ΕΘΝΙΚΗ ΤΡΑΠΕΖΑ ΤΗΣ ΕΛΛΑΔΟΣ Α.Ε.

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

Throughout its history from 1841 to today, NBG has consistently demonstrated its concern and long-standing interest in the promotion of the Greek economy, the support of society, as well as the protection of the natural environment NBG and its Group Companies recognize that the success of their business activity through the years stems largely from the fact that they operate on the basis of principles and values that the Group as a whole and each employee individually accept and embrace. Deeply aligned with the four core values of NBG's culture, as mentioned above, our Sustainability action is built on the following principles:

• Respect for Human Rights

The Bank and its subsidiaries fully comply with decisions that prohibit transactions with countries, businesses or individuals that aid and abet violence and terrorism.

• Respect for the Environment

The Bank and its subsidiaries believe that the adoption and implementation of specific environmental policies constitute an integral part of responsible corporate behaviour.

• Social Contribution

The Bank and its subsidiaries contribute to social cohesion and progress in the countries where they operate. The Group supports efforts to address international problems of social and economic growth.

• Contribution to Arts, Culture and Education

The Bank and its subsidiaries contribute to the enhancement and promotion of cultural values and actively support related initiatives in the field of art and education in the countries where they are active.

• Independence

The Bank's Sustainability Action and its subsidiaries is independent of the various customer, shareholder or third-party interests. The Bank and its subsidiaries do not support or sponsor political parties, whether directly or indirectly.

Sustainability Policy

At NBG we recognize that our operation has direct and indirect economic, social and environmental impacts on our stakeholders, as well as wider impacts on the economy, society and the natural environment. We recognize the importance of our role as a financial institution in the transition to a sustainable economy, and the importance of complying with the relevant regulatory framework. Towards this direction, we have adopted a Sustainable Development Policy, which defines our actions and contributes to the optimal management of the Bank’s and the Group's economic, social, governance, and environmental impacts. The purpose of our Sustainability Policy is to set the framework for the development of actions that assist in the management of economic, social, governance and environmental impacts of the Bank and the Group of Companies and mainly lead in:

1. Reducing - and, where possible, offsetting - of our environmental impacts, as such arises from the financing of our customers' activities, as well as from the operation of NBG itself.
2. Generating long-term value for our stakeholders and the economy at large and the communities where all our Group companies operate in Greece and abroad.
3. Undertaking initiatives and innovative actions in the fields of Corporate Governance, Corporate Social Responsibility and Business Ethics, in addition to ensuring compliance with the current legal and regulatory framework for these issues, thereby contributing to our common goal of making NBG the Bank of first choice.
4. Protecting the reputation and reliability of the Group and the cultivation / strengthening of our renewed value system. In the context of the policy, the Bank recognizes the interests and expectations of the Stakeholders and seeks to foster continuous communication / interaction through various communication channels, in accordance with internationally recognized standards, in order to understand, evaluate and meet the material issues, that they are concerned about .i.e. the issues with the greatest importance in terms of the decisions and choices of the Stakeholders and those with the greatest socio-economic importance. The Bank's response to the concerns and expectations of Stakeholders contributes in the medium-long term to the ongoing improvement in its operation, products and services, as well as to improvement in the overall results of its business operations. NBG Group Sustainability Policy is publicly available on our website and is also communicated to our employees through environmental awareness announcements at NBG’s intranet site. Please visit our website in order to find out more about NBG Group Sustainability Policy.

 
NBG Bank & Group Sustainability & other related policies

With People and Society at the core of its values system, the National Bank of Greece, makes every effort to ensure that its activities and initiatives contribute substantially and responsibly to a ‘better tomorrow’. In this context and with the aim of social welfare and sustainable development, it has formulated the Bank’s and Group's Sustainability Policy. This Policy is fully aligned with the existing legislative and regulatory requirements and with international practices included in international conventions and initiatives such as the Paris Climate Agreement and the UN Sustainable Development Goals. It determines the framework of NBG’s Sustainable Development actions and its main axes, while it is centered on the four key values lying at the core of the Bank's and the Group’s values system: Human-centricity, Trustworthiness, Responsiveness and Growth. In addition to the NBG Group Sustainability Policy, the Bank consistently and responsibly applies the rules of the Corporate Governance Code of the Bank and the Group, the Code of Ethics and Conduct, and other Group Policies, ensuring an effective corporate governance and business ethics framework and remaining true to its commitment to a better future.

Sustainable NBG Initiative

During 2021, NBG launched a holistic ESG Program, ensuring compliance with evolving regulatory framework and implementation of ESG best practices across the organization. Key initiatives relevant to the implementation of NBG's strategy with respect to ESG have been incorporated into NBG's Transformation Program, to ensure high level of focus and discipline in execution in this critical area.

Specifically, in 2021, the following initiatives took place:

➢ Definition of overarching ESG strategy and relevant metrics to monitor its implementation.

➢ Incorporation of ESG criteria into the corporate credit assessment process.

➢ Alignment of practices to UNEP FI Principles of Responsible Banking (“PRB”) and other regulatory guidelines.

➢ Implementation of actions to reduce direct and indirect own emissions.

Also, in terms of taxonomy content, Risk Types were reviewed and updated with additional emphasis on the Non-Financial Risks (Operational Risk and Strategic Risk), as well as on the pursuit of alignment with new regulatory requirements (i.e., the incorporation of ESG risk factors) and best practices. The Bank recognizes ESG as transversal, cross-cutting risks rather than stand-alone risks and considers them as drivers of existing types of financial and non-financial risks.

 
NBG ESG Strategy

Sustainability and Corporate Social Responsibility (CSR) are integral parts of our philosophy, and we constantly take new initiatives in the context of fully integrating CSR principles and environmental, social and governance (ESG) criteria into our practices. NBG’s strategic decision is to constantly upgrade its role and contribution to sustainable development in the context of its activities and operations. In this respect and under the umbrella of our Transformation Program, the Bank has articulated its overarching ESG Strategy, on the basis of its Group Sustainability Policy. Nine ESG strategic themes have been defined across the pillars of Environment, Society and Governance, and linked both with our four key values and with our vision to create a more prosperous and sustainable future together with our customers, people, and shareholders, according to the Sustainable Development Goals and the Paris Agreement. At the same time, our ESG strategic themes complement our transformation journey to becoming the undisputed Greek Bank of First Choice, in recognition that ESG increasingly shapes market trends, customer preferences and investors shifts and therefore makes an integral component of our overall business strategy. Our ESG strategic themes are listed below (1-9) in alignment with our values across the ESG pillars:

• Environment (E)

In alignment with our core values of Growth and Responsiveness we are building on NBG’s leading position in energy to address climate impact & support transition to a sustainable economy through initiatives where we:

1. • Lead the market in sustainable energy financing,
   • Accelerate transition to a sustainable economy
   • Role-model environmentally responsible practices.

