
and
 
accounting
 
write-offs
 
relating
 
to
 
loans,
 
Private
 
Sector
 
Initiative
 
(PSI+)
 
tax
 
related
 
losses,
 
losses
 
from
disposals and crystallized write-offs
 
of loans, depreciation of property and equipment, fair value adjustment
 
of investment property,
pension
 
and
 
other
 
retirement
 
benefit
 
obligations,
 
and
 
revaluation
 
of
 
certain
 
financial
 
assets
 
and
 
liabilities,
 
including
 
derivative
financial instruments.
Deferred
 
tax
 
assets
 
are
 
recognized
 
where
 
it
 
is
 
probable
 
that
 
future
 
taxable
 
profit
 
will
 
be
 
available
 
against
 
which
 
the
 
temporary
differences can be utilized.
 
The carrying amount of deferred
 
tax assets is reviewed at
 
each reporting date and reduced
 
to the extent
that it is no longer probable
 
that sufficient taxable
 
profits will be available
 
to allow all or part of the
 
asset to be recovered.
 
Any such
reduction is
 
reversed to
 
the extent
 
that it becomes
 
probable that
 
sufficient taxable
 
profit will be
 
available. The
 
Group recognises
 
a
previously unrecognised deferred tax asset to the extent that it
 
has become probable that future taxable profit will
 
allow the deferred
tax asset to be recovered.
Deferred
 
tax
 
related
 
to
 
debt
 
securities
 
at
 
FVOCI
 
and
 
cash
 
flow
 
hedges
 
is
 
recognized
 
to
 
other
 
comprehensive
 
income,
 
and
 
is
subsequently recognized in the income statement
 
together with the deferred gain
 
or loss.
The deferred
 
tax asset on
 
income tax losses
 
carried forward
 
is recognized as
 
an asset when it
 
is probable that
 
future taxable
 
profits
will be available against which these losses can be utilized.
The Group has
 
applied the mandatory
 
temporary exception
 
(relief) to the requirement
 
of IAS 12 and
 
does not recognise or
 
disclose
information about deferred
 
taxes arising from the Pillar Two
 
Income taxes.
(iii) Uncertain tax positions
The Group determines and assesses all material tax positions taken, including all, if
 
any, significant uncertain positions, in all tax years
that are
 
still subject
 
to assessment
 
(or when
 
the litigation
 
is in
 
progress)
 
by relevant
 
tax authorities.
 
In evaluating
 
tax positions
 
in
various states,
 
local, and foreign
 
jurisdictions, the
 
Group examines
 
all supporting
 
evidence (Ministry of
 
Finance circulars,
 
individual
rulings,
 
case
 
law,
 
past
 
administrative
 
practices,
 
ad
 
hoc
 
tax/legal
 
opinions
 
etc.)
 
to
 
the
 
extent
 
they
 
are
 
applicable
 
to
 
the
 
facts
 
and
circumstances of the particular Group’s
 
case/ transaction.
In addition, judgments concerning
 
the recognition of a provision
 
against the possibility of
 
losing some of the tax
 
positions are highly
dependent on
 
advice received
 
from internal/
 
external legal
 
counselors. For
 
uncertain tax
 
positions with a
 
high level of
 
uncertainty,
Notes to the Consolidated Financial Statements
 
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the Group recognizes, on a transaction by transaction basis, or together as a group, depending
 
on which approach better predicts the
resolution of the uncertainty using an expected value (probability
 
-weighted average) approach: (a)
 
a provision against tax receivable
which has been booked for the amount of
 
income tax already paid but further
 
pursued in courts or (b) a
 
liability for the amount which
is expected to be paid to the tax authorities. The Group presents in its balance sheet all uncertain tax balances as current or deferred
tax assets or liabilities.
The Group as a general
 
rule has opted to obtain
 
for the Group’s
 
Greek companies an ‘Annual
 
Tax
 
Certificate’,
 
which is issued after a
tax audit is performed by the same statutory auditor or audit firm that audits the annual financial statements. Further
 
information in
respect of the Annual
 
Tax
 
Certificate and the
 
related tax
 
legislation, as well as
 
the unaudited tax
 
years for
 
the Group’s
 
companies is
provided in note 13.
2.2.18 Employee benefits
(i) Short term benefits
Short term
 
employee benefits
 
are those
 
expected to
 
be settled wholly
 
before twelve
 
months after
 
the end of
 
the annual reporting
period in which the employees render the related
 
services and are expensed as these services are provided.
(ii) Pension obligations
The Group provides a number
 
of defined contribution pension
 
plans where annual contributions are invested and
 
allocated to specific
asset
 
categories.
 
Eligible
 
employees
 
are
 
entitled
 
to
 
the
 
overall
 
performance
 
of
 
the
 
investment.
 
The
 
Group's
 
contributions
 
are
recognized as employee benefit expense
 
in the year in which they are paid.
 
(iii) Standard legal staff retirement indemnity obligations (SLSRI) and termination
 
benefits
The
 
Group
 
operates
 
unfunded
 
defined
 
benefit
 
plans
 
in
 
Greece
 
and
 
Bulgaria,
 
under
 
broadly
 
similar
 
regulatory
 
frameworks.
 
In
accordance
 
with the
 
local labor
 
legislation, the
 
Group
 
provides for
 
staff
 
retirement
 
indemnity obligation
 
for
 
employees which
 
are
entitled to
 
a lump
 
sum payment
 
based on
 
a) the
 
number of
 
years
 
of service,
 
as of
 
the date
 
when employee
 
service first
 
leads to
benefits under the plan until the date
 
when further employee service will lead to
 
no material amount of further
 
benefits, and b) the
level of remuneration
 
at the date
 
of retirement,
 
if they remain
 
in the employment
 
of the Group
 
until normal retirement
 
age. More
specifically,
 
in line
 
with the
 
decision of
 
IFRIC Committee
 
for
 
IAS 19
 
fact pattern
 
issued in
 
May 2021,
 
the attribution
 
of the
 
benefit
begins from the
 
date when the
 
employee service first
 
leads to benefits
 
under the terms
 
of the plan,
 
and not from
 
the employment
date, until the date when further employee service will lead to no material
 
amount of further benefits.
In
 
addition,
 
the
 
Group
 
provides
 
termination
 
benefits
 
mainly
 
in
 
respect
 
of
 
the
 
Voluntary
 
Exit
 
Schemes
 
(VES),
 
which
 
have
 
been
implemented through
 
either lump-sum payments or
 
long-term leaves during
 
which the employees will be
 
receiving a percentage
 
of
a monthly salary,
 
or a combination thereof.
 
Provision has been made for
 
the actuarial value of the
 
lump sum payable on
 
retirement
(SLSRI)
 
and
 
termination
 
benefits
 
using
 
the
 
projected
 
unit
 
credit
 
method.
 
Under
 
this
 
method
 
the
 
cost
 
of
 
providing
 
retirement
indemnities and termination
 
benefits is charged
 
to the income
 
statement
 
so as to
 
spread the cost
 
over the period
 
of service of
 
the
employees, in accordance with the respective actuarial
 
valuations, which are performed every year.
The SLSRI and termination benefits
 
obligation is calculated
 
as the present value
 
of the estimated future
 
cash outflows using interest
rates of high quality corporate bonds. In countries where there is no deep market in such bonds, the yields on government bonds are
used. The currency
 
and term to
 
maturity of the
 
bonds used are
 
consistent with
 
the currency and
 
estimated term
 
of the retirement
and termination
 
benefit obligations.
 
Actuarial gains
 
and losses
 
that arise
 
in calculating
 
the Group’s
 
SLSRI and
 
termination
 
benefits
obligations are
 
recognized directly
 
in other comprehensive
 
income in the
 
period in which
 
they occur and
 
are not reclassified
 
to the
income statement in subsequent
 
periods.
Interest
 
cost on
 
the staff
 
retirement
 
indemnity and
 
termination
 
benefits
 
obligations,
 
as well
 
as service
 
cost,
 
consisting
 
of current
service cost, past service cost and gains or losses on settlement
 
are recognized in the income statement.
Termination
 
benefits are payable when employment is terminated by the Group before
 
the normal retirement date, or whenever an
employee accepts
 
voluntary redundancy
 
in exchange
 
for these
 
benefits (including
 
those in
 
the context
 
of the VES
 
implemented by
the
 
Group).
 
The
 
Group
 
recognizes
 
termination
 
benefits
 
at
 
the
 
earlier
 
of
 
the
 
following
 
dates:
 
(a)
 
when
 
the
 
Group
 
can
 
no
 
longer
withdraw
 
the
 
offer
 
of
 
those
 
benefits;
 
and
 
(b)
 
when
 
the
 
Group
 
recognizes
 
costs
 
for
 
a
 
restructuring
 
that
 
involves
 
the
 
payment
 
of
termination benefits. Any
 
reversals of the
 
SLRSI obligation arising
 
from employees that
 
are included in the long-term
 
leaves scheme
are accounted
 
for as
 
a curtailment
 
gain recognized
 
in the
 
income statement.
 
In the
 
case of
 
an offer
 
made to
 
encourage voluntary
Notes to the Consolidated Financial Statements
 
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redundancy,
 
the termination
 
benefits are measured
 
based on the
 
number of employees
 
expected to
 
accept the
 
offer.
 
Termination
benefits falling due more than 12 months after
 
the end of the reporting period are discounted to their present
 
value.
(iv) Performance-based cash payments
The Group's Management awards high performing employees with bonuses in cash, from time to time, on a discretionary basis. Cash
payments
 
requiring only
 
Management approval
 
are recognized
 
as employee
 
benefit expenses
 
on an
 
accrual basis.
 
Cash payments
requiring General
 
Meeting approval
 
as distribution of
 
profits to staff
 
are recognized
 
as employee benefit
 
expense in the
 
accounting
period that they are approved by the Group’s
 
shareholders.
(v) Share-based payments
The Group’s Management awards
 
employees with bonuses in the form of shares and share options on a discretionary basis and after
taking into account the current
 
legal framework. Non-performance
 
related shares vest in the
 
period granted. Share based payments
that are contingent upon the achievement
 
of a performance and service condition, vest only if both conditions are
 
satisfied.
The fair value of the share options
 
granted is recognized as an employee benefit expense over the
 
vesting period, with an equal credit
in equity,
 
i.e.no impact on
 
the Group’s
 
equity.
 
The amount
 
ultimately recognised
 
as an expense
 
is based on
 
the number
 
of awards
that meet the related service and non-market
 
performance conditions at the vesting date.
The fair
 
value of the
 
share options
 
at grant
 
date is determined
 
by using an
 
adjusted option
 
pricing model which
 
takes into
 
account
the
 
exercise
 
price,
 
the
 
exercise
 
dates,
 
the
 
term
 
of
 
the
 
option,
 
the
 
share
 
price
 
at
 
grant
 
date
 
and
 
expected
 
price
 
volatility
 
of
 
the
underlying share,
 
the expected
 
dividend yield
 
and the
 
risk-free
 
interest
 
rate
 
for the
 
term of
 
the options.
 
The expected
 
volatility is
measured at the grant date of the options
 
and is based on the historical volatility of the share price.
For share-based
 
payment awards
 
with non-vesting
 
conditions, the fair
 
value of the
 
share-based payment
 
at grant
 
date also reflects
such conditions and there is no true-up for differences
 
between expected and actual outcomes.
When the options
 
are exercised
 
and new shares
 
are issued, the
 
proceeds received
 
net of any
 
directly attributable
 
transaction costs
are credited to share capital
 
(par value) and share premium.
2.2.19 Repossessed properties
Land and buildings repossessed
 
through an auction
 
process to recover
 
impaired loans are,
 
except where
 
otherwise stated, included
in ‘Other Assets’. Assets acquired from an auction process are held temporarily for liquidation and are valued at the lower of cost and
net realizable value, which is the estimated
 
selling price, in the ordinary course of business, less costs necessary
 
to make the sale.
In cases where the Group makes use of repossessed
 
properties as part of its operations, they may be reclassified to
 
own occupied or
investment properties, as appropriate.
Any gains or losses on liquidation are included in the income statement.
2.2.20 Related party transactions
Related parties of the Group include:
(a) an entity
 
that has control
 
over the Group
 
and entities controlled,
 
jointly controlled
 
or significantly influenced
 
by this entity,
as well as members of its key management
 
personnel and their close family members;
(b) an entity that has significant influence over the Group
 
and entities controlled by this entity,
(c) members of key management personnel of the Group, their
 
close family members and entities controlled or jointly controlled
by the abovementioned persons;
(d) associates and joint ventures of the Group;
(e) fellow subsidiaries;
(f) post-employment benefit plans established for the benefit
 
of the Group’s employees.
Transactions
 
of similar
 
nature are
 
disclosed on
 
an aggregate
 
basis. All
 
banking transactions
 
entered into
 
with related
 
parties are
 
in
the normal course of business and are conducted on an arm's length
 
basis.
Notes to the Consolidated Financial Statements
 
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2.2.21 Provisions and contingent liabilities
Provisions are recognized when
 
the Group has a present legal or
 
constructive obligation as a result of past
 
events, it is probable that
an outflow of resources embodying economic benefits will be required
 
to settle the obligation, and reliable estimates
 
of the amount
of the obligation can be made.
The amount recognized as a provision is the best
 
estimate of the expenditure required to settle a present obligation at each reporting
date, taking into account the risks and uncertainties surrounding the amount of such expenditure. Where the effect of the time value
of money is material, the amount of the provision is the present
 
value of the estimated future expenditures
 
expected to be required
to settle the obligation.
Provisions
 
are reviewed
 
at
 
each reporting
 
date
 
and adjusted
 
to
 
reflect
 
the current
 
best
 
estimate.
 
If,
 
subsequently,
 
it is
 
no longer
probable that an outflow
 
of resources embodying economic
 
benefits will be
 
required to settle the
 
obligation, the provision is
 
reversed.
A provision is not
 
recognized and a contingent liability
 
is disclosed when
 
it is not
 
probable that an outflow
 
of resources will be
 
required
to settle the
 
obligation, when the
 
amount of the obligation
 
cannot be measured reliably
 
or in case that
 
the obligation
 
is considered
possible and is subject to the occurrence or non -occurrence of one or more uncertain
 
future events.
2.2.22 Operating segment
An operating
 
segment is
 
a component
 
of the
 
Group that
 
engages in
 
business activities
 
from which
 
it may
 
earn revenue
 
and incur
expenses within
 
a particular
 
economic environment.
 
Operating segments
 
are identified
 
on the
 
basis of
 
internal reports,
 
regarding
operating results, of components of the
 
Group that are regularly reviewed
 
by the chief operating decision maker
 
in order to allocate
resources
 
to the
 
segment
 
and to
 
assess its
 
performance.
 
The chief
 
operating
 
decision maker
 
has been
 
identified
 
as the
 
Strategic
Planning Committee that is
 
responsible for strategic decision making.
 
Segment revenue, segment expenses
 
and segment performance
include
 
transfers
 
between
 
business
 
segments.
 
Such
 
transfers
 
are
 
accounted
 
for
 
at
 
competitive
 
prices
 
in
 
line
 
with
 
charges
 
to
unaffiliated customers
 
for similar services.
2.2.23 Share capital
Ordinary shares and preference
 
shares are classified as equity.
 
Incremental
 
costs directly
 
attributable
 
to the
 
issue of
 
new shares
 
or
options are shown in equity as a deduction from the proceeds, net
 
of tax.
Dividend
 
distribution
 
on
 
shares
 
is
 
recognized
 
as
 
a
 
deduction
 
in
 
the
 
Group’s
 
equity
 
when
 
approved
 
by
 
the
 
General
 
Meeting
 
of
shareholders
 
and the
 
required
 
regulatory
 
approvals,
 
if any,
 
are
 
obtained.
 
Interim
 
dividends are
 
recognized
 
as
 
a deduction
 
in
 
the
Group's equity when approved by the Board
 
of Directors.
Intercompany
 
non-cash
 
distributions
 
that
 
constitute
 
transactions
 
between
 
entities
 
under
 
common
 
control
 
are
 
recorded
 
in
 
the
Group’s equity by reference
 
to the book value of the assets distributed.
Where any Group entity purchases the Company’s equity share capital (treasury shares), the consideration paid including any
 
directly
attributable incremental
 
costs (net
 
of income taxes),
 
is deducted
 
from shareholders’
 
equity until the
 
shares are
 
cancelled, reissued
or disposed of. Where such
 
shares are subsequently sold or reissued, any consideration
 
received is included in shareholders’ equity.
 
2.2.24
 
Financial guarantees and commitments to extend
 
credit
Financial guarantees
Financial guarantee
 
contracts are
 
contracts that
 
require the issuer
 
to make
 
specified payments to
 
reimburse the
 
holder for a
 
loss it
incurs because
 
a specified
 
debtor fails
 
to make
 
payments when
 
due, in
 
accordance with
 
the terms
 
of a
 
debt instrument.
 
Financial
guarantees
 
granted
 
by the
 
Group to
 
financial institutions
 
and other
 
bodies on
 
behalf of
 
customers to
 
secure loans,
 
overdrafts
 
and
other
 
banking
 
facilities,
 
are
 
initially
 
recognized
 
at
 
fair
 
value,
 
being
 
the
 
premium
 
received.
 
Subsequent
 
to
 
initial recognition,
 
such
guarantees are measured
 
at the higher of the amount of
 
the ECL allowance, and the
 
amount initially recognised less any
 
cumulative
amortization of the fee earned, where appropriate.
Financial guarantees purchased
 
by the Group that
 
are considered as integral
 
to the contractual
 
terms of the guaranteed
 
instrument
are not accounted for separately and
 
the cash flows from
 
the guarantee are taken into account
 
in the measurement of
 
the guaranteed
instrument’s expected credit losses, whereas any fees paid or transaction costs incurred for the acquisition of the financial guarantee
are considered as part of the guaranteed
 
asset’s effective interest
 
rate.
Notes to the Consolidated Financial Statements
 
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On the
 
other hand,
 
financial guarantees
 
purchased that
 
are not
 
considered as
 
integral to
 
the contractual
 
terms of
 
the guaranteed
instruments are accounted for separately where a reimbursement asset is recognized and included in Other
 
Assets once is its
 
virtually
certain that, under the terms and conditions of the guarantee, the Group will be reimbursed for the credit loss incurred.
 
The changes
in the carrying
 
amount of the
 
above reimbursement
 
asset arising from
 
financial guarantees,
 
entered into
 
to mitigate
 
the credit risk
of lending exposures measured at amortized
 
cost, are recognized under ‘Impairment
 
losses’ in the Group’s income
 
statement.
Commitments to extend credit
Commitments represent
 
off-balance sheet items
 
where the
 
Group commits,
 
over the
 
duration of
 
the agreement,
 
to provide
 
a loan
with
 
pre-specified
 
terms
 
to
 
the
 
customer.
 
Such
 
contractual
 
commitments
 
represent
 
commitments
 
to
 
extend
 
credit
 
and
 
standby
letters and they are part of the normal lending
 
activities of the Group, for which an ECL allowance is recognised
 
under IFRS 9.
ECL allowance for off-balance sheet exposures
 
(financial guarantees granted and
 
commitments) is included within Other Liabilities.
2.2.25 Non-current assets classified as held for sale and discontinued
 
operations
Non-current
 
assets are
 
classified as
 
held for
 
sale if
 
their carrying
 
amount will
 
be recovered
 
through a
 
sale transaction
 
rather than
through
 
continuing
 
use.
 
For
 
a non
 
-
 
current
 
asset
 
to
 
be classified
 
as
 
held
 
for
 
sale, it
 
is available
 
for
 
immediate
 
sale
 
in
 
its
 
present
condition, subject to terms that are usual and
 
customary for sales of such assets, and the sale is considered
 
to be highly probable. In
such cases, management
 
is committed to
 
the sale and actively markets
 
the property for
 
sale at a price that
 
is reasonable in relation
to the
 
current
 
fair value.
 
The sale
 
is also
 
expected to
 
qualify for
 
recognition
 
as a
 
completed sale
 
within one
 
year from
 
the date
 
of
classification.
 
Before
 
their
 
classification
 
as
 
held
 
for
 
sale,
 
such
 
assets
 
or
 
disposal
 
groups
 
are
 
remeasured
 
in
 
accordance
 
with
 
the
respective accounting standard.
Assets held for sale are subsequently remeasured at the lower of their carrying amount and
 
fair value less cost to sell. Any loss arising
from the above measurement is recorded in
 
profit or loss and can
 
be reversed in the future. When
 
the loss relates to a disposal
 
group,
it
 
is allocated
 
to
 
the assets
 
within that
 
disposal
 
group.
 
Those assets
 
and liabilities
 
that
 
are not
 
in the
 
scope
 
of the
 
measurement
requirements of IFRS 5
 
‘Non-current assets held for
 
sale and discontinued operations’,
 
such as financial instruments and investment
properties measured at fair value, continue to be
 
measured in accordance with the
 
Group’s relevant accounting policies, despite their
classification as held for sale.
The Group presents discontinued
 
operations in a
 
separate line in
 
the consolidated income statement. if
 
a Group entity
 
or a
 
component
of a Group entity has been disposed of or is classified as held for sale and:
(a) Represents a separate
 
major line of business or geographical area of operations;
(b) Is part of a single coordinated plan to dispose of a separate
 
major line of business or geographical area of operations;
 
or
(c) Is a subsidiary acquired exclusively with a view
 
to resale.
Profit or
 
loss from
 
discontinued operations
 
includes the
 
profit or
 
loss before
 
tax from
 
discontinued operations,
 
the gain
 
or loss
 
on
disposal
 
before
 
tax
 
or
 
measurement
 
to
 
fair
 
value
 
less
 
costs
 
to
 
sell
 
and
 
discontinued
 
operations
 
tax
 
expense.
 
Intercompany
transactions
 
between
 
continuing
 
and
 
discontinued
 
operations
 
are
 
presented
 
on
 
a
 
gross
 
basis
 
in
 
the
 
income
 
statement.
 
Upon
classification of a Group entity as a discontinued operation,
 
the Group restates prior periods in
 
the consolidated income statement.
2.2.26 Cash and cash equivalents
Cash and
 
cash equivalents
 
include cash
 
in hand,
 
unrestricted
 
deposits with
 
central
 
banks,
 
due from
 
credit institutions
 
that are
 
all
carried at amortised cost and other short-term highly liquid investments with original maturities of three months or
 
less that are held
for trading.
2.2.27 Government grants
Government grants are recognized when there is reasonable assurance that the grant will
 
be received and the Group will
 
comply with
the conditions
 
attached to
 
it. The
 
grants
 
are recognized
 
in the
 
income statement
 
on a
 
systematic
 
basis to
 
match the
 
way that
 
the
Group
 
recognizes
 
the
 
expenses
 
for
 
which
 
the
 
grants
 
are
 
intended
 
to
 
compensate.
 
In
 
case
 
of
 
subsequent
 
changes
 
in
 
the Group’s
expectations
 
of
 
meeting
 
the
 
conditions
 
attached
 
to
 
the
 
government
 
grants,
 
the
 
effect
 
of
 
such
 
changes
 
is
 
recognised
 
in
 
income
statement.
 
Notes to the Consolidated Financial Statements
 
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2.2.28 Fiduciary activities
The Group provides
 
custody,
 
trustee, corporate
 
administration, investment
 
management and advisory
 
services to third
 
parties that
result in the
 
holding or investing
 
of assets on behalf
 
of its clients. Those
 
assets that are
 
held in a fiduciary
 
capacity are not
 
assets of
the Group and are not recognized
 
in the financial statements. In addition,
 
the Group does not guarantee these investments
 
and as a
result it is not exposed to any credit risk in relation
 
to them.
 
3.
 
Critical accounting estimates and judgments in applying accounting policies
In the process
 
of applying the Group’s
 
accounting policies, Management
 
makes various
 
judgments, estimates and
 
assumptions that
may affect
 
the reported
 
amounts of
 
assets and
 
liabilities, revenues
 
and expenses
 
recognized in
 
the financial
 
statements within
 
the
next financial year
 
and the accompanying
 
disclosures. Estimates and
 
judgments are continually
 
evaluated and
 
are based on current
conditions, historical experience
 
and other factors, including
 
expectations of future
 
events that are believed
 
to be reasonable under
the
 
circumstances.
 
Revisions
 
to
 
estimates
 
are
 
recognized
 
prospectively.
 
The
 
most
 
significant
 
areas
 
in
 
which
 
the
 
Group
 
makes
judgments, estimates and assumptions in applying its accounting
 
policies are set out below:
3.1
 
Impairment losses on loans and advances to customers
The
 
economies
 
in
 
which
 
the
 
Group
 
operates
 
are
 
expected
 
to
 
continue
 
presenting
 
positive
 
growth
 
rates
 
despite
 
the
 
challenging
international
 
environment.
 
In 2024,
 
the Group's
 
asset quality
 
continued
 
its solid
 
performance as
 
demonstrated
 
by the
 
level of
 
its
credit quality indicators in terms of NPE ratio
 
and NPE coverage (note 2).
The Group remains cautious
 
for any developments
 
in the macroeconomic trends
 
and geopolitical front and
 
closely monitors all loan
portfolios, so as to revise, if needed, the respective estimates
 
and assumptions.
Expected Credit Loss (ECL) measurement
The ECL measurement requires
 
Management to apply
 
judgment, in particular,
 
to the estimation of
 
the amount and timing
 
of future
cash flows and collateral values when determining impairment losses and the
 
assessment of a significant increase in credit risk.
 
These
estimates are driven by a number of factors, changes in
 
which can result in significant changes to the
 
timing and amount of allowance
for credit loss to be recognized.
The Group’s ECL calculations are
 
outputs of complex
 
models with a
 
number of underlying
 
assumptions regarding the choice
 
of variable
inputs
 
and
 
their
 
interdependencies.
 
In
 
addition,
 
temporary
 
adjustments
 
may
 
be
 
required
 
to
 
capture
 
new
 
developments
 
and
information available, which are not
 
reflected yet in the ECL calculation through
 
the risk models.
The elements of the ECL models that are considered
 
significant accounting judgments and estimates include:
Determination of a significant increase of credit risk
IFRS 9
 
does not
 
include a definition
 
of what
 
constitutes a
 
significant increase
 
in credit
 
risk (SICR). An
 
assessment of
 
whether credit
risk has increased
 
significantly since initial
 
recognition is performed
 
at each reporting
 
period by considering
 
primarily the change
 
in
the risk of default occurring over the
 
remaining life of the financial instrument. The Group assesses
 
whether a SICR has occurred since
initial
 
recognition
 
based
 
on
 
qualitative
 
and
 
quantitative
 
reasonable
 
and
 
supportable
 
forward-looking
 
information
 
that
 
includes
significant management judgment (note 2.2.13).
Retail lending
For retail
 
lending exposures
 
the primary criterion
 
is the change in
 
the residual cumulative
 
lifetime Probability
 
of Default (PD)
 
above
specified thresholds. These thresholds vary per portfolio,
 
origination year,
 
product type as well as origination PD level.
As at 31 December 2024 and
 
2023, the upper PD thresholds based
 
on the above segmentation,
 
that trigger the allocation to stage
 
2
for Greece’s retail
 
exposures are set out below:
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
41
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Retail exposures
31 December 2024
31 December 2023
Upper SICR threshold
Mortgage
170%
170%
Home Equity
80%
80%
SBB
130%
130%
Consumer
100%
100%
 
Wholesale lending
For wholesale lending exposures, the origination PD curves and the residual lifetime PD curves at each reporting date
 
are mapped to
credit rating
 
bands. Accordingly,
 
SICR thresholds
 
are based
 
on the
 
comparison of
 
the origination
 
and reporting
 
date credit
 
ratings,
whereby rating
 
downgrades represent
 
changes in residual
 
lifetime PD.
 
Similar to retail
 
exposures, the
 
wholesale lending exposures
are segmented based
 
on asset class,
 
loan type and
 
credit rating at
 
origination.
In addition, for
 
securitization notes
 
issued by special
purpose entities established by
 
the Group, the
 
SICR assessment is
 
performed by considering the
 
performance of the
 
underlying assets.
As
 
at
 
31
 
December
 
2024
 
and
 
2023,
 
the
 
credit
 
rating
 
deterioration
 
thresholds
 
per
 
rating
 
bands
 
for
 
Greece’s
 
wholesale
 
lending
exposures that trigger
 
allocation to stage
 
2 are set
 
out below.
 
In addition, any
 
downgrade to rating
 
band 6 or high-risk
 
rating bands
(7,8 or 9) is considered as SICR event to all corporate
 
lending portfolios:
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale internal rating bands
Minimum SICR threshold range
1
Five notches
2
Four notches
3
Three notches
4
Two notches
5-8
One notch
 
Determination of scenarios, scenario weights and macroeconomic factors
To achieve
 
the objective of measuring ECL, the Group evaluates a
 
range of possible outcomes in line with the requirements
 
of IFRS 9
through the
 
application of
 
three macroeconomic
 
scenarios, i.e. baseline,
 
adverse and
 
optimistic, in a
 
way that
 
reflects an
 
unbiased
and probability weighted outcome.
 
The probability weights for
 
the above mentioned scenarios as
 
applied by the Bank, were revised
in the
 
first quarter
 
of 2024
 
in order
 
to appropriately
 
reflect Management’s
 
sentiment regarding
 
future economic
 
conditions in
 
the
form of macroeconomic, market and other factors as embodied
 
in each of the
 
three scenarios. More specifically, the scenario weights
applied in
 
the context
 
of IFRS9
 
ECL measurement
 
for
 
Greek lending
 
portfolios
 
were
 
revised as
 
follows:
 
adverse
 
30% -
 
base 50%
 
-
optimistic 20% (31 December 2023:
 
25%-50%-25%), having an insignificant
 
impact on impairment allowance
 
for loans and advances
to customers.
 
The weight
 
allocation among
 
IFRS9 ECL scenarios
 
as applied by
 
the Group
 
subsidiaries approximates
 
the one applied
by the Bank with the exception of Eurobank Bulgaria AD that applied the following
 
weights: adverse 30% - base 40% - optimistic 30%
considering macroeconomic, market and other
 
country -specific factors.
The baseline scenario for
 
Greek lending portfolios
 
assumed no escalation
 
of the open war
 
fronts, no change
 
in EU sanctions against
Russia, continuation
 
of ECB’s
 
monetary policy trajectory
 
as well as
 
Greek government’s
 
fiscal support
 
measures. Core
 
inflation rate
for
 
Greece
 
was
 
assumed
 
to
 
gradually
 
de-escalate
 
suggesting
 
a
 
moderate
 
economic
 
growth
 
path,
 
employment
 
was
 
assumed
 
to
contribute
 
to
 
lower
 
unemployment
 
path
 
given
 
the
 
capacity
 
constraints
 
stemming
 
from
 
demographic
 
factors,
 
real
 
estate
 
prices
registered
 
signs
 
of
 
slowing
 
down
 
for
 
2024
 
and
 
2025
 
compared
 
to
 
2023 but
 
remained
 
on
 
a positive
 
range
 
and
 
inflation
 
rate
 
was
forecasted to decrease
 
as a result of the ECB monetary
 
policy actions. Additionally,
 
the Greek economy’s short-term
 
prospects were
supported
 
by
 
the:
 
(a)
 
expected
 
strong
 
tourist
 
season,
 
(b)
 
Recovery
 
and
 
Resilience
 
Facility,
 
Multiannual
 
Financial
 
Framework
 
and
European Investment Bank funds, (c) ample liquidity
 
including strong deposit levels and the state cash
 
buffer and (d) fiscal measures
implemented to mitigate the impact of energy
 
costs.
The optimistic
 
and adverse
 
scenarios originated
 
from forecasts
 
that were,
 
respectively,
 
more positive,
 
or more
 
negative
 
regarding
real
 
GDP
 
growth,
 
unemployment
 
rates and
 
real
 
estate
 
prices,
 
in
 
comparison
 
to
 
the
 
baseline
 
scenario. On
 
the
 
other
 
hand,
 
an
environment
 
with lower
 
inflation relative
 
to the
 
baseline is
 
assumed for
 
the adverse
 
scenario in
 
combination with
 
the gradual
 
de-
escalation of
 
interest
 
rates.
 
For the
 
optimistic scenario
 
inflation remained
 
at low
 
levels while
 
growth increased
 
above the
 
baseline
scenario
 
levels.
 
The
 
forecasts
 
for these macroeconomic
 
variables
 
in
 
the
 
adverse/optimistic
 
scenarios
 
of
 
the
 
IFRS9
 
probability-
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
42
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
weighted
 
framework
 
were estimated
 
using a
 
Vector
 
Auto
 
Regression model.
 
This model
 
used historical
 
data
 
on real
 
GDP growth,
inflation, and unemployment rates together
 
with the aforementioned weights for
 
each scenario to generate its forecasts.
Forward-looking information
The Group ensures that impairment
 
estimates and macroeconomic forecasts applicable for business and
 
regulatory purposes are fully
consistent. Accordingly, the IFRS 9 baseline scenario applied in the
 
ECL calculation coincides with the one
 
used for ICAAP and business
planning
 
purposes.
 
In
 
addition,
 
relevant
 
experience
 
gained
 
from
 
the
 
stress
 
tests
 
imposed
 
by
 
the
 
regulator,
 
has
 
been
 
taken
 
into
account
 
in the
 
process of
 
developing
 
the macroeconomic
 
scenarios, as
 
well as
 
impairments for
 
stress testing
 
purposes have
 
been
forecasted in line with IFRS 9 ECL
 
methodology.
In terms of
 
macroeconomic assumptions,
 
the Bank assesses
 
a number of
 
indicators in
 
projecting the risk
 
parameters, namely
 
Gross
Domestic Product (GDP), Unemployment, Residential and
 
Commercial Property Price Indices,
 
inflation as well as
 
interest and FX rates.
The arithmetic averages of the key annual forecasts per macroeconomic
 
scenario for the next four year
 
period following the reporting
date used in the
 
ECL measurement of Greek
 
lending portfolios for the
 
year ended 31
 
December 2024 and
 
2023, are set
 
in the following
table:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key macroconomic
 
indicators
 
31 December 2024
 
Average (2025-2028) annual forecast
31 December 2023
 
Average (2024-2027) annual forecast
Optimistic
Base
 
Adverse
Optimistic
Base
 
Adverse
Gross Domestic Product growth
3.35%
2.15%
0.94%
3.91%
2.05%
0.19%
Unemployment Rate
 
7.04%
8.84%
10.72%
7.60%
9.09%
10.60%
Residential property prices' index
6.39%
4.20%
1.64%
6.14%
3.90%
1.66%
Commercial property prices' index
4.05%
1.84%
-1.18%
5.37%
1.47%
-2.42%
Inflation rate
1.50%
2.15%
1.55%
1.75%
2.10%
2.44%
The table below provides
 
the respective arithmetic averages of
 
the key annual forecasts used in
 
the ECL measurement in
 
the countries
where the Group operates with a significant
 
contribution to the Group ECL:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key macroconomic
 
indicators
 
31 December 2024
 
Average (2025-2028) annual forecast
31 December 2023
 
Average (2024-2027) annual forecast
Optimistic
Base
 
Adverse
Optimistic
Base
 
Adverse
Bulgaria
Gross Domestic Product growth
5.18%
2.70%
0.61%
7.08%
2.44%
-0.69%
Unemployment Rate
 
3.73%
4.57%
5.49%
3.84%
4.86%
5.97%
Residential property prices' index
9.87%
4.60%
1.33%
10.07%
2.92%
-0.31%
Cyprus
Gross Domestic Product growth
3.54%
2.91%
1.51%
3.60%
3.23%
1.35%
Gross fixed capital formation
6.70%
5.18%
2.38%
6.13%
5.50%
1.68%
Real Consumption growth
3.58%
3.08%
1.53%
-
-
-
Unemployment Rate
 
4.48%
5.20%
6.35%
-
-
-
Residential property prices' index
2.60%
1.95%
0.22%
-
-
-
Commercial property prices' index
2.32%
1.66%
0.05%
-
-
-
Inflation rate
1.99%
1.76%
2.86%
-
-
-
 
Note:
 
In
 
2024,
 
Eurobank
 
Cyprus,
 
αs
 
α
 
result
 
of
 
models’
 
recalibration,
 
updated
 
the
 
macroeconomic
 
variables
 
incorporated
 
in
 
ECL
measurement.
Changes in the
 
scenarios and weights,
 
the corresponding
 
set of macroeconomic
 
variables and
 
the assumptions made
 
around those
variables for
 
the forecast
 
horizon would
 
have a significant
 
effect on
 
the ECL amount.
 
The Group independently
 
validates all models
and
 
underlying
 
methodologies
 
used
 
in
 
the
 
ECL
 
measurement
 
through
 
competent
 
resources,
 
who are
 
independent
 
of
 
the
 
model
development process.
Development of ECL models, including the various formulas, choice
 
of inputs and interdependencies
For the purposes
 
of ECL measurement
 
the Group performs
 
the necessary model parameterization
 
based on observed point
 
-in-time
data on
 
a granularity
 
of monthly intervals.
 
The ECL calculations
 
are based
 
on input parameters,
 
i.e. exposure
 
at default
 
(EAD), PDs,
loss
 
given
 
default
 
(LGD),
 
credit
 
conversion
 
factors
 
(CCFs)
 
etc.
 
incorporating
 
Management’s
 
view
 
of
 
the
 
future.
 
The
 
Group
 
also
 
Notes to the Consolidated Financial Statements
 
.
43
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
determines the
 
links between
 
macroeconomic scenarios
 
and, economic inputs,
 
such as unemployment
 
levels and collateral
 
values,
and the effect on PDs, EADs and LGDs.
Furthermore,
 
the
 
PDs
 
incorporate
 
relevant
 
forward
 
looking
 
information
 
including
 
macroeconomic
 
scenarios.
 
The
 
forecasting
 
risk
parameters
 
models
 
incorporate
 
a
 
number
 
of
 
macroeconomic
 
variables,
 
such
 
as
 
GDP,
 
unemployment
 
etc.
 
and
 
portfolio
 
specific
variables such as seasonal flag etc., which are used as independent
 
variables for optimum predictive capability.
 
The
 
ECL
 
models
 
are
 
based
 
on
 
linear
 
and
 
logistic
 
regressions
 
and
 
run
 
under
 
the
 
different
 
macroeconomic
 
scenarios
 
and
 
relevant
changes and shocks in the macro environment
 
are reflected accordingly.
Segmentation of financial assets when their ECL is assessed on a collective
 
basis
The Group segments
 
its exposures on the
 
basis of shared credit
 
risk characteristics
 
upon initial recognition
 
for the purposes
 
of both
assessing significant
 
increase in
 
credit risk
 
and measuring
 
loan loss
 
allowance on
 
a collective
 
basis. The
 
different
 
segments aim
 
to
capture differences
 
in PDs
 
and in the
 
rates of
 
recovery in
 
the event
 
of default.
 
On subsequent
 
periods, the
 
Group re-evaluates
 
the
grouping
 
of
 
its
 
exposures
 
at
 
least
 
on
 
an
 
annual basis,
 
in
 
order
 
to
 
ensure
 
that
 
the groups
 
remain
 
homogeneous
 
in
 
terms
 
of
 
their
response
 
to the
 
identified
 
shared credit
 
risk characteristics.
 
Re-segmentation
 
reflects
 
management’s
 
perception
 
in respect
 
to
 
the
change of credit risk associated with the particular exposures
 
compared to initial recognition.
Modeling and Management overlays / adjustments
A number
 
of sophisticated
 
models have
 
been developed
 
or modified
 
to calculate
 
ECL, while
 
temporary
 
management
 
adjustments
may be required to
 
capture new developments and information
 
available, which are not yet
 
reflected in the ECL calculation
 
through
the risk models.
 
Such adjustments are governed
 
by the Group’s IFRS9
 
ECL Model Adjustments’ framework which
 
aims to ensure
 
timely
identification of non-modeled risks, if
 
any, that
 
may have an impact on
 
lending portfolios, as well as sufficient
 
quantification of such
risks based on sound methodologies and processes.
 
As at 31 December 2024, the Group re-estimated the post model adjustment for
addressing potentially negative macro
 
environment developments
 
in the foreseeable future to € 14 million (2023: € 31 million).
The risk
 
models are
 
governed
 
by the
 
Group’s
 
validation
 
framework
 
which aims
 
to
 
ensure their
 
independent
 
verification.
 
The risk
models as well as the management adjustments, if any, are approved by the Board Risk Committee (BRC) as per the internal approval
processes.
 
Sensitivity analysis on lending portfolios
The sensitivity analysis when performed on certain key parameters can provide meaningful information only for portfolios
 
where the
risk parameters have a significant
 
impact on the overall credit risk of a lending portfolio, particularly where such sensitivities are also
used for internal credit risk management purposes. Otherwise, a sensitivity analysis on certain combinations of some
 
risk parameters
may not produce
 
meaningful results, as
 
in reality there
 
are interdependencies
 
between the various
 
economic inputs, rendering
 
any
changes in the parameters, changes correlated
 
in other factors.
The sensitivity analysis presented
 
in the tables below
 
is applied in the modeled ECL
 
output and assumes a favorable
 
and an adverse
shift
 
in
 
the
 
scenario
 
weighting,
 
compared
 
to
 
the
 
one
 
applied
 
in
 
the
 
ECL
 
measurement.
 
As
 
at
 
31
 
December
 
2024
 
and
 
2023,
 
the
favorable shift assumes an increase in the weighting of the optimistic scenario at 50% and a stable weighting of the baseline scenario
at 50%,
 
while the
 
adverse shift
 
assumes an
 
increase in
 
the weighting
 
of the
 
adverse scenario
 
at 50%
 
and a
 
stable weighting
 
of the
baseline scenario at 50%.
The tables below present the estimated effect in the
 
ECL measurement (including off-balance sheet items) per stage and
 
per
 
country
with significant contribution to the Group ECL
 
,
 
upon a positive and an adverse shift in the scenario weighting
 
as described above :
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
44
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Estimated effect per stage as at 31 December 2024
Positive change
Adverse change
12-month ECL
- Stage 1
Lifetime ECL
- Stage 2
Lifetime ECL
credit-impaired
31 December
2024
12-month ECL
- Stage 1
Lifetime ECL
- Stage 2
Lifetime ECL
credit-impaired
31 December
2024
Greece
 
Ιmpact in € million
(12)
(38)
(20)
(70)
9
30
14
53
 
Ιmpact in % allowance
(8)
(12)
(3)
(7)
6
10
2
5
Bulgaria
 
Ιmpact in € million
(1)
(1)
(2)
(4)
1
1
2
4
 
Ιmpact in % allowance
(4)
(2)
(2)
(2)
4
2
2
2
Cyprus
 
Ιmpact in € million
(2)
(1)
(3)
(6)
2
0
3
5
 
Ιmpact in % allowance
(13)
(6)
(4)
(5)
12
5
3
5
Total
 
Ιmpact in € million
(15)
(40)
(25)
(80)
12
31
19
62
 
Ιmpact in % allowance
(7)
(11)
(3)
(6)
6
9
2
5
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Estimated effect per stage as at 31 December 2023
Positive change
Adverse change
12-month ECL
- Stage 1
Lifetime ECL
- Stage 2
Lifetime ECL
credit-impaired
31 December
2023
12-month ECL
- Stage 1
Lifetime ECL
- Stage 2
Lifetime ECL
credit-impaired
31 December
2023
Greece
 
Ιmpact in € million
(12)
(24)
(17)
(53)
11
30
17
58
 
Ιmpact in % allowance
(9)
(9)
(3)
(5)
8
10
3
6
Bulgaria
 
Ιmpact in € million
(1)
(1)
(2)
(4)
2
1
2
5
 
Ιmpact in % allowance
(4)
(2)
(2)
(2)
4
2
2
2
Cyprus
 
Ιmpact in € million
(3)
(2)
(2)
(7)
3
2
2
7
 
Ιmpact in % allowance
(38)
(32)
(4)
(13)
41
33
4
13
Total
 
Ιmpact in € million
(16)
(27)
(21)
(64)
16
33
21
70
 
Ιmpact in % allowance
(9)
(8)
(3)
(5)
8
10
3
5
 
Note
 
:
Figures as at 31 December 2023 for Cyprus refer to Eurobank Cyprus.
The
 
Group
 
updates
 
and
 
reviews
 
the
 
reasonability
 
and
 
performs
 
back-testing
 
of
 
the
 
main
 
assumptions
 
used
 
in
 
its
 
methodology
assessment for SICR
 
and ECL measurement,
 
at least on an
 
annual basis or earlier,
 
based on facts and
 
circumstances. In this
 
context,
experienced and dedicated staff within the
 
Group’s Risk Management function monitor the
 
risk parameters applied for the
 
estimation
of ECL. Furthermore, as part of the well-defined governance framework,
 
any revisions to the methodology used are approved by the
Group competent committees and
 
ultimately the Board Risk Committee (BRC).
3.2
 
Fair value of financial instruments
The fair
 
value of financial
 
instruments is
 
the price that
 
would be received
 
to sell an
 
asset or paid
 
to transfer
 
a liability in
 
an orderly
transaction
 
between market
 
participants in
 
the principal
 
(or most
 
advantageous)
 
market
 
at the
 
measurement
 
date
 
under current
market
 
conditions
 
(i.e. an
 
exit price)
 
regardless
 
of whether
 
that
 
price is
 
directly
 
observable
 
or estimated
 
using another
 
valuation
technique.
The fair
 
value of
 
financial instruments
 
that are
 
not quoted
 
in an
 
active market
 
is determined
 
by using
 
other valuation
 
techniques
including the use of valuation models. In addition, for financial instruments that trade infrequently and have little price transparency,
fair
 
value
 
is less
 
objective
 
and
 
requires
 
varying
 
degree
 
of
 
judgment
 
depending
 
on
 
liquidity,
 
concentration,
 
uncertainty
 
of market
factors,
 
pricing
 
assumptions
 
and
 
other
 
risks
 
affecting
 
the
 
specific
 
instrument.
 
In
 
these
 
cases,
 
the
 
fair
 
values
 
are
 
estimated
 
from
observable data in respect of similar financial instruments
 
or using other valuation techniques.
The valuation models used include
 
present value methods and other models based
 
mainly on observable inputs and
 
to a lesser extent
to non-observable inputs, in order to maintain
 
the reliability of the fair value measurement.
Notes to the Consolidated Financial Statements
 
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Where valuation models are
 
used to determine the fair
 
values of financial instruments that
 
are not quoted in an active market,
 
they
are
 
validated
 
and
 
periodically
 
reviewed
 
by
 
qualified
 
personnel
 
independent
 
of
 
the
 
personnel
 
that
 
created
 
them.
 
All
 
models
 
are
certified before they are used and are calibrated
 
to ensure that outputs reflect actual data and comparative
 
market prices. The main
assumptions and estimates, considered by
 
management when applying a valuation model include:
the likelihood and expected timing of future
 
cash flows;
the selection of the appropriate discount
 
rate, which is based on
 
an assessment of what a market
 
participant would regard
as an appropriate spread of the rate
 
over the risk-free rate;
 
and
judgment to determine what model to use in order
 
to calculate fair value.
To the extent practicable, models use only observable
 
data, however areas such as
 
credit risk (both own
 
and counterparty), volatilities
and correlations require Management to
 
make estimates to reflect uncertainties
 
in fair values resulting from the lack of market
 
data
inputs. Inputs into
 
valuations based on
 
unobservable data are
 
inherently uncertain
 
because there is little
 
or no current market
 
data
available. However,
 
in most
 
cases there
 
will be
 
some historical
 
data on
 
which to
 
base a
 
fair value
 
measurement and
 
consequently
even when unobservable inputs are used, fair values
 
will use some market observable inputs.
Information in respect of the fair valuation
 
of the Group’s financial assets and liabilities
 
is provided in note 5.3.
3.3
 
Classification of financial instruments
The Group applies significant judgment in assessing the classification
 
of its financial instruments and especially, in
 
the below areas:
Business model assessment
Judgment is exercised
 
in order
 
to determine
 
the appropriate
 
level at which
 
to assess the
 
business model. In
 
assessing the business
model of financial instruments, these are aggregated into groups (business lines) based on their characteristics, and the way they are
managed in order
 
to achieve the
 
Group’s
 
business objectives. In
 
general, the
 
assessment is performed
 
for lending exposures
 
at the
level
 
of
 
business
 
units
 
that
 
manage
 
the
 
respective
 
portfolio,
 
including
 
securitization
 
notes
 
issued
 
by
 
special
 
purpose
 
entities
established by the Group
 
and at the level of the measurement
 
category for debt
 
securities. However,
 
further disaggregation may be
performed by business strategy
 
or region.
In assessing the business model for financial
 
instruments, the Group performs a past sales evaluation of the
 
financial instruments and
assesses their expected evolution in the future. Judgment is
 
exercised in determining the effect of sales to a “hold
 
to collect” business
model depending on their objective and their acceptable level and frequency.
Contractual cash flow characteristics test
 
(SPPI test)
The
 
Group
 
performs
 
the
 
SPPI
 
assessment
 
of
 
lending
 
exposures
 
and
 
debt
 
securities
 
by
 
considering
 
all
 
the
 
features
 
which
 
might
potentially lead to SPPI failure. The above assessment may be
 
particularly challenging for more complex instruments with contractual
terms including leverage, prepayment
 
or extension options, securitizations
 
where the cash flows are linked
 
to the underlying assets,
non-recourse
 
arrangements,
 
as
 
well
 
as
 
environmental,
 
social
 
and
 
governance
 
linked
 
features
 
(sustainability
 
linked).
 
Judgment
 
is
applied by the responsible business
 
units when considering whether
 
certain contractual features significantly affect future cash flows,
are de-minimis or not genuine.
 
Accordingly, for
 
non-recourse financial assets, the Group assesses jointly criteria such as the adequacy of equity,
 
LTV (Loan-to-Value)
and DSCR (Debt-Service-Coverage
 
-Ratio) ratios
 
as well as the
 
existence of corporate
 
and personal guarantees.
 
For the securitization
notes
 
issued
 
by
 
special
 
purpose
 
entities,
 
either
 
established
 
by
 
the
 
Group
 
or
 
third
 
parties,
 
and
 
held
 
by
 
the
 
Group,
 
the
 
cash
 
flow
characteristics of the notes
 
and the underlying
 
pool of financial
 
assets as well
 
as the credit
 
risk inherent in
 
each securitization’s tranche
compared to
 
the credit
 
risk of all
 
of the underlying
 
pool of
 
financial assets,
 
are assessed.
 
Furthermore, in
 
order to
 
assess whether
any
 
variability
 
in
 
the
 
cash
 
flows
 
is
 
introduced
 
by
 
the
 
modified
 
time
 
value
 
of
 
money
 
element,
 
the
 
Group
 
performs
 
a
 
quantitative
assessment (as described
 
in note 2.2.9). For
 
the SPPI assessment
 
of sustainability linked
 
instruments that include
 
features that
 
may
change the contractual
 
cash flows, by
 
reducing or increasing
 
the interest rate
 
depending on whether the
 
borrower meets or
 
fails to
meet predetermined
 
ESG targets,
 
the Group
 
considers whether
 
such targets
 
are referenced
 
to an
 
index that
 
is not
 
specific to
 
the
borrower,
 
as
 
well
 
as
 
whether
 
the
 
related
 
contractual
 
cash
 
flows’
 
change
 
introduces
 
compensation
 
for
 
non-basic
 
lending
 
risks
(information about the Group’s
 
exposure in sustainability linked
 
instruments is provided in note 20). Moreover,
 
the Group evaluates
certain cases on whether the existence of performance-related
 
terms exposes the Group to asset risk rather to the borrower's credit
risk.
Notes to the Consolidated Financial Statements
 
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The Group has established a robust framework to perform the necessary assessments in accordance with Group’s
 
policies in order to
ensure
 
appropriate
 
classification
 
of
 
financial
 
instruments,
 
including
 
reviews
 
by
 
experienced
 
staff
 
for
 
lending
 
exposures
 
and
 
debt
securities.
3.4
 
Assess control over investees
Management exercises
 
judgment in
 
order to
 
assess if the
 
Group has control
 
over another
 
entity based on
 
the control
 
elements set
out in note 2.2.1 (i).
In particular, as part of its
 
funding activity and
 
non-performing loans’ management strategy, the Group sponsors certain securitization
vehicles, the relevant
 
activities of which have
 
been predetermined as part of
 
their initial design by the Group.
 
The Group is exposed
to variability of returns
 
from these vehicles
 
through the holding of
 
debt securities issued
 
by them or
 
by providing credit enhancements
in accordance with the respective contractual terms. In assessing whether it
 
has control, the Group considers whether it manages the
substantive decisions that could
 
affect these vehicles’ returns. Accordingly,
 
the Group assesses on a case-by-case basis the structure
of securitization transaction, including the respective
 
contractual arrangements, in order
 
to conclude if it controls these vehicles.
In
 
addition,
 
the
 
Group
 
is
 
involved
 
in
 
the
 
initial
 
design
 
of
 
various
 
mutual
 
funds
 
in
 
order
 
to
 
provide
 
customers
 
with
 
investment
opportunities. The
 
Group primarily
 
acts as
 
an agent
 
in exercising
 
its decision
 
making authority
 
as it
 
is predefined
 
by the
 
applicable
regulated framework.
 
As a result, the Group has concluded that it does not control
 
these funds.
Further information in respect of the structured
 
entities the Group is involved, either consolidated
 
or not, is provided in note 25.
3.5
 
Income tax
The Group is subject to income taxes
 
in various jurisdictions and estimates are required
 
in determining the liability for income taxes.
The Group
 
recognizes
 
liabilities
 
for
 
anticipated
 
tax
 
audit issues
 
based on
 
estimates
 
of whether
 
additional taxes
 
will be
 
due or
 
for
anticipated
 
tax disputes.
 
Where the
 
final tax
 
outcome of
 
these matters
 
is different
 
from the
 
amounts that
 
were initially
 
recorded,
such differences will impact the income tax and deferred
 
tax in the period in which such determination is made. Further information
in relation to the above is provided in
 
note 13.
In addition,
 
the Group
 
recognizes deferred
 
tax assets
 
to the
 
extent that
 
it is probable
 
that sufficient
 
taxable profit
 
will be
 
available
against
 
which
 
unused
 
tax
 
losses
 
and
 
deductible
 
temporary
 
differences
 
can
 
be
 
utilized.
 
Recognition
 
therefore
 
involves
 
judgment
regarding the
 
future financial performance
 
of the particular Group
 
legal entity in which
 
the deferred tax
 
asset has been recognized.
 
Particularly,
 
in order to determine the amount of deferred
 
tax assets that can be recognized,
 
significant management judgments are
required regarding the likely timing
 
and level of
 
future taxable profits. In
 
making this evaluation,
 
the Group has
 
considered all available
evidence, including management’s projections
 
of future taxable income and the tax legislation
 
in each jurisdiction.
The most significant judgment exercised by Management relates to the recognition of deferred tax assets in respect of losses realized
in Greece. In the event that, the Group assesses that it
 
would not be able to recover any portion of
 
the recognized deferred tax assets
in the future, the unrecoverable portion
 
would impact the deferred tax balances in the period in which
 
such judgment is made.
Further
 
information
 
in
 
respect
 
of
 
the
 
deferred
 
tax
 
assets
 
recognized
 
by
 
the
 
Group
 
and the
 
assessment
 
for
 
their recoverability
 
is
provided in note 13.
3.6
 
Retirement and termination benefit obligations
The present value of the retirement and termination benefits’ obligations depends on a number of factors that are determined on an
actuarial basis using a
 
number of assumptions, such as
 
the discount rate and future salary
 
increases. Any change in these
 
assumptions
impacts the carrying amount of the respective benefits’ obligations.
The Group determines the appropriate discount rate used to calculate the present value of
 
the estimated retirement and termination
benefits’ obligations,
 
at the
 
end of
 
each year
 
with reference
 
to interest
 
rates
 
of high-quality
 
corporate
 
bonds. In
 
countries where
there is no
 
deep market
 
in such bonds,
 
the yields on
 
government bonds
 
are used.
 
The currency and
 
term to
 
maturity of
 
the bonds
used are consistent
 
with the currency and estimated
 
average term to
 
maturity of the retirement
 
benefit obligations. The
 
salary rate
increase
 
assumption
 
is
 
based
 
on
 
future
 
inflation
 
estimates
 
reflecting
 
also
 
the
 
Group's
 
reward
 
structure
 
and
 
expected
 
market
conditions.
Other
 
assumptions
 
for
 
retirement
 
and
 
termination
 
benefits’
 
obligations,
 
such
 
as
 
future
 
inflation
 
estimates,
 
are
 
based
 
in
 
part
 
on
current and expected market
 
conditions.
Notes to the Consolidated Financial Statements
 
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For information
 
in respect
 
of the
 
sensitivity analysis
 
of the
 
Group’s
 
retirement
 
and termination
 
benefits’ obligations
 
to reasonably
possible, at the
 
time of preparation
 
of these financial
 
statements,
 
changes in the
 
abovementioned key
 
actuarial assumptions, refer
to note 36.
3.7
 
Investment properties
Investment
 
property is
 
carried at
 
fair value,
 
as determined
 
by external,
 
independent and
 
certified valuators
 
on an
 
annual basis,
 
or
more frequently
 
if deemed
 
appropriate
 
upon assessment
 
of any
 
relevant
 
circumstances.
 
The primary
 
valuation method
 
applied in
determining the fair
 
value of the Group’s
 
investment properties
 
is the Discounted
 
Cash Flow (DCF) method
 
which is considered
 
the
most appropriate
 
in cases of income generating
 
assets. This method is
 
based on discounting the
 
net future cash flows
 
generated by
a property over the assumed holding period, by using an appropriate
 
market derived discount rate.
Accordingly,
 
the main factors underlying the determination
 
of fair value under the DCF method, are related
 
with rental income from
current leases and assumptions
 
about its future
 
growth in the light
 
of current market conditions, including
 
CPI indexation that is based
on CPI predictions for the
 
next 10 years, as well
 
as exit yields that
 
are determined based on each
 
property’s characteristics/use, future
prospects of the
 
economy and property
 
market in general
 
as forecasted
 
by the IMF or
 
other internationally recognized
 
institutions.
In addition, potential legal or other restrictions on the
 
aforementioned rental income levels are taken into account, where applicable.
The present value of each property
 
is derived by discounting the above projected
 
net cash flows series with an appropriate,
 
market-
derived
 
discount.
 
Such
 
discount
 
rate
 
is
 
calculated
 
by
 
taking
 
into
 
consideration
 
the
 
initial
 
yield
 
of
 
the
 
investment
 
property,
 
the
expected return, the real rental
 
growth and annual obsolescence of the property.
Other assumptions incorporated in the valuations include
 
future vacancy rates and periods, the
 
level of future maintenance and
 
other
operating costs, as well as sustainability
 
issues, where applicable.
Where
 
the
 
fair
 
value
 
is
 
determined
 
based
 
on
 
market
 
prices
 
of
 
comparable
 
transactions
 
those
 
prices
 
are
 
subject
 
to
 
appropriate
adjustments,
 
in
 
order
 
to
 
reflect
 
current
 
economic
 
conditions
 
and
 
Management’s
 
best
 
estimate
 
regarding
 
the
 
future
 
trend
 
of
properties market based on advice received from
 
its independent external valuers.
Further information in respect of the fair valuation
 
of the Group’s investment
 
properties is provided in note 27.
3.8
 
Provisions and contingent liabilities
Considering the
 
subjectivity and
 
uncertainty
 
inherent
 
in the
 
determination
 
of the
 
probability and
 
amount of
 
the abovementioned
outflows, the Group takes into account
 
a number of factors including primarily legal advice, the progress of the matter
 
and historical
evidence from
 
similar cases.
 
In the
 
case of
 
an offer
 
made within
 
the context
 
of the
 
Group’s
 
voluntary
 
exit scheme,
 
the number
 
of
employees expected to accept the
 
abovementioned offer along with their
 
age cluster is a
 
significant factor affecting the measurement
of the outflow for the termination benefits.
 
Further information in relation to
 
the Group’s provisions
 
and contingent liabilities is provided in notes 35 and 42.
3.9
 
Share-based payments
The Group
 
grants shares
 
and share
 
options to
 
its employees
 
as a
 
common feature
 
of employee
 
remuneration.
 
IFRS 2
 
requires the
recognition of
 
an expense for
 
those shares
 
and share options
 
at their
 
fair value
 
on the grant
 
date (equity-settled
 
plans). For shares
granted to employees, the fair value is measured directly
 
at the market price of the entity’s shares, adjusted
 
to take into account the
terms and conditions upon which the shares were granted. For share options
 
granted to employees, in many cases market
 
prices are
not available because the options granted
 
are subject to terms and conditions that do not apply to
 
traded options. If this is the case,
the Group estimates
 
the fair value of the
 
equity instruments granted
 
using a valuation technique,
 
which is consistent with
 
generally
accepted valuation methodologies.
The valuation
 
method and the
 
inputs used to
 
measure the share
 
options granted
 
to employees of
 
the Group are
 
presented in
 
note
39.
3.10
 
Leases
The Group, as a lessee, determines the lease term as the non-cancellable term of the
 
lease, together with any periods covered by
 
an
option to extend
 
the lease if it is
 
reasonably certain to
 
be exercised,
 
or any periods covered
 
by an option to
 
terminate the lease if
 
it
is reasonably certain not to be exercised.
 
Notes to the Consolidated Financial Statements
 
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The Group
 
applies judgement
 
in evaluating
 
whether it is
 
reasonably certain
 
or not to
 
exercise an
 
option to
 
renew or
 
terminate the
lease, by
 
considering all
 
relevant
 
factors
 
and economic
 
aspects that
 
create an
 
economic incentive.
 
The Group
 
reassesses the
 
lease
term if
 
there is
 
a significant
 
event or
 
change in
 
circumstances
 
that is
 
within its
 
control
 
that affects
 
its ability
 
to exercise
 
or not
 
to
exercise the
 
option to
 
renew or to
 
terminate, such
 
as significant leasehold
 
improvements or
 
significant customization
 
of the leased
asset.
In measuring
 
lease liabilities,
 
the Group
 
uses the
 
lessees’ incremental
 
borrowing
 
rate
 
(‘IBR’) when
 
it cannot
 
readily determine
 
the
interest rate implicit in the
 
lease. The IBR is the rate of interest
 
that the Group would have to
 
pay to borrow over a similar
 
term, and
with
 
a
 
similar
 
security,
 
the
 
funds
 
necessary
 
to
 
obtain
 
an
 
asset
 
of
 
a
 
similar
 
value
 
to
 
the
 
right-of-use
 
asset
 
in
 
a
 
similar
 
economic
environment.
Therefore,
 
estimation is
 
required when
 
no observable
 
rates are
 
available (such
 
as for
 
subsidiaries that
 
do not
 
enter into
 
financing
transactions) or when
 
they need to
 
be adjusted to
 
reflect the terms
 
and conditions of
 
the lease. The Group
 
estimates the IBR
 
using
observable inputs (such as government bond yields)
 
as a starting point when available, and
 
performs certain additional entity-specific
adjustments,
 
such as
 
credit spread
 
adjustments
 
or adjustments
 
to reflect
 
the lease
 
terms and
 
conditions. For
 
the Bank
 
and Greek
subsidiaries,
 
the
 
IBR
 
is
 
derived
 
from
 
the
 
estimated
 
covered
 
bonds
 
yield
 
curve,
 
which
 
is
 
constructed
 
based
 
on
 
observable
 
Greek
Government
 
Bond
 
yields,
 
while
 
for
 
international
 
subsidiaries
 
the
 
IBR
 
is
 
determined
 
on
 
a
 
country
 
basis,
 
taking
 
into
 
consideration
specific local conditions.
3.11
 
Insurance contracts
The measurement of
 
insurance contract liabilities involves the
 
exercise of judgment, estimates, and
 
assumptions, especially in
 
relation
to mortality
 
and morbidity
 
rates,
 
claims, lapse
 
and surrender
 
rates,
 
and costs.
 
The basic
 
approaches
 
used in
 
the measurement
 
of
insurance contract liabilities are described in Note 2.2.16. Additionally,
 
the following assumptions were used when estimating future
cash flows:
Mortality and morbidity rates
:
The
 
Group
 
reviews,
 
at
 
least
 
on
 
an
 
annual
 
basis,
 
the
 
validity
 
of
 
the
 
mortality
 
assumptions,
 
and
 
when
 
deemed
 
necessary
 
the
assumptions
 
are
 
adjusted
 
accordingly.
 
The
 
assumptions
 
are
 
set
 
based
 
on
 
the
 
internal
 
experience
 
of
 
the
 
Group
 
when
 
there
 
are
sufficient volumes or data to support a credible investigation. When internal experience is not sufficient the assumptions are set with
reference to industry experience
 
and commonly used tables.
Expenses
:
The Group applies judgement
 
in assessing whether cash
 
flows are directly attributable
 
to a specific portfolio
 
of insurance contracts.
The
 
Group
 
considers
 
as
 
attributable
 
cash
 
flows
 
fixed
 
and
 
variable
 
overheads
 
directly
 
attributable
 
to
 
the
 
fulfilment
 
of
 
insurance
contracts. The Group also reviews,
 
at least on an annual basis, the expense assumptions used in the cashflow projections.
Lapse and surrender rates
:
Lapse and surrenders assumptions relate
 
to the rate by which policyholders cancel/surrender
 
their policies. The assumptions are set
in line with recent Group experience, by adjusting
 
for expected improvements/deteriorations
 
where necessary.
Discount rates
Long term life insurance
 
contract liabilities are
 
calculated by discounting
 
expected future cash flows.
 
The Group uses the bottom-up
approach in determining the discount rates and hence
 
uses a risk-free rate, plus an illiquidity premium.
 
Risk free rates are determined
by reference to the European Insurance and
 
Occupational Pensions Authority (EIOPA) yields and the
 
illiquidity premium is determined
using EIOPA’s
 
volatility adjustment.
Risk adjustments for non-financial risk
The risk adjustment for non-financial risk is determined to reflect the
 
compensation that the Group requires for bearing non-financial
risk and its
 
degree of risk
 
aversion. The
 
risk adjustment
 
is determined using
 
a confidence level
 
technique and
 
specifically the scalar
approach method with its target confidence level
 
set at 80 percent which represents
 
the Group’s degree of risk
 
aversion.
3.12
 
Other accounting estimates and judgments
Information in respect of other estimates
 
and judgments that are made by the Group is provided
 
in notes 20, 23.2, 24, 28 and 30.
.
 
 
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Notes to the Consolidated Financial Statements
 
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4.
 
Capital Management
The Group’s capital
 
adequacy position is presented in the following table:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December
2024
31 December
2023
€ million
€ million
Equity attributable to shareholders
 
of the Company
8,899
7,899
Less: Goodwill
(42)
(44)
Less: Other regulatory adjustments
(465)
(507)
Common Equity Tier 1 Capital
8,392
7,348
Total Tier 1 Capital
8,392
7,348
Tier 2 capital-subordinated debt
1,201
1,074
Add: Other regulatory adjustments
174
-
Total Regulatory
 
Capital
9,767
8,422
Risk Weighted Assets
49,977
43,395
Ratios:
%
%
Common Equity Tier 1
 
16.8
16.9
Pro-forma Common Equity Tier 1⁽¹⁾
15.7
17.0
Total
 
Capital Adequacy Ratio
 
19.5
19.4
Pro-forma Total
 
Capital Adequacy Ratio⁽¹⁾
18.5
20.2
 
(1)
 
As of
 
31 December
 
2024, pro-forma
 
with the
 
completion of
 
the project
 
“Solar” (note
 
20), projects
 
“Leon” and
 
“Wave
 
VI” that
 
significant risk
 
transfer
recognition is subject to ECB’s
 
confirmation (note 20), as well
 
as with the accrual for
 
dividend distribution from financial year 2024
 
Group profits, (subject to
regulatory approval).
 
As of
 
31 December
 
2023, pro-forma
 
with the
 
completion of
 
the projects
 
“Solar”,
 
“Leon” and
 
the impact
 
from the
 
completion of
 
the
issuance of Subordinated Tier II debt instruments in January 2024.
 
Notes:
 
a) The profit of € 1,448 million attributable to the shareholders of the Company for the period ended 31 December 2024 (31 December 2023: profit of € 1,140
million) has been included in the calculation of the above capital ratios.
b) As of 31
 
December 2024, the decrease
 
in CET1 ratio, compared
 
to 31 December
 
2023, is mainly attributed
 
to the increase
 
of the RWAs
 
mainly due to the
inclusion of Hellenic Bank and its subsidiaries in
 
the Company’s consolidated financial statements
 
in 2024 and the new production of
 
loans, partly offset by i)
the Group’s organic profitability, ii)
 
the change in
 
the mapping, following
 
the publication of
 
the Commission Implementing
 
Regulation (EU) 2024/1872,
 
between
corporate credit ratings and
 
respective risk weighting factors (Credit
 
Quality Steps), set out in
 
Regulation EU 575/2013 and
 
iii) the change of
 
the applicable Risk
Weighting Factors (RWF) for Central Bank/Central Government assets, according to article 244 (applicable from 1 July 2024) of Regulation 2024/1623/EU.
c) Deferred
 
tax credits
 
(DTC) stand
 
at 36%
 
of CET
 
1 capital
 
(note 13).
 
In line
 
with the
 
Bank's initiative
 
to enhance
 
the quality
 
of its
 
regulatory capital,
 
the
amortisation of DTC will be accelerated for regulatory purposes starting from 2025, aiming at its elimination by 2033.
The Group
 
has sought
 
to
 
maintain
 
an actively
 
managed
 
capital
 
base to
 
cover
 
risks
 
inherent
 
in the
 
business.
 
The adequacy
 
of the
Group's
 
capital
 
is
 
monitored
 
using, among
 
other
 
measures,
 
the
 
rules
 
and
 
ratios
 
established
 
by
 
the
 
Basel
 
Committee
 
on
 
Banking
Supervision (BIS rules/ratios) which have been incorporated in the European Union (EU)
 
legislation through the Directive 2013/36/EU
(known
 
as
 
CRD
 
IV)
 
along
 
with
 
the
 
Regulation
 
575/2013/EU
 
(known
 
as
 
CRR),
 
as
 
they
 
are
 
in
 
force.
 
The
 
above
 
Directive
 
has
 
been
transposed into Greek legislation by Law 4261/2014, as in force. Furthermore, the CRR as amended by the Regulation 2020/873 (CRR
quick fix) provides, among others, for the extension by two years of the ability of the
 
banks to add back to their regulatory capital any
increase in provisions
 
for (stage
 
1 and stage
 
2) expected losses
 
compared to those
 
that they have
 
recognized on
 
1 January 2020 for
their financial assets, which have not been defaulted.
 
The relief which is applicable for 2024 is 25%.
On 19 June
 
2024, Regulation
 
2024/1623/EU and Directive
 
2024/1619/EU of the
 
European Parliament
 
and of the
 
Council of 31
 
May
2024,
 
amending
 
Regulation
 
575/2013/EU
 
and
 
Directive
 
2013/36/EU,
 
respectively,
 
were
 
published
 
in
 
the Official
 
Journal
 
of
 
the
European Union. The revised CRR
 
(CRR3) will, in general, become
 
applicable from 1 January 2025,
 
with a transitional period envisaged
for certain rules set
 
out therein. EU member states
 
will need to transpose
 
the revised CRDIV (CRD6)
 
into national law,
 
to be applied
from 11
 
January
 
2026.
 
In
 
addition,
 
following
 
its
 
publication
 
in
 
the
 
Official
 
Journal
 
of
 
the
 
European
 
Union,
 
the
 
Commission
Implementing Regulation (EU) 2024/1872 of 1 July 2024, amended the implementing
 
technical standards laid down in Implementing
Regulation
 
(EU)
 
2016/1799 as
 
regards
 
the mapping
 
tables
 
specifying the
 
correspondence
 
between
 
the
 
credit
 
risk
 
assessments
 
of
external credit assessment institutions and
 
the credit quality steps
 
set out in
 
Regulation (EU) No 575/2013
 
of the European Parliament
and of the Council.
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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Supplementary to the above, in the context of Internal Capital Adequacy Assessment Process (ICAAP), the Group considers a broader
range of risk types
 
and the Group’s risk management capabilities.
 
ICAAP aims ultimately to
 
ensure that the Group
 
has sufficient capital
to cover all material risks that it is exposed
 
to, over a three-year horizon.
Based on Council Regulation No 1024/2013, the European Central Bank (ECB) conducts annually a Supervisory Review and
 
Evaluation
Process (SREP) in order
 
to define the prudential
 
requirements of the
 
institutions under its supervision.
 
The key purpose
 
of the SREP
is
 
to
 
ensure
 
that
 
institutions
 
have
 
adequate
 
arrangements,
 
strategies,
 
processes
 
and
 
mechanisms
 
as
 
well
 
as
 
capital
 
and
 
liquidity
to ensure a sound management and coverage of their risks, to which they are
 
or might be exposed, including those revealed by stress
testing and risks the institution may pose to
 
the financial system.
According to the 2024 SREP decision, from December 2024 the P2R for the Group is set at 2.85% in terms of total capital (or at 1.60%
in terms of
 
CET1 capital). The change
 
in the P2R is the
 
outcome of the
 
consolidation of Hellenic Bank.
 
Based on the ECB’s
 
‘Guide on
the
 
supervisory
 
approach
 
to
 
consolidation
 
in
 
the
 
banking
 
sector’,
 
in
 
case
 
of
 
M&As,
 
the
 
P2R
 
of
 
the
 
combined
 
entity/group
 
is
determined based
 
on the
 
weighted
 
average
 
of the
 
P2R (based
 
on RWAs)
 
of the
 
two entities
 
(i.e. Eurobank
 
Group: 2.75%,
 
Hellenic
Bank: 3.45%).
Thus, as of 31 December 2024, the Group is required
 
to meet a Common Equity Tier 1 Ratio
 
of at least 12.45% (including AT1
 
capital
shortfall)
 
and a
 
Total
 
Capital
 
Adequacy
 
Ratio
 
of
 
at
 
least
 
15.16% (Overall
 
Capital
 
Requirement
 
or OCR)
 
including Combined
 
Buffer
Requirement of 4.31%, which is covered with
 
CET1 capital and sits on top of the Total
 
SREP Capital Requirement (TSCR).
From
 
1
 
January
 
2024,
 
the
 
O-SII
 
buffer
 
for
 
the
 
Group
 
increased
 
to
 
1.25%
 
(from
 
1%
 
in
 
2023),
 
in
 
accordance
 
with
 
the
 
Executive
Committee Act 221/1/17.10.2023 of the Bank of Greece, following a change in the methodology applied for the determination of the
O-SII buffer rate. In addition, in accordance with the Executive Committee Act 235/07.10.2024 of the Bank of Greece, from 1 October
2025, a countercyclical capital buffer rate of 0.25%
 
will apply to
 
banks’ exposures to Greece, which
 
is expected to increase the
 
Group’s
capital requirements by 15bps.
 
The countercyclical capital buffer is
 
updated on a
 
quarterly basis in
 
accordance with the
 
countercyclical
capital buffer rates
 
applicable in each country to which the Group has exposures.
The breakdown of the Group’s
 
CET1 and Total
 
Capital requirements,
 
applicable from 31 December 2024, is presented below.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
CET1 Capital
Requirements
Total Capital
Requirements
Minimum regulatory requirement
4.50%
8.00%
Pillar 2 Requirement (P2R)
1.60%
2.85%
Total SREP Capital Requirement
 
(TSCR)
6.10%
10.85%
Combined Buffer Requirement (CBR)
Capital conservation buffer
 
(CCoB)
2.50%
2.50%
Countercyclical capital buffer
 
(CCyB)
0.56%
0.56%
Other systemic institutions buffer
 
(O-SII)
 
1.25%
1.25%
Overall Capital Requirement (OCR), excluding
 
shortfall
10.41%
15.16%
AT1 capital
 
shortfall
2.04%
-
Overall Capital Requirement (OCR), including shortfall
12.45%
15.16%
 
The
 
above
 
CET1
 
capital
 
requirement
 
of
 
12.45%
 
takes
 
into
 
account
 
that
 
the
 
Group
 
had
 
no
 
AT1
 
capital
 
as
 
of
 
31
 
December
 
2024.
Assuming that
 
the Group
 
had fully utilized
 
the AT1
 
capital capacity
 
as at
 
31 December 2024,
 
the CET1
 
requirement would
 
stand at
10.41%.
Following the receipt of regulatory approval,
 
in December 2024, Hellenic Bank redeemed its outstanding AT1
 
instruments of €130m.
Further disclosures regarding capital
 
adequacy in accordance with the Regulation 575/2013 are
 
provided in the Consolidated Pillar 3
Report on the Company’s website.
Minimum Requirements for Eligible Own Funds and Eligible Liabilities (MREL)
Under the Directive
 
2014/59 (Bank
 
Recovery and
 
Resolution Directive)
 
as in force,
 
which was
 
transposed into
 
the Greek legislation
pursuant to Law
 
4335/2015 as in force,
 
European banks are
 
required to
 
meet the minimum requirement
 
for own funds
 
and eligible
 
Notes to the Consolidated Financial Statements
 
.
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31 December 2024 Consolidated Financial Statements
 
 
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liabilities (MREL). The Single Resolution Board (SRB) has determined Eurobank S.A. as the Group’s resolution entity and a Single Point
of Entry (SPE)
 
strategy for
 
resolution purposes. Based
 
on the latest
 
SRB’s communication,
 
the fully calibrated
 
MREL (final target)
 
to
be met by Eurobank S.A. on a consolidated basis from 30 June 2025 is
 
set at 27.80% of its total risk weighted assets (RWAs), including
a combined
 
buffer requirement
 
(CBR) of
 
4.31%. The
 
final MREL
 
target
 
is updated
 
by the
 
SRB on
 
an annual
 
basis. The
 
2025 interim
non-binding MREL
 
target,
 
applicable from
 
January 2025,
 
stands at
 
25.62% of
 
RWAs,
 
including a
 
CBR of
 
4.31%. As
 
at 31
 
December
2024, the Bank’s MREL ratio at consolidated
 
level stands at 28.22% of RWAs including profit for
 
the period ended 31 December 2024
(31
 
December
 
2023:
 
24.91%),
 
while,
 
the
 
Bank’s
 
MREL
 
ratio
 
at
 
consolidated
 
level,
 
pro-forma
 
with
 
the
 
completion
 
of
 
the
 
project
“Solar”, projects
 
“Leon” and “Wave
 
VI”,
 
the accrual
 
for dividend
 
distribution from
 
financial year 2024
 
profits (subject
 
to regulatory
approval) and for the new issuances of the Company
 
and the Bank in 2025 (see post balance sheet event below) stands at
 
29.37% of
RWAs, exceeding
 
both the interim non-binding and the
 
final binding MREL targets,
 
as stated above.Finally,
 
as of 31 December 2024,
the Group’s assets stood at €101.2bn, exceeding the threshold of €100bn for
 
the classification of the Group as ‘top-tier’
 
for resolution
purposes. Hence, in accordance with Art. 12k(4) Regulation 806/2014 (SRMR) after a
 
3-year transitional period, Eurobank is expected
to be subject to an MREL subordination target of
 
ca 18% (i.e. subordination target of 13.5% RWAs
 
plus the then applicable CBR). The
MREL subordination
 
target
 
shall be
 
met with
 
subordinated
 
instruments
 
(i.e. capital
 
instruments
 
and senior
 
non-preferred
 
bonds).
Considering that the Group’s
 
total capital ratio
 
is expected to remain above
 
the aforementioned level
 
until the end of 2027,
 
there is
no need for the Group to issue senior non-preferred
 
instruments.
On 6 December 2024,
 
the Company announced that
 
the Bank successfully completed
 
the issuance of €
 
600 million Senior Preferred
Notes. The
 
proceeds from
 
the issue
 
support Eurobank
 
Group’s
 
strategy
 
to ensure
 
ongoing compliance
 
with its
 
Minimum Required
Eligible Liabilities (MREL) requirement and aim at increasing Eurobank’s MREL ratio towards the end-state MREL targeted compliance
range (note 34).
Post balance sheet event
In January 2025, Eurobank Holdings successfully completed the issuance of € 589 million Subordinated
 
Tier 2 debt instrument and in
February 2025, the
 
Bank successfully completed
 
the issuance of € 350
 
million Senior Preferred
 
Notes. The proceeds
 
from the issues
will support the Group’s
 
strategy to ensure ongoing compliance with
 
its total capital adequacy and MREL (note 34).
2025 EU - wide stress test
The EU-wide stress test exercise is carried out on a sample of
 
banks covering broadly 75% of the banking sector in
 
the euro area, each
non-euro area EU Member State and Norway, as expressed in terms of total consolidated assets as of end 2023. To be included in the
sample, banks have to have a minimum of
 
€ 30 bn total assets.
As per the 2025
 
EU-Wide Stress Test Methodological Note (published on 11 November
 
2024, footnote 92), Eurobank Ergasias Services
and Holdings
 
S.A. has
 
been excluded
 
from the
 
sample of
 
the EU-wide
 
stress test
 
exercise
 
because of
 
a major
 
acquisition (Hellenic
Bank).
 
 
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Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
5.
 
Financial risk management and fair value
 
 
5.1
 
Use of financial instruments
By
 
their
 
nature
 
the
 
Group's
 
activities
 
are
 
principally
 
related
 
to
 
the
 
use
 
of
 
financial
 
instruments
 
including
 
derivatives.
 