• Society (S)

In alignment with our core value of Human Centricity we are continuing NBG’s long-standing tradition of positive contribution to communities, culture & life through initiatives where we:

1. • Champion diversity & inclusion
   • Enable public health & well-being
   • Promote Greek heritage, culture & creativity
   • Foster entrepreneurship & innovation
   • Support prosperity through learning & digital literacy.

• Governance (G)

In alignment with our core value of Trust we are focusing on maintaining best-in-class transparency, governance and accountability through initiatives where we:

• • Adhere to the highest governance standards.

Our Strategic Priorities for 2022-2023

Between now and 2023 the Bank is pursuing the following ESG strategic priorities:

➢ Embedding a holistic ESG framework across the organization, addressing the risks emanating from climate change, while at the same time capturing the emerging opportunities.

➢ Delivering impact in society in areas of high priority, including, among others, diversity and inclusion, culture and creativity, and digital literacy.

➢ Adhering to the highest governance standards.

Principles for Responsible Banking

In September 2020, NBG became a signatory of United Nations Environment Programme Finance Initiative (UNEP FI). As part of this commitment, NBG shall implement the six (6) principles of the Principles for Responsible Banking (PRB) framework over a time period of four (4) years. PRB is a unique framework for ensuring that signatory banks' strategy and practice align with the vision society has set out for its future in the UN Sustainable Development Goals and the Paris Climate Agreement. The six principles of the framework are outlined below:

PRINCIPLE 1 ALIGNMENT: We will align our business strategy to be consistent with and contribute to individuals’ needs and society’s goals, as expressed in the Sustainable Development Goals, the Paris Climate Agreement and relevant and regional frameworks.

PRINCIPLE 2 IMPACT & TARGET SELLING: We will continuously increase our positive impacts while reducing the negative impacts on and managing the risks to, people and environment resulting from our activities, products and services. To this end, we will set and publish targets where we can have the most significant impacts.

PRINCIPLE 3 CLIENTS & CUSTOMERS: We will work responsibly with our clients and our customers to encourage sustainable practices and enable economic activities that create shared prosperity for current and future generations.

PRINCIPLE 4 STAKEHOLDERS: We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society’s goals.

PRINCIPLE 5 GOVERNANCE & CULTURE: We will implement our commitment to these Principles through effective governance and a culture of responsible banking.

PRINCIPLE 6 TRANSPARENCY & ACCOUNTABILITY: We will periodically review our individual and collective implementation of these Principles and be transparent about and accountable for our positive and negative impacts and our contribution to society’s goals.

Impact analysis

With regards to NBG's business activity impact on the economy, society and the environment, NBG conducted in 2021 an impact analysis to identify the potential impacts of its Corporate, Business and Retail portfolios, using the UNEP FI Portfolio Impact Analysis tool. For the purposes of its first impact analysis, under this framework, NBG focused on its business activities in Greece, representing over 95% of total activities. The results of the impact analysis showcased the key sectors that contribute to the potential positive and negative impacts caused through the financing provided by the Bank. The impact areas identified have been based on the , developed through UNEP FI's Positive Impact Initiative in 2018. The Radar investigates a holistic set of 22 impact areas across three pillars of sustainable development, namely: Impact Radar

1. Availability, accessibility, affordability and quality in domains essential to human dignity and development.
2. Quality and/or efficient use of our environment.
3. Economic value creation for people and society as a means for meeting human needs within the confines of our environment.

The impact areas are defined based on internationally recognized standards and definitions, including the SDGs. Find out more about the UNEP FI Impact radar. The process to identify the Bank's most significant potential impacts included a combined assessment of the scale of NBG's exposure in the key sectors that are associated with these impact areas and NBG's product penetration of the consumer customer base in the case of Retail, as well as the level of needs related to these areas and their impact topics in Greece.

The results of the impact analysis per business portfolio are presented below:

ESG risks

Acknowledging the importance and potential impact of ESG risks, the Bank has proceeded with the identification and materiality assessment of such risks and their incorporation in the overall risk management framework, and is committed to monitoring, assessing and managing the particular risks going forward. More specifically, the Bank:

• Incorporated C&E risks in its Risk identification, by recognizing in its Risk Taxonomy Framework ESG risks as transversal, cross-cutting risks and considering ESG factors as drivers of existing types of financial and non-financial risks.
• Developed the methodological approach to assess the materiality of ESG risks as drivers of existing types of financial and non-financial risks.
• Incorporated ESG risks/drivers in the Risk Management Framework of the existing risk types and implemented the necessary enhancements, as follows:
  • The Bank incorporated the assessment of ESG risks in its Credit Granting & Monitoring Process of the corporate portfolio. In this context, documentation, and tools (i.e. ESG process guidelines, user manuals, ESG scoring methodologies, ESG specific scorecards) have been developed and put to use by the corporate underwriters in order to assess and classify obligors and transactions in terms of ESG.
  • ESG related qualitative and quantitative risk metrics have been introduced to the Risk Appetite Framework of the Bank.
  • The Bank aligned the Operational Risk Taxonomy and all other Operational Risk Programs with the inclusion of ESG risks based on the requirements set by the competent authorities.
  • The Bank incorporated ESG risks in the ICAAP/Internal ST Frameworks.

Going forward, the Bank is planning to further enhance the incorporation of ESG factors in its Risk Management Framework as methodological approaches mature, quantification/analytical capabilities develop, and additional climate and environmental data becomes available.

Responsible Financing - Environmental Risk Evaluation and Management

NBG uses the Risk Advisor Model, which is implemented through the Credit Lens System, developed by Moody's Analytics to assess the credit ratings of most enterprises (large and medium-sized) included in its corporate loan book*. Alongside various other criteria associated with industry risk, the Risk Advisor Model includes the assessment of environmental impacts and risks of each sector of business activity, graded under three score levels (high, moderate and low-risk). The assessment is carried out at least every 12 months, including inter alia, visits by Relationship Managers to the companies' premises. In addition, the Bank places special emphasis on approvals of loans that serve to support business activities that will protect the environment. Failure on the borrower's or the guarantor's part to comply with the environmental and sanitary legislation may lead to termination of the loan contract by the Bank. Polluting businesses that do not take the appropriate measures are deemed undesirable on the basis of the Bank's credit policy.

Climate change: Risks and opportunities

According to the UNEPFI Report - Extending our Horizons, “[…] a low-carbon transition translates into a new and uncertain landscape of commercial risks and opportunities. These new risks and opportunities need to be understood, assessed, and translated into effective strategies if companies are to adapt to, benefit from, and contribute to a low carbon economy[…]. As the effects of climate change continue to manifest, the risk related to transition will increase [...] Banks need a framework and a new set of tools to identify these risks in a variety of potential contexts”.

Climate change entails significant risks for both banks and their customers, among others due to stricter legislation regarding the management of greenhouse gases, increased insurance premiums and Risks arising from climate change include the following:

• Physical risks.
• Transition risks.
• Risks due to non-compliance with the applicable legal and regulatory framework.

 
Initiatives

Since its establishment in 1841, NBG has supported the Greek society and economy through initiatives and actions for the benefit of its customers, shareholders and workforce.

• UNEP FI
• UN Principles for Responsible Banking (PRB)
• UN Global Combact
• Sustainable Development Goals
• Sustainable Development Committee of the Hellenic Bank Association
• Hellenic Network for Corporate Social Responsibility
• Climate Action in Financial Institutions Initiative (“CAFI”)

The sustainable actions implemented by the Group of the National Bank, their results, as well as the Bank's commitments for the coming years are presented in an annual report and, is addressed to all Group stakeholders.

Energy Management Strategy

Energy efficiency of buildings is an important part of NBG’s environmental policy and sustainable development strategy. The Bank aims to promote energy and resource efficiency and use of renewable resources to become the energy efficiency leader in the banking sector in Greece.

In 2021, NBG developed an Energy Management Strategy and action plan in order to improve buildings’ energy and carbon performance. With these actions and activities, NBG will not only improve its energy and environmental performance but will also put in place the necessary building blocks towards disclosing energy information, improving transparency and setting short and long-term goals and targets, as well as aligning its internal operations with the broader UN, EU and Paris Agreement goals.

See more: NBG ESG Report 2021, pp.: 27-28 - NBG_SUSTAINABILITY REPORT 202... p. 16-19, 28-29, 132-135.

See also: Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr)

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2. Materiality

ADMINISTRATIVE PRACTICES

In 2021 we accomplished a lot. National Bank of Greece, our Bank, is growing stronger by the day, both internally and in its external operations, investing in its people and in digital banking, emerging as the Bank of First Choice. First choice for its customers, first choice for its people, first choice for its investors. A trustworthy companion to its customers, knowing their needs, advising and servicing them. At NBG we work effectively as a team, set ambitious goals, and focus on results. We encourage our people to take initiatives, develop new skills and evolve. During 2021, the Bank summarized its new culture and its Statement of Purpose in a single phrase: “Together we create Future”. Together with our people and our customers we create a Bank that is Human, Trustworthy, Efficient and Growth-Promoting. Those four-core values capture our guiding principles and underpin all our activities and interactions with households, businesses and society at large, in a common journey of sustainable growth and prosperity.

Last year we continued reducing our operating costs, while reaching a single-digit Non-Performing Exposures (“NPE”) ratio. We also enhanced our major competitive advantage – our strong capital position – without resorting to a share capital increase that would require a cash contribution from our shareholders. Our capital position was strengthened courtesy of the increase in our profitability, a number of capital accretive transactions, such as the sale of Ethniki Insurance and the Frontier securitization, as well as initiatives enhancing our competitive strength, such as the strategic cooperation with EVO Payments Inc. on our merchant acquiring business. Looking to the future, we’re making innovative investments in technology infrastructure, breaking ground with our digital transformation. According to surveys of independent consulting companies, we are among the most advanced digital banks in Europe and the best in Greece. In digital banking, we have the largest number of users among Greek banks.

Moreover, we recently received an award from a renowned international magazine for our progress in digitalization and our pioneering e-banking services. ESG issues today are an integral part of NBG’s strategy and corporate image. We focus on green banking, while participating for the fifth consecutive year in the Bloomberg Gender Equality Index, creating equal opportunities for all. In 2021 we received awards from established international agencies as the Best Bank in Greece, as well as the Bank with the Best Corporate Governance in Greece. We were also awarded additional distinctions for being the best in key sectors of Corporate and Retail banking. NBG is making a strong comeback into the domestic economy at an opportune time. Today the Greek economy embarks on a decade of strong growth, with the banking sector playing a central role and with NBG leading the way as a key driver of economic conditions.

The Greek economy is healing the wounds of the pandemic at a faster pace than originally expected. In 2021, Gross Domestic Product (“GDP”) grew at one of the fastest rates in the Euro Area, already with its level approaching the level of 2019 and with the unemployment rate falling to an 11-year low. The diffusion of the recovery across many sectors of the economy, the rapid resurgence of tourism and the impressive pace of exports – which are topping record levels, and the utilization of European financing, are creating a strong positive momentum. The upswing in the economy is visible in the increase of household real disposable incomes and retail deposits, with the latter reaching the highest level since 2010. It is also visible in the rising property prices and the decline of government and corporate bond yields to historic lows during 2021. It is visible in business profitability and investment activity, which significantly exceed pre-pandemic levels, as well as in key business sentiment indicators, which hit a 20-year high in early 2022. The upturn in growth is expected to continue, accompanied by a parallel deepening of the economy’s productive and technological base, and backed by European financing. The impact of the Recovery and Resilience Facility is already evident, with annual financing surpassing 2.5% of GDP in 2022.

Nevertheless, we cannot ignore the new threats and challenges emerging from the geopolitical crisis in Ukraine. Inflation is accelerating to levels we haven’t seen since the 1990s, and geopolitical tensions recall the worst moments of the Cold War. Without yet knowing the final size of the negative humanitarian, geopolitical and economic implications, it is almost certain that fiscal and monetary decisions will be directed towards mitigating those downside risks. Against this uncertain global backdrop, we continue strengthening our internal control system and remain focused and vigilant on our strategic goals of growing our business, providing quality service to our customers, and supporting the Greek economy and society. Remaining loyal to its values and traditions, NBG today flourishes as a modern, competitive and strong institution, staying always next to its customers and enjoying their trust. The National Bank of Greece becomes the “Bank of First Choice”.

Materiality

Our Sustainable Development Strategy has taken into account the GRI Materiality, Completeness, Sustainability Context and the Stakeholder Inclusiveness Principles. In 2021, we carried out a materiality e-survey that contributed to the shaping of our Sustainable Development Strategy. Through the materiality survey, the material topics that NBG has identified as relevant to the impact it creates to its stakeholders and the broader economy, society and environment, were assessed, resulting in the materiality map found below.

The materiality analysis comprised of three phases:

• Phase 1. Identification

The initial phase of the materiality analysis included the identification of relevant sustainability topics to the business model and activities of the Bank, that either influence the decisions and assessments of its stakeholders or reflect wider environmental, social and economic impacts of NBG, in the context of its contribution to the UN SDGs. The identification of relevant topics was based on an analysis of the regulatory context, sectoral and peer priorities, stakeholder output through existing means of engagement, as well as the impacts created through our in-house operations (i.e. energy consumption, human resource and CSR activities etc.) and more importantly the impacts that were identified through the PRB impact analysis, created through our financing activities.