The
 
Group
accepts deposits from
 
customers, at both
 
fixed and floating
 
rates, and
 
for various periods
 
and seeks to
 
earn above average
 
interest
margins by investing these funds in high quality assets. The Group seeks to increase these margins by consolidating
 
short-term funds
and lending for longer periods at higher rates,
 
while maintaining sufficient liquidity to meet all claims that might
 
fall due.
The
 
Group
 
also
 
seeks
 
to
 
raise
 
its
 
interest
 
margins
 
by
 
obtaining
 
above
 
average
 
margins,
 
net
 
of
 
provisions,
 
through
 
lending
 
to
commercial and retail borrowers within a range of credit standing. Such exposures include both on-balance sheet loans and advances
and off-balance sheet guarantees and other commitments
 
such as letters of credit.
The Group also trades in financial instruments where it
 
takes positions in traded and over the counter financial
 
instruments, including
derivatives, to take
 
advantage of short-term
 
market movements in the equity and bond markets
 
and in currency and interest
 
rates.
5.2 Financial risk factors
Due to its activities,
 
the Group is
 
exposed to several
 
financial risks, such as
 
credit risk, market
 
risk (including currency,
 
interest rate,
spread, equity
 
and volatility
 
risk), liquidity,
 
operational
 
and other
 
non-financial risks,
 
as well
 
as to
 
sustainability
 
risks. The
 
Group's
overall risk management strategy seeks to minimize
 
any potential adverse effects
 
on its financial performance, financial position and
cash flows.
Risk Management objectives and policies
 
The Group
 
acknowledges that
 
taking risks
 
is an integral
 
part of its
 
operations in
 
order to
 
achieve its business
 
objectives. Therefore,
the Group’s
 
management sets adequate
 
mechanisms to identify those
 
risks at an
 
early stage and
 
assesses their potential
 
impact on
the achievement of these objectives.
Due to the fact that
 
economic, industry,
 
regulatory and operating conditions
 
will continue to change,
 
risk management mechanisms
are set in
 
a manner that
 
enable the Group
 
to identify and
 
deal with the risks
 
associated with those
 
changes. The Group’s
 
structure,
internal processes and existing control mechanisms
 
ensure both the
 
independence principle and
 
the exercise of sufficient supervision.
The Group's
 
Management considers
 
effective risk
 
management as
 
a top priority,
 
as well as
 
a major
 
competitive advantage,
 
for the
organization. As such, the Group has allocated significant resources for upgrading its policies, methods and infrastructure,
 
in order to
ensure compliance with the requirements of
 
the European Central Bank (ECB) and
 
of the Single
 
Resolution Board (SRB), the guidelines
of
 
the
 
European
 
Banking
 
Authority
 
(EBA)
 
and
 
the
 
Basel
 
Committee
 
for
 
Banking
 
Supervision
 
and
 
the
 
best
 
international
 
banking
practices.
 
The
 
Group
 
implements
 
a
 
well-structured
 
credit
 
approval
 
process,
 
independent
 
credit
 
reviews
 
and
 
effective
 
risk
management policies for all material risks it is exposed to, both in Greece and in each country of its international operations. The risk
management policies implemented by the Group are
 
reviewed mainly annually.
The maximum amount
 
of risk which the
 
Group is willing
 
to assume in the
 
pursuit of its strategic
 
objectives is articulated
 
via a set of
quantitative
 
and
 
qualitative
 
statements
 
for
 
specific risk
 
types,
 
including
 
specific tolerance
 
levels
 
as
 
described
 
in
 
the
 
Group’s
 
Risk
Appetite Framework. The objectives are to support the
 
Group’s business growth, balance a strong capital position with higher
 
returns
on equity and to ensure the Group’s
 
adherence to regulatory requirements.
The risk appetite that is
 
clearly communicated throughout the Group, determines risk culture and
 
forms the basis on which
 
the Group
establishes its risk limits
 
and risk policies. Aiming to
 
identify its material risks
 
,
 
the Group maintains
 
a well-defined Risk Identification
and Materiality Assessment (RIMA) Framework.
The identification and the
 
assessment of all risks is the
 
cornerstone for
 
the effective Risk Management.
 
The Group aiming to
 
ensure
a
 
collective
 
view
 
on
 
the
 
risks
 
linked
 
to
 
the
 
execution
 
of
 
its
 
strategy,
 
acknowledges
 
the
 
new
 
developments
 
at
 
an
 
early
 
stage
 
and
assesses the potential impact.
 
Board Risk Committee (BRC)
The Board Risk Committee (BRC)
 
is a committee of the
 
Board of Directors (BoD) and its
 
task is to advise
 
and support the BoD
 
regarding
the monitoring of Group’s overall actual and future risk appetite and
 
strategy, taking into account all types of risks to ensure that they
are in line with
 
the business strategy, objectives, corporate culture and values of the institution. The
 
BRC assists the BoD
 
in overseeing
the implementation
 
of Group’s
 
risk strategy
 
and the corresponding
 
limits set. It
 
also oversees
 
the implementation
 
of the strategies
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
 
 
 
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for capital
 
and liquidity risk
 
management as well
 
as for all
 
material risks, such
 
as credit, market,
 
IRRBB, sustainability
 
risks and non-
financial
 
risks
 
such
 
as
 
operational,
 
reputational
 
conduct,
 
legal,
 
cyber,
 
outsourcing,
 
in
 
order
 
to
 
assess
 
their
 
adequacy
 
against
 
the
approved risk appetite limits.
The BRC consists of five (5) non-executive directors,
 
meets at least 10 times per year and reports to the BoD on a quarterly basis and
on ad hoc instances if it is needed.
Management Risk Committee
The Management Risk Committee (MRC) is a management committee established by the
 
CEO and its main responsibility is to
 
oversee
the risk management framework of the Group. As part of its responsibilities, the MRC facilitates
 
reporting to the BRC on the range of
risk-related topics under its purview,
 
including sustainability risks. The MRC supports the Group Chief Risk Officer to identify material
risks, to promptly escalate them
 
to the BRC
 
and to ensure that
 
the necessary policies
 
and procedures are in
 
place to prudently manage
risks and to comply with regulatory requirements.
 
Group Risk Management
The
 
Group’s
 
Risk
 
Management
 
Unit
 
which
 
is
 
headed
 
by
 
the
 
Group
 
Chief
 
Risk
 
Officer
 
(GCRO),
 
operates
 
independently
 
from
 
the
business units and is responsible for the identification, assessment,
 
monitoring, measurement and management of the risks that the
Group
 
is exposed to.
 
It comprises of the
 
Group Credit (GC),
 
the Group Credit
 
Control (GCC), the
 
Group Credit
 
Risk Capital Adequacy
Control
 
(GCRCAC), the Group
 
Market and
 
Counterparty Risk
 
(GMCR), the Group
 
Operational and Non-Financial
 
Risks (GONFR), the
Group Model
 
Validation
 
and Governance
 
(GMVG), the
 
Group Risk
 
Management Strategy
 
Planning Operations
 
& Sustainability
 
Risk
(GRMSPO&SR), the Supervisory Relations and Resolution Planning (SRRP), and the Risk Analytics (RA) Units.
Furthermore, the
 
Group is
 
in the process
 
of aligning Hellenic
 
Bank risk management
 
policies and practices
 
with those of
 
the Group
across key risk types, following
 
the acquisition of control in the third
 
quarter of 2024 and in view of the completion of the Take
 
Over
Bid process to acquire 100% of Hellenic Bank’s
 
shares. This includes harmonizing key risk policies, standardizing
 
regulatory as well as
internal risk reporting, and aligning risk methodologies.
Non-Performing Exposures (NPEs) management
The Bank realizes the NPE Strategy
 
Plan through its implementation
 
by doValue Greece
 
for the assigned portfolio and
 
the successful
securitization transactions.
Troubled Assets Committee
The
 
Troubled
 
Assets
 
Committee
 
(TAC)
 
is
 
established
 
according
 
to
 
the
 
regulatory
 
provisions
 
and
 
its
 
main
 
purpose
 
is
 
to
 
act
 
as
 
an
independent body,
 
closely monitoring the Bank’s troubled
 
assets portfolio and the execution of its NPE Management
 
Strategy.
Remedial and Servicing Strategy (RSS)
The Remedial Servicing and Strategy (RSS) is responsible: a) for the management of the
 
non-performing and early arrears loans of the
Bank, b) for structured transactions which create capital (such as Synthetic SRT STS securitizations) and/or offer credit protection and
c) for cooperation with the other units of Group
 
Strategy for other transactions and initiatives.
RSSis closely
 
monitoring the
 
overall performance
 
of the NPE
 
portfolio as
 
well as the
 
relationship of
 
the Bank with
 
doValue
 
Greece.
Furthermore,
 
following
 
Eurobank’s
 
commitments
 
against
 
the
 
significant
 
risk
 
transfer
 
(SRT)
 
monitoring
 
regulatory
 
requirements
pertaining to Bank’s
 
concluded transactions, RSS
 
has a pivotal role
 
in ensuring that relevant
 
process is performed
 
smoothly and in a
timely manner and
 
that any shortcomings are
 
appropriately resolved, while providing any
 
required clarifications or additional
 
material
required by the regulatory authorities.
The Head of
 
RSS reports to the
 
General Manager of Group Strategy.
In this context, RSS
 
has been assigned
 
inter alia with
 
the following
responsibilities:
Structure
 
new
 
transactions
 
and perform
 
the
 
execution
 
of
 
any
 
transaction
 
processes,
 
by
 
also
 
establishing
 
negotiation
 
of
Commercial / Legal Terms
 
as well monitoring of these transactions
Develop and actively monitor the NPE targets
 
and reduction plan
Set the strategic principles, priorities, policy framework
 
and KPIs under which doValue Greece is servicing the portfolio
Notes to the Consolidated Financial Statements
 
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Closely monitor the execution of the
 
approved strategies, as well as all
 
contractual provisions under the relevant contractual
agreements for Eurobank’s
 
portfolio assigned to doValue Greece
 
including the securitized portfolio of ERB Recovery
 
DAC
 
Monitoring of
 
the performance
 
of the
 
senior notes
 
of the securitizations
 
in collaboration
 
with Group
 
Risk so
 
as to
 
ensure
compliance to significant risk transfer
 
(SRT) and to the Hellenic Asset Protection Scheme (HAPS)
Budget and monitor the Bank’s expenses
 
and revenues associated with the assigned portfolio
Cooperate closely with doValue
 
Greece on a daily basis in achieving the Group’s
 
objectives
Maintain supervisory dialogue
 
5.2.1 Credit Risk
 
Credit risk
 
is the risk
 
that a
 
counterparty will
 
be unable
 
to fulfill
 
its payment
 
obligations in
 
full when due.
 
Credit risk
 
is also related
with country risk and settlement risk, specified below:
a)
Country risk
 
is the
 
risk of
 
losses arising
 
from cross
 
-border lending
 
and investment
 
activities and
 
refers
 
to the
 
uncertainty
associated
 
with exposure
 
in a
 
particular country.
 
This uncertainty
 
may relate
 
to a
 
number of
 
factors
 
including the
 
risk of
losses following nationalization, expropriation,
 
debt restructuring and foreign exchange
 
rates’ movement.
b)
Settlement
 
risk
 
is
 
the
 
risk
 
arising
 
when
 
payments
 
are
 
settled,
 
for
 
example
 
for
 
trades
 
in
 
financial
 
instruments,
 
including
derivatives
 
and
 
currency
 
transactions.
 
The
 
risk
 
arises
 
when
 
the
 
Group
 
remits
 
payments
 
before
 
it
 
can
 
ascertain
 
that
 
the
counterparties’ payments have
 
been received.
 
Credit
 
risk
 
arises
 
principally
 
from
 
the
 
wholesale
 
and
 
retail
 
lending
 
activities
 
of
 
the
 
Group,
 
as
 
well
 
as
 
from
 
credit
 
enhancements
provided, such as financial guarantees and
 
letters of credit. The Group
 
is also exposed to credit risk arising from other activities
 
such
as investments in debt securities, trading, capital markets and settlement activities. Taking
 
into account that credit risk is the primary
risk the Group is exposed to, it is very closely managed and
 
monitored by specialised risk units, reporting to the GCRO.
(a) Credit approval process
The credit
 
approval and
 
credit review
 
processes are
 
centralized
 
both in
 
Greece and
 
in the
 
International operations
 
.
 
Segregation of
duties
 
ensures
 
independence
 
among
 
executives
 
responsible
 
for
 
the
 
customer
 
relationship,
 
the
 
approval
 
process
 
and
 
the
 
loan
disbursement, as well as monitoring of the loan during its lifecycle.
Credit Committees
The credit
 
approval process
 
in Corporate
 
Banking is centralized
 
through establishment
 
of Credit
 
Committees with
 
escalating Credit
Approval Levels. Main Committees of the Bank
 
are the following:
Credit Committees (Central
 
and Local) authorized to approve
 
new financing, renewals or amendments
 
mainly for domestic
groups in
 
the existing
 
credit limits,
 
in accordance
 
with their credit
 
approval authority,
 
depending on total
 
limit amount
 
of
the customer/group and risk category
 
(i.e. high, medium or low), as well as the value and type of security;
Special Handling Credit Committees authorized to
 
approve credit requests and take
 
actions for distressed clients;
International
 
Credit
 
Committees
 
(Regional
 
and
 
Country)
 
established
 
for
 
the
 
wholesale
 
borrowers
 
of
 
the
 
Group’s
international bank subsidiaries, authorized to approve new limits, renewals or amendments to existing limits, in accordance
with their credit approval
 
authority, depending on
 
total customer exposure
 
and risk category (i.e. high, medium
 
or low), as
well as the value and type of security; and
International
 
Special
 
Handling
 
Committees
 
established
 
for
 
handling
 
distressed
 
wholesale
 
borrowers
 
of
 
the
 
Group’s
international bank subsidiaries.
The Credit Committees meet on a weekly basis or more frequently,
 
if needed.
Group Credit (GC)
Within an environment of increased risk
 
requirements, Group Credit (GC) mission is
 
to safeguard the Group’s asset side, by evaluating
credit risk
 
and making
 
recommendations,
 
so that
 
borrower’s
 
credit exposure
 
is acceptable
 
and within
 
the approved
 
Risk Appetite
Framework. GC is headed by the Group Chief Credit
 
Officer (GCCO) with direct reporting to the Group
 
Chief Risk Officer (GCRO).
Notes to the Consolidated Financial Statements
 
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GC operations
 
are comprised
 
of two
 
functions, i.e.
 
the Corporate
 
Credit, including
 
both the domestic
 
and the
 
foreign underwriting
activities (the latter only
 
for material exposures of
 
International Subsidiaries), and
 
Retail Credit respectively, covering the underwriting
needs of the SBB portfolio and the Individuals Lending (mortgage, consumer
 
loans, auto-moto loans and credit cards).
1.
Corporate Credit
(a) Domestic and Greek related portfolio: the underwriting function includes the review of
 
credit requests originating from Corporate
Units handling
 
large and
 
medium scale
 
corporate
 
entities of
 
every risk
 
category and
 
specialised lending
 
units such
 
as Shipping
 
and
Structured Finance (Commercial
 
Real Estate,
 
Hotels & Leisure,
 
Project Finance, M&A
 
Financing) and Private
 
Banking. Major tasks
 
of
the respective workstream and involved
 
credit units pertain to the following:
Evaluation
 
of
 
credit
 
applications
 
and
 
issuance
 
of
 
an
 
independent
 
Risk
 
Opinion
 
when
 
required
 
according
 
to
 
internal
procedures, which includes:
(i)
 
assessment
 
of
 
the
 
customer
 
credit
 
profile
 
based
 
on
 
the
 
qualitative
 
and
 
quantitative
 
risk
 
factors
 
identified
 
(market,
operational, structural and financial)
(ii) recommendations for the formulation of bankable, well-secured and well-controlled
 
transactions (credit facility), as well
as
(iii) review and confirmation of the ratings
 
of each separate borrower to reflect
 
the risks acknowledged
Participation with voting right in all credit committees
 
as per the Credit Approval procedures
Active participation in
 
the regulatory audits and
 
major internal projects of
 
the Bank, providing
 
at the same
 
time credit related
knowledge, expertise and support to other Units
Preparation
 
of specialised reports
 
to Management
 
on a regular
 
basis, with regards
 
to the Top
 
25 largest,
 
in terms of
 
total
exposure, borrower Groups,
 
statistics on the new approved
 
financings and leveraged transactions.
(b)
 
International
 
Subsidiaries’
 
portfolio:
 
The
 
GC
 
through
 
its
 
specialized
 
International
 
Corporate
 
Credit
 
Unit
 
(IC)
 
is
 
responsible
 
to
actively
 
participate
 
in
 
the
 
evaluation
 
of
 
credit
 
applications
 
that
 
exceed
 
a
 
certain
 
threshold
 
for
 
the
 
wholesale
 
portfolio
 
of
 
the
International
 
Subsidiaries covering
 
Bulgaria,
 
Cyprus, and
 
portion of
 
the loan
 
portfolio
 
of Luxemburg
 
(and London).
 
Moreover,
 
the
respective unit’s tasks and responsibilities
 
are highlighted below:
Participation with voting right in all International Committees (Regional and Special Handling) and Country Risk Committees
(CRCs)
Participation
 
in
 
the
 
sessions
 
of
 
Special
 
Handling
 
Monitoring
 
Committees
 
for
 
Bulgaria
 
which
 
monitor
 
and
 
decide
 
on
 
the
strategy
 
of problematic
 
corporate
 
relationships with
 
loan outstanding
 
exceeding a
 
certain threshold,
 
that is
 
jointly set
 
by
ICC and Country TAG
Advice on best practices to the Credit Risk Units of International
 
Subsidiaries
GC is also responsible for the preparation
 
of all credit committees’ agendas, distribution of the respective
 
material and maintenance
of the respective Credit Committees’ minutes.
2.
Retail Credit
 
The scope of the Retail
 
Credit is the assessment of credit
 
applications submitted by Retail
 
Business Units, in relation to Borrowers
 
of
the performing
 
retail credit
 
portfolio (SBB
 
loans and
 
Individual Banking).
 
Such applications
 
refer to
 
new loans,
 
review /
 
renewal of
existing lines and after sales requests.
 
The main tasks of Retail Credit function are
 
outlined below:
Assess credit
 
requests in
 
alignment with
 
the credit
 
risk assessment
 
criteria and
 
methodology provided
 
in the
 
appropriate
Credit Policy Manual, in accordance with the defined
 
approval levels.
Analyze and evaluate risk factors depending
 
on the type
 
of credit request based
 
on both financial
 
and qualitative information
Prepare an independent Credit Opinion ensuring that the risks
 
identified are dully reflected in the Borrower’s
 
Rating
Participate with voting
 
rights in the credit committees
 
as per the credit
 
approval process,
 
according to the Approval
 
Levels
defined in the CPM
Active participation in
 
the regulatory audits and
 
major internal projects of
 
the Bank, providing
 
at the same
 
time credit related
knowledge, expertise and support to other units
Notes to the Consolidated Financial Statements
 
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(b)
Credit risk monitoring
Group Credit Control
The Group Credit
 
Control
 
(GCC) monitors
 
and assesses the
 
quality of all of
 
the Group’s
 
loan portfolios and
 
operates independently
from the business units of the Bank. The GCC reports directly to the GCRO.
The main responsibilities of the GCC are to:
supervise, support and maintain
 
the credit rating and impairment
 
systems used to assess the
 
wholesale and Large SB
 
lending
customers;
monitor and review the performance of all of the Group’s
 
loan portfolios;
supervise and control the foreign subsidiaries’ credit
 
risk management units;
monitor on
 
a regular
 
basis and
 
report on
 
a quarterly
 
basis to
 
the Board
 
of Directors
 
and the
 
BRC of
 
risk exposures,
 
along
with accompanying analyses;
monitor and evaluate the
 
efficiency of adopted strategies
 
and proposed solutions in terms
 
of dealing with Non-Performing
Exposures (NPEs)
 
and the
 
achievement of
 
targets
 
for NPEs
 
reduction, as
 
communicated
 
and agreed
 
with the
 
Supervisory
Authorities;
conduct field
 
reviews and
 
prepare written
 
reports to
 
the Management
 
on the
 
quality of
 
all of the
 
Group’s
 
loan portfolios
and adherence with EBA prevailing regulations;
monitor the proper EBA classifications in accordance
 
with the relevant provisions and guidelines;
participate in the approval of new credit policies and
 
new loan products;
participate in the Troubled
 
Asset Committee;
attend meetings of Credit Committees and
 
Special Handling Committees, without voting right;
formulate
 
the Group’s
 
credit
 
impairment
 
policy and
 
measure
 
the
 
provisions
 
of
 
the
 
Greek loan
 
portfolios
 
along with
 
the
relevant reporting to Management;
regularly review the adequacy of provisions of all of the Group’s
 
loan portfolios;
formulate, in collaboration
 
with the responsible lending Units the credit policy manuals for performing
 
borrowers;
provide guidance and monitor the process of designing and reviewing
 
credit policies before approved
 
by Management.
Through field
 
/ thematic reviews
 
on a sample
 
basis monitor the
 
proper application
 
of Real Estate
 
collaterals’ valuation,
 
as
per the Banks’ Collateral Valuation
 
policy and procedures;
monitor the supervisory,
 
regulatory developments,
 
emerging trends and
 
best practices within
 
its purview in order
 
to keep
Management abreast and propose required
 
actions;
Lead or participate in various risk related
 
projects including but not limited to supervisory
 
investigations, stress
 
tests, Asset
Quality Reviews, process improvement
 
projects etc.
Group Credit Risk Capital Adequacy Control
The Group Credit Risk Capital Adequacy Control develops and maintains the credit risk assessment models for the loans portfolio and
securitized
 
exposures
 
of
 
the
 
Group,
 
performs
 
capital
 
adequacy
 
calculations
 
and
 
assessment
 
for
 
the
 
loan
 
portfolios
 
of
 
the
 
group,
conducts internal & external stress test exercises as well as well as
 
forecasting of risk parameters, impairments in the context of IFRS9
and
 
RWAs
 
and
 
the
 
three
 
year
 
business
 
plan.
 
In
 
addition,
 
prepares
 
the
 
Pillar
 
2
 
assessment
 
for
 
credit
 
risk,
 
foreign
 
exchange
 
risk,
concentration risk and securitisation risk. The Unit
 
reports directly to the GCRO.
Specifically, the main responsibilities
 
of the Group Credit Risk Capital Adequacy Control
 
are to:
control,
 
measure
 
and
 
monitor
 
the
 
capital
 
requirements
 
arising
 
from
 
the
 
Group’s
 
loan
 
portfolio
 
along
 
with
 
the
 
relevant
reporting to Management and regulators
 
(ECB/SSM);
perform significant Risk Transfer
 
(SRT) tests and monitor independent synthetic
 
and traditional securitsations
manage the models
 
development, implementation
 
and monitoring of
 
the internal models
 
and IFRS9 models
 
of Probability
of Default (PD), Loss Given Default (LGD)
 
and Exposure at Default (EAD) for evaluating
 
credit risk
Notes to the Consolidated Financial Statements
 
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measure and monitor the risk parameters
 
(PD, LGD, EAD)
 
for the purposes of internal capital adequacy
 
assessment, as well
as the estimation
 
of risk
 
related parameters (such as
 
forecast 12-m PD, forecast lifetime PD)
 
for IFRS 9
 
impairment calculation
purposes;
review the grouping
 
of lending exposures
 
and ensuring their homogeneity
 
in accordance with the
 
Group’s IFRS
 
accounting
policies
development and monitoring of the significant increase
 
in credit risk (SICR) thresholds under IFRS9 standard;
prepare monthly
 
capital adequacy calculations
 
(Pillar 1) and
 
relevant management,
 
as well as
 
regulatory reports
 
(COREPs,
SREP) on a quarterly basis;
projection of asset quality and capital requirements
 
for the loan book (projected impairments and RWAs),
 
in the context of
the business plan, ICAAP and recovery plan and participation in the relevant
 
committees;
perform stress tests, both internal
 
and external (EBA/SSM), and maintain the credit risk
 
stress testing infrastructure;
coordinate the stress testing
 
exercises for the loan portfolios at
 
Group Level;
prepare the credit risk analyses for Internal
 
Capital Adequacy Assessment (ICAAP)/ Pillar 2 purposes;
prepare the Basel Pillar 3 and relevant IFRS9 disclosures
 
for credit risk;
regularly
 
report
 
to
 
the
 
GCRO,
 
to
 
the
 
Management
 
Risk
 
Committee
 
and
 
to
 
the
 
Board
 
Risk
 
Committee
 
on:
 
risk
 
models
performance,
 
risk
 
parameters
 
(PD,
 
LGD,
 
EAD),
 
forbearance
 
reporting,
 
vintage
 
analysis
 
and
 
default
 
/
 
redefault
 
statistics
portfolios forward looking analysis and new
 
disbursements quality.
guide, monitor and supervise the Credit Risk divisions of the subsidiaries on modelling, credit stress testing and other credit
risk related regulatory issues.
monitor and guide Group’s
 
international subsidiaries on credit risk related
 
ICAAP,
 
stress testing and other regulatory
 
credit
risk related issues, based on Group standards.
 
Review of local credit risk stress test
 
exercises;
support the business units in the use
 
of credit risk models in business decisions,
 
for funding purposes, in the capital
 
impact
assessment of strategic
 
initiatives and the development
 
and usage of risk related
 
metrics such as risk adjusted
 
pricing, Risk
Adjusted Return on Capital (RAROC) etc.; and
assist Remedial Servicing Strategy in the risk assessment
 
and risk impact of various programs and products.
Group Model Validation and Governance
1.
Group Model Validation and
 
Governance was set up with key mandates:
the establishment of a comprehensive model validation
 
and governance framework, and
the independent validation of significant models (credit risk, pricing, profitability etc.) used by the Group, in order to ensure
that the results produced are correct,
 
cover fully business needs, as well as that the methodologies and tools
 
applied are in
alignment with industry standards and the corresponding
 
regulatory requirements.
2.
In more detail, the tasks of the Unit are
 
outlined as follows:
Prepare
 
and
 
update
 
the
 
Group’s
 
Models
 
Framework
 
(to
 
include
 
model
 
definition,
 
roles
 
involved
 
per
 
model,
 
model
classification
 
principles
 
and methodology,
 
model validation
 
principles,
 
materiality
 
classifications
 
and thresholds,
 
models’
registry governance, etc)
Establish and update the Group’s
 
Models Registry
Review models’ classification, in accordance with the
 
methodology provided in the Group Models Framework
Support and advise Group subsidiaries in the implementation of the Group
 
Models Framework
Prepare and update the Group Models Validation
 
Framework
Design and update the methodologies
 
and procedures used
 
for model validation tests,
 
as defined in the Models Validation
Framework.
Prepare annual models’ validation/revalidation
 
plan.
Propose and escalate for approval
 
the quantitative thresholds, in order to
 
assess the results of the validation tests.
Conduct model validation tests in alignment with the Group
 
Model Validation Framework
 
and regulatory requirements.
Prepare detailed
 
reports with the model
 
valuation results according
 
to the specific requirements
 
of the model validated,
 
if
any
Notes to the Consolidated Financial Statements
 
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Support
 
and
 
advise
 
Group
 
subsidiaries
 
with
 
regards
 
to
 
the
 
preparation
 
and
 
implementation
 
of
 
their
 
model
 
validation
framework.
Disseminate models’ validation results within the Group,
 
as appropriate.
Prepare action plan for
 
remediation actions, if any,
 
as a result of the model
 
validation tests implemented,
 
and escalate the
plan for its approval by the appropriate
 
Management Authority
Participate in the sign-off of new models for
 
assessing ratings’ system accuracy
 
and suitability.
Monitor industry practices on the development
 
and use of models as well as related ECB guidelines and restrictions.
Monitor changes in ECB guidelines on models’ validation.
3.
As
 
of
 
September
 
2024,
 
the
 
Unit
 
has
 
additionally
 
assumed
 
responsibility
 
for
 
the
 
validation
 
of
 
Eurobank’s
 
compliance
 
to
 
the
requirements of
 
BCBS 239 (Risk
 
Data Aggregation
 
and Risk Reporting
 
framework). In
 
this context,
 
the relevant
 
tasks of
 
the unit are
outlined as follows:
Design and maintain an effective RDARR Validation
 
Framework describing the relevant methodologies and processes based
on most recent relevant regulatory
 
guidelines and other requirements.
Prepare annual RDARR compliance validation
 
plan.
Perform
 
Periodic validations
 
of level
 
of compliance
 
with regards
 
to the
 
implementation
 
of the
 
BCBS 239
 
Principles in
 
the
Group’s RDARR
 
processes and systems, in a timely manner,
 
in line with the RDARR Validation Framework
Perform periodic reviews of the validation
 
activities carried out by material subsidiaries.
Report the Group’s level of compliance with the BCBS 239
 
Principles in the annual validation report, in
 
the form of an overall
compliance score,
 
reflecting
 
the overall
 
results
 
derived
 
following
 
the completion
 
of all
 
its annual
 
validation
 
activities, as
described in the RDARR Validation
 
Framework
 
Disseminate validation results within the
 
Group, as appropriate.
Prepare action plan for remediation actions, if any, as a result of the validation tests implemented, and escalate the plan for
its approval by the appropriate Management
 
Authority
Supervise
 
and
 
review
 
of
 
changes
 
in
 
the
 
BCBS
 
239
 
Overarching
 
Framework,
 
in
 
order
 
to
 
proceed
 
with
 
the
 
necessary
amendments (if any) in the RDARR Validation
 
Framework
Group Market and Counterparty Risk
Group Market
 
and Counterparty Risk (GMCR) is responsible
 
for the measurement,
 
monitoring and periodic reporting
 
of the Group’s
exposure to counterparty
 
risk (issuer risk and market driven counterparty
 
risk), which is the risk of loss due to the custome
 
r’s failure
to
 
meet
 
its contractual
 
obligations
 
in the
 
context
 
of treasury
 
positions,
 
such as
 
debt
 
securities, derivatives,
 
repos,
 
reverse
 
repos,
interbank placings, etc.
In addition, GMCR monitors, controls and regularly reports country limits, exposures and escalates breaches to the Management and
to Committees.
 
GMCR uses a
 
comprehensive methodology
 
approved by
 
the BRC, for
 
determining the
 
acceptable country
 
risk level,
including the countries in which the Group has a strategic
 
presence.
The
 
Group
 
sets
 
limits on
 
the level
 
of
 
counterparty
 
risk
 
that
 
are
 
based
 
mainly
 
on
 
the counterparty’s
 
credit
 
rating,
 
as
 
provided
 
by
international rating agencies, the product type and
 
the maturity of the
 
transaction (e.g. control limits on net
 
open derivative positions
by both amount and term, sovereign bonds exposure,
 
corporate securities, asset backed securities etc.).
GMCR maintains and updates
 
the limits’ monitoring systems
 
and ensures the correctness and
 
compliance of all financial institutions
limits with the Bank’s policies as approved
 
by the Group’s relevant
 
bodies.
The utilization of the abovementioned limits, any excess of them, as well as the aggregate
 
exposure per Group’s
 
entity, counterparty
and product type are monitored by
 
GMCR on a daily basis. Risk mitigation contracts
 
are taken into account
 
for the calculation of the
final exposure.
Also, GMCR ensures that the
 
exposure arising from counterparties complies
 
with the approved country limits
 
framework. The GMCR’s
exposure
 
measurement
 
and
 
reporting
 
tool
 
is
 
also
 
available
 
to
 
the
 
Group’s
 
subsidiaries
 
treasury
 
divisions,
 
thus
 
enabling
 
them
 
to
monitor each counterparty’s exposure
 
and the limit availability.
Additionally,
 
for
 
the
 
Banks’
 
corporate
 
bond
 
portfolio,
 
GMCR
 
measures
 
and
 
monitors
 
daily
 
the
 
total
 
notional
 
limits,
 
the
 
sectoral
concentration
 
and the
 
maximum size
 
per issuer.
 
It uses
 
a measurement
 
tool for
 
monitoring any
 
downgrades and
 
any idiosyncratic
spread widening from purchase and any breach
 
is communicated to the Management and to
 
the relevant Committees.
Notes to the Consolidated Financial Statements
 
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GMCR implements the
 
market’s best practices and safeguards the compliance
 
of all involved parties
 
to limits’ policies
 
and procedures.
To
 
this direction,
 
for various
 
units and
 
International
 
subsidiaries, GMCR
 
provides
 
support and
 
guidance for
 
implementation
 
of the
limits’ guidelines and policies.
Furthermore,
 
GMCR prepares
 
specialized
 
reports for
 
the Management/Committees
 
along with
 
regular reporting
 
that includes
 
the
exposure
 
to the
 
Hellenic Republic
 
and a
 
report
 
that
 
is based
 
on the
 
calculation
 
of the
 
Lifetime
 
Expected
 
Losses for
 
the exposure
towards the Hellenic Republic (HR).
(c) Credit related commitments
The primary purpose of credit related commitments is
 
to ensure that funds are available to a
 
customer as agreed. Financial guarantee
contracts carry
 
the same credit
 
risk as loans
 
since they represent
 
irrevocable assurances
 
that the
 
Group will
 
make payments
 
in the
event that a customer
 
cannot meet its obligations
 
to third parties. Documentary
 
and commercial letters
 
of credit, which are written
undertakings by the Group
 
on behalf of a customer
 
authorizing a third party
 
to draw drafts
 
on the Group up to
 
a stipulated amount
under specific terms
 
and conditions,
 
are secured by
 
the underlying shipment
 
of goods to
 
which they relate
 
and therefore
 
carry less
risk than a loan. Commitments to extend credit
 
represent contractual commitments
 
to provide credit under pre-specified terms
 
and
conditions (note 42) in the form of loans, guarantees or letters of credit for which the
 
Group usually receives a commitment fee. Such
commitments are irrevocable over the
 
life of the facility or revocable only in response
 
to a material adverse effect.
(d) Concentration risk
The Group
 
structures the
 
levels of
 
credit risk
 
it undertakes
 
by placing
 
exposure limits
 
by borrower,
 
or groups
 
of borrowers,
 
and by
industry segments.
 
The exposure
 
to each
 
borrower is
 
further restricted
 
by sub-limits
 
covering on
 
and off-balance
 
sheet exposures,
and daily delivery risk limits in relation to trading items
 
such as forward foreign exchange
 
contracts.
Such risks are
 
monitored on a
 
revolving basis and are
 
subject to an
 
annual or more
 
frequent review. Risk concentrations are monitored
regularly
 
and
 
reported
 
to
 
the
 
BRC.
 
Such
 
reports
 
include
 
the
 
25
 
largest
 
exposures,
 
major
 
watch
 
list
 
and
 
problematic
 
customers,
industry analysis, analysis by rating/risk class, by delinquency bucket,
 
and loan portfolios by country.
(e) Rating systems
Rating of wholesale lending exposures
The Group has decided upon the differentiation of rating models for wholesale lending activities, in order to reflect appropriately the
risks
 
arising
 
from
 
customers
 
with
 
different
 
characteristics.
 
Accordingly,
 
the
 
Group
 
employs
 
the
 
following
 
rating
 
models
 
for
 
the
wholesale portfolio:
Moody’s Risk Analyst
 
model (“MRA” or “Fundamental
 
Analysis”-“FA”)
 
is used to assess the
 
risk of borrowers
 
for Corporate
Lending.
Internal Credit Rating model (“ICR”) is used for
 
those customers that cannot be rated
 
by MRA.
Slotting rating models are employed
 
in view of assessing the risk of specialized exposures,
 
which are part of the Specialized
Lending corporate portfolio.
Transactional
 
Rating model (“TR”) has
 
been developed in
 
order to
 
assess the risk
 
of transactions
 
taking into
 
consideration
their collaterals/guarantees.
Finally,
 
an
 
assessment
 
of
 
the
 
borrowers’
 
viability
 
and
 
the
 
identification
 
of
 
impairment
 
triggers
 
is
 
performed
 
using
 
the
“Unlikely to Pay” (“UTP”) / impairment test.
MRA, ICR, Slotting and ”UTP” functions are supported by the CreditLens (“CL”)
 
computing platform provided
 
by an external provider
(Moody’s Analytics), while the TR is internally developed
 
and is being supported by the core applications of the Bank.
MRA follows
 
the Moody’s
 
fundamental analysis
 
(FA)
 
approach. The
 
FA
 
models belong
 
to a
 
family of
 
models defined
 
as Knowledge
Based Systems and rely on a
 
probabilistic reasoning approach. They use quantitative and qualitative information of
 
individual obligors
in
 
order
 
to
 
assess
 
their
 
creditworthiness
 
and
 
determine
 
their
 
credit
 
rating.
 
In
 
particular,
 
MRA
 
takes
 
into
 
account
 
the
 
company's
balance sheets, profit & loss accounts and cash flow statements to calculate key ratios. Its ratio analysis includes assessments of each
ratio’s
 
trend across multiple periods, both in terms of the slope
 
and volatility of the trend. It also compares
 
the value of the ratio for
the most recent period
 
with the quartile values for
 
a comparable peer group.
 
Moreover,
 
MRA is supplied with a commonly
 
used set
of qualitative
 
factors
 
relating to
 
the quality
 
of the company’s
 
management, the
 
standing of
 
the company,
 
including the
 
company’s
Notes to the Consolidated Financial Statements
 
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transaction behavior towards the Bank, and the
 
perceived riskiness of the
 
industry. MRA is used for the assessment
 
of all legal entities
with full accountancy tax books irrespective
 
of their legal form, and is calibrated
 
on the Greek corporate environment.
The MRA is
 
not employed
 
for certain
 
types of entities
 
that use different
 
accounting methods
 
to prepare
 
their financial statements,
such as Insurance companies and brokerage firms. Moreover,
 
entities such as start-ups that have not produced financial information
for at least
 
two annual accounting periods
 
are not rated
 
with MRA. In such cases, the
 
Internal Credit Rating
 
(“ICR”) is utilized, which
is
 
a
 
scorecard
 
consisting
 
of
 
a
 
set
 
of
 
factors
 
grouped
 
into
 
3
 
main
 
sections
 
corresponding
 
to
 
particular
 
areas
 
of
 
analysis:
 
Financial
Information,
 
Qualitative
 
Criteria,
 
and
 
Behavior
 
Analysis.
 
In
 
addition,
 
the
 
Group
 
performs
 
an
 
overall
 
assessment
 
of
 
wholesale
customers, based both on their rating
 
(MRA or ICR) and the collaterals and guarantees
 
regularly at every credit assessment. In 2021,
in
 
combination
 
with
 
the
 
application
 
of
 
the
 
new
 
Definition
 
of
 
Default,
 
the
 
Bank
 
calibrated
 
its
 
MRA
 
and
 
ICR
 
models,
 
which
 
were
approved by the regulatory authorities.
With reference to Specialized Lending portfolio (for which the Bank is using Slotting rating models) and in line with European Banking
Authority (EBA) definitions, it comprises types of
 
exposures towards entities specifically created to finance or operate physical assets,
where the primary source of
 
income and repayment
 
of the obligation lies directly
 
with the assets being financed. Accordingly,
 
three
of its
 
product lines
 
that are
 
included in
 
the Specialized
 
Lending exposure
 
class: Project
 
Finance (assessed
 
with the
 
Project Finance
Scorecard), Commercial Real Estate
 
(assessed with the CRE investor & CRE Developer
 
Scorecards) and Object Finance (assessed with
the Object Finance Scorecard tailored for
 
the Shipping portfolio).
In addition, the
 
Group has developed
 
an Unlikely to Pay/Impairment test. Unlikeliness
 
to pay refers to circumstances when
 
a Borrower
is assessed as unlikely
 
to pay its credit
 
obligations in full without
 
realization of collateral,
 
regardless of the existence
 
of any past due
amount or of the days past due (i.e. to exposures less than 90 dpd). The impairment test , which is performed to all borrowers during
every credit assessment is implemented in the CL platform
 
and includes clearly defined indicators of unlikeliness to
 
pay (UTP). These
indicators are separated
 
in “Hard” and “Soft” UTP triggers.
Hard UTP indicators
 
lead directly to
 
a recognition of
 
non-performing (automatic
 
NPE classification), as
 
in most cases these
events, by their very nature, directly fulfil the definition
 
of UTP and there is little room for interpretation.
Soft
 
UTP
 
triggers
 
when
 
applied,
 
do
 
not
 
automatically
 
mean
 
that
 
an
 
exposure
 
is
 
non-performing,
 
but
 
that
 
a
 
thorough
assessment should be performed (assessment prior to
 
NPE classification).
The Group has further enhanced
 
its wholesale credit risk assessment
 
models linking risk parameters estimation with macro-economic
factors allowing the forecasting
 
of rating transitions under different
 
macroeconomic scenarios (base, adverse and optimistic).
The rating systems described
 
above are an integral part of the wholesale banking decision-making
 
and risk management processes:
the credit approval or rejection, both at the origination
 
and review process;
the allocation of competence levels for
 
credit approval;
risk-adjusted pricing;
the calculation of Economic Value
 
Added (EVA) and internal capital
 
allocation; and
the impairment calculation (staging criteria and
 
subsequent ECL estimation of forecasted
 
risk parameters).
Rating of retail lending exposures
The Group
 
assigns credit
 
scores to
 
its retail
 
customers
 
using a
 
number of
 
statistically-based
 
models both
 
at the
 
origination and
 
on
ongoing basis
 
through behavioral
 
scorecards.
 
These models have
 
been developed
 
to predict,
 
on the
 
basis of available
 
information,
the probability of default, the loss given default and the exposure at default. They cover the entire spectrum of retail products (credit
cards, consumer lending, unsecured revolving credits,
 
car loans, personal loans, mortgages and small business loans).
The
 
Bank’s
 
models
 
were
 
developed
 
based
 
on
 
historical
 
data
 
and
 
credit
 
bureau
 
data.
 
Behavioral
 
scorecards
 
are
 
calculated
automatically on a monthly basis, thus ensuring that the credit risk
 
assessment is up to date.
The
 
models
 
are
 
applied
 
in
 
the
 
credit
 
approval
 
process,
 
the
 
credit
 
limits
 
management,
 
as
 
well
 
as
 
the
 
collection
 
process
 
for
 
the
prioritization of the accounts in
 
terms of handling. Furthermore, the
 
models are often used
 
for the risk segmentation of
 
the customers
and the
 
risk based
 
pricing of
 
particular segments
 
or new
 
products
 
introduced
 
as well
 
as in
 
the calculation
 
of the
 
Economic
 
Value
Added (EVA) and Risk Adjusted Return
 
on Capital (RaRoC) measures.
Notes to the Consolidated Financial Statements
 
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In the context of IFRS9 implementation, the Bank
 
has further enhanced its retail credit
 
risk assessment models linking risk
 
parameters
estimation with macro-economic factors allowing their
 
forecasting over one year and
 
lifetime horizon under different macroeconomic
scenarios (base, adverse and optimistic) and supporting the staging analysis and allocation to risk classes under homogeneous pools.
The Group
 
Credit Risk
 
Capital Adequacy
 
Control
 
monitors the
 
capacity of
 
rating
 
models and
 
scoring systems
 
to classify
 
customers
according to
 
risk, as well as
 
to predict the
 
probability of default
 
and loss given
 
default and exposure
 
at default on
 
an ongoing basis.
The
 
Group
 
Models
 
Validation
 
and
 
Governance
 
implements
 
the
 
Bank's
 
validation
 
policy
 
which
 
complies
 
with
 
international
 
best
practices and regulatory requirements. The Bank verifies the validity of the rating models and scoring systems on an annual basis and
the validation includes both quantitative and qualitative aspects. The validation procedures
 
are documented, and regularly reviewed
and reported to the BRC.
The Group’s Internal
 
Audit also independently reviews the validation
 
process in wholesale and retail rating systems
 
annually.
(f) Credit risk mitigation
A key component of the Group's business strategy is to reduce risk by utilizing various risk mitigating techniques. The most important
risk mitigating means are collaterals'
 
pledges, guarantees and master
 
netting arrangements.
Types of collateral commonly accepted
 
by the Group
The Group has internal
 
policies in place
 
which set out
 
the following types of
 
collateral that are usually accepted
 
in a credit
 
relationship:
residential real estate,
 
commercial real estate (offices, shopping malls, etc.),
 
industrial buildings and land;
receivables (trade debtors)
 
and post dated cheques;
securities, including listed shares and bonds;
deposits;
guarantees and letters
 
of support;
insurance policies; and
equipment, mainly, vehicles
 
and vessels.
A specific
 
coverage
 
ratio
 
is pre-requisite,
 
upon the
 
credit relationship’s
 
approval and
 
on ongoing
 
basis, for
 
each collateral
 
type, as
specified in the Group’s credit
 
policy.
For
 
exposures,
 
other than
 
loans to
 
customers
 
(i.e. reverse
 
repos,
 
derivatives),
 
the
 
Group
 
accepts as
 
collateral
 
only
 
cash or
 
liquid
bonds.
Valuation principles of collaterals
In defining
 
the maximum
 
collateral
 
ratio for
 
loans, the
 
Group considers
 
all relevant
 
information available,
 
including the
 
collaterals’
specific characteristics,
 
if market
 
participants
 
would
 
take
 
those into
 
account
 
when
 
pricing the
 
relevant
 
assets.
 
The valuation
 
and
hence eligibility is based on the following factors:
the collateral’s
 
fair value, i.e. the
 
exit price that
 
would be received
 
to sell the asset
 
in an orderly transaction
 
under current
market conditions;
the fair
 
value reflects
 
market participants’
 
ability to
 
generate economic
 
benefits by
 
using the
 
asset in
 
its highest
 
and best
use or by selling it;
a reduction in the collateral’s
 
value is considered if the type, location or condition (such as deterioration
 
and obsolescence)
of the asset indicate so; and
no collateral value is assigned if a pledge is not
 
legally enforceable.
The
 
Group
 
performs
 
collaterals’
 
valuation
 
in
 
accordance
 
with
 
its
 
processes
 
and
 
policies.
 
The
 
Group
 
has
 
an
 
approved
 
list
 
of
independent and qualified appraisers, which is updated on an annual basis or at shorter intervals if necessary.
 
With the exception of
special cases (e.g. syndicated
 
loans), the real estate collaterals
 
of all units are valued by
 
Cerved Property Services S.A. (“CPS”) who is
the successor
 
of the Bank’s
 
former subsidiary,
 
Eurobank Property
 
Services S.A. CPS
 
is regulated
 
by the
 
Royal Institute
 
of Chartered
Surveyors
 
and
 
employs
 
internal
 
or
 
external
 
qualified
 
appraisers
 
based
 
on
 
predefined
 
criteria
 
(qualifications
 
and
 
expertise).
 
All
appraisals
 
take
 
into
 
account
 
factors
 
such
 
as
 
the
 
region,
 
age
 
and
 
marketability
 
of
 
the
 
property,
 
and
 
are
 
further
 
reviewed
 
and
countersigned by experienced staff.
 
The valuation methodology employed is based on International
 
Valuation Standards
 
(IVS), while
Notes to the Consolidated Financial Statements
 
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quality controls are in place, such as reviewing mechanisms, independent
 
sample reviews by independent well established
 
valuation
companies.
In order to monitor the valuation of residential property held as collateral, the Group uses the Residential Property Index of the Bank
of Greece. The
 
index has been
 
created by
 
the Real Estate
 
Market Analysis
 
Section of BoG using
 
detailed information
 
collected from
all Credit
 
Institutions
 
and Real
 
Estate
 
Investment
 
Companies (REIC)
 
operating
 
in Greece.
 
The Residential
 
Property
 
Index is
 
used in
combination with physical inspection and desktop
 
valuation, depending on the EBA status and the
 
balance of the loan.
For commercial
 
real
 
estates,
 
the Group
 
uses the
 
Commercial Real
 
Estate
 
Index developed
 
by CPS.
 
This index
 
is derived
 
through
 
a
combination of CPS & BoG CRE indices and it is
 
based on internationally accepted methodology. It constitutes a tool for the statistical
monitoring
 
of possible
 
changes of
 
the values
 
of the
 
commercial properties
 
as well
 
as for
 
the trends
 
in the
 
particular market.
 
The
Commercial Real
 
Estate
 
Index is
 
used in
 
combination with
 
physical inspection
 
and desktop
 
valuation, depending
 
on the
 
EBA status
and the balance of the loan.
To ensure
 
the quality of the post-dated cheques
 
accepted as collateral, the Bank has developed
 
a pre-screening system, which
 
takes
into
 
account
 
a
 
number
 
of
 
criteria
 
and
 
risk
 
parameters,
 
so
 
as
 
to
 
evaluate
 
their
 
eligibility.
 
Furthermore,
 
the
 
post-dated
 
cheques’
valuation is monitored through
 
the use of advanced statistical
 
reports and through the review
 
of detailed information
 
regarding the
recoverability of cheques, referrals
 
and bounced cheques, per issuer broken down.
Collateral policy and documentation
Regarding collaterals, Group’s
 
policy emphasizes the need that collaterals and relevant processes are timely and prudently executed,
in
 
order
 
to
 
ensure
 
that
 
collaterals
 
and relevant
 
documentation
 
are
 
legally
 
enforceable
 
at
 
any
 
time. The
 
Group
 
holds the
 
right
 
to
liquidate collateral in the event
 
of the obligor’s financial
 
distress and can claim
 
and control cash proceeds
 
from the liquidation process.
Guarantees
The guarantees used as credit risk mitigation
 
by the Group are largely issued by central and
 
regional governments in the countries in
which
 
it
 
operates.
 
The
 
Hellenic
 
Development
 
Bank
 
(HDB)
 
and
 
similar
 
funds,
 
banks
 
and
 
insurance
 
companies
 
are
 
also
 
significant
guarantors of credit risk.
Management of repossessed properties
The
 
objective
 
of
 
the
 
repossessed
 
assets’
 
management
 
is
 
to
 
minimize
 
the
 
time
 
cycle
 
of
 
the
 
asset’s
 
disposal
 
and
 
to
 
maximize
 
the
recovery of the capital engaged.
To this
 
end, the management of repossessed assets
 
aims at improving rental
 
and other income from the
 
exploitation of such assets,
and at the
 
same time reducing
 
the respective holding and
 
maintenance costs. Additionally, the Group is
 
actively engaged in identifying
suitable potential buyers for its portfolio of repossessed assets (including specialized funds involved
 
in acquiring specific portfolios of
properties repossessed), both in Greece and abroad,
 
in order to reduce its stock of properties with a time horizon
 
of 3-5 years.
Repossessed assets are closely monitored based on technical and
 
legal due diligence reports, so that their market value
 
is accurately
reported and updated in accordance with market
 
trends.
Counterparty risk
The
 
Group
 
mitigates
 
counterparty
 
risk
 
arising
 
from
 
treasury
 
activities
 
by
 
entering
 
into
 
master
 
netting
 
arrangements
 
and
 
similar
agreements, as well
 
as collateral agreements
 
with counterparties with
 
which it undertakes
 
a significant volume
 
of transactions. The
respective credit risk is reduced through a master netting agreement to the extent that if an event of default occurs, all amounts with
the counterparty are terminated and
 
settled on a net basis.
In the case of
 
derivatives, the Group
 
makes use of
 
International Swaps
 
and Derivatives Association
 
(ISDA) contracts,
 
which limit the
exposure
 
via
 
the
 
application
 
of
 
netting,
 
and
 
Credit
 
Support
 
Annex
 
(CSAs),
 
which
 
further
 
reduce
 
the
 
total
 
exposure
 
with
 
the
counterparty. Under these agreements, the total exposure with the counterparty is calculated on a daily
 
basis taking into account any
netting arrangements and collaterals.
The same
 
process is
 
applied in
 
the case
 
of repo
 
transactions where
 
standard
 
Global Master
 
Repurchase
 
Agreements
 
(GMRAs) are
used. The exposure
 
(the net difference
 
between repo
 
cash and the
 
market value
 
of the securities)
 
is calculated
 
on a daily basis
 
and
collateral is transferred
 
between the counterparties thus minimizing the exposure.
 
Notes to the Consolidated Financial Statements
 
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Following
 
the
 
European
 
Market
 
Infrastructure
 
Regulation
 
(EMIR),
 
the
 
Bank
 
performs
 
centrally
 
cleared
 
transactions
 
for
 
eligible
derivative contracts
 
through an EU
 
authorized European
 
central counterparty
 
(CCP), recorded
 
in trade
 
repositories. The
 
use of CCP
increases market transparency
 
and reduces counterparty credit and operational
 
risks inherent in derivatives markets.
The Bank uses a comprehensive
 
collateral management
 
system for
 
the monitoring of ISDA, CSAs
 
and GMRAs, i.e. the daily valuation
of the derivatives
 
and the market value
 
of the securities are used for
 
the calculation of each counterparty’s
 
exposure. The collateral
which should be posted or requested by the relevant
 
counterparty is calculated daily.
With
 
this
 
system,
 
the
 
Bank
 
monitors
 
and
 
controls
 
the
 
collateral
 
flow
 
in
 
case
 
of
 
derivatives
 
and
 
repos,
 
independently
 
of
 
the
counterparty. The effect of any market
 
movement that increases the Bank’s exposure is reported and the Bank proceeds to collateral
call accordingly.
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
5.2.1.1 Maximum exposure to credit
 
risk before collateral held
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Credit risk exposures relating to on-balance sheet assets
 
are as
follows:
Due from credit institutions
2,197
2,355
Less: Impairment allowance
(1)
2,196
(1)
2,354
Debt securities held for trading
186
245
Derivative financial instruments
838
881
Loans and advances to customers at
 
amortised cost:
- Wholesale lending⁽¹⁾
31,663
25,912
- Mortgage lending
12,466
9,942
- Consumer lending
4,533
3,436
- Small business lending
3,583
3,484
Less: Impairment allowance
(1,309)
50,936
(1,258)
41,516
Fair value changes of loans in portfolio hedging of
 
interest rate risk
(3)
15
Loans and advances to customers measured
 
at FVTPL
19
15
Investment securities:
- Debt securities measured at amortised cost
17,677
10,974
Less: Impairment allowance
(26)
17,651
(18)
10,955
Debt securities measured at FVOCI
4,148
3,492
Investment securities at FVTPL
384
263
Other financial assets⁽²⁾
149
218
Less: Impairment allowance
(23)
126
(22)
196
Credit risk exposures relating to off-balance
 
sheet items (note 43):
- Loan commitments
10,489
8,068
- Financial guarantee contracts and
 
other commitments
3,517
3,348
Total
90,487
71,348
(1)
Includes loans to public sector.
(2)
Refers to financial assets subject to IFRS 9 impairment requirements, which are recognised within other assets
 
The above table represents the Group’s
 
maximum credit risk exposure as at 31 December 2024 and
 
31 December 2023 respectively,
without taking
 
account
 
of any
 
collateral
 
held or
 
other credit
 
enhancements
 
that
 
do not
 
qualify for
 
offset
 
in the
 
Group's
 
financial
statements.
For on-balance
 
sheet assets,
 
the exposures
 
set out above
 
are based
 
on the carrying
 
amounts as reported
 
in the balance
 
sheet. For
off-balance
 
sheet
 
items,
 
the
 
maximum
 
exposure
 
is
 
the
 
nominal
 
amount
 
that
 
the
 
Group
 
may
 
be
 
required
 
to
 
pay
 
if
 
the
 
financial
guarantee contracts
 
and other commitments
 
are called upon
 
and the loan
 
commitments are drawn
 
down. Off-balance
 
sheet credit
risk exposures
 
presented
 
above, include
 
revocable loan
 
commitments to
 
extend credit
 
of €
 
4.7 billion
 
(2023: €
 
3.5 billion)
 
that are
subject to ECL measurement.
 
 
 
doc1p253i0 doc1p253i1
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
5.2.1.2
 
Loans and advances to customers
The section below provides an
 
overview of the Group’s exposure to credit risk arising
 
from its customer lending portfolios, in line
 
with
the guidelines
 
set by
 
the Hellenic
 
Capital
 
Markets
 
Commission and
 
the Bank
 
of Greece
 
(BoG) released
 
on 30
 
September 2013,
 
as
updated by the Group
 
in order to comply with
 
the revised IFRS 7 ‘Financial
 
Instruments: Disclosures’,
 
following the adoption of
 
IFRS
9
 
from
 
2018.
 
In
 
addition,
 
the
 
types
 
of
 
the
 
Group’s
 
forbearance
 
programs
 
are
 
in
 
line
 
with
 
the
 
BoG’s
 
Executive
 
Committee
 
Act
42/30.05.2014 and its amendments.
(a) Credit quality of loans and advances to customers
Loans and advances to customers carried
 
at amortised cost are classified depending on how ECL is measured.
Accordingly,
 
loans reported
 
as non-impaired
 
include loans
 
for
 
which a
 
‘12-month
 
ECL allowance’
 
is recognized
 
as they
 
exhibit
 
no
significant increase in credit risk since initial recognition and loans for which a ‘Lifetime ECL allowance’
 
is recognized as they exhibit a
significant increase in credit risk since initial recognition
 
but are not considered to be in default.
Credit impaired loans category includes loans that are considered to be in default, for which a loss allowance equal to a ‘Lifetime ECL’
is recognized,
 
and loans
 
classified as ’Purchased
 
or originated
 
credit impaired’
 
(POCI) which are
 
always measured
 
on the
 
basis of a
‘Lifetime
 
ECL’.
 
The
 
Group
 
applies
 
a
 
default
 
definition
 
for
 
accounting
 
purposes,
 
which
 
is
 
consistent
 
with
 
the
 
European
 
Banking
Authority (EBA) definition for non-performing
 
exposure and regulatory definition of default.
Loans
 
and
 
advances
 
to
 
customers
 
carried
 
at
 
FVTPL
 
are
 
not
 
subject
 
to
 
ECL
 
measurement
 
and
 
therefore
 
are
 
not
 
included
 
in
 
the
quantitative information provided in the below sections for loans and advances measured at amortised cost, except where indicated.
The Group’s accounting
 
policy for impairment of financial assets is set out in note 2.2.13.
Quantitative information
The
 
following
 
quantitative
 
analysis
 
presents
 
information
 
about
 
the
 
total
 
gross
 
carrying
 
amount
 
of
 
loans
 
and
 
advances
 
including
securitization
 
notes
 
issued
 
by
 
special
 
purpose
 
entities
 
established
 
by
 
the
 
Group,
 
and
 
the
 
nominal
 
amount
 
of
 
credit
 
related
commitments, that are
 
classified as non-impaired (stage
 
1 and stage
 
2) and those classified as
 
credit-impaired (stage
 
3 and POCI). It
also presents
 
the impairment
 
allowance recognized
 
in respect of
 
all loans and
 
advances and
 
credit related
 
commitments, analyzed
into individually or
 
collectively assessed, based
 
on how the
 
respective impairment allowance has
 
been calculated, the
 
carrying amount
of
 
loans
 
and advances,
 
as well
 
as
 
the
 
value
 
of
 
collateral
 
held to
 
mitigate
 
credit
 
risk
 
which is
 
capped
 
to
 
the respective
 
gross
 
loan
amount. In particular,
 
the following four tables for 2024 and
 
2023
 
provide:
a
 
summary
 
of
 
the
 
credit
 
quality
 
of
 
lending
 
exposures
 
and
 
credit
 
related
 
commitments,
 
presenting
 
product
 
line,
 
stage
allocation, respective impairment allowance and
 
collateral held
the classification of lending exposures and credit related
 
commitments into the internal credit rating
 
categories,
the movement of the gross carrying amounts for
 
loans and advances to customers by product line and
 
stage,
the ageing analysis of credit impaired (Stage 3 and
 
POCI) loans and advances to customers
Public Sector lending
 
exposures include exposures
 
to the central
 
government, local
 
authorities, state-linked
 
companies and entities
controlled and fully
 
or partially owned by the
 
state, excluding
 
public and private
 
companies with commercial activity.
 
For credit risk
management purposes, exposures to Public Sector
 
are incorporated in wholesale lending.
.
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
66
|
Page
 
31 December 2024 Consolidated Financial Statements
The following tables present
 
summary information about the
 
credit quality (stage analysis,
 
impairment allowance and
 
collateral held per product
 
line) of loans
 
and advances to
 
customers carried at amortised
cost and
 
credit related
 
commitments.
 
In addition,
 
they include the
 
fair value
 
changes of
 
loans in
 
portfolio hedging
 
of interest
 
rate risk
 
and the loans
 
and advances
 
to customers
 
carried at
 
FVTPL for
 
the
purpose of reconciliation with the total carrying amount
 
of loan and advances to customers:
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Impairment allowance
Lifetime ECL - Stage 3
Lifetime ECL - Stage 3
12-month ECL -
Stage 1
Lifetime ECL -
Stage 2
Individually
assessed
Collectively
assessed
POCI
Total gross carrying
amount/nominal
exposure
12-month ECL -
Stage 1
Lifetime ECL -
Stage 2
Individually
assessed
Collectively
assessed
POCI
Carrying
amount
Value of
collateral
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
Retail Lending
15,743
3,733
62
715
329
20,582
(132)
(315)
(43)
(374)
(23)
19,695
14,806
- Mortgage
9,249
2,706
36
323
151
12,466
(64)
(218)
(30)
(147)
(10)
11,997
Value of collateral
9,090
2,405
20
258
147
11,919
- Consumer
3,064
317
1
127
152
3,660
(42)
(42)
(0)
(90)
(10)
3,475
Value of collateral
711
7
1
7
148
874
- Credit card
767
75
0
29
1
873
(8)
(5)
(0)
(23)
(1)
835
Value of collateral
29
1
0
0
1
30
- Small business
2,663
635
24
237
24
3,583
(17)
(50)
(13)
(113)
(1)
3,389
Value of collateral
1,296
507
13
142
24
1,982
Wholesale Lending
29,687
1,184
532
140
89
31,632
(58)
(39)
(244)
(77)
(4)
31,211
20,012
- Large corporate
20,189
568
272
17
38
21,082
(42)
(23)
(115)
(10)
(2)
20,889
Value of collateral
10,637
372
152
9
36
11,206
- SMEs
5,130
617
260
124
51
6,182
(16)
(16)
(129)
(67)
(2)
5,953
Value of collateral
3,653
468
188
78
51
4,438
- Securitization notes⁽²⁾
4,368
-
-
-
-
4,368
(0)
-
-
-
-
4,368
Value of collateral
4,368
-
-
-
-
4,368
Public Sector
30
-
-
0
1
31
(0)
-
-
(0)
-
30
4
- Greece
12
-
-
0
-
13
(0)
-
-
(0)
-
12
Value of collateral
-
-
-
0
-
0
- Other countries
18
-
-
-
1
18
(0)
-
-
-
-
18
Value of collateral
3
-
-
-
0
4
Fair value changes of loans in portfolio
 
hedging of
interest rate risk
(3)
Loans and advances to customers at
 
FVTPL
 
19
19
Total
45,460
4,917
593
856
419
52,245
(191)
(354)
(287)
(451)
(27)
50,953
34,841
Total value of collateral
 
29,787
3,760
373
495
407
Credit related commitments
 
13,645
263
39
26
33
14,005
(22)
(4)
(21)
(7)
(9)
Loan commitments
10,256
212
7
7
6
10,489
(15)
(4)
(0)
(0)
(1)
Financial guarantee contracts and
 
other
commitments
3,389
50
32
19
26
3,517
(7)
(1)
(21)
(6)
(8)
Value of collateral
2,077
74
20
5
11
 
 
 
doc1p253i0 doc1p253i1
 
Notes to the Consolidated Financial Statements
 
.
67
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
 
Impairment allowance
Lifetime ECL - Stage 3 and POCI⁽¹⁾
Lifetime ECL - Stage 3 and POCI⁽¹⁾
12-month ECL -
Stage 1
Lifetime ECL - Stage 2
Individually
assessed
Collectively
assessed
Total gross carrying
amount/nominal
exposure
12-month ECL -
Stage 1
Lifetime ECL - Stage 2
Individually
assessed
Collectively
assessed
Carrying amount
Value of
collateral
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
Retail Lending
12,331
3,716
85
730
16,861
(99)
(272)
(60)
(381)
16,050
11,385
- Mortgage
6,909
2,618
39
376
9,942
(20)
(154)
(33)
(175)
9,560
Value of collateral
6,726
2,237
16
310
9,289
- Consumer
2,242
297
1
102
2,642
(45)
(48)
(1)
(84)
2,463
Value of collateral
132
1
1
0
133
- Credit card
701
73
0
20
794
(8)
(4)
(0)
(19)
762
Value of collateral
0
0
0
0
0
- Small business
2,480
728
45
231
3,484
(25)
(65)
(26)
(102)
3,265
Value of collateral
1,246
547
23
147
1,962
Wholesale Lending
23,987
1,198
539
169
25,893
(71)
(58)
(219)
(99)
25,447
16,621
- Large corporate
15,791
544
232
27
16,593
(47)
(30)
(85)
(12)
16,420
Value of collateral
8,370
395
150
10
8,926
- SMEs
3,752
654
307
142
4,856
(25)
(28)
(134)
(86)
4,584
Value of collateral
2,429
517
220
86
3,252
- Securitization notes⁽²⁾
4,444
-
-
-
4,444
(0)
-
-
-
4,444
Value of collateral
4,444
-
-
-
4,444
Public Sector
18
0
-
0
19
(0)
(0)
-
(0)
18
1
- Greece
18
-
-
0
18
(0)
-
-
(0)
18
Value of collateral
1
-
-
0
1
- Other countries
0
0
-
-
0
(0)
(0)
-
-
0
Value of collateral
-
-
-
-
-
Fair value changes of loans in portfolio
 
hedging of
interest rate risk
15
Loans and advances to customers
 
at FVTPL
 
15
15
Total
36,336
4,914
624
899
42,773
(170)
(329)
(279)
(480)
41,545
28,022
Total value of collateral
 
23,348
3,697
409
553
Credit related commitments
 
11,049
311
36
20
11,416
(18)
(4)
(20)
(6)
Loan commitments
7,801
259
6
2
8,068
(11)
(3)
-
-
Financial guarantee contracts and
 
other
commitments
3,247
51
31
19
3,348
(7)
(1)
(20)
(6)
Value of collateral
1,193
101
14
7
(1)
 
As at 31 December 2023, total gross carrying amount of credit impaired loans includes POCI loans
 
of € 29 million and carry an impairment allowance of € 8.1 million.
(2)
 
It refers to the
 
notes of securitizations of
 
loans originated by Group
 
entities measured at amortised
 
cost, that are collateralized by
 
the underlying pool
 
of loans held by
 
the respective securitization
 
vehicles (note 20). The
 
amount of the securitized
loan portfolios presented as collateral has been capped to the gross carrying amount
 
of the senior notes. Moreover, the senior notes of the Cairo and Mexico securitizations are guaranteed by the Hellenic Republic in the context of Hellenic Asset
Protection Scheme (note 20). The respective approval for the senior note of Leon securitization is in progress
 
and expected shortly.
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
68
|
Page
 
31 December 2024 Consolidated Financial Statements
The Group assesses the credit quality of its loans and advances to customers
 
and credit related commitments that are subject to
 
ECL
using internal credit
 
rating systems
 
for the wholesale
 
portfolio, which
 
are based on
 
a variety of quantitative
 
and qualitative factors,
while the credit quality of the retail portfolio is based
 
on the allocation of risk classes into homogenous pools.
 
The following tables present the distribution
 
of the gross carrying amount of loans and advances and the nominal exposure
 
of credit
related commitments based on the credit quality
 
classification categories and stage allocation:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Internal credit rating
12-month
ECL-Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL -
Stage 3
POCI
Total gross
carrying
amount
Retail Lending
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
- Mortgage
PD<2.5%
8,905
1,534
-
33
10,471
2.5%<=PD<4%
197
18
-
0
215
4%<=PD<10%
93
754
-
7
854
10%<=PD<16%
43
148
-
3
194
16%<=PD<99.99%
12
252
-
4
269
100%
-
-
359
104
463
- Consumer
PD<2.5%
995
2
-
15
1,012
2.5%<=PD<4%
1,484
4
-
14
1,502
4%<=PD<10%
443
34
-
20
497
10%<=PD<16%
103
12
-
4
119
16%<=PD<99.99%
38
264
-
8
310
100%
-
-
128
92
219
- Credit card
PD<2.5%
353
2
-
0
355
2.5%<=PD<4%
381
25
-
-
406
4%<=PD<10%
31
16
-
0
47
10%<=PD<16%
1
4
-
0
5
16%<=PD<99.99%
0
28
-
0
28
100%
-
-
29
1
30
- Small business
PD<2.5%
1,563
21
-
1
1,585
2.5%<=PD<4%
696
32
-
0
728
4%<=PD<10%
374
355
-
0
729
10%<=PD<16%
28
148
-
3
179
16%<=PD<99.99%
2
79
-
0
81
100%
-
-
261
20
280
Wholesale Lending
- Large corporate
Strong
14,005
29
-
-
14,034
Satisfactory
5,898
360
-
9
6,268
Watch list
285
178
-
12
475
Impaired (Defaulted)
-
-
288
17
305
- SMEs
Strong
1,593
24
-
0
1,616
Satisfactory
3,334
312
-
14
3,661
Watch list
203
281
-
9
493
Impaired (Defaulted)
-
-
383
28
412
- Securitization notes
 
Strong
4,368
-
-
-
4,368
Public Sector
All countries
Strong
13
-
-
-
13
Satisfactory
17
-
-
1
18
Watch list
-
-
-
-
-
Impaired (Defaulted)
-
-
0
-
0
Total
45,460
4,917
1,449
419
52,245
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
69
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Internal credit rating
12-month ECL -
Stage 1
Lifetime ECL -
Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
Total gross
carrying amount
Retail Lending
€ million
 
€ million
 
€ million
 
€ million
 
- Mortgage
PD<2.5%
6,587
1,282
0
7,869
2.5%<=PD<4%
196
69
0
265
4%<=PD<10%
105
874
0
980
10%<=PD<16%
14
192
0
206
16%<=PD<99.99%
7
201
1
209
100%
-
-
414
414
- Consumer
PD<2.5%
512
0
-
512
2.5%<=PD<4%
700
21
-
721
4%<=PD<10%
945
29
0
975
10%<=PD<16%
54
74
-
129
16%<=PD<99.99%
30
172
0
202
100%
-
-
103
103
- Credit card
PD<2.5%
335
1
-
337
2.5%<=PD<4%
338
26
0
364
4%<=PD<10%
27
15
-
42
10%<=PD<16%
-
3
0
3
16%<=PD<99.99%
-
27
-
27
100%
-
-
20
20
- Small business
PD<2.5%
912
26
-
938
2.5%<=PD<4%
715
161
-
876
4%<=PD<10%
825
381
-
1,206
10%<=PD<16%
1
67
-
68
16%<=PD<99.99%
26
93
-
119
100%
-
-
276
276
Wholesale Lending
- Large corporate
Strong
11,391
1
-
11,392
Satisfactory
4,197
377
10
4,583
Watch list
204
166
-
369
Impaired (Defaulted)
-
-
249
249
- SMEs
Strong
1,194
19
-
1,213
Satisfactory
2,401
334
0
2,735
Watch list
157
301
-
458
Impaired (Defaulted)
-
-
450
450
- Securitization notes
 
Strong
4,444
-
-
4,444
Public Sector
All countries
Strong
18
-
-
18
Satisfactory
1
-
-
1
Watch list
-
0
-
0
Impaired (Defaulted)
-
-
0
0
Total
36,336
4,914
1,523
42,773
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
70
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
31 December 2023
Internal credit rating
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
Total
nominal
amount
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
Total
nominal
amount
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
Credit Related
Commitments
 
Retail Lending
Loan commitments
PD<2.5%
1,571
8
0
1,579
1,084
6
-
1,090
2.5%<=PD<4%
1,571
45
0
1,615
1,356
46
-
1,401
4%<=PD<10%
492
51
0
544
574
97
-
671
10%<=PD<16%
41
12
0
54
47
18
-
64
16%<=PD<99.99%
0
28
0
28
0
30
-
30
100%
-
-
4
4
-
-
2
2
Financial guarantee
contracts and other
commitments
PD<2.5%
38
0
0
38
14
-
-
14
2.5%<=PD<4%
118
0
-
118
136
0
-
136
4%<=PD<10%
38
1
-
39
29
1
-
30
10%<=PD<16%
-
-
-
-
5
0
-
6
16%<=PD<99.99%
-
-
-
-
1
-
-
1
100%
-
-
6
6
-
-
2
2
Wholesale Lending
Loan commitments
Strong
4,184
2
-
4,185
3,738
1
-
3,739
Satisfactory
2,339
57
1
2,397
978
56
-
1,034
Watch list
58
9
0
67
25
7
-
31
Impaired
(Defaulted)
-
-
15
15
-
-
6
6
Financial guarantee
contracts and other
commitments
Strong
2,396
1
-
2,398
2,017
1
-
2,018
Satisfactory
728
27
-
755
987
31
-
1,018
Watch list
70
21
-
91
57
19
-
77
Impaired
(Defaulted)
-
-
72
72
-
-
48
48
Total
13,645
263
98
14,005
11,049
311
57
11,416
The table below depicts the internal credit rating
 
bands (MRA rating scale or equivalent)
 
for the wholesale portfolio that correspond
to the credit quality classification categories
 
presented in the above tables:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale Lending
Credit Quality classification
categories
Internal Credit Rating
 
 
Large Corporate
 
Internal Credit Rating
 
SMEs
Strong
1-4
1-3
Satisfactory
5-6
4-6
Watch list
7-9
7-9
Impaired (Defaulted)
10
10
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
71
|
Page
 
31 December 2024 Consolidated Financial Statements
The following tables present the movement of the gross carrying
 
amounts for loans and advances to customers
 
by product line and stage and is calculated by reference
 
to the opening and closing balances
for the reporting years from 1 January
 
2024 to 31 December 2024 and 1 January 2023 to 31 December 2023:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Wholesale
Mortgage
Consumer
Small business
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
POCI
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
POCI
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
POCI
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
POCI
Total
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
Gross carrying amount at 1
January
24,005
1,198
688
21
6,909
2,618
411
4
2,942
369
119
5
2,480
728
276
0
42,773
New loans and advances
originated or purchased
 
8,427
-
-
-
1,090
-
-
-
1,189
-
-
-
674
-
-
-
11,380
Arising from acquisition (note
23.2)
2,593
-
-
71
2,229
-
-
159
617
-
-
160
111
-
-
27
5,965
Securitization notes (note 20)
281
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
281
Transfers between
 
stages
-to 12-month ECL
 
265
(257)
(8)
-
107
(97)
(10)
-
116
(105)
(10)
-
99
(91)
(9)
-
-
-to lifetime ECL
(672)
689
(17)
-
(354)
436
(82)
-
(218)
240
(22)
-
(110)
157
(47)
-
-
-to lifetime ECL credit-impaired
loans
(82)
(54)
136
-
(66)
(136)
203
-
(75)
(49)
124
-
(59)
(89)
148
-
-
Loans and advances
derecognised/ reclassified as
held for sale during the year
(25)
-
(21)
-
(7)
(1)
(133)
-
(4)
(0)
(15)
(3)
(0)
(1)
(70)
-
(279)
Amounts written-off⁽¹⁾
-
-
(14)
(0)
-
-
(9)
(1)
-
-
(47)
(1)
-
-
(13)
(0)
(84)
Repayments
(5,092)
(428)
(83)
(6)
(992)
(209)
(42)
(14)
(823)
(61)
(33)
(14)
(625)
(93)
(35)
(6)
(8,556)
Foreign exchange differences
and other movements
17
36
(9)
5
334
96
21
3
88
(4)
41
7
93
23
11
4
766
Gross Carrying amount at 31
December
29,717
1,184
672
90
9,249
2,706
359
151
3,831
392
157
153
2,663
635
261
24
52,245
Impairment allowance
(58)
(39)
(321)
(4)
(64)
(218)
(177)
(10)
(51)
(48)
(114)
(11)
(17)
(50)
(126)
(1)
(1,309)
Carrying amount at 31
December
29,659
1,145
351
86
9,185
2,489
182
141
3,780
344
43
142
2,645
585
135
23
50,936
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
72
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Wholesale
Mortgage
Consumer
Small business
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI
Total
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
 
€ million
Gross carrying amount at 1
January
23,448
1,581
1,024
6,832
2,825
545
2,669
427
257
2,668
740
434
43,450
New loans and advances
originated or purchased
 
5,930
-
-
756
-
-
859
-
-
536
-
-
8,081
Arising from acquisition
-
-
-
-
-
-
443
-
6
-
-
-
450
Transfers
 
between stages
-to 12-month ECL
451
(443)
(8)
532
(520)
(12)
74
(65)
(9)
123
(116)
(7)
-
-to lifetime ECL
(363)
498
(135)
(392)
487
(95)
(84)
103
(18)
(186)
235
(49)
-
-to lifetime ECL credit-
impaired loans
(55)
(173)
228
(54)
(163)
217
(36)
(38)
74
(53)
(77)
130
-
Loans and advances
derecognised/ reclassified as
held for sale during the year
(696)
(53)
(29)
(180)
(11)
(174)
(465)
(91)
(129)
(104)
(23)
(155)
(2,109)
Amounts written-off⁽¹⁾
-
-
(216)
-
-
(46)
-
-
(62)
-
-
(62)
(387)
Repayments
(4,654)
(240)
(135)
(858)
(185)
(49)
(484)
(59)
(44)
(578)
(75)
(36)
(7,396)
Foreign exchange differences
and other movements
(55)
27
(21)
274
185
30
(33)
92
48
73
44
21
685
Gross Carrying amount at 31
December
24,005
1,198
709
6,909
2,618
415
2,942
369
124
2,480
728
276
42,773
Impairment allowance
(72)
(58)
(318)
(20)
(154)
(208)
(53)
(53)
(105)
(25)
(65)
(128)
(1,258)
Carrying amount at 31
December
23,934
1,140
391
6,888
2,464
207
2,890
317
19
2,454
663
148
41,515
(1)
The contractual amount outstanding on lending exposures that were written off during the year ended 31 December 2024 and that are
 
still subject to enforcement activity is € 68 million (2023: € 338 million).
Note 1: Wholesale product line category includes also Public sector loans portfolio.
Note 2: “Loans and advances derecognised/ reclassified as
 
held for sale during the year” presents loans
 
derecognized due to a) substantial
 
modifications of the loans’ contractual terms,
 
b) sale and securitization transactions, c) debt
 
to equity
transactions and those that have been reclassified as held for sale during the year
 
(notes 20 and 30).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
73
|
Page
 
31 December 2024 Consolidated Financial Statements
 
Credit impaired loans and advances to customers
The following
 
tables present
 
the ageing
 
analysis of
 
credit impaired
 
(Stage 3
 
and POCI)
 
loans and
 
advances by
 
product line
 
at their
gross carrying amounts, as well as the respective impairment
 
allowance and the value of collaterals held to
 
mitigate credit risk.
For denounced loans, the Group ceases to monitor the delinquency status and therefore the respective balances have
 
been included
in the ‘over 360 days’ time band, with the
 
exception of consumer exposures which continue to be monitored up to 360
 
days past due.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Retail lending
Wholesale lending
Public sector
Lifetime ECL
credit-impaired
Mortgage
Consumer
Credit card
Small
business
Large
corporate
SMEs
Greece and
other countries
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
up to 90 days
235
133
6
125
185
236
1
920
90 to 179 days
43
25
7
21
0
7
-
103
180 to 360 days
76
38
10
49
6
13
-
192
more than 360 days
156
84
8
90
135
179
0
653
Total gross carrying
amount
 
511
280
30
285
326
435
1
1,868
Impairment allowance
(188)
(101)
(24)
(127)
(127)
(197)
(0)
(765)
Carrying amount
 
323
179
6
158
199
238
1
1,103
Value of Collateral
425
156
1
179
198
316
0
1,275
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Retail lending
Wholesale lending
Public sector
Lifetime ECL
credit-impaired
Mortgage
Consumer
Credit card
Small
business
Large
corporate
SMEs
Greece and
other countries
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
up to 90 days
174
42
6
132
191
189
0
734
90 to 179 days
32
18
6
20
33
14
-
123
180 to 360 days
73
22
5
33
1
45
-
179
more than 360 days
136
21
3
91
33
202
0
487
Total gross carrying
amount
 
415
104
20
276
259
450
0
1,523
Impairment allowance
(208)
(86)
(19)
(128)
(98)
(220)
(0)
(759)
Carrying amount
 
207
18
1
148
161
230
0
764
Value of Collateral
326
1
0
169
160
306
0
962
Note: As at 31 December 2024, total gross carrying amount of credit impaired loans includes POCI loans
 
of € 419 million (2023: € 29 million).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
74
|
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31 December 2024 Consolidated Financial Statements
(b) Collaterals and repossessed assets
 
Collaterals
The Loan-to-Value
 
(LTV)
 
ratio of
 
the mortgage
 
lending reflects
 
the gross
 
loan exposure
 
at the
 
balance sheet
 
date over
 
the market
value of the property held as collateral.
The LTV ratio
 
of the mortgage portfolio is presented below:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Mortgages
Less than 50%
4,740
2,852
50%-70%
3,221
2,456
71%-80%
1,689
1,621
81%-90%
1,041
979
91%-100%
599
659
101%-120%
502
557
121%-150%
333
402
Greater than 150%
343
415
Total exposure
12,466
9,942
Average LTV
44.64%
55.18%
The breakdown of collateral
 
and guarantees for loans and advances to
 
customers at amortised cost is presented
 
below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Value of collateral received
Guarantees
received⁽¹⁾
Real Estate
Financial
 
Other
Total
 
€ million
€ million
€ million
€ million
€ million
Retail Lending
13,421
701
684
14,806
857
Wholesale Lending
6,864
1,601
11,547
20,012
613
Public sector
1
3
0
4
-
Total
20,285
2,306
12,231
34,822
1,470
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Value of collateral received
Guarantees
Received⁽¹⁾
Real Estate
Financial
 
Other
Total
 
€ million
€ million
€ million
€ million
€ million
Retail Lending
10,618
304
463
11,385
554
Wholesale Lending
 
5,300
877
10,444
16,621
632
Public sector
-
1
0
1
-
Total
15,919
1,181
10,907
28,007
1,186
(1)
In addition
 
to the
 
above presented
 
guarantees, the
 
Group has
 
entered into
 
financial guarantees
 
contracts (projects
 
‘Wave’)
 
related to
 
the portfolios
 
of
performing SME, SBB and large corporate loans of € 4.3 billion as at 31 December 2024 (31 December 2023: € 4
 
billion) (note 20).
The collaterals
 
presented in
 
the above table
 
under category
 
“Other”, include
 
assigned receivables,
 
equipment, inventories,
 
vessels,
etc. They
 
also include
 
the amount
 
of the securitized
 
loans held
 
by the
 
securitizations vehicles
 
that issued
 
the related
 
senior notes.
The amount of the securitized
 
loans has been capped to the
 
gross carrying amount of the
 
senior notes. In addition, the
 
senior notes
of the Cairo
 
and Mexico securitizations
 
are guaranteed
 
by the Hellenic
 
Republic in
 
the context
 
of Hellenic Asset
 
Protection Scheme
(note 20).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
75
|
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31 December 2024 Consolidated Financial Statements
 
Repossessed assets
The Group recognizes
 
collateral assets
 
on the balance
 
sheet by taking
 
possession usually through
 
legal processes or
 
by calling upon
other credit enhancements. As at 31 December
 
2024, the carrying amount of repossessed assets
 
which are included in “Other assets”
amounted to € 527 million
 
(31 December 2023: €
 
495 million), note 29. These
 
assets are carried at the lower of
 
cost and net realizable
value (note 2.2.19).
The main
 
type of
 
collateral
 
that the
 
Group repossesses
 
against
 
repayment
 
or reduction
 
of the
 
outstanding
 
loan is
 
real estate.
 
The
below
 
table
 
presents
 
the
 
movement
 
of
 
repossessed
 
real
 
estate
 
assets
 
during
 
the
 
year,
 
including
 
a)
 
those
 
transferred
 
to
 
the
appropriate category based on their use by the Group as part of its operations i.e. investment property or own-used (notes 2.2.6, 26,
and 27) and b) those reclassified to “held for sale” category
 
(notes 30).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
Real estate
 
Real estate
 
Residential
Commercial
Total
Residential
Commercial
Total
€ million
€ million
€ million
€ million
€ million
€ million
Balance at 1 January
195
298
493
212
345
557
Arising from acquisition (note 23.2)
4
105
109
-
-
-
Additions⁽¹⁾
7
26
33
11
17
28
Transfers
 
to investment property
(2)
(18)
(20)
(2)
-
(2)
Disposals
(14)
(45)
(59)
(12)
(27)
(39)
Valuation losses
(2)
(26)
(28)
(4)
(14)
(18)
Held for Sale (note 30)
(1)
(0)
(1)
(8)
(24)
(32)
Other
 
(0)
(2)
(2)
(2)
1
(1)
Balance at 31 December
187
338
525
195
298
493
(1)
 
The carrying amount
 
of the real
 
estate properties
 
obtained during the
 
year and held
 
at the year
 
ended 31
 
December 2024
 
amounted to €
 
32 million
 
(31
December 2023: € 24 million).
In addition, the Group
 
repossesses other types of
 
collaterals mainly
 
referring to
 
equity positions due to
 
the participation in debt
 
for
equity transactions as part of forbearance measures.
(c) Geographical and industry concentrations
 
of loans and advances to customers
As
 
described
 
above
 
in
 
note
 
5.2.1,
 
the
 
Group
 
holds
 
diversified
 
portfolios
 
across
 
markets
 
and
 
countries
 
and
 
implements
 
limits
 
on
concentrations arising from the
 
geographical location or the
 
activity of groups
 
of borrowers that could
 
be similarly affected by
 
changes
in economic or other conditions, in order to mitigate
 
credit risk.
 
 
 
doc1p253i0 doc1p253i1
 
Notes to the Consolidated Financial Statements
 
.
76
|
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31 December 2024 Consolidated Financial Statements
The following
 
tables break
 
down the
 
Group’s
 
exposure into
 
loans and
 
advances to
 
customers and
 
credit related
 
commitments at
 
their gross
 
carrying amount
 
and nominal
 
amount respectively
 
by stage,
product line, industry and geographical region
 
and impairment allowance by product line, industry and geographical
 
region:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Greece
Rest of Europe
Other Countries
Gross carrying/nominal amount
Gross carrying/nominal amount
Gross carrying/nominal amount
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL
-Stage 3
POCI
Impairment
allowance
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL
-Stage 3
POCI
Impairment
allowance
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL
-Stage 3
POCI
Impairment
allowance
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Retail Lending
8,038
3,324
624
0
(683)
7,625
408
153
327
(203)
80
0
0
2
(1)
-Mortgage
4,476
2,595
302
0
(410)
4,759
111
57
150
(59)
14
0
0
1
(0)
-Consumer
986
72
55
0
(68)
2,012
244
72
151
(117)
66
0
0
1
(0)
-Credit card
568
41
23
0
(28)
199
34
6
1
(9)
0
0
0
0
(0)
-Small business
2,008
615
243
-
(177)
655
20
18
24
(17)
0
-
-
-
(0)
Wholesale Lending
14,000
622
518
12
(298)
11,579
551
151
77
(120)
4,107
11
3
0
(4)
-Commerce and services⁽²⁾
5,717
271
248
9
(136)
7,000
104
83
39
(50)
580
3
1
0
(2)
-Manufacturing
2,927
204
182
3
(119)
839
52
19
9
(14)
69
-
0
-
(0)
-Shipping
76
-
-
-
(0)
589
1
3
8
(1)
3,112
-
1
-
(2)
-Construction
1,318
30
24
-
(16)
1,192
59
11
10
(9)
217
7
0
-
(0)
-Tourism
1,406
110
59
-
(18)
472
159
11
1
(9)
-
-
-
-
-
-Energy
2,505
0
4
-
(6)
249
7
0
0
(3)
-
-
-
-
-
-Other
51
8
1
-
(3)
1,238
169
24
10
(34)
130
-
-
-
(0)
Public Sector
12
-
0
-
(0)
18
-
-
1
(0)
-
-
-
-
-
Total
22,051
3,947
1,142
12
(982)
19,222
959
304
404
(323)
4,188
11
3
2
(4)
Credit related Commitments
 
8,609
144
47
0
(44)
4,574
116
18
32
(19)
462
3
0
0
(0)
-Loan commitments
6,468
119
0
0
(12)
3,338
91
14
6
(8)
450
3
0
0
(0)
-Financial guarantee
contracts and other
commitments
2,141
25
47
-
(32)
1,236
25
4
26
(11)
12
0
0
0
(0)
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
77
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Greece
Rest of Europe
Other Countries
Gross carrying/nominal amount
Gross carrying/nominal amount
Gross carrying/nominal amount
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
Impairment
allowance
12-month ECL
 
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
Impairment
allowance
12-month ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
Impairment
allowance
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Retail Lending
8,338
3,374
687
(638)
3,983
341
127
(173)
10
0
0
(0)
-Mortgage
4,821
2,531
361
(331)
2,080
87
53
(51)
7
0
0
(0)
-Consumer
936
131
53
(89)
1,303
166
50
(89)
3
0
0
(0)
-Credit card
546
43
16
(25)
154
30
5
(7)
0
0
0
(0)
-Small business
2,035
670
258
(193)
445
59
18
(26)
0
-
-
(0)
Wholesale Lending
11,601
668
573
(348)
9,038
527
133
(96)
3,348
3
3
(3)
-Commerce and services⁽²⁾
4,443
284
270
(168)
5,411
69
70
(45)
427
3
1
(1)
-Manufacturing
2,614
131
189
(110)
780
42
21
(14)
5
-
-
(0)
-Shipping
14
-
0
(0)
210
-
-
(0)
2,725
-
1
(2)
-Construction
1,329
30
42
(36)
784
80
4
(4)
83
-
0
(0)
-Tourism
1,045
215
67
(22)
357
98
9
(8)
-
-
-
-
-Energy
2,098
0
4
(7)
244
21
3
(4)
-
-
-
-
-Other
58
9
1
(4)
1,253
217
25
(20)
107
-
-
(0)
Public Sector
18
-
0
(0)
0
0
-
-
-
-
-
-
Total
19,957
4,042
1,260
(986)
13,021
868
260
(269)
3,358
3
3
(3)
Credit related Commitments
8,066
199
49
(44)
2,634
109
8
(4)
349
3
0
(0)
-Loan commitments
5,778
163
0
(11)
1,687
94
7
(3)
336
3
0
(0)
-Financial guarantee
contracts and other
commitments
2,287
36
49
(33)
947
15
1
(1)
13
-
0
(0)
(1)
 
Includes POCI loans of € 12.7 million held by operations in Greece, € 16.1 million held
 
by operations in Rest of Europe and € 0.1 million held by operations in Other Countries.
(2)
 
The operations in Rest of Europe include € 4,368 million related to the notes of securitizations of loans originated by Group entities (2023: € 4,444 million).
As at 31 December 2024,
 
the carrying amount of
 
Group's loans measured at
 
FVTPL of € 19 million
 
was included in Wholesale
 
lending portfolio, which
 
was held by operations
 
in Rest of Europe
 
(2023: € 15
million).
 
 
doc1p253i0 doc1p253i1
Notes to the Consolidated Financial Statements
 
.
 
78
|
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31 December 2024 Consolidated Financial Statements
 
(d) Forbearance practices on lending activities
Modifications
 
of
 
the
 
loans’
 
contractual
 
terms
 
may
 
arise
 
due
 
to
 
various
 
factors,
 
such
 
as
 
changes
 
in
 
market
 
conditions,
 
customer
retention and other factors as
 
well as due
 
to the potential
 
deterioration in the borrowers’ financial
 
condition. The Group
 
has employed
a range of forbearance
 
solutions in order to
 
enhance the management of
 
customer relationships
 
and the effectiveness
 
of collection
efforts, as well as to improve
 
the recoverability of cash flows
 
and minimize credit losses for both retail
 
and wholesale portfolios.
Forbearance practices’ classification
Forbearance practices
 
as monitored
 
and reported by
 
the Group, based
 
on the European
 
Banking Authority Implementing
 
Technical
Standards (EBA
 
ITS) guidelines,
 
occur only
 
in the
 
cases where
 
the contractual
 
payment terms
 
of a
 
loan have
 
been modified,
 
as the
borrower is considered unable to
 
comply with the existing loan’s
 
terms due to apparent financial difficulties, and
 
the Group grants a
concession by
 
providing more
 
favorable
 
terms and
 
conditions that
 
it would
 
not otherwise
 
consider had
 
the borrower
 
not been
 
in
financial difficulties.
All other
 
types of
 
modifications granted
 
by the
 
Group, where
 
there is
 
no apparent
 
financial difficulty
 
of the
 
borrower and
 
may be
driven by factors of a business nature
 
are not classified as forbearance measures.
Forbearance solutions
Forbearance solutions are granted following an assessment of the borrower’s ability and willingness to repay and can be of a short or
longer
 
term
 
nature.
 
The
 
objective
 
is to
 
assist
 
financially
 
stressed
 
borrowers
 
by rearranging
 
their
 
repayment
 
cash
 
outflows into
 
a
sustainable
 
modification,
 
and
 
at
 
the
 
same
 
time,
 
protect
 
the
 
Group
 
from
 
suffering
 
credit
 
losses.
 
The
 
Group
 
deploys
 
targeted
segmentation strategies
 
with the objective
 
to tailor different
 
short or long
 
term and sustainable
 
management solutions
 
to selected
groups of borrowers for
 
addressing their specific financial needs.
The nature and type of forbearance options
 
may include but is not necessarily limited to, one or more of the following:
arrears capitalization;
arrears repayment plan;
reduced payment above interest
 
only;
interest-only payments;
reduced payment below interest
 
only;
grace period;
interest rate reduction;
loan term extensions;
 
split balance and gradual step-up of installment
 
payment plans;
partial debt forgiveness/write-down;
operational restructuring; and
debt to equity swaps.
Specifically
 
for
 
unsecured
 
consumer
 
loans
 
(including
 
credit
 
cards),
 
forbearance
 
programs
 
(e.g.
 
term
 
extensions),
 
are
 
applied
 
in
combination with debt consolidation whereby all existing consumer balances are pooled together.
 
Forbearance solutions are applied
in
 
order
 
to
 
ensure
 
a
 
sufficient
 
decrease
 
on
 
installment
 
and
 
a
 
viable
 
solution
 
for
 
the
 
borrower.
 
In
 
selected
 
cases,
 
the
 
debt
consolidations may be combined with mortgage prenotations
 
to convert unsecured lending exposures
 
to secured ones.
In the case of mortgage loans, a decrease of installment
 
may be achieved through
 
forbearance measures such as extended payment
periods, capitalization of arrears,
 
split balance and gradual step-up of installment
 
payment plans.
Wholesale exposures
 
are subject to
 
forbearance when
 
there are indications
 
of financial difficulties
 
of the borrower,
 
evidenced by a
combination of factors including the deterioration
 
of financials, credit rating downgrade, payment
 
delays and other.
Debt for equity swaps
For
 
wholesale
 
portfolios,
 
the Group
 
on
 
occasion
 
participates
 
in
 
debt
 
for
 
equity
 
transactions
 
as
 
part
 
of
 
forbearance
 
measures,
 
as
described in note
 
2.2.9. In 2024
 
and 2023, there
 
were no equity
 
positions acquired by
 
the Group and
 
held as of
 
31 December 2024
and 31 December 2023 respectively.
Notes to the Consolidated Financial Statements
 
.
 
79
|
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31 December 2024 Consolidated Financial Statements
 
 
 
doc1p253i0 doc1p253i1
i.
Classification of Forborne loans
Loans for which forbearance measures have been applied after origination or acquisition, are classified either as non-impaired (stage
2), or impaired (stage 3) by assessing their delinquency and credit
 
quality status.
Credit impaired
 
forborne loans enter
 
initially a probation
 
period of one
 
year where
 
the borrowers’
 
payment performance
 
is closely
monitored. If at
 
the end of the abovementioned
 
period, the borrowers
 
have complied with
 
the terms of the
 
program and there
 
are
no past due amounts and concerns
 
regarding the loans’ full
 
repayment, the loans are
 
then reported as non-impaired forborne
 
loans
(stage 2).
 
In addition,
 
non-impaired forborne
 
loans, including those
 
that were
 
previously classified as
 
credit impaired
 
and complied
with the
 
terms of
 
the program,
 
are monitored
 
over a
 
period of
 
two years.
 
If,
 
at the
 
end of
 
that period,
 
the borrowers
 
have made
regular payments
 
of a
 
significant aggregate
 
amount, there
 
are no
 
past due
 
amounts over
 
30 days
 
and the
 
loans are
 
neither credit
impaired nor any other SICR criteria are met they
 
exit forborne status and are classified as stage
 
1.
Particularly,
 
the category
 
of
 
credit
 
impaired
 
forborne
 
loans includes
 
those that
 
(a) at
 
the date
 
when
 
forbearance
 
measures
 
were
granted, were
 
more than
 
90 days
 
past due
 
or assessed
 
as unlikely
 
to pay,
 
(b) at
 
the end
 
of the one
 
year probation
 
period met
 
the
criteria of entering the
 
non -impaired status and
 
during the two years monitoring
 
period new forbearance
 
measures were extended
or became more than 30 days past
 
due, and (c) were initially classified as non-
 
impaired and during the two years
 
monitoring period
met the criteria for entering the credit impaired
 
status.
Furthermore,
 
forborne
 
loans
 
that
 
fail
 
to
 
perform
 
under
 
the
 
new
 
modified
 
terms
 
and
 
are
 
subsequently
 
denounced
 
cease
 
to
 
be
monitored as
 
part of the
 
Group’s
 
forbearance activities
 
and are reported
 
as denounced credit
 
impaired loans (stage
 
3) consistently
with the Group’s management
 
and monitoring of all denounced loans.
ii.
Impairment assessment
Where forbearance
 
measures are extended,
 
the Group performs
 
an assessment of
 
the borrower’s
 
financial condition and
 
its ability
to repay,
 
under the
 
Group’s
 
impairment policies,
 
as described
 
in notes
 
2.2.13 and
 
5.2.1. Accordingly,
 
forborne loans
 
to wholesale
customers,
 
retail
 
individually
 
significant
 
exposures
 
and
 
financial
 
institutions
 
are
 
assessed
 
on
 
an
 
individual
 
basis.
 
Forborne
 
retail
lending
 
portfolios
 
are
 
generally
 
assessed
 
for
 
impairment
 
separately
 
from
 
other
 
retail
 
loan portfolios
 
on a
 
collective
 
basis as
 
they
consist of large homogenous portfolio.
iii.
Loan restructurings
In
 
cases
 
where
 
the
 
contractual
 
cash
 
flows
 
of
 
a
 
forborne
 
loan
 
have
 
been
 
substantially
 
modified,
 
the
 
original
 
forborne
 
loan
 
is
derecognized
 
and a
 
new loan
 
is recognized.
 
The Group
 
records
 
the modified
 
asset as
 
a ‘new’
 
financial asset
 
at fair
 
value and
 
the
difference with the carrying amount of the existing
 
one is recorded in the income statement
 
as derecognition gain or loss.
In cases where
 
the modification as
 
a result of
 
forbearance measures
 
is not considered
 
substantial, the Group
 
recalculates the
 
gross
carrying amount of
 
the loan and
 
recognizes the difference as a
 
modification gain or loss
 
in the income
 
statement. The Group continues
to monitor the modified forborne loan in
 
order to determine if the financial
 
asset exhibits significant increase in credit risk since
 
initial
recognition during the forbearance period.
As at 31 December 2024, the carrying amount of Group's forborne
 
loans measured at FVTPL was nil (2023: nil).
The following
 
tables present
 
an analysis
 
of Group’s
 
forborne activities
 
for loans
 
measured at
 
amortised cost.
 
In order
 
to align
 
with
the quantitative information provided in section (a) based on
 
IFRS 7 requirements, the relevant tables below are presented on a
 
gross
carrying amount
 
basis, while cumulative
 
impairment allowance
 
is presented
 
separately,
 
in line with
 
the Group’s
 
internal credit
 
risk
monitoring and reporting.
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
80
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
The following table presents a summary of the types of the Group’s
 
forborne activities:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Forbearance measures:
Split balance
275
147
Loan term extension
693
787
Arrears capitalisation
77
72
Reduced payment below interest owed
34
36
Interest rate reduction
153
117
Reduced payment above interest owed
98
81
Arrears repayment plan
56
96
Interest only
27
57
Grace period
92
68
Partial debt forgiveness/Write-down
19
1
Operational restructuring
11
13
Other
55
34
Total gross carrying
 
amount
1,588
1,509
Less: cumulative impairment allowance
(321)
(307)
Total carrying amount
1,267
1,202
The following tables present a summary of the credit
 
quality of forborne loans and advances to customers:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Total loans &
advances at
amortised
cost
Forborne
loans &
advances
% of Forborne
 
loans &
advances
€ million
€ million
Gross carrying amounts:
12-month ECL-Stage 1
45,460
50
0.1
Lifetime ECL-Stage 2
4,917
788
16.0
Lifetime ECL-Stage 3
1,449
559
38.6
POCI
419
191
45.6
Total Gross Amount
52,245
1,588
3.0
Cumulative ECL Loss allowance:
12-month ECL-Stage 1
(191)
(0)
Lifetime ECL-Stage 2
(354)
(49)
Lifetime ECL-Stage 3 of which:
 
(738)
(258)
- Individually assessed
 
(287)
(118)
- Collectively assessed
 
(451)
(140)
POCI
(27)
(13)
Total carrying amount
50,936
1,267
2.5
Collateral received
34,822
1,211
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
81
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Total loans &
advances at
amortised cost
Forborne loans
& advances
% of Forborne
 
loans &
advances
€ million
€ million
Gross carrying amounts:
12-month ECL-Stage 1
36,336
-
-
Lifetime ECL-Stage 2
4,914
889
18.1
Lifetime ECL-Stage 3 and POCI
1,523
620
40.7
Total Gross
 
Amount
42,773
1,509
3.5
Cumulative ECL Loss allowance:
12-month ECL-Stage 1
(170)
-
Lifetime ECL-Stage 2
(329)
(49)
Lifetime ECL-Stage 3 and POCI of which:
 
(759)
(257)
- Individually assessed
 
(279)
(112)
- Collectively assessed
 
(480)
(145)
Total carrying amount
41,515
1,202
2.9
Collateral received
28,007
1,184
Note: As at 31 December 2024, performing forborne loans of € 50 million acquired from Hellenic Bank,
 
are presented at stage 1.
The following table presents the movement
 
of forborne loans and advances:
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Gross carrying amount at 1 January
1,509
2,012
Arising from acquisition (note 23.2)
275
-
Forbearance measures in the year
377
322
Forborne loans derecognised/ reclassified as held
 
for sale during the year ⁽¹⁾
(29)
(85)
Write-offs of forborne loans
(5)
(47)
Repayment of loans
 
(310)
(221)
Loans & advances that exited forbearance status
 
⁽²⁾
(328)
(582)
Other
99
110
Less: cumulative impairment allowance
(321)
(307)
Carrying amount at 31 December
1,267
1,202
(1)
 
“Forborne loans derecognised/ reclassified
 
as held for
 
sale during the
 
year” presents loans derecognized
 
during the year
 
due to a)
 
sale and securitization
transactions and b) substantial modifications
 
of the loans’ contractual terms
 
and those that have been reclassified
 
as held for sale
 
during the year (notes 20
and 30).
(2)
 
In 2024, an amount of € 46 million loans and advances that exited forbearance status refers to loans that were denounced (2023: € 73 million).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
82
|
Page
 
31 December 2024 Consolidated Financial Statements
The following table presents the Group’s
 
exposure to forborne loans and advances by
 
product line:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Retail Lending
813
762
- Mortgage
437
457
- Consumer
183
78
- Credit card
4
6
- Small business
188
220
Wholesale Lending
775
747
-Large corporate
282
237
-SMEs
493
510
Total gross carrying
 
amount
1,588
1,509
Less: cumulative impairment allowance
(321)
(307)
Total carrying amount
1,267
1,202
The following table presents the Group’s
 
exposure to forborne loans and advances
 
by geographical region:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Greece
947
1,116
Rest of Europe
636
388
Other countries
6
5
Total gross carrying
 
amount
1,588
1,509
Less: cumulative impairment allowance
(321)
(307)
Total carrying amount
1,267
1,202
The
 
following
 
table
 
provides
 
information
 
on
 
modifications
 
due
 
to
 
forbearance
 
measures
 
on
 
lending
 
exposures
 
which
 
have
 
not
resulted
 
in
 
derecognition.
 
Such financial
 
assets
 
were
 
modified
 
while
 
they
 
had
 
a loss
 
allowance
 
measured
 
at
 
an
 
amount
 
equal
 
to
lifetime ECL.
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
Modified lending exposures
€ million
€ million
Loans modified during the year with loss allowance measured
 
at an amount equal to lifetime ECL
 
Gross carrying amount at 31 December
396
401
Modification gain / (loss)
(5)
8
Loans modified since initial recognition at a time when loss allowance was based on
lifetime ECL
Gross carrying amount at 31 December for which loss allowance has changed to 12-month
ECL measurement
244
410
In
 
the
 
year
 
ended
 
31
 
December
 
2024,
 
the
 
gross
 
carrying
 
amount
 
of
 
loans
 
previously
 
modified
 
for
 
which
 
the
 
loan
 
allowance
 
has
reverted to being measured at an amount
 
equal to lifetime ECL amounted to
 
€ 300 million (2023: € 284 million).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
83
|
Page
 
31 December 2024 Consolidated Financial Statements
5.2.1.3 Debt Securities
The following
 
tables present
 
an analysis
 
of debt
 
securities by
 
external
 
credit rating
 
agency designation
 
at 31
 
December 2024
 
and
2023, based on Moody's ratings or their equivalent:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
Total
€ million
€ million
€ million
€ million
Debt securities at amortised cost
Aaa
6,661
-
-
6,661
Aa1 to Aa3
 
855
-
-
855
A1 to A3
1,833
4
-
1,837
Lower than A3
8,110
15
-
8,125
Unrated
163
-
36
199
Gross Carrying Amount
 
17,621
20
36
17,677
Impairment Allowance
(15)
(1)
(9)
(26)
Carrying Amount
 
17,606
19
26
17,651
Debt securities at FVOCI
Aaa
514
-
-
514
Aa1 to Aa3
 
551
-
-
551
A1 to A3
546
-
-
546
Lower than A3
2,385
28
-
2,414
Unrated
64
-
-
64
Carrying Amount
 
4,061
28
-
4,090
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
Total
€ million
€ million
€ million
€ million
Debt securities at amortised cost
Aaa
2,789
-
-
2,789
Aa1 to Aa3
 
132
-
-
132
A1 to A3
231
4
-
235
Lower than A3
7,602
3
-
7,605
Unrated
180
-
32
212
Gross Carrying Amount
 
10,935
7
32
10,974
Impairment Allowance
(11)
(0)
(7)
(18)
Carrying Amount
 
10,924
7
25
10,955
Debt securities at FVOCI
Aaa
316
-
-
316
Aa1 to Aa3
 
202
-
-
202
A1 to A3
436
8
-
444
Lower than A3
2,411
40
-
2,451
Unrated
63
-
-
63
Carrying Amount
 
3,427
48
-
3,475
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
84
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Debt securities
held for trading
Debt securities
measured at
FVTPL
€ million
€ million
Debt securities at FVTPL
Aaa
19
11
Aa1 to Aa3
 
-
6
A1 to A3
10
1
Lower than A3
158
0
Carrying Amount
 
186
18
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Debt securities
held for trading
Debt securities
measured at
FVTPL
€ million
€ million
Debt securities at FVTPL
Aaa
55
-
A1 to A3
14
-
Lower than A3
176
0
Unrated
0
25
Carrying Amount
 
245
26
The carrying
 
amount of
 
debt securities rated
 
lower than
 
A3, amounting
 
to €
 
10,684 million (2023:
 
€ 10,222
 
million), is
 
analyzed as
follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
Sovereign
Banks and
Corporate
Sovereign
Banks and
Corporate
€ million
€ million
€ million
€ million
Debt securities
 
Greece
5,919
1,399
6,015
1,248
Other Eurozone members
762
775
967
604
Other EU members ⁽¹⁾
990
73
765
67
Other countries
 
240
527
194
362
Carrying Amount
 
7,911
2,773
7,941
2,281
 
(1)
It includes debt securities issued by non-Eurozone members European countries of the Group's presence. As at 31 December 2024, it includes
 
debt securities
issued by Bulgaria with carrying value of € 660 million (2023: securities issued by
 
Bulgaria with carrying value of € 527 million).
Following a
 
series of sovereign
 
rating upgrades
 
in the second
 
half of 2023,
 
the Greek
 
government’s
 
long-term debt
 
securities were
considered investment
 
grade by four
 
out of the five
 
Eurosystem-approved
 
External Credit Assessment
 
Institutions (DBRS: BBB(low),
positive
 
outlook,
 
Fitch:
 
BBB-,
 
stable
 
outlook;
 
Scope:
 
BBB,
 
stable
 
outlook;
 
S&P:
 
BBB-,
 
positive
 
outlook),
 
and
 
one
 
notch
 
below
investment grade by the fifth one, Moody’s
 
(Βa1, positive outlook) as of early 2025.
The carrying amount of
 
unrated debt securities
 
of € 254 million (2023: €
 
293 million) comprise € 188
 
million Greek corporate
 
bonds
(2023: €
 
181 million),
 
€ 42
 
million
 
Cyprus
 
corporate
 
bonds
 
(2023: €
 
90 million)
 
and
 
€ 24
 
million
 
corporate
 
bonds
 
issued in
 
other
European countries (2023: € 22 million).
As at
 
31 December 2024,
 
the nominal
 
value of
 
the Group’s
 
Russian debt
 
exposures, which
 
have been
 
classified as
 
credit impaired,
amounted
 
to
 
 
39
 
million,
 
with
 
an
 
impairment
 
allowance
 
of
 
 
7
 
million
 
(2023:
 
 
36
 
million
 
nominal
 
value
 
with
 
an
 
impairment
allowance of € 5 million).
In the first
 
quarter of 2024,
 
the Group
 
proceeded with
 
the disinvestment
 
of short-term
 
sovereign debt
 
securities of face
 
value of €
365 million
 
measured at
 
amortized cost,
 
resulting in
 
a derecognition
 
loss of
 
€ 16.6
 
million. The
 
sale was
 
assessed to
 
be consistent
with the held to collect business model in accordance with the Group’s
 
accounting policy.
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
85
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
The following tables present the Group's exposure in debt securities, as categorized by stage, counterparty's geographical
 
region and
industry sector:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Greece
Other European countries
Other countries
12-month ECL-
Stage 1
Lifetime ECL-
Stage 3
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Debt securities at amortised cost
Sovereign
5,039
-
4,004
-
-
1,434
-
10,477
Banks
1,097
-
2,621
-
-
832
-
4,551
Corporate
304
5
1,499
14
31
791
6
2,649
Gross Carrying Amount
6,440
5
8,124
14
31
3,057
6
17,677
Impairment Allowance
(9)
(2)
(5)
(1)
(7)
(1)
(0)
(26)
Net Carrying Amount
 
6,431
3
8,119
13
24
3,056
6
17,651
Debt securities at FVOCI
Sovereign
803
-
1,566
-
-
449
-
2,817
Banks
16
-
164
-
-
-
-
179
Corporate
177
-
612
28
-
276
-
1,093
Carrying Amount
995
-
2,342
28
-
725
-
4,090
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Greece
Other European countries
Other countries
12-month ECL-
Stage 1
Lifetime ECL-
Stage 3
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
12-month ECL-
Stage 1
Lifetime ECL-
Stage 2
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Debt securities at amortised cost
Sovereign⁽¹⁾
4,966
-
1,561
-
-
1,164
-
7,691
Banks⁽¹⁾
923
-
369
-
-
-
-
1,292
Corporate
326
4
1,012
3
27
614
4
1,991
Gross Carrying Amount
6,215
4
2,942
3
27
1,778
4
10,974
Impairment Allowance
(7)
(2)
(3)
(0)
(5)
(1)
(0)
(18)
Net Carrying Amount
 
6,208
3
2,939
3
22
1,777
4
10,955
Debt securities at FVOCI
Sovereign
909
-
887
-
-
426
-
2,221
Banks
14
-
210
-
-
-
-
224
Corporate
172
-
528
40
-
281
8
1,029
Carrying Amount
1,095
-
1,625
40
-
707
8
3,475
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Greece
Other
 
European
countries
Other countries
Total
€ million
€ million
€ million
€ million
Debt securities at FVTPL
Sovereign
-
16
-
16
Banks
-
2
-
2
Corporate
0
-
-
0
Carrying Amount
 
0
18
-
18
Debt securities held for trading
Sovereign
80
19
19
118
Corporate
-
62
6
69
Carrying Amount
 
80
81
25
186
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
86
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Greece
Other
 
European
countries
Other countries
Total
€ million
€ million
€ million
€ million
Debt securities at FVTPL
Banks
-
25
-
25
Corporate
0
-
-
0
Carrying Amount
 
0
25
-
26
Debt securities held for trading
Sovereign
142
18
55
216
Corporate
0
27
3
30
Carrying Amount
 
142
45
58
245
(1)
In the comparative year, € 203 million debt securities at AC
 
previously classified under the industry sector of "Banks" have been transferred to "Sovereign",
in order to align with this year's presentation.
5.2.1.4 Offsetting of financial assets and financial liabilities
Financial assets and
 
financial liabilities are
 
offset according
 
to IAS 32
 
‘Financial Instruments
 
and the net
 
amount is presented
 
in the
balance sheet when, there is a legally enforceable right
 
to set off the recognized amounts and there
 
is an intention to settle on a net
basis, or to realize the asset and settle the liability simultaneously (the offsetting criteria), as also set out in Group's accounting policy
2.2.4.
 
Financial instruments
 
that meet the
 
offsetting criteria
 
include the eligible
 
repos and
 
reverse repos
 
under global
 
master repurchase
agreements
 
(GMRAs)
 
and
 
the
 
CCP
 
(Central
 
Counterparty)
 
cleared
 
OTC
 
derivative
 
financial
 
instruments.
 
Regarding
 
the
 
latter,
 
the
Group has assessed the terms of the clearing agreements for the derivatives
 
entered into with Clearing Members and has concluded
that the offsetting criteria are met, in respect of the cash accounts used for variation margin purposes for such derivatives, which are
also used
 
for
 
the settlement
 
of all
 
payments
 
thereunder.
 
Accordingly,
 
derivative
 
assets of
 
€ 619
 
million (2023:
 
€ 752
 
million)
 
and
derivative
 
liabilities
 
of
 
 
420
 
million
 
(2023:
 
 
492
 
million)
 
(note
 
19)
 
were
 
offset
 
against
 
 
240
 
million
 
(2023:
 
 
317
 
million)
 
cash
collateral received (note 32) and
 
€ 42 million (2023: € 57 million) cash collateral pledged (note
 
17).
Financial instruments under
 
master netting
 
arrangements and
 
similar agreements that
 
do not meet the
 
criteria for offsetting
 
in the
balance
 
sheet
 
include
 
derivatives
 
(bilateral
 
agreements)
 
as
 
well
 
as
 
repos
 
and
 
reverse
 
repos,
 
for
 
which
 
a)
 
the
 
right
 
of
 
set-off
 
is
enforceable
 
only
 
following
 
an
 
event
 
of
 
default,
 
insolvency
 
or
 
bankruptcy
 
of
 
the
 
Group
 
or
 
the
 
counterparties
 
or
 
following
 
other
predetermined events and/or b)
 
the Group and its counterparties may not intend to settle
 
on a net basis or to realize the assets and
settle the liabilities simultaneously.
The following tables
 
present financial assets
 
and financial liabilities that
 
meet the criteria for
 
offsetting and thus
 
are presented
 
on a
net
 
basis
 
in
 
the
 
balance
 
sheet,
 
as
 
well
 
as
 
amounts
 
that
 
are
 
subject
 
to
 
enforceable
 
master
 
netting
 
arrangements
 
and
 
similar
agreements for
 
which the offsetting
 
criteria mentioned above
 
are not satisfied.
 
In respect of
 
the latter,
 
the Group
 
may receive and
provide
 
collateral
 
in
 
the
 
form
 
of
 
marketable
 
securities
 
and
 
cash
 
that
 
are
 
included
 
in
 
the
 
tables
 
below
 
under
 
columns
 
‘financial
instruments’ and ‘cash collateral’.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
87
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Related amounts not offset in the BS
Gross amounts
of recognised
financial assets
Gross amounts of
recognised
financial
liabilities offset in
the balance sheet
Net amounts of
financial assets
presented in the
balance sheet
Financial
instruments
(incl. non-cash
collateral)
Cash
collateral
received
Net
amount
€ million
€ million
€ million
€ million
€ million
€ million
Financial Assets
Reverse repos with banks
481
(447)
34
(32)
2
Derivative financial instruments
1,447
(619)
828
(550)
(153)
125
Other financial assets
4
(4)
-
-
Deposits to banks pledged as collateral
622
(42)
580
(150)
430
Total
2,554
(1,112)
1,442
(732)
(153)
557
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Related amounts not offset in the BS
Gross amounts
of recognised
financial
liabilities
Gross amounts of
recognised
financial assets
offset in the
balance sheet
Net amounts of
financial
liabilities
presented in the
balance sheet
Financial
instruments
(incl. non-cash
collateral)
Cash
collateral
pledged
Net
amount
€ million
€ million
€ million
€ million
€ million
€ million
Financial Liabilities
Derivative financial instruments
1,510
(420)
1,090
(783)
(150)
157
Repurchase agreements with banks
2,399
(447)
1,952
(1,952)
-
-
Other financial liabilities
4
(4)
-
-
Deposits from banks received as collateral
358
(240)
118
(118)
-
Total
4,271
(1,111)
3,160
(2,853)
(150)
157
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Related amounts not offset in the BS
Gross amounts
of recognised
financial assets
Gross amounts of
recognised
financial liabilities
offset in the
balance sheet
Net amounts of
financial assets
presented in the
balance sheet
Financial
instruments (incl.
non-cash
collateral)
Cash
collateral
received
Net amount
€ million
€ million
€ million
€ million
€ million
€ million
Financial Assets
Reverse repos with banks
1,249
(1,210)
39
(39)
-
-
Derivative financial instruments
1,612
(752)
860
(672)
(56)
132
Other financial assets
4
(4)
-
-
-
-
Deposits to banks pledged as collateral
1,093
(57)
1,036
(340)
-
696
Total
3,958
(2,023)
1,935
(1,051)
(56)
828
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
88
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Related amounts not offset in the BS
Gross amounts
of recognised
financial
liabilities
Gross amounts of
recognised
financial assets
offset in the
balance sheet
Net amounts of
financial
liabilities
presented in the
balance sheet
Financial
instruments (incl.
non-cash
collateral)
Cash
collateral
pledged
Net amount
€ million
€ million
€ million
€ million
€ million
€ million
Financial Liabilities
Derivative financial instruments
1,906
(492)
1,414
(930)
(340)
144
Repurchase agreements with banks
3,638
(1,210)
2,428
(2,428)
-
-
Other financial liabilities
4
(4)
-
-
-
-
Deposits from banks received as collateral
404
(317)
87
(56)
-
31
Total
5,952
(2,023)
3,929
(3,414)
(340)
175
Derivative
 
financial assets
 
and liabilities
 
not under
 
master
 
netting arrangements
 
and similar
 
agreements
 
of carrying
 
value of
 
€ 10
million and € 30 million, respectively,
 
(2023: € 21 million and € 36 million, respectively) are not presented
 
in the above tables.
Financial assets and
 
financial liabilities are
 
disclosed in the above
 
tables at their
 
recognized amounts,
 
either at fair
 
value (derivative
assets and liabilities) or amortized cost (all other financial instruments),
 
depending on the type of financial instrument.
 
5.2.2
 
Market risk
The Group takes on exposure to market risk, which is the risk of potential financial loss due to an adverse change in market variables.
Changes
 
in
 
interest
 
rates,
 
foreign
 
exchange
 
rates,
 
credit
 
spreads,
 
equity
 
prices
 
and
 
other
 
relevant
 
factors,
 
such
 
as
 
the
 
implied
volatilities, can affect the Group’s
 
income or the fair value of its financial instruments. The market
 
risks, the Group is exposed to, are
monitored, controlled and estimated
 
by Group Market and Counterparty Risk
 
Unit (GMCRU).
GMCRU is responsible
 
for the measurement,
 
monitoring, control
 
and reporting of
 
all market
 
risks, including the
 
interest rate
 
risk in
the Banking Book (IRRBB) and the credit spread risk
 
in the Banking Book (CSRBB) of the Group. In particular,
 
the Bank in response to
the
 
regulatory
 
developments
 
and requirements
 
(EBA/GL/2022/14),
 
has
 
further
 
enhanced
 
its infrastructure,
 
governance
 
and
 
limit
structure accordingly, so as to measure and monitor its
 
CSRBB, via a
 
dedicated stress testing framework. The Unit reports
 
to the GCRO
and its main responsibilities include:
Monitoring of all key market,
 
IRRBB and CSRBB risk indicators;
Implementation of Stress Testing
 
methodologies for market risk, IRRBB and
 
CSRBB (historical and hypothetical);
Monitoring and reporting of market and IRRBB and CSRBB risk limits utilization;
Development, maintenance and expansion of risk management
 
infrastructure.
The market risks the Group is exposed
 
to, are the following:
(a) Interest rate risk
The Group takes
 
on exposure to
 
the effects of
 
fluctuations in the
 
prevailing levels
 
of market interest
 
rates on its
 
cash flows and
 
the
fair
 
value
 
of
 
its financial
 
positions.
 
Cash flow
 
interest
 
rate
 
risk is
 
the risk
 
that
 
the future
 
cash flows
 
of
 
a financial
 
instrument
 
will
fluctuate because of
 
changes in market
 
interest rates.
 
Fair value interest
 
rate risk
 
is the risk that
 
the value of
 
a financial instrument
will fluctuate because of changes in market interest
 
rates. Fair value interest
 
rate risk is further split into ‘General’ and ‘Specific’.
 
The
former refers
 
to changes in the fair valuation
 
of positions due to the movements
 
of benchmark interest rates,
 
while the latter refers
to changes in the fair valuation of positions due to the
 
movements of specific issuer yields and credit spreads.
(b) Currency risk
The Group takes
 
on exposure to the
 
effects of fluctuations
 
in the prevailing foreign
 
currency exchange rates
 
on its financial position
and cash flows.
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
89
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
(c) Equity risk
Equity price risk is the risk
 
of the decrease of fair values as
 
a result of changes in the
 
levels of equity indices and the
 
value of individual
stocks. The equity risk that the Group undertakes
 
arises mainly from the investment portfolio.
(d) Implied volatilities
The Group carries limited implied volatility (vega)
 
risk, mainly as a result of open positions on options.
The BoD and
 
Board Risk Committee set limits on the level of exposure
 
to market risks, which are monitored
 
on a daily basis.
Market
 
risk
 
in
 
Greece
 
and
 
International
 
Subsidiaries
 
is
 
managed
 
and
 
monitored
 
mainly
 
using
 
Value
 
at
 
Risk
 
(VaR)
 
methodology.
Sensitivity and stress test analysis is additionally performed.
(i) VaR
 
summary for 2024 and 2023
VaR is a
 
methodology used in measuring financial risk
 
by estimating the potential
 
negative change in the
 
market value of
 
a portfolio
at a
 
given confidence
 
level and
 
over a
 
specified time
 
horizon. The
 
VaR
 
that the
 
Group measures
 
is an
 
estimate based
 
upon a
 
99%
confidence level and a holding period of 1 day and the methodology used for the calculation is Monte Carlo simulation (full
 
re-pricing
of the positions is performed).
The VaR
 
models are designed
 
to measure
 
market risk
 
in a normal
 
market environment.
 
It is assumed
 
that any
 
changes occurring
 
in
the risk factors affecting the
 
normal market environment
 
will follow a normal distribution.
Although VaR
 
is an
 
important tool
 
for measuring
 
market risk,
 
the assumptions
 
on which
 
the model
 
is based
 
do give
 
rise to
 
certain
limitations. Given this, actual outcomes are
 
monitored regularly,
 
via back testing process, to test
 
the validity of the assumptions and
the parameters used in the VaR
 
calculation.
The perimeter of the
 
VaR analysis
 
includes Eurobank Ergasias
 
Services and Holdings S.A., Eurobank
 
S.A. and its banking subsidiaries,
taking into account the FVTPL, including trading
 
and FVOCI portfolios. Consequently,
 
the potential impact as it is depicted in the VaR
figures would directly affect Group’s
 
Capital (income statement or equity).
Since VaR
 
constitutes an
 
integral part
 
of the Group's
 
market risk
 
control regime,
 
VaR limits
 
have been
 
established for
 
all the above
operations
 
(trading
 
and
 
investment
 
portfolios
 
measured
 
at
 
fair
 
value)
 
and
 
actual
 
exposure
 
is
 
reviewed
 
daily
 
by
 
management.
However,
 
the use of this approach does not prevent losses outside of these limits in the
 
event of extraordinary market
 
movements.
VaR by risk type - Greece and International
 
Subsidiaries
(1)
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
(Average)
2024
2023
(Average)
2023
€ million
€ million
€ million
€ million
Interest Rate Risk
6
6
7
9
Foreign Exchange Risk
0
1
0
1
Equities Risk
1
1
2
1
Total VaR
6
6
8
9
(1)
 
Includes all portfolios measured at fair value.
The aggregate VaR of the interest
 
rate, foreign exchange and equities VaR
 
benefits from diversification effects. The largest portion
 
of
the Group’s Interest Rate VaR figures is attributable to the risk associated with
 
interest rate and credit spread sensitive debt securities
and derivatives. The average
 
VaR of 2024 remains
 
relatively stable at
 
low levels, as compared to
 
the average VaR
 
of 2023, reflecting
the reduced volatility observed in the markets.
(ii) Interest rate gap and sensitivity
The following
 
table provides
 
the interest
 
rate repricing
 
gap of
 
the Group,
 
which analyses
 
the structure
 
of interest
 
rate mismatches
within the balance sheet. The Group’s
 
financial assets/liabilities are included at their notional/outstanding
 
amounts and categorized
based on either (i) the next contractual repricing date if floating rate
 
or (ii) the maturity/call date (whichever is first) if fixed
 
rate. The
below analysis provides an approximation of the interest rate risk exposure since transactions with different
 
duration are aggregated
together per time bucket.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
90
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024⁽²⁾
less than 1
month
1-3 months
3-12 months
1-5
 
years
More than 5
years
€ million
€ million
€ million
€ million
€ million
Balances with central banks
15,512
-
-
-
-
Due from credit institutions
2,185
355
7
60
-
Debt securities⁽¹⁾
1,518
1,086
1,532
8,121
8,988
Loans and advances to customers
18,023
11,724
12,563
6,225
3,510
37,238
13,165
14,102
14,407
12,499
Due to central banks
-
-
-
-
-
Due to credit institutions
(2,936)
(596)
(0)
(10)
-
Due to customers
(53,944)
(8,155)
(11,024)
(3,157)
(2,071)
Debt securities in issue
(660)
(0)
(335)
(3,771)
(2,165)
(57,540)
(8,752)
(11,360)
(6,938)
(4,237)
Derivative financial instruments
(6,382)
(776)
(171)
11,573
(4,375)
Interest rate gap
(26,684)
3,638
2,571
19,042
3,887
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023⁽²⁾
less than 1
month
1-3 months
3-12 months
1-5
 
years
More than 5
years
€ million
€ million
€ million
€ million
€ million
Balances with central banks
10,438
-
-
-
-
Due from credit institutions
2,208
1,125
7
-
60
Debt securities⁽¹⁾
758
481
928
5,333
6,446
Loans and advances to customers
16,453
8,026
8,084
5,133
4,675
29,857
9,632
9,018
10,467
11,182
Due to central banks
(3,665)
-
-
-
-
Due to credit institutions
(1,148)
(3,260)
-
(251)
-
Due to customers
(44,418)
(4,859)
(6,655)
(1,406)
-
Debt securities in issue
-
-
(96)
(3,872)
(711)
(49,231)
(8,118)
(6,751)
(5,529)
(711)
Derivative financial instruments
1,891
2,397
60
1,146
(5,584)
Interest rate gap
(17,483)
3,910
2,327
6,084
4,886
(1)
Including short positions in debt securities (note 35).
(2)
 
Amounts are before offsetting (note 5.2.1.4).
The Group performs a sensitivity analysis to assess
 
the impact on net interest income (NII) and
 
on other comprehensive income (OCI),
to a hypothetical change in the market
 
interest rates.
.
The impact
 
on NII is
 
calculated under
 
the scenario of
 
an instantaneous
 
parallel shift
 
of all interest
 
rates by
 
+/- 100bps,
 
for a 1-year
period, assuming a static balance sheet approach. As at 31 December 2024 the impact on NII, under the scenario of a parallel shift
 
in
the yield curves, stands at € 122 million (+100bps) and € -167 million (-100bps) (31 December
 
2023: € 194 million and € -171 million,
respectively).
The
 
impact on
 
OCI is
 
calculated
 
as the
 
fair
 
value
 
movement
 
of
 
all financial
 
assets measured
 
at
 
FVOCI,
 
net of
 
hedging
 
and of
 
any
hedging instruments
 
designated in
 
qualifying cash flow
 
hedge relationships.
 
As at 31
 
December 2024 the
 
impact on OCI,
 
under the
scenario of a parallel shift
 
in the yield curves, stands
 
at € -71 million (+100bps) and
 
€ 75 million (-100bps) (31 December
 
2023: € -68
million and € 72 million, respectively).
.
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
 
91
|
Page
 
31 December 2024 Consolidated Financial Statements
(iii) Foreign exchange risk
The following tables present the Group’s
 
exposure to foreign currency
 
exchange risk as at 31 December 2024 and 2023:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
USD
CHF
GBP
RON
BGN
OTHER
EUR
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
ASSETS
Cash and balances with
central banks
 
18
 
2
 
7
 
0
 
684
 
2
 
15,417
 
16,131
Due from credit
institutions
 
641
 
47
 
62
 
27
 
0
 
70
 
1,349
 
2,196
Securities held for trading
 
19
 
-
 
28
 
-
 
20
 
-
 
219
 
285
Derivative financial
instruments
 
29
 
0
 
1
 
0
 
-
 
1
 
808
 
838
Loans and advances to
customers
 
3,936
 
1,690
 
985
 
6
 
6,078
 
6
 
38,251
 
50,953
Investment securities
 
1,985
 
-
 
121
 
-
 
103
 
190
 
19,784
 
22,184
Other assets⁽¹⁾
 
12
 
2
 
1
 
19
 
308
 
0
 
8,130
 
8,472
Assets of disposal groups
classified as held for sale
(note
 
30)
 
-
 
0
 
-
 
5
 
-
 
-
 
85
 
91
Total Assets
 
6,641
 
1,743
 
1,205
 
56
 
7,193
 
269
 
84,043
 
101,150
LIABILITIES
Due to central banks and
credit institutions
 
32
 
3
 
4
 
0
 
2
 
3
 
2,755
 
2,800
Derivative financial
instruments
 
10
 
3
 
1
 
0
 
0
 
2
 
1,104
 
1,120
Due to customers
 
 
7,489
 
80
 
610
 
6
 
5,541
 
165
 
64,702
 
78,593
Debt securities in issue
 
76
 
-
 
-
 
-
 
-
 
-
 
6,980
 
7,056
Other liabilities⁽²⁾
 
47
 
1
 
6
 
37
 
99
 
1
 
2,491
 
2,682
Total Liabilities
 
7,654
 
87
 
621
 
43
 
5,643
 
171
 
78,032
 
92,251
Net on balance sheet
position
 
(1,013)
 
1,656
 
583
 
13
 
1,550
 
98
 
6,011
 
8,899
Derivative forward
foreign exchange position
 
1,040
 
(1,705)
 
(571)
 
(7)
 
(439)
 
(107)
 
1,777
 
(12)
Total Foreign
 
Exchange
Position
 
27
 
(49)
 
12
 
6
 
1,112
 
(9)
 
7,788
 
8,887
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
92
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
USD
CHF
RON
BGN
OTHER
EUR
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
ASSETS
Cash and balances with
central banks
 
13
 
2
 
0
 
867
 
7
 
10,054
 
10,943
Due from credit
institutions
 
380
 
31
 
33
 
2
 
72
 
1,836
 
2,354
Securities held for trading
 
55
-
 
-
 
 
19
 
0
 
305
 
379
Derivative financial
instruments
 
19
 
0
-
 
 
0
 
1
 
861
 
881
Loans and advances to
customers
 
3,210
 
1,886
 
7
 
5,129
 
714
 
30,599
 
41,545
Investment securities
 
1,668
-
 
-
 
 
75
 
288
 
12,679
 
14,710
Other
 
assets ⁽¹⁾
 
13
 
4
 
4
 
288
 
2
 
8,452
 
8,763
Assets of disposal groups
classified as held for sale
(note 30)
 
0
 
59
-
 
-
 
-
 
 
147
 
206
Total Assets
 
5,358
 
1,982
 
44
 
6,380
 
1,084
 
64,933
 
79,781
LIABILITIES
Due to central banks and
credit institutions
 
188
 
0
 
0
 
5
 
11
 
6,645
 
6,849
Derivative financial
instruments
 
18
 
2
 
0
 
0
 
1
 
1,429
 
1,450
Due to customers
 
 
5,822
 
61
 
2
 
5,035
 
593
 
45,929
 
57,442
Debt securities in issue
 
76
-
 
-
 
-
 
 
0
 
4,680
 
4,756
Other
 
liabilities⁽²⁾
 
43
 
1
 
21
 
80
 
7
 
1,233
 
1,385
Total Liabilities
 
6,147
 
64
 
23
 
5,120
 
612
 
59,916
 
71,882
Net on balance sheet
position
 
(789)
 
1,918
 
21
 
1,260
 
472
 
5,017
 
7,899
Derivative forward foreign
exchange position
 
668
 
(1,921)
 
(10)
 
(329)
 
(502)
 
1,781
 
(313)
Total Foreign
 
Exchange
Position
 
(121)
 
(3)
 
11
 
931
 
(30)
 
6,798
 
7,586
(1)
Other assets include Investments in associates and joint ventures, Property and equipment, Investment
 
property, Intangible assets, Deferred tax
 
assets and
Other assets.
(2)
 
Other liabilities include liabilities of disposal group classified
 
as held for sale (note 30).
 
 
 
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Notes to the Consolidated Financial Statements
 
.
 
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|
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31 December 2024 Consolidated Financial Statements
5.2.3
 
Liquidity risk
The Group
 
is exposed
 
to daily
 
calls on
 
its available
 
cash resources
 
due to
 
deposits withdrawals,
 
maturity of
 
medium or
 
long-term
notes,
 
maturity of
 
secured
 
or unsecured
 
funding (interbank
 
repos and
 
money market
 
takings), loan
 
drawdowns
 
and forfeiture
 
of
guarantees. Furthermore, margin calls on secured funding transactions (with ECB and the market), on risk mitigation contracts (CSAs,
GMRAs) and on
 
centrally cleared transactions
 
(CCPs) result in
 
liquidity exposure. The
 
Group maintains
 
cash resources to
 
meet all of
these needs. The Board Risk Committee sets liquidity limits to ensure
 
that sufficient funds are available to
 
meet such contingencies.
Past experience
 
shows that
 
liquidity requirements
 
to support
 
calls under
 
guarantees and
 
standby letters
 
of credit
 
are considerably
less than the amount
 
of the commitment. This is
 
also the case with credit
 
commitments where the outstanding
 
contractual amount
to extend
 
credit does
 
not necessarily
 
represent
 
future cash
 
requirements,
 
as many
 
of these
 
commitments will
 
expire or
 
terminate
without being funded.
The
 
matching
 
and
 
controlled
 
mismatching
 
of
 
the
 
maturities
 
and
 
interest
 
rates
 
of
 
assets
 
and
 
liabilities
 
is
 
fundamental
 
to
 
the
management of the
 
Group. It is
 
unusual for banks
 
to be completely
 
matched, as transacted
 
business is often
 
of uncertain term
 
and
of different types. An unmatched
 
position potentially enhances profitability,
 
but also increases the risk of losses.
The maturities of assets and liabilities and the ability to
 
replace, at an acceptable cost, interest
 
bearing liabilities as they mature, are
important factors in assessing the liquidity of the
 
Group.
Liquidity Risk Management Framework
The Group’s Liquidity Risk Policy
 
defines the following supervisory and control structure:
Board Risk Committee's role
 
is to approve all
 
strategic liquidity risk
 
management decisions and to monitor
 
the quantitative
and qualitative aspects of liquidity risk;
Group
 
Assets
 
and
 
Liabilities Committee
 
has
 
the
 
mandate
 
to
 
form
 
and
 
implement
 
the
 
liquidity
 
policies and
 
guidelines
 
in
conformity with Group's risk appetite, and
 
to review at least monthly the overall
 
liquidity position of the Group;
Group Treasury is responsible for the implementation of the
 
Group's liquidity strategy, taking into account the latest funding
plan and for the daily management of the Group’s
 
liquidity;
Group Market and Counterparty Risk Sector is responsible for measuring, controlling, monitoring and reporting the liquidity
risk of the Group.
The main items related to liquidity risk that are
 
monitored on a periodic basis are summarized as follows:
The analysis of liquidity buffer held on Group level
 
per asset type and per subsidiary;
The Liquidity Coverage Ratio (LCR) both in solo
 
and group level;
The Net Stable Funding Ratio (NSFR) both in solo and group level;
Liquidity stress
 
test
 
scenarios. These
 
scenarios evaluate
 
the impact
 
of a
 
number of
 
stress events
 
on the
 
Group's liquidity
position;
Market sensitivities affecting liquidity;
The Additional Liquidity Monitoring Metrics (ALMM) both in solo and group level;
The Asset Encumbrance (AE) both in solo and group level;
Monitoring and implementation of the funding plan.
 
 
 
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Notes to the Consolidated Financial Statements
 
.
 
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|
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31 December 2024 Consolidated Financial Statements
Maturity analysis of assets and assets held for managing liquidity risk
The following tables present maturity analysis of Group assets as at 31 December 2024 and 2023, based on their carrying values. The
Group has established credit risk mitigation contracts
 
with its interbank counterparties (ISDA/CSA). Under these contracts
 
the Group
has
 
posted
 
or
 
received
 
collateral,
 
which
 
covers
 
the
 
corresponding
 
net
 
liabilities
 
or
 
net
 
assets
 
from
 
derivative
 
transactions.
 
The
collateral
 
posted
 
is
 
not
 
presented
 
in
 
the
 
below
 
tables.
 
For
 
derivative
 
assets
 
not
 
covered
 
by
 
ISDA/CSA
 
agreements
 
the
 
positive
valuation is presented at fair
 
value in the ‘over 1 year’ time bucket.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Less than 1
month
1 - 3
months
3 months
to 1 year
Over 1
year
Total
€ million
€ million
€ million
€ million
€ million
- Cash and balances with central banks
16,131
-
-
-
16,131
- Due from credit institutions
1,275
121
50
250
1,696
- Loans and advances to customers
3,304
1,557
3,894
42,198
50,953
- Debt Securities
246
332
1,275
20,092
21,945
- Equity securities
-
-
-
524
524
- Derivative financial instruments
-
-
-
6
6
- Other assets⁽¹⁾
60
16
8
8,388
8,472
- Assets of disposal groups classified as held for sale (note 30)
-
12
79
-
91
Total
21,016
2,038
5,306
71,458
99,818
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Less than 1
month
1 - 3
months
3 months
to 1 year
Over 1
year
Total
€ million
€ million
€ million
€ million
€ million
- Cash and balances with central banks
10,943
-
-
-
10,943
- Due from credit institutions
841
128
-
330
1,299
- Loans and advances to customers
2,841
1,348
3,817
33,539
41,545
- Debt Securities
 
72
93
617
13,919
14,701
- Equity securities
 
-
-
-
388
388
- Derivative financial instruments
-
-
-
13
13
- Other assets⁽¹⁾
62
16
8
8,677
8,763
- Assets of disposal groups classified as held for sale
-
-
206
-
206
Total
14,759
1,585
4,648
56,866
77,858
(1)
 
Other assets include Investments in associates and joint ventures, Property and equipment, Investment property,
 
Intangible assets, Deferred tax assets and
Other assets.
The
 
Group
 
holds
 
a
 
diversified
 
portfolio
 
of
 
cash
 
and
 
highly
 
liquid
 
assets
 
to
 
support
 
payment
 
obligations
 
and
 
contingent
 
deposit
withdrawals in a stressed market
 
environment. The Group's assets held for
 
managing liquidity risk comprise:
(a) Cash and balances with central banks;
(b) Eligible bonds and other financial assets for collateral
 
purposes; and
(c) Current accounts with banks and interbank
 
placings maturing within one month.
The unutilized assets, containing highly liquid and central banks eligible assets, provide
 
a contingent liquidity reserve of € 40.1 billion
as
 
of
 
31 December
 
2024
 
(2023:
 
 
22.3
 
billion).
 
This
 
increase
 
is
 
attributed
 
mainly
 
to:
 
i)
 
inflows
 
due
 
to
 
customer
 
deposits
 
(annual
increase by € 6 billion), ii) EMTN
 
and Tier II issuances equal to € 2 billion),
 
and iii) the impact from the consolidation
 
of Hellenic Bank
(€ 11 billion)
 
(note 23.2).
 
In addition,
 
the Group
 
holds other types
 
of liquid assets,
 
as defined by
 
the regulator,
 
amounting to
 
€ 6.6
billion (cash value) (2023: €
 
7.0 billion). It should be noted that
 
a part of the ECB available
 
collateral of € 7 billion
 
(cash value) (2023:
 
1.8
 
billion)
 
is
 
held
 
by
 
Group’s
 
subsidiaries
 
for
 
which
 
regulatory
 
restrictions
 
are
 
applied
 
and
 
currently
 
limit
 
the
 
level
 
of
 
its
transferability between
 
group entities.
 
 
 
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Notes to the Consolidated Financial Statements
 
.
 
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|
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31 December 2024 Consolidated Financial Statements
Maturity analysis of liabilities
The amounts disclosed
 
in the
 
tables below are
 
the contractual undiscounted cash
 
flows for the
 
years 2024 and
 
2023. Liabilities without
contractual
 
maturities (sight
 
and saving
 
deposits) are
 
presented in
 
the ‘less
 
than 1 month’
 
time bucket.
 
The Group
 
has established
credit risk
 
mitigation
 
contracts with
 
its interbank
 
counterparties (ISDA/CSA).
 
Due to
 
these contracts
 
the Group
 
has already
 
posted
collateral which covers the valuation
 
of its net liabilities from interbank derivatives. For derivative liabilities not covered
 
by ISDA/CSA
agreements the negative valuation
 
is presented at fair value in the ‘less than
 
1 month’ time bucket.
It should be noted that this table represents the worst case scenario since it is based on the assumption that all liabilities will be paid
at maturity
 
and they will
 
not be rolled
 
over
 
(e.g. all term
 
deposits are
 
withdrawn at
 
their contractual
 
maturity.
 
Even in
 
an adverse
scenario of a systemic financial crisis the likelihood
 
of such an event is remote.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Gross nominal
 
Less than
1 - 3
3 months
Over
(inflow)/
 
1 month
months
 
to 1 year
1 year
outflow
€ million
€ million
€ million
€ million
€ million
Non-derivative liabilities:
- Due to central banks and credit institutions
992
1,032
251
1,109
3,384
- Due to customers
59,640
7,912
10,166
984
78,702
- Debt securities in issue
90
36
478
8,096
8,700
- Lease liabilities
 
4
7
29
181
221
- Insurance contract liabilities
-
5
15
88
108
- Other liabilities
482
1,471
433
-
2,386
61,208
10,463
11,372
10,458
93,501
Derivative financial instruments
6
-
-
-
6
 
Off-balance sheet items
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Less than
Over
1 year
1 year
€ million
€ million
Credit related commitments
6,241
7,767
Contractual commitments⁽¹⁾
51
Total
6,292
7,767
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Gross nominal
 
Less than
1 - 3
3 months
Over
(inflow)/
 
1 month
months
 
to 1 year
1 year
outflow
€ million
€ million
€ million
€ million
€ million
Non-derivative liabilities:
- Due to central banks and credit institutions
713
2,889
3,079
396
7,077
- Due to customers
44,691
5,775
6,682
424
57,572
- Debt securities in issue
75
593
245
4,986
5,899
- Lease liabilities
 
4
16
55
143
218
- Other liabilities
501
460
234
-
1,195
45,984
9,733
10,295
5,949
71,961
Derivative financial instruments
11
-
-
-
11
 
 
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Notes to the Consolidated Financial Statements
 
.
 
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|
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31 December 2024 Consolidated Financial Statements
 
Off-balance sheet items
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Less than
Over
1 year
1 year
€ million
€ million
Credit related commitments
2,429
8,989
Contractual commitments⁽¹⁾
41
-
Total
2,470
8,989
(1)
 
It refers to contractual commitments for the purchase of own used, investment property and intangible assets (note 43).
 
5.2.4 Sustainability risks
Sustainability risks are neither new
 
nor stand-alone risks, rather they are
 
transverse risks, manifesting
 
through existing risk types. As
sustainability risks interact with other risks and result in direct
 
distributional impacts and indirect macroeconomic impacts, the Group
understands that careful consideration of the cross-cutting nature thereof
 
is necessary in
 
order to ensure the
 
optimal implementation
of adaptation activities.
Specifically,
 
sustainability
 
risks are
 
defined as
 
potential
 
losses arising
 
from any
 
negative
 
financial impact
 
for
 
the Group,
 
stemming
from current or prospective impacts of
 
any climate-related & environmental, social or governance event(s) on Group’s counterparties
or invested assets.
Definitions of sustainability risks include the following:
Climate-Related
 
and Environmental
 
risks:
 
Climate-related
 
and environmental
 
risks
 
are
 
defined
 
as the
 
risks
 
deriving from
potential loss or
 
negative impact
 
to the Group,
 
including loss/ damage to
 
physical assets,
 
disruption of business
 
or system
failures,
 
transition
 
expenditures
 
and
 
reputational
 
effects
 
from
 
the
 
adverse
 
consequences
 
of
 
climate
 
change
 
and
environmental degradation.
Social risk: Social risk refers
 
to potential losses arising
 
from any negative
 
financial impact on the Group
 
stemming from the
current
 
or
 
prospective
 
impacts
 
of
 
social
 
factors
 
(such
 
as
 
human
 
rights
 
violation,
 
income
 
inequality,
 
customer
 
safety
 
&
protection and consumers’ changing preferences)
 
on the Group’s counterparties
 
or invested assets.
Governance
 
risk:
 
Governance
 
risk
 
refers
 
to
 
potential
 
losses
 
arising
 
from
 
any
 
negative
 
financial
 
impact
 
on
 
the
 
Group
stemming from the current or prospective impacts of governance factors (such as anti-financial crime, non-compliance with
policies or regulations and governance practices) on the
 
Group’s counterparties
 
or invested assets.
The Group is adopting a strategic approach towards
 
sustainability, climate change risk identification
 
and risk management, signifying
the great
 
importance that
 
is given
 
in the
 
risks
 
and opportunities
 
arising from
 
the transitioning
 
to
 
a low-carbon
 
and more
 
circular
economy. In
 
this context, the Bank has approved and implements
 
its Financed Impact Strategy,
 
which focuses on:
Clients’ engagement and awareness
 
to adapt their business so as to address climate change challenges and
 
opportunities
Actions for supporting clients in their transition efforts
 
towards a more sustainable economic environment
Enablers and tools, such as frameworks
 
and products, to underpin sustainable financing
Assessment and
 
management of
 
sustainability
 
related
 
risks within
 
its loan
 
and investment
 
portfolios,
 
including assessing
exposure to transition and physical
 
risks linked to climate change.
To
 
facilitate
 
the
 
classification
 
of
 
sustainable/green
 
financing
 
opportunities
 
in
 
a
 
structural
 
manner,
 
the
 
Group
 
has
 
developed
 
its
Sustainable Finance Framework (SFF). Through its SFF,
 
the Group is able to classify sustainable lending solutions offered to its clients,
specifying the applied classification approach
 
and the activities defined as eligible to
 
access sustainable financing (eligible green
 
and
social
 
assets).
 
Moreover,
 
the
 
Group
 
maintains
 
a
 
Sustainable
 
Investment
 
Framework
 
(SIF),
 
which
 
outlines
 
the
 
Group’s
 
various
sustainable investment
 
approaches/ strategies
 
based on criteria observed
 
as per international
 
market practices,
 
the process for
 
the
selection of eligible investments, as well as the
 
monitoring frequency applicable to the sustainable portfolio.
Furthermore,
 
the
 
Group
 
has
 
updated
 
its
 
Sustainability
 
Governance
 
structure
 
by
 
introducing
 
and
 
defining
 
specific
 
roles
 
and
responsibilities in
 
order to
 
support the roll
 
-out of the
 
Sustainability Strategy
 
and the integration
 
of sustainability
 
risks, through
 
the
involvement
 
of various
 
key stakeholders
 
(i.e. Business
 
& Risk
 
Units, Committees,
 
etc.). The
 
Group applies
 
a model
 
of defined
 
roles
and responsibilities regarding the management
 
of sustainability risks across the 3 Lines of Defense.
Notes to the Consolidated Financial Statements
 
.
 
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|
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31 December 2024 Consolidated Financial Statements
 
 
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In this
 
context and
 
taking into
 
account the
 
significant impact
 
of sustainability
 
risks both
 
on financial
 
institutions and
 
on the
 
global
economy,
 
the
 
Group
 
developed
 
and
 
approved
 
its
 
Sustainability
 
Risk
 
Management
 
Policy
 
which
 
aims
 
at
 
fostering
 
a
 
holistic
understanding of the effects of sustainability
 
risks on its business model, as well as support decision-making regarding these matters
and provide a robust
 
governance under its Risk Management
 
Framework. The purpose
 
of the Policy is to
 
provide an overview
 
and a
common
 
understanding
 
of
 
Group’s
 
main
 
governance
 
arrangements,
 
as
 
well
 
as
 
roles
 
&
 
responsibilities
 
undertaken
 
by
 
the
 
Group
Sustainability Risk (GSR), in the context of the Group’s
 
overall Sustainability risks management activities.
GSR has the overall responsibility for overseeing,
 
monitoring, and managing sustainability risks. More specifically,
 
GSR:
prepares
 
and
 
maintains
 
the
 
Bank’s
 
Sustainability
 
Risk
 
Management
 
Policy,
 
as
 
well
 
as
 
relevant
 
policies,
 
processes
 
and
methodologies
 
(e.g.
 
ESG
 
Risk
 
Assessment,
 
Climate
 
Risk
 
Scorecard,
 
exclusion
 
lists)
 
in
 
collaboration
 
with
 
the
 
Group
Sustainability Unit, Business & Risk Units.
leads the
 
development
 
and implementation
 
of the
 
Sustainability
 
risk related
 
framework,
 
as well
 
as relevant
 
policies and
processes
 
(e.g., Sustainability
 
Risk Management
 
Framework,
 
Climate
 
Risk
 
Stress
 
Test
 
Framework
 
documents)
 
across
 
the
Group,
 
in
 
coordination
 
with
 
other
 
involved
 
units,
 
as
 
well
 
as
 
the
 
development
 
and
 
update
 
of
 
the
 
Sustainable
 
Finance
Frameworks.
monitors and reports to the Group Senior Sustainability Officer
 
(GSSO) the progress of the implementation of
 
the developed
Climate Risk action plan and reports to the Board for
 
Sustainability Risk matters.
supports, reviews and challenges the involved
 
stakeholders, across the Group,
 
regarding the setting of the Net Zero
 
targets
and of the Financed Impact Strategy implementation, through the identification of material Sustainability risk related areas.
leads the 2nd Line of Defense
 
independent sustainable lending re
 
-assessment process (i.e. provides
 
opinion on sustainable
financings
 
regarding
 
the
 
CIB
 
Portfolio,
 
as
 
part
 
of
 
a
 
bespoke
 
process
 
and
 
the
 
characterization
 
of
 
products
 
of
 
the
 
Retail
Portfolio as sustainable) against
 
the Sustainable Finance criteria (as per pre-determined
 
thresholds).
develops
 
and maintains
 
the Climate
 
Risk Stress
 
Testing
 
(CRST) Framework,
 
as well
 
as scenario
 
analysis and
 
stress testing
methodologies, and coordinates the performance of sustainability risk scenario analysis and relevant stress test exercises at
Group level.
Further information on sustainability risks
 
is provided in the Group’s
 
Sustainability Statement as at 31 December 2024.
 
5.3
 
Fair value of financial assets and liabilities
Fair value is
 
the price that
 
would be received
 
to sell an asset
 
or paid to
 
transfer a
 
liability in an orderly
 
transaction between
 
market
participants in
 
the principal (or
 
most advantageous)
 
market at
 
the measurement
 
date under
 
current market
 
conditions (i.e. an
 
exit
price).
 
When
 
a
 
quoted
 
price
 
for
 
an
 
identical
 
asset
 
or
 
liability
 
is
 
not
 
observable,
 
fair
 
value
 
is
 
measured
 
using
 
another
 
valuation
technique that
 
is appropriate
 
in the
 
circumstances
 
and maximizes
 
the use
 
of relevant
 
observable inputs
 
and minimizes
 
the use
 
of
unobservable inputs. Observable inputs are developed
 
using market data, such as publicly available
 
information about actual events
or transactions, and reflect assumptions that market participants would
 
use when pricing financial
 
instruments, such as quoted prices
in active markets for similar instruments,
 
interest rates and yield curves,
 
implied volatilities and credit spreads.
The Group’s financial instruments measured at fair value or at amortized cost for which fair value is disclosed
 
are categorized into the
three levels of the fair value hierarchy
 
based on whether the inputs to the fair values are observable or
 
unobservable, as follows:
(a)
 
Level 1-Financial instruments measured based on quoted prices (unadjusted)
 
in active markets for identical financial instruments
that the Group can
 
access at the measurement date.
 
A market is considered
 
active when quoted prices are
 
readily and regularly
available
 
from
 
an
 
exchange,
 
dealer,
 
broker,
 
industry
 
group,
 
pricing
 
service,
 
or
 
regulatory
 
agency
 
and
 
represent
 
actually
 
and
regularly
 
occurring
 
transactions.
 
Level
 
1 financial
 
instruments
 
include
 
actively
 
quoted
 
debt
 
instruments
 
held
 
or
 
issued
 
by the
Group,
 
equity
 
and
 
derivative
 
instruments
 
traded
 
on
 
exchanges,
 
as
 
well
 
as
 
mutual
 
funds
 
that
 
have
 
regularly
 
and
 
frequently
published quotes.
(b)
 
Level
 
2-Financial
 
instruments
 
measured
 
using
 
valuation
 
techniques
 
with
 
inputs,
 
other
 
than
 
level
 
1
 
quoted
 
prices,
 
that
 
are
observable either directly or
 
indirectly, such as: i)
 
quoted prices for similar
 
financial instruments in active
 
markets, ii) quoted prices
for identical or similar financial instruments in markets
 
that are not active, iii) inputs other than quoted prices that are directly or
indirectly observable,
 
mainly interest
 
rates and
 
yield curves observable
 
at commonly
 
quoted intervals,
 
forward exchange
 
rates,
equity prices, credit spreads and implied volatilities obtained from internationally recognized market
 
data providers and iv) other
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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unobservable inputs which
 
are insignificant to
 
the entire fair
 
value measurement. Level
 
2 financial instruments
 
include over the
counter (OTC) derivatives,
 
less liquid debt instruments held or issued by the Group and equity instruments.
(c)
 
Level
 
3-Financial
 
instruments
 
measured
 
using
 
valuation
 
techniques
 
with
 
significant
 
unobservable
 
inputs.
 
When
 
developing
unobservable
 
inputs,
 
best
 
information
 
available
 
is
 
used,
 
including
 
own
 
data,
 
while
 
at
 
the
 
same
 
time
 
market
 
participants'
assumptions are reflected (e.g.
 
assumptions about risk). Level
 
3 financial instruments include
 
unquoted equities or equities
 
traded
in markets that are not considered active, certain OTC derivatives, loans and advances to customers including securitization notes
of loan
 
portfolios
 
originated
 
by the
 
Group
 
and recognized
 
in financial
 
assets and
 
certain debt
 
securities held
 
or issued
 
by the
Group.
Financial instruments carried at fair value
The fair value hierarchy categorization of the
 
Group's financial assets and
 
liabilities measured at
 
fair value is presented in
 
the following
tables:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Level 1
Level 2
Level 3
Total
€ million
€ million
€ million
€ million
Securities held for trading
285
0
-
285
Investment securities at FVTPL
259
33
92
384
Derivative financial instruments⁽¹⁾
0
838
-
838
Investment securities at FVOCI
3,881
191
77
4,148
Loans and advances to customers mandatorily
 
at FVTPL
-
-
19
19
Financial assets measured at fair value
4,425
1,062
188
5,675
Derivative financial instruments⁽¹⁾
1
1,119
-
1,120
Trading liabilities
43
-
-
43
Financial liabilities measured at fair value
44
1,119
-
1,163
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Level 1
Level 2
Level 3
Total
€ million
€ million
€ million
€ million
Securities held for trading
379
0
-
379
Investment securities at FVTPL
137
21
105
263
Derivative financial instruments⁽¹⁾
0
881
0
881
Investment securities at FVOCI
3,209
271
12
3,492
Loans and advances to customers mandatorily
 
at FVTPL
-
-
15
15
Financial assets measured at fair value
3,725
1,173
132
5,030
Derivative financial instruments⁽¹⁾
2
1,448
-
1,450
Trading liabilities
121
-
-
121
Financial liabilities measured at fair value
123
1,448
-
1,571
 
(1)
Amounts
are presented after offsetting € 619
 
million and € 420 million level 2
 
derivative financial assets and liabilities, respectively,
 
against cash collateral
received/pledged (2023: after offsetting € 752 million and € 492 million derivative financial
 
assets and liabilities, respectively) (note 5.2.1.4).
The Group
 
recognizes
 
transfers
 
into
 
and out
 
of the
 
fair value
 
hierarchy
 
levels at
 
the beginning
 
of the
 
quarter in
 
which a
 
financial
instrument's
 
transfer
 
was effected.
 
During the
 
year ended
 
31 December
 
2024, the
 
Group transferred
 
debt securities
 
measured at
FVOCI of € 94 million
 
from level 2 to
 
level 1 and € 26
 
million from level 2
 
to level 3, following
 
the enhancement of the methodology
applied for their classification (see below in section Group’s
 
valuation processes and techniques).
Reconciliation of Level 3 fair value measurements
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balance at 1 January
132
155
Arising from acquisition ⁽²⁾
20
-
Transfers
 
into Level 3
27
1
Transfers
 
out of Level 3
(0)
(7)
Additions, net of disposals and redemptions ⁽¹⁾
12
(20)
Total gain/(loss)
 
for the year included in profit or loss
1
3
Total gain/(loss)
 
for the year included in other comprehensive income
1
0
Foreign exchange differences and other
(4)
0
Balance at 31 December
188
132
(1)
 
Including capital returns on equity instruments.
 
(2)
 
It refers to Level 3 fair value measurements of Hellenic Bank group, which was consolidated as of the third quarter of 2024 (note 23.2).
 
 
Group's valuation processes and techniques
The Group’s
 
processes and procedures
 
governing the
 
fair valuations
 
are established
 
by the Group
 
Market Counterparty
 
Risk Sector
in line
 
with the
 
Group’s
 
accounting policies.
 
The Group
 
uses widely
 
recognized
 
valuation
 
models for
 
determining the
 
fair value
 
of
common
 
financial
 
instruments
 
that
 
are
 
not quoted
 
in an
 
active market,
 
such as
 
interest
 
and cross
 
currency
 
swaps,
 
that
 
use only
observable market data
 
and require little management
 
estimation and judgment. Specifically,
 
observable prices or model inputs are
usually
 
available
 
in
 
the
 
market
 
for
 
listed
 
debt
 
and
 
equity
 
securities,
 
exchange-traded
 
and
 
simple
 
over-the-counter
 
derivatives.
Availability
 
of
 
observable
 
market
 
prices
 
and
 
model
 
inputs
 
reduces
 
the
 
need
 
for
 
management
 
judgment
 
and
 
estimation
 
and
 
also
reduces
 
the uncertainty associated with determining fair values. For the year ended 31 December 2024, the Group has enhanced the
methodology applied for the classification of debt
 
securities into the three levels of
 
the fair value hierarchy, by assigning a rating scale
for each debt
 
security, based
 
on the quality and quantity
 
of the market data
 
inputs used to calculate
 
its fair value
 
at a specific date.
The debt securities are
 
then allocated into
 
levels based on specific rating
 
thresholds representing
 
highly liquid to thinly
 
traded debt
securities.
Where valuation
 
techniques are used
 
to determine the
 
fair values
 
of financial instruments
 
that are not
 
quoted in an
 
active market,
they
 
are
 
validated
 
against
 
historical
 
data
 
and,
 
where
 
possible,
 
against
 
current
 
or
 
recent
 
observed
 
transactions
 
in
 
different
instruments,
 
and
 
periodically
 
reviewed
 
by
 
qualified
 
personnel
 
independent
 
of
 
the
 
personnel
 
that
 
created
 
them.
 
All
 
models
 
are
certified before
 
they are
 
used and models
 
are calibrated
 
to ensure
 
that outputs reflect
 
actual data
 
and comparative
 
market prices.
Fair values’
 
estimates obtained
 
from models
 
are adjusted
 
for any
 
other factors,
 
such as liquidity
 
risk or model
 
uncertainties, to
 
the
extent that market
 
participants would take
 
them into account in
 
pricing the instrument. Fair
 
values also reflect the credit
 
risk of the
instrument and include adjustments to take
 
account of the credit risk of the Group and the counterparty,
 
where appropriate.
Valuation
 
controls applied by
 
the Group may
 
include verification of
 
observable pricing, re-performance
 
of model valuations,
 
review
and approval process for new models and/or changes
 
to models, calibration and back-testing against observable market transactions,
where available, analysis of
 
significant valuation movements, etc.
 
Where third parties'
 
valuations are used for
 
fair value measurement,
these are reviewed in order to ensure
 
compliance with the requirements of IFRS 13.
The fair values of
 
OTC derivative financial
 
instruments are estimated
 
by discounting expected cash
 
flows using market
 
interest rates
at the measurement date.
 
Counterparty credit risk adjustments
 
and own credit risk
 
adjustments are applied to
 
OTC derivatives, where
appropriate. Bilateral
 
credit risk adjustments
 
consider the expected cash
 
flows between the Group
 
and its counterparties under
 
the
relevant terms
 
of the derivative
 
instruments and the
 
effect of the
 
credit risk on
 
the valuation of
 
these cash flows.
 