• Phase 2. Prioritisation

During the second phase of the materiality analysis, an on-line internal and external survey was carried out, in order for the material topics to be prioritized based on the degree that they:

• influence decisions and assessments of NBG's stakeholders,
• reflect wider environmental, social and economic impacts of NBG.
• Phase 3. Validation

The last stage of the materiality analysis included the validation of the survey results from the Senior Management Team of NBG. As part of this validation, 9 material topics were defined as most material, and they are mapped and further analyzed in the Report.

The identified sustainability topics were prioritized as it is illustrated in the materiality map below. Although the highlighted topics were prioritized as material, as a result of the stakeholder engagement, NBG appreciates that all identified topics are significant and therefore these have been included in the ESG Report along with their relevant metrics (where these are currently available) measuring the Bank's performance in these areas.

The impact boundaries of material topics are presented in the table below. More specifically, the information captured in the table below presents: b. Which are the stakeholders affected by the most significant environmental and socio-economic impacts created by NBG (based on the results of the 2021 materiality analysis survey)?

1. Topic materiality (why is each topic material?)
2. What are the UN Sustainable Development Goals to which NBG contributes to, based on the environmental and socio-economic impacts it creates to its stakeholders and the broader economy, society and the natural environment?
3. Which are the stakeholders affected by the most significant environmental and socio-economic impacts created by NBG (based on the results of the 2021 materiality analysis survey)?

2.Topic boundaries (where do the impacts occur?)

According to the GRI Standards, the topic Boundary is a description of where the impacts occur for a material topic and the organization's involvement with those impacts. Organizations might be involved with impacts either through their own activities or as a result of their business relationships with other entities (i.e. impacts it contributes to and impacts that are directly linked to its activities, products or services through a business relationship). As a result, some impacts occur directly through NBG's operational activities (i.e. impact to climate change through the energy consumption in NBG buildings), or through its financing activities (i.e. impact to climate change through NBG's financed emissions.

Building upon its long-lasting tradition of trust and service to society, the National Bank of Greece embarked on a large-scale Transformation Program in the second half of 2018, responding to the challenges and tapping the business opportunities presented by the rapidly changing economic and banking landscape. The Transformation Program identifies the strategic areas that leverage on our strengths and address our weaknesses, so as to unlock the Bank's substantial untapped profitability potential through six discrete workstreams that align with its six strategic priorities described below.

• Healthy Balance Sheet
• Efficiency & Agility
• Best Bank for our clients
• Technology & Processes
• People Organisation & Culture
• Visibility, Control & Compliance

Recognizing climate change as a major environmental challenge of our times, NBG is committed to reducing any adverse impact on the environment arising, primarily, from its financing activities, but also from its own operations and infrastructure. This commitment aligns with the Bank’s transition effort towards a net-zero economy, more circular and with less dependency on natural resources.

While the risks arising from climate change are evident, a number of significant growth opportunities are emerging, which NBG intends to exploit. For example, the development of an economy that produces fewer pollutants on both the national and international level will generate competitive advantages for organizations that have already taken precautionary measures to this end, and at the same time new markets and innovative products designed to reduce greenhouse gas emissions will comprise a new area of business activity. The Bank is currently in the process of implementing its Action Plan for the incorporation of ESG factors/risks across the areas of governance, processes, risk management framework, reporting etc., aiming to adhere to the relevant supervisory guidelines. Specific focus is being placed on the incorporation of ESG factors in the credit assessment process, as well as in the incorporation of environmental and climate-related risks in its risk management framework covering the identification and materiality assessment of such risks and their integration in key risk management and planning processes of the Bank such as ICAAP, Stress Testing and Risk Appetite Framework.

Responsible towards the Environment (E)

NBG has recently taken a series of impactful initiatives and committing decisions to align its strategy and activity towards this direction:

• Issuing the first green senior bond in the Greek market, totaling €500 million

NBG is contractually committed to channeling all the funds raised from the sale of the bond to financing projects related to the green economy. NBG already maintains a high share in the Renewable Energy Market – a level that we aim to solidify and increase. The financing of projects in the energy sector and above all in renewable energy, is a strategic goal of the Bank. In 2021, the Bank contributed to the country's efforts to improve its environmental footprint by financing RES projects worth €569 million.

• Becoming a Signatory to the UNEP FI's Principles for Responsible Banking

To embed those principles properly and more effectively into our business model, NBG is already reviewing all its processes with a view to either adapt and align existing ones or create new ones. Finally, at the back of UNEP FI's portfolio impact analysis exercise, NBG is in the process of setting its first PRB (Principles for Responsible Banking) targets.

• Reducing our own environmental footprint

We completed a series of focused interventions aimed at reducing NBG's own environmental footprint, such as:

• • Certifying NBG's biggest back office building in Gerakas, Athens with LEED (the only IT office building in Greece that holds a Gold grade LEED certification).
  • Producing electrical energy of 242.52  MWh from photovoltaic panels in 2021.
  • Diverting 294 tones of waste from disposal (recycling) in 2021.  Complying with recent/new regulatory requirements
• Complying with recent/new regulatory requirements

In the 1 quarter of 2021, we submitted a detailed action plan to ECB for embedding environmental and climate related factors into our strategy and operating frameworks

• • In 2021, NGE's total energy consumption decreased by 5.3% compared to 2020 and by 15.3% compared to 2019.
  • Reduction of CO₂ emissions by 239.85 tons in 2021, through energy saving actions and energy upgrades.
  • In 2021, NΒG's total CO₂ emissions (Scope 1, 2, 3 including financed emissions) decreased by 9.1% (Location-based) and by 9.7% (Market-based) compared to 2020. The reduced emission of pollutants in the environment, beyond the obvious environmental dimension, also implies indirect benefits for public health and the economy.
  • 22% (location-based) and 52% (market-based) reduction in Scope 1, 2, 3 emissions deriving from our operations (2020 vs 2021).
  • For the first time in 2021, we added new categories and data to the calculation of indirect CO₂ emissions (Scope 3, Cat. 1-14 excl. financed emissions).

In terms of NBG’s footprint deriving from its financing activities:

• NBG in 2021 with total approvals for RES investment projects amounting to €569 million, contributed to our country's effort for a positive environmental footprint.
• NBG's inaugural Green Senior Bond issued in October 2020, was the first green bond from any greek bank, amounting to €500 million. Within the first year of issuance, 70% of the proceeds have been allocated to 42 RES projects, across Greece.
• Provision of green products to retail customers (€8.04 million under the "Estia Green Home" loan).
• Incorporating ESG factors into the business lending process by assessing environmental (including climate change), social and governance risks. The assessment is applied based on the prescribed Sustainable Lending Criteria which are, to a large extent, aligned with the EU Taxonomy.
• For the first time in 2021, we calculated the indirect CO₂ emissions from our financing activities (Scope 3, Cat. 15), which constitute the vast majority of the Bank's total CO₂ emissions

Responsible towards Society (S)

On the cultural and educational front, NBG continued its activity via the “NBG Cultural Foundation” and “NBG Historical Archive”, both of which are regarded as model institutions in Greece, while in 2021 marking the historic importance of the Greek Revolution's 200-year anniversary via a series of initiatives.