As appropriate in
circumstances,
 
the Group
 
considers also
 
the effect
 
of any
 
credit risk
 
mitigating arrangements,
 
including collateral
 
agreements and
master netting agreements on the calculation of
 
credit risk valuation adjustments (CVAs). CVA calculation uses probabilities of default
(PDs) based
 
on observable
 
market data
 
such as
 
credit default
 
swaps (CDS)
 
spreads, where
 
appropriate, or
 
based on
 
internal rating
models.
 
The
 
Group
 
applies
 
similar
 
methodology
 
for
 
the
 
calculation
 
of
 
debit-value-adjustments
 
(DVAs),
 
when
 
applicable.
 
Where
valuation techniques
 
are based
 
on internal
 
rating models
 
and the
 
relevant
 
CVA is
 
significant to
 
the entire
 
fair value
 
measurement,
such
 
derivative
 
instruments
 
are
 
categorized
 
as
 
Level
 
3
 
in
 
the
 
fair
 
value
 
hierarchy.
 
A
 
reasonably
 
possible
 
change
 
in
 
the
 
main
unobservable input (i.e.
 
the recovery rate), used
 
in their valuation,
 
would not have
 
a significant effect on
 
their fair value measurement.
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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31 December 2024 Consolidated Financial Statements
 
 
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The Group
 
determines
 
fair values
 
for
 
debt securities
 
held using
 
quoted
 
market
 
prices in
 
active markets
 
for
 
securities with
 
similar
credit
 
risk,
 
maturity
 
and
 
yield, quoted
 
market
 
prices
 
in
 
non
 
active markets
 
for
 
identical
 
or
 
similar
 
financial
 
instruments,
 
or
 
using
discounted cash flows method.
Unquoted equity
 
instruments at
 
FVTPL, included
 
in Level
 
3, are estimated
 
using mainly
 
(i) third
 
parties' valuation
 
reports based
 
on
investees'
 
net
 
assets,
 
where
 
management
 
does
 
not
 
perform
 
any
 
further
 
significant
 
adjustments,
 
and
 
(ii)
 
net
 
assets'
 
valuations,
adjusted where considered necessary.
Loans and advances to customers including securitization notes of loan
 
portfolios originated by the Group with contractual cash flows
that do not represent
 
solely payments of principal and interest
 
(SPPI failures), are measured
 
mandatorily at fair value
 
through profit
or loss. Quoted market
 
prices are not available
 
as there are no active
 
markets where these
 
instruments are traded.
 
Their fair values
are estimated on an individual loan basis by discounting the future expected cash flows over the time period they are expected to
 
be
recovered, using an appropriate discount rate or by reference to other comparable assets of
 
the same type that have been
 
transacted
during
 
a
 
recent
 
time
 
period.
 
Expected
 
cash
 
flows,
 
which
 
incorporate
 
credit
 
risk,
 
represent
 
significant
 
unobservable
 
input
 
in
 
the
valuation and as such, the entire fair value
 
measurement is categorized as Level
 
3 in the fair value hierarchy.
Financial instruments not measured at fair value
The fair value hierarchy
 
categorization of the
 
Group’s financial assets
 
and liabilities not measured at fair
 
value on the balance sheet,
is presented in the following tables:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Level 1
Level 2
Level 3
Fair value
Carrying
amount⁽¹⁾
€ million
€ million
€ million
€ million
€ million
Loans and advances to customers
-
-
51,923
51,923
50,934
Investment securities at amortised cost
12,716
3,237
1,313
17,267
17,651
Financial assets not measured at fair value
12,716
3,237
53,236
69,190
68,585
Debt securities in issue
5,371
351
1,588
7,310
7,056
Financial liabilities not measured at fair value
5,371
351
1,588
7,310
7,056
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Level 1
Level 2
Level 3
Fair value
Carrying
amount
€ million
€ million
€ million
€ million
€ million
Loans and advances to customers
-
-
41,888
41,888
41,530
Investment securities at amortised cost
7,191
1,948
1,323
10,462
10,955
Financial assets not measured at fair value
7,191
1,948
43,211
52,350
52,485
Debt securities in issue
2,540
1,626
554
4,720
4,756
Financial liabilities not measured at fair value
2,540
1,626
554
4,720
4,756
 
(1)
 
Provisional fair
 
value adjustments resulting
 
from the acquisition
 
of Hellenic Bank
 
(note 23.2), are
 
not reflected in
 
the carrying amount
 
of the acquired
 
financial
assets and liabilities.
The assumptions and methodologies underlying the calculation of fair values
 
of financial instruments not measured at fair value,
 
are
in line with those used to calculate the fair values for
 
financial instruments measured at fair value. Particularly:
(a)
Loans and advances to customers including
 
securitization notes of loan portfolios originated
 
by the Group: quoted market
 
prices
are not available as there are no active markets where these instruments are traded. The fair values are estimated by discounting
future expected
 
cash flows
 
over the
 
time period
 
they are
 
expected to
 
be recovered,
 
using appropriate
 
risk-adjusted
 
rates (i.e.,
discounted
 
expected
 
cash
 
flows
 
technique).
 
More
 
specifically,
 
loans
 
to
 
customers
 
are
 
grouped
 
into
 
homogenous
 
assets
 
with
similar
 
characteristics,
 
as
 
monitored
 
by
 
Management,
 
such
 
as
 
lending
 
business
 
unit,
 
products’
 
characteristics,
 
and
performing/nonperforming status, in
 
order to improve the
 
accuracy of the estimated
 
valuation outputs. In estimating
 
the future
cash flows of
 
lending portfolios, the
 
Group makes assumptions on
 
expected prepayments, products’ spreads over
 
risk-free interest
rates, where applicable. The discount
 
rates applied for the
 
discounting of loans’ expected
 
cash flows incorporate inputs that
 
would
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
be taken
 
into account by
 
independent market participants,
 
such as risk
-free interest
 
rates, expected
 
credit losses, cost
 
of equity
requirements and
 
funding. For credit
 
impaired-loans, the timing of
 
collateral realization
 
is taken into
 
account for the
 
estimation
of the future cash flows which are
 
discounted by non-credit risk adjusted
 
rates. In addition, the fair
 
value of securitization senior
notes of
 
loan portfolios
 
originated by
 
the Group
 
is estimated
 
by discounting
 
the expected
 
cash flows
 
using appropriate
 
market
interest rates of other
 
comparable assets with similar quality and duration;
(b)
Investment securities
 
measured at amortized
 
cost: the fair
 
values are determined
 
using prices quoted in
 
an active market
 
when
these are
 
available. In
 
other cases,
 
fair values
 
are determined
 
using quoted
 
market prices
 
for securities
 
with similar
 
credit risk,
maturity
 
and
 
yield,
 
quoted
 
market
 
prices
 
in
 
non
 
active
 
markets
 
for
 
identical
 
or
 
similar
 
financial
 
instruments,
 
or
 
by
 
using
 
the
discounted cash flows method. In addition, for certain high quality corporate bonds for which quoted prices are not available,
 
fair
value
 
is determined
 
using
 
prices that
 
are
 
derived
 
from
 
reliable data
 
management
 
platforms
 
while
 
part
 
of them
 
is verified
 
by
market
 
participants
 
(e.g. brokers).
 
In certain
 
cases, prices
 
are
 
implied by
 
liquidity agreements
 
(e.g. repos,
 
pledges) with
 
other
financial institutions; and
(c)
Debt securities in issue: the fair values are determined using quoted market prices,
 
if available. If quoted prices are not available,
fair values are determined based on third party
 
valuations, quotes for similar debt securities or by discounting the
 
expected cash
flows at a risk-adjusted rate, where the Group's own credit risk is
 
determined using inputs indirectly observable, i.e. quoted prices
of similar securities issued by the Group or other Greek issuers.
For other financial instruments, which are short term or re
 
-price at frequent intervals (cash and balances with central
 
banks, due
from credit
 
institutions, due
 
to central
 
banks, due
 
to credit
 
institutions and
 
due to
 
customers), the
 
carrying amounts
 
represent
reasonable approximations of fair values.
6.
 
Net interest income
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Interest income
Customers
2,479
2,122
- measured at amortised cost
2,479
2,121
- measured at FVTPL
0
1
Banks and other assets⁽¹⁾
583
460
Securities
618
429
- measured at amortised cost
492
309
- measured at FVOCI
119
107
- measured at FVTPL
7
13
Derivatives (hedge accounting)
507
527
Derivatives (no hedge accounting)
909
916
5,096
4,454
Interest expense
 
Customers ⁽¹⁾
(655)
(435)
Banks ⁽¹⁾
(291)
(317)
Debt securities in issue ⁽¹⁾
(300)
(222)
Derivatives (hedge accounting)
 
(454)
(430)
Derivatives (no hedge accounting)
 
(886)
(873)
Lease liabilities - IFRS 16
(3)
(3)
(2,589)
(2,280)
Total from continuing
 
operations
2,507
2,174
 
(1)
 
Measured at amortized cost.
.
In 2024, the increase
 
in net interest income is primarily attributable to the
 
consolidation of Hellenic Bank group as
 
of the third quarter
2024 contributing € 295 million (notes 23.2 and 44), the higher average interest rates, the loan growth and the increased positions in
investment bonds partly offset by
 
higher debt issued and deposits cost.
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
Interest income recognized
 
by quality of Loans and Advances and Product Line is further analyzed
 
below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Interest income
on non-impaired
loans and
advances
Interest
 
income on
impaired loans
and advances
Total
 
€ million
€ million
€ million
Retail lending
1,007
36
1,043
Wholesale lending⁽¹⁾
1,408
28
1,436
Total interest
 
income from customers
2,415
64
2,479
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Interest income
on non-impaired
loans and
advances
Interest
 
income on
impaired loans
and advances
Total
 
€ million
€ million
€ million
Retail lending
854
33
888
Wholesale lending⁽¹⁾
1,193
41
1,234
Total interest
 
income from customers
2,048
74
2,122
(1)
 
Including interest income on loans and advances to Public Sector.
7.
 
Net banking fee and commission income
The
 
following
 
tables
 
include
 
net
 
banking
 
fees
 
and
 
commission
 
income
 
from
 
contracts
 
with
 
customers
 
in
 
the
 
scope
 
of
 
IFRS
 
15,
disaggregated by major type of services and operating
 
segments (note 44).
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Retail
Corporate
Global
Markets &
Asset Mngt
International
Other ⁽²⁾
Total
€ million
€ million
€ million
€ million
€ million
€ million
Lending related activities
7
120
33
25
1
186
Asset management ⁽¹⁾
22
2
50
15
3
92
Network activities and other ⁽³⁾
77
8
33
131
2
250
Capital markets
 
-
7
23
6
(2)
34
Total from continuing
 
operations ⁽⁴⁾
106
137
138
176
5
561
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Retail
Corporate
Global
Markets &
Asset Mngt
International
Other⁽²⁾
Total
€ million
€ million
€ million
€ million
€ million
€ million
Lending related activities
 
8
111
16
15
2
152
Asset management ⁽¹⁾
17
2
39
11
6
75
Network activities and other
 
⁽³⁾
62
7
31
90
3
193
Capital markets
 
-
7
16
6
(2)
27
Total from
 
continuing operations
87
127
102
122
9
447
(1)
 
It includes mutual funds, assets under management and bank assurance.
(2)
 
Includes “Remedial and Servicing Strategy” and “Other and elimination
 
center” segments.
(3)
 
Including income from credit cards related services.
(4)
It includes € 40 million referring to Hellenic Bank group, which was consolidated
 
as of the third quarter of 2024 (notes 23.2 and 44).
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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31 December 2024 Consolidated Financial Statements
8.
 
Income from non banking services
Income
 
from
 
non
 
banking
 
services
 
from
 
continuing
 
operations
 
includes
 
(a)
 
net
 
insurance
 
income
 
of
 
 
8.1
 
million,
 
following
 
the
consolidation of Hellenic Bank group as of the third quarter 2024 (note 23.2), (b) rental income of € 95.8 million (31 December 2023:
€ 95.5 million) from real estate properties and (c) income of € 1.1 million (31 December 2023: € 1.0 million) from IT services provided
by the Group entities.
The breakdown of the net insurance income is set out
 
below.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Life
 
insurance
Non-Life
insurance
Total
€ million
€ million
€ million
Insurance revenue
11
22
33
Insurance service expenses
(5)
(19)
(24)
Insurance service result from insurance contracts issued
6
3
9
Allocation of reinsurance premiums
(4)
(10)
(14)
Amounts recoverable from reinsures
5
9
14
Net expense from reinsurance contracts held
 
1
(1)
(0)
Net insurance service result
7
2
9
Finance income/(expense) from
 
insurance/reinsurance contracts
(1)
(0)
(1)
Total
6
2
8
9.
 
Net trading income and gains less losses from investment securities
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Net trading income/(loss)
Debt securities, including short positions
(3)
(24)
Derivative financial instruments
84
86
Equity securities⁽¹⁾
8
4
Revaluation on foreign exchange
 
positions
5
5
Total
94
71
Gains less losses from investment securities
Debt securities
 
2
38
- measured at FVOCI ⁽²⁾
13
57
- measured at AC⁽³⁾
(12)
(18)
- measured at FVTPL
1
(1)
Equity securities
11
19
Total from
 
continuing operations
13
57
 
(1)
 
Includes € 16 million loss relating to
 
derivatives on equity instruments which is presented
 
along with equity securities that hedge economically
 
(2023: € 22
million loss).
(2)
It includes termination fees from related derivatives in single hedging relationships
 
amounting to € 5 million income (2023: € 6 million income)
 
(3)
 
Mainly refers to the disinvestment of short-term sovereign debt securities (note 5.2.1.3).
In the comparative
 
year trading results
 
include € 23
 
million loss on
 
short positions on
 
debt instruments
 
entered into
 
the context
 
of
the Group's economic hedging strategies.
Gains from
 
derivative
 
financial instruments
 
of €
 
84 million
 
comprise mainly
 
a) €
 
6 million
 
loss resulting
 
from fair
 
value changes
 
of
derivatives
 
not designated
 
in hedge
 
accounting relationships
 
(31 December
 
2023: €
 
33 million
 
loss) and
 
b) €
 
88 million
 
gains from
portfolio hedging of interest
 
rate risk (macro hedging)
 
(31 December 2023: € 124 million gains), of which
 
€ 3 million gains arise from
hedge ineffectiveness
 
and €
 
85 million
 
gains from
 
fair value
 
changes of
 
the hedging
 
derivatives that
 
occur as
 
part of
 
the dynamic
 
 
Notes to the Consolidated Financial Statements
 
.
 
104
|
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31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
management of the pool of hedging instruments on a monthly basis, and include fair value changes before initial designation or after
de-designation as well as realized gains of the
 
liquidated positions following de-designation (notes 2.2.3(i) and
 
19).
10.
 
Other income/ (expenses)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Gain/(loss) from change in fair value of investment
 
property (note 27)
17
6
Gain from acquisition/increase in shareholding of Hellenic Bank as an associate⁽¹⁾
99
111
Derecognition gain/(loss) on loans measured at
 
amortised cost (note 20)
5
3
Loss on loans' modifications and related adjustments
 
(97)
(49)
Fee expense related to the deferred
 
tax credits (note 13)
(5)
(6)
Dividend income
8
3
Gains/(losses) on loans at FVTPL
8
(0)
Gain on sale of real estate properties
12
3
Change in provisional fair value adjustments related to
 
the acquisition of Hellenic Bank
 
17
-
Other
 
(3)
(3)
Total from continuing
 
operations
61
68
(1)
Reflects the gain on initial application of equity accounting (2023) and the increase in ownership
 
interest in Hellenic Bank as an associate (note 24).
From the date of
 
acquisition of Hellenic
 
Bank till the
 
end of 2024,
 
the change in
 
provisional fair value adjustments from
 
the subsequent
measurement of the related assets and liabilities, amounted
 
to € 17 million income (note 23.2).
 
In the context of the
 
increased interest rates
 
environment, the Bank has
 
introduced since 2023 the probability
 
of prepayment on
 
its
floating rate
 
loans, focusing
 
on retail
 
portfolios
 
of long-term
 
loans that
 
are expected
 
to exhibit
 
higher,
 
than historically
 
observed,
prepayment
 
rates,
 
depending on
 
their particular
 
contractual
 
terms.
 
Accordingly,
 
for
 
performing retail
 
loans that
 
their contractual
interest rate
 
spread is scheduled to
 
increase (step-up) over the next
 
years, the Bank has assessed
 
that the combined increase
 
of the
reference interest
 
rates and
 
the pre-determined
 
client spreads,
 
increase the probability
 
of the borrowers’
 
prepaying or
 
refinancing
their loans at prevailing market rates
 
earlier than their contractual maturity.
The
 
Bank,
 
considering
 
the
 
current
 
and
 
expected
 
levels
 
of
 
the
 
reference
 
rates
 
as
 
well
 
as
 
the
 
prevailing
 
markets
 
rates
 
for
 
newly
originated loans, adjusts
 
the perimeter of
 
performing retail
 
loans that are likely
 
to be repaid
 
earlier and reassesses the
 
prepayment
probability
 
incorporated
 
in the
 
specific loans’
 
expected
 
cash flows,
 
adjusting
 
their gross
 
carrying amount
 
accordingly.
 
In the
 
year
ended
 
31
 
December
 
2024,
 
the
 
loss
 
resulting
 
from
 
the
 
extension
 
of
 
the
 
perimeter
 
of
 
the
 
said
 
loans
 
and
 
the
 
reassessment
 
of
 
the
prepayment probability,
 
which is included in “Loss on loans’ modification and related adjustments”,
 
amounted to ca. € 86 million (31
December 2023: € 35 million).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
105
|
Page
 
31 December 2024 Consolidated Financial Statements
11.
 
Operating expenses
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Staff costs
 
(588)
(473)
Administrative expenses
(338)
(275)
Contributions to resolution and deposit guarantee
 
funds
(11)
(33)
Depreciation of real estate properties
 
and equipment
(47)
(42)
Depreciation of right of use assets
(37)
(37)
Amortisation of intangible assets
(51)
(41)
Contribution to the school renovations program
 
(27)
-
Contribution to restoration
 
initiatives after natural disasters
-
(14)
Total from
 
continuing operations ⁽¹⁾
(1,099)
(915)
(1)
 
It includes € 127 million referring to Hellenic Bank group, which was consolidated as of the third quarter of
 
2024 (notes 23.2 and 44).
In the context of
 
the systemic banks’ participation in
 
the Greek state’s school renovation program, the
 
Bank has recognised
 
a provision
of € 27 million in the fourth quarter of 2024.
Pursuant to the notification of the Hellenic
 
Deposit and Investment Guarantee Fund (HDIGF) received by the Bank in November 2023,
no
 
additional
 
contributions
 
were
 
recognized
 
for
 
the
 
Resolution
 
Scheme
 
of
 
the
 
HDIGF
 
for
 
the
 
year
 
ended
 
31
 
December
 
2024.
 
In
addition, according to the announcement of the
 
Single Resolution Board on 15 February
 
2024, no regular annual contributions were
collected in 2024 from the institutions falling within the scope of
 
the Single Resolution Fund.
In
 
the third
 
quarter
 
of 2023,
 
the Bank
 
recognized
 
a provision
 
of
 
€ 13.5
 
million
 
for
 
its contribution
 
to
 
the restoration
 
of damages
following the recent natural disasters in Greece. This is mainly relating to the destructive floods in Thessaly and the relevant initiative
of the four Greek
 
systemic banks,
 
in the context
 
of their corporate
 
social responsibility,
 
to contribute € 50
 
million to the restoration
effort,
 
which
 
will
 
be
 
allocated
 
and
 
provided
 
mostly
 
for
 
infrastructure,
 
in
 
collaboration
 
with
 
the
 
related
 
ministries,
 
the
 
local
administration and social and economic institutions
 
of the region.
Staff costs
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Wages, salaries and performance remuneration
(446)
(355)
Social security costs
(62)
(52)
Additional pension and other post employment costs
(27)
(21)
Other
 
(53)
(45)
Total from
 
continuing operations
(588)
(473)
The
 
average
 
number
 
of
 
employees
 
during
 
the
 
year
 
was
 
11,810 (2023:
 
10,323
 
from
 
the
 
Group’s
 
continuing
 
operations).
 
As
 
at
 
31
December 2024, the number of branches and business/private banking
 
centers of the Group amounted to
 
568 (2023: 540).
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
106
|
Page
 
31 December 2024 Consolidated Financial Statements
12.
 
Other impairments, risk provisions and restructuring costs
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Impairment and valuation losses on real estate properties⁽¹⁾
(21)
(49)
Impairment losses on computer hardware and software (notes 26,
 
28)
(19)
(17)
Impairment (losses)/reversal on bonds
(12)
4
Other impairments, litigation and conduct-related
 
provisions and costs
 
(8)
(34)
Other impairments, risk provisions and related costs
(60)
(96)
Voluntary exit schemes and other related costs
 
(note 37)
(161)
(7)
Other restructuring costs
(7)
(30)
Restructuring costs
(168)
(37)
Total from continuing
 
operations⁽²⁾
(228)
(133)
(1)
For 2024, it includes € 9.4
 
million remeasurement/impairment loss
 
on real estate properties of IMO
 
Property Investments Bucuresti S.A., (note
 
30). For 2023,
it includes € 23 million remeasurement/impairment loss on real estate
 
properties of IMO Property Investments Sofia E.A.D,
 
which was disposed of during the
year (note 23.1).
(2)
It includes € 3 million referring to Hellenic Bank group, which was consolidated as of the third quarter of 2024 (notes 23.2 and 44).
For the
 
year ended
 
31 December
 
2024, an
 
amount
 
of ca.
 
€ 131
 
million, net
 
of the
 
discounting
 
effect,
 
has been
 
recognised
 
in the
Group’s income statement
 
for the cost of employee termination benefits in respect of the new Voluntary
 
Exit Scheme (VES) that was
launched by
 
the Group
 
in February
 
2024 for
 
eligible units
 
in Greece and
 
offered
 
mainly to
 
employees over
 
a specific age
 
limit. The
new VES is implemented through either lump-sum
 
payments or long term leaves during which they
 
will be receiving a percentage of
a monthly salary, or a
 
combination thereof. The
 
saving in personnel expenses is expected at
 
circa € 31 million on an annual basis
In the year
 
ended 31 December
 
2023, the Group
 
recognized €
 
30 million other
 
restructuring costs
 
of which €
 
10.6 million refers
 
to
the acquisition
 
of BNP
 
Paribas Personal
 
Finance Bulgaria
 
by Eurobank
 
Bulgaria A.D.,
 
while the
 
remaining costs
 
mainly relate
 
to the
Group’s transformation
 
projects and initiatives.
13.
Income tax
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Current tax ⁽¹⁾
 
(141)
 
(83)
Deferred tax
 
(220)
 
(178)
Total income tax from
 
continuing operations
 
 
(361)
 
(261)
 
(1)
 
In the year ended 31 December 2024, following a favorable court decision, the Group has recognized a tax income of €
 
20 million for tax claims against the
Greek State.
 
According
 
to
 
Law
 
4172/2013
 
currently
 
in
 
force,
 
the
 
nominal
 
Greek
 
corporate
 
tax
 
rate
 
for
 
credit
 
institutions
 
that
 
fall
 
under
 
the
requirements
 
of article 27A
 
of Law
 
4172/2013 regarding
 
eligible deferred
 
tax assets
 
(DTAs)/deferred
 
tax credits
 
(DTCs) agains
 
t
 
the
Greek State is 29%.
 
The Greek corporate tax
 
rate for legal entities
 
other than the
 
aforementioned credit institutions is
 
22%. In addition,
the withholding tax rate for
 
dividends distributed, other than
 
intragroup dividends, is 5%.
 
In particular, the intragroup dividends under
certain preconditions are relieved from
 
both income and withholding tax.
The nominal corporate tax
 
rates applicable in the banking
 
subsidiaries incorporated in the
 
international segment of the Group
 
(note
44) are as follows: Bulgaria 10%, Cyprus 12.5%
 
and Luxembourg 24.94%.
 
 
Notes to the Consolidated Financial Statements
 
.
 
107
|
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31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
 
Pillar Two income taxes
The Group is subject to the top
 
up tax under the Pillar Two
 
legislation that introduces a global minimum
 
effective tax rate
 
at 15% on
multinational entities with consolidated
 
revenues over € 750
 
million, effective as of 1
 
January 2024. The Pillar Two
 
effective tax rate
is lower than
 
15% in respect
 
of Group’s
 
operations in Bulgaria
 
and Cyprus, containing
 
the operations of
 
Eurobank Cyprus and
 
those
of Hellenic Bank group (note
 
44), mainly due to the
 
nominal corporate tax
 
rates (CIT) applying in
 
these jurisdictions (see above). For
the
 
year
 
ended
 
31
 
December
 
2024,
 
the
 
Group
 
has
 
recognized
 
a
 
current
 
tax
 
expense
 
of
 
 
21.6
 
million
 
related
 
to
 
the
 
top
 
up
 
tax
applicable on the profits earned in the aforementioned
 
jurisdictions.
The Group
 
has applied a
 
temporary mandatory
 
relief from
 
deferred
 
tax accounting
 
for the
 
impacts on the
 
top up
 
tax and
 
accounts
for it as a current tax when it is incurred.
Tax certificate
 
and open tax years
The Company and its subsidiaries, associates
 
and joint ventures, which operate
 
in Greece (notes 23 and 24) have
 
in principle up to 6
open tax years. For fiscal years starting from 1 January
 
2016 onwards, pursuant to the Tax Procedure Code, an ‘Annual Tax Certificate’
on an optional basis, is provided for the Greek entities, with annual financial statements audited compulsorily,
 
which is issued after a
tax audit is performed
 
by the same statutory auditor
 
or audit firm that audits the annual
 
financial statements. The Company
 
and, as
a general rule, the Group’s
 
Greek companies have opted to obtain
 
such certificate.
The Company’s
 
open tax years
 
are 2020-2024, while
 
the Bank’s
 
open tax years
 
are 2022-2024. The
 
tax certificates
 
of the Company,
the Bank and the other Group’s entities,
 
which operate in Greece, are unqualified for
 
their open tax years until 2023. In addition, for
the year ended 31 December 2024, the tax audits from external
 
auditors are in progress.
In accordance
 
with the
 
Greek tax
 
legislation and
 
the respective
 
Ministerial Decisions
 
issued, additional
 
taxes and
 
penalties may
 
be
imposed by
 
the Greek
 
tax authorities
 
following a
 
tax audit
 
within the applicable
 
statute
 
of limitations
 
(i.e. in principle
 
five years
 
as
from
 
the
 
end
 
of
 
the
 
fiscal
 
year
 
within
 
which
 
the
 
relevant
 
tax
 
return
 
should
 
have
 
been
 
submitted),
 
irrespective
 
of
 
whether
 
an
unqualified tax
 
certificate has
 
been obtained
 
from the
 
tax paying
 
company.
 
In light of
 
the above,
 
as a general
 
rule, the
 
right of the
Greek State
 
to impose taxes
 
up to tax
 
year 2018 (included)
 
has been time-barred
 
for the Group’s
 
Greek entities
 
as at 31
 
December
2024.
The open tax years of the foreign banking entities of the Group are as follows: (a) Eurobank Cyprus Ltd, 2018-2024 (a tax audit for tax
years
 
2018-2020
 
is
 
in
 
progress),
 
(b)
 
Hellenic
 
Bank
 
Public
 
Company
 
Limited,
 
2016-2024
 
(a
 
tax
 
audit
 
for
 
tax
 
years
 
2016-2022
 
is
 
in
progress),
 
(c) Eurobank Bulgaria
 
A.D., 2019-2024 and
 
(d) Eurobank Private
 
Bank Luxembourg S.A.,2020-2024.
 
The remaining foreign
entities of the Group (notes 23 and 24), which operate
 
in countries where a statutory
 
tax audit is explicitly stipulated by
 
law, have
 
in
principle up to 6 open tax years, subject to
 
certain preconditions of the applicable tax legislation of
 
each jurisdiction.
In reference
 
to its total
 
uncertain tax
 
positions, the Group
 
assesses all relevant
 
developments (e.g. legislative
 
changes, case
 
law,
 
ad
hoc tax/legal opinions, administrative
 
practices) and raises adequate provisions.
 
 
 
Deferred tax
Deferred tax
 
is calculated
 
on all deductible
 
temporary differences
 
under the
 
liability method as
 
well as for
 
unused tax losses
 
at the
rate in effect at
 
the time the reversal is expected to take
 
place.
The net deferred tax is analyzed
 
as follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Deferred tax assets
3,780
3,991
Deferred tax liabilities
(43)
(28)
Net deferred tax
3,737
3,963
The movement on deferred tax
 
is as follows:
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
108
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balance at 1 January
3,963
4,130
Arising from acquisition⁽¹⁾
(14)
-
Income statement credit/(charge) from
 
continuing operations
 
(220)
(178)
Investment securities at FVOCI
2
(8)
Cash flow hedges
0
1
Actuarial gains/(losses)
1
1
Discontinued operations (note 30)
3
17
Other
2
(0)
Balance at 31 December
3,737
3,963
 
(1)
 
it mainly includes deferred tax liability upon acquisition of Hellenic Bank group (note 23.2).
Deferred income tax (charge)/credit
 
from continuing operations is attributable
 
to the following items:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Impairment/ valuation relating to loans, disposals and write-offs
(251)
(213)
Tax deductible PSI+ losses
(50)
(50)
Carried forward debit difference of law 4831/2021
111
39
Change in fair value and other temporary differences
(30)
46
Deferred income tax (charge)/credit
 
from continuing operations
(220)
(178)
Deferred tax assets/(liabilities) are
 
attributable to the following items:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Impairment/ valuation relating to loans and accounting write-offs
803
940
PSI+ tax related losses
851
901
Losses from disposals and crystallized write-offs of loans
1,998
2,120
Carried forward debit difference of law 4831/2021
150
39
Other impairments/ valuations through the income statement
 
(94)
(49)
Cash flow hedges
6
6
SLSRI and employee termination benefits⁽²⁾
40
17
Real estate properties, equipment and intangible assets
(122)
(97)
Investment securities at FVOCI
(21)
(23)
Other⁽¹⁾⁽²⁾
126
109
Net deferred tax
3,737
3,963
 
(1)
 
It includes, among others, DTA on deductible temporary differences relating to operational risk provisions and the leasing operations.
 
(2)
 
DTA attributable to employee termination benefits (mainly referring to the new VES, note 12), previously included in line “Other”, has been presented along
with DTA on SLSRI. Comparative information has been adjusted accordingly.
Further information, in relation to
 
the aforementioned categories of deferred
 
tax assets as at 31 December 2024, is as follows:
(a)
 
 
803
 
million
 
refer
 
to
 
deductible
 
temporary
 
differences
 
arising
 
from
 
impairment/valuation
 
relating
 
to
 
loans
 
including
 
the
accounting debt write-offs
 
according to the Greek
 
tax law 4172/2013, as
 
in force. These temporary
 
differences can be utilized
 
in
future periods with no specified time limit and according to current
 
tax legislation of each jurisdiction;
(b) €
 
851 million
 
refer to
 
losses resulted
 
from the
 
Group’s
 
participation in
 
PSI+ and the
 
Greek’s
 
state debt
 
buyback program
 
which
are subject to amortization for tax purposes over a thirty-year period, i.e. 1/30 of
 
losses per year starting from year 2012 onwards
(see below – DTCs section);
(c) € 1,998 million refer to the unamortized part of the crystallized tax
 
losses arising from write-offs and disposals of loans, which are
subject to amortization over a twenty
 
-year period;
Notes to the Consolidated Financial Statements
 
.
 
109
|
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31 December 2024 Consolidated Financial Statements
 
 
 
doc1p253i0 doc1p253i1
 
Assessment of the recoverability of deferred
 
tax assets
The recognition
 
of the deferred
 
tax assets
 
is based on
 
management’s assessment
 
that the Group’s
 
legal entities will
 
have sufficient
future taxable profits, against which the deductible temporary differences and the unused tax losses can be utilized. The deferred tax
assets
 
are
 
determined
 
on
 
the
 
basis
 
of
 
the
 
tax
 
treatment
 
of
 
each
 
deferred
 
tax
 
asset
 
category,
 
as
 
provided
 
by
 
the
 
applicable
 
tax
legislation of each jurisdiction
 
and the eligibility of
 
carried forward
 
losses for offsetting
 
with future taxable
 
profits. Additionally,
 
the
Group’s
 
assessment
 
on
 
the
 
recoverability
 
of
 
recognized
 
deferred
 
tax
 
assets
 
is
 
based
 
on
 
(a)
 
the
 
future
 
performance
 
expectations
(projections
 
of
 
operating
 
results)
 
and
 
growth
 
opportunities
 
relevant
 
for
 
determining
 
the
 
expected
 
future
 
taxable
 
profits,
 
(b)
 
the
expected timing of reversal of the
 
deductible and taxable temporary
 
differences, (c) the probability
 
that the Group entities will have
sufficient taxable
 
profits in the
 
future, in the
 
same period as
 
the reversal
 
of the deductible
 
and taxable
 
temporary differences
 
or in
the years into which the tax losses can be carried forward, and (d) the historical levels of Group entities’ performance in combination
with the previous years’ tax losses caused
 
by one off or non-recurring events.
In particular,
 
for the year
 
ended 31 December
 
2024, the deferred
 
tax asset (DTA)
 
recoverability assessment
 
has been based on
 
the
three-year
 
Business Plan
 
that was
 
approved
 
by the
 
Board of
 
Directors
 
in January
 
2025, for
 
the period
 
up to
 
the end
 
of 2027
 
(also
submitted to
 
the Single Supervisory
 
Mechanism -SSM-). For
 
the years
 
beyond 2027,
 
the forecast
 
of operating
 
results was
 
based on
the management projections considering the growth opportunities
 
of the Greek and European economy,
 
the banking sector and the
Group
 
itself.
 
Specifically,
 
the
 
management
 
projections
 
for
 
the
 
Group’s
 
future
 
profitability
 
adopted
 
in
 
the
 
Business
 
Plan,
 
have
considered, among others, (a) the gradual decrease of interest rates
 
,
 
starting from 2024, (b) the sustainable increase in loan volumes
with pressure in business lending spreads and
 
the growth, at a relatively lower pace, of
 
customer deposits with gradually lower
 
betas,
(c) the increase in fee and commission income mostly
 
driven by assets under management, and network
 
activities,
 
(d) the discipline
to operating
 
expenses’ targets
 
, (e)
 
the further
 
decrease of
 
NPE ratio,
 
(f) the resilient
 
asset quality
 
with lower
 
cost of
 
risk, which
 
is
expected
 
to
 
carry the
 
effect
 
from the
 
improved
 
macroeconomic outlook
 
driven by
 
the resilient
 
growth
 
of Greek
 
economy,
 
above
European
 
average,
 
as well
 
as the
 
unemployment
 
rate
 
at single
 
digit levels,
 
close to
 
historical
 
lows and
 
(g) the
 
fulfilment of
 
MREL
targets
 
throughout
 
the plan
 
period. The
 
major initiatives
 
introduced
 
in the
 
context
 
of the
 
Group’s
 
transformation
 
plan “Eurobank
2030”, will contribute
 
to meeting its financial objectives.
The Group
 
closely monitors
 
and constantly
 
assesses the
 
developments
 
on the
 
macroeconomic and
 
geopolitical front
 
(note 2)
 
and
their potential
 
effect on
 
the achievement
 
of its Business
 
Plan targets
 
in terms of
 
asset quality and
 
profitability and
 
will continue
 
to
update its estimates accordingly.
Deferred tax credit against the
 
Greek State and tax regime for
 
loan losses
As at 31 December
 
2024, pursuant to the Law 4172/2013, as in force, the Bank’s eligible DTAs/deferred tax credits (DTCs) against the
Greek State
 
amounted to
 
€ 3,022 million (31
 
December 2023: €
 
3,212 million). The
 
DTCs are
 
accounted for
 
on: (a) the unamortised
losses from the Private
 
Sector Involvement (PSI)
 
and the Greek State Debt
 
Buyback Program, which are subject to
 
amortisation over
a thirty-year
 
period and
 
(b) on the
 
sum of (i)
 
the unamortized
 
part of the
 
DTC eligible
 
crystallized tax
 
losses arising
 
from write-offs
and disposals
 
of loans, which
 
are subject
 
to amortization
 
over a
 
twenty-year period,
 
(ii) the accounting
 
debt write-offs
 
and (iii) the
remaining
 
accumulated
 
provisions
 
and
 
other
 
losses
 
in
 
general
 
due
 
to
 
credit
 
risk
 
recorded
 
up
 
to
 
30
 
June
 
2015.
 
The
 
DTCs
 
will
 
be
converted into directly enforceable claims (tax credit) against
 
the Greek State provided that the Bank’s after tax accounting
 
result for
the year is a loss.
According
 
to
 
the
 
Law
 
4831/2021
 
(article
 
125),
 
which
 
amended
 
Law
 
4172/2013,
 
the
 
amortization
 
of
 
the
 
PSI
 
tax
 
related
 
losses
 
is
deducted from
 
the taxable
 
income at a
 
priority over
 
that of the
 
crystallized tax
 
losses (debit difference)
 
arising from
 
write-offs and
disposals of loans. In addition, the amount of the annual tax amortization of the above crystallized tax losses is limited to the amount
of the
 
annual taxable
 
profits, calculated
 
before the
 
deduction of
 
such losses
 
and following
 
the annual
 
tax deduction
 
of the
 
PSI tax
related losses. The
 
unutilized part of the
 
annual tax amortization
 
of the crystallized
 
loan losses can be carried
 
forward for
 
offsetting
over a period of 20
 
years. If at the end
 
of the 20-year utilization period, there are balances
 
that have not been offset, these will
 
qualify
as
 
a tax
 
loss, which
 
is subject
 
to
 
the
 
5-year
 
statute
 
of
 
limitation.
 
The above
 
provisions
 
apply
 
as
 
of
 
1 January
 
2021 and
 
cover
 
the
crystallized tax losses that
 
have arisen from write-offs and disposals of
 
loans as of 1 January 2016 onwards.
Taking
 
into
 
account
 
the
 
tax
 
regime
 
in
 
force,
 
the
 
recovery
 
of
 
the
 
Bank’s
 
deferred
 
tax
 
asset
 
recorded
 
on
 
loans
 
and
 
advances
 
to
customers
 
and
 
the
 
regulatory
 
capital
 
structure
 
are
 
further
 
safeguarded,
 
contributing
 
substantially
 
to
 
the
 
achievement
 
of
 
NPE
management targets through
 
write-offs and disposals, in line with the regulatory framework
 
and SSM requirements.
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
110
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
According to tax Law 4172/2013 as in
 
force, an annual fee of 1.5% is
 
imposed on the excess amount of
 
deferred tax assets guaranteed
by the Greek
 
State, stemming
 
from the difference
 
between the current
 
tax rate
 
for the eligible
 
credit institutions
 
(i.e. 29%) and
 
the
tax rate applicable on 30 June 2015 (i.e. 26%). For the year ended
 
31 December 2024, an amount of €
 
5.2 million has been recognized
in “Other income/(expenses) (31 December 2023: € 5.6 million).
Income tax reconciliation and unused tax losses
The tax on the
 
Group's profit before
 
tax differs
 
from the theoretical
 
amount that would
 
arise using the Bank’s
 
applicable tax rate
 
of
29% as follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Profit before tax
1,872
1,542
Tax at the applicable tax
 
rate
(543)
(447)
Tax effect
 
of:
- income not subject to tax and non deductible expenses
 
(16)
5
- effect of different tax rates
 
in different countries
134
70
- Share of results of associates/joint ventures and related income
76
58
- Tax deductible losses for which DTA
 
had not been recognised
18
63
- Pillar Two income taxes
(22)
-
- other
(8)
(10)
Total income tax from
 
continuing operations
(361)
(261)
For the year ended 31 December 2024, the Group’s
 
effective tax rate
 
reached 19% (2023: 17%).
As at 31 December
 
2024, the Company
 
and the Bank have
 
not recognised deferred
 
tax asset (DTA)
 
on unused tax losses
 
amounting
to € 362 million (2023: € 421
 
million). The analysis of unrecognized
 
DTA on
 
unused tax losses of the Company
 
and the Bank per year
of maturity of related tax losses is presented
 
in the table below:
 
 
 
 
 
 
Unrecognized
DTA
 
€ million
Year of maturity of unused tax losses
2025
347
2026
12
2027
1
2028
2
2029
1
Total
362
14.
 
Earnings per share
Basic earnings
 
per share,
 
in principle, is
 
calculated by
 
dividing the
 
net profit
 
attributable to
 
ordinary shareholders
 
by the
 
weighted
average number of ordinary shares in issue
 
during the year, excluding the average number of ordinary shares purchased by the Group
and held as treasury shares.
The diluted earnings
 
per share, in principle,
 
is calculated by
 
adjusting the weighted
 
average number
 
of ordinary shares
 
outstanding
to
 
assume
 
conversion
 
of
 
all
 
dilutive
 
potential
 
ordinary
 
shares
 
during
 
the
 
period.
 
As
 
at
 
31
 
December
 
2024,
 
the
 
Group’s
 
dilutive
potential
 
ordinary
 
shares
 
relate
 
to
 
the
 
share
 
options
 
that
 
were
 
allocated
 
to
 
employees
 
of
 
Eurobank
 
Holdings
 
and
 
its
 
affiliated
companies (note 40). The
 
weighted average
 
number of shares is adjusted
 
for the share
 
options by calculating the
 
weighted average
number of shares
 
that could have
 
been acquired at
 
fair value (determined
 
as the average
 
market price of
 
the Company's shares
 
for
the period). The number of shares resulting from
 
the above calculation is added to the weighted
 
average number of ordinary
 
shares
in issue in
 
order to determine
 
the weighted
 
average number
 
of ordinary shares
 
used for the
 
calculation of the
 
diluted earnings per
share.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
111
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Year ended 31 December
2024
2023
Net profit for the year attributable to ordinary shareholders
€ million
1,448
1,140
Net profit for the year from continuing operations attributable
 
to ordinary
shareholders
 
€ million
1,455
1,281
Weighted average number of ordinary
 
shares used for
 
basic earnings per share
Number of shares
3,665,235,475
3,698,802,084
Weighted average number of ordinary
 
shares used for diluted earnings per
share
Number of shares
3,682,680,282
3,713,688,124
Earnings per share
- Basic earnings per share
 
0.40
0.31
- Diluted earnings per share
 
0.39
0.31
Earnings per share from continuing operations
- Basic and diluted earnings per share
 
0.40
0.34
Basic and
 
diluted losses
 
per share
 
from discontinued
 
operations for
 
the year
 
ended 31
 
December 2024
 
amounted to
 
€ 0.0019
 
(31
December 2023: € 0.04 losses).
 
15.
 
Cash and balances with central banks
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Cash in hand
617
502
Balances with central banks
 
15,514
10,441
Total
16,131
10,943
The
 
Bank
 
and
 
its
 
banking
 
subsidiaries
 
in
 
Eurozone
 
(Cyprus
 
and
 
Luxemburg),
 
are
 
required
 
to
 
hold
 
a
 
minimum
 
level
 
of
 
deposits
(minimum reserve requirement
 
- MRR) with their national
 
central bank on an
 
average basis
 
over maintenance periods
 
(i.e. six week
periods);
 
these deposits
 
are
 
calculated
 
as 1%
 
of certain
 
liabilities, mainly
 
customers’
 
deposits, and
 
can be
 
withdrawn
 
at any
 
time
provided that the MRR is met over the determined period of time. Similar obligations for the maintenance of minimum reserves with
its national central bank are also applied to the banking subsidiary in
 
Bulgaria. As at 31 December 2024, the mandatory reserves (i.e.
those that
 
the Group
 
entities maintain
 
in order
 
to meet
 
the MRR)
 
with central
 
banks amounted
 
to €
 
1,652 million
 
(2023: €
 
1,096
million). MRR
 
deposits placed
 
to the
 
European Central
 
Bank (ECB)
 
were remunerated
 
at the
 
ECB’s
 
deposit facility
 
rate
 
(DFR) until
September 2023 and at zero (0%) thereafter.
.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
112
|
Page
 
31 December 2024 Consolidated Financial Statements
16.
 
Cash and cash equivalents and other information on cash flow statement
For the
 
purpose of
 
the cash
 
flow statement,
 
cash and
 
cash equivalents
 
comprise the
 
following balances
 
with original
 
maturities of
three months or less:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Cash and balances with central banks (excluding mandatory and collateral
 
deposits with
central banks) (note 15)
14,479
9,847
Due from credit institutions
1,398
998
Securities held for trading
31
0
Total
15,908
10,845
Other (income)/losses on investment securities presented
 
in continuing operating activities are analyzed
 
as follows:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Amortisation of premiums/discounts and accrued interest
(102)
(10)
(Gains)/losses from investment securities
(13)
(57)
Dividends
(8)
(3)
Total
(123)
(70)
In the year
 
ended 31 December
 
2024, other adjustments
 
of € 253
 
million mainly include
 
a) € 99
 
million gain on
 
acquisition of additional
holding in Hellenic Bank (note 23.2) and b) € 161 million Group’s
 
share of results (income) in associates and
 
joint ventures (note 24),
(31 December
 
2023: € 153
 
million mainly include
 
€ 111 million
 
gain on
 
investment
 
in Hellenic Bank
 
accounted for
 
as an associate,
note 24).
Changes in liabilities arising from financing activities
During the year ended
 
31 December 2024,
 
changes in the Group’s liabilities arising
 
from financing activities, other
 
than lease liabilities
(note 42),
 
are attributable
 
to: a) debt
 
issuance amounting
 
to € 2,649
 
million (2023: €
 
1,078 million) (net
 
of issuance costs),
 
b) debt
repayment amounting to € 789 million (2023: €
 
30 million) and c) accrued
 
interest and amortisation of debt issuance costs amounting
to € 1.4 million (2023: € 51.3 million).
17.
 
Due from credit institutions
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Pledged deposits with banks⁽¹⁾
580
1,036
Placements and other receivables from banks⁽¹⁾
1,112
970
Current accounts and settlement balances with banks
504
348
Total
2,196
2,354
(1)
 
The amounts presented are after offsetting (note 5.2.1.4).
As at 31 December 2024, the Group’s
 
pledged deposits with banks include: a) € 543 million mainly
 
cash collaterals on risk mitigation
contracts for derivative transactions and repurchase agreements (CSAs, GMRAs) and b) € 37 million
 
cash collateral relating to the sale
of former Romanian subsidiaries.
The
 
Group's
 
exposure
 
arising
 
from
 
credit
 
institutions,
 
as
 
categorized
 
by
 
counterparty's
 
geographical
 
region,
 
is
 
presented
 
in
 
the
following table:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Greece
14
59
Other European countries
1,874
2,139
Other countries
307
156
Total
2,196
2,354
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
113
|
Page
 
31 December 2024 Consolidated Financial Statements
18.
 
Securities held for trading
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Debt securities (note 5.2.1.3)
186
245
Equity securities
99
134
Total
285
379
19.
 
Derivative financial instruments and hedge accounting
The Group uses derivative financial instruments
 
both for hedging and non-hedging purposes.
The table below presents the fair values of the Group’s derivative financial instruments by product type and hedge relationship along
with
 
their
 
notional
 
amounts.
 
The
 
notional
 
amounts
 
of
 
derivative
 
instruments
 
provide
 
a
 
basis
 
for
 
comparison
 
with
 
instruments
recognized on
 
the balance sheet
 
but do not
 
necessarily indicate the
 
amounts of future
 
cash flows involved
 
or the current
 
fair value
of the instruments and, therefore, are
 
not indicative of the Group’s
 
exposure at the reporting date.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
31 December 2023
Contract /
notional
amount
Fair values
Contract /
notional
amount
Fair values
Assets
Liabilities
Assets
Liabilities
€ million
€ million
€ million
€ million
€ million
€ million
Derivatives for which hedge accounting is not
applied/ held for trading
- Interest rate swaps
34,439
1,096
937
33,909
1,215
1,059
- Interest rate options ⁽¹⁾
8,265
45
47
9,268
69
71
- Foreign exchange contracts ⁽²⁾
4,700
54
26
3,468
21
26
- Other
 
⁽³⁾
893
3
14
462
5
40
1,199
1,025
1,310
1,196
Derivatives designated as fair value hedges
- Interest rate swaps
12,171
244
442
8,221
308
452
- Interest rate swaps/portfolio hedging ⁽⁴⁾
7,800
6
2
6,642
15
94
- Interest rate floors
5,759
-
33
6,447
-
53
- Bond Forwards
55
1
-
-
-
-
251
477
323
599
Derivatives designated as cash flow hedges
- Cross currency interest
 
rate swaps
819
7
38
1,579
-
147
7
38
-
147
Offsetting (note 5.2.1.4)
- Interest rate swaps
(619)
(420)
(752)
(492)
Total derivatives assets/liabilities
838
1,120
881
1,450
 
(1)
Interest rate options include interest rate caps and floors and swaptions.
(2)
 
It includes currency swaps, forwards and options
(3)
It includes credit default swaps, warrants, commodity derivatives, futures and exchange traded equity options.
 
(4)
It includes deals that are transacted for macro hedging during the reporting
 
month and will be included in the pool of hedging instruments at the end of the
month.
Information on the fair value measurement
 
and offsetting of derivatives is provided
 
in notes 5.3 and 5.2.1.4, respectively.
 
Notes to the Consolidated Financial Statements
 
.
 
114
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
The
 
Group
 
uses
 
certain
 
derivatives
 
and
 
other
 
financial
 
instruments,
 
designated
 
in
 
a
 
qualifying
 
hedge
 
relationship,
 
to
 
reduce
 
its
exposure to market
 
risks. The hedging practices
 
applied by the Group,
 
as well as the
 
relevant accounting
 
treatment are disclosed
 
in
note 2.2.3. In particular:
(a) Fair value hedges
The Group
 
hedges a
 
portion of
 
its existing
 
interest
 
rate risk
 
resulting from
 
any potential
 
change in
 
the fair
 
value of
 
fixed rate
 
debt
securities, held
 
or issued,
 
or fixed
 
rate loans,
 
denominated both
 
in local
 
and foreign
 
currencies, using
 
interest rate
 
swaps whereby
the fixed
 
legs represent
 
the economic
 
risks of
 
the hedged
 
items. The
 
Group uses
 
pay fixed/receive
 
floating interest
 
rate
 
swaps to
hedge its fixed rate debt
 
securities held and loans and pay floating/receive fixed interest
 
rate swaps to hedge its
 
fixed rate liabilities.
The Group
 
also hedges
 
the changes
 
in the
 
fair value
 
of debt
 
securities to
 
be disposed
 
in the
 
future under
 
forward
 
transactions. In
2024,
 
the
 
Group
 
recognized
 
a loss
 
of
 
€ 34
 
million
 
(2023: €
 
175 million
 
loss)
 
from
 
changes
 
in the
 
carrying
 
amount
 
of the
 
hedging
instruments and
 
€ 27 million
 
gain (2023:
 
€ 173 million
 
gain) from
 
changes in
 
the fair
 
value of the
 
hedged items
 
attributable to
 
the
hedged risk. The amount
 
of hedge ineffectiveness
 
recognized for
 
2024 in “Net trading
 
income/(loss)” was € 7
 
million loss (2023: € 2
million loss).
(b) Fair value hedges – portfolios of assets
 
and liabilities
The Group hedges a portion of its existing interest rate risk resulting from any potential
 
change in the fair value of a portfolio of fixed
rate loans including securitization notes initially issued
 
and subsequently held by
 
the Group (macro-hedging), using a
 
group of interest
rate
 
swaps. The
 
Group
 
primarily designates
 
the change
 
in fair
 
value attributable
 
to changes
 
in the
 
benchmark interest
 
rate as
 
the
hedged risk including
 
also assumptions for
 
prepayment risk and,
 
accordingly,
 
enters into
 
interest rate
 
swaps whereby
 
the fixed legs
represent the economic risks of the hedged items. In 2024, the Group recognized a gain of €
 
20 million (2023: € 139 million loss)
 
from
changes in the
 
carrying amount of
 
the hedging instruments
 
and € 18
 
million loss (2023:
 
€ 145 million
 
gain)
 
from changes in
 
the fair
value of the
 
designated hedged
 
items attributable
 
to the hedged
 
risk. Accordingly,
 
the amount of
 
hedge ineffectiveness
 
recognized
for 2024 in “Net trading income/(loss)” was
 
€ 2 million gain (2023:
 
€ 6 million gain).
The Group
 
also hedges the
 
variability deriving
 
from the fair
 
value changes of
 
purchased interest
 
rate floors
 
embedded in portfolios
of floating
 
rate
 
loans and
 
debt securities
 
by writing
 
the floors
 
in the
 
market.
 
In 2024,
 
the Group
 
recognized
 
a gain
 
of €
 
15 million
(2023: € 45 ths gain) from changes in the carrying amount of the hedging instruments, and € 15 million loss (2023: € 45
 
ths loss) from
changes in the fair value of the hedged items attributable
 
to the hedged risk.
Finally,
 
similar to
 
portfolio
 
hedging of
 
interest
 
rate
 
risk for
 
assets, the
 
Group
 
hedges part
 
of its
 
interest
 
rate
 
exposure
 
of demand
deposit portfolios attributable
 
to changes in the benchmark interest
 
rates (macro-hedging). Despite
 
their contractual terms and due
to their nature,
 
part of the demand deposits
 
are interest
 
rate-insensitive and
 
hence behave similarly to
 
fixed interest
 
rate liabilities.
Accordingly, the Group enters into a group of interest rate swaps that receives fixed interest rate and pays floating interest rate based
on the benchmark rate
 
and its volume is re-assessed on a
 
monthly basis. In 2024, the Group recognized
 
a loss of € 1 million (2023: €
7 million
 
loss) from
 
changes in
 
the carrying
 
amount of
 
the hedging
 
instruments
 
and €
 
2 million
 
gain (2023:
 
€ 5
 
million gain)
 
from
changes
 
in
 
the
 
fair
 
value
 
of
 
the
 
designated
 
hedged
 
items
 
attributable
 
to
 
the
 
hedged
 
risk.
 
Accordingly,
 
the
 
amount
 
of
 
hedge
ineffectiveness recognized
 
for 2024 in “Net trading income/(loss)” was
 
€ 1 million gain (2023: € 2 million loss).
(c) Cash flow hedges
The Group hedges
 
a portion of
 
its existing interest rate and
 
foreign currency risk resulting
 
from any cash flow
 
variability due to
 
changes
in market interest
 
rates on floating rate
 
loans, denominated in foreign currency,
 
using cross currency interest
 
rate swaps, where
 
the
variable legs are based
 
on the benchmark rates
 
of the hedged items. The
 
interest rate
 
risk with respect to the
 
benchmark reference
rate -
 
swap curve
 
of such items,
 
which share the
 
same benchmark interest
 
rate risk
 
may be hedged
 
on a single
 
item or group
 
basis
using interest rate
 
swaps of similar maturity.
 
For the year ended 31 December 2024, an amount
 
of € 1 million loss was recognised in
other comprehensive income in relation to derivatives
 
designated as cash flow hedges (2023: € 3 million loss). Furthermore, in 2024,
the ineffectiveness recognized
 
in the income statement that
 
arose from cash flow hedges was nil (2023: nil).
In addition, the Group
 
uses other derivatives,
 
not designated in a
 
qualifying hedge relationship,
 
to manage its exposure
 
primarily to
interest rate and foreign currency risks. Non
 
qualifying hedges are derivatives entered into
 
as economic hedges of
 
assets and liabilities
for which hedge accounting
 
was not applied. The said derivative
 
instruments are monitored
 
and have been classified for
 
accounting
purposes along with those held for trading.
The
 
fair
 
value
 
of
 
Group's
 
derivative
 
financial
 
assets,
 
as
 
categorized
 
by
 
counterparty's
 
geographical
 
region
 
and
 
industry
 
sector,
 
is
presented in the following tables:
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
115
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Greece
Other
 
European
countries
Other
 
countries
Total
€ million
€ million
€ million
€ million
Sovereign
167
-
-
167
Banks
5
235
310
550
Corporate
113
6
2
121
Total
285
241
312
838
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Greece
Other
 
European
countries
Other
 
countries
Total
€ million
€ million
€ million
€ million
Sovereign
227
-
-
227
Banks
12
228
335
575
Corporate
72
7
-
79
Total
311
235
335
881
As at 31 December 2024,
 
the net carrying value
 
of the derivatives with
 
the Hellenic Republic amounted
 
to a liability of €
 
233 million
(31 December 2023: € 260 million liability).
At 31 December 2024 and 2023,
 
the maturity profile of the nominal amount
 
of the financial instruments designated
 
by the Group in
hedging relationships is presented in the tables
 
below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Fair Value Hedges
 
Cash Flow Hedges
 
1 - 3
months
 
3 - 12
months
1-5 years
 
Over 5
years
Total
1 - 3
months
 
3 - 12
months
1-5 years
 
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Interest rate swaps⁽¹⁾
-
90
6,721
5,361
12,171
-
-
-
-
Interest rate options
-
-
800
4,847
5,647
-
-
-
-
Cross currency interest rate
swaps
-
-
112
-
112
-
618
201
819
Bond Forwards
55
-
-
-
55
-
-
-
-
Total
55
90
7,633
10,208
17,985
-
618
201
819
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Fair Value Hedges
 
Cash Flow Hedges
 
1 - 3
months
 
3 - 12
months
1-5 years
 
Over 5
years
Total
1 - 3
months
 
3 - 12
months
1-5 years
 
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Interest rate swaps⁽¹⁾
500
16
4,285
3,420
8,221
-
-
-
-
Interest rate options
-
-
800
5,647
6,447
-
-
-
-
Cross currency interest
 
rate swaps
-
-
-
-
-
175
602
802
1,579
Total
500
16
5,085
9,067
14,668
175
602
802
1,579
 
(1)
Nominal amount
of interest rate swaps designated as fair value macro hedges is not included.
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
(a) Fair value hedges
The following
 
tables present
 
data relating
 
to the hedged
 
items under fair
 
value hedges
 
for the years
 
ended 31 December
 
2024 and
2023:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
Carrying
amount/Exposure
designated as
hedged
 
Accumulated
amount of FV
hedge
adjustments
related to the
hedged item
 
Change in value as
the basis for
recognising hedge
ineffectiveness
€ million
€ million
 
€ million
Assets
Loans and advances to customers⁽¹⁾
6,939
(46)
(16)
Debt securities AC⁽¹⁾
5,568
195
41
Debt securities FVOCI
1,736
(26)
30
Liabilities
Debt securities in issue
5,864
47
61
Due to customers⁽¹⁾
4,700
(9)
(2)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2023
Carrying amount/
Exposure
designated as
hedged
 
Accumulated
amount of FV
hedge adjustments
related to the
hedged item
 
Change in value as
the basis for
recognising hedge
ineffectiveness
€ million
€ million
€ million
Assets
Loans and advances to customers⁽¹⁾
9,184
69
172
Debt securities AC⁽¹⁾
4,474
154
163
Debt securities FVOCI
1,027
(54)
88
Liabilities
Debt securities in issue
3,812
(15)
105
Due to customers⁽¹⁾
1,628
20
(5)
(1)
For loans
 
and advances
 
to customers
 
hedges,
 
debt securities
 
at amortised
 
cost included
 
in portfolio
 
hedges and
 
due to
 
customers hedges,
 
the exposure
designated as hedged is presented.
At 31 December
 
2024, the accumulated
 
amounts
 
of fair value
 
hedge adjustments
 
remaining in the balance
 
sheet for any
 
items that
have ceased to be adjusted for
 
hedging gains and losses were € 218 million assets for
 
debt securities held at AC, € 2 million liabilities
for debt issued and € 28 million liabilities for adjustments related to debt securities held at FVOCI (2023: € 253 million assets for debt
securities held
 
at
 
AC,
 
€ 3
 
million liabilities
 
for
 
debt
 
issued and
 
€ 44
 
million liabilities
 
for
 
adjustments
 
related
 
to
 
debt securities
 
at
FVOCI). The
 
respective
 
fair
 
value hedge
 
adjustments
 
relating
 
to
 
macro-hedging, amounted
 
to
 
€ 8
 
million gain
 
for
 
loans (including
securitization notes)
 
and € 5 million gain for deposits (2023 : € 57 million loss and € 25 million gains, respectively).
(b) Cash flow hedges
The cash flow hedge reserves
 
for continuing hedges as at
 
31 December 2024 were € 0.5 million
 
loss (2023: € 0.7 million gain), which
relate to loans and advances to customers.
As at 31 December 2024, the
 
balances remaining in the cash
 
flow hedge reserve from
 
any cash flow hedging
 
relationships for which
hedge accounting is no longer applied was € 20 million loss (2023: € 20 million loss).
The reconciliation of the components of Group’s
 
special reserves including cash flow hedges is provided in note 39.
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
 
117
|
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31 December 2024 Consolidated Financial Statements
20.
 
Loans and advances to customers
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Loans and advances to customers at amortised cost
 
 
- Gross carrying amount
52,245
42,773
 
- Impairment allowance
(1,309)
(1,258)
Carrying Amount
50,936
41,515
Fair value changes of loans in portfolio hedging of interest rate
 
risk
(3)
15
Loans and advances to customers at FVTPL
19
15
Total
50,953
41,545
The table below presents the carrying amount of loans and advances to customers
 
per product line and per stage as at 31 December
2024:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
31 December 2023
12-month ECL-
Stage 1
Lifetime
 
ECL-
Stage 2
Lifetime ECL -
Stage 3
POCI⁽¹⁾
Total amount
Total amount
€ million
€ million
€ million
€ million
€ million
€ million
Loans and advances to customers at
amortised cost
Mortgage lending:
 
- Gross carrying amount
9,249
2,706
359
151
12,466
9,942
 
- Impairment allowance
(64)
(218)
(177)
(10)
(469)
(382)
Carrying Amount
9,185
2,489
182
141
11,997
9,560
Consumer lending:
 
- Gross carrying amount
3,831
392
157
153
4,533
3,436
 
- Impairment allowance
(51)
(48)
(114)
(11)
(223)
(210)
Carrying Amount
3,780
344
43
142
4,310
3,225
Small Business lending:
 
- Gross carrying amount
2,663
635
261
24
3,583
3,484
 
- Impairment allowance
(17)
(50)
(126)
(1)
(194)
(219)
Carrying Amount
2,645
585
135
23
3,389
3,265
Wholesale lending:⁽²⁾⁽³⁾
 
- Gross carrying amount
 
29,717
1,184
672
90
31,663
25,912
 
- Impairment allowance
(58)
(39)
(321)
(4)
(422)
(447)
Carrying Amount
29,659
1,145
351
86
31,241
25,465
Total loans and advances to customers at
AC
 
- Gross carrying amount , of which:
45,460
4,917
1,449
419
52,245
42,773
Non Performing exposures (NPE)
-
-
1,449
269
1,719
1,512
 
- Impairment allowance
(191)
(354)
(738)
(27)
(1,309)
(1,258)
Carrying Amount
45,270
4,563
711
392
50,936
41,515
Fair value changes of loans in portfolio
hedging of interest rate risk
(3)
15
Loans and advances to customers at FVTPL
 
Carrying Amount⁽⁴⁾
19
15
Total
 
50,953
41,545
 
(1)
 
Following the acquisition of Hellenic Bank (note 23.2), loans with a
 
carrying amount of € 0.4 billion as of 30
 
June 2024 have been added to the Group POCI
loans.
 
(2)
 
Includes € 4,368 million
 
related to the notes of
 
securitizations of loans
 
originated by Group entities
 
measured at amortised cost,
 
which have been categorized
in Stage 1.
(3)
Includes loans to public sector.
(4)
Includes the mezzanine notes of securitizations of loans originated by the Bank.
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
 
 
 
As at 31 December
 
2024, the Group’s
 
NPE stock amounting
 
to € 1,530 million
 
excluding Hellenic
 
Bank loans of
 
€ 0.2 billion covered
by the Asset
 
Protection Scheme (APS) agreement
 
in Cyprus. The Group
 
NPE ratio, excluding
 
the NPE covered
 
by the APS, decreased
to 2.9% (31 December 2023: 3.5%), while the NPE coverage
 
ratio improved
 
to 88.4% (31 December 2023: 86.4%). With the inclusion
of
 
the
 
above
 
NPE
 
covered
 
by
 
the
 
APS,
 
the
 
Group
 
NPE
 
ratio
 
and
 
the
 
NPE
 
coverage
 
ratio
 
would
 
be
 
3.3%
 
and
 
79.8%
 
respectively.
According to the Group’s
 
business plan for the period 2025-2027, the Group NPE ratio
 
will be decreased further to ca 2.5% in 2027.
Sustainability linked loans
In
 
line
 
with
 
its
 
Sustainable
 
Finance
 
Framework,
 
the
 
Group
 
grants
 
loans,
 
which
 
as
 
part
 
of
 
their contractual
 
terms,
 
incentivize
 
the
borrower’s
 
achievement
 
of
 
predetermined
 
sustainability
 
performance
 
targets
 
(SPTs).
 
Specifically,
 
these
 
SPTs
 
consist
 
of
 
a
 
list
 
of
environmental
 
(E), social (S), and
 
governance (G) targets,
 
the fulfillment of
 
which by the
 
client is determined
 
by meeting respective
KPIs, i.e.,
 
metrics to
 
quantify the
 
client’s
 
performance,
 
for
 
example
 
climate-related
 
targets,
 
such as
 
reducing
 
carbon
 
emissions or
social targets, such as increasing the level of diversity at Board level. As part of the terms of these loans, the contractual
 
interest rate
is increased if the borrower fails to meet
 
specific targets linked to its
 
activity.
The abovementioned
 
loans held
 
as of 31
 
December 2024 have
 
been assessed,
 
in line with
 
the Group’s
 
accounting policies
 
(note 2)
that their contractual cash flows are
 
SPPI pass.
As at
 
31 December
 
2024, the
 
carrying amount
 
of the
 
sustainability linked
 
loans measured
 
at amortized
 
cost amounted
 
to €
 
1,024
million (2023: € 354 million).
Project “Solar”
In
 
the
 
context
 
of
 
its
 
NPE
 
management
 
strategy,
 
the
 
Group
 
has
 
been
 
structuring
 
another
 
NPE
 
securitization
 
transaction
 
(project
‘Solar’), as part of a
 
joint initiative with
 
the other Greek
 
systemic banks
 
(the Banks) since
 
2018.Out of the
 
notes to be
 
issued by the
SPV,
 
the
 
Banks
 
will hold
 
100%
 
of
 
the
 
Senior
 
notes
 
as
 
well
 
as
 
the
 
5%
 
of
 
the
 
Mezzanine
 
and
 
Junior
 
notes,
 
and will
 
dispose
 
of
 
the
remaining stake of the subordinated tranches.
 
In June 2024, the Banks submitted to the Greek Ministry of Finance a joint application
for the inclusion of the senior notes to be issued in the Hellenic Asset Protection
 
Scheme.
Since June 2022,
 
the Group classified
 
the underlying corporate loan
 
portfolio as held
 
for sale, while
 
the remeasurement of its
 
expected
credit losses, in
 
accordance with the
 
Group’s
 
accounting policy for
 
the impairment of
 
financial assets, resulted
 
in the recognition
 
of
impairment loss of € 12 million in the fourth quarter of 2023. The aforementioned impairment loss is determined by reference to the
estimated fair
 
value of the
 
notes to be
 
retained by
 
the Group, upon
 
the completion of
 
transaction, and the
 
consideration expected
to be received by the sale
 
of mezzanine and junior notes. As at
 
31 December 2024, the carrying amount of the aforementioned
 
loan
portfolio reached € 46 million, comprising loans with gross carrying
 
amount of € 243 million, which carried an impairment allowance
of € 197 million. Furthermore, the impairment allowance of the letters
 
of guarantee included in the underlying portfolio reached
 
€ 1
million (note 35).
Project ‘’Leon’’- loans’ derecognition and other loans held for sale
In December 2023, the Group, aiming to accelerate further its NPE reduction plan, initiated the sale process of a mixed
 
NPE portfolio
of total gross book value
 
ca. € 400 million, engaging in
 
parallel in negotiations with potential
 
investors. Accordingly,
 
at 31 December
2023, the
 
Bank classified
 
the aforementioned
 
loan portfolio
 
as held
 
for
 
sale, remeasured
 
the portfolio’s
 
expected credit
 
losses, in
accordance with the Bank’s accounting policy
 
for the impairment of
 
financial assets and recognized an
 
impairment loss of €
 
55 million.
In the first
 
half of 2024, the
 
Bank revised its
 
NPE sale target
 
and increased the
 
aforementioned perimeter
 
of NPE loans by
 
ca. € 240
million, which were also classified as held-for-sale. As
 
a result of the above, at 30
 
June 2024, the carrying amount of
 
the loan portfolio
under held for sale
 
perimeter reached € 239
 
million, comprising loans with
 
gross carrying amount of
 
€ 637 million, which carried
 
an
impairment allowance of € 398 million.
On
 
8
 
July
 
2024,
 
the
 
Group,
 
through
 
its
 
special
 
purpose
 
financing
 
vehicle
 
‘’LEON
 
CAPITAL
 
FINANCE
 
DAC’’
 
(SPV),
 
issued
 
senior,
mezzanine and
 
junior notes of
 
nominal amount
 
of ca. €
 
1.5 billion, via
 
the securitization
 
of a mixed
 
NPE portfolio,
 
which comprises
the loans that were
 
classified as held
 
for sale at 30
 
June 2024 (project’s ‘’Leon’’
 
perimeter) as well
 
as
 
written off loans of
 
total principal
amount due
 
of ca. €
 
1.5 billion and
 
gross carrying
 
amount of ca.€
 
0.6 billion that
 
complied with
 
the requirements
 
of Hellenic Asset
Protection
 
Scheme law.
 
Further
 
to
 
the
 
above,
 
on
 
13
 
September
 
2024,
 
the
 
Group,
 
as
 
the
 
holder
 
of
 
the
 
notes
 
issued
 
by
 
the
 
SPV,
proceeded
 
with
 
the
 
disposal
 
of
 
the
 
95%
 
of
 
the
 
mezzanine
 
and
 
junior
 
tranches
 
to
 
a
 
third
 
party
 
investor.
 
Accordingly,
 
as
 
of
 
the
aforementioned date,
 
the Group ceased to control
 
the SPV and the related real
 
estate company
 
‘Leon Capital Estate Single Member
S.A.’,
 
which resides with the majority stake of mezzanine noteholders,
 
derecognized the underlying loan portfolio on the basis that it
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
 
transferred
 
substantially
 
all risks
 
and rewards
 
of the
 
portfolio’s
 
ownership and
 
relinquished its
 
control
 
over it,
 
and recognized
 
the
retained notes
 
on its balance
 
sheet, i.e. 100%
 
of the senior
 
and 5% of the
 
mezzanine and
 
junior notes of
 
Leon securitization,
 
at fair
value. In addition, prior to the derecognition of the loan portfolio, the Group reassessed the portfolio’s
 
expected credit losses, which
was determined by reference to
 
the estimated fair value of
 
the notes to
 
be retained by the
 
Group and the
 
consideration to be received
by the sale of mezzanine and junior notes,
 
and recognized an impairment release of € 16 million (note
 
21).
The carrying amount of
 
the loan portfolio derecognized,
 
as a result of
 
the Transaction,
 
amounted to €
 
256 million, comprising loans
with gross
 
carrying amount of
 
€ 589 million,
 
which carried
 
an impairment allowance
 
of € 333
 
million. The respective
 
derecognition
loss, recorded
 
in “other
 
income/(expenses)”,
 
amounted
 
to €
 
1 million.
 
As at
 
31 December
 
2024, the
 
gross carrying
 
amount of
 
the
remaining loan portfolio under sale amounted to
 
€ 42 million with an equal amount of impairment allowance.
Project “Wave”
In July 2024, the Bank
 
proceeded with the execution
 
of another synthetic risk
 
transfer transaction
 
(project “Wave V”) in
 
the form of
a financial guarantee, providing credit protection over the mezzanine loss of a portfolio of
 
performing SME and Large Corporate loans
amounting
 
to
 
 
1.1
 
billion
 
(the
 
reference
 
portfolio).
 
Similarly
 
to
 
the
 
previous
 
synthetic
 
risk
 
transfer
 
transactions
 
of
 
similar
characteristics (“Wave”
 
projects), the Wave
 
V transaction was accounted
 
for as a purchased
 
financial guarantee contract
 
that is not
integral to the contractual
 
terms of the reference
 
portfolio, where a compensation
 
right resulting from the
 
expected credit losses of
the protected
 
loans is
 
recognized,
 
to
 
the extent
 
that
 
it is
 
virtually certain
 
that
 
the Group
 
will be
 
reimbursed
 
for
 
the credit
 
losses
incurred. The reference portfolios
 
of Wave V continued to
 
be recognized on the Group’s
 
Balance Sheet.
The Wave
 
V transaction,
 
that was
 
performed in
 
the context
 
of the
 
Group’s
 
initiatives for
 
the optimization
 
of its
 
regulatory capital,
resulted in a capital benefit of 25 bps to Eurobank
 
Holdings Group’s CAD ratio.
Another synthetic
 
risk transfer
 
transaction was
 
executed in
 
December 2024
 
(project “Wave
 
VI”), in
 
the form
 
of credit
 
linked notes
(“CLN”). More specifically, the Bank issued a CLN of € 80 million that provides credit protection over the mezzanine loss of a portfolio
of performing SME
 
and Large Corporate
 
loans amounting to
 
€ 1.1 billion. The
 
credit protection
 
to the Bank
 
is provided by
 
means of
adjustments
 
(write-downs)
 
to
 
the
 
principal
 
balance
 
of
 
the
 
CLN,
 
after
 
the
 
occurrence
 
of
 
certain
 
credit
 
events
 
in
 
relation
 
to
 
the
protected loans, pursuant to
 
the terms and conditions of the CLN.
The CLN is accounted for as a financial liability presented
 
under “Debt securities in issue” (note 34).
The Wave VI transaction,
 
which was performed in the
 
context of the Group’s
 
initiatives for the optimization
 
of its regulatory capital,
is expected to contribute 22 bps to
 
Eurobank Holdings Group’s
 
CAD ratio.
Securitizations of other loan portfolios originated by the Group
The Group
 
in the
 
context
 
of the
 
achievement
 
of its
 
NPE reduction
 
targets
 
has entered
 
into the
 
securitization
 
of various
 
classes of
primarily NPE
 
through the
 
issue of senior,
 
mezzanine and
 
junior notes,
 
which resulted,
 
as described below,
 
in the derecognition
 
of
the underlying loan portfolios and the recognition of the retained
 
notes.
‘Mexico’ securitization
In May
 
2021, the
 
Group, through
 
its special
 
purpose financing
 
vehicle (SPV)
 
‘Mexico Finance
 
Designated
 
Activity Company’
 
issued
senior, mezzanine and
 
junior notes of total face value of ca. € 5.2 billion, via a securitization of a mixed portfolio comprising primarily
NPE. The
 
Group
 
included ‘’Mexico”
 
securitization
 
under the
 
Hellenic Asset
 
Protection
 
Scheme (HAPS)
 
thus
 
the senior
 
note of
 
the
securitization became entitled to the Greek State’s
 
guarantee.
In December 2021, the sale of 95% of the mezzanine and junior notes of Mexico securitization to doValue
 
S.p.A. was completed and,
as a result, the Group
 
ceased to control
 
the SPV and derecognized
 
the underlying loan portfolio
 
from its balance sheet,
 
on the basis
that
 
it transferred
 
substantially
 
all risks
 
and rewards
 
of the
 
portfolio’s
 
ownership and
 
ceased to
 
have
 
control
 
over the
 
securitized
loans. In addition, the Group recognized the retained notes on its balance sheet i.e. 100% of the senior and 5% of the mezzanine and
junior notes, with carrying amount € 1,290 million at 31 December 2024 (31 December 2023:
 
€ 1,415 million).
‘Cairo’ securitization
In June
 
2019, the
 
Group, through
 
the special
 
purpose financing
 
vehicles (SPVs)
 
‘Cairo No.
 
1 Finance
 
Designated Activity
 
Company’,
‘Cairo No. 2 Finance Designated
 
Activity Company’ and ‘Cairo No. 3 Finance Designated
 
Activity Company’,
 
issued senior,
 
mezzanine
and junior notes of total face value of ca. € 7.5 billion, via a securitization
 
of a mixed portfolio consisting primarily of non-performing
 
Notes to the Consolidated Financial Statements
 
.
 
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doc1p253i0 doc1p253i1
loans
 
(NPE)
 
(“Cairo”
 
securitization).
 
In
 
December
 
2019,
 
the
 
Group
 
announced
 
that
 
it
 
has
 
entered
 
into
 
a binding
 
agreement
 
with
doValue S.p.A. for the sale
 
of 20% of
 
the mezzanine and 50.1%
 
of the junior
 
notes of “Cairo”
 
securitization. The Group included
 
“Cairo”
securitization under
 
the Hellenic Asset
 
Protection Scheme
 
(HAPS) thus
 
the senior
 
note of
 
the securitization
 
became entitled
 
to the
Greek State’s
 
guarantee.
In June 2020,
 
the sale of
 
the aforementioned
 
notes was
 
completed and,
 
as a result,
 
the Group ceased
 
to control
 
the Cairo
 
SPVs on
the basis that it does not have
 
the power to direct their
 
relevant activities. Furthermore,
 
in June 2020, Eurobank Holdings,
 
following
a decision of the Board of
 
Directors (BoD), proceeded
 
to the contribution of the
 
retained Cairo notes,
 
i.e. 75% of the mezzanine
 
and
44.9% of
 
the junior
 
notes, along
 
with an
 
amount of
 
€ 1.5
 
million in
 
cash to
 
its Cyprus-based
 
subsidiary Mairanus
 
Ltd, renamed
 
to
‘Cairo Mezz Plc’,
 
in exchange for
 
the newly-issued shares
 
of the aforementioned
 
subsidiary.
 
In July 2020, the
 
General Shareholders’
Meeting of the Company
 
approved the distribution of Cairo
 
Mezz Plc shares to
 
Eurobank Holding’s shareholders through the decrease
in kind of its share capital.
In September 2020,
 
following the completion
 
of the distribution
 
of the Cairo
 
Mezz Plc shares,
 
the underlying loan
 
portfolio and the
related assets and liabilities were derecognized
 
from the Group’s
 
balance sheet, on the basis that at that time the Group transferred
substantially all risks
 
and rewards of the portfolio’s
 
ownership and ceased to have
 
control over the securitized
 
portfolio. In addition,
the Group recognized
 
the retained notes
 
on its balance sheet,
 
i.e. 100% of the
 
senior notes, 5% of
 
mezzanine and junior
 
notes with
carrying amount € 1,790 million at 31 December 2024 (31 December 2023: € 2,019 million).
 
 
‘Pillar’ securitization
In
 
June
 
2019, the
 
Group,
 
through
 
the special
 
purpose
 
financing vehicle
 
(SPV)
 
‘Pillar
 
Finance Designated
 
Activity
 
Company’ issued
senior,
 
mezzanine
 
and
 
junior
 
notes
 
of
 
total
 
value
 
of
 
ca.
 
 
2
 
billion,
 
via
 
a
 
securitization
 
of
 
residential
 
mortgage
 
primarily
 
NPE.
 
In
September 2019, the Group sold 95% of the above-mentioned mezzanine
 
and junior notes to Celidoria S.A R.L. Upon the completion
of the
 
sale, the
 
Group ceased
 
to control
 
the SPV
 
and derecognized
 
the underlying
 
loan portfolio
 
in its
 
entirety,
 
on the
 
basis that
 
it
transferred substantially
 
all the risks and rewards of the underlying loan portfolio’s
 
ownership. In addition, the Group recognized the
retained notes, i.e. 100% of the senior, 5% of the mezzanine and junior notes, on
 
its balance sheet with carrying amount €
 
966 million
at 31 December 2024 (31 December 2023: € 1,020 million).
‘Starlight’ notes held following the acquisition of Hellenic Bank
Following the
 
acquisition of
 
Hellenic Bank,
 
which was
 
consolidated as
 
of the
 
third quarter
 
of 2024 (note
 
23.2), the
 
Group, as
 
at 31
December 2024, included
 
in its loans
 
and advances to
 
customers,
 
senior and mezzanine
 
securitization notes
 
of € 58
 
million and € 5
million respectively,
 
retained by Hellenic Bank as part of the Starlight securitization
 
of NPE loans originated by the latter.
Support measures to customers
In March 2024, the
 
Bank announced the extension of
 
the reward initiative for housing loan clients
 
under floating rate loans, as
 
initially
was implemented
 
in April
 
2023. In
 
particular,
 
the Bank,
 
in its
 
effort
 
to continue
 
to support
 
and reward
 
its non-delinquent
 
housing
clients, announced
 
that the
 
application of
 
“a cap
 
rate’’
 
in the
 
loans’ applicable
 
base rates
 
is extended
 
for another
 
12 months.
 
The
effect of the extension of the
 
cap rate was assessed against
 
the prevailing market rates
 
and was reflected prospectively
 
in the loans’
effective interest
 
rate.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
121
|
Page
 
31 December 2024 Consolidated Financial Statements
21.
 
Impairment allowance for loans and advances to customers
The following tables present the movement
 
of the impairment allowance on loans and advances to customers
 
(expected credit losses – ECL):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Wholesale
Mortgage
Consumer
Small business
12-month
ECL
-Stage 1
Lifetime
ECL
-Stage 2
Lifetime
ECL
-Stage 3
POCI
12-month
ECL
-Stage 1
Lifetime
ECL
-Stage 2
Lifetime
ECL
-Stage 3
POCI
12-month
ECL
-Stage 1
Lifetime
ECL
-Stage 2
Lifetime
ECL
-Stage 3
POCI
12-month
ECL
-Stage 1
Lifetime
ECL
-Stage 2
Lifetime
ECL
-Stage 3
POCI
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Impairment allowance as at 1 January
72
58
314
4
20
154
207
1
53
53
101
3
25
65
128
0
1,258
New loans and advances originated or
purchased
38
(0)
-
-
3
-
-
-
26
-
-
-
6
-
-
-
73
Transfers
 
between stages
 
- to 12-month ECL
16
(11)
(5)
-
4
(3)
(1)
-
20
(14)
(6)
-
10
(7)
(3)
-
-
 
- to lifetime ECL
(6)
12
(5)
-
(3)
30
(27)
-
(3)
16
(13)
-
(1)
15
(13)
-
-
 
- to lifetime ECL credit-impaired
 
loans
(1)
(4)
5
-
(5)
(12)
17
-
(2)
(8)
9
-
(1)
(10)
11
-
-
Impact of ECL net remeasurement
(46)
(12)
41
(4)
47
47
52
3
(36)
4
79
(1)
(33)
(11)
59
(7)
181
Recoveries from written -
 
off loans
-
-
10
0
-
-
8
4
-
-
15
5
-
-
5
5
51
Loans and advances derecognised/
reclassified as held for sale during the
year⁽²⁾
(0)
-
(29)
-
(0)
(0)
(37)
-
(0)
(0)
(15)
-
-
-
(24)
-
(105)
Amounts written off⁽³⁾
-
-
(14)
(0)
-
-
(9)
(1)
-
-
(47)
(1)
-
-
(13)
(0)
(84)
Unwinding of Discount
(0)
-
(7)
-
-
-
(0)
-
-
-
(1)
-
-
-
(1)
-
(10)
Foreign exchange and other movements
 
(14)
(3)
11
4
(2)
2
(32)
3
(7)
(3)
(8)
5
12
(2)
(25)
3
(55)
Impairment allowance as at 31 December
58
39
321
4
64
218
177
10
51
48
114
11
17
50
126
1
1,309
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
122
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Wholesale
Mortgage
Consumer
Small business
12-month
ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
12-month
ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
12-month
ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
12-month
ECL
-Stage 1
Lifetime ECL
-Stage 2
Lifetime ECL -
Stage 3 and
 
POCI⁽¹⁾
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Impairment allowance as at 1 January
68
75
478
21
160
229
37
48
186
23
72
229
1,626
New loans and advances originated or
purchased
23
-
-
0
-
-
20
-
-
4
-
-
47
Transfers between stages
 
- to 12-month ECL
23
(20)
(3)
10
(8)
(1)
15
(7)
(7)
11
(8)
(2)
-
 
- to lifetime ECL
 
(6)
28
(22)
(3)
27
(23)
(2)
15
(13)
(2)
13
(11)
-
 
- to lifetime ECL credit-impaired loans
(5)
(21)
27
(0)
(12)
12
(1)
(6)
6
(1)
(10)
11
-
Impact of ECL net remeasurement
(31)
(3)
72
(7)
(16)
148
4
10
84
(7)
(1)
89
342
Recoveries from written - off loans
-
-
18
-
-
8
-
-
18
-
-
6
49
Loans and advances
derecognised/reclassified as held for sale
during the year⁽²⁾
(4)
(1)
(17)
(0)
(0)
(92)
(4)
(7)
(95)
(1)
(1)
(115)
(337)
Amounts written off⁽³⁾
-
-
(216)
-
-
(46)
-
-
(62)
-
-
(62)
(387)
Unwinding of Discount
-
-
(8)
-
-
(3)
-
-
(2)
-
-
(3)
(16)
Foreign exchange and other movements
 
3
(0)
(10)
0
4
(24)
(16)
(1)
(11)
(1)
0
(13)
(67)
Impairment allowance as at 31 December
72
58
318
20
154
208
53
53
105
25
65
128
1,258
(1)
The impairment allowance for POCI loans of € 8.1 million is included in ‘Lifetime ECL – stage 3 and POCI’.
 
(2)
It represents the impairment allowance of loans derecognized due
 
to a) substantial modifications of the
 
loans’ contractual terms, b) sale and securitization
 
transactions, c) debt to equity transactions and those
 
that have been reclassified as
held for sale during the year (notes 20 and 30).
(3)
The contractual amount outstanding on lending exposures that were written off during the year ended 31 December 2024 and that
 
are still subject to enforcement activity is € 68 million (2023: € 338 million).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
123
|
Page
 
31 December 2024 Consolidated Financial Statements
The impairment losses relating
 
to loans and advances
 
to customers recognized
 
in the Group’s
 
income statement
 
for the year
 
ended
31 December 2024 amounted to € 303 million, including € 16
 
million impairment release relating to the project Leon (note 20) (2023:
€ 412 million) and are analyzed as follows:
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Impairment loss on loans and advances to customers
(255)
(390)
Net income / (loss) from financial guarantee contracts⁽¹⁾
(44)
(37)
Modification gain / (loss) on loans and advances to customers
(5)
8
Impairment (loss)/ reversal for credit
 
related commitments
 
(0)
7
Total from
 
continuing operations⁽²⁾
(303)
(412)
(1)
 
It refers to purchased financial guarantee contracts, not integral to the guaranteed loans (projects Wave).
(2)
 
It includes €
 
9 million referring to
 
Hellenic Bank group, which
 
was consolidated as of the
 
third quarter of 2024
 
(notes 23.2 and 44),
 
of which € 15
 
million refers
to the initial provision for stage 1 loans upon acquisition.
22.
 
Investment securities
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Investment securities at FVOCI
 
4,148
3,492
Investment securities at amortised cost
 
17,651
10,955
Investment securities at FVTPL
 
384
263
Total
22,184
14,710
Note: information on debt securities of the investment portfolio is presented in note 5.2.1.3.
As part of
 
its
 
strategic and
 
other initiatives, the
 
Group has elected
 
to designate
 
the following equity
 
securities at initial
 
recognition
as measured at FVOCI.
.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Plum Fintech Ltd
12
7
Attica Bank S.A.
0
8
Mintus Group Limited
2
2
JCC Payment Systems
 
Ltd
13
-
Demetra Holdings Plc
30
-
Other
2
-
Total
59
17
 
Sustainability linked bonds
As at 31 December
 
2024, the Group holds positions
 
in sustainability linked bonds with Sustainability
 
Performance Targets (SPTs)
 
(note
20) of carrying value of € 248 million, of which € 156 million measured
 
at FVOCI and € 92 million at AC (2023: € 118 million, of
 
which
€ 82 million at
 
FVOCI and € 36
 
million at AC).
 
The Group has
 
assessed the ESG features
 
of the aforementioned
 
debt instruments,
 
in
line with the
 
Group’s
 
accounting policies (note
 
2) and has concluded
 
that they do
 
not create exposure
 
to risks that
 
are inconsistent
with a basic lending arrangement and therefore
 
the SPPI criteria are met.
Post balance sheet event
In January 2025, the Bank announced the
 
completion of the sale of its
 
8.58% holding in Demetra Holdings Plc for a cash
 
consideration
of ca.
 
€ 27 million.
 
This transaction
 
was part
 
of the Bank’s
 
broader agreement
 
with Demetra
 
and Logicom
 
for the
 
acquisition of
 
an
additional 24.66% stake in Hellenic Bank (note
 
23.2).
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
124
|
Page
 
31 December 2024 Consolidated Financial Statements
22.1
 
Movement of investment securities
The tables below present the movement of the carrying
 
amount of investment securities per measurement
 
category and per stage:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Debt securities at FVOCI
 
Investment securities at amortised cost
 
Investment
securities at
FVTPL
 
Equity
securities at
FVOCI
12-month
ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
12-month
ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Gross carrying amount at 1
January
3,427
48
-
10,935
7
32
263
17
14,729
Arising from acquisition
36
-
-
5,203
0
0
140
14
5,394
Additions, net of disposals and
redemptions
453
(22)
-
1,368
-
0
(23)
39
1,815
Transfers between stages
3
(3)
-
(12)
12
-
-
-
0
Net gains/(losses) from changes in
fair value for the year
66
5
-
-
-
-
16
(11)
76
Amortisation of
premiums/discounts and interest
18
1
-
82
0
1
0
-
102
Changes in fair value
 
due to hedging⁽¹⁾
-
-
-
5
0
1
-
-
6
Exchange adjustments and other
movements⁽²⁾
57
0
-
40
0
2
(12)
-
88
Discontinued operations
-
-
-
-
-
-
-
-
-
Gross carrying amount at 31
December
4,061
28
-
17,622
20
36
385
59
22,210
Impairment allowance
-
-
-
(15)
(1)
(9)
-
-
(26)
Net carrying amount at 31
December
4,061
28
-
17,606
19
27
385
59
22,184
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Debt securities at FVOCI
 
Investment securities at amortised cost
 
Investment
securities at
FVTPL
 
Equity
securities at
FVOCI
12-month
ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
12-month
ECL-
Stage 1
Lifetime ECL-
Stage 2
Lifetime ECL-
Stage 3
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Gross carrying amount at 1
January
3,612
121
-
9,175
6
33
241
95
13,283
Additions, net of disposals and
redemptions
(394)
-
-
1,621
-
(2)
3
18
1,246
Transfers between stages
76
(76)
-
(1)
1
-
-
-
-
Net gains/(losses) from changes in
fair value for the year
244
4
-
-
-
-
19
7
273
Amortisation of
premiums/discounts and interest
(19)
0
-
28
(0)
2
(0)
-
10
Changes in fair value due to
hedging⁽¹⁾
-
-
-
146
0
-
-
-
146
Exchange adjustments and other
movements⁽²⁾
(11)
(1)
-
(34)
(0)
(1)
0
(103)
(150)
Discontinued operations
(81)
-
-
-
-
-
-
-
(81)
Gross carrying amount at 31
December
3,427
48
-
10,935
7
32
263
17
14,729
Impairment allowance
-
-
-
(11)
(0)
(7)
-
-
(18)
Net carrying amount at 31
December
3,427
48
-
10,924
7
25
263
17
14,710
(1)
Changes in fair value due to continued hedging relationships amount to € 41 million gain (2023: € 172 million
 
gain)
(2)
 
Other movements include
 
debt securities of
 
face value of
 
€ 3
 
million at
 
FVOCI, €
 
31 million at
 
AC and
 
€ 25
 
million at FVTPL,
 
eliminated for consolidation
purposes following the acquisition
 
of Hellenic Bank. Other
 
movements in equity securities
 
at FVOCI in the
 
comparative year, mainly refer to Hellenic
 
Bank which
was accounted for as a Group's associate as of the second quarter of 2023 (note 23.2).
 
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
125
|
Page
 
31 December 2024 Consolidated Financial Statements
22.2
 
Movement of ECL
The table below presents the ECL movement per portfolio,
 
including ECL movement analysis per stage:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
31 December 2023
Measured at
amortised cost
Measured at
 
FVOCI
Total
Measured at
amortised cost
Measured at
 
FVOCI
Total
€ million
€ million
€ million
€ million
€ million
€ million
Balance at 1 January
18
8
26
22
12
34
New financial assets purchased
6
4
10
4
2
6
- of which 12-month ECL-Stage 1
6
4
10
4
2
6
Transfers
 
between stages
- (from)/to 12-month ECL-Stage 1
(0)
0
0
0
1
1
- (from)/to lifetime ECL-Stage 2
0
(0)
(0)
(0)
(1)
(1)
- (from)/to lifetime ECL-Stage 3
-
-
-
-
-
-
Remeasurement due to change in
ECL risk parameters
 
4
1
4
(8)
(5)
(13)
- of which 12-month ECL-Stage 1
1
(1)
0
(5)
(4)
(9)
- of which lifetime ECL-Stage 2
1
2
2
(0)
(1)
(1)
- of which lifetime ECL-Stage 3
2
-
2
(3)
-
(3)
Financial assets disposed during the
year
(1)
(5)
(6)
(1)
(1)
(2)
- of which 12-month ECL-Stage 1
(1)
(3)
(4)
(1)
(1)
(2)
Financial assets redeemed during the
year
(0)
(0)
(1)
(0)
(0)
(0)
- of which lifetime ECL-Stage 3
-
-
-
-
-
-
Foreign exchange and other
movements
 
0
0
0
1
(0)
1
Balance as at 31 December
26
8
33
18
8
26
22.3
 
Equity reserve: revaluation of the investment
 
securities at FVOCI
Gains
 
and
 
losses
 
arising
 
from
 
the
 
changes
 
in
 
the
 
fair
 
value
 
of
 
investment
 
securities
 
at
 
FVOCI
 
are
 
recognized
 
in
 
a
 
corresponding
revaluation reserve in equity.
 
The movement of the reserve is as follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balance at
 
1 January
48
(10)
Net gains/(losses) from changes in fair value
60
255
Tax (expense)/benefit
 
(10)
(49)
50
206
Net (gains)/losses transferred to net profit on disposal
(7)
(50)
ECL transferred to net profit
4
(3)
Tax (expense)/benefit on net (gains)/losses
 
transferred to net profit on disposal
2
15
Tax (expense)/benefit on ECL
 
transferred to net profit
(1)
1
(2)
(37)
Net (gains)/losses transferred to net profit from
 
fair value hedges
(45)
(91)
Tax (expense)/benefit
11
24
(34)
(67)
Revaluation reserve from associated undertakings, net of tax
 
(5)
1
Revaluation reserve for the investment
 
in Hellenic Bank transferred to R/E
(0)
(45)
Balance at 31 December
57
48
 
doc1p253i0 doc1p253i1
 
Notes to the Consolidated Financial Statements
 
.
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31 December 2024 Consolidated Financial Statements
 
23.
 
Group composition
23.1
 
Shares in subsidiaries
The following is a listing of the Company's subsidiaries as at 31 December 2024, included in the consolidated financial statements
 
for
the year ended 31 December 2024:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name
Note
Percentage
holding
Country of
incorporation
Line of business
Eurobank S.A.
100.00
Greece
Banking
Be Business Exchanges Single Member Societe Anonyme
of Business Exchanges Networks and Accounting and Tax
Services
c
100.00
Greece
Business-to-business e-commerce,
accounting, tax and sundry services
Eurobank Asset Management Mutual Fund Mngt
Company Single Member S.A.
100.00
Greece
Mutual fund and asset management
Eurobank Equities Investment Firm Single Member S.A.
100.00
Greece
Capital markets and advisory services
Eurobank Leasing Single Member S.A.
100.00
Greece
Leasing
Eurobank Factors Single Member S.A.
100.00
Greece
Factoring
Herald Greece Single Member Real Estate development
and services S.A. 1
100.00
Greece
Real estate
Herald Greece Single Member Real Estate development
and services S.A. 2
100.00
Greece
Real estate
Piraeus Port Plaza 1 Single Member Development S.A.
100.00
Greece
Real estate
 
(Under liquidation) Anchor Hellenic Investment Holding
Single Member S.A.
100.00
Greece
Real estate
 
Athinaiki Estate Investments Single Member S.A.
 
100.00
Greece
Real estate
 
Piraeus Port Plaza 2 Single Member Development S.A.
100.00
Greece
Real estate
 
Piraeus Port Plaza 3 Single Member Development S.A.
100.00
Greece
Real estate
 
Tenberco Real Estate
 
Single Member S.A.
100.00
Greece
Real estate
 
Value Touristiki Single Member Development S.A.
100.00
Greece
Real estate
 
Insignio Single Member S.A.
100.00
Greece
Real estate
Eurobank Ananeosimes Single Member S.A.
100.00
Greece
Production and distribution of solar generated
electric energy
Eurobank Bulgaria A.D.
 
99.99
Bulgaria
Banking
PB Personal Finance E.A.D.
99.99
Bulgaria
Pension assurance intermediary business
Berberis Investments Ltd
d
100.00
Channel Islands
Holding company
Eurobank Cyprus Ltd
100.00
Cyprus
Banking
Hellenic Bank Public Company Limited⁽²⁾
55.96
Cyprus
Banking
Hellenic Bank (Investments) Ltd⁽²⁾
55.96
Cyprus
Investment banking, asset management and
brokerage
HB Data Analytics Ltd⁽²⁾
55.96
Cyprus
Auxiliary services
Pancyprian Insurance Ltd⁽²⁾
55.94
Cyprus
General Insurance
Hellenic Life Insurance Company Ltd⁽²⁾
55.96
Cyprus
Life Insurance
Hellenic Bank Insurance Holding Ltd⁽²⁾
55.96
Cyprus
Insurance services
Hellenic Insurance Agency Ltd⁽²⁾
55.96
Cyprus
Insurance Intermediation
Ezmero Holdings Ltd⁽²⁾
55.96
Cyprus
Real estate
Anolia Industrial Ltd⁽²⁾
55.96
Cyprus
Real estate
Drypto Holdings Ltd⁽²⁾
55.96
Cyprus
Real estate
Arzetio Holdings Ltd⁽²⁾
55.96
Cyprus
Real estate
Katlero Holdings Ltd⁽²⁾
55.96
Cyprus
Real estate
Foramonio Ltd
100.00
Cyprus
Real estate
 
Lenevino Holdings Ltd
100.00
Cyprus
Real estate
 
Rano Investments Ltd
100.00
Cyprus
Real estate
 
Neviko Ventures Ltd
100.00
Cyprus
Real estate
 
Zivar Investments Ltd
100.00
Cyprus
Real estate
 
Amvanero Ltd
100.00
Cyprus
Real estate
 
Revasono Holdings Ltd
100.00
Cyprus
Real estate
 
Notes to the Consolidated Financial Statements
 
.
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doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name
Note
Percentage
holding
Country of
incorporation
Line of business
Volki Investments Ltd
100.00
Cyprus
Real estate
 
Adariano Investments Ltd
100.00
Cyprus
Real estate
 
Elerovio Holdings Ltd
100.00
Cyprus
Real estate
 
Afinopio Investments Ltd
100.00
Cyprus
Real estate
 
Ovedrio Holdings Ltd
100.00
Cyprus
Real estate
 
Primoxia Holdings Ltd
100.00
Cyprus
Real estate
 
Severdor Ltd
100.00
Cyprus
Holding company
Eurobank Private Bank Luxembourg S.A.
100.00
Luxembourg
Banking
Eurobank Fund Management Company (Luxembourg) S.A.
100.00
Luxembourg
Fund management
ERB Lux Immo S.A.
100.00
Luxembourg
Real estate
 
ERB New Europe Funding B.V.
100.00
Netherlands
Finance company
ERB New Europe Funding II B.V.
100.00
Netherlands
Finance company
ERB New Europe Holding B.V.
100.00
Netherlands
Holding company
ERB IT Shared Services S.A.
100.00
Romania
Informatics data processing
IMO Property Investments Bucuresti S.A.⁽¹⁾
100.00
Romania
Real estate services
Seferco Development S.A.
99.99
Romania
Real estate
 
ERB Leasing A.D. Beograd-in Liquidation
100.00
Serbia
Leasing
IMO Property Investments A.D. Beograd
100.00
Serbia
Real estate services
Karta II Plc
-
United Kingdom
Special purpose financing vehicle
 
Astarti Designated Activity Company
-
Ireland
Special purpose financing vehicle
 
ERB Recovery Designated Activity Company
-
Ireland
Special purpose financing vehicle
 
 
(1)
 
The company has been classified as a held for sale subsidiary (note 30).
(2)
 
Entities of Hellenic Bank group, which was
 
consolidated as of the third quarter of 2024.As of
 
November 2024, following the share purchase agreements
 
with
certain shareholders of
 
Hellenic Bank and
 
Eurobank’s squeeze-out right to acquire
 
the remaining shares
 
of Hellenic Bank,
 
the entity is
 
included in the
 
Company’s
consolidated financial statements with 100% holding percentage (note 23.2).
 
The following entities are not included in the consolidated
 
financial statements due to immateriality:
(i) the Group’s
 
special purpose financing
 
vehicles and the
 
related holding
 
entities, which are
 
dormant and/or
 
are under liquidation:
Themeleion
 
III
 
Holdings
 
Ltd,
 
Themeleion IV
 
Holdings
 
Ltd,
 
Themeleion Mortgage
 
Finance Plc,
 
Themeleion
 
II Mortgage
 
Finance Plc,
Themeleion
 
III
 
Mortgage
 
Finance
 
Plc,
 
Themeleion
 
IV
 
Mortgage
 
Finance
 
Plc,
 
Themeleion
 
V
 
Mortgage
 
Finance
 
Plc,
 
Themeleion
 
VI
Mortgage Finance Plc, Anaptyxi APC Ltd and Byzantium
 
II Finance Plc.
(ii) the holding entity of Karta II Plc: Karta II Holdings Ltd.
(iii) dormant entity: Enalios Real Estate
 
Development S.A.
(iv) entities
 
controlled by
 
the Group
 
pursuant to
 
the terms
 
of the relevant
 
share pledge
 
agreements: Finas
 
S.A., Rovinvest
 
S.A. and
Promivet S.A.
In 2024, the changes
 
in the Group structure
 
due to: a) acquisitions
 
and mergers of
 
companies, b) sales and
 
other corporate
 
actions,
which
 
resulted
 
in loss
 
of
 
control,
 
c) transactions
 
with
 
the non-controlling
 
interests,
 
which did
 
not
 
result
 
in loss
 
of
 
control
 
and
 
d)
liquidations, are as follows:
(a) Reco Real Property A.D. Beograd,
 
Serbia
In February 2024, the Bank signed an agreement for
 
the sale of its participation interest
 
of 100% in Reco Real Property
 
A.D. Beograd
to
 
a third
 
party
 
for
 
a
 
cash
 
consideration
 
of
 
 
11.5
 
million.
 
Following
 
the
 
above,
 
the
 
company
 
was
 
classified
 
as
 
held
 
for
 
sale and
measured by reference to the agreed consideration,
 
being lower than its carrying amount. Accordingly,
 
in the first quarter of 2024, a
fair value remeasurement
 
loss of € 1.8 million
 
for the company’s
 
main asset, relating
 
to investment property,
 
was recognized
 
in the
income statement
 
line “Other income/(expenses)”.
 
In June 2024, the sale of the company
 
was completed, with an immaterial
 
effect
on the Group’s income
 
statement.
(b) Special purpose financing vehicle for the securitization of Bank’s
 
loans and related real estate
 
company
In
 
the context
 
of
 
Project
 
“Leon”,
 
on 8
 
July
 
2024, the
 
Bank proceeded
 
to
 
a securitization
 
transaction
 
through
 
the special
 
purpose
financing vehicle
 
“LEON CAPITAL
 
FINANCE DESIGNATED
 
ACTIVITY COMPANY”.
 
In September
 
2024, the
 
Group
 
disposed 95%
 
of the
Notes to the Consolidated Financial Statements
 
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doc1p253i0 doc1p253i1
mezzanine and junior notes of
 
the abovementioned securitization to a
 
third party, therefore ceased to control the SPV and
 
the related
real estate company
 
“Leon Capital Estate Single Member S.A.”
 
(note 20).
(c) Be
 
Business Exchanges
 
Single Member
 
Societe
 
Anonyme
 
of Business
 
Exchanges
 
Networks
 
and Accounting
 
and Tax
 
Services,
Greece
In September 2024, Εurobank Holdings acquired an additional participation interest of 1.99% in the company, therefore its holding in
the
 
company’s
 
share
 
capital
 
reached
 
100%.
 
The
 
transaction
 
had
 
an
 
immaterial
 
effect
 
that
 
was
 
recognized
 
directly
 
in
 
the
 
equity
attributable to
 
the shareholders of
 
Eurobank Holdings. In October
 
2024, following the
 
above transaction, the
 
name of the company
was amended with the inclusion of the term “Single member”.
(d) Berberis Investments Ltd, Channel Islands
In 2024, the liquidation of the company was decided.
(e) ADEXA Real Estate Single Member S.A., Greece
In December 2024,
 
the merger of
 
the Bank and
 
its wholly owned subsidiary
 
ADEXA Real Estate
 
Single Member S.A.
 
was completed,
by absorption of the latter by the former
.
(f) Severdor Ltd, Cyprus and Insignio Single Member S.A., Greece
In December 2024, the Bank acquired 100% of the shares of Severdor
 
Ltd for a cash consideration
 
of ca. € 34 million. The main asset
of Severdor
 
Ltd is
 
the participation
 
in the
 
whole of
 
the issued
 
share capital
 
of Insignio
 
Single Member
 
S.A., which
 
in turn
 
owns an
investment
 
property as
 
its main
 
asset. In
 
line with
 
IFRS 3
 
requirements,
 
the
 
acquisition was
 
accounted
 
for as
 
an asset
 
acquisition
rather than a
 
business combination, since substantially
 
all of the fair
 
value of the gross
 
assets acquired was
 
concentrated in
 
a single
identifiable
 
asset
 
and
 
no
 
substantive
 
business
 
processes
 
were
 
acquired.
 
Accordingly,
 
no
 
goodwill
 
was
 
recognized,
 
whereas
 
the
acquired property,
 
along with other assets/other liabilities, were recognized
 
in the Group’s
 
balance sheet by allocating the purchase
price to the individual identifiable assets and liabilities on the basis of their relative fair values. Following the above treatment, at the
acquisition date the total assets of both companies amounted to ca. €
 
86 million, of which ca. € 75
 
million investment property, while
total liabilities amounted to ca. € 52 million, of which ca.
 
€ 44 million intragroup funding.
(g) Ezelco Holdings Ltd, Prunelox Holdings Ltd,
 
Shanlo Holdings Ltd and Torki
 
Holdings Ltd, Cyprus
In November 2024, the merger of Hellenic Bank with its above mentioned
 
wholly owned subsidiaries was completed.
In 2023, the significant changes in the Group structure
 
were as follows:
(i) Eurobank Direktna a.d., Serbia
On 2 November 2023, the Bank announced that the sale of its 70% shareholding in Eurobank Direktna a.d. to AIK Banka a.d. Beograd
was completed (note 30).
(ii) Acquisition of BNP Paribas Personal Finance Bulgaria by Eurobank
 
Bulgaria A.D.
On 9 December
 
2022, Eurobank
 
Holdings announced that
 
it had reached
 
an agreement
 
for the
 
acquisition of
 
BNP Paribas
 
Personal
Finance Bulgaria
 
(the “Business”)
 
by Eurobank’s
 
subsidiary in Bulgaria,
 
Eurobank Bulgaria
 
A.D. (“Postbank”).
 
The completion
 
of the
transaction
 
took
 
place
 
in
 
May
 
2023,
 
following
 
the
 
receipt
 
of
 
the
 
approvals
 
by
 
all
 
competent
 
regulatory
 
authorities.
 
Further
information is provided in note 23.2 of the
 
consolidated financial statements
 
for the year ended 31 December 2023.
(iii) IMO Property Investments Sofia E.A.D., Bulgaria
During the second quarter of 2023, the sale of IMO Property
 
Investments Sofia E.A.D. was
 
considered highly probable, therefore
 
the
company was
 
classified as held
 
for sale
 
and measured
 
by reference
 
to the
 
pre-agreed consideration
 
with the third
 
party,
 
being the
lower of
 
its carrying amount
 
and fair
 
value less
 
costs to
 
sell, in accordance
 
with IFRS
 
5. Accordingly,
 
a remeasurement/impairment
loss of € 23
 
million on real estate properties
 
was recognised in the
 
income statement. In May 2023, the
 
sale of the
 
Bank’s participation
interest of 100% in the company, along with the loan receivable from the company,
 
was completed with a total cash consideration of
€ 15.5 million.
Notes to the Consolidated Financial Statements
 
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(iv) ADEXA Real Estate Single Member S.A., Greece
In June 2023,
 
the Bank acquired
 
100% of the
 
shares and voting
 
rights of ADEXA
 
Real Estate Single Member
 
S.A. for a
 
cash consideration
of €
 
50.8 million.
 
In line with
 
IFRS 3 requirements,
 
the acquisition
 
was accounted
 
for as
 
an asset acquisition
 
rather than
 
a business
combination, since
 
substantially all
 
of the fair
 
value of the
 
gross assets
 
acquired was
 
concentrated
 
in a single
 
identifiable asset
 
and
no substantive
 
business processes
 
were acquired.
 
Accordingly,
 
no goodwill
 
was recognized,
 
whereas the
 
acquired property,
 
along
with other
 
assets/other liabilities,
 
were recognized
 
in the
 
Group’s
 
balance sheet
 
by allocating
 
the purchase
 
price to
 
the individual
identifiable assets and
 
liabilities on the basis
 
of their relative
 
fair values. Following
 
the above treatment,
 
at the acquisition
 
date the
total assets of
 
the company amounted
 
to € 52.3 million,
 
of which € 33.4
 
million refer
 
to own used
 
property and €
 
18.7 million refer
to investment property,
 
while total liabilities amounted to € 1.5 million.
Significant restrictions on the Group's ability to access or
 
use the assets and settle the liabilities of the Group
The Group does
 
not have any
 
significant restrictions
 
on its ability to
 
access or use its
 
assets and settle
 
its liabilities other than
 
those
resulting from regulatory,
 
statutory and contractual requirements,
 
set out below:
Banking and other financial institution subsidiaries are subject to regulatory restrictions and central bank requirements
 
in the
countries
 
in which
 
the subsidiaries
 
operate.
 
Such supervisory
 
framework
 
requires
 
the subsidiaries
 
to
 
maintain
 
minimum
capital buffers and certain capital
 
adequacy and liquidity ratios, including restrictions to limit exposures
 
and/or the transfer
of funds to the
 
Company and other subsidiaries
 
within the Group. Accordingly,
 
even if the subsidiaries’
 
financial assets are
not pledged
 
at an
 
individual entity
 
level, their
 
transfer
 
within the
 
Group may
 
be restricted
 
under the
 
existing supervisory
framework.
 
As
 
at
 
31
 
December
 
2024,
 
the
 
carrying
 
amount
 
of
 
the
 
Group
 
financial
 
institution
 
subsidiaries’
 
assets
 
and
liabilities, before intercompany eliminations, amounted to € 108.1 billion and
 
€ 96.2 billion, respectively, including Eurobank
S.A. (2023: € 85.6 billion and € 76.2 billion).
Subsidiaries are subject to statutory requirements
 
mainly relating with the level of capital and total
 
equity that they should
maintain,
 
restrictions
 
on the
 
distribution
 
of
 
capital
 
and
 
special reserves,
 
as
 
well
 
as
 
dividend
 
payments
 
to
 
their
 
ordinary
shareholders.
Insurance subsidiaries, which are also subject to regulatory
 
and statutory restrictions, hold financial assets
 
of € 128 million,
(before intercompany
 
eliminations)
 
in order to satisfy their obligations to policy holders
 
.
The Group
 
uses its
 
financial assets
 
as collateral
 
for repo
 
and derivative
 
transactions, secured
 
borrowing from
 
central and
other banks, issuances
 
of covered bonds, as
 
well as securitizations. As
 
a result of
 
financial assets’ pledge,
 
their transfer within
the Group is not permitted. Information
 
relating to the Group’s
 
pledged financial assets is provided in notes 17, 29 and 41.
The Group
 
is required
 
to maintain
 
mandatory and
 
collateral deposits
 
with central
 
banks. Information
 
for these deposits
 
is
provided in note 15.
 
23.2 Consolidation of Hellenic Bank group
Hellenic Bank Public
 
Company Ltd
 
(“Hellenic Bank”), a
 
financial institution
 
based in Cyprus
 
and listed in
 
the Cyprus Stock
 
Exchange,
was accounted
 
for as a
 
Group’s
 
associate under the
 
equity method from
 
April 2023 until
 
30 June 2024 (note
 
24). The Hellenic Bank
group provides a wide range of banking and financial services, which include financing, investment and insurance services, custodian
and factoring services and the management and disposal of properties,
 
predominantly acquired in debt satisfaction.
As a result
 
of the agreements
 
the Bank had
 
entered into
 
with certain
 
of Hellenic Bank’s
 
shareholders since
 
August 2023,
 
on 4 June
2024, the
 
Bank announced
 
that following
 
the receipt
 
of the relevant
 
regulatory approvals,
 
acquired an
 
additional 26.1% holding
 
in
Hellenic Bank (“Transaction”) for a total consideration
 
of € 275.7 million. Following the aforementioned Transaction,
 
pursuant to the
Takeover
 
Bids Law of 2007 of the Republic of Cyprus, L.41(I)/2007 as amended (“Law”), the Bank also announced the submission of a
Mandatory Takeover
 
Bid (“Takeover
 
Bid”) to all
 
shareholders of Hellenic
 
Bank for
 
the acquisition
 
of up to
 
100% of the
 
issued share
capital of Hellenic Bank. The
 
consideration offered
 
by the Bank was € 2.56
 
per share, paid in cash to
 
all the shareholders who would
accept the Takeover
 
Bid during the period from 1 July until 30 July 2024.
Furthermore, within
 
June 2024, the
 
Bank proceeded with
 
the acquisition of
 
an additional 0.18%
 
holding in Hellenic
 
Bank for
 
a total
consideration of € 2 million,
 
i.e. at a price of € 2.56 per share.
 
Accordingly,
 
as of 30 June 2024 the Bank’s
 
participation percentage in
Hellenic Bank reached 55.48%.
 
Notes to the Consolidated Financial Statements
 
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Despite
 
being
 
the
 
holder
 
of
 
over
 
50%
 
of
 
Hellenic Bank’s
 
shares,
 
until
 
the
 
expiration
 
of
 
the
 
Takeover
 
Bid
 
acceptance
 
period,
 
and
pursuant to the Law,
 
Eurobank as the offeror,
 
its nominees and persons acting in concert with it could not be appointed to the Board
of Directors of Hellenic
 
Bank, nor they
 
could exercise, or procure the
 
exercise of, the votes attaching to any
 
shares they held in
 
Hellenic
Bank.
 
In
 
addition,
 
during
 
the period
 
when
 
they
 
became aware
 
that
 
a bid
 
was
 
imminent
 
and until
 
expiration
 
of the
 
Takeover
 
Bid
acceptance
 
period,
 
the
 
Board
 
of
 
Directors
 
of
 
Hellenic
 
Bank
 
could
 
not
 
without
 
prior
 
authorization
 
of
 
the
 
general
 
meeting
 
of
shareholders, take any
 
action which could result in the frustration of the Takeover
 
Bid.
On 30
 
July 2024,
 
the acceptance
 
period for
 
the Takeover
 
Bid expired,
 
therefore
 
the restrictions
 
imposed by
 
the Law
 
on the
 
Bank’s
ability to
 
exercise its
 
voting rights
 
no longer applied,
 
and Eurobank,
 
since then, has
 
been able to
 
exercise its
 
rights in
 
full. Based on
the above and considering the
 
relevant provisions of the Cyprus’ legal framework including the
 
Companies Law Cap. 113,
 
and Hellenic
Bank’s articles of
 
association in relation to
 
the exercise of shareholders’
 
rights, including the timing for
 
convening a general
 
meeting
of the shareholders, it was assessed that the Group
 
acquired control over Hellenic Bank group within
 
July.
More
 
specifically,
 
in
 
accordance
 
with
 
IFRS10,
 
control
 
exists
 
when
 
the investor
 
has the
 
practical
 
ability to
 
exercise
 
its rights
 
when
decisions for the relevant activities need to be made. In this context, based on legal and
 
corporate provisions including the minimum
period
 
required
 
for
 
the
 
convocation
 
of
 
any
 
shareholders’
 
meeting, 15
 
July
 
2024, was
 
the
 
last
 
date
 
that
 
a general
 
meeting of
 
the
shareholders
 
of Hellenic
 
Bank could
 
be convened
 
and take
 
place before
 
the expiration
 
of the
 
Takeover
 
Bid acceptance
 
period, in
which the
 
Bank would
 
not have
 
the ability
 
to exercise
 
its voting
 
rights. From
 
16 July
 
onwards,
 
the Bank
 
would be
 
in a
 
position to
exercise its
 
rights freely should
 
a shareholders’
 
meeting be convened,
 
as it would
 
not take
 
place until after
 
a minimum period
 
of at
least 14
 
calendar
 
days,
 
when the
 
restrictions
 
would have
 
already been
 
lifted. Accordingly
 
,
 
Hellenic Bank
 
and its
 
subsidiaries were
included in the
 
Company’s consolidated
 
financial statements
 
from the beginning
 
of the third quarter
 
of 2024 using the
 
most recent
available
 
published financial
 
information.
 
Any P&L
 
from the
 
date
 
of consolidation
 
up to
 
the acquisition
 
date was
 
considered non-
significant.
The
 
acquisition
 
of
 
Hellenic
 
Bank
 
was
 
accounted
 
for
 
as
 
a
 
business
 
combination
 
using
 
the
 
purchase
 
method
 
of
 
accounting,
 
where
provisional values have
 
been applied, as a fair
 
value exercise is
 
in progress by the
 
Group to measure the
 
identifiable assets acquired
and liabilities incurred and is expected to be completed no later than the one year initial measurement
 
period from acquisition date,
given the size
 
of the acquired
 
group and related
 
complexities.
 
In accordance with
 
the Group’s
 
accounting policies, during
 
this initial
measurement period the Group will retrospectively
 
adjust the provisional amounts recognized
 
at the acquisition date to reflect
 
new
information obtained about facts
 
and circumstances that existed as
 
of the acquisition date.
Accordingly,
 
the difference
 
between (a)
 
the measurement
 
at acquisition
 
date of
 
fair values
 
of the
 
identifiable assets
 
acquired and
liabilities assumed relating to 55.48% participation held in Hellenic Bank as of 30 June 2024 based on provisional
 
values - see below -
amounting
 
to
 
€ 868
 
million and
 
(b) the
 
carrying
 
amount
 
of the
 
investment
 
in the
 
entity accounted
 
for
 
previously
 
as an
 
associate
amounting to € 862 million, resulted in
 
ca. € 6 million gain, after taking into
 
account the remeasurement loss of pre-existing
 
interest
at its fair
 
value of € 602
 
million, reflecting the
 
price levels of
 
the Hellenic Bank shares
 
in the local
 
stock exchange
 
trading below
 
the
entity’s book value . This result, along with the related acquisition costs
 
of € 6 million have been recognized in the income statement
line “Other income/(expenses)”.
In particular,
 
the acquisition
 
balance sheet
 
of Hellenic
 
Bank group,
 
based on
 
its published
 
interim
 
financial statements
 
for
 
the six
month period ended 30 June 2024,
 
including the provisional fair
 
value adjustments recognized
 
as updated in the fourth
 
quarter,
 
are
set out below:
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
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Provisional
values on
acquisition
€ million
ASSETS
Cash and balances with central banks
5,390
Due from credit institutions
328
Loans and advances to customers
5,965
Investment securities
5,456
Property and equipment
171
Investment property
10
Intangible assets ⁽¹⁾
34
Other assets ⁽²⁾
167
Fair value adjustments (see below)
(81)
Total assets ⁽³⁾
17,439
LIABILITIES
Due to credit institutions
92
Due to customers
14,991
Debt securities in issue
437
of which intercompany balances with the Group
63
Other liabilities ⁽⁴⁾
320
Fair value adjustments (see below)
35
Total liabilities
15,875
Net assets of Hellenic Bank group acquired
1,565
Net assets attributable to non controlling interests
697
Net assets of Hellenic Bank group attributable to shareholders
868
Carrying amount of the investment in the Hellenic Bank group accounted for as an
associate as at 30 June 2024
862
Fair value of previously held interest in the Hellenic Bank group accounted for
 
as an
associate as at 30 June 2024
 
⁽⁵⁾
602
 
(1)
 
Intangible assets of
 
Hellenic Bank group
 
were reduced by
 
€ 14 million,
 
referring to recorded
 
Goodwill not to
 
be recognized as
 
an identifiable asset
 
of the
Group as the acquirer.
(2)
 
Other assets include € 24 million reinsurance contract assets.
(3)
 
Includes cash and cash equivalents of € 5,506 million.
(4)
 
Other liabilities include € 104 million insurance contract liabilities.
(5)
 
Based on the price of Hellenic Bank shares as at 28 June 2024.
The above provisional fair value adjustments as of the acquisition
 
that are presented within the balance sheet lines
 
‘Other assets’ and
‘Other liabilities’ of the Group, are analyzed
 
in the table below per asset/liability category:
Notes to the Consolidated Financial Statements
 
.
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doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
 
 
 
 
Provisional
fair value
 
adjustments
€ million
ASSETS
Loans and advances to customers
(17)
Investment securities
(84)
Intangible assets
 
6
Other assets (repossessed properties)
 
13
Total assets
 
(81)
 
LIABILITIES
 
Debt securities in issue
31
Other Liabilities (contingent liabilities)
4
Total liabilities
 
35
As at
 
31 December 2024,
 
the carrying
 
amount of
 
the provisional
 
fair value
 
adjustments, after
 
the subsequent
 
measurement of
 
the
related assets and liabilities,
 
as included in
 
balance sheet lines
 
‘Other assets’ and ‘Other
 
liabilities’ amounted to €
 
66 million (decrease)
and € 33 million (increase) respectively (notes 29 and 35).
In the first half of
 
2024, Hellenic Bank group recorded a
 
net profit of € 189
 
million in accordance with its respective published financial
statements.
 
In the
 
same period,
 
the Group’s
 
share of
 
results οf
 
Hellenic Bank
 
group that
 
was accounted
 
for under
 
equity method
amounted to € 133 million income, as adjusted in the third quarter of 2024 (further information is provided in note 24 – investments
in associates and joint ventures).
 
For the period from its
 
acquisition until 31 December 2024, Hellenic
 
Bank group contributed
 
€ 382
million to
 
the Group's
 
net revenues
 
from
 
international
 
operations
 
and €
 
141 million
 
to
 
its net
 
profit
 
attributable
 
to
 
shareholders
(further information is provided in note
 
44 “Operating segment information”).
On 7
 
August 2024,
 
the Bank
 
announced that
 
after the
 
final review
 
of the
 
Acceptance and
 
Transfer
 
Forms, the
 
total percentage
 
of
acceptance of the Takeover Bid reached 0.481%, giving Eurobank total participation of 55.962% in the issued share capital of Hellenic
Bank. For the additional stake
 
acquired in the subsidiary,
 
the difference between
 
the fair value of
 
the additional net assets
 
acquired
(based on
 
provisional
 
values)
 
amounting to
 
ca. €
 
8 million
 
and the
 
consideration
 
paid amounting
 
to
 
ca. €
 
6 million,
 
including the
acquisition
 
related
 
costs,
 
resulted
 
in a
 
gain
 
of
 
ca.
 
€ 2
 
million that
 
was
 
recorded
 
directly
 
in equity
 
,
 
as
 
a transaction
 
with the
 
non-
controlling shareholders.
Furthermore, in November 2024, the Bank announced that it has entered
 
into share purchase agreements with certain shareholders
of the
 
Hellenic Bank,
 
pursuant to
 
which, it
 
has agreed
 
to acquire
 
an additional
 
total holding
 
of 37.51%
 
(154,832,195 shares)
 
in the
entity,
 
for a total
 
consideration of
 
ca. € 750
 
million, corresponding
 
to € 4.843
 
per share. Specifically,
 
Eurobank agreed
 
to acquire
 
a)
88,064,705 Hellenic Bank
 
shares (21.33%) from
 
Demetra Holdings Plc,
 
for a consideration of
 
ca. € 426.5
 
million, subject to
 
the approval
of the General
 
Assembly of the shareholders
 
of the seller,
 
b) 53,037,786 Hellenic Bank
 
shares (12.848%) from
 
Cyprus Union of Bank
Employees, the
 
Cyprus Bank
 
Employees Welfare
 
Fund, the
 
Cyprus Bank
 
Employees Health
 
Fund and
 
the Financial
 
Sector Provident
Fund, for
 
a total
 
adjusted consideration
 
of ca.
 
€ 257 million
 
and c) 13,729,704
 
Hellenic Bank
 
shares (3.33%)
 
from Logicom
 
Services
Limited, for a consideration of ca. € 66.5 million.
As of 31
 
December 2024, the
 
above transactions
 
were subject
 
to regulatory
 
approvals and
 
upon their completion,
 
Eurobank’s
 
total
holding in Hellenic Bank reaches 93.47%.
Moreover,
 
in accordance with the provisions of the Takeover
 
Bids Law of 2007 in Cyprus (“Law”), the Bank, following the completion
of the above-mentioned transactions has the obligation to proceed to a tender offer for the remaining outstanding shares of Hellenic
Bank for at least
 
the same price i.e. € 4.843
 
per share, whereas
 
pursuant to Article
 
36 of the same law
 
it is able, after
 
completion of
the said tender offer and given
 
that it will hold more
 
than 90% votes, to require all
 
the holders of the remaining
 
securities to sell those
securities.
 
On
 
those
 
grounds,
 
the
 
Bank
 
announced
 
in
 
November
 
2024
 
that
 
it
 
will
 
exercise
 
its
 
squeeze-out
 
right
 
to
 
acquire
 
any
outstanding
 
shares of
 
Hellenic Bank
 
and take
 
all necessary
 
steps
 
for
 
the delisting
 
of Hellenic
 
Bank's shares
 
from the
 
Cyprus Stock
Notes to the Consolidated Financial Statements
 
.
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doc1p253i0 doc1p253i1
 
Exchange. Effectively,
 
the mandatory tender
 
offer along with
 
the squeeze-out right
 
oblige counterparties to
 
execute the
 
acquisition
of
 
all the
 
remaining
 
shares
 
by the
 
Bank
 
and therefore
 
the outcome
 
is certain,
 
thus
 
the transaction
 
is deemed
 
as
 
equivalent
 
to
 
a
forward contract that
 
gives rise to a contractual obligation
 
attached to the underlying shares.
The
 
above
 
transactions
 
including
 
the
 
Bank’s
 
squeeze-out
 
right
 
for
 
the
 
acquisition
 
of
 
the
 
remaining
 
shares
 
of
 
Hellenic Bank
 
were
accounted
 
for
 
in the
 
Group’s
 
financial statements
 
as forward
 
contracts
 
at a
 
fixed
 
price (€
 
4.843 per
 
share)
 
to
 
acquire shares
 
in a
subsidiary that are held by non-controlling interests and were deemed to provide present
 
access to the risks & rewards of ownership
of these
 
shares to
 
the Bank.
 
Accordingly,
 
as of
 
November 2024
 
Hellenic Bank
 
is included
 
in the
 
Group’s
 
financial statements
 
with
100% consolidation percentage.
 
The difference between
 
a) the carrying amount of non-controlling shareholders’
 
interest in Hellenic
Bank of
 
ca. €
 
745 million
 
that was
 
derecognized and
 
b) the
 
financial liability
 
of ca.
 
€ 880
 
million that
 
was recognised
 
to reflect
 
the
Bank’s
 
unconditional
 
obligation
 
to deliver
 
cash to
 
non-controlling
 
shareholders
 
for
 
the acquisition
 
of their
 
Hellenic Bank’s
 
shares,
resulted in a loss of ca. € 136 million, including acquisition-related
 
costs that were recorded directly
 
in equity.
Post balance sheet event
On 11 February
 
2025, the Bank
 
announced that following the
 
receipt of the
 
relevant regulatory approvals, it completed the
 
acquisition
of the
 
additional
 
holding of
 
37.51% in
 
Hellenic Bank,
 
as per
 
the aforementioned
 
agreements
 
of the
 
Bank with
 
certain
 
of Hellenic
Bank’s shareholders
 
in November 2024. Following
 
that and pursuant
 
to the provisions
 
of the Takeover
 
Bids Law in Cyprus,
 
the Bank
also announced the submission of a Mandatory Takeover
 
Bid for the acquisition of up to 100% of the issued share capital
 
of Hellenic
Bank (“Takeover
 
Bid”). Further to the above,
 
on 6 March 2025 the
 
Bank announced that on
 
5 March 2025 the Cyprus
 
Securities and
Exchange Commission (the “CySEC”) approved
 
the Takeover
 
Bid Document and authorised its
 
publication. Pursuant to
 
the Takeover
Bid Document, the consideration
 
offered to the
 
shareholders of Hellenic Bank who
 
will accept the Takeover
 
Bid is € 4.843 per
 
share
paid in cash. The acceptance period of the Takeover
 
Bid commences on 11th March 2025 and ends on 9th April 2025.
Agreement with CNP Assurances on CNP Cyprus Insurance Holdings
On 9
 
July 2024, Hellenic
 
Bank and
 
CNP Assurances
 
signed a Sales
 
and Purchase
 
Agreement for
 
the acquisition of
 
its subsidiary CNP
Cyprus Insurance Holdings Limited, (the “Transaction”)
 
for a total consideration that is expected
 
to be € 182 million.
 
CNP Cyprus Insurance
 
Holdings Limited group,
 
which consists of amongst
 
others: CNP Cyprialife
 
Ltd, CNP Asfalistiki
 
Ltd, CNP Zois
 
SA
and CNP Cyprus
 
Properties Ltd.,
 
is a leading
 
insurance operator
 
in Cyprus. It
 
offers life
 
and general
 
insurance products
 
and services
through
 
a
 
large
 
network
 
of
 
independent
 
agents
 
in
 
Cyprus.
 
For
 
the
 
year
 
ended
 
31
 
December
 
2023,
 
it
 
had
 
c.
 
330
 
employees
 
and
generated € 236 million
 
of gross premiums. In
 
terms of the
 
potential profit contribution towards the Group going
 
forward, CNP Cyprus
entities had a cumulative
 
profit of c. € 21 million
 
for the year ended
 
31 December 2023. CNP Cyprus
 
Insurance Holdings Limited has
also presence in the Greek market.
On 28 November
 
2024, the Hellenic Bank announced
 
that the Commission for
 
the Protection of
 
Competition, in its meeting
 
held on
27 November
 
2024, approved
 
the concentration
 
arising from
 
the Transaction
 
.
 
The Transaction
 
is also
 
subject to
 
other regulatory
approvals and it is expected to be completed
 
within the first quarter of 2025.
 
23.3
 
Initiation of the merger process between Eurobank Ergasias Services and Holdings
 
S.A. and Eurobank S.A.
On 19
 
December 2024,
 
Eurobank
 
Holdings
 
announced
 
that
 
its Board
 
of
 
Directors
 
decided
 
the initiation
 
of the
 
merger
 
process
 
of
Eurobank Holdings with
 
the Bank through
 
absorption of the
 
former by the
 
latter,
 
in order that
 
operational efficiencies
 
and a leaner
group structure
 
be achieved. The merger
 
will be implemented
 
with a combined
 
application of Law 4601/2019
 
and article 16 of
 
Law
2515/1997 and 31 December 2024, was defined as the merger transformation
 
balance sheet date.
 
Upon the completion of the merger a) Eurobank Holdings ceases to exist and its shareholders
 
become shareholders of the Bank with
the same stakes and the same number of shares, receiving the entirety of Bank’s newly issued shares and b) the Bank, that will retain
its banking license, substitutes
 
Eurobank Holdings as
 
universal successor in
 
the totality
 
of its assets and
 
liabilities transferred
 
to the
Bank, as
 
they appear
 
in the
 
transformation
 
balance sheet
 
of Eurobank
 
Holdings and
 
as it
 
is formulated
 
until the
 
completion of
 
the
merger.
Before the completion of the merger,
 
the shares of the Bank will be listed in the Athens
 
Exchange and upon its completion, they
 
will
be distributed to
 
Eurobank Holdings shareholders
 
in exchange of
 
the Eurobank Holdings shares
 
they possess at a
 
ratio of one
 
newly
issued share of the Bank for one existing share of Eurobank
 
Holdings.
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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The
 
completion
 
of
 
the
 
merger
 
is
 
subject
 
to
 
all
 
necessary
 
by
 
Law
 
approvals,
 
including
 
the
 
approval
 
of
 
the
 
shareholders’
 
General
Meeting of both merging companies as well as the receipt of
 
all the necessary approvals of the competent Authorities.
24.
 
Investments in associates and joint ventures
.
.
As at 31 December 2024, the
 
carrying amount of the Group’s investments in associates and joint ventures amounted to € 203 million
(2023: € 541 million). The following is the listing of the Group’s
 
associates and joint ventures as at 31 December 2024:
.
 
 
 
 
 
 
 
 
 
 
Name
Country of
 
incorporation
Line of business
Group's
share
Femion Ltd
 
Cyprus
 
Special purpose investment vehicle
66.45
Global Finance S.A.
 
Greece
 
Investment financing
33.82
Odyssey GP S.a.r.l.
 
Luxembourg
 
Special purpose investment vehicle
20.00
Eurolife FFH Insurance Group Holdings S.A.
 
Greece
 
Holding company
20.00
Alpha Investment Property Commercial Stores S.A.
 
Greece
 
Real estate
30.00
Peirga Kythnou P.C.
 
Greece
 
Real estate
50.00
doValue Greece Loans and Credits Claim Management S.A.
 
Greece
 
Loans and Credits Claim Management
20.00
Perigenis Business Properties S.A.
 
Greece
 
Real estate
18.90
Note: In the first half of 2024, in the context of Solar securitization (note 20), the Group along with the other Greek systemic banks established “REOCO SOLAR
S.A.”
 
with its
 
holding percentage
 
amounting to
 
23.4%. The
 
company’s operating
 
activities are
 
expected to
 
commence upon
 
the completion
 
of the
 
relevant
securitization transaction.
Omega Insurance
 
and Reinsurance
 
Brokers
 
S.A. in which
 
the Group
 
holds 26.05% is
 
not accounted
 
under the
 
equity method in
 
the
consolidated financial statements. The Group is
 
not represented in the
 
Board of Directors of
 
the company, therefore does not exercise
significant influence over it.
Femion Ltd.
 
is accounted
 
for as
 
a joint
 
venture of
 
the Group
 
based on
 
the substance
 
and the
 
purpose of
 
the arrangement
 
and the
terms of the
 
shareholder’s agreement which require the
 
unanimous consent of
 
the shareholders for significant
 
decisions and establish
shared control through the equal representation
 
of the shareholders in the management bodies of the company.
Perigenis Business Properties
 
S.A. is accounted
 
for as an
 
associate of the
 
Group based
 
on the Bank’s
 
representation
 
in the Board
 
of
Directors and the decision-making process as prescribed
 
in the company’s articles of association.
Hellenic Bank Public Company Ltd, Cyprus
Hellenic Bank
 
Public Company
 
Ltd (“Hellenic
 
Bank”), was
 
accounted for
 
as a Group’s
 
associate under
 
the equity
 
method from
 
April
2023 until 30
 
June 2024. During
 
June 2024, the
 
Group acquired
 
an additional holding
 
of 26.28% in
 
Hellenic Bank, and
 
as a result
 
its
participation percentage in the
 
company’s share
 
capital reached 55.48%. As of
 
30 June 2024, the Group assessed that
 
it still had not
obtained control over the company, therefore Hellenic Bank
 
was accounted for as
 
an associate under
 
the equity method
 
of accounting
(further information is provided in note
 
23.2).
The
 
difference
 
between:
 
a)
 
the
 
additional
 
26.28%
 
share
 
of
 
the
 
fair
 
value
 
of
 
the
 
Hellenic
 
Bank
 
group’s
 
net
 
identifiable
 
assets,
amounting to
 
€ 383.3 million
 
and b) the
 
cost of
 
the additional Bank’s
 
holding in the
 
entity amounting
 
€ 277.7 million,
 
resulted in
 
a
gain
 
of
 
 
99.4
 
million
 
net
 
of
 
 
6.2
 
million
 
acquisition
 
related
 
costs
 
that
 
was
 
recognized
 
in
 
the
 
income
 
statement
 
line
 
“Other
income/(expenses)” (31 December 2023:
 
€ 111 million
 
gain, net of €
 
3 million acquisition
 
related costs, following the initial
 
application
of the equity accounting).
In the period that
 
ended on 30 June
 
2024, the last date
 
that Hellenic Bank group
 
was accounted for
 
as an associate, the
 
share of its
results
 
referred
 
to the
 
period from
 
30 September
 
2023 to
 
31 March
 
2024, as
 
they were
 
based on
 
its available
 
published financial
information. Accordingly,
 
in the third
 
quarter of 2024,
 
the share
 
of results
 
of the Hellenic
 
Bank group
 
has been adjusted
 
to include
the share
 
of results
 
for the
 
second quarter
 
of 2024
 
based on
 
its published
 
financial information.
 
As a
 
result, in
 
the year
 
ended 31
December 2024, the Group’s
 
share of results of the Hellenic Bank
 
group presented in the
 
income statement line
 
“Share of results of
associates and joint ventures”,
 
amounted to € 133 million gain (31 December 2023: € 58 million gain).
Associates and joint ventures material to
 
the Group
With regards to the Group’s associates and joint ventures,
 
Eurolife FFH Insurance Group Holdings S.A. and doValue Greece Loans and
Credits Claim Management
 
S.A. are considered
 
individually material for
 
the Group. Financial
 
information regarding
 
those entities is
provided in the tables below:
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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Eurolife FFH Insurance Group Holdings S.A.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Current assets
3,544
3,387
Non-current assets
290
353
Total assets
3,834
3,740
Current liabilities
389
380
Non-current liabilities
2,783
2,683
Total liabilities
3,172
3,063
Equity
662
677
Group’s carrying amount of the investment
132
135
Operating income
211
223
Net profit
90
112
Other comprehensive income
(46)
(18)
Total comprehensive
 
income
45
94
Dividends paid to the Group
12
7
 
doValue Greece Loans and Credits
 
Claim Management S.A.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Current assets
212
153
Non-current assets
309
323
Total assets
521
476
Current liabilities
117
157
Non-current liabilities
86
60
Total liabilities
203
217
Equity
318
259
Group's share in equity
64
52
Goodwill and other adjustments
 
(6)
(4)
Group’s carrying amount of the investment
58
48
Operating income
110
79
Net profit
56
57
Total comprehensive
 
income
56
57
Dividends paid to the Group
-
5
Note:
Goodwill and other
 
adjustments comprise a) €
 
6 million Goodwill included
 
in the carrying amount
 
of the investment, and b)
 
€ -12 million adjustment from
the elimination of the Group’s
 
share of the associate’s
 
income relating to upstream
 
transactions with the Bank,
 
of which € 2
 
million (loss) was recognised in
2024. The Group’s share of
 
the associate’s results after the
 
above adjustments, including
 
cut off differences, amounts
 
to € 10 million
 
income (2023: € 7.5
 
million
income).
 
The carrying amount, in aggregate, of the Group's joint ventures as at 31 December 2024 amounted to € 4 million (2023: € 4 million).
The Group’s share
 
of profit and loss and total comprehensive income of the
 
above entities was immaterial (2023: immaterial).
Notes to the Consolidated Financial Statements
 
.
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The
 
carrying
 
amount,
 
in
 
aggregate,
 
of
 
the
 
Group's
 
associates
 
excluding
 
Eurolife
 
FFH
 
Insurance
 
Group
 
Holdings
 
S.A.
 
and
 
doValue
Greece Loans and Credits Claim
 
Management S.A. which is
 
presented above (i.e. Global Finance
 
S.A., Odyssey GP S.a.r.l.,
 
and Perigenis
Business Properties
 
S.A.)
 
as at 31
 
December 2024 amounted
 
to €
 
9 million
 
(2023: € 9
 
million). The Group’s
 
share of
 
profit and
 
loss
and total comprehensive income of the above
 
entities was immaterial (2023: immaterial).
The Group has not recognized losses in relation
 
to its interest in its joint ventures,
 
as its share of losses exceeded its interest
 
in them
and no
 
incurred obligations
 
exist or
 
any payments
 
were performed
 
on behalf
 
of them. For
 
the year
 
ended 31
 
December 2024,
 
the
unrecognized share
 
of losses for the
 
Group’s
 
joint ventures
 
amounted to €
 
0.1 million (2023: €
 
0.1 million). The cumulative
 
amount
of unrecognized share of losses for
 
the joint ventures amounted to € 4 million
 
(2023: € 4 million).
As
 
at
 
31
 
December
 
2024,
 
the
 
Group
 
has
 
no
 
unrecognized
 
commitments
 
in
 
relation
 
to
 
its
 
participation
 
in
 
joint
 
ventures
 
nor
 
any
contingent liabilities regarding its participation
 
in associates or joint ventures, which could result to a future outflow
 
of cash or other
resources.
The Group’s associate
 
Eurolife FFH Insurance Group Holdings S.A is subject to regulatory
 
and statutory restrictions and is required
 
to
maintain sufficient capital to satisfy
 
its insurance obligations.
Except
 
as described
 
above, no
 
significant restrictions
 
exist (e.g.
 
resulting
 
from loan
 
agreements, regulatory
 
requirements
 
or other
contractual arrangements) on the ability of associates or joint ventures to
 
transfer funds to the Group either as dividends or to repay
loans that have been financed by the Group.
 
25.
 
Structured Entities
The Group is involved in various types of structured
 
entities, such as securitization vehicles, mutual funds and private
 
equity funds.
A structured
 
entity is
 
an entity that
 
has been
 
designed so
 
that voting
 
or similar rights
 
are not the
 
dominant factor
 
in deciding
 
who
controls the entity, such as when any voting rights
 
relate to administrative tasks only and the relevant activities are
 
directed by means
of contractual arrangements. A structured entity often has restricted activities, a narrow well-defined objective, insufficient equity to
permit it
 
to finance
 
its activities
 
without subordinated
 
financial support
 
and financing
 
in the
 
form
 
of multiple
 
contractually
 
linked
instruments to investors
 
that create concentrations
 
of credit or other risks.
An
 
interest
 
in
 
a
 
structured
 
entity
 
refers
 
to
 
contractual
 
and non-contractual
 
involvement
 
that
 
exposes
 
the
 
Group
 
to
 
variability
 
of
returns from
 
the performance
 
of the
 
structured
 
entity.
 
Examples of
 
interest
 
in structured
 
entities include
 
the holding
 
of debt
 
and
equity instruments, contractual arrangements,
 
liquidity support, credit enhancement, residual value.
Structured entities may be established
 
by the Group or by a third party and are
 
consolidated when the substance of the relationship
is such that the structured entities are controlled by the Group, as set out in note 2.2.1(i). As a result of the consolidation assessment
performed, the Group has involvement
 
with both consolidated and unconsolidated structured
 
entities, as described below.
Consolidated structured entities
The
 
Group,
 
as
 
part
 
of
 
its
 
funding activity,
 
enters
 
into
 
securitization
 
transactions
 
of
 
various
 
classes of
 
loans
 
(corporate,
 
small
 
and
medium enterprise, mortgage, consumer loans, credit card and bond loans), which generally result in
 
the transfer of the above assets
to structured
 
entities (securitization
 
vehicles), which,
 
in turn
 
issue debt
 
securities held
 
by investors
 
and the
 
Group’s
 
entities.
 
The
Group monitors the credit quality of the securitizations’ underlying loans, as well as the credit ratings of the debt instruments issued,
when applicable,
 
and provides
 
either credit
 
enhancements to
 
the securitization
 
vehicles and/or
 
transfers
 
new loans
 
to the
 
pool of
their underlying assets, whenever necessary,
 
in accordance with the terms of the relevant
 
contractual arrangements in force.
A listing of the Group’s
 
consolidated structured entities is set out in note 23.
As at 31 December 2024, the face value of debt securities issued by the securitizations sponsored by the Group amounted
 
to € 2,724
million, of which € 2,171 million were held by the Bank (2023: € 3,959 million, of which € 3,406 million were held by the Bank) (notes
20 and 34).
The Group did not provide any
 
non contractual financial or other support
 
to these structured entities, where applicable,
 
and currently
has no intention to do so in the foreseeable future.
 
 
 
Notes to the Consolidated Financial Statements
 
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Unconsolidated structured entities
The
 
Group
 
enters
 
into
 
transactions
 
with
 
unconsolidated
 
structured
 
entities,
 
which
 
are
 
those not
 
controlled
 
by
 
the Group,
 
in
 
the
normal course of business, in order to provide
 
fund management services or take advantage
 
of specific investment opportunities.
Moreover,
 
the Group
 
in the
 
context of
 
its NPE
 
reduction targets
 
has
 
entered into
 
the securitization
 
of various
 
classes of
 
primarily
NPE loan portfolios originated or acquired by the Group
 
through the issue of senior,
 
mezzanine and junior notes (note 20).
Group managed funds
The Group establishes
 
and manages structured
 
entities in order
 
to provide customers,
 
either retail or
 
institutional, with investment
opportunities.
 
Accordingly,
 
through
 
its subsidiaries
 
Eurobank
 
Asset Management
 
Mutual Fund
 
Mngt
 
Company
 
S.A. and
 
Eurobank
Fund Management
 
Company
 
(Luxembourg)
 
S.A., it
 
is engaged
 
with the
 
management
 
of different
 
types of
 
mutual funds,
 
including
fixed income, equities, funds of funds and money market.
Additionally,
 
the Group
 
is entitled to
 
receive management
 
and other
 
fees and
 
may hold
 
investments
 
in such mutual
 
funds for
 
own
investment purposes as well as for the benefit
 
of its customers.
The Group is involved in the initial design of the mutual funds and, in its capacity as fund manager, takes investment decisions on the
selection
 
of
 
their
 
investments,
 
nevertheless
 
within
 
a
 
predefined,
 
by
 
relevant
 
laws
 
and
 
regulations,
 
decision
 
making
 
framework.
Τherefore, the Group has determined
 
that it has no power over these funds.
Furthermore,
 
in its
 
capacity as
 
fund manager,
 
the Group
 
primary acts
 
as an
 
agent in
 
exercising
 
its decision
 
making authority
 
over
them. Based on the above, the
 
Group has assessed that it has no
 
control over these mutual funds and as a
 
result does not consolidate
them. The Group does not have any contractual obligation to provide financial
 
support to the managed funds and
 
does not guarantee
their rate of return.
Non-Group managed funds
The Group purchases and
 
holds units of
 
third party managed
 
funds including mutual
 
funds, private equity and
 
other investment funds.
Securitizations
The Group has interests in unconsolidated securitization vehicles by investing in residential
 
mortgage backed and other asset-backed
securities issued by these entities.
The
 
table
 
below
 
sets
 
out
 
the
 
carrying
 
amount
 
of
 
the
 
Group’s
 
interests
 
in
 
unconsolidated
 
structured
 
entities,
 
recognized
 
in
 
the
consolidated
 
balance
 
sheet
 
as
 
at
 
31
 
December
 
2024,
 
representing
 
its
 
maximum
 
exposure
 
to
 
loss
 
in
 
relation
 
to
 
these
 
interests.
Information relating
 
to the
 
total income
 
derived from
 
interests in
 
unconsolidated
 
structured entities,
 
recognized either
 
in profit
 
or
loss or
 
other comprehensive
 
income during
 
2024 is also
 
provided (i.e.
 
fees, interest
 
income, net
 
gains or
 
losses on revaluati
 
on and
derecognition):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Unconsolidated structured entity type
Securitizations
Group managed
funds
Non- Group
managed funds
Total
€ million
€ million
€ million
€ million
Group's interest-
 
assets
Loans and advances to customers
4,387
-
-
4,387
Investment securities
2,008
89
113
2,210
Other Assets
-
2
-
2
Total
 
6,395
91
113
6,599
Total
 
comprehensive income from Group interests
158
77
3
238
 
 
 
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Notes to the Consolidated Financial Statements
 
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31 December 2023
Unconsolidated structured entity type
Securitizations
Group managed
funds
Non- Group
managed funds
Total
€ million
€ million
€ million
€ million
Group's interest-
 
assets
Loans and advances to customers
 
4,454
-
-
4,454
Investment securities⁽¹⁾
1,517
85
28
1,630
Other Assets
-
2
-
2
Total
 
5,971
87
28
6,086
Total
 
comprehensive income from Group interests
123
62
0
185
(1)
It includes asset-backed
 
securities held by Group
 
entities from third-party
 
issuances; comparative information has
 
been adjusted to
 
align with the
 
current
year’s presentation.
For
 
the
 
year
 
ended
 
31 December
 
2024, total
 
comprehensive
 
income
 
related
 
to
 
the
 
Group’s
 
interests
 
from
 
securitizations
 
mainly
includes: (i) € 147.3 million
 
interest income of debt securities retained by the Group measured at amortized cost,
 
at FVOCI and FVTPL,
(ii)
 
 
3.1
 
million
 
from
 
gains
 
or
 
losses
 
on
 
revaluation
 
recognized
 
in
 
other
 
comprehensive
 
income
 
and
 
(iii)
 
 
7.4
 
million
 
gain
 
on
revaluation of mezzanine
 
securitization notes. Total
 
income from Group interests
 
in relation to Group
 
managed funds consists of: (i)
€ 70.2 million income referring to management and related fees for
 
the Group managed funds and (ii) € 7.3 million gains or losses on
revaluation or from sale of the Group’s holding in funds recognized in profit or loss. In addition, total income in relation to non-Group
managed funds consists mainly of gains or losses on revaluation or from sale of
 
the Group’s holding in funds and has been recognized
in profit or loss.
As at 31 December 2024, the total assets of funds under the Group’s
 
management amounted to € 5.9 billion (2023: € 4.3 billion).
For the securitization notes included in the balance sheet line “Loans and advances to customers”,
 
referring to the senior,
 
mezzanine
and junior notes of the
 
securitizations of loans
 
originated by Group
 
entities (note 20), the notional
 
amount of total
 
issuances by the
unconsolidated
 
securitization vehicles
 
amounted to
 
€ 15.2 billion
 
(2023: € 14.0
 
billion). As
 
at 31
 
December 2024
 
and 2023,
 
for the
securitization
 
notes included
 
in the
 
balance sheet
 
line “Investment
 
securities” the
 
Group did
 
not hold
 
a significant
 
position of
 
the
notional amount of total issuances by the unconsolidated
 
securitization vehicles.
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
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26.
 
Property and equipment
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Land, buildings,
leasehold
improvements
Furniture,
equipment,
 
motor
vehicles
Computer
hardware,
software
Right of use assets
(RoU)⁽¹⁾
Total
€ million
€ million
€ million
€ million
€ million
Cost:
Balance at 1 January
697
191
316
338
1,542
Arising from acquisitions (note 23)
 
148
54
51
15
268
Transfers
 
21
(3)
3
-
21
Transfers from/to repossessed assets
2
(1)
-
-
1
Additions
 
26
21
26
15
88
Disposals, write-offs and adjustment to RoU ⁽¹⁾
(16)
(7)
(2)
7
(18)
Impairment
-
-
(5)
-
(5)
Balance at 31 December
878
255
389
375
1,897
Accumulated depreciation:
Balance at 1 January
(220)
(140)
(241)
(168)
(769)
Arising from acquisitions (note 23)
 
(1)
(45)
(42)
(8)
(96)
Transfers
0
1
-
-
1
Disposals, write-offs and adjustment to RoU ⁽¹⁾
11
7
2
3
23
Charge for the year
(15)
(11)
(21)
(34)
(81)
Balance at 31 December
(225)
(188)
(302)
(207)
(922)
Net book value at 31 December
653
67
87
168
975
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Land, buildings,
leasehold
improvements
Furniture,
equipment,
 
motor
vehicles
Computer
hardware,
software
Right of use assets
(RoU)⁽¹⁾
Total
€ million
€ million
€ million
€ million
€ million
Cost:
Balance at 1 January
676
206
526
328
1,736
Arising from acquisitions
33
1
1
2
37
Transfers
 
3
-
14
-
17
Additions
 
28
15
11
11
65
Disposals, write-offs and adjustment to RoU⁽¹⁾
(6)
(21)
(217)
20
(224)
Impairment
(1)
-
(9)
-
(10)
Discontinued operations
(36)
(10)
(10)
(23)
(79)
Balance at 31 December
697
191
316
338
1,542
Accumulated depreciation:
Balance at 1 January
(221)
(156)
(443)
(141)
(961)
Arising from acquisitions
 
-
(1)
-
-
(1)
Transfers
1
0
(1)
-
0
Disposals, write-offs and adjustment to RoU⁽¹⁾
4
20
217
2
243
Charge for the year
(13)
(8)
(20)
(37)
(78)
Discontinued operations
9
5
6
8
28
Balance at 31 December
(220)
(140)
(241)
(168)
(769)
Net book value at 31 December
477
51
75
170
773
 
(1)
The respective lease liabilities are presented in “other
 
liabilities” (note 35). Adjustment to RoU
 
refers to termination, modifications and remeasurements of
RoU. It includes the remeasurement from
 
revised estimates of the lease term
 
during the year, considering all
 
facts and circumstances that affect
 
the Group’s
housing needs.
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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As at
 
31 December
 
2024, the
 
RoU assets
 
amounting to
 
€ 168
 
million (31
 
December 2023:
 
€ 170
 
million) refer
 
to leased
 
office and
branch premises, ATM
 
locations, residential properties
 
of € 159 million (31 December 2023: € 165
 
million) and motor vehicles of € 9
million (31 December 2023: € 5 million).
Leasehold improvements relate to
 
premises occupied by the Group for its own activities.
27.
 
Investment property
The
 
Group
 
applies
 
the
 
fair
 
value
 
model
 
regarding
 
the
 
measurement
 
of
 
Investment
 
Property
 
according
 
to
 
IAS
 
40
 
“Investment
property”.
The movement of investment property
 
is as follows:
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balance at 1 January
1,357
1,410
Additions
8
4
Arising from acquisition (note 23)
84
19
Transfers
 
from/to repossessed assets
33
2
Other transfers
 
(20)
(3)
Disposals
(41)
(80)
Net gain/(loss) from fair values adjustments
9
6
Held for sale/Discontinued operations
(26)
(3)
Additions and adjustment to RoU
-
2
Balance at 31 December
1,404
1,357
As at 31 December
 
2024, RoU assets
 
that meet the definition
 
of investment
 
property amount to
 
€ 17 million (31
 
December 2023: €
16 million). The respective lease liabilities are presented
 
in “other liabilities” (note 35).
Changes
 
in
 
fair
 
values
 
of
 
investment
 
property
 
are
 
recognized
 
as
 
gains/(losses)
 
in
 
profit
 
or
 
loss
 
and
 
included
 
in
 
the
 
"Other
Income/(expense)" (note 10). All gains/(losses) are
 
unrealized.
During
 
the year
 
ended 31
 
December 2024,
 
an amount
 
of €
 
90 million
 
(2023: €
 
89 million)
 
was
 
recognized
 
as rental
 
income from
investment property in income from
 
non banking services (note 8).
The main classes of investment property have
 
been determined based on the nature, the characteristics
 
and the risks of the Group’s
properties. The
 
fair value
 
measurements of
 
the Group’s
 
investment property,
 
which are categorized
 
within level
 
3 of the
 
fair value
hierarchy,
 
are presented in the below table.
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Residential
 
4
6
Commercial
 
1,373
1,320
Land Plots
27
30
Industrial
 
-
1
Total
 
1,404
1,357
 
The
 
basic
 
methods
 
used
 
for
 
estimating
 
the
 
fair
 
value
 
of
 
the
 
Group’s
 
investment
 
property
 
are
 
the
 
income
 
approach
 
(income
capitalization/discounted
 
cash flow
 
method), the
 
comparative
 
method and
 
the cost
 
approach, which
 
are also
 
used in
 
combination
depending on the class of property being valued.
The discounted cash flow (DCF) method is the primary method used for estimating
 
the fair value of the Group’s
 
investment property
and is used mainly
 
for the commercial class of investment property but also
 
for other classes of investment property to a
 
large extent,
in conjunction
 
with other methods.
 
Under DCF method,
 
the fair
 
value is
 
calculated through
 
the projection
 
of a series
 
of cash
 
flows
using explicit
 
assumptions
 
regarding
 
the benefits
 
and liabilities
 
of ownership
 
(income and
 
operating
 
costs,
 
vacancy
 
rates,
 
income
growth),
 
including
 
the
 
residual
 
value
 
anticipated
 
at
 
the
 
end
 
of
 
the
 
projection
 
period.
 
To
 
this
 
projected
 
cash
 
flows
 
series,
 
an
appropriate, market-derived discount
 
rate is applied to establish its present
 
value.
 
Notes to the Consolidated Financial Statements
 
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Under
 
the
 
income
 
capitalization
 
method,
 
also
 
used
 
for
 
the
 
commercial
 
class
 
of
 
investment
 
property,
 
a
 
property’s
 
fair
 
value
 
is
estimated based on the
 
normalized net operating
 
income generated by
 
the property,
 
which is divided by the capitalization
 
rate (the
investor's rate of
 
return).
The comparative method is used for the residential, commercial and land plot classes of investment
 
property. Fair value
 
is estimated
based on data for
 
comparable transactions, by
 
analyzing either real transaction
 
prices of similar properties,
 
or by asking prices after
performing the necessary adjustments.
The cost approach is used
 
for estimating the fair value of
 
the residential and the industrial
 
classes of the Group’s investment property.
This approach refers to the
 
calculation of the
 
fair value based on
 
the cost of
 
reproduction/replacement (estimated construction costs),
which is then reduced by an appropriate rate
 
to reflect depreciation.
The Group’s
 
investment
 
property valuations
 
are performed
 
taking into
 
consideration the
 
highest and
 
best use of
 
each asset that
 
is
physically possible, legally permissible and financially feasible.
The main method used to estimate the fair value of Group’s Investment property portfolio as at 31 December 2024, is
 
the discounted
cash flow method. Significant unobservable inputs used in the fair value measurement of the
 
relevant portfolio are the rental income
growth and the discount
 
rate. Increase in rental
 
income growth would result
 
in increase in the carrying
 
amount while an increase in
the discount rate would have the
 
opposite result. The discount rate used
 
ranges from 7% to 12%.
 
As at 31
 
December 2024, an increase
or decrease
 
of 5% in
 
the discount
 
rate used
 
in the DCF
 
analysis, would
 
result in
 
a downward
 
or upward
 
adjustment of
 
the carrying
value of the respective investment
 
properties by € 33 and € 35.4 million, respectively.
In the context of properties’ valuation, sustainability and environmental matters encompass a wide
 
range of physical, climate change,
social, corporate responsibility and economic factors, including key
 
environmental risks such as flooding, energy efficiency,
 
as well as
matters of design, configuration, accessibility and legislation, that impact their value. The Group is gradually upgrading its real-estate
portfolio, aiming to reduce its environmental footprint and shift towards high-end, modern, environmentally friendly buildings, given
that such buildings are in
 
high demand. In addition,
 
the Group has introduced “green” certifications to its real
 
estate assets, validating
their sustainability value and at the same time maximizing their return and market value. On the other hand, environmental
 
risks are
taken into
 
account in properties’ valuation
 
in cases where there
 
is an indication that
 
the valued property is
 
subject to physical
 
risks,
such as floods, is contaminated or is adversely
 
affected by existing environmental
 
laws/regulations.
On an
 
annual
 
basis,
 
the
 
Group
 
aims at
 
the
 
evaluation
 
of
 
an
 
increased
 
number
 
of
 
selected
 
properties
 
included
 
in
 
the
 
investment
property portfolio
 
for their
 
gradual certification
 
in accordance with
 
international standards,
 
while actively investing
 
to improve
 
the
energy efficiency of its properties’ portfolio and its
 
environmental profile.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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28.
 
Intangible assets
As at 31 December
 
2024, the carrying
 
amount of intangible assets
 
was € 415 million
 
(31 December 2023: € 334
 
million), comprising
€ 373 million computer software, which refer
 
to purchased and developed software,
 
and € 42 million goodwill (31 December 2023 €
44 million).
The table below presents the movement of computer
 
software:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Cost:
Balance at 1 January
515
658
Arising from acquisitions (note 23)
107
1
Transfers
 
(2)
(14)
Additions
117
83
Disposals and write-offs
(13)
(142)
Impairment
(13)
(8)
Discontinued operations
(63)
Balance at 31 December
711
515
Accumulated amortisation:
 
Balance at 1 January
(225)
(362)
Arising from acquisitions (note 23)
(74)
Transfers
 
-
1
Amortisation charge for the year
(51)
(42)
Disposals and write-offs
12
142
Discontinued operations
-
36
Balance at 31 December
(338)
(225)
Net book value at 31 December
373
290
Impairment testing of goodwill
As at
 
31 December
 
2024, the
 
carrying amount
 
of goodwill
 
in the
 
Group is
 
€ 42
 
million, arising
 
from the
 
acquisition of
 
BNP Paribas
Personal Finance Bulgaria by Eurobank
 
Bulgaria A.D in May 2023, and is attributed to the Group’s
 
International, Bulgaria segment.
For the purpose of impairment testing,
 
goodwill is fully allocated to
 
the Consumer Lending business of Eurobank
 
Bulgaria A.D, being
the CGU
 
that
 
is expected
 
to benefit
 
from
 
the abovementioned
 
business
 
combination.
 
No impairment
 
losses of
 
the CGU
 
to which
goodwill has been allocated were identified during the year
 
ended 31 December 2024.
In particular,
 
the recoverable amount
 
of the CGU was determined to be its fair
 
value less costs of disposal, calculated
 
by discounting
the future cash
 
flows expected to
 
be generated
 
from the continuing
 
use of the
 
CGU’s
 
assets and their
 
ultimate disposal.
 