Above all, NBG recognizes the significance of its people as a key factor for evolution and business success. In this context:

• Health and safety in the workplace remain a priority both for the Bank and the Group companies that aim to ensure a safe working environment, enhance the quality of employees' professional life and prevent any associated risks. Specifically, in order to ensure the health and safety of our employees and customers, as well as the resilience of our operations, from very early on and continuing until early 2021, c. 50% of our staff works remotely, with the percentage exceeding c.70% during the full lockdowns, both efficiently and cyber-securely. In addition, all our branches have remained open throughout the pandemic crisis, while our support to our customers steadfast.
• With the NBG “Responsibility for the Community” program NBG undertook actions and initiatives to strengthen the National Health System during the Covid-19 crisis.
• We provide development and career opportunities to our people, while also ensuring that equal opportunities and diversity are protected. Half of our total headcount are women, while 33% of the Bank's top 10% compensated employees are women and 27% hold senior Management positions. We are proud of this gender-balanced workforce. We are promoting multiple initiatives in order to achieve effective equality in opportunities and remuneration between male & female employees at all positions.
• NBG continued to offer a variety of training programs, aimed at deepening and sharpening the skillset of its workforce, with customized and continuously refreshed curriculum. In 2021, over 160k training manhours were consumed, in approximately 50k participations, with a total invested budget amounting to €0.54 million and a staggering 98% taking place digitally.
• In 2021 we held internal discussions of the 2020 Employee Experience Survey’s results in groups, identified particular focus areas and prepared targeted action plans. 68% of the planned actions were completed or set in motion during 2021. The 2nd Survey, regarding the Employee’s working experience throughout the year 2021 and early 2022, launched in May 2022 and the results are presented in the following table. We plan to identify particular focus areas and prepare targeted action plans with regards to the new Survey results, which will be discussed in the coming year.

Responsible Governance (G)

NBG monitors developments in the applicable framework and relevant guidelines and best practices and proceeds to the actions deemed appropriate in order to ensure that the policies followed are in alignment with the prevailing applicable regulatory framework and relevant guidelines.

To achieve its strategic goals under this pillar, in 2020 and the first half of 2021, the Bank implemented a series of actions and initiatives on Corporate Governance, the most important of which can be summarized as follows:

• Establishment of the ESG Management Committee. The ESG Management Committee, chaired by the Chief Executive Officer, has been set up to govern all strategic decisions related to ESG, while a dedicated Group Corporate Social Responsibility & Sustainability Division has been established under the Group Chief Compliance and Corporate Governance Officer to oversee matters pertaining to corporate social responsibility, sustainability, and climate change.
• Adoption of a Suitability Assessment Policy and Procedure and a Diversity Policy for Board members.
• Revision of the Group's Corporate Governance Policy.
• Approval of the revised Remuneration Policy for NBG Board Members and Senior Executives by the 2020 AGM of Shareholders.
• Adoption of a Nomination and Suitability Assessment Policy for NBG Senior Executives.
• Revision of the Group's Code of Ethics by incorporating new principles, updating and enriching the framework of the Code and
• Declaration of a new Group Sustainability Policy, laying the ground for building and implementing an impactful ESG strategy.

See more: NBG ESG Report 2021, pp.: 10, 12, 155-156.

See also: Annual-Financial-Report-2021-EN.pdf (nbg.gr), p. 112. Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr).

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3. Objectives

ADMINISTRATIVE PRACTICES

Long-term commitments

We have defined ESG strategic themes across the pillars of Environment, Society and Governance, that are aligned with our purpose and values to create a more prosperous and sustainable future together with our customers, people, and shareholders. At the same time, our ESG strategic themes complement our business strategy & transformation, and our vision of becoming the undisputed Greek Bank of First Choice. Our ESG strategic themes are listed below in alignment with our values across the ESG pillars:

Since 2020 NBG has set out specific on-going ESG commitments which are monitored annually, and they constitute fundamental pieces of its ESG Strategy.

 
Short/mid-term ESG commitments and targets

Moreover, NBG has set short/mid-term ESG commitments for which the time of achievement is referred in the column “Commitment year”. The following table presents the status of selected NBG’s ESG short/ mid-term commitments:

In the context of UNEP FI’s commitments and following the Impact Analysis process, the impact areas of “Climate “and “Inclusive, Healthy Economies” were prioritized as potentially the most significant impact areas. NBG has initially set 2 SMART targets on these impact areas {€600 million financing of renewable energy in 2022-25 and 3 million active digital users (12-month) by the end of 2024} and is in the process of revisiting and enhancing these targets following further analysis. For further information please see NBG 1st UNEP-FI PRB Self-Assessment Report 2022. Also, for more information about the Bank’s Human Resources priorities for 2022, please see Group and Bank Annual Financial Report 2021, page 103.

In the context of implementing the UNEP FI Principles for Responsible Banking (PRB), NBG used the UNEP FI Portfolio Impact Analysis Tool to identify the potential environmental and socioeconomic impacts caused from finance and services provided to the corporate, business and retail clients. The above potential impacts were prioritized through the stakeholder engagement that took place as part of the materiality analysis survey performed in 2021.

Via the Company’s standards, targets implementation is monitored and evaluated.

Also, as part of its efforts to safeguard the good reputation and prestige of the Bank and Group companies vis-a-vis their shareholders, customers, investors and regulatory and other independent authorities, NBG continuously seeks to strengthen and enhance the Internal Control System (ICS) at Group level. The ICS comprises a set of control mechanisms and procedures that cover on an ongoing basis every activity and contribute to the efficient and secure operation of the Bank and the Group.

Additional, the Sustainability Committee ensures there is continuous monitoring and tracking of important developments and long-term trends related to Innovation, Sustainability, Information Technology, ESG, and Banking.

Sustainability related targets are also discussed in the context of updates provided to the Strategy and Transformation Committee of the Board on the Bank's Transformation Program which includes initiatives relevant to ESG/Sustainability, while the Bank’s Risk Appetite Framework, which is discussed and approved at Board level, includes ESG related metrics.

See more: NBG ESG Report 2021, pp.: 60-62, 25,155.