The CGU’s
future cash flows for a three-year period are in accordance with the officially approved three-year business plan, which already takes
into account
 
factors such
 
as expected market
 
growth, inflation, as
 
well as expectations
 
of future outcomes
 
taking into
 
account past
experience. A long-term growth rate (terminal value growth rate)
 
was used to extrapolate cash flows beyond the three-year
 
horizon.
The
 
terminal
 
value
 
growth
 
rate
 
is
 
determined
 
by
 
considering
 
factors
 
such
 
as
 
the
 
expected
 
long-term
 
inflation
 
rate
 
and real
 
-GDP
growth rate in
 
Bulgaria. The discount rate
 
applied is constructed using the Capital
 
Assets Pricing Model methodology (CAPM), based
on the
 
rate
 
of 10-year
 
Bulgarian government
 
bonds, adjusted
 
for
 
a risk
 
premium
 
to reflect
 
both the
 
increased
 
risk of
 
investing
 
in
equities generally and the systematic risk of the specific CGU. The discounting of the budgeted cash flows and terminal values is
 
done
on an after-tax cash flow basis.
The key assumptions used in the calculation of the CGU’s
 
fair value less costs of disposal were as follows:
 
 
 
Budgeted operating income growth
(average for the 3-year period)
Discount Rate
Growth rate beyond
initial cash flow
Key assumption value
9.0%
14.5%
2.0%
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
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Cost of disposal
 
is calculated
 
as a percentage
 
of the CGU’s
 
assets and is
 
based on observed
 
averages from
 
global industry practices
(2-4% range).
The values assigned
 
to the above
 
key assumptions
 
represent Management’s
 
assessment of future
 
trends in the
 
relevant sector
 
and
have been based on historical data
 
from both external and internal sources.
The recoverable
 
amount of
 
the CGU to
 
which goodwill
 
has been allocated
 
is sensitive to
 
the above
 
key assumptions.
 
A decrease in
the operating income by 5% or an
 
increase in the discount rate of 1% are considered reasonably possible
 
changes in key assumptions.
If the aforementioned changes occur,
 
goodwill of the remaining CGU will continue to be recoverable.
The key assumptions described above may change as economic and market
 
conditions change. The Group estimates that reasonably
possible changes in these assumptions would not cause the recoverable amount of either CGU to decline
 
below the carrying amount.
29.
 
Other assets
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Receivable from Deposit Guarantee and Investment
 
Fund
 
70
286
Repossessed properties and relative prepayments
 
541
509
Pledged amount for a Greek sovereign risk financial guarantee
242
236
Balances under settlement⁽¹⁾
55
53
Deferred costs and accrued income
144
85
Other guarantees
262
215
Income tax receivable⁽²⁾
98
58
Insurance and reinsurance contract assets (note 36)
30
-
Other assets⁽³⁾
253
325
Total
1,695
1,767
(1)
Includes settlement balances with customers and brokerage activity.
(2)
Includes withholding taxes, net of provisions.
(3)
Includes provisional fair value adjustments for Hellenic Bank group assets (decrease) of
 
ca. € 66 million (note 23.2).
Pursuant
 
to Law
 
4370/2016 as
 
in force,
 
in December
 
2024, an
 
amount of
 
€ 215
 
million was
 
refunded
 
to the
 
Bank by
 
the Hellenic
Deposit and Investment Guarantee Fund
 
(HDIGF) referring to the receivable for
 
the “Supplementary Deposit Cover Fund”.
As at 31 December 2024, other assets net of provisions, amounting to
 
€ 253 million include, among others, receivables related
 
to (a)
prepayments to suppliers, (b) public entities,
 
(c) property management activities (d)
 
legal cases and e) the
 
sale of the Bank’s Merchant
Acquiring Business in 2022 .
30.
 
Disposal groups classified as held for sale and discontinued operations
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Assets of disposal groups
Real estate properties
33
37
Loans portfolios (note 20)
46
169
IMO Property Investments Bucuresti S.A.
12
-
Total
91
206
Liabilities of disposal groups
IMO Property Investments Bucuresti S.A.
2
-
Other liabilities related to loans portfolios (notes 20 and 35)
1
1
Total
 
3
1
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
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Real estate properties
In the context of its strategy for the active management of its real
 
estate portfolio (repossessed, investment properties and own used
properties), the Group
 
has gradually classified as
 
held for sale certain
 
pools of real estate
 
assets of total
 
remaining carrying amount
ca. € 33 million as at
 
31 December 2024 (31 December 2023: €
 
37 million), after their remeasurement
 
in accordance with the IFRS 5
requirements.
The Group remains
 
committed to
 
its plan to sell
 
the aforementioned
 
assets, which are gradually
 
being disposed, and undertakes
 
all
necessary actions towards this direction.
The above
 
non-recurring fair
 
value measurements
 
were categorized
 
as Level 3
 
of the fair
 
value hierarchy
 
due to the
 
significance of
the unobservable inputs used, with no change occurring up to 31 December 2024.
IMO Property Investments Bucuresti S.A., Romania
In
 
June
 
2024,
 
the
 
sale
 
of
 
IMO
 
Property
 
Investments
 
Bucuresti
 
S.A.
 
was
 
considered
 
highly
 
probable,
 
therefore
 
the
 
company
 
was
classified as held for sale in accordance with IFRS 5. Accordingly, in the second quarter of 2024, a remeasurement/impairment loss of
€ 9.4 million on
 
real estate
 
properties was recognised
 
in the income statement
 
line “Other impairments,
 
risk provisions and related
costs”.
Discontinued operations
In the year
 
ended 31 December 2024,
 
an additional provision
 
of € 10 million
 
(€ 7.1 million net
 
of tax) was
 
recognized, in
 
relation to
the sale of a
 
Bank’s former
 
subsidiary,
 
previously presented
 
as a discontinued
 
operation, based on
 
specific indemnity clauses in
 
the
relevant Sale Purchase Agreement.
Eurobank Direktna a.d. disposal group
As of
 
31 March
 
2023, the
 
assets of
 
Eurobank
 
Direktna a.d.
 
and the
 
associated liabilities,
 
which formed
 
part of
 
the share
 
purchase
agreement signed by the
 
Bank with AIK
 
Banka a.d. Beograd, were
 
classified as held
 
for sale and presented as
 
a discontinued operation.
The subsidiary was the major part of the Group’s
 
operations in Serbia, which are presented
 
in the International segment.
Until the completion of the sale, the net loss of Eurobank
 
Direktna a.d. disposal group for 2023 amounted
 
to € 47 million, of which €
12 million was attributable to non controlling
 
interests.
On
 
2
 
November
 
2023,
 
following
 
the
 
receipt
 
of
 
the
 
approvals
 
by
 
all
 
competent
 
regulatory
 
authorities,
 
the
sale
 
of
 
the
 
Group’s
shareholding in Eurobank Direktna to AIK
 
Banka a.d. Beograd was completed for a
 
cash consideration of € 188.7
 
million, net of related
costs. Following the remeasurement losses
 
of € 63.5
 
million recognized until 31 October
 
2023, in accordance with
 
IFRS 5 requirements
the resulting
 
loss from
 
the sale amounted
 
to € 123
 
million before
 
tax, including
 
the recyclement
 
to the income
 
statement
 
of € 124
million cumulative losses (mainly currency translation
 
differences), previously recognized
 
in other comprehensive income.
31.
 
Due to central banks
In December
 
2024, the
 
Group fully
 
repaid its
 
secured borrowing
 
under the
 
TLTRO
 
III refinancing
 
program
 
of the
 
European Central
Bank (ECB) (31 December 2023: € 3.7 billion outstanding principal under TLTRO
 
III program).
32.
 
Due to credit institutions
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Secured borrowing from credit institutions⁽¹⁾
1,952
2,428
Borrowings from international financial and similar institutions
457
379
Deposits from banks received as collateral⁽¹⁾
118
87
Current accounts and settlement balances with banks
104
79
Interbank takings
169
105
Total
2,800
3,078
 
(1)
 
The amounts presented are after offsetting (note 5.2.1.4).
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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Borrowings from international
 
financial and similar institutions include
 
borrowings from European
 
Investment Bank, European
 
Bank
for Reconstruction and Development
 
and other similar institutions.
33.
 
Due to customers
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Savings and current accounts
49,993
37,238
Term deposits
28,604
20,209
Carrying amount
78,597
57,447
Fair value changes of deposits in portfolio hedging
 
of interest rate risk
(4)
(5)
Total
78,593
57,442
For the year
 
ended 31 December
 
2024, due to
 
customers for
 
the Greek and
 
International operations
 
amounted to
 
€ 43,287 million
and € 35,306 million, respectively (2023: € 39,950 million and € 17,492 million, respectively).
34.
 
Debt securities in issue
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Securitisations
554
555
Subordinated notes (Tier 2)
 
1,758
1,296
Medium-term notes (EMTN)
4,664
2,905
Credit linked notes
 
80
-
Total
7,056
4,756
 
Subordinated Tier 2 notes
In January 2024, the Company announced the issuance of a € 300 million subordinated Tier II debt instrument which matures in April
2034, is callable
 
at par
 
in April 2029
 
offering a
 
coupon of
 
6.25% per annum
 
and is listed
 
on the Luxembourg
 
Stock Exchange’s
 
Euro
MTF market. On the same date, the Bank issued a subordinated instrument
 
of equivalent terms, held by the Company.
 
The proceeds
from
 
the
 
issue
 
support
 
Eurobank
 
Holding’s
 
Group
 
strategy
 
to
 
ensure
 
ongoing
 
compliance
 
with
 
its
 
total
 
capital
 
adequacy
 
ratio
requirements and are
 
used for the Bank’s
 
general funding purposes.
 
Further information about
 
the issue is provided
 
in the relevant
announcement published in the Company’s website
 
on 19 January 2024.
As at 31 December 2024, Tier
 
II subordinated instruments include notes issued by Hellenic Bank with nominal value €
 
200 million, out
of which
 
€ 33
 
million were
 
held by
 
Group
 
entities. The
 
notes were
 
issued in
 
March
 
2023 at
 
par offering
 
a coupon
 
of 10.25%
 
per
annum,
 
mature
 
in
 
14
 
June
 
2033,
 
are
 
callable
 
at
 
par
 
for
 
a
 
3-month
 
period
 
commencing
 
on
 
14
 
March
 
2028
 
and
 
are
 
listed
 
on
 
the
Luxembourg Stock Exchange’s
 
Euro MTF market.
Medium-term notes (EMTN)
In March 2024, the Bank exercised its call option
 
on senior preferred notes of face
 
value of € 500 million.
In April 2024,
 
the Company announced
 
that Eurobank S.A.
 
successfully completed the
 
issuance of €
 
650 million senior
 
preferred notes.
The bond matures
 
on 30 April 2031,
 
is callable at
 
par on 30 April
 
2030 offering
 
a coupon of 4.875
 
% per annum
 
and is listed
 
on the
Luxembourg Stock Exchange’s
 
Euro MTF market. The
 
proceeds from the issue support
 
Eurobank Group’s
 
strategy to ensure
 
ongoing
compliance with its Minimum Required Eligible Liabilities (MREL) requirement and are used for Eurobank’s general funding purposes.
Further information about the issue is provided in the relevant announcement published in the Company’s
 
website on 24 April 2024.
In July 2024, the
 
Company announced that Eurobank S.A. successfully
 
completed a tap issue (“New
 
Bonds”) to the April 2024
 
issuance
of € 650 million fixed rate senior preferred notes (“Initial Bonds”). The New Bonds, of an aggregate principal amount of € 100 million,
will be
 
consolidated and
 
form a
 
single series with
 
the Initial
 
Bonds. Further
 
information about
 
the issue
 
is provided
 
in the
 
relevant
announcement published in the Company’s website
 
on 8 July 2024.
 
Notes to the Consolidated Financial Statements
 
.
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doc1p253i0 doc1p253i1
 
In September
 
2024, the Company
 
announced that Eurobank
 
S.A. successfully completed
 
the issuance of
 
€ 850 million
 
Green senior
preferred
 
notes. The
 
bond matures
 
on 24
 
September 2030,
 
is callable
 
at par
 
on 24
 
September 2029
 
offering
 
a coupon
 
of 4
 
% per
annum and is
 
listed on
 
the Luxembourg
 
Stock Exchange’s
 
Euro MTF
 
market. The
 
proceeds from
 
the issue will
 
be used to
 
finance or
refinance
 
a
 
portfolio
 
of
 
Green
 
Eligible
 
Projects
 
selected
 
in
 
accordance
 
with
 
the
 
criteria
 
described
 
in
 
Eurobank’s
 
Green
 
Bond
Framework
 
and
 
will
 
support
 
Eurobank
 
Group’s
 
strategy
 
to
 
ensure
 
ongoing
 
compliance
 
with
 
its
 
MREL
 
requirement.
 
Further
information about the issue is provided in the relevant
 
announcement published in the Company’s website
 
on 18 September 2024.
In September
 
2024, Hellenic
 
Bank announced
 
the issuance
 
of €
 
100 million
 
senior preferred
 
notes, out
 
of which
 
€ 57
 
million were
held by Group entities.
 
The bond matures on
 
17 September 2026, offering a
 
coupon of 4
 
% per annum and
 
is listed on the
 
Luxembourg
Stock Exchange’s
 
Euro MTF market.
In December 2024 the Company announced that Eurobank S.A. successfully completed the issuance of € 600 million senior preferred
notes. The bond matures
 
on 12 March 2030, is callable
 
at par on 12 March
 
2029 offering a coupon of
 
3.25% per annum and is listed
on the Luxembourg Stock Exchange’s Euro MTF market. The
 
proceeds from the issue
 
will support Eurobank Group’s strategy to ensure
ongoing compliance with its MREL
 
requirements and will be used
 
for Eurobank’s general funding purposes. Further information about
the issue is provided in the relevant announcement
 
published in the Company’s website on 6 December 2024.
Credit linked note
In December
 
2024, the
 
Bank issued
 
a credit
 
linked note
 
(“CLN”) of €
 
80 million
 
that provides
 
credit protection
 
over the
 
mezzanine
tranche of a portfolio of performing SME and Large Corporate loans amounting
 
to € 1.1 billion (“Wave VI” transaction - note 20). The
credit
 
protection
 
to
 
the
 
Bank
 
is
 
provided
 
by
 
means
 
of
 
adjustments
 
(write-downs)
 
to
 
the
 
principal
 
balance
 
of
 
the
 
CLN,
 
after
 
the
occurrence of certain
 
credit events
 
in relation to
 
the protected
 
loans, pursuant to
 
the terms and
 
conditions of the
 
CLN. In addition,
the issued note matures in
 
July 2039, is callable in September 2029 and pays
 
a floating interest rate
 
(3-month Euribor plus spread of
9.39%) that also reflects the tranche protection
 
components, as specified in the terms and conditions of the CLN.
Post balance sheet events
Subordinated Tier 2 notes
In
 
January
 
2025,
 
the
 
Company
 
announced
 
that
 
it
 
has
 
successfully
 
priced
 
the
 
issuance
 
of
 
 
400
 
million
 
subordinated
 
Tier
 
II
 
debt
instruments (New
 
Instruments) which
 
mature in
 
April 2035, are
 
callable at par
 
from 30 January
 
2030 until 30
 
April 2030, offer
 
ing a
coupon
 
of
 
4.25%
 
per
 
annum
 
and
 
are
 
listed
 
on
 
the
 
Luxembourg
 
Stock
 
Exchange’s
 
Euro
 
MTF
 
market.
 
In
 
addition,
 
the
 
Company
announced an any
 
-and-all exchange
 
offer for
 
Hellenic Bank’s
 
outstanding €
 
200 million Tier
 
2 notes, out
 
of which €
 
33 million were
held by Group entities,
 
with additional Eurobank Holdings Tier
 
2 subordinated notes, issued under
 
a single series
 
and with same terms
with the € 400 million subordinated notes. The offer
 
period was set from 21 January 2025 until 27 January 2025.
On 28 January
 
2025, the Company
 
announced that it
 
has decided to
 
accept all existing
 
notes offered
 
for exchange,
 
pursuant to
 
the
exchange offer,
 
with nominal value of € 157 million. The nominal value of new
 
instruments to be issued is € 188.5 million, which will
form a single series with the New Instruments with a combined aggregate
 
nominal amount of € 589 million.
The
 
purpose
 
of
 
the
 
Exchange
 
Offer
 
and
 
the
 
issuance
 
of
 
the
 
Eurobank
 
Holdings
 
subordinated
 
notes
 
is
 
to
 
optimize
 
the
 
regulatory
efficiency of Eurobank Holdings’ capital base while the proceeds
 
will be used for general financing purposes.
Medium term notes (EMTN)
In
 
February
 
2025
 
Eurobank
 
S.A.
 
successfully
 
completed
 
the
 
issuance
 
of
 
 
350
 
million
 
senior
 
preferred
 
notes
 
through
 
a
 
private
placement. The bonds mature on 7 February 2036, are callable at par on 7 February 2035
 
offering a coupon of 4% per annum and are
listed on the Luxembourg Stock Exchange’s
 
Euro MTF market. The proceeds from the issue will support Eurobank Group’s strategy
 
to
ensure ongoing compliance with its MREL requirements.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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35.
 
Other liabilities
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balances under settlement⁽¹⁾
439
380
Lease liabilities
190
190
Deferred income and accrued expenses
269
194
Other provisions
154
116
ECL allowance for credit related commitments (note
 
5.2.1.2)
63
48
Standard legal staff retirement
 
indemnity obligations and employee termination benefits
(note 37)
143
59
Sovereign risk financial guarantee
 
29
31
Income taxes payable
70
30
Deferred tax liabilities (note 13)
43
28
Trading liabilities
43
121
Insurance contract liabilities
108
-
Obligation relating to the acquisition of NCI in Hellenic Bank (note 23.2)
880
-
Other liabilities⁽²⁾
251
188
Total
2,682
1,385
(1)
Includes settlement balances relating to bank cheques and remittances, credit card transactions,
 
other banking and brokerage activities.
(2)
 
Includes provisional fair value adjustments for Hellenic Bank group liabilities (increase) of
 
ca. € 33 million (note 23.2).
As
 
at
 
31
 
December
 
2024,
 
other
 
liabilities
 
amounting
 
to
 
 
251
 
million
 
mainly
 
consist
 
of
 
payables
 
relating
 
with
 
(a)
 
suppliers
 
and
creditors, (b) contributions to insurance
 
organizations, and (c) duties and other taxes.
In the context
 
of its non-performing exposures
 
(NPE) securitizations (Pillar,
 
Cairo, Mexico), and
 
as is customary for
 
the seller in such
types
 
of transactions,
 
the Bank
 
has provided
 
representation
 
and warranties
 
(R&Ws)
 
to the
 
investors
 
in respect
 
of the
 
underlying
loans, covering various
 
areas such as legality,
 
ownership and good
 
title of the loans,
 
accuracy of collateral
 
data etc., time-barred
 
up
to three
 
years
 
from the
 
transactions’
 
date. Accordingly,
 
as at
 
31 December
 
2024, the
 
Bank has
 
recognized
 
a prov
 
ision of
 
ca. €
 
22
million for potential losses in expectation
 
of such R&Ws realization (31 December 2023: € 12 million).
 
Considering that
 
the substantiation
 
and crystallization
 
of potential
 
amounts
 
under dispute
 
and final
 
agreement
 
between
 
involved
parties require significant time, the Group continues
 
to assess their impact as more information becomes available.
As at 31 December 2024, other provisions amounting to €
 
154 million (2023: € 116 million) mainly include: (a) € 33 million for claims
in dispute and
 
outstanding litigations against
 
the Group (note 43), (b)
 
€ 32 million relating to
 
the sale of Bank’s
 
former subsidiaries,
(c)
 
 
22
 
million
 
for
 
R&Ws
 
provided
 
to
 
investors
 
in
 
the
 
context
 
of
 
the
 
NPE
 
securitization
 
transactions,
 
d)
 
 
15
 
million
 
for
 
other
operational
 
risk events
 
e) €
 
12 million
 
relating
 
to contribution
 
to restoration
 
initiatives
 
after natural
 
disasters,
 
and f)
 
€ 27
 
million
 
relating to the participation in the Greek state’
 
s school renovation program
 
(note 11).
The movement of the Group's other provisions,
 
is presented in the following tables:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Litigations and
 
claims in
dispute
Other
Total
€ million
€ million
€ million
Balance at 1 January
38
78
116
Arising from acquisition
8
5
13
Amounts charged during the year
3
59
62
Amounts used during the year
(13)
(12)
(25)
Amounts reversed during the year
 
(2)
(7)
(9)
Foreign exchange and other movements
 
(1)
(2)
(3)
Balance at 31 December
33
121
154
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Litigations and
 
claims in
dispute
Other
Total
€ million
€ million
€ million
Balance at 1 January
28
52
80
Amounts charged during the year
21
34
55
Amounts used during the year
(5)
(7)
(12)
Amounts reversed during the year
 
(1)
-
(1)
Foreign exchange and other movements
 
(1)
(0)
(1)
Discontinued operations
(4)
(1)
(5)
Balance at 31 December
38
78
116
36.
 
Insurance contract (assets)/liabilities and reinsurance contract assets
Following
 
Hellenic Bank
 
group
 
inclusion in
 
the Company’s
 
consolidated
 
financial statements
 
from
 
the third
 
quarter
 
of 2024
 
(note
23.2), the Group assumed liabilities from insurance contracts issued that are presented within other liabilities
 
(note 35), and acquired
assets from reinsurance contracts
 
that are presented with other assets (note
 
29).
 
The Group applies the three
 
measurement models under IFRS
 
17 Insurance contracts
 
for the measurement of
 
its insurance contract
liabilities and reinsurance
 
contract assets,
 
i.e. the variable
 
fee approach
 
("VFA”),
 
the premium allocation
 
approach (“PAA”)
 
and the
general measurement model (“GMM”),
 
depending on the characteristics of each relevant
 
group of contracts.
 
The breakdown of the
 
insurance contract (assets)/liabilities and reinsurance
 
contract assets per line
 
of business and
 
per measurement
method applied, is set out below.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Life
Non - Life
Net Insurance
contract
(assets)/liabilities⁽¹⁾
Reinsurance
contract assets
Insurance contract
liabilities
Reinsurance
contract assets
€ million
€ million
€ million
€ million
VFA
61
-
-
-
PAA
8
0
37
3
GMM
(1)
11
1
14
Total
68
12
38
17
(1)
It includes insurance contract assets of € 1 million.
The following table presents the
 
movement per line of
 
business for the period
 
1 July -
 
31 December 2024
 
of the net
 
insurance contract
(assets)/liabilities for remaining coverage
 
(“LRC”) and incurred claims (“LIC”) from insurance contracts issued.
 
 
 
doc1p253i0 doc1p253i1
 
 
Notes to the Consolidated Financial Statements
 
.
149
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Life
Non - Life
Liabilities for
remaining
coverage
Liabilities for
incurred
 
claims
Liabilities for
remaining
coverage
Liabilities
for incurred
 
claims
Total
€ million
€ million
€ million
€ million
€ million
Net insurance contract (assets)/liabilities
 
as at 1 July
62
12
6
25
104
Insurance revenue
 
(11)
-
(22)
-
(34)
Incurred claims and other
 
insurance service expenses
0
5
3
17
25
Insurance service result
 
(11)
5
(19)
17
(9)
Insurance finance expenses
(2)
3
0
1
2
Total changes in the income statement
 
(13)
8
(19)
18
(7)
Premiums received
 
11
-
22
-
33
Claims and other insurance
 
service expenses paid
 
(3)
(8)
(3)
(10)
(24)
Total cash flows
 
8
(8)
19
(10)
9
Net insurance contract (assets)/liabilities
 
as at 31 December
 
57
11
5
33
106
As at 31 December 2024, the net insurance contract (assets)/liabilities under the PAA
 
measurement model amounted to € 46 million
(1 July 2024 €
 
46 million), comprising
 
a) a LIC of
 
€ 41 million (1 July
 
2024 € 33 million)
 
including € 38 million
 
in relation to
 
estimates
of the
 
present
 
value of
 
the future
 
cash flows
 
and €
 
2 million
 
in relation
 
to risk
 
adjustment for
 
non-financial risk
 
(1 July
 
2024 €
 
31
million and € 2 million respectively) and b) a LRC of € 5 million (1 July 2024 € 13 million).
The following table presents the movement for
 
the period 1 July - 31 December 2024 of net insurance contract (assets)/liabilities
 
for
life business under the VFA
 
and GMM measurement models by measurement component.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
Notes to the Consolidated Financial Statements
 
.
150
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Life
Estimates of PV of
future
 
cash flows
Risk
 
adjustment
Contractual
service
 
margin
Total
€ million
€ million
€ million
€ million
Net insurance contract (assets) /
liabilities as at 1 July
 
41
2
15
58
Contractual service margin (CSM)
recognised for services provided
-
-
(1)
(1)
Risk, experience and other adjustments
1
(0)
-
1
Changes that relate to current services
 
1
(0)
(1)
(0)
Contracts initially recognised in the period
(2)
0
2
0
Changes in estimates reflected in the CSM
(3)
0
3
(0)
Changes in estimates that do not adjust
the CSM
(0)
(0)
-
(0)
Changes that relate to future services
 
(5)
0
5
0
Adjustments to liabilities for
 
incurred claims
 
(2)
(0)
-
(2)
Insurance service result
 
(6)
0
3
(2)
Insurance finance expenses
 
0
0
1
1
Total changes in the income statement
 
(6)
0
4
(1)
Total cash flows
3
-
-
3
Net insurance contract (assets)/liabilities
as at 31 December
39
2
19
60
An analysis of insurance contracts issued that
 
are liabilities based on their contractual maturity is provided
 
in note 5.2.3
37.
 
Standard legal staff retirement indemnity obligations (SLSRI) and termination benefits
The Group provides for staff retirement indemnity obligation for its employees in Greece and abroad, who are entitled to a lump sum
payment
 
based on
 
the number
 
of years
 
of service
 
and the
 
level of
 
remuneration
 
at the
 
date
 
of retirement,
 
if they
 
remain in
 
the
employment of the Group until
 
normal retirement age, in accordance with the
 
local labor legislation. The
 
above retirement indemnity
obligations typically expose the Group to actuarial risks such as interest rate risk and salary risk. Therefore, a decrease in the discount
rate used to calculate
 
the present value of
 
the estimated future cash
 
outflows or an increase in
 
future salaries will increase the
 
staff
retirement indemnity obligations of
 
the Group.
In addition, the Group has
 
provided employee termination benefits mainly in respect of
 
the Voluntary Exit Schemes (VES), which have
been implemented through either
 
lump-sum payments or long-term
 
leaves during which the
 
employees will be
 
receiving a percentage
of a monthly salary, or a combination
 
thereof.
The table below presents the breakdown
 
of defined benefit obligations.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December
2024
31 December
2023
€ million
€ million
SLSRI obligation
21
22
Employee termination benefits
122
37
Total
 
143
59
The table
 
below presents
 
a reconciliation
 
from
 
the opening
 
to
 
the
 
closing balance
 
for
 
staff
 
retirement
 
indemnity
 
obligations
 
and
employee termination benefits.
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
151
|
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31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Balance at 1 January
59
80
Arising from acquisition
-
1
Current service cost
3
3
Interest cost
2
2
Past service cost and (gains)/losses on settlements
132
6
Remeasurements:
Actuarial (gains)/losses arising from changes in financial assumptions
1
(1)
Actuarial (gains)/losses arising from changes in demographic assumptions
(0)
(0)
Actuarial (gains)/losses arising from experience and other adjustments
 
2
3
Benefits paid
 
(56)
(34)
Discontinued operations
-
(1)
Balance at 31 December
143
59
For SLSRI obligations the significant actuarial assumptions
 
(expressed as weighted averages)
 
were as follows:
 
 
 
 
2024
%
2023
%
Discount rate
3.0
3.6
Future salary increases
3.3
3.2
 
As at
 
31 December
 
2024, the
 
assumption for
 
the price
 
inflation
 
(weighted
 
average)
 
is 2.0%
 
(2023: 2.3%)
 
and has
 
been taken
 
into
account in determining the above actuarial assumptions for
 
future salaries increases.
As at 31 December 2024,
 
the average duration of the standard legal staff retirement indemnity obligation was 7 years (2023: 7 years).
A quantitative
 
sensitivity analysis
 
based on
 
reasonable
 
changes to
 
significant actuarial
 
assumptions as
 
at 31
 
December 2024
 
is as
follows:
An increase/(decrease) of the discount
 
rate assumed, by 50 bps/(50 bps),
 
would result in a (decrease)/increase of the
 
standard legal
staff retirement obligations
 
by (€ 0.8 million)/ € 0.8 million.
An increase/(decrease) of
 
the future salary
 
growth assumed, by
 
0.5%/(0.5%) would result
 
in an increase/(decrease)
 
of the standard
legal staff retirement
 
obligations by € 0.8 million/(€ 0.8 million).
The above sensitivity analysis is based on a change in an assumption while
 
holding all other assumptions constant. In practice,
 
this is
unlikely to occur,
 
and changes in some of the assumptions may be correlated.
The
 
methods
 
and
 
assumptions
 
used
 
in
 
preparing
 
the
 
above
 
sensitivity
 
analysis
 
were
 
consistent
 
with
 
those
 
used
 
to
 
estimate
 
the
retirement benefit obligation
 
and did not change compared to the previous year.
For
 
employee
 
termination
 
benefits,
 
the
 
discount
 
rate
 
(weighted
 
average)
 
is
 
the
 
significant
 
actuarial
 
assumption,
 
which
 
as
 
at
 
31
December 2024 stood at 2.5% (2023: 3.8%) based on the applicable tenor of the liabilities. On the same date, an increase/(decrease)
of the discount
 
rate assumed,
 
by 50 bps/(50
 
bps), would result
 
in a (decrease)/increase
 
of employee termination
 
benefits by (€
 
1.2
million)/ € 1.2 million.
Post balance sheet event
On 17 February
 
2025, Hellenic Bank
 
Public Company Limited
 
announced the launch
 
of a Voluntary
 
Exit Scheme (VES),
 
which will be
offered to employees of the bank
 
and its insurance subsidiaries.
38.
 
Share capital, share premium and treasury shares
As
 
at
 
31 December
 
2024, the
 
par value
 
of the
 
Company's
 
shares is
 
€ 0.22
 
per
 
share
 
(2023: €
 
0.22). All
 
shares
 
are
 
fully paid.
 
The
movement of share capital and share
 
premium is as follows:
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
152
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Share capital
Share
premium
€ million
€ million
Balance at 1 January 2023
816.3
1,161.3
Share capital increase following the exercise of share options
1.3
0.1
Balance at 31 December 2023
817.6
1,161.4
Balance at 1 January 2024
817.6
1,161.4
Cancellation of treasury shares
(11.5)
(16.3)
Share capital increase following the exercise of share options
2.7
0.1
Balance at 31 December 2024
808.9
1,145.2
AGM decisions
On 23 July 2024, the Annual General Meeting (AGM) of the shareholders
 
of the Company, among others,
 
approved:
The cancellation
 
of 52,080,673
 
treasury shares
 
acquired in
 
2023 from
 
Hellenic Financial
 
Stability Fund.
 
Following the
 
said
cancellation, the share capital
 
and the share premium of the
 
Company decreased by € 11,457,748.06 and
 
€ 16,274,764.99,
respectively.
The distribution
 
of a
 
cash dividend
 
of €
 
342 million
 
from the
 
“Special Reserves”
 
account, following
 
the approval
 
received
from the European Central Bank (ECB) on 5 June 2024 (note 39). The said dividend corresponds to a 30% payout ratio of the
Group’s
 
net profit
 
for 2023
 
and a
 
gross dividend
 
of €
 
0.09333045 per
 
share, following
 
the above
 
cancellation of
 
treasury
shares.
The distribution
 
of € 404,330
 
to senior management
 
and employees of
 
the Company from
 
the “Special Reserves”
 
account
(note
 
39).
 
In
 
addition,
 
it
 
was
 
noted
 
in
 
AGM
 
that
 
the
 
respective
 
amount
 
that
 
was
 
approved
 
to
 
be
 
distributed
 
to
 
senior
management and employees of the Bank was € 26,237,474.
Share capital increase
Following the exercise of share options granted
 
to executives of the Group under the current share options’ plan (see below), and by
virtue
 
of
 
the decision
 
of
 
the
 
Board
 
of
 
Directors
 
of
 
the Company
 
on
 
30 August
 
2024, the
 
Company’s
 
share
 
capital
 
increased
 
by
 
2,714,189.50 through the issue of 12,337,225 new common voting shares of a nominal value of € 0.22 per
 
share and exercise price of
€ 0.23 per share.
 
The difference between
 
the exercise price
 
of the new
 
shares and their nominal
 
value, net of the
 
expenses directly
attributable to the equity transaction, amounted to € 100,899.18 and was recorded in the account “Share premium”. The new shares
were listed on the Athens Exchange
 
on 12 September 2024.
The following is an analysis of the movement in the number of the
 
Company’s shares outstanding:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Number of shares
Issued
 
Shares
Treasury
 
Shares
Net
Balance at 1 January 2023
3,710,677,508
(260,036)
3,710,417,472
Share capital increase following the exercise of share options
5,802,269
-
5,802,269
Buyback of shares held by HFSF
-
(52,080,673)
(52,080,673)
Other purchases of treasury shares
-
(5,740,696)
(5,740,696)
Sale of treasury shares
-
1,654,166
1,654,166
Balance at 31 December 2023
3,716,479,777
(56,427,239)
3,660,052,538
Balance at 1 January 2024
3,716,479,777
(56,427,239)
3,660,052,538
Share capital increase following the exercise of share options
12,337,225
-
12,337,225
Cancellation of treasury shares
(52,080,673)
52,080,673
-
Purchase of treasury shares
-
(1,475,008)
(1,475,008)
Sale of treasury shares
-
3,907,033
3,907,033
Balance at 31 December 2024
3,676,736,329
(1,914,541)
3,674,821,788
 
Treasury shares
 
Notes to the Consolidated Financial Statements
 
.
153
|
Page
 
31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
As at 31 December 2024, the number of treasury shares held
 
by the Company’s subsidiary Eurobank
 
Equities Investment Firm Single
Member S.A. (in the ordinary course of its business), was 1,914,541 and its carrying amount (debit balance within reserves) was € 3.9
million (31 December 2023: € 101 million, including € 93.8 million referring to the aforementioned treasury shares acquired from the
HFSF). On the same
 
date, the number of
 
the Company’s shares held by
 
the Group’s associates in the ordinary
 
course of their insurance
and investing activities was 64,163,790 in total
 
(31 December 2023: 64,163,790).
39.
 
Reserves and retained earnings/losses
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Statutory
reserves
Non-taxed
reserves
Fair value reserve
Other
 
reserves
Retained
earnings/(losses)
Total
€ million
€ million
€ million
€ million
€ million
€ million
Balance at 1 January 2023
270
829
(10)
2,077
1,495
4,660
Net profit
 
-
-
-
-
1,140
1,140
Transfers between reserves
 
(42)
(0)
(45)
64
24
-
Debt securities at FVOCI
-
-
83
-
-
83
Cash flow hedges
-
-
-
(2)
-
(2)
Foreign currency translation (note 30)
-
-
-
123
-
123
Gains/(losses) from equity securities at FVOCI
-
-
18
-
-
18
Associates and joint ventures
-Adoption of IFRS 9 “Financial Instruments” by a
Group’s associate
-
-
(7)
-
7
-
-changes in the share of other comprehensive
income, net of tax
-
-
9
(12)
0
(4)
Actuarial gains/(losses) on post employment
benefit obligations, net of tax
-
-
-
-
(2)
(2)
Share options plan
-
-
-
-
7
7
Purchase/sale of treasury shares
 
-
-
-
(100)
-
(100)
Other
(1)
-
(0)
(1)
(1)
(3)
Balance at 31 December 2023
227
829
48
2,147
2,670
5,920
Balance at 1 January 2024
227
829
48
2,147
2,670
5,920
Net profit
 
-
-
-
-
1,448
1,448
Arising from acquisition (note 23.2)
260
-
-
-
(260)
-
Transfers between reserves
 
44
1
(1)
383
(428)
-
Debt securities at FVOCI
-
-
22
-
-
22
Cash flow hedges
-
-
-
(1)
-
(1)
Foreign currency translation
-
-
-
-
0
0
Gains/(losses) from equity securities at FVOCI
-
-
(8)
-
-
(8)
Associates and joint ventures
-changes in the share of other comprehensive
income, net of tax
-
-
(5)
(3)
(0)
(8)
Actuarial gains/(losses) on post employment
benefit obligations, net of tax
-
-
-
(2)
(2)
Dividends (see below)
-
-
-
(342)
-
(342)
Changes in participating interest/consolidation
percentage in subsidiaries (note 23.2)
-
-
-
-
(134)
(134)
Share options plan (note 40)
-
-
-
-
18
18
Purchase/sale and cancellation of treasury shares
(note 38)
-
-
-
97
(64)
33
Other
-
-
-
-
(1)
(1)
Balance at 31 December 2024
532
830
57
2,281
3,246
6,945
 
As at 31 December 2024, other reserves comprise, among others, a) € 1,752 million reserves relating to dividends and gains from the
sale of participations
 
(2023: € 1,713
 
million), b) corporate law reserves
 
of
 
€ 8 million,
 
pursuant to the provisions
 
of the Greek
 
company
law
 
in
 
force
 
(2023:
 
 
8 million),
 
c) €
 
4 million
 
(debit
 
balance)
 
relating
 
to
 
the
 
carrying
 
amount
 
of
 
the
 
treasury
 
shares
 
held by
 
the
Company and
 
its subsidiary
 
Eurobank Equities
 
Investment
 
Firm Single
 
Member S.A.
 
(2023: €
 
101 million)
 
(note 38),
 
d) €
 
15 million
 
 
 
Notes to the Consolidated Financial Statements
 
.
154
|
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31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
accumulated loss from cash flow hedging (2023: € 14 million accumulated loss) and e)
 
€ 3 million accumulated loss relating to foreign
operations’ translation differences
 
(2023: € 2 million accumulated loss).
Dividends/Shareholders’ remuneration
In the
 
third quarter
 
of 2024,
 
pursuant
 
to the
 
abovementioned
 
decisions of
 
the AGM
 
of the
 
shareholders
 
of the
 
Company,
 
a cash
dividend of € 342 million was distributed to the shareholders, corresponding to a 30% payout
 
ratio of the Group’s net profit
 
for 2023
and a gross dividend of € 0.09333045 per share.
In December 2024, the Bank proceeded with the distribution of non-mandatory
 
reserves for a total amount of € 240 million which
 
is
part of
 
the Banks’
 
overall
 
contribution to
 
its sole
 
shareholder,
 
Eurobank
 
Holdings, in
 
order
 
to enable
 
the latter
 
to remunerate
 
its
shareholders
 
out of
 
the profits
 
of the
 
financial year
 
2024, in
 
accordance with
 
the provisions
 
of article
 
162 par.
 
3 of
 
Company
 
Law
4548/2018.
Based on the
 
Group’s
 
financial performance
 
for the
 
financial year 2024,
 
Eurobank Holdings
 
intends to
 
remunerate
 
its shareholders
with an amount of € 674 million corresponding
 
to a 50% payout ratio of the
 
Group’s net profit
 
for 2024 less the negative goodwill
 
(€
99.5
 
million
 
gain
 
on
 
acquisition
 
of
 
a
 
shareholding
 
in
 
Hellenic
 
Bank),
 
subject
 
to
 
approval
 
of
 
the
 
Annual
 
General
 
Meeting
 
of
 
its
shareholders and the regulatory authorities. The final
 
remuneration will be a combination of cash and
 
share buyback.
40.
 
Share options
The Annual
 
General Meeting
 
of the
 
shareholders
 
of Eurobank
 
Holdings held
 
on 28
 
July 2020
 
approved
 
the establishment
 
of a
 
five
year shares
 
award
 
plan, starting
 
from 2021,
 
in the
 
form
 
of share
 
options rights
 
by issuing
 
new shares
 
with a
 
corresponding share
capital increase, in accordance with the provisions of article
 
113 of law 4548/2018, awarded to executives and personnel of Eurobank
Holdings and its affiliated companies according to article 32 of law 4308/2014. The maximum number
 
of rights that can be approved
was
 
set at
 
55,637,000
 
rights,
 
each of
 
which would
 
correspond
 
to
 
one new
 
share
 
with
 
exercise
 
price equal
 
to
 
€ 0.23.
 
The Annual
General
 
Meeting authorized
 
the Board
 
of Directors
 
of Eurobank
 
Holdings to
 
define the
 
eligible staff
 
and determine
 
the remaining
terms and conditions of the plan.
The
 
final
 
terms
 
and the
 
implementation
 
of
 
the
 
share
 
options
 
plan,
 
which
 
is
 
a
 
forward-looking
 
long-term
 
incentive
 
aiming
 
at
 
the
retention of key executives,
 
are defined and approved annually by the Board of Directors
 
in accordance with the applicable legal and
regulatory framework, as well as the policies of the
 
Group.
The options are exercisable in portions annually
 
during a period
 
from one to five years.
 
Each portion may be exercised wholly or
 
partly
and
 
converted
 
into
 
shares
 
at
 
the
 
employees’
 
option,
 
provided
 
that
 
they
 
remain
 
employed
 
by
 
the
 
Group
 
until
 
the
 
first
 
available
exercise
 
date.
 
Each
 
portion
 
is treated
 
as a
 
separate
 
award
 
with
 
a different
 
vesting
 
period
 
and different
 
fair
 
value.
 
The
 
corporate
actions that adjust the number and the price of shares also adjust
 
accordingly the share options.
The movement of share options during the year
 
is analysed as follows:
 
 
 
Share options granted
2024
2023
Balance at 1 January
26,863,702
22,268,322
Options awarded during the year
6,822,123
12,101,092
Options cancelled/expired during the year
-
(1,703,443)
Options exercised during the year
(12,337,225)
(5,802,269)
Balance at 31 December
 
21,348,600
26,863,702
In July
 
2024, the
 
Group
 
awarded to
 
its executives
 
6,822,123 new
 
share options,
 
exercisable
 
in annual
 
portions up
 
to 2029,
 
out of
which 3,076,786 options were exercised
 
during the third quarter of 2024.
 
From the total number of granted share options exercisable
 
in 2024, 12,337,225 options were exercised during the year , resulting in
the issue of an equal number of new common voting shares.
The share options outstanding at the end of the year totaled
 
to 21,348,600 (31 December 2023: 26, 863,702) and have the following
expiry dates:
 
 
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Notes to the Consolidated Financial Statements
 
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Share options
Expiry date ⁽¹⁾
31 December 2024
2025
6,194,066
2026
5,763,315
2027
5,763,177
2028
3,149,366
2029
478,676
Weighted average remaining contractual
 
life of share
options outstanding at the end of the period
23 months
(1)
 
Based on the earliest contractual exercise date.
In accordance
 
with the
 
Group’s
 
accounting policy
 
on employees’
 
share based
 
payments, the
 
grant date
 
fair value
 
of the
 
options is
recognized as an expense with a corresponding
 
increase in equity over the vesting period.
The fair
 
value at
 
grant date
 
is determined
 
using an
 
adjusted form
 
of the
 
Black-Scholes
 
model for
 
Bermudan equity
 
options which
takes
 
into account
 
the exercise
 
price, the
 
exercise
 
dates, the
 
term of
 
the option,
 
the share
 
price at
 
grant
 
date and
 
expected price
volatility of the underlying share, the expected dividend
 
yield and the risk-free interest
 
rate for the term of the options.
 
The weighted
 
average fair
 
value of the
 
share options
 
granted in
 
July 2024 was
 
€ 1.66 (2023:
 
€ 1.13). The
 
significant inputs
 
into the
model were a share price of € 2.021 (2023: € 1.442) at the grant date, exercise price of € 0.23, annualized dividend yield of 3% (2023:
3%), expected average
 
volatility of 32% (2023:
 
41%), expected option
 
life of 1-5 years,
 
and a risk-free
 
interest rate
 
corresponding to
the options’ maturities, based on the Euro swap yield curve. The expected
 
volatility is measured at the grant date
 
of the options and
is based on the average historical volatility
 
of the share price.
 
41.
 
Transfers
 
of financial assets
The Group
 
enters
 
into transactions
 
by which
 
it transfers
 
recognized
 
financial assets
 
directly to
 
third
 
parties or
 
to Special
 
Purpose
Entities (SPEs).
(a) The Group sells, in exchange
 
for cash, securities under an agreement
 
to repurchase them (repos)
 
and assumes a liability to repay
to the counterparty the cash received.
 
In addition, the Group pledges,
 
in exchange for cash, securities, covered bonds, as well
 
as loans
and receivables and assumes a liability to
 
repay to the counterparty
 
the cash received. The Group
 
may also transfer securities under
securities lending agreements with no exchange of cash or pledging of other financial assets as collateral.
 
For all the aforementioned
transactions, the
 
Group has
 
determined that
 
it retains
 
substantially all
 
the risks,
 
including associated
 
credit and
 
interest rate
 
risks,
and rewards of these financial assets and therefore has not derecognized them. As a result, the Group
 
is unable to use, sell or pledge
the transferred assets for the duration of the transaction. The related liability, where applicable, is recognized in Due to central banks
and credit institutions (notes 31 and 32), Due to customers
 
(note 33) and Debt securities in issue (note 34), as appropriate.
The Group
 
enters
 
into
 
securitizations
 
of various
 
classes of
 
loans
 
(corporate,
 
small and
 
medium enterprise,
 
consumer
 
and various
classes of non-performing loans), under which it assumes an obligation to pass on the cash flows from the loans to the holders of the
notes. The Group has determined that it retains substantially
 
all risks, including associated credit and interest rate risks,
 
and rewards
of these
 
loans and
 
therefore
 
has not
 
derecognized
 
them. As
 
a result
 
of the
 
above transactions,
 
the Group
 
is unable
 
to use,
 
sell or
pledge the
 
transferred
 
assets for
 
the duration
 
of their retention
 
by the
 
SPE. Moreover,
 
the note
 
holders' recourse
 
is limited
 
to the
transferred
 
loans. As at 31
 
December 2024, the carrying
 
value of the
 
securitizations’ issues held
 
by third parties
 
amounted to €
 
554
million (2023: € 555 million) (note 34).
 
 
 
Notes to the Consolidated Financial Statements
 
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The table below sets
 
out the details of
 
Group's financial assets that
 
have been sold or
 
otherwise transferred to third parties, but
 
which
do not qualify for derecognition:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Carrying amount⁽¹⁾
2024
2023
€ million
€ million
Securities held for trading
-
11
Loans and advances to customers
2,801
9,947
-securitized loans
727
767
-pledged loans under covered bond program
1,794
3,832
-pledged loans with central banks
-
5,017
-other pledged loans
 
280
332
Investment securities
 
1,200
2,231
Carrying amount of assets
 
4,001
12,189
Associated liabilities⁽²⁾
2,954
7,969
(1)
 
The amounts presented above
 
do not include securitised loans
 
and assets pledged under cover
 
bond program or with
 
central banks, which
 
have not been
utilised for secured financing; comparative information has been adjusted accordingly.
(2)
Amounts are before offsetting repo agreements in the balance sheet against reverse repo deals of € 447 million (2023: € 1,210 million)
 
(note 5.2.1.4)
(b) The Group
 
may sell or
 
re-pledge any
 
securities borrowed
 
or obtained through
 
reverse repos
 
and has an
 
obligation to
 
return the
securities.
 
The
 
counterparty
 
retains
 
substantially
 
all
 
the
 
risks
 
and
 
rewards
 
of
 
ownership
 
and
 
therefore
 
the
 
securities
 
are
 
not
recognized by the Group.
 
As at 31 December 2024, the securities obtained through
 
reverse repo by the Group
 
of face value of € 583
million had not been sold or re-pledged (2023: € 1,413 million face value obtained
 
through reverse repo not sold or re
 
-pledged).
The
 
Group’s
 
financial
 
assets
 
pledged
 
as
 
collaterals
 
for
 
repos,
 
derivatives,
 
securitizations
 
and
 
other
 
transactions
 
other
 
than
 
the
financial assets presented in the table above are
 
provided in notes 17 and 29.
 
 
 
 
42.
 
Leases
Group as a lessee
The Group leases office and branch premises, ATM
 
locations, residential properties for the Group’s
 
personnel, and motor vehicles.
The majority of the Group’s property leases are under long term agreements (for a term of 12
 
years or more in the case of leased real
estate
 
assets),
 
with
 
options
 
to
 
extend
 
or
 
terminate
 
the
 
lease
 
according
 
to
 
the
 
terms
 
of
 
each
 
contract
 
and
 
the
 
usual
 
terms
 
and
conditions
 
of commercial
 
leases
 
applicable
 
in each
 
jurisdiction,
 
while motor
 
vehicles generally
 
have
 
lease terms
 
of up
 
to
 
4 years.
Extension options held by the Group are included in the lease term when it is reasonably certain that they will be exercised
 
based on
its assessment. For contracts having an indefinite remaining life, the lease term has been determined at an average
 
of 7 years for the
Bank,
 
after
 
considering
 
all relevant
 
facts
 
and circumstances.
 
For
 
new
 
or
 
modified
 
lease contracts
 
with
 
an
 
indefinite
 
life,
 
that
 
are
effective from the fourth quarter
 
of 2023
 
onwards, the estimated lease
 
term has been
 
revised to 5
 
years. Where applicable, depending
on the terms of each lease contract, lease payments are
 
adjusted annually in line with the consumer Price Index, as published by the
Greek Statistical Authority,
 
plus an agreed fixed percentage.
Information about the leases for which the Group
 
is a lessee is presented below:
Right-of-Use Assets
As at 31 December 2024, the right-of-use assets included
 
in property plant and equipment amounted to
 
€ 168 million (31 December
2023: € 170 million) (note
 
26), while those that
 
meet the definition of
 
investment property
 
amounted to € 17
 
million (31 December
2023: € 16 million) (note 27).
Lease Liabilities
The
 
lease liability
 
included under
 
other
 
liabilities
 
amounted
 
to
 
€ 190
 
million
 
as at
 
31 December
 
2024 (31
 
December 2023:
 
 
190
million) (note 35). The
 
maturity analysis of lease
 
liabilities as at 31
 
December 2024, based on
 
the contractual undiscounted cash flows,
is presented in note 5.2.3.
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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Amounts recognised in profit or loss
Interest on lease liabilities is presented in note 6 and the lease expense relating to short term leases is ca. € 1.2 million (31 December
2023: € 1.2 million).
The Group had total cash outflows for
 
leases of € 41 million in 2024 (2023: € 44 million).
 
 
Group as a lessor
Finance lease
The Group leases out certain real estate
 
properties and equipment under finance leases, in its capacity as a lessor.
The maturity analysis of finance lease
 
receivables, based on the undiscounted lease payments to be
 
received after the reporting date,
is provided below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Not later than one year
205
230
1-2 years
88
89
2-3 years
74
95
3-4 years
64
53
4-5 years
36
34
Later than 5 years
116
154
Lease Payments:
583
656
Gross investment in finance leases
583
656
Less: unearned finance income
(60)
(83)
Net investment in finance leases
523
573
Less: impairment allowance
(80)
(93)
Total
443
480
 
Operating Leases
The
 
Group
 
leases
 
out
 
its
 
investment
 
property
 
under
 
the
 
usual
 
terms
 
and
 
conditions
 
of
 
commercial
 
leases
 
applicable
 
in
 
each
jurisdiction.
 
When such
 
leases do
 
not transfer
 
substantially
 
all of
 
the risks
 
and rewards
 
incidental
 
to the
 
ownership
 
of the
 
leased
assets, the Group classifies these lease as
 
operating leases. Information relating to operating leases of investment property,
 
including
the rental income
 
recognised by the
 
Group during the
 
year, is provided in note
 
27. The
 
maturity analysis of
 
operating lease receivables,
based on the undiscounted lease payments to be received
 
after the reporting date, is provided below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Not later than one year
85
94
One to two years
75
83
Two to three years
67
76
Three to four years
61
68
Four to five years
47
64
More than five years
153
209
Total
488
594
 
43.
 
Contingent liabilities and other commitments
The Group
 
presents
 
the credit
 
related
 
commitments
 
it has
 
undertaken
 
within the
 
context
 
of its
 
lending related
 
activities into
 
the
following
 
three categories:
 
a) financial
 
guarantee
 
contracts,
 
which refer
 
to guarantees
 
and standby
 
letters
 
of credit
 
that carry
 
the
same credit risk
 
as loans (credit
 
substitutes), b) commitments to extend
 
credit, which comprise firm
 
commitments that are irrevocable
over the life of the facility or revocable
 
only in response to a material adverse effect
 
and c) other credit related commitments, which
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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refer
 
to
 
documentary
 
and
 
commercial
 
letters
 
and
 
other
 
guarantees
 
of
 
medium
 
and
 
low
 
risk
 
according
 
to
 
the
 
Regulation
 
No
575/2013/EU.
Credit related commitments are analyzed
 
as follows:
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Financial guarantee contracts
2,221
2,082
Commitments to extend credit
 
5,783
4,521
Other credit related commitments
 
1,298
1,268
Total
9,302
7,871
The credit related commitments within the scope of IFRS 9 impairment requirements of continuing operations amount to € 14 billion
(31 December 2023:
 
€ 11.4 billion),
 
including revocable
 
loan commitments
 
of €
 
4.7 billion
 
(31 December 2023:
 
€ 3.5 billion),
 
while
the corresponding allowance for impairment
 
losses amounts to € 63 million (31 December 2023: € 48 million).
In addition, the Group has issued a sovereign risk financial guarantee of € 0.24 billion (31 December 2023: € 0.24 billion) for which an
equivalent amount has been deposited under the relevant
 
pledge agreement (note 29).
Other commitments
(a) The
 
Bank has signed
 
irrevocable payment
 
commitment (IPC)
 
and collateral
 
arrangement agreements
 
with the
 
Single Resolution
Board (SRB) amounting in total
 
to € 29 million as at
 
31 December 2024 (2023: € 29 million). According
 
to the agreements, which are
backed by cash collateral
 
of an equal amount, the Bank undertook to
 
pay to the SRB an amount up to
 
the above IPC, in case of a call
and demand for payment made by it, in relation to a resolution action taken for another European bank. The IPC has been accounted
for as
 
a contingent
 
liability and the
 
said cash
 
collateral
 
has been
 
recognized as
 
a financial
 
asset measured
 
at amortized
 
cost in
 
the
Group’s balance sheet line “Other
 
assets’’(note 29).
By a ruling in October 2023, the General Court
 
of the European Union dismissed the appeal of a French
 
Credit institution against the
Single
 
Resolution
 
Board
 
(SRB)
 
following
 
the
 
rejection,
 
by
 
the
 
latter,
 
of
 
the
 
request
 
for
 
return
 
of
 
collateral
 
linked
 
to
 
ex-ante
contributions provided
 
in the
 
form of
 
IPC. The reimbursement
 
of the collateral
 
linked to
 
the IPC,
 
requested by
 
the institution
 
after
the withdrawal of its license, had been refused by the SRB, arguing that the return of IPC collateral required the prior payment of the
compulsory contribution for which the institution
 
was liable.
The aforementioned decision is not final, as the institution concerned decided to appeal to the European
 
Court of Justice against the
ruling of the General Court
 
of the European Union, therefore the
 
Group has not proceeded to any
 
change in the accounting treatment
described above for the purposes of these financial statements.
 
The Group will continue to monitor any
 
developments in the case and assess the potential impact on its financial statements.
(b) As at 31
 
December 2024, the contractual commitments for the acquisition
 
of own used property, investment property, equipment
and intangible assets amounted to € 51 million (2023: € 41 million).
Legal proceedings
As at 31 December 2024, the
 
provisions for legal
 
proceedings outstanding against
 
the Group amounted to
 
€ 33 million (note 35) (31
December 2023: € 38 million).
Furthermore, in the normal course of its business, the Group has been involved in a number of legal proceedings, which are either at
still a premature
 
or at an advanced trial
 
instance. The final settlement
 
of these cases may
 
require the lapse of
 
a certain time so that
the litigants exhaust the legal remedies provided for by the
 
law. Management, is closely monitoring the developments to the relevant
cases and having
 
considered the
 
advice of Legal
 
Services, does not
 
expect that
 
there will
 
be an outflow
 
of resources
 
and therefore
does not acknowledge the need for a provision.
In addition,
 
following
 
Hellenic Bank
 
group inclusion
 
in the
 
Company’s
 
consolidated
 
financial statements
 
from the
 
third quarter
 
of
2024 (note 23.2),
 
the Group is
 
assessing the legal
 
proceedings against
 
Hellenic Bank group
 
and has recognized
 
contingent liabilities
at a provisional fair
 
value of € 4 million on the
 
acquisition date under the purchase
 
method of accounting in accordance
 
with IFRS 3,
Business Combinations.
 
 
 
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44.
 
Operating segment information
Management has
 
determined the operating
 
segments based on
 
the internal reports
 
reviewed by
 
the Strategic
 
Planning Committee
that
 
are
 
used
 
to
 
allocate
 
resources
 
and
 
to
 
assess
 
their
 
performance
 
in
 
order
 
to
 
make
 
strategic
 
decisions.
 
The
 
Strategic
 
Planning
Committee considers the business both from a business unit and geographic perspective. Geographically, management considers the
performance of its business activities originated from Greece and
 
other countries in Europe (International).
Greece
 
is
 
further
 
segregated
 
into
 
retail,
 
corporate,
 
global
 
markets
 
& asset
 
management,
 
investment
 
property
 
and Remedial
 
and
Servicing Strategy.
 
International is
 
monitored and
 
reviewed on
 
a country
 
basis. The
 
Group aggregates
 
segments when
 
they exhibit
similar economic characteristics and profile
 
and are expected to have similar long-term
 
economic development.
In more detail, the Group is organized
 
in the following reportable segments:
-
Retail: incorporating customer
 
current accounts, savings, deposits and
 
investment savings products,
 
credit and debit cards,
consumer loans, small business banking and mortgages.
-
Corporate:
 
incorporating
 
current
 
accounts,
 
deposits,
 
overdrafts,
 
loan
 
and
 
other
 
credit
 
facilities,
 
foreign
 
currency
 
and
derivative
 
products
 
to
 
corporate
 
entities,
 
custody
 
and
 
clearing
 
services,
 
cash
 
management
 
and
 
trade
 
services
 
and
investment banking services including corporate
 
finance, merger and acquisitions advice.
-
Global Markets & Asset Management: incorporating financial instruments trading, services to institutional investors, as well
as, specialized financial
 
advice and intermediation. In
 
addition, this segment
 
incorporates mutual fund products, institutional
asset management and equity brokerage.
-
International: incorporating operations
 
in a) Bulgaria, b) Cyprus, containing the operations of Eurobank Cyprus and those of
Hellenic Bank group,
 
which is included
 
in the Company’s
 
consolidated financial
 
statements as
 
of the third
 
quarter of
 
2024
(note
 
23.2),
 
c) Luxembourg
 
and d)
 
Romania
 
and Serbia,
 
which as
 
of
 
the
 
third
 
quarter
 
of
 
2024 are
 
presented
 
in
 
“Other”
segment of the International operations.
-
Investment
 
Property:
 
incorporating
 
investment
 
property
 
activities
 
relating
 
to
 
a
 
diversified
 
portfolio
 
of
 
commercial
 
real
estate assets.
-
Remedial and Servicing
 
Strategy (RSS): incorporating the management of
 
non - performing assets,
 
the property management
(repossessed assets),
 
the notes
 
of the
 
securitizations of
 
loans originated
 
by the
 
Bank, which
 
were retained
 
by the
 
Group,
and the Group’s share
 
of results of doValue Greece Loans and Credits
 
Claim Management S.A.
Other
 
segment
 
of
 
the
 
Group
 
refers
 
mainly
 
to
 
(a)
 
property
 
management
 
(own
 
used
 
property
 
&
 
equipment),
 
(b)
 
other
 
investing
activities (including equities’ positions), (c) private
 
banking services to medium and high net
 
worth individuals, (d) the Group’s
 
share
of results of Eurolife Insurance group
 
and (e) the results related to the Group’s
 
transformation projects and initiatives.
The
 
Group's
 
management
 
reporting
 
is
 
based
 
on
 
International
 
Financial
 
Reporting
 
Standards
 
(IFRS)
 
as
 
adopted
 
by
 
the
 
EU.
 
The
accounting policies of the Group's operating segments
 
are the same with those described in the principal accounting policies.
Revenues from
 
transactions between business
 
segments are allocated
 
on a mutually agreed
 
basis at rates
 
that approximate
 
market
prices.
 
 
 
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44.1
 
Operating segments
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Retail
Corporate
Global Markets &
 
Asset Mngt
Investment
Property
RSS
International
Other and
Elimination
center
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Net interest income
1,170
405
32
 
(13)
 
(37)
1,023
 
(73)
2,507
Net banking fee and commission income
106
137
138
0
3
176
2
561
Other net revenue
 
(51)
19
76
108
 
(31)
61
91
272
Total external
 
revenue
1,225
560
245
95
 
(65)
1,261
20
3,341
Inter-segment revenue
59
49
 
(55)
2
 
(0)
 
(6)
 
(49)
-
Total revenue
1,283
610
190
97
 
(65)
1,255
 
(30)
3,341
Operating expenses
 
(391)
 
(131)
 
(63)
 
(33)
 
(60)
 
(416)
 
(6)
 
(1,098)
Impairment losses relating to loans
 
and advances to customers
 
(230)
 
(3)
-
-
34
 
(61)
 
(43)
 
(303)
Other impairments, risk provisions and related
 
costs
(note 12)
 
(4)
 
(0)
 
(11)
 
(1)
 
(9)
 
(18)
 
(16)
 
(59)
Share of results of associates and
 
joint ventures
-
-
 
(0)
-
10
133
18
161
Profit/(loss) before tax from
 
continuing operations
before restructuring costs
658
476
116
64
 
(90)
893
 
(76)
2,040
Restructuring costs (note 12)
 
(15)
 
(2)
 
(2)
 
(1)
 
(0)
 
(2)
 
(145)
 
(168)
Profit/(loss) before tax from
 
continuing operations
643
474
114
64
 
(91)
891
 
(222)
1,872
Loss before tax from discontinued
 
operations (note 30)
-
-
-
-
-
-
 
(10)
 
(10)
Profit/(loss) before tax attributable
 
to non controlling
interests
-
-
-
 
(0)
-
66
0
66
Profit/(loss) before tax attributable
 
to shareholders
643
474
114
64
 
(91)
825
 
(232)
1,796
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Retail
Corporate
Global Markets &
 
Asset Mngt
Investment
Property
RSS
International
Other and
Elimination
center⁽¹⁾
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Segment assets
11,921
18,825
14,617
1,474
7,734
42,318
4,260
101,150
Segment liabilities
32,270
12,215
4,391
221
1,288
37,874
3,992
92,251
 
 
 
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Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
The International segment is further analyzed
 
as follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Cyprus⁽³⁾
Bulgaria
Eurobank Cyprus
Hellenic Bank
Luxembourg
Other
Total
International
€ million
€ million
€ million
€ million
€ million
€ million
Net interest income
 
394
 
273
 
295
 
58
 
4
 
1,023
Net banking fee and commission income
 
83
 
42
 
40
 
11
 
(1)
 
176
Other net revenue
 
9
 
4
 
48
 
1
 
(1)
 
61
Total external revenue
 
486
 
320
 
382
 
70
 
2
 
1,261
Inter-segment revenue
 
0
 
0
-
 
(6)
 
(0)
 
(6)
Total revenue
 
486
 
320
 
382
 
64
 
2
 
1,255
Operating expenses
 
(194)
 
(59)
 
(127)
 
(32)
 
(3)
 
(416)
Impairment losses relating to loans and
advances to customers
 
(49)
 
(7)
 
(9)
 
0
 
4
 
(61)
Other impairments, risk provisions and
related costs
 
(4)
 
(1)
 
(2)
 
(1)
 
(10)
 
(18)
Share of results of associates and joint
ventures
-
-
 
133
-
-
 
133
Profit/(loss) before tax from continuing
operations before restructuring costs
 
 
239
 
253
 
377
 
31
 
(8)
 
893
Restructuring costs (note 12)
-
-
 
(1)
 
(1)
-
 
(2)
Profit/(loss) before tax from continuing
operations
 
239
 
253
 
376
 
31
 
(8)
 
891
Loss before tax from discontinued operations
-
-
-
-
-
-
Profit/(loss) before tax attributable to non
controlling interests
 
0
-
 
66
-
-
 
66
Profit/(loss) before tax attributable to
shareholders
 
239
 
253
 
309
 
31
 
(8)
 
825
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
Cyprus⁽³⁾
Bulgaria
Eurobank Cyprus
Hellenic Bank
Luxembourg
Other
Total
International
€ million
€ million
€ million
€ million
€ million
€ million
Segment assets⁽²⁾
11,529
9,275
18,262
3,240
128
42,318
Segment liabilities⁽²⁾
10,193
8,074
16,501
3,005
215
37,874
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
Notes to the Consolidated Financial Statements
 
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31 December 2023
Retail
Corporate
Global Markets &
 
Asset Mngt
Investment
Property
RSS
International
Other and
Elimination
center
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Net interest income
1,118
437
59
(12)
(8)
657
(77)
2,174
Net banking fee and commission income
87
127
102
5
122
4
447
Other net revenue
(48)
3
108
103
15
(1)
113
293
Total external
 
revenue
1,157
567
269
91
12
778
40
2,914
Inter-segment revenue
41
39
(40)
2
(8)
(34)
-
Total revenue
1,198
606
229
93
12
770
6
2,914
Operating expenses
(379)
(118)
(55)
(35)
(62)
(263)
(3)
(915)
Impairment losses relating to loans and
 
advances to
customers
(126)
(31)
-
-
(159)
(57)
(39)
(412)
Other impairment losses,risk provisions and
 
related
costs (note 12)
(20)
(1)
3
(1)
(25)
(36)
(16)
(96)
Share of results of associates and
 
joint ventures
-
8
58
22
88
Profit/(loss) before tax from
 
continuing operations
before restructuring costs
673
456
177
57
(226)
472
(30)
1,579
Restructuring costs (note 12)
(4)
(4)
(1)
(1)
(11)
(16)
(37)
Profit/(loss) before tax from
 
continuing operations
669
452
176
57
(227)
461
(46)
1,542
Profit before tax from
 
discontinued operations
-
-
-
-
-
(170)
-
(170)
Profit/(loss) before tax attributable
 
to non controlling
interests
-
-
-
-
-
(12)
(12)
Profit/(loss) before tax attributable
 
to shareholders
669
452
176
57
(227)
303
(46)
1,384
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Retail
Corporate
Global Markets &
 
Asset Mngt
Investment
Property
RSS
International
Other and
Elimination
center⁽¹⁾
Total
€ million
€ million
€ million
€ million
€ million
€ million
€ million
€ million
Segment assets
12,344
15,897
14,627
1,453
8,259
21,336
5,865
79,781
Segment liabilities
31,264
11,558
4,942
280
1,767
18,740
3,331
71,882
 
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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31 December 2023
Bulgaria
Cyprus
Luxembourg
Romania
Serbia
Total
International
€ million
€ million
€ million
€ million
€ million
€ million
Net interest income
322
273
58
3
1
657
Net banking fee and commission income
76
39
8
(1)
-
122
Other net revenue
6
-
(2)
(1)
(4)
(1)
Total external revenue
404
312
64
1
(3)
778
Inter-segment revenue
-
-
(8)
-
-
(8)
Total revenue
404
312
56
1
(3)
770
Operating expenses
(169)
(59)
(28)
(5)
(2)
(263)
Impairment losses relating to loans and
advances to customers
(52)
(16)
-
11
-
(57)
Other impairments, risk provisions and
related costs
(31)
(1)
-
(4)
-
(36)
Share of results of associates and joint
ventures
-
58.00
-
-
-
58
Profit/(loss) before tax from continuing
operations before restructuring costs
152
294
28
3
(5)
472
Restructuring costs
(11)
-
-
-
-
(11)
Profit/(loss) before tax from continuing
operations
141
294
28
3
(5)
461
Profit before tax from discontinued
operations
 
-
-
-
-
(170)
(170)
Profit/(loss) before tax attributable to non
controlling interests
-
-
-
-
(12)
(12)
Profit/(loss) before tax attributable to
shareholders
141
294
28
3
(163)
303
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2023
Bulgaria
Cyprus
Luxembourg
Romania
Serbia
Total
international
€ million
€ million
€ million
€ million
€ million
€ million
Segment assets⁽²⁾
9,832
8,625
2,644
143
91
21,336
Segment liabilities⁽²⁾
8,714
7,300
2,426
214
86
18,740
(1)
 
Interbank and debt securities in issue eliminations between International and the other Group’s segments are included.
 
(2)
 
Intercompany balances among the Countries have been excluded from the reported assets and liabilities of International segment.
 
(3)
 
The Group’s
 
share of
 
results of
 
the Hellenic
 
Bank group
 
up to
 
30 June
 
2024, amounting
 
to €
 
133 million
 
gain is
 
included in
 
the corresponding
 
separate
segment of the Cyprus’
 
operations. In the comparative
 
period, the Group’s share of results
 
of the Hellenic Bank
 
group included in Cyprus’
 
operations, amounted
to € 58 million gain (note 24).
44.2
 
Entity wide disclosures
Breakdown of the Group's revenue
 
for each group of similar products and services is as follows:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Lending related activities
1,203
1,117
Deposits, network and asset management activities
2,011
1,671
Capital markets
(31)
(36)
Non banking and other services
158
162
Total from continuing operations
3,341
2,914
Information on the Country by Country Reporting based
 
on Law 4261/2014 is provided in the Appendix.
 
 
doc1p253i0 doc1p253i1
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
 
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31 December 2024 Consolidated Financial Statements
45.
 
Post balance sheet events
Details of post balance sheet events are provided
 
in the following notes:
Note 4
 
– Capital Management
Note 22
 
– Investment securities
Note 23.2
 
– Consolidation of Hellenic Bank group
Note 34
 
– Debt securities in issue
Note 37
 
– Standard legal staff retirement
 
indemnity obligations (SLSRI) and termination benefits
Note 46
 
– Related parties
46.
 
Related parties
Eurobank Ergasias Services and Holdings S.A. (the
 
Company or Eurobank Holdings) is the
 
parent company of Eurobank S.A. (the
 
Bank).
The Board
 
of Directors
 
(BoD) of Eurobank
 
Holdings is the
 
same as the
 
BoD of the
 
Bank and part
 
of the key
 
management personnel
(KMP) of the Bank
 
provides services to Eurobank Holdings
 
according to the terms
 
of the relevant agreement between
 
the two entities.
Fairfax Group (“Fairfax”)
 
is considered to have significant influence over Eurobank
 
Holdings. Following the changes in the Company’s
share capital in the
 
third quarter of 2024 (note
 
38), Fairfax held
 
33.29% of Eurobank Holdings’ total
 
number of voting rights as
 
at 31
December 2024 (31 December 2023:
 
32.93%), based on the latest
 
notification that the Company
 
had received from the
 
entity. On
 
7
February 2025 Eurobank
 
Holdings announced that further to
 
its announcement dated
 
23 January 2025, it has
 
been informed by the
entity that following the completion of
 
the sale of 80
 
million shares of the
 
Company, Fairfax holds 32.89% of Eurobank Holdings’ share
capital and voting rights. Further information
 
is provided in the Directors’ Report for
 
the year ended 31 December 2024.
A number
 
of banking
 
transactions are
 
entered into
 
with related
 
parties in
 
the normal
 
course of
 
business and
 
are conducted
 
on an
arm's length basis.
 
These include loans,
 
deposits and guarantees.
 
In addition, as
 
part of its normal
 
course of business
 
in investment
banking activities, the Group at times may hold positions in debt
 
and equity instruments of related parties.
The
 
outstanding
 
balances
 
of
 
the
 
transactions
 
with
 
(a)
 
Fairfax
 
group,
 
(b)
 
the
 
key
 
management
 
personnel
 
(KMP)
 
and
 
the
 
entities
controlled or jointly controlled by
 
KMP and (c) other related parties, as well as the relating income and
 
expenses are as follows:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
31 December 2024
31 December 2023
Fairfax
Group⁽²⁾
 
KMP and Entities
controlled or jointly
controlled by KMP⁽¹⁾
Other Related
Parties⁽³⁾
Fairfax
Group⁽²⁾
KMP and Entities
controlled or jointly
controlled by KMP⁽¹⁾
Other Related
Parties⁽³⁾
€ million
€ million
€ million
€ million
€ million
€ million
Investment securities
 
-
 
-
 
-
 
-
 
-
60.95
Loans and advances to
customers
152.23
5.32
0.17
119.64
5.25
25.55
Other assets
11.97
 
-
99.77
12.89
0.54
85.19
Due to credit institutions
 
-
 
-
 
-
 
-
 
-
0.04
Due to customers
23.35
18.05
96.11
46.57
16.33
93.24
Debt securities in issue
 
-
0.91
1.23
82.85
2.01
103.56
Other liabilities
0.01
0.19
8.43
0.01
0.11
6.02
Net interest income
8.28
 
(0.11)
 
(1.10)
3.20
 
(0.05)
 
(0.98)
Net banking fee and
commission income
0.03
0.04
13.57
0.04
0.07
10.57
Gains less losses from
investment securities
 
-
 
-
 
-
 
-
 
-
0.57
Impairment losses relating to
loans and securities including
relative fees
0.72
 
-
 
(69.50)
 
(2.60)
 
-
 
(77.26)
Other operating
income/(expenses)
9.77
 
(8.83)
 
(13.16)
5.71
 
(13.97)
 
(9.06)
Guarantees issued
2.48
 
-
0.45
2.47
 
-
 
 
-
 
 
(1)
Includes the key management personnel of the Group and their close family members.
 
 
 
 
Notes to the Consolidated Financial Statements
 
.
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31 December 2024 Consolidated Financial Statements
 
 
doc1p253i0 doc1p253i1
(2)
 
The balances with the Group’s
 
associate Eurolife FFH Insurance Group
 
Holdings S.A., which is also a member
 
of Fairfax Group are presented
 
in the column
other related parties.
(3)
Other related parties include associates (Hellenic Bank has been included from the second quarter of 2023 until the end of the second quarter of 2024, note
24), joint ventures and the Eurobank Group’s personnel occupational insurance fund.
For the year ended 31
 
December 2024, an impairment of
 
€ 0.01 million (2023:
 
€ 0.01 million) has
 
been recorded against loan balances
with Group’s associates and joint ventures, while the
 
respective impairment allowance amounted to €
 
0.1 million (31
 
December 2023:
€ 0.02 million).
Key management compensation (directors
 
and other key management personnel of the Group)
Key management personnel
 
are entitled to compensation
 
in the form of short-term
 
employee benefits of € 11.8
 
million (2023: € 8.3
million)
 
including
 
 
2.2
 
million
 
in
 
upfront
 
variable
 
remuneration
 
awarded
 
as
 
profit
 
sharing,
 
and
 
long-term
 
employee
 
benefits
amounting to
 
€ 5.3 million
 
(2023:
 
€ 1.4 million)
 
including € 3.2
 
million in deferred
 
variable remuneration
 
awarded as
 
profit sharing
and payable in equal installments over the next 4-5 years.
 
In addition, KMP have been granted € 5.5 million in variable remuneration
through share
 
options (2023: €
 
7.8 million), €
 
3.3 million of
 
which relates
 
to options exercisable
 
in equal portions
 
over the next
 
4-5
years. The variable
 
remuneration was awarded
 
following the Annual General
 
Meetings of the shareholders
 
of the Company and the
Bank taken place on
 
23 July 2024 (note 38), in accordance
 
with the Company’s
 
and the Bank’s remuneration
 
policy. Furthermore,
 
as
at 31 December 2024,
 
the defined benefit obligation
 
for the KMP amounts to
 
€ 2.1 million (2023: € 1.8 million)
 
while the respective
cost for the period through the income statement amounts to € 0.1 million
 
(2023: € 0.1 million) and the
 
other comprehensive income
(actuarial loss) amounts to € 0,3 million (2023: € 0.05 million actuarial loss).
47.
 
External Auditors
The
 
Group
 
has
 
adopted
 
a
 
Policy
 
on
 
External
 
Auditors’
 
Independence
 
which
 
provides
 
amongst
 
others,
 
for
 
the
 
definition
 
of
 
the
permitted
 
and non-permitted
 
services the
 
Group
 
auditors
 
may provide
 
further to
 
the statutory
 
audit. For
 
any
 
such services
 
to be
assigned to
 
the Group’s
 
auditors there
 
are specific
 
controlling
 
mechanisms in
 
order for
 
the Company’s
 
Audit Committee
 
to ensure
that a) the non-audit services
 
assigned to “KPMG Certified Auditors S.A.”, along with the KPMG network (KPMG), have been reviewed
and approved as required and b) there
 
is proper balance between audit and permitted non-audit work.
The total fees of the Group’s
 
principal independent auditor KPMG, for audit and other services provided
 
are analyzed as follows:
 
 
 
 
 
 
 
 
 
 
 
 
2024
2023
€ million
€ million
Statutory audit⁽¹⁾
(3.0)
(2.9)
Tax certificate
(0.5)
(0.4)
Other audit related assignments
(1.5)
(1.4)
Non audit assignments
(0.5)
(0.2)
Total from
 
continuing operations
(5.5)
(4.9)
(1)
 
Includes fees for statutory audit of the annual separate and consolidated financial statements.
It is noted
 
that the non-audit
 
assignment fees
 
of “KPMG Certified
 
Auditors S.A.”
 
Greece, statutory
 
auditor of the
 
Group, amounted
to € 0.23 million.
 
 
 
doc1p253i0 doc1p253i1
Notes to the Consolidated Financial Statements
 
.
166
|
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31 December 2024 Consolidated Financial Statements
48.
 
Board of Directors
The Board of Directors (BoD) was elected by the Annual General Meeting of the Shareholders
 
(AGM) held on 23 July 2024 for a three
- year term of office that will expire on 23 July 2027, prolonged until the end of the period the AGM for the year 2027 will take
 
place.
The BoD is as follows:
G. Zanias
Chairman, Non-Executive Member
F. Karavias
Chief Executive Officer
 
S. Ioannou
Deputy Chief Executive Officer
 
K. Vassiliou
Deputy Chief Executive Officer
 
B.P.
 
Martin
Non-Executive Member
A. Gregoriadi
Non-Executive Independent Member
I. Rouvitha Panou
Non-Executive Independent Member
R. Kakar
Non-Executive Independent Member
J. Mirza
Non-Executive Independent Member
C. Basile
Non-Executive Independent Member
B. Eckes
Non-Executive Independent Member
J. A. Hollows
Non-Executive Independent Member
E. Kotsovinos
Non-Executive Independent Member
Athens, 7 March 2025
Georgios P.
 
Zanias
 
Fokion C. Karavias
Harris V. Kokologiannis
I.D. No ΑI - 414343
I.D. No ΑΙ - 677962
I.D. No AN - 582334
 
CHAIRMAN
 
OF THE BOARD OF DIRECTORS
CHIEF EXECUTIVE OFFICER
GENERAL MANAGER OF GROUP FINANCE
 
 
CHIEF FINANCIAL OFFICER
 
 
 
 
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Notes to the Consolidated Financial Statements
 
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|
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31 December 2024 Consolidated Financial Statements
APPENDIX – Disclosures under Law 4261/2014
Country by Country Reporting
Pursuant to article 81 of Law 4261/2014, which incorporated article 89 of Directive
 
2013/36/EC into the Greek legislation, the Group
provides the following information
 
for each country in which it has an establishment:
(i)
 
Names, nature of activities and geographical location.
(ii)
 
The operating income (turnover), the
 
profit/(loss) before tax, the tax
 
on profit/ (loss) and the current tax
 
on a consolidated
basis for each country; intercompany
 
transactions among countries are eliminated
 
through the line ‘Intra-Group
 
amounts’.
The amounts disclosed are prepared on the same basis as
 
the Group’s financial statements for the year ended 31 December
2024.
(iii)
 
The number of employees on a full time equivalent basis.
(iv)
 
The public subsidies received.
For the listing of the
 
Bank’s subsidiaries
 
at 31 December 2024, the
 
country of their incorporation
 
and the line of their business refer
to note 23.1.
The information per country is set out below:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Year ended 31 December 2024
Operating
income
 
Profit/(loss)
before tax
Tax on profit/(loss)
Current
tax
Number of
employees at 31
December
€ million
€ million
€ million
€ million
Greece
2,064
918
 
(218)
 
(0)
6,043
Bulgaria
487
247
 
(36)
 
(36)
3,444
Romania
 
(4)
 
(15)
 
(0)
 
(0)
12
Cyprus
705
505
 
(92)
 
(90)
2,768
Serbia
 
(2)
 
(3)
 
(0)
 
(0)
6
Luxembourg⁽¹⁾
91
58
 
(15)
 
(15)
133
Netherlands
1
1
 
-
 
 
-
 
 
-
 
Other countries
 
0
 
(0)
 
-
 
 
-
 
 
-
 
Intra-Group amounts
 
(1)
Total from continuing
 
operations
3,341
1,711
 
(361)
 
(141)
12,406
Total from discontinued operations
 
-
 
 
(10)
3
 
-
 
Total
3,341
1,701
 
(358)
 
(141)
12,406
(1)
 
The operations of Eurobank Private Bank Luxembourg S.A.’s branch in London are included within Luxembourg.
Article 82 of Law 4261/2014
For 2024, the Group’s return on assets (RoA) was
 
1.64 %. RoA is calculated by dividing the net profit for the year ended 31 December
2024 by the Group’s average
 
total assets for the year.
doc1p422i2 doc1p252i2
FINANCIAL STATEMENTS
FOR THE YEAR ENDED
 
31 DECEMBER 2024
8 Othonos Str, Athens
 
105 57,
 
Greece
eurobankholdings.gr,
 
Tel.: (+30) 214 40 61000
General Commercial
 
Registry No: 000223001000
 
 
doc1p253i0 doc1p253i1
 
.
 
Index to the Financial Statements
 
..................................................................................................................................................
Page
Balance Sheet ........................................................................................................................................................................................ 1
Statement of Comprehensive Income ................................................................................................................................................... 2
Statement of Changes in Equity................................
 
............................................................................................................................. 3
Cash Flow Statement ............................................................................................................................................................................. 4
Notes to the Financial Statements
1.
 
General information ................................................................................................
 
.....................................................................
 
5
2.
 
Basis of preparation and material accounting
 
policies
 
................................................................................................................. 5
2.1
 
Basis of preparation ......................................................................................................................................................................
 
5
2.2
 
Material accounting policies .........................................................................................................................................................
 
8
3.
 
Critical accounting estimates and judgments
 
in applying accounting policies ...........................................................................
 
17
4.
 
Financial risk management and fair value ................................................................................................
 
..................................
 
18
4.1
 
Financial risk factors and risk management................................................................
 
................................................................
 
19
4.2
 
Fair value of financial assets and liabilities .................................................................................................................................
 
19
5.
 
Net interest income .................................................................................................................................................................... 20
6.
 
Other income/(expenses) ........................................................................................................................................................... 21
7.
 
Operating expenses .................................................................................................................................................................... 21
8.
 
Income tax .................................................................................................................................................................................. 21
9.
 
Investment securities
 
................................................................................................................................................................
 
..
 
22
10.
 
Shares in subsidiaries
 
................................................................................................................................................................
 
..
 
22
11.
 
Other assets
 
................................................................................................................................................................
 
................
 
23
12.
 
Debt securities in issue ............................................................................................................................................................... 23
13.
 
Other liabilities ................................................................................................................................
 
...........................................
 
23
14.
 
Share capital, share premium and treasury shares ................................
 
.................................................................................... 25
15.
 
Reserves and retained earnings/(losses) .................................................................................................................................... 26
16.
 
Share options
 
................................................................................................................................................................
 
..............
 
26
17.
 
Cash and cash equivalents ..........................................................................................................................................................
 
28
18.
 
Post balance sheet events ................................................................................................................................
 
..........................
 
28
19.
 
Related parties
 
................................................................................................................................................................
 
............
 
28
20.
 
External Auditors ................................................................................................................................................................
 
........
 
29
21.
 
Board of Directors
 
................................................................................................................................................................
 
.......
 
30
 
 
 
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Balance Sheet
 
.
1
 
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Page
 
31 December
 
2024 Financial
 
Statements
Notes on pages 5 to 30 form an integral part of these
 
financial statements.
 
 
 
doc1p253i0 doc1p253i1 doc1p425i1
Statement of Comprehensive Income
 
.
2
 
|
Page
 
31 December
 
2024 Financial
 
Statements
Notes on pages 5 to 30 form an integral part of these
 
financial statements
 
 
 
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Statement of Changes in Equity
 
.
3
 
|
Page
 
31 December
 
2024 Financial
 
Statements
(1)
 
The changes in equity do not sum to the totals provided due to rounding
Notes on pages 5 to 30 form an integral part of these
 
financial statements.
 
 
 
doc1p253i0 doc1p253i1 doc1p427i1
Cash Flow Statement
 
.
4
 
|
Page
 
31 December
 
2024 Financial
 
Statements
Notes on pages 5 to 30 form an integral part of these
 
financial statements.
 
 
 
doc1p253i0 doc1p253i1
Notes to the Financial Statements
 
.
5
 
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31 December
 
2024 Financial
 
Statements
1.
 
General information
Eurobank
 
Ergasias
 
Services and
 
Holdings S.A.
 
(the Company
 
or Eurobank
 
Holdings) is
 
the parent
 
company
 
of Eurobank
 
S.A. (the
Bank) which
 
along with
 
its subsidiaries
 
(Eurobank S.A.
 
Group), comprise
 
the major
 
part of
 
Eurobank Holdings
 
Group (the
 
Group)
(note 10).
 
The Company
 
operates
 
mainly in
 
Greece and
 
through the
 
Bank’s
 
subsidiaries in
 
Bulgaria, Cyprus
 
and Luxembourg.
 
Its
main activities
 
relate to
 
the strategic
 
planning of
 
the administration
 
of non-performing
 
loans and
 
the provision
 
of services
 
to its
subsidiaries and third parties, while
 
the Eurobank S.A. Group is
 
active in retail, corporate
 
and private banking, asset
 
management,
treasury, capital
 
markets and other services. The Company is incorporated in Greece, with its registered
 
office at 8 Othonos Street,
Athens 105 57 and its shares are listed on
 
the Athens Stock Exchange.
These financial statements were approved by the
 
Board of Directors on 7
 
March 2025. The Independent
 
Auditor’s Report is included
in section E.I of the Annual Financial Report.
2.
 
Basis of preparation and material accounting policies
The
 
financial
 
statements
 
of
 
the
 
Company
 
have
 
been
 
prepared
 
on
 
a
 
going
 
concern
 
basis
 
and
 
in
 
accordance
 
with
 
the
 
material
accounting policies set out below:
2.1
 
Basis of preparation
The financial statements of the Company have been prepared in accordance with International Financial Reporting Standards (IFRS)
issued by
 
the International
 
Accounting
 
Standards
 
Board
 
(IASB), as
 
endorsed by
 
the European
 
Union (EU),
 
and in
 
particular with
those standards
 
and interpretations,
 
issued and
 
effective
 
or issued
 
and early
 
adopted as
 
at the
 
time of
 
preparing these
 
financial
statements.
The financial statements are
 
prepared under the historical cost basis
 
except for the financial assets measured
 
at fair value through
other comprehensive income and financial assets and financial liabilities measured
 
at fair-value-through-profit
 
-or-loss.
 
The accounting policies for the preparation of the financial statements of the Company have been consistently applied to the years
2024 and 2023, after
 
taking into account
 
the amendments in IFRSs
 
as described in section
 
2.1.1 (a) “New and
 
amended standards
adopted by the Company
 
as of 1 January 2024”.
 
Where necessary,
 
comparative figures have
 
been adjusted to conform
 
to changes
in presentation in the current year.
The
 
preparation
 
of
 
financial
 
statements
 
in
 
accordance
 
with
 
IFRS
 
requires
 
the
 
use
 
of
 
estimates
 
and
 
judgements
 
that
 
affect
 
the
reported amounts of
 
assets and liabilities and
 
disclosure of contingent
 
liabilities at the date
 
of the financial statements,
 
as well as
the reported amounts of
 
revenues and expenses during the
 
reporting period. Although these
 
estimates are based on management's
best knowledge of current events and conditions,
 
actual results ultimately may differ from
 
those estimates.
The Company’s presentation currency is the Euro (€). Except
 
as indicated, financial information presented in Euro has
 
been rounded
to the nearest million. The figures presented
 
in the notes may not sum precisely to the totals provided
 
due to rounding.
Going concern considerations
The
 
Company’s
 
business
 
strategy
 
and
 
activities
 
are
 
linked
 
to
 
those
 
of
 
its
 
banking
 
subsidiary
 
Eurobank
 
S.A.
 
In
 
this
 
context,
 
the
directors monitor closely the
 
capital and liquidity
 
position of the
 
Bank as well
 
as the associated
 
risks, uncertainties and the
 
mitigating
factors affecting its operations. In December 2024, the Board of Directors of Eurobank Holdings decided
 
the initiation of the merger
process of the
 
Company with the Bank
 
through absorption of
 
the former by
 
the latter,
 
in order that
 
operational efficiencies and
 
a
leaner group structure be achieved. Upon the
 
completion of the merger,
 
the Company’s shareholders
 
become shareholders of the
Bank with the same stakes
 
and the same number of shares,
 
and the Bank will substitute
 
Eurobank Holdings as universal
 
successor
in the
 
totality of
 
its assets
 
and liabilities
 
transferred
 
to the
 
Bank (note
 
10). Following
 
the above,
 
the annual
 
financial statements
have
 
been
 
prepared
 
on
 
a
 
going
 
concern
 
basis,
 
as
 
the
 
Board
 
of
 
the
 
Directors
 
considered
 
as
 
appropriate,
 
taking
 
also
 
into
consideration:
In 2024, despite the challenging international environment, the macroeconomic backdrop was supportive in the Group’s three core
markets. In
 
particular,
 
the economies of Greece,
 
Bulgaria and Cyprus
 
remained in expansionary
 
territory,
 
overperforming most
 
of
their European Union
 
(EU) peers. According
 
to the Hellenic
 
Statistical Authority
 
(ELSTAT)
 
provisional data,
 
the real GDP
 
of Greece
expanded by 2.3% on an
 
annual basis in the
 
first nine months of 2024
 
–versus 0.5% in the euro area
 
(Eurostat)–
 
driven by household
consumption and the buildup of inventories. The average
 
annual inflation rate based on the Harmonized
 
Index of Consumer Prices
 
 
 
doc1p253i0 doc1p253i1
Notes to the Financial Statements
 
.
6
 
|
Page
 
31 December
 
2024 Financial
 
Statements
(HICP) decreased
 
to 3.0%
 
in 2024
 
from 4.2%
 
in 2023,
 
while the
 
average
 
monthly unemployment
 
rate declined
 
to 10.1%
 
in 2024,
from 11.1% in 2023, dropping to a
 
15-year low. In its Autumn Economic Forecasts (November 2024), the European Commission (EC)
expects real GDP in Greece to grow by 2.1% in 2024 and 2.3% in 2025 (2023: 2.3%). The HICP growth rate is expected to decelerate
to 2.4% in 2025
 
and the unemployment
 
rate to drop
 
to 9.8%, respectively.
 
On the fiscal front,
 
the EC expects
 
a primary surplus of
2.9% of GDP
 
in 2024 and
 
2025, up from
 
2.1% of GDP
 
in 2023. The
 
gross public debt
 
-to-GDP ratio,
 
following a
 
sizeable increase
 
in
nominal GDP due to the
 
combination of real GDP growth and
 
inflation, is expected to decline
 
to 153.1% in 2024
 
and 146.8% in 2025,
from 163.9% in 2023.
According to the EC Autumn Economic Forecasts, real GDP growth in Bulgaria in 2024
 
is expected at 2.4%, with a
 
moderate increase
in 2025 to
 
2.9% (2023: 1.8%),
 
while the HICP
 
is forecast
 
to decrease to
 
2.5% in 2024
 
and to 2.3%
 
in 2025 (2023:
 
8.6%). In Cyprus,
the real GDP growth
 
is forecast at
 
3.6% and 2.8% in 2024 and 2025,
 
respectively (2023: 2.5%), while
 
the HICP is estimated
 
at 2.2%
in 2024, and 2.1% in 2025 (2023: 3.9%).
Growth in
 
Greece as well
 
as in Bulgaria
 
and Cyprus is
 
expected to receive
 
a significant
 
boost from EU-funded
 
investment projects
and reforms.
 
Greece shall
 
receive in
 
total €
 
36 billion
 
(€ 18.2
 
billion in
 
grants and
 
€ 17.7
 
billion in
 
loans) up
 
to 2026
 
through the
Recovery and Resilience
 
Facility (RRF), Next Generation
 
EU (NGEU)’s
 
largest instrument, out
 
of which € 18.2 billion (€ 8.6
 
billion in
grants and
 
€ 9.6 billion in
 
loans) had been disbursed
 
by the EU as
 
of the end 2024.
 
A further € 40
 
billion is due through
 
EU’s
 
long-
term budget (MFF), out of which € 20.9 billion is to fund the National Strategic
 
Reference Frameworks
 
(ESPA 2021–2027).
In 2024, the Greek government raised € 9.55 billion from
 
the international financial markets through
 
the Public Debt Management
Agency (PDMA) by issuing
 
two new bonds (a 10-year
 
bond at a yield of
 
3.478% in January and a
 
30-year bond at
 
a yield of 4.241%
in April), and
 
re-opening eleven
 
past issues
 
with maturities
 
of 5 and
 
10 years.
 
At the
 
end of 2024,
 
the cash reserves
 
of the Greek
government
 
stood
 
close
 
to
 
 
33
 
billion.
 
Following
 
a
 
series
 
of
 
sovereign
 
rating
 
upgrades
 
in
 
the
 
second
 
half
 
of
 
2023,
 
the
 
Greek
government’s
 
long-term debt
 
securities were
 
considered investment
 
grade by
 
four out
 
of the five
 
Eurosystem-approved
 
External
Credit Assessment Institutions (DBRS: BBB(low), positive outlook, Fitch: BBB-, stable outlook; Scope: BBB, stable outlook; S&P: BBB-
, positive
 
outlook), and
 
one notch
 
below investment
 
grade by
 
the fifth
 
one, Moody’s
 
(Βa1, positive
 
outlook) as
 
of 31
 
December
2024. On monetary policy developments, after ten rounds of
 
interest rate hikes in 2022 and in 2023 and
 
on the back of an
 
improved
inflation outlook, the
 
European Central
 
Bank (ECB) implemented
 
five interest
 
rate cuts
 
from June 2024
 
to January 2025,
 
lowering
its deposit facility rate by 125 basis points in
 
total.
Regarding
 
the
 
outlook
 
for
 
the next
 
12 months,
 
the major
 
macroeconomic
 
risks
 
and
 
uncertainties
 
in
 
Greece
 
and
 
our
 
region
 
are
associated with:
 
(a) the
 
geopolitical tensions
 
caused primarily
 
by the
 
war in
 
Ukraine and
 
the fragile
 
situation in
 
the Middle
 
East,
their
 
implications
 
regarding
 
regional
 
and
 
global
 
stability
 
and
 
security,
 
and
 
their
 
repercussions
 
on
 
the
 
global
 
and
 
the
 
European
economy,
 
(b)
 
an
 
interruption
 
or
 
even
 
a reversal
 
of
 
the
 
disinflationary
 
trend
 
observed
 
in the
 
past
 
24
 
months
 
and
 
its
 
impact
 
on
economic growth, employment, public
 
finances, household budgets,
 
firms’ production costs, external
 
trade and banks’ asset
 
quality,
as well
 
as any
 
potential social
 
and/or political
 
ramifications
 
this may
 
entail, (c)
 
the timeline
 
of the
 
potential further
 
interest
 
rate
cuts by the ECB and the Federal Reserve Bank, as persistence on high rates for longer may
 
keep exerting pressure on sovereign
 
and
private borrowing costs and certain financial institutions’ balance sheets, but early rate cuts entail the risk of a rebound in inflation,
(d)
 
the
 
prospect
 
of
 
Greece’s
 
and
 
Bulgaria’s
 
major
 
trade
 
partners,
 
primarily
 
the
 
euro
 
area,
 
remaining
 
stagnant
 
or
 
even
 
facing
 
a
temporary
 
downturn,
 
(e)
 
the
 
elevated
 
political
 
and
 
economic
 
uncertainty
 
stemming
 
from
 
the
 
international
 
and
 
trade
 
policy
decisions of
 
the new
 
administration
 
in the
 
United States,
 
(f) the
 
persistently
 
large current
 
account deficit
 
that seems
 
to become
once again a structural feature of the Greek economy,
 
(g) the absorption capacity of the NGEU and MFF funds and the attraction of
new
 
investments
 
in
 
the
 
countries
 
of
 
presence,
 
especially
 
in
 
Greece,
 
(h)
 
the
 
effective
 
and
 
timely implementation
 
of
 
the
 
reform
agenda
 
required
 
to
 
meet
 
the RRF
 
milestones
 
and
 
targets
 
and to
 
boost
 
productivity,
 
competitiveness,
 
and resilience
 
and
 
(i) the
exacerbation
 
of natural
 
disasters due
 
to the
 
climate change
 
and their
 
effect on
 
GDP,
 
employment, fiscal
 
balance and
 
sustainable
development in the long run.
Materialization of the above risks would have potentially adverse effects on the fiscal planning of the Greek government, as it
 
could
decelerate the pace
 
of expected
 
growth and on
 
the liquidity,
 
asset quality,
 
solvency and profitability
 
of the Greek
 
banking sector.
In
 
this
 
context,
 
the
 
Group’s
 
Management
 
and
 
Board
 
are
 
continuously
 
monitoring
 
the
 
developments
 
on
 
the
 
macroeconomic,
financial and geopolitical
 
fronts as well as
 
the evolution of the Group’s
 
asset quality and liquidity KPIs
 
and have maintaine
 
d
 
a high
level of readiness, so as to accommodate decisions, initiatives and policies to protect the Group’s
 
capital, asset quality and liquidity
standing
 
as
 
well
 
as
 
the
 
fulfilment,
 
to
 
the
 
maximum
 
possible
 
degree,
 
of
 
its
 
strategic
 
and
 
business
 
goals
 
in
 
accordance
 
with
 
the
business plan for 2025 - 2027.
 
 
 
doc1p253i0 doc1p253i1
 
Notes to the Financial Statements
 
.
7
 
|
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31 December
 
2024 Financial
 
Statements
For the
 
year ended
 
31 December
 
2024, at
 
the Group
 
level, the
 
net profit
 
attributable to
 
shareholders,
 
following the
 
inclusion of
Hellenic Bank group in
 
the Company’s consolidated financial statements from the
 
third quarter of
 
2024, amounted to €
 
1,448 million
(2023: € 1,140 million). The adjusted net profit, excluding
 
(a) the € 121 million restructuring costs (after
 
tax), mainly related to VES
, (b) the € 99.5 million gain arising from the acquisition of an
 
additional 26.28% shareholding of Hellenic Bank in June 2024 , (c) the
€ 19 million
 
Bank’s
 
contribution (after
 
tax) for
 
the Greek
 
state’s
 
program
 
for school
 
renovations,
 
(d) the
 
€ 11 million
 
impairment
release (after tax) relating to
 
the project “Leon” and (e) the € 7 million net loss from discontinued operations
 
amounted to € 1,484
million (2023: € 1,256 million), of which € 709 million profit was related to the international operations (2023: € 468 million profit).
 
The net profit for the Company,
 
carrying the impact of the Bank’s
 
distribution of non-mandatory reserves totalling
 
€ 240 million to
the Company (note
 
15), equals to €
 
231 million (2023: €
 
403 million profit).
 
As at 31 December
 
2024, the Group’s
 
Total
 
Adequacy
Ratio (total CAD) and Common Equity Tier 1 (CET1) ratios,
 
including the impact of the distribution of cash dividend to shareholders
approved by
 
the AGM
 
in July
 
2024 and the
 
inclusion of
 
Hellenic Bank group
 
in the
 
Company’s consolidated
 
financial statements,
stood at 19.5% (31 December 2023: 19.4%) and 16.8% (31 December 2023: 16.9%).
With regard to
 
asset quality,
 
as at 31 December 2024, the Group’s
 
NPE stock, including the impact of
 
Hellenic Bank, stood at
 
€ 1.5
billion, excluding
 
the €
 
0.2 billion
 
NPE of
 
Hellenic Bank
 
covered
 
by the
 
Asset Protection
 
Scheme (APS)
 
(31 December
 
2023: €
 
1.5
billion), driving the NPE ratio to
 
2.9% at 31 December 2024 (31 December 2023: 3.5%).
 
Τhe NPE coverage ratio
 
improved to 88.4%
(31 December 2023: 86.4%).
In terms of liquidity, as at 31
 
December 2024 the Group
 
deposits, including the impact
 
of the Hellenic
 
Bank consolidation that added
 
15.8
 
billion,
 
stood
 
at
 
 
78.6 billion
 
(31
 
December
 
2023:
 
 
57.4
 
billion).
 
The
 
funding
 
from
 
the
 
targeted
 
long
 
term
 
refinancing
operations of the ECB – TLTRO
 
III programme was fully repaid
 
during the year (31 December 2023: € 3.8 billion), while the Group’s
debt securities
 
in issue,
 
increased by
 
€ 2.3
 
billion. The
 
rise in
 
high quality
 
liquid assets
 
of the
 
Group
 
led the
 
respective
 
Liquidity
Coverage ratio
 
(LCR) to 188.2%
 
(31 December 2023:
 
178.6%). Information
 
on the financial
 
risks to which
 
the Company is
 
exposed
and its risk management strategy is set out
 
in note 4.
Going concern assessment
The Board of Directors, acknowledging the geopolitical, macroeconomic and financial risks to the economy and the banking system
and taking into
 
account the above
 
factors relating
 
to (a) the idiosyncratic
 
growth opportunities in
 
Greece, Bulgaria and
 
Cyprus for
this and the next years, also underpinned by the mobilisation of the EU funding mainly through the RRF, (b) the Bank’s
 
and Group’s
pre-provision
 
income
 
generating
 
capacity,
 
asset quality,
 
capital
 
adequacy
 
and liquidity
 
position,
 
and (c)
 
the continuation
 
of
 
the
Company’s business operations by the Bank after their merger, has been satisfied that the financial statements of the Company can
be prepared on a going concern basis.
2.1.1
 
New and amended standards and interpretations
(a) New and amended standards adopted by the Company as
 
of 1 January 2024
The following amendments to existing standards
 
as issued by the IASB and endorsed by the EU, that are relevant to the Company’s
activities apply as of 1 January 2024:
IAS 1, Amendments, Classification of Liabilities as Current or Non-Current
 
and Non-current liabilities with covenants
The
 
amendments,
 
published
 
in January
 
2020, introduce
 
a definition
 
of
 
settlement
 
of
 
a liability,
 
while
 
they
 
make
 
clear
 
that
 
the
classification of liabilities as
 
current or non-current should be
 
based on rights
 
that are in
 
existence at the end
 
of the reporting period.
In addition, it is clarified that the assessment
 
made at the end of the reporting period
 
for liabilities’ classification is not
 
affected by
the expectations about events
 
after the reporting
 
period and whether
 
an entity will
 
exercise its right to
 
defer settlement of a
 
liability.
The Board also clarified that
 
when classifying liabilities as
 
current or non-current, an entity can ignore only
 
those conversion options
that are classified as equity.
In October 2022, the IASB issued
 
Non-current Liabilities with Covenants (Amendments to IAS 1)”
 
with respect to liabilities for which
an entity’s
 
right to
 
defer their
 
settlement for
 
at least
 
12 months
 
after the
 
reporting date,
 
is subject
 
to the
 
entity complying
 
with
conditions after the
 
reporting period (“future
 
covenants”). The amendments
 
specify that covenants
 
to be complied with
 
after the
reporting date
 
do not affect
 
the classification of
 
debt as current
 
or non-current
 
at the reporting
 
date. However,
 
the amendments
require a company to disclose information
 
about these covenants in the notes to the financial statements.
The adoption of the amendments had no impact on the financial statements.
 
 
 
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Notes to the Financial Statements
 
.
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31 December
 
2024 Financial
 
Statements
(b) New and amended standards not yet adopted by the Company
A number of new standards and amendments to existing standards are effective after 2024, as they have not yet been endorsed by
the EU or have not been early applied by the Company.
 
Those that may be relevant to the Company’s
 
activities are set out below:
IFRS 18, Presentation and Disclosure in Financial Statements
 
(effective 1 January 2027, not yet endorsed by EU)
In April 2024, the IASB published
 
the new standard IFRS 18 “Presentation and Disclosure in Financial Statements” which will replace
IAS
 
1
 
“Presentation
 
of
 
Financial
 
Statements”.
 
The
 
new
 
standard
 
sets
 
out
 
the
 
requirements
 
for
 
presentation
 
and
 
disclosures
 
in
financial statements
 
with focus on the
 
income statement
 
and reporting of financial
 
performance, in order
 
to ensure that
 
financial
statements provide relevant
 
information that faithfully represents
 
an entity’s financial position, performance, and cash
 
flows.
Specifically,
 
the
 
new
 
standard
 
contains
 
new
 
guidance
 
regarding
 
the
 
structure
 
of
 
the
 
income
 
statement,
 
as
 
well
 
as
 
disclosure
requirements for Management-defined Performance Measures (MPMs). In addition, it provides enhanced guidance on aggregation
and disaggregation of information on the face of financial statements
 
and in the notes, while sets out general requirements for the
classification and presentation of assets, liabilities,
 
equity, income, and expenses.
The new standard is effective
 
for annual periods beginning on or after January 1, 2027, with early adoption permitted
 
and will also
apply to comparative information.
Adoption of IFRS 18 is not expected to impact the financial statements.
IFRS 9 & IFRS 7, Amendments to
 
the Classification and Measurement of Financial
 
Instruments (effective 1
 
January 2026, not yet
endorsed by EU)
In May 2024, the IASB issued “Amendments to the Classification and Measurement of Financial Instruments – Amendments to IFRS
9
 
and
 
IFRS
 
7”.
 
The
 
amendments
 
clarify
 
the
 
requirements
 
related
 
to
 
the
 
derecognition
 
of
 
financial
 
liabilities
 
settled
 
through
electronic payment systems, provide additional guidance for the SPPI assessment of financial instruments with
 
contingent features,
non-recourse features,
 
as well as for transactions that are contractually
 
linked instruments.
Additionally, the amendments
 
introduce disclosure requirements
 
regarding financial instruments with contingent
 
features, as well
as for investment in equity instruments
 
designated at FVOCI.
The amendments are effective for annual reporting periods beginning on or
 
after 1 January 2026 with
 
earlier application permitted.
The adoption of the amendments is not expected to impact the financial statements.
Annual improvements to IFRSs - Volume
 
11 (effective 1 January 2026, not yet endorsed by EU)
In July 2024, the IASB issued amendments to several IFRS standards, which resulted from
 
the IASB’s annual improvements process.
This volume includes minor amendments to several standards
 
namely :
-IFRS
 
1 “First
 
-time Adoption
 
of International
 
Financial Reporting
 
Standards”
 
on Clarifications
 
on hedge
 
accounting
 
for
 
first-time
adopters,
-IFRS
 
7
 
“Financial
 
Instruments:
 
Disclosures”
 
and
 
its
 
accompanying
 
Guidance
 
on
 
implementing
 
IFRS
 
7
in
 
disclosures
 
related
 
to
derecognition, fair value and credit risk,
- IFRS 9 “Financial Instruments” on clarifications about lessee derecognition of lease liabilities and on definition of transaction price
over the initial measurement of trade receivables,
-IFRS 10 “Consolidated Financial Statements”
 
on the determination of a 'De Facto Agent'
 
and
-IAS 7 “Statement of Cash-Flows” on definition of cost
 
method.
The adoption of the amendments is not expected to impact the financial statements.
2.2
 
Material accounting policies
2.2.1
 
Investments in subsidiaries
Investments
 
in subsidiaries, including
 
investments acquired
 
through common
 
control transactions,
 
are accounted
 
at cost
 
less any
impairment losses. Cost is the fair value of the consideration
 
given being the amount of cash or shares issued.
 
 
 
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As an exception
 
to the
 
above measurement
 
basis, when the
 
Company transfers
 
a business sector
 
to a new
 
subsidiary formed
 
for
this purpose in a transaction that does not have commercial substance, the Company’s
 
investment in that newly formed subsidiary
is recognized at carrying amount of the net
 
assets given up.
Dividend
 
income
 
from
 
investments
 
in
 
subsidiaries
 
is recognised
 
in
 
the
 
income
 
statement
 
when
 
the
 
right
 
to
 
receive
 
payment
 
is
established, that is when the dividend distribution is approved
 
by the appropriate body of the entity.
A listing of the Company’s subsidiaries is set out
 
in note 10.
2.2.2 Foreign currencies
Foreign currency
 
transactions
 
are translated
 
into the
 
functional currency
 
using the
 
exchange
 
rates
 
prevailing
 
at the
 
dates of
 
the
transactions.
 
Foreign exchange
 
gains and
 
losses resulting
 
from the
 
settlement of
 
such transactions
 
are recognized
 
in the
 
income
statement.
Monetary assets and liabilities denominated in foreign
 
currencies are translated into the functional currency
 
at the exchange rates
prevailing at each reporting date and
 
exchange differences are
 
recognized in the income statement.
Non-monetary assets and liabilities are
 
translated into the functional currency at the
 
exchange rates prevailing at initial recognition.
2.2.3 Interest income and expense
Interest
 
income and
 
expense are
 
recognized
 
in the
 
income statement
 
for all
 
interest
 
bearing financial
 
instruments on
 
an accrual
basis, using the
 
effective interest
 
rate (EIR)
 
method. The effective
 
interest rate
 
is the rate
 
that exactly
 
discounts estimated
 
future
cash payments or receipts through the expected life of the financial instrument
 
or, when appropriate,
 
a shorter period to the gross
carrying
 
amount
 
of
 
the
 
financial
 
asset
 
or
 
to
 
the
 
amortized
 
cost
 
of
 
a
 
financial
 
liability.
 
When
 
calculating
 
the
 
EIR
 
for
 
financial
instruments, the
 
Company estimates
 
future cash
 
flows considering
 
all contractual
 
terms of
 
the financial
 
instrument but
 
does not
consider expected credit losses.
 
The EIR calculation includes fees and basis points paid or received that are an integral part of
 
the effective interest rate, transaction
costs, and other premiums or discounts. Transaction costs include incremental costs that are directly attributable to the acquisition
or issue of a financial asset or liability.
The amortized
 
cost of
 
a financial
 
asset or
 
liability is
 
the amount
 
at which
 
it is
 
measured upon
 
initial recognition
 
minus principal
repayments, plus or minus cumulative
 
amortization using the EIR (as described above) and for
 
financial assets it is adjusted for the
expected
 
credit
 
loss
 
allowance.
 
The
 
gross
 
carrying
 
amount
 
of
 
a
 
financial
 
asset
 
is
 
its
 
amortized
 
cost
 
before
 
adjusting
 
for
 
ECL
allowance.
The Company
 
calculates interest
 
income and
 
expense by
 
applying the EIR
 
to the
 
gross carrying
 
amount of
 
non-impaired financial
assets (exposures in Stage 1 and 2) and to the
 
amortized cost of financial liabilities respectively.
For
 
financial
 
assets
 
that
 
have
 
become
 
credit-impaired
 
subsequent
 
to
 
initial
 
recognition
 
(exposures
 
in
 
Stage
 
3),
 
the
 
Company
calculates
 
interest
 
income by
 
applying the
 
effective
 
interest
 
rate
 
to the
 
amortized
 
cost
 
of the
 
financial asset
 
(i.e. gross
 
carrying
amount adjusted
 
for the expected
 
credit loss allowance).
 
If the asset is
 
no longer credit
 
-impaired, then the
 
EIR is applied again
 
to
the gross carrying amount.
Interest income and expense are presented separately
 
in the income statement for all interest bearing financial instruments within
net interest income.
2.2.4 Impairment of subsidiaries
The Company assesses at
 
each reporting date whether
 
there is any indication
 
that its investments
 
in subsidiaries may be impaired
by considering
 
both external
 
and internal
 
sources of
 
information,
 
such as
 
the net
 
assets compared
 
to the
 
carrying value
 
of each
subsidiary,
 
as well
 
as forward
 
looking developments
 
and/or economy
 
sector in
 
which they
 
operate.
 
In addition,
 
the collection
 
of
dividends from subsidiaries is also a potential
 
trigger that may indicate that
 
the respective investments
 
are impaired. In particular,
when
 
dividend
 
is
 
received
 
from
 
the
 
Company’s
 
subsidiaries,
 
it
 
is
 
also
 
examined
 
whether
 
that
 
dividend
 
exceeds
 
the
 
total
comprehensive income of the
 
subsidiary in the period the dividend is declared,
 
to determine whether an indication
 
of impairment
exists.
 
 
 
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If any
 
indication of
 
impairment exists
 
at each
 
reporting date,
 
the Company
 
estimates the
 
recoverable
 
amount of
 
the investment,
being the higher of its fair value less costs to sell and
 
its value in use.
An impairment loss is recognized in profit or loss when the
 
recoverable amount of the investment
 
is less than its carrying amount.
Investments
 
in
 
subsidiaries
 
for
 
which
 
an
 
impairment
 
loss
 
was
 
recognized
 
in
 
prior
 
reporting
 
periods,
 
are
 
reviewed
 
for
 
possible
reversal of such impairment at each reporting
 
date.
2.2.5 Financial assets
Financial assets – Classification and measurement
The Company classifies
 
its financial assets based
 
on the business model
 
for managing those assets
 
and their contractual
 
cash flow
characteristics.
 
Accordingly,
 
financial assets
 
are classified
 
into one
 
of the following
 
measurement categories:
 
amortized cost
 
(AC)
and fair value through other comprehensive
 
income (FVOCI).
Financial Assets measured at Amortized Cost (‘AC’)
The Company classifies and measures a financial asset at AC only if both of the following
 
conditions are met:
(a) The financial asset is held within
 
a business model whose objective is to
 
collect contractual cash flows
 
(hold-to-collect business
model) and,
(b) The contractual
 
terms of the financial
 
asset give rise on
 
specified dates to
 
cash flows that
 
are solely payments
 
of principal and
interest on the principal amount outstanding
 
(SPPI).
These financial assets
 
are recognized initially at
 
fair value plus
 
or minus direct
 
and incremental transaction costs
 
that are attributable
to the acquisition of these assets, and are subsequently
 
measured at amortized cost, using the effective
 
interest rate
 
(EIR) method
(as described in 2.2.3 above).
Interest income, realized
 
gains and losses on derecognition,
 
and changes in expected credit
 
losses from assets classified at
 
AC, are
included in the income statement.
Financial Assets measured at Fair Value through Other
 
Comprehensive Income (‘FVOCI’)
The Company classifies and measures a financial asset at FVOCI only if both of the
 
following conditions are met:
(a) The
 
financial asset
 
is held
 
within a
 
business model
 
whose objective
 
is achieved
 
by both
 
collecting contractual
 
cash flows
 
and
selling financial assets (hold-to-collect-and-sell business model) and,
(b) The contractual terms of the financial asset give rise on specified dates
 
to cash flows that are SPPI.
Financial
 
assets
 
that
 
meet these
 
criteria
 
are
 
debt
 
instruments
 
and are
 
measured
 
initially
 
at
 
fair
 
value,
 
plus or
 
minus direct
 
and
incremental transaction costs that
 
are attributable to the acquisition of these assets.
Subsequent to
 
initial recognition,
 
FVOCI debt
 
instruments are
 
re-measured at
 
fair value
 
through OCI,
 
except for
 
interest
 
income,
related
 
foreign
 
exchange
 
gains
 
or losses
 
and expected
 
credit losses,
 
which are
 
recognized
 
in the
 
income statement.
 
Cumulative
gains
 
and
 
losses
 
previously
 
recognized
 
in
 
OCI
 
are
 
transferred
 
from
 
OCI
 
to
 
the
 
income
 
statement
 
when
 
the
 
debt
 
instrument
 
is
derecognised.
Business model and contractual characteristics assessment
The business model assessment determines how the Company
 
manages a group of assets to generate
 
cash flows. That is, whether
the Company's
 
objective is solely
 
to collect contractual
 
cash flows from
 
the asset, to
 
realize cash
 
flows from the
 
sale of assets,
 
or
both to
 
collect contractual
 
cash flows
 
and cash
 
flows from
 
the sale of
 
assets. In addition,
 
the business
 
model is determined
 
after
aggregating the
 
financial assets into
 
groups (business lines)
 
which are managed
 
similarly rather
 
than at an
 
individual instrument’s
level.
The business model
 
is determined by
 
the Company’s key management personnel consistently with
 
the operating model, considering
how
 
financial
 
assets
 
are
 
managed
 
in
 
order
 
to
 
generate
 
cash
 
flows,
 
the
 
objectives
 
and
 
how
 
performance
 
of
 
each
 
portfolio
 
is
monitored and reported and any available
 
information on past sales and on future sales’ strategy,
 
where applicable.
 
 
 
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Accordingly, in making the above assessment, the Company will consider a number of
 
factors including the risks associated with the
performance of the business model and how those risks are evaluated and managed, the related personnel compensation,
 
and the
frequency, volume
 
and reasons of past sales, as well as expectations about future
 
sales activity.
Types of business models
The Company’s
 
business models
 
fall into
 
two categories,
 
which are
 
indicative of
 
the key
 
strategies used
 
to generate
 
returns. The
hold-to-collect (HTC) business model
 
has the objective
 
to hold the
 
financial assets in
 
order to collect
 
contractual cash flows. Financial
assets classified
 
within this
 
business model
 
include investment
 
securities and
 
due from
 
banks, which
 
are measured
 
at amortized
cost. Sales within this model are monitored and may be
 
performed for reasons which are not inconsistent with this business model.
More specifically, sales of financial assets
 
due to credit deterioration, as well
 
as sales close
 
to the maturity are considered consistent
with
 
the
 
objective
 
of
 
hold-to-collect
 
contractual
 
cash
 
flows
 
regardless
 
of
 
value
 
and
 
frequency.
 
Sales
 
for
 
other
 
reasons
 
may
 
be
consistent with the HTC model such as liquidity needs in any stress case scenario or sales made to manage high concentration level
of credit risk.
 
Such sales are
 
monitored and
 
assessed depending on
 
frequency and value
 
to conclude whether
 
they are
 
consistent
with the HTC model.
The hold-to-collect-and-sell
 
business model
 
(HTC&S) has
 
the objective
 
both to
 
collect contractual
 
cash flows
 
and sell
 
the assets.
Activities such
 
as liquidity management,
 
interest yield
 
and duration
 
are consistent
 
with this business
 
model, while sales
 
of assets
are
 
integral
 
to
 
achieving
 
the
 
objectives
 
of
 
this
 
business
 
model.
 
Financial
 
assets
 
classified
 
within
 
this
 
business
 
model
 
include
investment securities which are measured at
 
FVOCI, subject to meeting the SPPI assessment criteria.
Cash flow characteristics assessment
For
 
a financial
 
asset to
 
be measured
 
at
 
AC,
 
its contractual
 
terms must
 
give rise
 
on specified
 
dates
 
to
 
cash flows
 
that
 
are solely
payments of principal and interest (SPPI) on
 
the principal amount outstanding.
For
 
the
 
purpose
 
of
 
this
 
assessment
 
principal
 
is
 
defined
 
as
 
the
 
fair
 
value
 
of
 
the
 
asset
 
at
 
initial
 
recognition
 
and
 
interest
 
as
 
the
consideration for the time value of money,
 
credit risk, other basic lending risks and a profit margin.
More specifically,
 
at the initial recognition
 
of a financial asset, an
 
assessment is performed of
 
whether the financial asset
 
contains
a contractual term
 
that could change the amount
 
or timing of contractual
 
cash flows in a way
 
that it would not be
 
consistent with
the
 
above
 
condition.
 
The
 
Company
 
considers
 
the
 
existence
 
of
 
various
 
features,
 
including
 
among
 
others,
 
prepayment
 
terms,
deferred interest-free payments,
 
extension and equity conversion options. Where the contractual terms introduce exposure
 
to risk
or volatility that are inconsistent
 
with a basic lending arrangement, the related
 
financial asset is considered to have
 
failed the SPPI
assessment and will be measured at FVTPL.
In
 
addition,
 
for
 
the
 
purposes
 
of
 
the
 
SPPI
 
assessment,
 
if
 
a
 
contractual
 
feature
 
could
 
have
 
an
 
effect
 
that
 
is
 
de-minimis
 
on
 
the
contractual cash flows of the financial asset, it
 
does not affect its classification. Moreover, a contractual feature is considered as not
genuine by the Company,
 
if it affects the
 
instrument’s contractual
 
cash flows only on the
 
occurrence of an event
 
that is extremely
rare, highly abnormal and very unlikely to
 
occur.
 
In such a case, it does not affect the instrument’s
 
classification.
Derecognition of financial assets
The Company
 
derecognizes
 
a financial
 
asset when
 
its contractual
 
cash flows
 
expire, or
 
the rights
 
to receive
 
those cash
 
flows are
transferred in an outright sale
 
in which substantially all
 
risks and rewards of
 
ownership have been transferred. In addition,
 
a financial
asset is derecognized even
 
if rights to receive cash
 
flows are retained
 
but at the same time the Company
 
assumes an obligation to
pay the received cash
 
flows without a material
 
delay (pass through agreement)
 
or when substantially all
 
the risks and rewards
 
are
neither transferred
 
nor retained
 
but the
 
Company has
 
transferred
 
control
 
of the
 
asset. Control
 
is transferred
 
if,
 
and only
 
if,
 
the
transferee
 
has
 
the
 
practical
 
ability
 
to
 
sell
 
the
 
asset
 
in
 
its
 
entirety
 
to
 
unrelated
 
third
 
party
 
and
 
is
 
able
 
to
 
exercise
 
that
 
ability
unilaterally and without imposing additional restrictions
 
on the transfer.
On derecognition
 
of
 
a financial
 
asset,
 
the difference
 
between
 
the
 
carrying
 
amount
 
of
 
the asset
 
and the
 
consideration
 
received
(including any new asset obtained less any new
 
liability assumed) is recognized in income statement.
Modification of financial assets that may result in derecognition
In addition, derecognition of financial
 
asset arises when its contractual
 
cash flows are modified and
 
the modification is considered
substantial
 
enough so
 
that the
 
original asset
 
is derecognized
 
and a
 
new one
 
is recognised.
 
Substantial
 
modifications resulting
 
in
 
 
 
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derecognition may
 
include among others
 
change in borrower,
 
change in the asset’s
 
denomination currency,
 
debt consolidation of
unsecured exposure into a single new secured asset. The Company records the modified asset
 
as a ‘new’ financial asset at
 
fair value
plus
 
any
 
eligible
 
transaction
 
costs
 
and
 
the
 
difference
 
with
 
the
 
carrying
 
amount
 
of
 
the
 
existing
 
one
 
is
 
recorded
 
in
 
the
 
income
statement as derecognition
 
gain or loss.
2.2.6 Financial liabilities
Financial liabilities - Classification and measurement
The Company classifies its financial liabilities at amortized cost
 
category.
These
 
financial
 
liabilities
 
are
 
recognized
 
initially
 
at
 
fair
 
value
 
minus
 
transaction
 
costs
 
that
 
are
 
attributable
 
to
 
the
 
issue of
 
these
liabilities, and
 
are subsequently
 
measured at
 
amortized cost,
 
using the
 
effective interest
 
rate (EIR)
 
method (as
 
described in
 
2.2.3
above).
Derecognition of financial liabilities
A
 
financial
 
liability is
 
derecognized
 
when
 
the obligation
 
under
 
the liability
 
is discharged,
 
cancelled or
 
expires.
 
When
 
an existing
financial liability of the Company is replaced by another
 
from the same counterparty on substantially
 
different terms, or the
 
terms
of an existing
 
liability are substantially
 
modified, such an
 
exchange or
 
modification is treated
 
as an extinguishment
 
of the original
liability and the recognition of a new liability and any difference
 
arising is recognized in the income statement.
The Company
 
considers the
 
terms to
 
be substantially
 
different,
 
if the
 
discounted present
 
value of
 
the cash
 
flows under
 
the new
terms,
 
including any
 
fees
 
paid net
 
of any
 
fees
 
received
 
and discounted
 
using the
 
original effective
 
interest
 
rate,
 
is at
 
least 10%
different from the discounted
 
present value of the remaining cash flows
 
of the original financial liability.
If an exchange
 
of debt instruments
 
or modification of
 
terms is accounted
 
for as an
 
extinguishment, any
 
costs or fees
 
incurred are
recognized
 
as
 
part
 
of
 
the
 
gain
 
or
 
loss
 
on
 
the
 
extinguishment.
 
If
 
the
 
exchange
 
or
 
modification
 
is
 
not
 
accounted
 
for
 
as
 
an
extinguishment, any costs or fees incurred adjust the carrying amount
 
of the liability and are amortized over the remaining term of
the modified liability.
Similarly,
 
when the
 
Company
 
repurchases
 
any
 
debt instruments
 
issued by
 
the Company,
 
it accounts
 
for
 
such transactions
 
as an
extinguishment of debt.
2.2.7 Fair value measurement of financial instruments
Fair
 
value of
 
financial instruments
 
is the
 
price that
 
would be
 
received to
 
sell an
 
asset or
 
paid to
 
transfer
 
a liability
 
in an
 
orderly
transaction
 
between
 
market
 
participants
 
at
 
the
 
measurement
 
date
 
under
 
current
 
market
 
conditions
 
in
 
the
 
principal
 
or,
 
in
 
its
absence, the most advantageous
 
market to which the Company
 
has access at that date. The fair
 
value of a liability reflects its
 
non-
performance risk.
When
 
available,
 
the
 
Company
 
measures
 
the
 
fair
 
value
 
of
 
an
 
instrument
 
using
 
the
 
quoted
 
price
 
in
 
an
 
active
 
market
 
for
 
that
instrument. A market
 
is regarded as
 
active if transactions
 
for the asset
 
or liability take
 
place with sufficient
 
frequency and volume
to provide
 
pricing information
 
on an ongoing
 
basis. If there
 
is no quoted
 
price in an
 
active market,
 
then the Company
 
uses other
valuation techniques that maximize the use of relevant observable inputs and minimize the use of
 
unobservable inputs. The chosen
valuation technique incorporates
 
all of the factors that market
 
participants would take into
 
account in pricing a transaction.
The Company has
 
elected to use mid-market
 
pricing as a practical
 
expedient for
 
fair value measurements
 
within a bid-ask spread.
The best evidence of the fair value of a financial instrument at initial recognition is normally the transaction price, i.e. the fair value
of the
 
consideration
 
given or
 
received
 
unless the
 
Company
 
determines
 
that
 
the fair
 
value
 
at
 
initial recognition
 
differs
 
from
 
the
transaction price.
 
In this case,
 
if the fair
 
value is
 
evidenced by
 
a quoted
 
price in an
 
active market
 
for an
 
identical asset
 
or liability
(i.e.
 
Level
 
1
 
input)
 
or
 
based
 
on
 
a
 
valuation
 
technique
 
that
 
uses
 
only
 
data
 
from
 
observable
 
markets,
 
a
 
day
 
one
 
gain
 
or
 
loss
 
is
recognized
 
in
 
the
 
income
 
statement.
 
On
 
the
 
other
 
hand,
 
if
 
the
 
fair
 
value
 
is
 
evidenced
 
by
 
a
 
valuation
 
technique
 
that
 
uses
unobservable inputs,
 
the financial instrument
 
is initially measured
 
at fair
 
value, adjusted
 
to defer
 
the difference
 
between the
 
fair
value at initial
 
recognition and the
 
transaction price (day
 
one gain or
 
loss). Subsequently the deferred
 
gain or loss
 
is amortized on
an appropriate
 
basis over the
 
life of the
 
instrument or released
 
earlier if a quoted
 
price in an
 
active market
 
or observable
 
market
data become available or the financial instrument
 
is closed out.
 
 
 
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All assets and liabilities for which fair value is
 
measured or disclosed in the financial
 
statements are categorized within the fair value
hierarchy based on the lowest level
 
input that is significant to the fair value
 
measurement as a whole.
For assets and liabilities that
 
are measured at fair
 
value on a recurring basis,
 
the Company recognizes transfers
 
into and out of the
fair value hierarchy
 
levels at the beginning of the quarter in which a financial instrument's transfer
 
was effected.
2.2.8 Impairment of financial assets
The Company recognizes allowance for
 
expected credit losses (ECL) that
 
reflect changes in credit quality since initial recognition
 
to
financial assets
 
that are
 
measured at
 
AC. ECL
 
are a
 
probability-weighted
 
average
 
estimate
 
of credit
 
losses that
 
reflects the
 
time
value of money.
Upon initial recognition
 
of the financial instruments,
 
the Company records
 
a loss allowance equal
 
to 12-month ECL,
 
being the ECL
that result from default events
 
that are possible within the next twelve months.
 
Subsequently, for
 
those financial instruments
 
that
have
 
experienced
 
a
 
significant
 
increase
 
in
 
credit
 
risk
 
(SICR)
 
since
 
initial
 
recognition,
 
a
 
loss
 
allowance
 
equal
 
to
 
lifetime
 
ECL
 
is
recognized, arising from default
 
events that are possible over the expected life
 
of the instrument.
Accordingly,
 
ECL are recognized using a three-stage
 
approach based on the extent of credit deterioration
 
since origination:
Stage 1 – When there is no significant increase in credit risk since initial recognition of a financial instrument, an amount equal
to 12-month
 
ECL is recorded.
 
The 12 –
 
month ECL
 
represent a
 
portion of lifetime
 
losses, that result
 
from default
 
events that
are possible within the next 12 months after the reporting date and is equal to the expected cash shortfalls
 
over the life of the
instrument or group of
 
instruments, due to loss
 
events probable within the
 
next 12 months. Not
 
credit-impaired financial assets
that are either newly
 
originated or purchased,
 
as well as assets recognized
 
following a substantial
 
modification accounted for
as a derecognition, are classified initially in Stage 1.
Stage 2 – When a financial instrument experiences a SICR subsequent
 
to origination but is not considered to be in default,
 
it is
included
 
in
 
Stage
 
2. Lifetime
 
ECL
 
represent
 
the
 
expected
 
credit
 
losses
 
that
 
result
 
from
 
all possible
 
default
 
events
 
over
 
the
expected life of the financial instrument.
Stage 3 – Financial instruments that are considered to be in default are included in this stage. Similar to Stage 2, the allowance
for credit losses captures the lifetime expected
 
credit losses.
A financial asset is credit-impaired when one or more
 
events that have a detrimental
 
impact on the estimated future cash flows
 
of
that exposure have occurred:
The borrower faces a significant difficulty
 
in meeting his financial obligations.
There has been a breach of contract,
 
such as a default or past due event.
The Company,
 
for economic or contractual
 
reasons relating to the borrower’s
 
financial difficulty,
 
has granted to the
 
borrower
a concession(s) that the Company would not otherwise consider.
There is a probability that the borrower
 
will enter bankruptcy or other financial re-organization.
The Company
 
determines
 
the risk
 
of default
 
using an
 
internal credit
 
rating
 
scale. In
 
particular,
 
the Company
 
considers
 
financial
assets as credit impaired if the internal rating
 
of the counterparty corresponds to a rating
 
equivalent to "C" (Moody's rating
 
scale).
Significant increase in credit risk (SICR) and staging allocation
Determining
 
whether
 
a
 
loss
 
allowance
 
should
 
be
 
based
 
on
 
12-month
 
expected
 
credit
 
losses
 
or
 
lifetime
 
expected
 
credit
 
losses
depends on whether there has been a significant increase in credit
 
risk (SICR) of the financial assets since initial recognition.
At
 
each reporting
 
date,
 
the Company
 
performs
 
an assessment
 
as to
 
whether
 
the risk
 
of a
 
default
 
occurring over
 
the remaining
expected lifetime
 
of the
 
exposure has
 
increased significantly
 
from the
 
expected risk
 
of a default
 
estimated at
 
origination for
 
that
point in time.
Specifically, the assessment
 
of SICR is performed on an individual basis based on the number of notches downgrade
 
in the internal
credit rating scale since the origination date.
 
 
 
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Measurement of Expected Credit Losses/ECL Key Inputs
The ECL calculations
 
are based on
 
the term structures
 
of the probability
 
of default (PD),
 
the loss
 
given default (LGD) and
 
the exposure
at
 
default
 
(EAD). Generally,
 
these parameters
 
are
 
based on
 
observed
 
point-in-time and
 
historical
 
data,
 
derived
 
by international
rating agencies.
The PDs are obtained by an
 
international rating agency using risk methodologies that
 
maximize the use of objective non-judgmental
variables and market data. The Company
 
assigns internal credit ratings to each counterparty
 
based on these PDs.
The Exposure at default
 
(EAD) is an estimate of
 
the exposure at a future
 
default date, taking
 
into account expected
 
changes in the
exposure after the reporting date.
The LGD is typically
 
based on historical
 
data derived mainly
 
from rating
 
agencies’ studies but may
 
also be determined
 
considering
the existing and expected liabilities structure
 
of the obligor and macroeconomic environment.
Presentation of impairment allowance
For financial assets measured at amortized cost, impairment allowance is
 
recognized as a loss allowance reducing the gross
 
carrying
amount of the financial assets in the balance sheet. The respective ECL
 
is recognised within impairment losses.
Write-off of financial assets
Where the Company has no reasonable expectations of recovering
 
a financial asset either in its entirety or a portion of it, the gross
carrying amount of that
 
instrument is reduced directly,
 
partially or in full, against
 
the impairment allowance. The
 
amount written-
off is considered as derecognized. Subsequent recoveries of amounts
 
previously written off decrease the amount
 
of the impairment
losses in the income statement.
2.2.9 Income tax
Income tax consists of current and
 
deferred tax.
(i) Current income tax
Income tax payable
 
on profits, based
 
on the applicable
 
tax law and
 
the tax rate
 
enacted at the reporting
 
date, is recognized
 
as an
expense in the period in which profits arise.
(ii) Deferred tax
Deferred
 
tax is
 
provided
 
in full,
 
using the
 
liability method,
 
on temporary
 
differences
 
arising between
 
the tax
 
base of
 
assets and
liabilities and
 
their carrying
 
amounts in
 
the financial
 
statements.
 
Deferred
 
tax assets
 
and liabilities are
 
measured at
 
the tax
 
rates
that are expected
 
to apply to the
 
period when the asset
 
is realized or
 
the liability is settled,
 
based on tax
 
rates (and tax
 
laws) that
have been enacted or substantively enacted
 
by the balance sheet date.
Deferred
 
tax
 
assets are
 
recognized
 
where
 
it is
 
probable
 
that
 
future taxable
 
profit
 
will be
 
available against
 
which the
 
temporary
differences can be utilized. The carrying amount of deferred tax assets is reviewed at each
 
reporting date and reduced to the extent
that it is no longer probable that sufficient taxable profits will be available to allow all or part of the
 
asset to be recovered. Any such
reduction is reversed to the extent that it becomes probable that sufficient taxable profit will be available. The Company recognises
a previously
 
unrecognised
 
deferred
 
tax asset
 
to the
 
extent
 
that it
 
has become
 
probable
 
that future
 
taxable
 
profit will
 
allow the
deferred tax asset to be recovered.
 
The deferred tax asset on income tax losses
 
carried forward is recognized as an
 
asset when it is
probable that future taxable profits
 
will be available against which these losses can be utilized.
The
 
Company
 
has
 
applied the
 
mandatory
 
temporary
 
exception
 
(relief) to
 
the
 
requirement
 
of IAS
 
12 and
 
does
 
not recognise
 
or
disclose information about deferred
 
taxes arising from the Pillar Two
 
Income taxes.
(iii) Uncertain tax positions
The Company determines and assesses all material tax positions taken,
 
including all, if any, significant uncertain positions,
 
in all tax
years that are still subject
 
to assessment (or when
 
the litigation is in
 
progress) by relevant tax authorities. In
 
evaluating tax positions,
the
 
Company
 
examines
 
all
 
supporting
 
evidence
 
(Ministry
 
of
 
Finance
 
circulars,
 
individual
 
rulings,
 
case
 
law,
 
past
 
administrative
practices, ad hoc tax/legal
 
opinions etc.) to the
 
extent they are applicable
 
to the facts and
 
circumstances of the particular
 
Company’s
case/ transaction.
 
 
 
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In addition, judgments concerning the recognition of a provision against the possibility of
 
losing some of the tax positions are highly
dependent on advice received from internal/
 
external legal counselors. For
 
uncertain tax positions with a high level of uncertainty,
the Company recognizes, on a
 
transaction by transaction basis,
 
or together as a
 
group, depending on
 
which approach better predicts
the
 
resolution
 
of
 
the
 
uncertainty
 
using
 
an
 
expected
 
value
 
(probability-weighted
 
average)
 
approach:
 
(a)
 
a
 
provision
 
against
 
tax
receivable which has been booked
 
for the amount of income tax
 
already paid but further pursued
 
in courts or (b) a liability for
 
the
amount which is expected to be paid to the tax authorities. The Company presents in its balance sheet all uncertain tax balances as
current or deferred tax
 
assets or liabilities.
The Company as a general rule has opted to obtain
 
an ‘Annual Tax
 
Certificate’,
 
which is issued after a tax audit is performed by the
same statutory
 
auditor or audit firm
 
that audits the
 
annual financial statements.
 
Further information
 
in respect of the
 
Annual Tax
Certificate and the related tax
 
legislation, is provided in note 8.
2.2.10 Employee benefits
(i) Short term benefits
Short term employee benefits are those
 
expected to be settled wholly before
 
twelve months after the end of the annual reporting
period in which the employees render the related
 
services and are expensed as these services are provided.
(ii) Pension obligations
The Company provides
 
a number of defined
 
contribution pension
 
plans where annual
 
contributions are invested
 
and allocated to
specific asset categories. Eligible
 
employees are entitled to the
 
overall performance of the investment. The
 
Company's contributions
are recognized as employee benefit
 
expense in the year in which they are paid.
(iii) Standard legal staff retirement indemnity obligations (SLSRI) and termination
 
benefits
The
 
Company
 
operates
 
unfunded
 
defined
 
benefit
 
plans,
 
under
 
the
 
regulatory
 
framework.
 
In
 
accordance
 
with
 
the
 
local
 
labor
legislation,
 
the
 
Company
 
provides
 
for
 
staff
 
retirement
 
indemnity
 
obligation
 
for
 
employees
 
which
 
are
 
entitled
 
to
 
a
 
lump
 
sum
payment based
 
a) on the
 
number of years
 
of service, as
 
of the date
 
when employee
 
service first
 
leads to benefits
 
under the plan
until the date when further employee
 
service will lead to no material amount
 
of further benefits, and b) the level
 
of remuneration
at the date of retirement,
 
if they remain in the employment of the
 
Company until normal retirement
 
age. More specifically,
 
in line
with the decision of IFRIC Committee for IAS 19 fact pattern issued in May 2021, the attribution of the benefit begins from the date
when the employee
 
service first
 
leads to benefits
 
under the terms
 
of the plan,
 
and not from
 
the employment date,
 
until the date
when further employee service will lead to no material amount of further
 
benefits.
In addition,
 
the Company
 
provides termination
 
benefits mainly
 
in respect
 
of the
 
Voluntary
 
Exit Schemes
 
(VES), which
 
have been
implemented through
 
either lump-sum payments
 
or long-term leaves
 
during which
 
the employees will
 
be receiving a
 
percentage
of
 
a
 
monthly
 
salary,
 
or
 
a
 
combination
 
thereof.
 
Provision
 
has
 
been
 
made
 
for
 
the
 
actuarial
 
value
 
of
 
the
 
lump
 
sum
 
payable
 
on
retirement
 
(SLSRI)
 
and
 
termination
 
benefits
 
using
 
the
 
projected
 
unit
 
credit
 
method.
 
Under
 
this
 
method
 
the
 
cost
 
of
 
providing
retirement
 
indemnities and
 
termination benefits
 
is charged
 
to the
 
income statement
 
so as
 
to spread
 
the cost
 
over the
 
period of
service of the employees, in accordance with the respective actuarial
 
valuations which are performed every year.
The SLSRI and termination benefits obligation is calculated as the
 
present value of the estimated future cash outflows using interest
rates of
 
high quality corporate
 
bonds. The currency
 
and term to
 
maturity of the
 
bonds used are
 
consistent with
 
the currency
 
and
estimated term
 
of the retirement
 
benefit obligations.
 
Actuarial gains
 
and losses that
 
arise in calculating
 
the Company’s
 
SLSRI and
termination benefits obligations
 
are recognized
 
directly in other comprehensive
 
income in the period
 
in which they occur
 
and are
not reclassified to the income statement
 
in subsequent periods.
Interest cost
 
on the staff
 
retirement indemnity
 
and termination
 
benefits obligations,
 
as well as
 
service cost,
 
consisting of
 
current
service cost, past service cost and gains or losses on settlement
 
are recognized in the income statement.
Termination benefits are payable when employment is
 
terminated by the Company
 
before the normal retirement date,
 
or whenever
an employee accepts voluntary redundancy
 
in exchange for these benefits
 
(including those in the context of
 
the VES implemented
by the Company). The Company recognizes termination benefits at the earlier of the following dates: (a) when the Company can no
longer
 
withdraw
 
the
 
offer
 
of
 
those
 
benefits;
 
and
 
(b)
 
when
 
the
 
Company
 
recognizes
 
costs
 
for
 
a
 
restructuring
 
that
 
involves
 
the
payment of
 
termination benefits.
 
Any reversals
 
of the SLRSI
 
obligation arising
 
from employees
 
that are
 
included in the
 
long-term
leaves
 
scheme
 
are
 
accounted
 
for
 
as
 
a
 
curtailment
 
gain
 
recognized
 
in
 
the
 
income
 
statement.
 
In
 
the
 
case
 
of
 
an
 
offer
 
made
 
to
 
 
 
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encourage voluntary
 
redundancy,
 
the termination
 
benefits are measured
 
based on the
 
number of employees
 
expected to
 
accept
the offer. Termination benefits falling due more than 12
 
months after the
 
end of the
 
reporting period are
 
discounted to their present
value.
(iv) Performance-based cash payments
The Company's Management awards high performing employees with bonuses in cash, from time to time, on a discretionary basis.
Cash
 
payments
 
requiring
 
only
 
Management
 
approval
 
are
 
recognized
 
as
 
employee
 
benefit
 
expenses
 
on
 
an
 
accrual
 
basis.
 
Cash
payments requiring General
 
Meeting approval as distribution of
 
profits to staff
 
are recognized as
 
employee benefit expense in the
accounting period that they are approved
 
by the Company’s shareholders.
(v) Share-based payments
The Company’s Management awards
 
employees with bonuses in the form of shares and share options on a discretionary basis and
after taking
 
into
 
account the
 
current
 
legal framework.
 
Non-performance
 
related
 
shares vest
 
in the
 
period granted.
 
Share based
payments
 
that
 
are
 
contingent
 
upon
 
the
 
achievement
 
of
 
a
 
performance
 
and
 
service
 
condition,
 
vest
 
only
 
if
 
both
 
conditions
 
are
satisfied.
The fair
 
value of
 
the share
 
options granted
 
is recognized
 
as an
 
employee benefit
 
expense over
 
the vesting
 
period,
 
with an
 
equal
credit in equity
 
i.e. no impact on
 
the Company’s
 
equity. The
 
amount ultimately recognised
 
as an expense
 
is based on the
 
number
of awards that meet the related
 
service and non-market performance conditions at the
 
vesting date.
The fair value of the share
 
options at grant date
 
is determined by using an adjusted
 
option pricing model which takes
 
into account
the exercise
 
price, the
 
exercise
 
dates,
 
the term
 
of the
 
option, the
 
share
 
price at
 
grant
 
date
 
and expected
 
price volatility
 
of the
underlying share, the
 
expected dividend yield
 
and the risk-free
 
interest rate
 
for the term
 
of the options.
 
The expected volatility
 
is
measured at the grant date of the options
 
and is based on the historical volatility of the share price.
For share-based payment awards with non-vesting conditions, the fair
 
value of the share-based payment at grant date also reflects
such conditions and there is no true-up for differences
 
between expected and actual outcomes.
When the options are exercised and new shares are issued, the proceeds received net
 
of any directly attributable transaction costs
are credited to share capital
 
(par value) and share premium.
Share
 
options
 
granted
 
by the
 
Company
 
to
 
employees
 
of
 
group
 
entities
 
are
 
treated
 
as
 
a contribution
 
by
 
the Company
 
to
 
these
entities, thus increasing the investment cost
 
in them.
2.2.11 Related party transactions
Related parties of the Company include:
(a) an entity that
 
has control over
 
the Company and
 
entities controlled, jointly
 
controlled or significantly
 
influenced by this entity,
as well as members of its key management
 
personnel and their close family members;
(b) an entity that has significant influence over the
 
Company and entities controlled by this entity;
(c) members of key management personnel of
 
the Company, their close family members and entities
 
controlled or jointly controlled
by the abovementioned persons;
(d) subsidiaries; and
(e) post-employment benefit plans established
 
for the benefit of the Group’s
 
employees.
Transactions
 
of similar nature are disclosed
 
on an aggregate basis. All
 
banking transactions entered into
 
with related parties are in
the normal course of business and are conducted on an arm's length
 
basis.
2.2.12 Provisions and contingent liabilities
Provisions are recognized when the Company
 
has a present legal or constructive obligation
 
as a result of past events, it is probable
that an
 
outflow of resources
 
embodying economic benefits
 
will be required
 
to settle
 
the obligation,
 
and reliable estimates
 
of the
amount of the obligation can be made.
 
 
 
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The amount
 
recognized
 
as a
 
provision
 
is the
 
best
 
estimate
 
of the
 
expenditure
 
required
 
to settle
 
the present
 
obligation
 
at each
reporting date,
 
taking into
 
account the
 
risks and
 
uncertainties surrounding
 
the amount
 
of such expenditure.
 
Where the
 
effect of
the time value of
 
money is material, the amount of
 
the provision is the
 
present value of the estimated future expenditures expected
to be required to settle the obligation.
Provisions are
 
reviewed at
 
each reporting
 
date and
 
adjusted to
 
reflect the
 
current best
 
estimate. If,
 
subsequently,
 
it is
 
no longer
probable
 
that
 
an
 
outflow
 
of
 
resources
 
embodying
 
economic
 
benefits
 
will
 
be
 
required
 
to
 
settle
 
the
 
obligation,
 
the
 
provision
 
is
reversed.
A provision
 
is not
 
recognized
 
and a
 
contingent
 
liability is
 
disclosed when
 
it is
 
not probable
 
that
 
an outflow
 
of resources
 
will be
required to
 
settle the obligation,
 
when the amount
 
of the obligation
 
cannot be measured
 
reliably or in
 
case that the
 
obligation is
considered possible and is subject to the occurrence or non-occurrence
 
of one or more uncertain future events.
2.2.13 Share capital
Ordinary shares and preference
 
shares are classified as equity.
 
Incremental costs directly attributable
 
to the issue of new shares or
options are shown in equity as a deduction from the proceeds, net
 
of tax.
Dividend distribution
 
on shares
 
is recognized
 
as a
 
deduction in
 
the Company’s
 
equity when
 
approved by
 
the General
 
Meeting of
shareholders
 
and the
 
required regulatory
 
approvals,
 
if any,
 
are obtained.
 
Interim dividends
 
are recognized
 
as a
 
deduction in
 
the
Company's equity when approved by the Board
 
of Directors.
Intercompany
 
non-cash
 
distributions
 
that
 
constitute
 
transactions
 
between
 
entities
 
under
 
common
 
control
 
are
 
recorded
 
in
 
the
Company’s equity by reference
 
to the book value of the assets distributed.
Where the Company purchases own shares (treasury shares), the consideration paid including any directly attributable incremental
costs (net
 
of income
 
taxes), is
 
deducted from
 
shareholders’ equity
 
until the
 
shares are
 
cancelled, reissued
 
or disposed
 
of. Where
such shares are subsequently sold or reissued, any
 
consideration received is included in shareholders’
 
equity.
2.2.14 Cash and cash equivalents
Cash and cash equivalents include cash in hand and due from credit
 
institutions that are all carried at amortized
 
cost.
3.
 
Critical accounting estimates and judgments in applying accounting policies
In
 
the
 
process
 
of
 
applying
 
the
 
Company’s
 
accounting
 
policies,
 
the
 
Management
 
makes
 
various
 
judgments,
 
estimates
 
and
assumptions
 
that
 
may
 
affect
 
the
 
reported
 
amounts
 
of
 
assets
 
and
 
liabilities,
 
revenues
 
and
 
expenses
 
recognized
 
in
 
the
 
financial
statements
 
within the
 
next financial
 
year and
 
the accompanying
 
disclosures. Estimates
 
and judgments
 
are continually
 
evaluated
and
 
are
 
based
 
on
 
current
 
conditions,
 
historical
 
experience
 
and
 
other
 
factors,
 
including
 
expectations
 
of
 
future
 
events
 
that
 
are
believed to be reasonable under the circumstances.
 
Revisions to estimates are recognized
 
prospectively.
The most significant
 
areas in which the
 
Company makes
 
judgments, estimates and
 
assumptions in applying its
 
accounting policies
are set out below:
3.1
Impairment losses on financial assets
The expected
 
credit losses
 
(ECL) measurement
 
of financial
 
instruments requires
 
management to
 
apply judgement
 
relating to
 
the
risk parameters
 
used in
 
the calculation
 
of the
 
ECL and
 
in assessing
 
whether
 
a significant
 
increase of
 
credit
 
risk (SICR)
 
event
 
has
occurred
 
since
 
initial
 
recognition.
 
These
 
estimates
 
are
 
based
 
on
 
quantitative
 
and
 
qualitative
 
information
 
reasonable
 
and
supportable forward looking information. A degree of uncertainty is involved
 
in making estimations using assumptions that may be
subjective and sensitive to the risk factors.
Specifically, the assessment
 
of SICR is performed on an individual basis based on the number of notches downgrade
 
in the internal
credit
 
rating
 
scale since
 
the origination
 
date,
 
while the
 
PD used
 
for
 
the ECL
 
measurement
 
is received
 
by an
 
international
 
rating
agency using
 
risk methodologies
 
that
 
maximize
 
the use
 
of observable
 
variables
 
and market
 
data.
 
Furthermore,
 
the LGD
 
used is
based on historical data
 
derived from rating
 
agencies’ studies that present
 
the recoveries on such
 
instruments taking into
 
account
the seniority of the exposure.
 
The
 
Company
 
independently
 
validates
 
all
 
ECL
 
key
 
inputs
 
and
 
underlying
 
assumptions
 
used
 
in
 
the
 
ECL
 
measurement
 
through
competent resources.
 
 
 
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3.2
Impairment losses on investment in subsidiaries
The Company assesses
 
for impairment its
 
investment in subsidiaries at
 
each reporting date
 
as described in
 
note 2.2.4. If
 
an indication
of impairment exists, the
 
Company performs an impairment test
 
by comparing the carrying
 
value of the
 
investment in the subsidiary
with its
 
estimated
 
recoverable
 
amount, determined
 
as the
 
higher of
 
its fair
 
value less
 
cost to
 
sell and
 
its value
 
in use,
 
based on
reasonable and supportable information. The calculation of the recoverable amount involves the exercise of judgement in selecting
the appropriate parameters,
 
such as the applicable discount and growth rates.
3.3 Income tax
The Company
 
is subject
 
to income
 
taxes
 
and estimates
 
are required
 
in determining
 
the liability
 
for
 
income taxes.
 
The Company
recognizes liabilities
 
for anticipated
 
tax audit issues
 
based on estimates
 
of whether additional
 
taxes will
 
be due or
 
for anticipated
tax
 
disputes.
 
Where
 
the
 
final
 
tax
 
outcome
 
of
 
these
 
matters
 
is
 
different
 
from
 
the
 
amounts
 
that
 
were
 
initially
 
recorded,
 
such
differences will impact the income tax in the
 
period in which such determination is made.
In addition, the
 
Company recognizes deferred tax assets to
 
the extent that it
 
is probable that
 
sufficient taxable profit will be
 
available
against
 
which unused
 
tax
 
losses and
 
deductible temporary
 
differences
 
can be
 
utilized.
 
Recognition
 
therefore
 
involves
 
judgment
regarding the future financial performance of the Company.
 
As at 31 December 2024, based on the Management’s assessment the
Company is not expected to have sufficient
 
future taxable profits, against
 
which the unused tax losses can be utilized (note
 
8).
3.4 Retirement and termination benefit obligations
The present value of the retirement
 
and termination benefits’ obligations
 
depends on a number of factors
 
that are determined on
an
 
actuarial
 
basis
 
using
 
a
 
number
 
of
 
assumptions,
 
such
 
as
 
the discount
 
rate
 
and
 
future
 
salary
 
increases.
 
Any
 
changes
 
in
 
these
assumptions impact the carrying amount of the respective benefits’
 
obligations.
The
 
Company
 
determines
 
the
 
appropriate
 
discount
 
rate
 
used
 
to
 
calculate
 
the
 
present
 
value
 
of
 
the
 
estimated
 
retirement
 
and
termination
 
benefits’
 
obligations,
 
at
 
the end
 
of
 
each year
 
with reference
 
to
 
interest
 
rates
 
of
 
high quality
 
corporate
 
bonds. The
currency and term
 
to maturity of
 
the bonds used
 
are consistent
 
with the currency
 
and estimated average
 
term to maturity
 
of the
retirement
 
benefit
 
obligations.
 
The
 
salary
 
rate
 
increase
 
assumption
 
is
 
based
 
on
 
future
 
inflation
 
estimates
 
reflecting
 
also
 
the
Company's reward structure
 
and expected market conditions.
Other assumptions
 
for retirement
 
and termination
 
benefits’ obligations,
 
such as
 
future inflation
 
estimates,
 
are based
 
in part
 
on
current and expected market
 
conditions.
For
 
information
 
in
 
respect
 
of
 
the
 
sensitivity
 
analysis
 
of
 
the
 
Company’s
 
retirement
 
and
 
termination
 
benefits’
 
obligations
 
to
reasonably
 
possible,
 
at
 
the
 
time
 
of
 
preparation
 
of
 
these
 
financial
 
statements,
 
changes
 
in
 
the
 
abovementioned
 
key
 
actuarial
assumptions, refer to note 13.
3.5 Share-based payments
The Company
 
grants
 
shares and
 
share options
 
to its
 
employees as
 
well as
 
the employees
 
of the
 
Group’s
 
entities, as
 
a common
feature of employee remuneration.
For shares granted to employees, the fair value is measured directly at the market
 
price of the entity’s shares, adjusted to take into
account
 
the terms
 
and conditions
 
upon which
 
the shares
 
were granted.
 
For share
 
options granted
 
to employees,
 
in many
 
cases
market prices are not available because
 
the options granted are subject to
 
terms and conditions that
 
do not apply to
 
traded options.
If this
 
is the
 
case, the
 
Company estimates
 
the fair
 
value of
 
the equity
 
instruments granted
 
using a
 
valuation technique,
 
which is
consistent with generally accepted
 
valuation methodologies.
The
 
valuation
 
method
 
and the
 
inputs
 
used to
 
measure
 
the share
 
options
 
granted
 
to
 
employees
 
of
 
the
 
Company
 
and its
 
Group
entities are presented in note 16.
4.
 
Financial risk management and fair value
The Company
 
is exposed
 
to financial
 
risks such
 
as credit
 
risk, market
 
risk (including
 
currency and
 
interest
 
rate risk)
 
liquidity risk,
operational risk and other non-financial risks, as well as to sustainability
 
risks.
 
 
 
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Statements
4.1
 
Financial risk factors and risk management
As part of its overall system of internal controls the Company has engaged in a Service Level Agreement (SLA) with Eurobank S.A. in
order
 
to
 
receive
 
supporting
 
and advisory
 
services in
 
all applicable
 
areas
 
of
 
risk
 
management
 
(credit,
 
market,
 
liquidity
 
and non-
financial risks) undertaken by the Company.
The
 
Company’s
 
overall
 
risk
 
management
 
strategy
 
seeks
 
to
 
minimize
 
any
 
potential
 
adverse
 
effects
 
on
 
its
 
financial
 
performance,
financial position and cash flows.
The main financial risks to which the Company is exposed relate
 
to:
(a) Credit risk
The Company takes
 
on exposure to
 
credit risk which
 
is the risk that
 
a counterparty will
 
be unable to
 
fulfill its payment
 
obligations
in
 
full
 
when
 
due.
 
The
 
Company
 
is
 
exposed
 
to
 
credit
 
risk
 
arising
 
mainly
 
from
 
subordinated
 
instruments
 
(note
 
9)
 
issued
 
by
 
its
subsidiary Eurobank S.A. and
 
from its deposits that
 
are placed with the
 
latter of € 265
 
million. Accordingly,
 
the aggregate
 
carrying
amount of the above financial assets approximates
 
the maximum credit risk exposure of the Company.
(b) Market risk
The Company
 
takes
 
on exposure
 
to market
 
risk, which
 
is the
 
risk of
 
potential
 
financial loss
 
due to
 
an adverse
 
change in
 
market
variables, such as interest rates
 
and foreign exchange rates.
The
 
Company’s
 
interest
 
rate
 
risk,
 
which
 
relates
 
to
 
the
 
position
 
in
 
the
 
aforementioned
 
subordinated
 
fixed
 
rate
 
instruments,
 
is
eliminated by
 
the subordinated
 
Tier II
 
debt instruments
 
issued by
 
the Company,
 
which have
 
equivalent
 
terms with
 
those of
 
the
forme
r.
With respect to the deposits and borrowing of the Company, a sensitivity analysis is performed to assess the impact on net interest
income (NII) to a hypothetical change in the market
 
interest rates.
The impact on NII is calculated
 
under the scenario of an instantaneous
 
parallel shift of all interest
 
rates by +/-
 
100bps, for a 1-year
period, assuming a static balance sheet
 
approach. As at 31 December 2024 the
 
impact on NII, under the scenario of a parallel
 
shift
in
 
the yield
 
curves, stands
 
at
 
€ 2
 
million
 
(+100bps)
 
and €
 
-2 million
 
(-100bps)
 
(31 December
 
2023: €
 
2 million
 
and €
 
-2 million,
respectively).
The Company’s financial assets and liabilities are
 
in Euro, therefore, currency
 
risk is eliminated.
(c) Liquidity risk
The maturity
 
of the Company’s
 
main assets
 
and liabilities, which
 
relate to
 
the aforementioned
 
subordinated instruments,
 
match,
and
 
the
 
underlying
 
cash
 
flows
 
are
 
the
 
same.
 
Accordingly,
 
the
 
Company’s
 
liquidity
 
or
 
cash
 
flow
 
risk
 
for
 
these
 
instruments
 
is
substantially eliminated. In addition, the majority of the Company’s
 
aforementioned deposits with Eurobank S.A. mature within six
months.
(d) Sustainability risks
Sustainability
 
risks
 
are
 
defined
 
as
 
potential
 
losses
 
arising
 
from
 
any
 
negative
 
financial
 
impact
 
for
 
the
 
Company,
 
stemming
 
from
current or prospective impacts of any climate-related & environmental, social or governance event(s) on Company’s counterparties
or invested assets.
4.2
 
Fair value of financial assets and liabilities
The Company’s financial instruments carried at amortized cost are categorised into the three levels of fair value hierarchy
 
based on
whether the inputs to their fair values are market
 
observable or unobservable, as follows:
Level 1
 
- Financial instruments
 
are measured
 
based on quoted
 
prices (unadjusted)
 
in active
 
markets for
 
identical financial
instruments that the Company
 
can access at the measurement
 
date. A market
 
is considered active when quoted
 
prices are
readily and
 
regularly available
 
from an
 
exchange, dealer,
 
broker,
 
industry group,
 
pricing service, or
 
regulatory agency
 
and
represent actually and regularly occurring transactions. The Company’s financial instruments
 
categorised into Level 1 of the
fair
 
value
 
hierarchy
 
refer
 
to
 
certain
 
subordinated
 
instruments
 
issued
 
by
 
its
 
subsidiary,
 
Eurobank
 
S.A.
 
and
 
held
 
by
 
the
Company (note 9) and the related subordinated
 
Tier II instruments issued by the Company (note 12).
 
 
 
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2024 Financial
 
Statements
Level
 
2
 
 
Financial
 
instruments
 
are
 
measured
 
using
 
valuation
 
techniques
 
with
 
inputs
 
other
 
than
 
level
 
1
 
quoted
 
prices,
observable either directly or indirectly, such as (i)
 
quoted prices for similar financial instruments in
 
active markets (ii) quoted
prices for identical financial instruments in markets that are
 
not active, (iii) inputs other than quoted prices that are directly
or indirectly observable, mainly interest rates and yield curves observable at commonly quoted intervals, forward
 
exchange
rates, equity
 
prices, credit spreads
 
and implied volatilities
 
obtained from
 
internationally recognised
 
market data
 
providers
and (iv) other
 
unobservable inputs which
 
are insignificant to
 
the entire
 
fair value
 
measurement.
As at 31
 
December 2024,
none of the Company’s financial instruments
 
were categorized into
 
Level 2 of the fair value hierarchy.
Level
 
3
 
-
 
Financial
 
instruments
 
are
 
measured
 
using
 
valuation
 
techniques
 
with
 
significant
 
unobservable
 
inputs.
 
When
developing
 
unobservable
 
inputs,
 
best
 
information
 
available
 
is used,
 
including own
 
data,
 
while
 
at
 
the
 
same
 
time
 
market
participants’
 
assumptions
 
are
 
reflected
 
(e.g.
 
assumptions
 
about
 
risk).
 
The
 
Company’s
 
financial
 
instruments,
 
which
 
are
categorised into Level 3
 
of the fair
 
value hierarchy refer to the deposits
 
with Eurobank S.A.,
 
certain subordinated instruments
issued by its
 
subsidiary,
 
Eurobank S.A. and
 
held by the
 
Company (note
 
9) and the
 
related subordinated
 
Tier II instruments
issued by the Company (note 12).
Company's valuation processes and techniques
The fair
 
value of
 
the subordinated
 
Tier II
 
debt instruments
 
issued by
 
the Company
 
(note 12)
 
is determined
 
using quoted
 
market
prices, if available. If quoted
 
prices are not available, fair
 
values are determined based on
 
third party valuations, quotes
 
for similar
debt securities or by
 
discounting the expected cash flows at
 
a risk-adjusted rate, where the Company’s own credit risk is
 
determined
using inputs indirectly
 
observable, i.e. quoted
 
prices of similar
 
securities issued by
 
the Group or
 
other Greek issuers.
 
For the year
ended 31
 
December 2024,
 
the Company
 
has enhanced
 
the methodology
 
applied for
 
the classification
 
of debt
 
securities into
 
the
three levels of
 
the fair value
 
hierarchy,
 
by assigning a
 
rating scale for
 
each debt security,
 
based on the quality
 
and quantity of the
market
 
data
 
inputs used
 
to
 
calculate
 
its fair
 
price at
 
a specific
 
date.
 