See also: Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr)

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4. Management of Value Chain

ADMINISTRATIVE PRACTICES

The Group of the National Bank, with its long-term presence, strong tradition and contribution to the development transformation of the country, but mainly with the trust of its shareholders, customers, depositors and employees, is a pillar of stability for the Greek economy. The Group operates mainly in 9 countries (Greece, Bulgaria, Romania, North Macedonia, Cyprus, Malta, Egypt, United Kingdom and Australia) and has, in addition to the NBG, 2 subsidiary commercial banks in North Macedonia and Malta, employing a total of 8,773 employees (ongoing activities). It also has a wide network of distribution of products and services abroad (78 branches), as well as a more complete network in Greece, with 339 Units and 1,474 ATMs in total.

The National Bank of Greece

The National Bank was founded in 1841 and was the first bank of the modern Greek state, with a decisive contribution to the economic life of the country in these 181 years of its history. Today, NBG heads one of the largest and most powerful Financial Services Groups in Greece, with a dynamic contribution to the support of the Greek economy and the development and social transformation of the country. With 339 Units (including 2 i-bank stores) and 1,474 ATMs, it has the widest service network, covering the entire geographical area of Greece, while also developing modern electronic channels, such as Mobile and Internet Banking services. NBG employs a total of 7,365 employees as per 31.12.2021.

NBG heads one of the largest financial groups in Greece, playing a key role in the efforts to support the Greek economy and the economic and social transformation of the country. It provides a wide range of financial products and services, including deposit and investment products, various financing facilities and brokerage, insurance, leasing and factoring services, that aim at covering fully and effectively the constantly changing needs of its customers, whether businesses or individuals.

National Bank of Greece

• 12,825,015 deposit accounts
• 1,167,115 loan accounts
• 7,365 Employees
• 339 Units
• 1,474 ATMs

The Code of Ethics sets out clearly the ethical moral principles and values, as well as the rules of conduct upheld by the Bank and Group. To this end, the Bank, is aware of its responsibility to respect human rights, meaning avoiding infringing on the human rights of others and addressing such impacts where they occur.

The Bank undertakes to contribute to the creation of positive economic and social impacts for its stakeholders and more broadly for the economies and societies where it operates, through its activities (the provision of funds, products and services), within its role as an employer, as well as with the development of specific programs for CSR actions.

During the first months of 2021, NBG launched a holistic Environment, Social and Governance (“ESG”) effort to ensure compliance with evolving regulatory framework, fulfilment of its commitment to the Principles of Responsible Banking (“PRB”) of the United Nations Environment Program Finance Initiative (“UNEP FI”) and implementation of ESG best practices across the organization (covering management of credit and other types of risk, business strategy, products and services, reporting, as well as efforts to reduce NBG’s direct and indirect emissions footprint).

In the same context, the Bank ensures the dissemination and implementation of the principles of responsible entrepreneurship and sustainable development throughout its value chain (customers, suppliers and partners, employees, etc.)  Pursuant to the institutional framework, all parties involved in procurement and technical projects must be aware of and conform with the Bank’s and the Group’s Code of Ethics, which also applies to purchasing and technical projects. The Bank reviews and evaluates its suppliers (in terms of quality, certifications, respect for human/employee rights, etc.) on an ongoing basis.

The Code of Ethics is posted on the Bank's website www.nbg.gr (https://www.nbg.gr/en/group/esg/corporate-governance/corporategovernance-framework). The Code of Ethicsis periodically reviewed, integrating new principles, updating and enriching the context of the respective Code, as well as redesigning the format of the Code, so as to facilitate a better understanding of the rules of conduct and obligations arising from the regulatory framework. It is noted that the Bank ensures that its staff is trained through special elearning programs, regarding the content of the Code of Ethics. In this context, in 2021, the dedicated mandatory e-learning program of the Code of Ethics was updated to incorporate the changes introduced in 2020.

 
Training Programs on Corporate Social Responsibility

CSR related trainings were offered in co-operation with external providers for 33 participants (188 training man-hours). Based on the reformed training strategy of our Bank, through the creation of the “NBG Academy” and the extensive skills gap analysis that preceded in 2020, long-term development initiatives for key employee populations were prioritized and implemented throughout the year 2021. Special emphasis was given on upskilling and reskilling a large number of Programmers and Developers on new modern technologies in order to support and further accelerate the Bank’s digital transformation effort, while our focus was also on strengthening the customer-centric mentality and skills of our Network executives, through systematic training initiatives that aim to enhance their advisory approach, as well as the excellent service and experience of our customers. At the same time, the development of Leadership skills and mentality that will empower our Executives to meet future opportunities and challenges of the modern unstable environment, was considered a top priority. Finally, new mandatory e-learning programs on ethics, values, whistleblowing, risk controls and risk management have significantly strengthened our efforts to create a corresponding culture in our Human Resources.

Responsible procurement

Standing by its longstanding commitment to responsible operations, NBG has adopted policies, regulations and processes which are formalized in relevant Codes of Conduct ensuring transparency and impartiality as well as avoidance of conflicts of interest in its supplies and implementation of technical projects. Under contractual terms, suppliers should conduct their activities in line with applicable anti-corruption and anti-bribery legislation, comply with the Bank’s Code of Conduct and with Corporate Social Responsibility national legislative framework(…)Furthermore, the Bank reviews and evaluates its suppliers (in terms of quality, certifications, respect for human/employee rights, etc.) on an ongoing basis. In the event that inspections of facilities/data security are required, special teams may visit these facilities and certify their suitability. Regular sample qualitative and quantitative controls are carried out for every order and delivery of goods/equipment, etc. In 2021, there were no confirmed incidents where contracts with business partners were terminated or not renewed due to violations related to corruption.

Prospective suppliers are under the obligation to comply with Corporate Social Responsibility requirements (documenting compliance by sending relevant supporting material), as these are stipulated in the relevant EU Directives, on issues such as:

➔ Environmental protection
➔ Child labour
➔ Work health and safety
➔ Social equality/solidarity.

In 2021, NBG engaged with 39,604 suppliers whose geographic location is in Greece by 97% (38,358 suppliers) and abroad by 3% (1,246 suppliers).

• Environmental procurement criteria

NBG seeks to act responsibly in the area of procurement, with a view to exercising indirect pressure on its suppliers and associates to improve their processes aiming to reducing their environmental impact.

To do this, NBG evaluates its suppliers in terms of environmental criteria, including:

Technical specifications of products (i.e. low energy consumption). Compliance with legal requirements concerning environmental issues (e.g. avoiding the use of harmful chemicals).  Participation in alternative management and recycling systems for obsolete equipment. Since 2013, the Bank has included corporate responsibility terms in all invitations for tenders and procurement contracts, as stated in the relevant EU directives regarding environmental protection. Indicatively, to minimize the impact of its electrical and electronic equipment on the environment, the Bank applies a number of environmental criteria, classified as either mandatory or optional:

• Mandatory criteria include the supplier's declaration that the equipment in question meets legal provisions regarding recycling /alternative waste management
• Optional criteria include an environmental management certificate issued by the manufacturer or any other document proving the measures taken by the manufacturer or supplier. Also, as part of the LEED certification of Gerakas building complex, in addition to the planned IT upgrade works that were already in progress, the specification of building cleaning and maintenance materials and other consumables was required, so as to ensure they are environmentally friendly.