The debt
 
securities are
 
then
 
allocated
 
into
 
levels based
 
on
specific rating thresholds representing
 
highly liquid to thinly traded debt securities.
 
Based on the above, as at 31 December 2024, the fair value of the Company’s Tier II debt instruments issued by the Company (note
12) classified at Level 1 of the fair value hierarchy amounted to € 691 million, while those categorized at Level 3 amounted to
 
€ 954
million (2023: € 1,226 million categorized at
 
Level 2).
 
Respectively,
 
the fair
 
value of
 
the debt
 
instruments
 
issued by
 
the Bank
 
and held
 
by the
 
Company
 
(note 9),
 
which is
 
determined
based on the valuation of the related subordinated Tier II debt instruments issued by the Company,
 
amounted to € 1,645 million, €
691 million
 
of
 
which were
 
categorized
 
at
 
Level
 
1 of
 
the
 
fair value
 
hierarchy
 
and €
 
954 million
 
at
 
Level
 
3 (2023:
 
€ 1,226
 
million
categorized at Level 2).
 
Moreover,
 
the carrying amount of the Company’s borrowing and deposits with Eurobank
 
S.A. represent reasonable approximation
of their fair value.
5.
 
Net interest income
In the
 
year
 
ended 31
 
December 2024,
 
the interest
 
expense
 
that
 
was
 
recognised
 
in the
 
income statement
 
mainly relates
 
to
 
the
subordinated Tier II instruments issued by the Company,
 
while the interest income of a similar amount relates to the
 
subordinated
Tier II notes issued by Eurobank S.A. and held by the Company.
 
 
 
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Notes to the Financial Statements
 
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31 December
 
2024 Financial
 
Statements
6.
 
Other income/(expenses)
In the year ended 31 December 2024, other income /(expenses),
 
amounting to € 4 million (2023: € 4 million), consist
 
of € 2 million
income from IT
 
services (2023: € 3 million)
 
and € 2 million income
 
regarding loan
 
portfolio’s related
 
services provided to the
 
Bank
(2023: € 1 million).
7.
 
Operating expenses
In the year ended 31 December 2024, the operating
 
expenses of € 10 million (2023: € 11 million) mainly refer:
 
a) to staff cost € 5.0
million (2023: € 4.4
 
million) and b) other administrative expenses €
 
5.4 million (2023: €
 
6.3 million). Administrative expenses include
€ 3.7
 
million
 
(2023: €
 
4.3 million)
 
insurance
 
premiums
 
relating
 
to
 
the
 
Group’s
 
financial lines
 
insurance,
 
including protection
 
for
professional liability.
8.
 
Income tax
According
 
to Law
 
4172/2013 currently
 
in force,
 
the Greek
 
corporate
 
tax rate
 
for
 
legal entities
 
other than
 
credit institutions
 
(i.e.
credit institutions that fall
 
under the requirements of article 27A
 
of Law 4172/2013 regarding eligible DTAs/deferred
 
tax credits) is
22%.
 
In
 
addition,
 
the
 
withholding
 
tax
 
rate
 
for
 
dividends
 
distributed,
 
other
 
than
 
intragroup
 
dividends,
 
is
 
5%.
 
In
 
particular,
 
the
intragroup dividends under certain preconditions
 
are relieved from both income and withholding tax.
For the year ended
 
31 December 2024, an
 
amount of € 4 million
 
current income tax
 
has been recognized
 
by the Company related
to the top
 
up tax (see
 
below). Based on
 
the management’s assessment the
 
Company is not
 
expected to have sufficient future
 
taxable
profits against
 
which the unused tax
 
losses can be utilized
 
and accordingly,
 
in the year
 
ended 31 December 2024,
 
no deferred
 
tax
has been recognized in the statement
 
of comprehensive income.
Pillar Two income taxes
The Pillar
 
Two
 
legislation that
 
introduces a
 
minimum global tax
 
rate at
 
15% on multinational
 
entities with
 
consolidated revenues
over € 750 million
 
(top up tax)
 
is effective
 
as of 1
 
January 2024. In
 
accordance with the
 
Pillar Two
 
legislation, the Ultimate
 
Parent
Entity of an
 
MNE Group is
 
primarily liable for the
 
Globe Top-up Tax of all Low-Tax (subject to an ETR below
 
15%) Constituent Entities.
Top-up taxation
 
is mainly triggered when the jurisdictional GloBE
 
ETR is below 15% and is
 
levied on the aggregated Globe Pillar Two
results of all Constituent Entities per jurisdiction.
The
 
Company,
 
as
 
the
 
ultimate
 
parent
 
entity
 
of
 
the
 
Group,
 
has
 
identified
 
potential
 
exposure
 
to
 
Pillar
 
Two
 
income
 
taxes
 
mainly
through its subsidiaries in Bulgaria and Cyprus, containing the operations of
 
Eurobank Cyprus and those of Hellenic
 
Bank group. The
Pillar
 
Two
 
effective
 
tax
 
rate
 
is lower
 
than
 
15%
 
in
 
the
 
above
 
jurisdictions
 
mainly
 
due
 
to
 
their
 
nominal
 
corporate
 
tax
 
rates
 
(CIT)
applying on their profits (i.e.
 
the current CIT in Bulgaria and
 
Cyprus is 10% and 12.5%
 
respectively). For the year ended 31 December
2024, the Group has recognized a current tax expense
 
of € 21.6 million related to the top up tax applicable on the profits earned in
the aforementioned jurisdictions.
For the year
 
2024, the Company
 
is required to
 
pay a Top
 
-up Tax
 
with respect to
 
earnings of Eurobank
 
Cyprus and its
 
subsidiaries,
and the corresponding tax recognized
 
for the year ended 31 December 2024 amounts to € 4 million.
Tax certificate
 
and open tax years
For fiscal years starting from
 
1 January 2016
 
onwards, pursuant to the
 
Tax Procedure Code, an ‘Annual Tax Certificate’ on an optional
basis, is provided
 
for the Greek
 
entities, with annual
 
financial statements
 
audited compulsorily,
 
which is issued after
 
a tax audit
 
is
performed by the same
 
statutory auditor or audit
 
firm that audits
 
the annual financial
 
statements. The Company has opted
 
to obtain
such certificate.
The Company’s
 
open tax years
 
are 2020-2024. The
 
tax certificates,
 
which have been
 
obtained by the Company
 
are unqualified for
the open tax years until 2023, while for
 
the year ended 31 December 2024, the tax audit from external auditor
 
is in progress.
In accordance with the Greek
 
tax legislation and the respective
 
Ministerial Decisions issued, additional
 
taxes and penalties
 
may be
imposed by the Greek tax authorities following a tax audit
 
within the applicable statute of limitations (i.e. five years as from the
 
end
of the
 
fiscal year
 
within
 
which the
 
relevant
 
tax
 
return
 
should have
 
been submitted)
 
,
 
irrespective
 
of whether
 
an unqualified
 
tax
certificate has been obtained from the tax
 
paying company.
 
 
 
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31 December
 
2024 Financial
 
Statements
In reference to its total uncertain tax positions, the Company assesses all relevant
 
developments (e.g. legislative changes, case law,
ad hoc tax/legal opinions, administrative
 
practices) and raises adequate provisions.
Unused tax losses
As at 31 December 2024, the Company has not
 
recognised deferred tax asset (DTA) on unused tax losses amounted to € 276 million
(2023: € 337
 
million). The
 
analysis of
 
unrecognized DTA
 
on unused
 
tax losses
 
of the Company
 
per year
 
of maturity
 
of related
 
tax
losses is presented in the table below:
9.
 
Investment securities
As at 31 December 2024, the
 
total carrying amount of the subordinated debt instruments, issued by the
 
Bank, held by the Company
and categorised as at amortized
 
cost, amounted to € 1,556 million (31 December 2023: € 1,277 million), including
 
accrued interest
of
 
€ 15.2
 
million
 
(31
 
December
 
2023: €
 
32.9 million),
 
€ 6.5
 
unamortized
 
issuance
 
costs
 
(31 December
 
2023:
 
 
4.2 million)
 
and
impairment
 
allowance
 
of
 
 
2.5
 
million
 
(31
 
December
 
2023:
 
 
1.5
 
million)
 
(12-month
 
ECL).
 
In
 
particular,
 
in
 
the
 
year
 
ended
 
31
December 2024,
 
the Company
 
recognised
 
in the
 
statement
 
of comprehensive
 
income €
 
1 million
 
loss, in
 
relation
 
to impairment
allowance (31 December 2023: € 1.2 million gain).
Post balance sheet event
In January 2025, the Bank following the issuance of a € 589 million subordinated Tier II debt instrument
 
by the Company (note 12),
issued a subordinated instrument of equivalent
 
terms, held by the Company.
10.
 
Shares in subsidiaries
The following is a listing of the Company's subsidiaries held
 
directly at 31 December 2024:
(a) Be Business
 
Exchanges Single
 
Member Societe Anonyme
 
of Business Exchanges
 
Networks and Accounting
 
and Tax
 
Services,
Greece
 
In September 2024, Εurobank Holdings acquired an additional participation interest of 1.99% in the company, therefore its holding
in the
 
company’s
 
share capital
 
reached 100%.
 
In October
 
2024, following
 
the above
 
transaction,
 
the name
 
of the
 
company
 
was
amended with the inclusion of the term “Single member”.
Initiation of the merger process between Eurobank Ergasias
 
Services and Holdings S.A. and Eurobank S.A.
On 19
 
December 2024,
 
Eurobank Holdings
 
announced that
 
its Board
 
of Directors
 
decided the
 
initiation of
 
the merger
 
process of
Eurobank Holdings with the Bank through absorption of the former by the latter,
 
in order that operational efficiencies and a leaner
group structure be achieved. The merger will be implemented with a combined application of Law 4601/2019 and article 16 of Law
2515/1997 and 31 December 2024, was defined as the merger transformation
 
balance sheet date.
 
 
 
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Notes to the Financial Statements
 
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31 December
 
2024 Financial
 
Statements
Upon the
 
completion of
 
the merger
 
(a) Eurobank
 
Holdings ceases to
 
exist and
 
its shareholders
 
become shareholders
 
of the Bank
with the same
 
stakes and
 
the same number
 
of shares, receiving
 
the entirety
 
of Bank’s
 
newly issued shares
 
and (b) the
 
Bank, that
will
 
retain
 
its
 
banking
 
license,
 
substitutes
 
Eurobank
 
Holdings
 
as
 
universal
 
successor
 
in
 
the
 
totality
 
of
 
its
 
assets
 
and
 
liabilities
transferred to
 
the Bank, as they appear
 
in the transformation
 
balance sheet of Eurobank
 
Holdings and as it is formulated
 
until
 
the
completion of the merger.
Before the
 
completion of
 
the merger,
 
the shares
 
of the Bank
 
will be
 
listed in
 
the Athens
 
Exchange and
 
upon its
 
completion, they
will be distributed
 
to Eurobank Holdings
 
shareholders in
 
exchange of
 
the Eurobank Holdings
 
shares they possess
 
at a ratio
 
of one
newly issued share of the Bank for one existing share
 
of Eurobank Holdings.
The completion
 
of the
 
merger
 
is subject
 
to
 
all necessary
 
by Law
 
approvals,
 
including the
 
approval
 
of the
 
shareholders’
 
General
Meeting of both merging companies as well as the receipt of
 
all the necessary approvals of the competent Authorities.
11.
 
Other assets
As at 31 December 2024, other assets amounting to € 4 million (31 December 2023:
 
€ 4 million) primarily consist of (a) € 1.7 million
(31 December
 
2023: €
 
1.3 million)
 
prepaid expenses
 
mainly for
 
insurance premiums,
 
(b) €
 
1.7 million
 
(31 December
 
2023: €
 
1.2
million) receivables
 
for IT
 
services provided
 
to the
 
Group companies
 
and third
 
parties, (c) €
 
0.3 million (31
 
December 2023:
 
€ 0.3
million)
 
receivables
 
from
 
Fairfax
 
Group
 
relating
 
to
 
financial
 
consulting
 
services
 
(d)
 
 
0.1
 
million
 
in
 
relation
 
to
 
property
 
and
equipment and intangible assets (31 December 2023: € 0.2 million).
12.
 
Debt securities in issue
In January
 
2024, the
 
Company announced
 
the issuance
 
of a
 
€ 300
 
million subordinated
 
Tier II debt
 
instrument which
 
matures in
April 2034, is callable at par in April
 
2029 offering a coupon of 6.25%
 
per annum and is listed on the
 
Luxembourg Stock Exchange’s
Euro MTF market.
 
On the same date,
 
the Bank issued a
 
subordinated instrument
 
of equivalent terms,
 
held by the Company
 
(note
9). Further information about
 
the issue is
 
provided in the relevant announcement
 
published in the
 
Company’s website on 19 January
2024.
Post balance sheet event
In January
 
2025, the
 
Company announced
 
that
 
it has
 
successfully priced
 
the issuance
 
of €
 
400 million
 
subordinated
 
Tier II
 
debt
instruments (New Instruments) which mature
 
in April 2035, are callable at par from 30 January
 
2030 until 30 April 2030, offering a
coupon
 
of
 
4.25%
 
per
 
annum
 
and
 
are
 
listed
 
on
 
the
 
Luxembourg
 
Stock
 
Exchange’s
 
Euro
 
MTF
 
market.
 
In
 
addition,
 
the
 
Company
announced an
 
any-and-all exchange
 
offer for
 
the Tier
 
II notes
 
of its
 
indirect subsidiary,
 
Hellenic Bank,
 
of nominal
 
value of
 
€ 200
million, with additional Eurobank
 
Holdings Tier 2 subordinated
 
notes, issued under a
 
single series and with same
 
terms with the €
400 million subordinated notes. The offer
 
period was set from 21 January 2025 until 27 January 2025.
On 28 January 2025, the Company announced that it has decided to accept all existing notes offered
 
for exchange, pursuant
 
to the
exchange offer,
 
with nominal
 
value of €
 
157 million.
 
The nominal value
 
of new instruments
 
to be issued
 
is € 188.5
 
million, which
will form a single series with the New Instruments with a combined aggregate
 
nominal amount of € 589 million.
13.
 
Other liabilities
As at
 
31 December
 
2024, other
 
liabilities amounting
 
to €
 
6 million
 
(31 December
 
2023: €
 
2 million)
 
primarily consist
 
of (a)
 
€ 0.6
million (31 December 2023: € 0.9 million) accrued expenses, (b) € 0.9 million (31 December 2023: € 0.8 million) current payables to
suppliers
 
and (c)
 
€ 0.2
 
million (31
 
December 2023:
 
€ 0.2
 
million)
 
Standard
 
legal staff
 
retirement
 
indemnity obligations,
 
d) €
 
0.7
million employee termination benefits obligation in respect
 
of the new Voluntary Exit Scheme
 
(VES) that was launched by
 
the Group
in February 2024 and (e) € 4 million income tax payable
 
referring to top up tax (note
 
8).
Standard legal staff retirement
 
indemnity obligations (SLSRI) and termination benefits
The Company provides for staff
 
retirement indemnity obligation for
 
its employees, who are entitled to a lump sum payment based
on the number of years of service and the level of remuneration at the date of retirement, if they remain in the employment of the
Company until
 
normal retirement
 
age, in accordance
 
with the local
 
labor legislation.
 
The above
 
retirement indemnity
 
obligations
typically expose the Company
 
to actuarial risks such
 
as interest rate
 
risk and salary risk. Therefore,
 
a decrease in the discount
 
rate
used to
 
calculate the
 
present value
 
of the
 
estimated
 
future cash
 
outflows or
 
an increase
 
in future
 
salaries will
 
increase the
 
staff
retirement indemnity obligations of
 
the Company.
 
 
 
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In addition, the Company has provided employee termination benefits mainly in
 
respect of the Voluntary Exit Schemes (VES), which
have been
 
implemented through
 
either lump-sum
 
payments or
 
long-term leaves
 
during which
 
the employees
 
will be
 
receiving a
percentage of a monthly salary,
 
or a combination thereof.
The table below presents the breakdown
 
of defined benefit obligations.
The table
 
below presents
 
a reconciliation
 
from the
 
opening to
 
the closing
 
balance for
 
staff retirement
 
indemnity obligations
 
and
employee termination benefits.
For SLSRI obligations the significant actuarial assumptions
 
(expressed as weighted averages)
 
were as follows:
As at 31
 
December 2024, the
 
assumption for
 
the price inflation
 
(weighted average)
 
is 2.0% (2023:
 
2.3%) and has
 
been taken
 
into
account in determining the above actuarial assumptions for
 
future salaries increases.
As at
 
31 December
 
2024, the
 
average
 
duration
 
of the
 
standard
 
legal staff
 
retirement
 
indemnity obligation
 
was 7
 
years
 
(2023: 7
years).
A quantitative
 
sensitivity analysis
 
based on reasonable
 
changes to significant
 
actuarial assumptions
 
as at 31
 
December 2024 is
 
as
follows:
An increase/(decrease)
 
of the
 
discount rate
 
assumed, by
 
50 bps/(50
 
bps), would
 
result in
 
a (decrease)/
 
increase of
 
the standard
legal staff retirement
 
obligations by (€ 0.01 million)/ € 0.01 million.
An increase/(decrease) of the future
 
salary growth assumed, by
 
0.5%/(0.5%), would result in
 
an increase /(decrease) of
 
the standard
legal staff retirement
 
obligations by € 0.01 million/ (€ 0.01 million).
The above sensitivity analysis is based
 
on a change in an assumption while holding
 
all other assumptions constant.
 
In practice, this
is unlikely to occur,
 
and changes in some of the assumptions may be correlated.
The methods
 
and assumptions
 
used in
 
preparing the
 
above sensitivity
 
analysis were
 
consistent
 
with those
 
used to
 
estimate the
retirement benefit obligation
 
and did not change compared to the previous year.
 
 
 
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For
 
employee
 
termination
 
benefits, the
 
discount
 
rate
 
(weighted
 
average)
 
is the
 
significant
 
actuarial assumption,
 
which as
 
at
 
31
December 2024
 
stood
 
at
 
2.5% based
 
on the
 
applicable
 
tenor
 
of the
 
liabilities. On
 
the same
 
date,
 
an increase/(decrease)
 
of the
discount
 
rate
 
assumed,
 
by
 
50 bps/(50
 
bps),
 
would
 
result
 
in
 
a
 
(decrease)/increase
 
of
 
employee
 
termination
 
benefits
 
by
 
(€ 0.01
million)/ € 0.01 million.
14.
 
Share capital, share premium and treasury shares
As at
 
31 December
 
2024, the
 
par value
 
of the
 
Company's shares
 
is €
 
0.22 per
 
share (2023:
 
€ 0.22).
 
All shares
 
are fully
 
paid. The
movement of share capital and share
 
premium is as follows:
AGM decisions
On 23 July 2024, the Annual General Meeting (AGM) of the shareholders
 
of the Company, among others,
 
approved:
The cancellation of 52,080,673 treasury
 
shares acquired in 2023 from
 
Hellenic Financial Stability Fund. Following
 
the said
cancellation, the share capital and the
 
share premium of the Company decreased
 
by € 11,457,748.06 and
 
€ 16,274,764.99,
respectively.
The distribution of a cash
 
dividend of € 342 million from
 
the “Special Reserves” account,
 
following the approval
 
received
from the European
 
Central Bank (ECB)
 
on 5 June 2024
 
(note 15). The said
 
dividend corresponds to
 
a 30% payout
 
ratio of
the Group’s net profit for
 
2023 and a
 
gross dividend of
 
€ 0.09333045
 
per share, following
 
the above cancellation
 
of treasury
shares.
The distribution of € 404,330 to senior management and employees of the Company from the “Special Reserves” account
(note
 
15). In
 
addition, it
 
was noted
 
in AGM
 
that
 
the respective
 
amount
 
that
 
was
 
approved
 
to
 
be distributed
 
to
 
senior
management and employees of the Bank was € 26,237,474.
Share capital increase
Following the exercise
 
of share options granted
 
to executives of the
 
Group under the current
 
share options’ plan (see below), and
by virtue of the decision of
 
the Board of Directors
 
of the Company on 30 August
 
2024, the Company’s share
 
capital increased by
 
2,714,189.50 through the issue of 12,337,225 new common voting shares of a nominal value of € 0.22 per share
 
and exercise price
of €
 
0.23 per
 
share.
 
The difference
 
between
 
the exercise
 
price of
 
the new
 
shares
 
and their
 
nominal value,
 
net of
 
the expenses
directly attributable
 
to the equity transaction,
 
amounted to € 100,899.18
 
and was recorded
 
in the account “Share
 
premium”.
 
The
new shares were listed on the Athens
 
Exchange on 12 September 2024.
 
 
 
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The following is an analysis of the movement in the number of the
 
Company’s shares outstanding:
15.
 
Reserves and retained earnings/(losses)
As of
 
31 December
 
2024, 'Special
 
reserves'
 
of €
 
1,312 million
 
(2023: €
 
1,414 million)
 
relate
 
to
 
dividends
 
from
 
participations.
 
In
particular, in December 2024, the Company recognised € 240 million dividend income, following the Bank’s
 
distribution of reserves
of equal amount to the Company (see below).
Dividends/ Shareholders’ remuneration
In the
 
third quarter
 
of 2024,
 
pursuant to
 
the abovementioned
 
decisions of
 
the AGM
 
of the shareholders
 
of the
 
Company,
 
a cash
dividend of
 
€ 342
 
million was
 
distributed to
 
the shareholders,
 
corresponding
 
to a
 
30% payout
 
ratio of
 
the Group’s
 
net profit
 
for
2023 and a gross dividend of € 0.09333045 per share.
In December 2024, the Bank proceeded with
 
the distribution of non-mandatory reserves
 
for a total amount of €
 
240 million which
is part of the Banks’ overall contribution
 
to its sole shareholder,
 
Eurobank Holdings, in order to enable the latter
 
to remunerate its
shareholders out
 
of the profits
 
of the
 
financial year
 
2024, in
 
accordance with
 
the provisions
 
of article
 
162 par.3
 
of Company
 
Law
4548/2018.
Based on the Group’s financial performance
 
for the financial year 2024, Eurobank Holdings intends to
 
remunerate its shareholders
with an
 
amount corresponding
 
to a 50%
 
payout ratio
 
of the Group’s
 
net profit
 
for 2024
 
less the negative
 
goodwill (€ 99.5
 
million
gain on acquisition
 
of a shareholding in
 
Hellenic Bank), subject to
 
approval of the
 
Annual General Meeting
 
of its shareholders
 
and
the regulatory authorities. The final remuneration
 
will be a combination of cash and share buyback.
16.
 
Share options
The Annual General
 
Meeting of the
 
shareholders of Eurobank
 
Holdings held on
 
28 July 2020 approved
 
the establishment
 
of a five
year shares
 
award plan,
 
starting from
 
2021, in the
 
form of
 
share options
 
rights by
 
issuing new shares
 
with a corresponding
 
share
capital
 
increase,
 
in
 
accordance
 
with
 
the
 
provisions
 
of
 
article
 
113
 
of
 
law
 
4548/2018,
 
awarded
 
to
 
executives
 
and
 
personnel
 
of
Eurobank Holdings and
 
its affiliated companies
 
according to article 32
 
of law 4308/2014. The
 
maximum number of rights
 
that can
 
 
 
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31 December
 
2024 Financial
 
Statements
be approved
 
was set at
 
55,637,000 rights,
 
each of which
 
would correspond
 
to one new
 
share with exercise
 
price equal to
 
€ 0.23.
The Annual General Meeting authorized the Board
 
of Directors of Eurobank Holdings to define
 
the eligible staff and determine the
remaining terms and conditions of the plan.
The final
 
terms and
 
the implementation
 
of the
 
share options
 
plan, which
 
is a
 
forward-looking
 
long-term incentive
 
aiming at
 
the
retention of
 
key executives,
 
are defined
 
and approved
 
annually by the
 
Board of
 
Directors in
 
accordance with
 
the applicable
 
legal
and regulatory framework, as well as the policies of the
 
Company and the Group.
The options are
 
exercisable in
 
portions, annually during
 
a period from
 
one to five
 
years. Each
 
portion may
 
be exercised
 
wholly or
partly and converted into shares
 
at the employees’ option,
 
provided that they remain
 
employed by the
 
Group until the
 
first available
exercise
 
date. Each
 
portion is
 
treated
 
as a
 
separate
 
award with
 
a different
 
vesting period
 
and different
 
fair value.
 
The corporate
actions that adjust the number and the price of shares also adjust accordingly
 
the share options.
The movement of share options during the year is analysed
 
as follows:
In July 2024,
 
the Group
 
awarded to
 
its executives
 
6,822,123 new share
 
options, exercisable
 
in annual portions
 
up to 2029,
 
out of
which 3,076,786 options were exercised
 
during the third quarter of 2024.
From the total
 
number of granted share
 
options exercisable in
 
2024, 12,337,225 options were
 
exercised during
 
the year,
 
resulting
in the issue of an equal number of new common voting shares.
The share options outstanding at the
 
end of the year
 
totaled to 21,348,600 (31 December
 
2023: 26, 863,702) and
 
have the following
expiry dates:
(1)
 
Based on the earliest contractual exercise date.
In accordance with the Company’s accounting
 
policy on employees’ share based payments, the grant
 
date fair value of the options
is recognized
 
as
 
an
 
expense
 
with
 
a corresponding
 
increase
 
in equity
 
over
 
the vesting
 
period. The
 
share
 
options
 
granted
 
by the
Company to employees of Group entities, are treated as a contribution by the Company to the Bank, being their parent entity, thus
increasing the investment cost of the
 
Company in the latter.
The fair
 
value at
 
grant date
 
is determined using
 
an adjusted
 
form of the
 
Black-Scholes model
 
for Bermudan
 
equity options which
takes into
 
account the exercise
 
price, the exercise
 
dates, the term
 
of the option,
 
the share price
 
at grant
 
date and expected
 
price
volatility of the underlying share, the expected dividend
 
yield and the risk-free interest
 
rate for the term of the options.
 
The weighted average
 
fair value of the share options granted
 
in July 2024 was € 1.66 (2023: € 1.13). The significant inputs into
 
the
model were
 
a share
 
price of
 
€ 2.021
 
(2023: €
 
1.442) at
 
the grant
 
date, exercise
 
price of
 
€ 0.23,
 
annualized
 
dividend yield
 
of 3%
(2023:
 
3%),
 
expected
 
average
 
volatility
 
of
 
32%
 
(2023:
 
41%),
 
expected
 
option
 
life
 
of
 
1-5
 
years,
 
and
 
a
 
risk-free
 
interest
 
rate
 
 
 
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2024 Financial
 
Statements
corresponding to the options’ maturities, based on the Euro swap yield curve. The expected volatility is measured at the grant date
of the options and is based on the average historical
 
volatility of the share price.
17.
 
Cash and cash equivalents
For the
 
purpose of
 
the cash
 
flow statement,
 
cash and
 
cash equivalents
 
with original
 
maturities of
 
three months
 
or less,
 
as at
 
31
December 2024, amount to € 25 million (31 December 2023: € 399 million).
In the year ended
 
31 December 2024,
 
the carrying amount of
 
a) the debt securities
 
in issue decreased by
 
€ 16 million
 
due to changes
in accrued
 
interest
 
and amortisation
 
of debt
 
issuance costs
 
(31 December
 
2023: increase
 
by €
 
1 million)
 
and b)
 
the investment
securities decreased by €
 
18 million due to changes
 
in accrued interest and amortisation of
 
premium/discounts (31 December 2023:
increase by € 1 million).
18.
 
Post balance sheet events
Details of post balance sheet events are provided
 
in the following notes:
Note 9 - Investment securities
Note 12 - Debt securities in issue
Note 19 – Related parties
19.
 
Related parties
Eurobank
 
Ergasias
 
Services and
 
Holdings S.A.
 
(the Company
 
or Eurobank
 
Holdings) is
 
the parent
 
company
 
of Eurobank
 
S.A. (the
Bank).
The Board of Directors
 
(BoD) of Eurobank Holdings is the same
 
as the BoD of the Bank and part
 
of the key management
 
personnel
(KMP)
 
of
 
the
 
Bank provides
 
services to
 
Eurobank
 
Holdings
 
according
 
to
 
the terms
 
of
 
the relevant
 
agreement
 
between
 
the two
entities.
Fairfax Group (“Fairfax”) is considered to
 
have significant influence over
 
Eurobank Holdings. Following the
 
changes in the
 
Company’s
share capital in the third quarter of 2024 (note 14), Fairfax held 33.29% of Eurobank Holdings’ total number of voting rights as at 31
December 2024 (31 December 2023: 32.93%),
 
based on the latest
 
notification that the Company
 
had received from the
 
entity. On
7 February 2025
 
Eurobank Holdings announced
 
that further to
 
its announcement dated
 
23 January 2025, it
 
has been informed
 
by
the entity that following the completion of
 
the sale of 80
 
million shares of the Company, Fairfax holds 32.89% of Eurobank Holdings’
share capital and voting rights. Further information
 
is provided in the Directors’ Report for
 
the year ended 31 December 2024.
 
A number
 
of transactions
 
are entered
 
into with
 
related parties
 
in the
 
normal course
 
of business
 
and are
 
conducted on
 
an arm's
length basis. The outstanding balances of the transactions with the Company’s
 
subsidiaries are as follows:
(1)
The expenses in relation
 
to KMP services
 
provided by the Company’s
 
subsidiary Eurobank S.A. are
 
included in Key
 
management compensation disclosed
below.
 
 
 
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31 December
 
2024 Financial
 
Statements
As
 
at
 
31
 
December
 
2024,
 
the
 
Company
 
has
 
recognised
 
receivables
 
and
 
operating
 
income
 
of
 
amount
 
 
0.33
 
million
 
related
 
to
financial consulting
 
services with
 
Fairfax
 
group (31
 
December 2023: €
 
0.32 million).
 
In addition,
 
for the
 
year ended
 
31 December
2024 the
 
Company
 
has
 
recognized
 
operating
 
expenses
 
of
 
€ 0.12
 
million
 
(2023:
 
€ 0.14
 
million)
 
related
 
to
 
the Group’s
 
associate
Eurolife FFH Insurance Group
 
Holdings S.A., which is also a member of Fairfax Group.
Key management compensation
In the year ended 31 December
 
2024, the Company recognized
 
Key management compensation
 
amounting to € 0.4 million
 
that is
referring mainly to KMP services provided by
 
Eurobank S.A. in accordance with the relevant agreement
 
(2023: € 0.2 million).
20.
 
External Auditors
The Company
 
has adopted
 
a Policy
 
on External
 
Auditors’ Independence
 
which provides
 
amongst others,
 
for the
 
definition of
 
the
permitted and non-permitted services the Company’s
 
auditors may provide further
 
to the statutory audit. For any
 
such services to
be assigned to
 
the Company’s
 
auditors there
 
are specific controlling
 
mechanisms in order
 
for the Company’s
 
Audit Committee to
ensure that (a) the non-audit
 
services assigned to “KPMG
 
Certified Auditors S.A.”,
 
along with the KPMG
 
network (KPMG), have been
reviewed and approved as required
 
and (b) there is proper balance between audit and permitted
 
non-audit work.
The total fees of the Company’s
 
independent auditor KPMG for audit and other services provided are
 
analyzed as follows:
(1)
 
Includes fees for statutory audit of the Company’s annual financial statements.
 
 
 
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31 December
 
2024 Financial
 
Statements
21.
 
Board of Directors
The Board
 
of Directors
 
(BoD) was
 
elected by
 
the Annual
 
General Meeting
 
of the
 
Shareholders
 
(AGM) held
 
on 23
 
July 2024
 
for a
three -
 
year term
 
of office
 
that will
 
expire on
 
23 July
 
2027, prolonged
 
until the
 
end of the
 
period the
 
AGM for
 
the year
 
2027 will
take place.
The BoD is as follows:
G. Zanias
Chairman, Non-Executive Member
F. Karavias
Chief Executive Officer
S. Ioannou
Deputy Chief Executive Officer
K. Vassiliou
Deputy Chief Executive Officer
B.P.
 
Martin
Non-Executive Member
A. Gregoriadi
Non-Executive Independent Member
I. Rouvitha Panou
Non-Executive Independent Member
R. Kakar
Non-Executive Independent Member
J. Mirza
Non-Executive Independent Member
C. Basile
Non-Executive Independent Member
B. Eckes
Non-Executive Independent Member
J. A. Hollows
Non-Executive Independent Member
E. Kotsovinos
Non-Executive Independent Member
 
Athens, 7 March 2025
Georgios P.
 
Zanias
 
Fokion C. Karavias
Harris V. Kokologiannis
I.D. No ΑI - 414343
I.D. No ΑΙ - 677962
I.D. No AN - 582334
 
CHAIRMAN
 
OF THE BOARD OF DIRECTORS
CHIEF EXECUTIVE OFFICER
GENERAL MANAGER OF GROUP FINANCE
 
 
CHIEF FINANCIAL OFFICER
doc1p454i0
 
 
 
 
 
 
KPMG Certified Auditors S.A.
44 Syngrou Avenue
117 42 Athens, Greece
Telephone:
 
+30 210 60 62 100
Fax:
 
+30 210 60 62 111
Email:
 
info@kpmg.gr
KPMG Certified Auditors S.A., a Greek Societe Anonyme and a member
firm of the KPMG global organization of independent member firms affiliated
with KPMG International Limited, a private English company limited by
guarantee.All rights reserved.
Certified Auditors
GCR 001352601000
Independent Auditor
s Report
To
 
the Shareholders of
Eurobank Ergasias Services and Holdings S.A.
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We
 
have
 
audited the
 
Separate and
 
Consolidated Financial
 
Statements
 
of Eurobank
 
Ergasias
Services
 
and
 
Holdings S.A.
 
(the
 
“Company”)
 
which comprise
 
the
 
Separate
 
and
 
Consolidated
Balance Sheet as at
 
31 December 2024,
 
the Consolidated Income
 
Statement, the Separate
 
and
Consolidated Statements of Comprehensive Income, Changes in Equity and Cash
 
Flow for the
year
 
then
 
ended,
 
and
 
notes,
 
comprising
 
material
 
accounting
 
policies
 
and
 
other
 
explanatory
information.
In
 
our
 
opinion,
 
the
 
accompanying
 
Separate
 
and
 
Consolidated
 
Financial
 
Statements
 
present
fairly,
 
in
 
all
 
material
 
respects,
 
the
 
separate
 
and
 
consolidated
 
financial
 
position
 
of
 
Eurobank
Ergasias Services and Holdings
 
S.A. and its subsidiaries
 
(the “Group”) as at
 
31 December 2024
and its separate and
 
consolidated financial performance
 
and its separate and
 
consolidated cash
flows for
 
the year
 
then ended,
 
in accordance
 
with International
 
Financial Reporting
 
Standards
(IFRS), as adopted by the European Union
Basis for Opinion
We
 
conducted
 
our
 
audit
 
in
 
accordance
 
with
 
International
 
Standards
 
on
 
Auditing
 
(ISA),
 
as
incorporated
 
in
 
Greek
 
legislation.
 
Our
 
responsibilities
 
under
 
those
 
standards
 
are
 
further
described
 
in
 
the
 
Auditor’s
 
Responsibilities
 
for
 
the
 
Audit
 
of
 
the
 
Separate
 
and
 
Consolidated
Financial Statements section of our report. We are independent of the Company and the Group
in accordance with the International Ethics
 
Standards Board for Accountants International
 
Code
of Ethics for Professional Accountants, as incorporated
 
in Greek legislation, and with the ethical
requirements that are
 
relevant to the
 
audit of the
 
separate and consolidated
 
financial statements
in
 
Greece
 
and
 
we
 
have
 
fulfilled
 
our
 
other
 
ethical
 
responsibilities
 
in
 
accordance
 
with
 
the
requirements of the applicable legislation. We believe that the audit evidence we have obtained
is sufficient and appropriate to provide a basis for our opinion.
doc1p455i0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Audit Matters
Key audit
 
matters are
 
those matters,
 
that, in
 
our professional
 
judgment, were
 
of most
 
significance
in our audit of the Separate
 
and Consolidated Financial
 
Statements of the current period.
 
These
matters and the relevant significant assessed risks of material misstatement were addressed in
the context of our audit of the
 
Separate and Consolidated Financial
 
Statements as a whole, and
in forming our opinion thereon, and we do not provide a separate
 
opinion on these matters.
Impairment allowance on loans and advances at amortised cost
See
Notes 2.2.13
,
3.1
,
20
 
and
 
21
 
to the Consolidated Financial Statements.
The key audit matter
How the matter was addressed in our audit
Loans
 
and
 
advances
 
to
 
customers
 
at
amortized
 
cost
 
for
 
the
 
Group
 
amounted
 
to
EUR 52
 
245 million
 
as at
 
31 December 2024
(2023:
 
EUR
 
42
 
773
 
million)
 
and
 
impairment
allowance
 
for
 
expected
 
credit
 
losses
 
(“ECL”)
for the Group amounted to
 
EUR 1 309 million
as at 31
 
December 2024
 
(2023: 1 258
 
million).
Measurement
 
of
 
expected
 
credit
 
losses
 
on
loans
 
and
 
advances
 
at
 
amortised
 
cost
involves
 
significant
 
judgment
 
and
 
estimates.
The
 
key
 
areas
 
where
 
we
 
identified
 
greater
levels
 
of
 
management
 
judgement
 
and
therefore, increased
 
levels of
 
audit focus
 
in the
Group’s estimation of ECL are:
 
Significant Increase
 
in Credit Risk
 
(“SICR”)
– The identification of qualitative
 
indicators
for
 
identifying
 
a
 
significant
 
increase
 
in
credit
 
risk
 
for
 
staging
 
classification
 
is
judgmental
 
taking
 
also
 
into
 
account
 
the
current
 
macroeconomic
 
and
 
geopolitical
uncertainty.
 
Model estimations – Inherently judgmental
modelling
 
and
 
assumptions
 
are
 
used
 
to
estimate
 
ECL
 
which
 
involves
 
determining
Probabilities of Default
 
(“PD”), Loss Given
Our audit procedures included, among others:
Controls testing:
We
 
tested
 
relevant
 
manual,
 
general
 
IT
 
and
automated
 
controls
 
over
 
key
 
systems
 
used
 
in
the ECL process.
Main
 
aspects
 
of
 
our
 
controls
 
testing
 
involved
evaluating the design and testing the operating
effectiveness of the key controls over the:
 
Completeness
 
and
 
accuracy
 
of
 
the
 
key
inputs into the IFRS 9 impairment models.
 
Application of the staging criteria.
 
Model validation.
 
ECL adjustments.
 
Governance and
 
policies around
 
ECL
 
and
related approvals.
Test
 
of details:
Key
 
aspects
 
of
 
our
 
testing
 
included,
 
among
others the following:
 
We performed substantive procedures
 
on a
sample
 
basis
 
in
 
order
 
to
 
assess the
 
SICR
assessment
 
for
 
both
 
corporate
 
and
 
retail
portfolios.
doc1p455i0
 
 
 
 
 
Default (“LGD”), and Exposures
 
at Default
(“EAD”).
 
ECL
 
may
 
be
 
inappropriate
 
if
certain models
 
or underlying
 
assumptions
or
 
their
 
application
 
or
 
data
 
used
 
do
 
not
accurately
 
predict
 
defaults
 
or
 
recoveries
over
 
time
 
or
 
fail
 
to
 
reflect
 
the
 
estimated
credit
 
losses
 
of
 
loans
 
and
 
advances
 
to
customers.
 
As
 
a
 
result,
 
certain
 
IFRS
 
9
models, model assumptions and
 
data, are
the
 
key
 
drivers
 
of
 
complexity
 
and
subjectivity in
 
the Group’s
 
calculation of
 
the
ECL estimate.
 
ECL
 
adjustments
 
 
Adjustments
 
to
 
the
model-driven
 
ECL
 
results
 
are
 
raised
 
by
management
 
to
 
address
 
any
 
known
limitations
 
or
 
emerging
 
trends
 
as
 
well
 
as
risks
 
not
 
captured
 
by
 
models.
 
These
adjustments
 
are
 
inherently
 
uncertain
 
and
significant
 
management
 
judgement
 
is
involved especially
 
in relation
 
to the
 
current
macroeconomic
 
and
 
geopolitical
environment.
 
Macroeconomic
 
Forward
 
Looking
Information
 
scenarios
 
 
IFRS
 
9
 
requires
the Group
 
to measure
 
ECL on
 
an unbiased
forward-looking basis reflecting a
 
range of
future
 
economic
 
conditions.
 
Significant
management
 
judgement
 
is
 
applied
 
in
determining the
 
forward-looking economic
scenarios used,
 
the probability
 
weightings
associated
 
with
 
the
 
scenarios
 
and
 
the
complexity
 
of
 
models
 
used
 
to
 
derive
 
the
probability
 
weightings
 
applied
 
to
 
them,
especially
 
when
 
considering
 
the
 
current
macroeconomic
 
and
 
geopolitical
environment.
 
Individually
 
assessed
 
loans
 
–The
estimation of
 
future cash
 
flows, valuation
 
of
collateral
 
and
 
probability
 
weighting
 
of
scenarios constitute
 
assumptions with
 
high
estimation uncertainty.
Disclosures
 
in
 
the
 
Consolidated
 
Financial
Statements.
The
 
disclosures
 
regarding
 
the
 
Group’s
application
 
of
 
IFRS
 
9
 
are
 
key
 
for
 
the
understanding
 
of
 
the
 
significant
 
judgements
and material inputs to the
 
IFRS 9 ECL results,
 
We
 
assessed
 
the
 
appropriateness
 
of
adjustments
 
to
 
the
 
model
 
driven
 
ECL
results,
 
by
 
considering
 
the
 
assumptions,
reviewing
 
calculations
 
and
 
data
 
used
 
and
inspecting
 
the
 
governance
 
around
 
these
adjustments,
 
with
 
the
 
support
 
from
 
our
financial risk specialists.
 
We
 
assessed
 
the
 
reasonableness
 
and
appropriateness
 
of
 
the
 
macroeconomic
variables’
 
forecasts,
 
scenarios,
 
weights,
and models
 
applied, with
 
the support
 
from
our
 
specialists.
 
Our
 
testing
 
included
benchmarking against external sources.
 
We
 
performed
 
substantive
 
procedures
 
to
assess
 
the
 
completeness and
 
accuracy of
critical data input used in the ECL models.
 
We
 
reperformed
 
ECL
 
calculations
 
for
lending
 
exposures
 
in
 
all
 
stages,
 
with
 
the
support
 
from
 
our
 
financial
 
risk
 
specialists
and on a sample basis.
 
We
 
performed
 
substantive
 
procedures
 
to
assess
 
the
 
reasonableness
 
of
 
significant
assumptions
 
used
 
in
 
the
 
measurement
 
of
impairment
 
of
 
individually
 
assessed
 
credit
impaired
 
exposures,
 
including
 
the
assumptions
 
used
 
to
 
estimate
 
discounted
future
 
cash
 
flows
 
and
 
the
 
valuation
 
of
collaterals for
 
which we
 
have engaged
 
our
real estate valuation specialists.
Our financial risk specialists assisted with the:
 
Assessment
 
of
 
the
 
Group’s
 
impairment
methodologies conceptual soundness.
 
Assessment
 
of
 
the
 
Group’s
 
impairment
methodologies
 
implementation
 
by
evaluating the risk
 
parameter models used
as
 
well
 
as,
 
reperforming the
 
calculation
 
of
certain risk parameters, on a sample basis.
Assessing disclosures:
 
We
 
evaluated
 
the
 
adequacy
 
and
appropriateness
 
of
 
the
 
disclosures
 
in
 
the
Consolidated
 
Financial
 
Statements
 
that
address the
 
uncertainty which
 
exists when
determining
 
the
 
ECL.
 
In
 
addition,
 
we
assessed whether the disclosure of
 
the key
judgements
 
and
 
assumptions
 
was
sufficiently clear and explanatory.
doc1p455i0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
as
 
well
 
as,
 
to
 
provide
 
transparency
 
of
 
the
credit risk exposures of the Group.
Recognition of deferred tax assets
See
Notes 2.2.17
,
3.5
 
and
 
13
 
to the Consolidated Financial Statements.
The key audit matter
How the matter was addressed in our audit
The
 
Group
 
has
 
recognized
 
deferred
 
tax
assets
 
of
 
EUR
 
3
 
780
 
million
 
as
 
at
31 December 2024 (2023: 3 991 million).
The
 
recognition
 
and
 
measurement
 
of
deferred
 
tax
 
assets
 
is
 
considered
 
a
 
key
audit matter as
 
it depends on
 
estimates of
future
 
profitability,
 
which
 
requires
significant
 
judgement
 
and
 
includes
 
the
risk of management bias.
Significant
 
judgement
 
and
 
especially
complex assumptions
 
and method,
 
due to
inherent
 
uncertainties
 
relate
 
to
 
the
following:
The
 
extent
 
that
 
there
 
are
 
probable
future taxable profits that will
 
allow the
deferred
 
tax
 
asset
 
amount
 
to
 
be
recovered in the foreseeable future.
Forecast of future taxable
 
profit, which
is mainly impacted by macroeconomic
forward-looking information.
Disclosures in the Consolidated Financial
Statements
The
 
disclosures
 
regarding
 
the
 
Group’s
application
 
of
 
the
 
Standards
 
in
 
this
 
area
are
 
key for
 
the
 
understanding of
 
the
 
key
judgements
 
surrounding
 
the
recoverability of deferred tax assets.
Our
 
audit
 
procedures,
 
included,
 
among
 
others
 
the
following:
We assessed the design and implementation of
controls
 
relevant
 
to
 
the
 
recognition
 
and
recoverability
 
of
 
deferred
 
tax
 
assets
 
including
the
 
approval
 
of
 
three-year
 
business
 
plan
 
and
monitoring of actual results against budgeted.
We
 
evaluated
 
the
 
appropriateness
 
of
 
the
assumptions
 
used
 
by
 
management
 
in
 
the
approved
 
three-year
 
business
 
plan
 
by
comparing the
 
revenue and
 
growth projections
to industry
 
trends and
 
ensuring consistency
 
with
strategic
 
plans.
 
We
 
also
 
evaluated
 
the
appropriateness
 
of
 
the
 
assumptions
 
used
 
and
the reasonableness of projections
 
for the period
that
 
lies
 
beyond
 
the
 
approved
 
three-year
business plan.
We assessed the accuracy of
 
forecasted future
taxable
 
profits
 
by
 
evaluating
 
the
 
accuracy
 
of
management’s
 
projections
 
of
 
prior
 
year
 
by
comparing them to actual results.
We
 
tested
 
the
 
accuracy
 
of
 
the
 
relevant
underlying
 
data
 
of
 
the
 
estimate,
 
including
 
the
conversion
 
of
 
future
 
accounting
 
profits
 
to
taxable profits.
Our
 
tax
 
specialists,
 
considering
 
current
 
tax
legislation,
 
assisted
 
to
 
confirm
 
the
completeness and
 
accuracy of
 
the relevant
 
tax
adjustments that produce the taxable results.
Assessing disclosures:
We evaluated the adequacy
 
and appropriateness of
the
 
disclosures
 
in
 
the
 
Consolidated
 
Financial
doc1p455i0
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Statements
 
that
 
address
 
the
 
deferred
 
tax
 
asset
recoverability. In addition, we assessed whether the
disclosures of
 
the key
 
judgements and
 
assumption
were sufficiently clear and explanatory.
Use of IT systems relevant to the financial information
The key audit matter
How the matter was addressed in our audit
The Group’s
 
financial reporting
 
processes
are
 
dependent
 
to
 
a
 
large
 
extent
 
on
information
 
produced
 
by
 
the
 
Group’s
Information
 
Technology
 
(IT)
 
systems,
and/or automated processes
 
and controls
(i.e.
 
calculations,
 
reconciliations)
implemented in these systems.
The
 
above
 
is
 
a
 
key
 
audit
 
matter
 
as
 
the
Group’s
 
financial
 
reporting
 
systems
 
rely
heavily
 
on
 
complex
 
information
 
systems
that
 
process
 
very
 
large
 
number
 
of
transactions. These IT
 
systems functions
are based on
 
the operating effectiveness
of internal
 
controls in place
 
to assure the
completeness
 
and
 
accuracy
 
as
 
well
 
as
the
 
security
 
of
 
the
 
information
 
of
 
the
Group
 
that
 
produce
 
eventually
 
the
financial information to be included
 
in the
Consolidated Financial Statements.
We have evaluated
 
in collaboration
 
with our IT
 
Audit
specialists the general controls
 
over the IT systems,
databases
 
and
 
applications
 
that
 
support
 
the
financial reporting process of the Group.
For
 
this
 
purpose,
 
we
 
performed
 
procedures
 
as
follows:
We
 
evaluated
 
the
 
information
 
security
resilience of
 
the Group
 
by evaluating
 
the design
of key IT processes and
 
controls over financial
reporting.
We
 
evaluated
 
the
 
design
 
of
 
the
 
relevant
preventative and
 
detective general
 
IT
 
controls
over administration of
 
access to programs
 
and
data for the systems in
 
scope of our audit and,
we tested
 
the operating
 
effectiveness of
 
these
relevant controls.
We evaluated
 
the design
 
of the
 
relevant general
IT
 
controls
 
of
 
the
 
Group
 
over
 
program
development,
 
program
 
change
 
management
and
 
computer
 
operations
 
for
 
the
 
systems
 
in
scope of our audit and, we
 
tested the operating
effectiveness of these relevant controls.
Other Information
The Board of Directors is responsible
 
for the other information. The other
 
information comprises
the
 
information included
 
in the
 
Board of
 
Directors’ Report,
 
for
 
which reference
 
is made
 
in the
“Report on Other Legal and Regulatory Requirements” and the Declarations of the Members of
the Board of
 
Directors but
 
does not
 
include the
 
Separate and
 
Consolidated Financial
 
Statements
and our Auditor’s Report thereon.
Our opinion
 
on the
 
Separate and
 
Consolidated Financial Statements
 
does not
 
cover the
 
other
doc1p455i0
 
 
 
 
 
 
 
 
information and we do not express any form of assurance
 
conclusion thereon.
In
 
connection
 
with
 
our
 
audit
 
of
 
the
 
Separate
 
and
 
Consolidated
 
Financial
 
Statements,
 
our
responsibility
 
is
 
to
 
read
 
the
 
other
 
information
 
and,
 
in
 
doing
 
so,
 
consider
 
whether
 
the
 
other
information is materially inconsistent with the Separate and Consolidated Financial Statements,
or our
 
knowledge obtained
 
in the
 
audit, or
 
otherwise appears
 
to be
 
materially misstated.
 
If, based
on the work we have performed, we conclude that there is a material misstatement of this other
information, we are required to report that fact. We have nothing to report in
 
this regard.
Responsibilities
 
of
 
the
 
Board
 
of
 
Directors
 
and
 
Those
 
Charged
 
with
 
Governance
for the Separate and Consolidated Financial Statements
The Board
 
of Directors is
 
responsible for the
 
preparation and fair
 
presentation of the
 
Separate
and Consolidated
 
Financial Statements
 
in accordance
 
with IFRS
 
as adopted
 
by the
 
European
Union, and for such internal
 
control as the Board of Directors
 
determines is necessary to
 
enable
the
 
preparation
 
of
 
separate
 
and
 
consolidated
 
financial
 
statements
 
that
 
are
 
free
 
from
 
material
misstatement, whether due to fraud or error.
In
 
preparing
 
the
 
Separate
 
and
 
Consolidated
 
Financial
 
Statements,
 
the
 
Board
 
of
 
Directors
 
is
responsible for assessing
 
the Company’s and
 
the Group’s ability
 
to continue as
 
a going concern,
disclosing, as applicable, matters related
 
to going concern and using the
 
going concern basis of
accounting unless the Board of
 
Directors either intends to
 
liquidate the Company and
 
the Group
or to cease operations, or has no realistic alternative but to do
 
so.
The
 
Audit
 
Committee
 
of
 
the
 
Company
 
is
 
responsible
 
for
 
overseeing
 
the
 
Company’s
 
and
 
the
Group’s financial reporting process.
Auditor’s
 
Responsibilities
 
for
 
the
 
Audit
 
of
 
the
 
Separate
 
and
 
Consolidated
Financial Statements
Our
 
objectives
 
are
 
to
 
obtain
 
reasonable
 
assurance
 
about
 
whether
 
the
 
Separate
 
and
Consolidated Financial
 
Statements as
 
a whole
 
are free
 
from material
 
misstatement, whether
 
due
to fraud
 
or error,
 
and to
 
issue an
 
auditors’ report
 
that includes
 
our opinion.
 
Reasonable
 
assurance
is a high
 
level of assurance, but
 
is not a
 
guarantee that an audit
 
conducted in accordance with
ISAs
 
which
 
have
 
been
 
incorporated
 
in
 
Greek
 
legislation
 
will
 
always
 
detect
 
a
 
material
misstatement
 
when
 
it
 
exists. Misstatements
 
can arise
 
from
 
fraud
 
or
 
error and
 
are
 
considered
material if, individually
 
or in
 
the aggregate, they
 
could reasonably be
 
expected to influence the
economic decisions of
 
users taken on
 
the basis
 
of these
 
Separate and Consolidated
 
Financial
Statements.
As part of an audit in accordance with ISAs, which have
 
been incorporated in Greek legislation,
we exercise
 
professional judgment
 
and maintain professional
 
skepticism throughout the
 
audit.
We also:
 
Identify
 
and
 
assess
 
the
 
risks
 
of
 
material
 
misstatement
 
of
 
the
 
separate
 
and
 
consolidated
financial statements,
 
whether due
 
to fraud
 
or error,
 
design and
 
perform audit
 
procedures
doc1p455i0
responsive
 
to
 
those
 
risks,
 
and
 
obtain
 
audit
 
evidence
 
that
 
is
 
sufficient
 
and
 
appropriate
 
to
provide a basis
 
for our opinion. The
 
risk of not
 
detecting a material misstatement resulting
from fraud
 
is higher
 
than for
 
one resulting
 
from error, as
 
fraud may
 
involve collusion,
 
forgery,
intentional omissions, misrepresentations, or the override of internal control.
 
Obtain
 
an
 
understanding of
 
internal
 
control
 
relevant
 
to
 
the
 
audit
 
in
 
order
 
to
 
design
 
audit
procedures that are appropriate in
 
the circumstances, but not
 
for the purpose of expressing
an opinion on the effectiveness of the Company’s and the Group’s internal control.
 
Evaluate
 
the
 
appropriateness
 
of
 
accounting
 
policies
 
used
 
and
 
the
 
reasonableness
 
of
accounting estimates and related disclosures made by the Board of Directors.
 
Conclude on the appropriateness of the Board of Directors’ use of the going concern basis
of
 
accounting and,
 
based on
 
the audit
 
evidence obtained,
 
whether a
 
material uncertainty
exists related to events or conditions
 
that may cast significant doubt on
 
the Company’s and
the Group’s ability
 
to continue
 
as a going
 
concern. If we
 
conclude that
 
a material
 
uncertainty
exists, we are required to draw attention in our auditors’ report to the related disclosures in
the Separate
 
and Consolidated
 
Financial Statements
 
or, if such disclosures
 
are inadequate,
to modify our opinion. Our conclusions are based on the
 
audit evidence obtained up to the
date of our auditors’ report. However,
 
future events or conditions may cause the Company
or the Group to cease to continue as a going concern.
 
Evaluate the overall presentation, structure, and content of the Separate and Consolidated
Financial Statements,
 
including the
 
disclosures, and
 
whether the
 
separate and
 
consolidated
financial
 
statements
 
represent
 
the
 
underlying
 
transactions
 
and
 
events
 
in
 
a
 
manner
 
that
achieves fair presentation.
 
Plan and perform
 
the group audit
 
to obtain sufficient
 
appropriate audit evidence
 
regarding
the financial information of the entities or business activities
 
within the Group to express an
opinion
 
on
 
these
 
Group
 
Financial
 
Statements.
 
We
 
are
 
responsible
 
for
 
the
 
direction,
supervision
 
and
 
review
 
of
 
the
 
audit
 
work
 
performed for
 
purposes
 
of
 
the
 
group
 
audit.
 
We
remain solely responsible for our audit opinion.
 
We
 
communicate
 
with
 
those
 
charged
 
with
 
governance
 
regarding,
 
among
 
other
 
matters,
 
the
planned
 
scope
 
and
 
timing
 
of
 
the
 
audit
 
and
 
significant
 
audit
 
findings,
 
including any
 
significant
deficiencies in internal control that we identify during our audit.
We also
 
provide those
 
charged with
 
governance with
 
a statement
 
that we
 
have complied
 
with
relevant
 
ethical
 
requirements
 
regarding
 
independence
 
and
 
communicate
 
with
 
them
 
all
relationships and
 
other matters
 
that may
 
reasonably be
 
thought to
 
bear on
 
our independence,
and where applicable, related safeguards.
From
 
the
 
matters
 
communicated
 
with
 
those
 
charged
 
with
 
governance,
 
we
 
determine
 
those
matters that
 
were of most
 
significance in the
 
audit of the
 
Separate and Consolidated
 
Financial
Statements
 
of
 
the
 
current
 
period
 
and
 
are
 
therefore the
 
key
 
audit
 
matters. We
 
describe
 
these
matters
 
in
 
our
 
auditor’s report
 
unless
 
law
 
or
 
regulation
 
precludes
 
public
 
disclosure
 
about
 
the
matter
 
or
 
when,
 
in
 
extremely
 
rare
 
circumstances,
 
we
 
determine
 
that
 
a
 
matter
 
should
 
not
 
be
communicated in our report
 
because the adverse consequences of
 
doing so would reasonably
be expected to outweigh the public interest benefits of such
 
communication.
doc1p455i0
 
 
 
 
 
 
 
 
 
 
 
 
Report on Other Legal and Regulatory Requirements
1
Board of Directors’ Report
The Board of Directors is responsible for the preparation of the Board of Directors’ Report and
the
 
Sustainability Report
 
and
 
the
 
Corporate Governance
 
Statement that
 
are
 
included in
 
this
report. Our opinion
 
on the financial
 
statements does not
 
cover the Board
 
of Directors’ Report
and
 
we
 
do
 
not
 
express
 
an
 
audit
 
opinion
 
thereon.
 
Our
 
responsibility
 
is
 
to
 
read
 
the
 
Board
 
of
Directors’ Report and,
 
in doing so,
 
consider whether,
 
based on our
 
financial statements audit
work, the
 
information
 
therein is
 
materially misstated
 
or inconsistent
 
with the
 
financial statements
or our audit knowledge. Based
 
solely on that work
 
pursuant to the requirements of
 
paragraph
1, cases aa and b, of article 154C
 
of Law 4548/2018 and case ab, which does not include the
Sustainability Report
 
and for
 
which we
 
have issued
 
on date
 
7 March
 
2025 a
 
relevant limited
assurance report
 
in accordance
 
with the
 
International Standard
 
on Assurance
 
Engagements
3000 (Revised) we note that:
(a)
The Board
 
of Directors’
 
Report includes
 
a Corporate
 
Governance Statement
 
which provides
the information set by Article 152 of Law 4548/2018.
(b)
In our
 
opinion, the
 
Board of
 
Directors’ Report
 
has been
 
prepared in
 
accordance with
 
the
applicable
 
legal
 
requirements
 
of
 
Articles 150
 
and
 
153
 
of
 
Law 4548/2018
 
excluding
 
the
requirement for the submission of the
 
Sustainability Report of paragraph 5A of
 
Article 150
of
 
the
 
same
 
law
 
and
 
its
 
contents
 
correspond
 
with
 
the
 
accompanying
 
Separate
 
and
Consolidated Financial Statements for the year ended 31 December
 
2024.
(c)
Based on the knowledge
 
acquired during our audit,
 
relating to Eurobank Ergasias
 
Services
and Holdings S.A. and its environment, we have not identified any material misstatements
in the Board of Directors’ Report.
2
 
Additional Report to the audit Committee
Our audit
 
opinion on
 
the Separate
 
and Consolidated
 
Financial Statements
 
is consistent
 
with
the Additional Report
 
to the Audit Committee
 
of the Company dated
 
7 March 2025,
 
pursuant to
the requirements of article 11 of the Regulation 537/2014 of the European Union (EU).
3
 
Provision of non-Audit Services
We have
 
not provided to
 
the Company and
 
its subsidiaries any
 
prohibited non-audit services
referred to in article 5 of Regulation (EU) 537/2014.
The permissible non-audit services that
 
we have provided to the Company
 
and its subsidiaries
during
 
the
 
year
 
ended
 
31 December
 
2024
 
are
 
disclosed
 
in
 
Notes
 
20
 
and
 
47
 
of
 
the
accompanying Separate and Consolidated Financial Statements,
 
respectively.
4
 
Appointment of Auditors
doc1p455i0
 
 
 
 
 
 
We were
 
appointed for
 
the first
 
time as
 
Certified Auditors
 
of the
 
Company based
 
on the
 
decision
of
 
the
 
Annual
 
General
 
Shareholders’
 
Meeting
 
dated
 
10
 
July
 
2018.
 
From
 
then
 
onwards
 
our
appointment has been renewed uninterruptedly for a total period
 
of seven years based on the
annual decisions of the General Shareholders’ Meeting.
5
 
Operations Regulation
The Company
 
has an
 
Operations Regulation
 
in accordance
 
with the
 
content provided
 
by the
provisions of the article 14 of Law 4706/2020.
6
 
Assurance Report on the European Single Electronic Reporting Format
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Subject Matter
We were engaged to perform a reasonable assurance engagement to examine
 
the digital files
of the company Eurobank Ergasias Services and Holdings S.A. (the Company
 
or/and Group),
which were
 
prepared in
 
accordance with
 
the European
 
Single Electronic Format
 
(ESEF) and
that include
 
the Separate
 
and Consolidated
 
financial statements
 
of the
 
Company and
 
the Group
for the year ended as at 31 December 2024 in XHTML format (JEUVK5RWVJEN8W0C9M24-
2024-12-31-en.xhtml),
 
and
 
also
 
the
 
file
 
XBRL
 
(JEUVK5RWVJEN8W0C9M24-2024-12-31-
en.zip) with the
 
appropriate mark up
 
of the those
 
consolidated financial statements, including
other
 
explanatory
 
information
 
(Notes
 
to
 
the
 
Financial
 
Statements)
 
(hereafter
 
the
 
“Subject
matter”), in order to
 
verify that it was
 
prepared in accordance with
 
the requirements set out
 
in
the Applicable Criteria section.
Applicable Criteria
The Applicable
 
Criteria for
 
the European
 
Single Electronic
 
Format (ESEF)
 
are defined
 
by the
European Commission Delegated Regulation (EU) 2019/815, as in force (hereafter “the ESEF
Regulation”)
 
and
 
the
 
2020/C
 
379/01
 
Commission
 
Interpretative
 
Communication
 
issued
 
on
10 November 2020, as required by
 
the Law 3556/2007 and the relevant
 
announcements of the
Hellenic Capital Markets Commission and the Athens Stock Exchange.
In summary, these Criteria provide, among others, the following:
 
All the annual financial reports must be prepared in XHTML format.
 
 
With
 
respects
 
to
 
the
 
consolidated
 
financial
 
statements
 
based
 
on
 
International Financial
Reporting Standards (IFRS), the financial information that is included in the Consolidated
Balance
 
Sheet,
 
Consolidated
 
Statements
 
of
 
Income
 
and
 
Comprehensive
 
Income,
Changes in Equity
 
and Cash Flow,
 
as well as
 
in the Notes
 
to the Consolidated
 
Financial
Statements, must
 
be marked
 
up with
 
XBRL tags and
 
“block tag”,
 
in accordance with
 
the
ESEF
 
Taxonomy,
 
as
 
in
 
force.
 
The
 
technical
 
requirements
 
for
 
the
 
ESEF,
 
including
 
the
relevant taxonomy, are included in the ESEF Regulatory Technical Standards.
Responsibilities of the Board of Directors and those charged with governance
The
 
Board
 
of
 
Directors
 
is
 
responsible
 
for
 
the
 
preparation
 
and
 
filing
 
of
 
the
 
Separate
 
and
Consolidated Financial
 
Statements of
 
the Company
 
and the
 
Group, for
 
the year
 
ended as
 
at
31 December 2024, in accordance with the Applicable Criteria, and for such internal control as
the Board of Directors determines
 
is necessary to enable
 
the preparation of digital
 
files that are
free from material misstatement, whether due to fraud or error.
Auditors’ Responsibilities
Our responsibility is to issue this
 
Report regarding the evaluation of the Subject Matter,
 
based
on our work performed, which is described below in the “Scope
 
of Work Performed” section.
Our
 
work
 
was
 
conducted
 
in
 
accordance
 
with
 
International
 
Standard
 
on
 
Assurance
Engagements
 
3000
 
(Revised)
 
“Assurance
 
Engagements
 
Other
 
than
 
Audits
 
or
 
Reviews
 
of
Historical Financial Information” (hereafter “ISAE 3000”).
ISAE 3000 requires
 
that we plan
 
and perform our work
 
to obtain reasonable assurance
 
about
the evaluation of
 
the Subject Matter in
 
accordance with the
 
Applicable Criteria. In
 
the context of
the
 
procedures
 
performed,
 
we
 
assess
 
the
 
risk
 
of
 
material
 
misstatement
 
of
 
the
 
information
related to the Subject Matter.
doc1p455i0
We believe
 
that the
 
evidence we
 
have obtained
 
is sufficient
 
and appropriate
 
and support
 
the
conclusion expressed in this assurance report.
Professional ethics and quality management
We
 
are
 
independent of
 
the
 
Company and
 
the
 
Group, throughout
 
this
 
engagement and
 
have
complied with
 
the requirements
 
of the
 
International Code
 
of Ethics
 
for Professional
 
Accountants
issued
 
by
 
the
 
International
 
Ethics
 
Standards
 
Board
 
for
 
Accountants,
 
the
 
ethics
 
and
independence requirements of Law 4449/2017 and Regulation
 
(EU) 537/2014.
Our
 
firm
 
applies
 
International
 
Standard
 
on
 
Quality
 
Management
 
(ISQM)
 
1,
 
“Quality
Management
 
for
 
Firms
 
that
 
Perform
 
Audits
 
or
 
Reviews
 
of
 
Financial
 
Statements,
 
or
 
Other
Assurance or
 
Related Services
 
Engagements” and
 
consequently maintains
 
a comprehensive
quality
 
management
 
system
 
that
 
includes
 
documented
 
policies
 
and
 
procedures
 
regarding
compliance
 
with
 
ethical
 
requirements,
 
professional
 
standards
 
and
 
applicable
 
legal
 
and
regulatory requirements.
Scope of work performed
The
 
assurance
 
work
 
we
 
performed
 
covers
 
only
 
the
 
items
 
included
 
in
 
the
 
214/4/11-02-2022
Decision of
 
the Hellenic
 
Accounting and
 
Auditing Standards
 
Oversight Board
 
and the
 
Guidelines
for
 
the
 
assurance
 
engagement
 
and
 
report
 
of
 
Certified
 
Auditors
 
on
 
the
 
European
 
Single
Electronic
 
Reporting
 
Format
 
(ESEF)
 
of
 
issuers
 
with
 
shares
 
listed
 
in
 
a
 
regulated
 
market
 
in
Greece”,
 
as these
 
were issued
 
by the
 
Institute of
 
Certified Public
 
Accountants of
 
Greece on
14/02/2022,
 
in
 
order
 
to
 
obtain
 
reasonable
 
assurance
 
that
 
the
 
financial
 
statements
 
of
 
the
Company that
 
are prepared
 
by the
 
Board of
 
Directors of
 
the Company
 
comply in
 
all material
respects with the Applicable Criteria.
Conclusion
Based
 
on
 
the
 
procedures performed
 
and the
 
evidence obtained,
 
we
 
express the
 
conclusion
that the
 
Separate and Consolidated
 
Financial Statements of
 
the Company and
 
the Group
 
for
the
 
year
 
ended
 
as
 
of
 
31 December
 
2024
 
in
 
XHTML
 
format
 
(JEUVK5RWVJEN8W0C9M24-
2024-12-31-en.xhtml),
 
and
 
the
 
XBRL
 
file
 
(JEUVK5RWVJEN8W0C9M24-2024-12-31-en.zip)
marked
 
up
 
with
 
respects
 
to
 
the
 
Consolidated
 
Financial
 
Statements,
 
including
 
the
 
other
explanatory
 
information
 
(Notes
 
to
 
financial
 
statements),
 
have
 
been
 
prepared,
 
in
 
all
 
material
respects, in accordance with the requirements as defined in the Applicable
 
Criteria.
Athens, 7 March 2025
KPMG Certified Auditors S.A.
AM SOEL 186
Nikolaos Vouniseas, Certified Auditor Accountant
Α.Μ. SOEL 18701
doc1p454i0
KPMG Certified Auditors S.A.
44 Syngrou Avenue
117 42 Athens, Greece
Telephone:
 
+30 210 60 62 100
Fax:
 
+30 210 60 62 111
Email:
 
info@kpmg.gr
KPMG Certified Auditors S.A., a Greek Societe Anonyme and a member
firm of the KPMG global organization of independent member firms affiliated
with KPMG International Limited, a private English company limited by
guarantee.All rights reserved.
Certified Auditors
GCR 001352601000
Independent Auditor’s Limited Assurance Report
 
To
 
the Shareholders of
 
Eurobank Ergasias Services and Holdings S.A.
Independent Auditor’s Limited
 
Assurance Report on the
 
Sustainability Report of Eurobank
Ergasias Services and Holdings S.A.
We have performed a limited assurance engagement in relation to the consolidated Sustainability
Report of
 
Eurobank Ergasias
 
Services and
 
Holdings S.A.
 
(hereafter the
 
“Company” or
 
the “Group”),
which
 
is
 
included
 
in
 
the
 
section
 
BII
 
of
 
the
 
Report
 
of
 
the
 
Directors
 
(hereafter
 
the
 
“Sustainability
Report”), for the period from 1 January 2024 to 31 December 2024.
Limited assurance conclusion
Based on the
 
procedures performed, as
 
this is described
 
in the “Scope
 
of work performed”,
 
as well
as the evidence obtained, nothing has come to our attention to
 
cause us to believe that:
 
The Sustainability Report
 
has not
 
been prepared, in
 
all material
 
respect, in accordance
 
with
the article 154 of L.4548/2018
 
as this was amended and
 
in force with the Law 5164/2024
 
with
which the
 
article 29(a)
 
of EU
 
Directive 2013/34/EU
 
has been
 
transposed into
 
Greek legislation,
 
the
 
Sustainability
 
Report
 
does
 
not
 
comply
 
with
 
the
 
European
 
Sustainability
 
Reporting
Standards (hereafter “ESRS”),
 
in accordance with
 
Commission Regulation (EU)
 
2023/2772 of
31 July 2023 and EU Directive 2022/2464/EU of the European Parliament and of the Council
of 14 December 2022,
 
the process followed by
 
the Company for the
 
identification and the assessment of
 
significant
risks and
 
opportunities (hereafter “the
 
Process”), as
 
set out
 
in Note
 
1.5 of
 
the Sustainability
Report,
 
does
 
not
 
comply
 
with
 
the
 
“Disclosure
 
Requirement
 
IRO-1
 
-
 
Description
 
of
 
the
processes
 
to
 
identify
 
and
 
assess
 
material
 
impacts,
 
risks
 
and
 
opportunities”
 
of
 
ESRS
 
2
“General Disclosures”,
 
the
 
disclosures
 
of
 
section
 
2.1
 
of
 
the
 
Sustainability
 
Report
 
do
 
not
 
comply
 
with
 
Article
 
8
 
of
Regulation (EU) 2020/852.
 
this assurance report does not extend to information for prior
 
periods.
doc1p455i0
Basis for conclusion
We conducted
 
our limited
 
assurance engagement in
 
accordance with
 
the International
 
Standard
on Assurance Engagements
 
(ISAE) 3000 (Revised),
 
“Assurance Engagements
 
Other Than Audits
or Reviews of Historical Financial Information” (hereafter “ISAE
 
3000”).
The procedures performed
 
in a limited assurance
 
engagement vary in
 
nature and timing
 
from, and
are
 
less
 
in
 
extent
 
than
 
for,
 
a
 
reasonable
 
assurance
 
engagement.
 
Consequently,
 
the
 
level
 
of
assurance obtained in a limited assurance engagement is
 
substantially lower than the assurance
that would have been obtained had a reasonable assurance
 
engagement been performed.
Our responsibilities are further described in the “Auditor’s
 
responsibilities” section of our report.
Professional Ethics and Quality Management
We
 
are
 
independent
 
of
 
the
 
Company
 
throughout
 
this
 
engagement
 
and
 
have
 
complied
 
with
 
the
requirements
 
of
 
the
 
International
 
Code
 
of
 
Ethics
 
for
 
Professional
 
Accountants
 
issued
 
by
 
the
International Ethics Standards
 
Board for Accountants
 
(IESBA Code),
 
the ethics and
 
independence
requirements of Law 4449/2017 and Regulation (EU) 537/2014.
Our firm applies
 
International Standard on
 
Quality Management (ISQM)
 
1, “Quality Management
for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related
Services
 
Engagements”
 
and
 
consequently
 
maintains
 
a
 
comprehensive
 
quality
 
management
system
 
that
 
includes
 
documented
 
policies
 
and
 
procedures
 
regarding
 
compliance
 
with
 
ethical
requirements, professional standards and applicable legal and regulatory
 
requirements.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis
 
for
our conclusion.
Responsibilities of management for the Sustainability Report
Management of the Company is responsible for designing and implementing a process to identify
the required information
 
reported in
 
the Sustainability
 
Report in accordance
 
with the ESRS,
 
as well
as for disclosing this process in Note 1.5 of the Sustainability Report.
More specifically, this responsibility includes:
 
Understanding the
 
context in
 
which the
 
Company’s
 
and
 
the
 
Group’s
 
activities and
 
business
relationships take place and developing an understanding of its affected stakeholders.
 
Identifying the
 
actual and
 
potential impacts
 
(both negative
 
and positive)
 
related to
 
sustainability
matters, as
 
well as
 
risks and
 
opportunities that
 
affect, or
 
could reasonably
 
be expected
 
to affect,
the financial position, financial performance, cash flows, access to finance or cost of capital of
the Company and the Group over the short-, medium-, or long-term;
 
Assessing
 
the
 
materiality
 
of
 
the
 
identified
 
impacts,
 
risks
 
and
 
opportunities
 
related
 
to
sustainability matters by selecting and applying appropriate thresholds;
 
and
 
Developing assumptions that are reasonable in the circumstances.
Management of
 
the Company
 
and the
 
Group is
 
responsible for
 
the preparation
 
of the
 
Sustainability
Report,
 
in
 
accordance
 
with
 
article
 
154
 
of
 
Law
 
4548/2018,
 
as
 
amended
 
and
 
in
 
force
 
by
 
Law
5164/2024, which incorporated article 29(a)
of EU Directive 2013/34/EU into Greek legislation.
doc1p455i0
In this context, the Management of the Company and the Group is
 
responsible for:
 
Compliance of the Sustainability Report with the ESRS;
 
Preparing the disclosures in section 2.1 of
 
the Sustainability Report, in compliance with
 
Article
8 of Regulation (EU) 2020/852.
 
Designing
 
and
 
implementing
 
appropriate
 
internal
 
controls
 
that
 
management
 
determines
 
are
necessary to
 
enable the
 
preparation of
 
the Sustainability
 
Report such
 
that it
 
is free
 
from material
misstatement, whether due to fraud or error; and
 
Selecting
 
and
 
applying
 
appropriate
 
sustainability
 
reporting
 
methods,
 
including
 
assumptions
and estimates about
 
individual sustainability disclosures in
 
the Sustainability Report,
 
that are
reasonable in the circumstances.
The
 
Audit
 
Committee
 
is
 
responsible
 
for
 
overseeing
 
the
 
process
 
for
 
the
 
preparation
 
of
 
the
Company's Sustainability Report.
Inherent limitations in preparing the Sustainability Report
In reporting forward-looking information in
 
accordance with ESRS, Management of the
 
Company
is required to
 
prepare the forward-looking
 
information on the
 
basis of disclosed
 
assumptions about
events that
 
may occur
 
in the
 
future and
 
possible future
 
actions by
 
the Company
 
and the
 
Group.
The actual outcome of these actions is likely to be different since anticipated events frequently do
not occur as expected.
As stated
 
in Note
 
2.2.2 to
 
the Sustainability
 
Report, the
 
information incorporated
 
in the
 
relevant
disclosures
 
is
 
based,
 
among
 
other
 
things,
 
on
 
climate-related
 
scenarios,
 
which
 
are
 
subject
 
to
inherent
 
uncertainty
 
regarding
 
the
 
likelihood,
 
timing
 
or
 
impact
 
of
 
potential
 
future
 
natural
 
and
transitional climate-related impacts.
Our work covered
 
the matters set
 
out in the
 
“Scope of Work
 
Performed” section to
 
obtain limited
assurance based
 
on the
 
procedures included
 
in the
 
program of
 
limited assurance
 
which was
 
issued
with
 
the
 
Decision
 
of
 
the
 
Hellenic
 
Accounting
 
and
 
Auditing
 
Standards
 
Oversight
 
Board
 
on
22 January 2025
 
(hereafter
 
“Program”). Our
 
work does
 
not constitute
 
an audit
 
or review
 
of historical
financial
 
information
 
in
 
accordance
 
with
 
applicable
 
International
 
Standards
 
on
 
Auditing
 
or
International Standards on
 
Review Engagements,
 
and for this
 
reason we do
 
not express any
 
other
assurance beyond that set out in the “Scope of Work Performed” section.
Auditors’ Responsibilities
 
This
 
limited
 
assurance
 
report
 
has
 
been
 
prepared
 
based
 
on
 
the
 
provisions
 
of
 
article
 
154C
 
of
Law 4548/2018 and article 32A of Law 4449/2017.
Our responsibility
 
is to
 
plan and
 
perform the
 
assurance engagement to
 
obtain limited
 
assurance
about whether the
 
Sustainability Report is free
 
from material misstatement, whether
 
due to fraud
or error, and issue a limited
 
assurance report that
 
includes our conclusion.
 
Misstatement can arise
from fraud
 
or error
 
and is
 
considered material
 
if, individually
 
or in
 
the aggregate,
 
it could
 
reasonably
be expected
 
to influence
 
decisions of
 
users taken
 
on the
 
basis of
 
the Sustainability
 
Report as
 
a
whole.
In
 
the
 
context
 
of
 
a
 
limited
 
assurance
 
engagement
 
in
 
accordance
 
with
 
ISA
 
3000
 
(Revised),
 
we
exercise professional judgment
 
and maintain professional
 
skepticism throughout the
 
engagement.
doc1p455i0
Our responsibilities regarding the Sustainability Report, in relation
 
to the Process, include:
 
Conducting
 
risk
 
assessment
 
procedures,
 
including
 
understanding
 
the
 
relevant
 
internal
controls,
 
to
 
identify risks
 
related to
 
whether the
 
Process
 
followed
 
by the
 
Company
 
and the
Group to
 
determine the
 
information reported
 
in the
 
Sustainability Report
 
does not
 
meet the
applicable requirements of the
 
ESRS, but not for
 
the purpose of providing
 
a conclusion on the
effectiveness of internal controls over the Process; and
 
Designing
 
and
 
performing
 
procedures
 
to
 
evaluate
 
whether
 
the
 
Process
 
for
 
identifying
 
the
information
 
reported
 
in
 
the
 
Sustainability
 
Report
 
is
 
consistent
 
with
 
the
 
description
 
of
 
the
Process as disclosed in Note 1.5 of the Sustainability Report.
We are further responsible for:
 
Performing risk assessment procedures, including
 
understanding relevant internal control, to
identify those
 
disclosures that
 
are likely
 
to
 
be materially
 
misstated, whether
 
due to
 
fraud
 
or
error,
 
but
 
not
 
for
 
the
 
purpose
 
of
 
providing
 
a
 
conclusion
 
about
 
the
 
effectiveness
 
of
 
the
Company's and the Group's internal control.
 
Designing
 
and
 
performing
 
procedures
 
relevant
 
to
 
those
 
disclosures
 
in
 
the
 
consolidated
Sustainability Report
 
where material
 
misstatements are
 
likely to
 
arise. The
 
risk of
 
not detecting
a
 
material
 
misstatement
 
resulting
 
from
 
fraud
 
is
 
higher
 
than
 
for
 
one
 
resulting
 
from
 
error,
 
as
fraud may
 
involve collusion,
 
forgery, intentional omissions,
 
misrepresentations, or
 
the override
of internal control.
Scope of work performed
Our engagement includes
 
performing procedures
 
and obtaining audit
 
evidence in order
 
to express
a limited assurance conclusion and covers exclusively the limited assurance
 
procedures provided
for in
 
the Program,
 
as it
 
was formulated for
 
the purpose
 
of issuing a
 
limited assurance report
 
on
the Sustainability Report of the Company and the Group.
Our
 
procedures
 
were
 
designed
 
to
 
obtain
 
a
 
limited
 
level
 
of
 
assurance
 
on
 
which
 
to
 
base
 
our
conclusion and
 
do not
 
provide all
 
the evidence
 
that would
 
be required
 
to provide
 
a reasonable
 
level
of assurance.
Athens, 7 March 2025
KPMG Certified Auditors S.A.
 
AM SOEL 186
Anastasios Kyriacoulis, Certified Auditor Accountant
 
AM SOEL 39291