It is estimated that 97% of the suppliers, associated with the Bank, have been assessed against environmental criteria as well.

• Management of relationships with suppliers

In the context of the centralized management of complaints now deployed by the Bank, complaints lodged by suppliers (such as objections to tender procedures, pending invoice payments, etc.) are handled centrally by NBG.

See more: NBG ESG Report 2021, pp.: 164-165.

See also: Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr), p. 101

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5. Responsibility

ADMINISTRATIVE PRACTICES

Regarding environmental and social issues, NBG has established the following governance structure:

• As per National Bank of Greece Corporate Governance Code, the Board oversees sustainability matters and considers, among others or driving others, climate-related and environmental risks. Within this context, the Board should ensure that material environmental and social considerations are integrated into the Bank’s strategy, business model and risk management framework and addressed in its public disclosures.
• The Charters of the new Board Innovation and Sustainability Committee and of the Compliance, Ethics and Culture Committee, specify responsibilities relevant to ESG, while it is noted that all Board Committees, may be involved in relevant matters depending on the particular topic per case (e.g., Human Resources and Remuneration Committee as regards Social issues/personnel issues, Risk Committee as regards risk metrics etc.). The Innovation and Sustainability Committee ensures there is continuous monitoring and tracking of important developments and long-term trends related to Innovation, Sustainability, Information Technology, ESG and Banking.
• The ESG - Environmental, Social and Governance Management Committee, chaired by the Group CEO, to contribute to the governance of multiple aspects of NBG’s ESG strategy. Among other responsibilities, the Committee oversees the implementation of the Principles and relevant approvals required by the competent Units for the respective initiatives and the monitoring of the Bank’s alignment with the PRB requirements.
• A dedicated Group Corporate Social Responsibility & Sustainability Division was established in 2021 and is operating under the Group Chief Compliance and Corporate Governance Officer. The Division for ESG and sustainability matters reports through its General Manager to the Compliance, Ethics and Culture Committee as well as to the new Board Innovation and Sustainability Committee.

See also: Annual-Financial-Report-2021-EN.pdf (nbg.gr), p. 95

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6. Rules & Processes

ADMINISTRATIVE PRACTICES

The Bank’s corporate governance framework is aligned with the requirements of Greek and European legislation, the decisions and acts of the Bank of Greece, the guidance of the European Central Bank, the guidelines of the European Banking Authority and the European Securities and Markets Authority, as well as the decisions and guidance of the HCMC. Additionally, the stipulations of the Relationship Framework Agreement (“RFA”) between the Bank and the HFSF, and the obligations of the Bank towards the Monitoring Trustee (in accordance with particular procedures foreseen as long as these are in force) are applied. In February 2006, the Bank’s Board of Directors adopted a directional framework that describes the Bank’s corporate governance structure and policy, while throughout the years this framework has been revised as deemed necessary, in alignment to regulatory provisions, guidelines, best practices and developments in the Bank’s internal governance arrangements.

As far as year 2021 is concerned, the Bank’s Corporate Governance Code was amended in January 2021, further enhancing provisions on the role of the Senior Independent Director. In June 2021, in accordance with article 17 of Greek Law 4706/2020, the Bank adopted the Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council, which constitutes the Hellenic Corporate Governance Code for Companies with securities listed on the stock market, in accordance with Article 17 of Greek Law 4706/2020 and Article 4 of the Decision of the Hellenic Capital Market Commission (Decision 2/905/3.3.2021 of the Board of Directors of the HCMC). Further, the Bank's Corporate Governance Code, which was amended in June 2021, mainly in order to adjust to the respective stipulations of Greek Law 4706/2020, includes additional provisions in compliance with more specific corporate governance framework applying to credit institutions, as well as provisions on internal arrangements and processes that the Bank implements in compliance with the relevant legal and regulatory framework. The Bank monitors developments in the applicable framework and relevant guidelines, as well as best practices in the area of corporate governance and proceeds to actions deemed appropriate in order to ensure compliance with the applicable legal and regulatory framework, as in force, as well as relevant guidelines.

In order to achieve a robust corporate governance and strengthen the existing risk management framework, the Bank has adopted corporate governance practices and policies, governing the relations between the shareholders, management and stakeholders, are harmonized with its activities and ensure the transparency and efficiency of its operations. This framework is communicated to NBG employees through the execution of specific training programmes as mentioned above. This way NBG actively promotes culture for Responsible Banking.

It is noted that during 2020-2021, the Bank ensured that all the Bank’s human resources are trained, through a special e-learning program, regarding the content of the Code of Ethics. In this context, in 2021, the dedicated mandatory e-learning program of the Code of Ethics was updated to incorporate the changes introduced in 2020. Further, all personnel have access to the internal e-communication network of the Bank (intranet), through which they are able to get prompt and full information on all key matters regarding Group’s developments and operations, including internal communication announcements, internal circulars, policies that the Bank has in place etc. Please visit our website in orderto find out more about NBG Group Code of Ethics.

Additionally, there has been a dedicated Board Training session which took place in 2021 on ESG related topics, namely a half day program hosted by the International Corporate Governance Network, with all Directors attending and a certificate was provided by the Organization as per their completion of the training. Further, in the context of the CEO Monthly Report to the Board of Directors, Board Members discuss on ESG related matters of the Bank.

Certifications - ISO Certificates

Following a demanding and highly successful certification process, the General Division of the Bank fully complied with the guidelines of ISO 26000:2010 for Corporate Social Responsibility integrating them in its values and practices.

The Bank has also certification for two international standards and more specifically the:

• Compliance management, as set out in ISO 19600: 2014 International Guide
• Corporate Governance, (EBA's Guidelines on Internal Governance| EBA-GL-2017- 11).

The Bank successfully completed a certification process for two international standards and more specifically the: 

• Certification for Quality Management (ISO 9001:2015), January 2020
• Certification and Anti-bribery (ISO 37001:2016), February 2020.

The aforementioned standards provide guidance for establishing, developing, implementing, evaluating, maintaining and improving an effective and responsive compliance management system within NBG and are based on the principles of good governance, proportionality, transparency and sustainability.

In addition, the Bank successfully maintained the certification of all five standards already held by the same standard (ISO 37001 Anti Bribery, ISO 37000 Governance, ISO 26000 CSR, ISO 19600 Governance, ISO 9001 Quality Management) following the annual review that was carried out in December 2020.

Protection of personal data

With a view to ensuring full compliance of the Bank and the Group with the applicable legislative and regulatory framework, as well as with international best practices and guidelines regarding the management of personal data, by decision of the Bank's Board the NBG Group Data Protection Policy was introduced in compliance with GDPR. Furthermore, the Bank has developed Policies for Data Security and Data Governance. All these Policies further enhance the existing framework for data security, data protection and appropriate data governance, while at the same time it sets out a uniform framework of principles and rules at Group level, by observing the applicable respective national statutory law of the country where each Group Company is active.

Responsibility of the payment of taxes

The Bank, realizing the constantly changing economic environment both in Greece and abroad, which results in tax law changes, monitors tax developments on a constant basis through its relevant taxation division. The NBG Group Taxation Division undertakes an advisory and supervisory role ensuring the Bank's compliance with the applicable tax legislation, shielding it against tax risks and protecting its Management from any serious charges or criminal liability.

Internal Control System (ICS)

As part of its efforts to safeguard the good reputation and prestige of the Bank and Group companies vis-a-vis their shareholders, customers, investors and regulatory and other independent authorities, NBG continuously seeks to strengthen and enhance the Internal Control System (ICS) at Group level. The ICS comprises a set of control mechanisms and procedures that cover on an ongoing basis every activity and contribute to the efficient and secure operation of the Bank and the Group. In the context of developing the appropriate business strategy and identifying the main business risks, the Bank's Board, with the support of its Committees, adopts the appropriate policies, procedures and regulations to ensure the operation of an adequate and effective ICS for the Bank and the Group. The Management is responsible for the effective planning and implementation of adequate and efficient safeguards that derive from effective procedures, appropriately adapted to the scope, risks and nature of the activities undertaken by the Bank and the Group, for the identification and assessment of any weaknesses in the ICS and the adoption of any necessary corrective action by drawing up appropriate and timely action plans. Finally it should be noted that, in accordance with particular requirements which the applicable regulatory framework (Bank of Greece Governor's Act 2577/2006) imposes in this respect, external auditors review and assess the effectiveness of the Bank's Internal Control System on a three-year basis.

Risk management

The Group's risk management is based on the internationally established principle of the “three lines of defense”:

• First line

The Group's risk management is based on the internationally established principle of the “three lines of defense”: The risk-taking Units (e.g. credit units, treasury) are responsible for assessing and minimizing risks related to them for a given level of expected return by establishing and applying internal rules and controls to the ongoing business.

• Second line

Group Compliance and Corporate Governance Function

Recognizing the key importance of a strong and effective framework of Regulatory Compliance and Corporate Governance in maximizing the long-term value of the Bank and protecting the interests of customers, shareholders, employees and generally all stakeholders, the Bank places special emphasis on maintaining, regularly upgrading, and strengthening this framework, with a view to further enhancing its efficiency. The NBG Group Compliance and Corporate Governance Function and its respective activities are supervised and coordinated by the General Manager - Group Chief Compliance & Corporate Governance Officer. The Compliance and Corporate Governance Function is subjected administratively to the Bank's CEO and functionally to the BoD through the Compliance, Ethics and Culture Committee, as well as the Audit Committee. Further, the Function reports to the Corporate Governance and Nominations Committee of the Board on corporate governance related matters.

Group Risk Management Function

The Group Risk Management Function oversees, monitors, reviews and quantifies the risks, provides all the necessary tools, methodologies, coordination and support to the risk-taking Units. It also contributes to the measurement of the risk-adjusted performance of the said Units, participates in the credit approval process of the Group for the corporate and retail portfolios, as well as of the Group subsidiaries, conducts an independent assessment of the credit risk undertaken with veto power, and proposes appropriate ways to mitigate risks, supported by the subsidiaries' Risk Management Units as well as by other specialized Units of the Bank.

• Third line

The Internal Audit Units of the Bank and the Group, which report directly to the Board of Directors through the Audit Committee, complement the risk management framework, acting as an independent audit body, focusing on the effectiveness of the risk management framework and control environment. The duties and responsibilities of all aforementioned lines of defense are clearly defined and segregated, while the relevant Units have adequate independence.

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PERFORMANCE INDICATORS

Vision and Values

Our vision is to become the bank of first choice for our customers, but also to attract talent and investors. A trustworthy, human, responsive bank, that acts as a growth catalyst and unlocks potential for households, businesses and communities. Our Code of Ethics sets the principles and values that are fundamental to the corporate culture of NBG Group, harmonized with the applicable legal and regulatory framework and international best practices. The above mentioned 4 key values comprise the core of the Bank's and the Group's value system:

• Human: Your needs and choices are at the centre of everything we do.
• Trustworthy: We operate with transparency, knowledge and experience.
• Responsive: We provide flexible solutions tailored to your needs.
• Α Growth Catalyst: We accelerate progress and prosperity.

Corporate Governance Policies and Practices

The Bank's corporate governance framework is determined by the relevant provisions of the legislative and regulatory framework at national and European level and best practices of corporate governance, as incorporated in the Bank's Articles of Association, the Corporate Governance Code and other internal arrangements/ regulations. Furthermore, the regulatory framework set out in the revised Relationship Framework Agreement (RFA) between the Bank and the HFSF, and the Bank's obligations against the Monitoring Trustee apply. In order to achieve a robust corporate governance and strengthen the existing risk management framework, the Bank has adopted corporate governance practices and policies, governing the relations between the shareholders, management and stakeholders, and which are harmonized with its activities and ensure the transparency and efficiency of its operations.

Group Code of Ethics

In 2020 the NBG Group Code of Ethics was revised to incorporate new principles, to update and enrich the framework of the Code, as well as to redesign its form, in order to facilitate a better understanding of the rules of conduct and obligations arising from the regulatory framework. It is noted that the Bank ensures that all the Bank's human resources are trained, through a special e-learning program, regarding the content of the Code of Ethics and Conduct. The NBG Group Code of Ethics is available at the Bank's website at www.nbg.gr (Section: Group/ Corporate Governance/ Regulations & Principles.

Code of Ethics for Financial Professionals

The Code of Ethics for Financial Professionals sets out the key ethical obligations and standards of conduct applying to persons who are involved in the procedures for the preparation, compilation and submission of financial statements and other financial disclosures of the Bank and the Group companies. Further information is set out in the Corporate Governance Statement, which is an integral part of the Annual Report of 2020 of the NBG Group, available at the Bank's website.

Whistleblowing Policy

The Bank has adopted the Whistleblowing Policy for the Bank and the Group through which procedures are established for the submission of confidential reports or comments by any party, either anonymously or not, regarding behavior of the Bank and the Group's executives, which indicate the existence of an irregular activity or misconduct or omission relating to breaches in regard to internal Policies and Procedures. The Policy complies with the provisions of Greek Law 4261/2014 regarding the internal procedures for violation complaints. The Compliance, Ethics and Culture Committee of the Bank's Board of Directors is responsible for the establishment and the continuous monitoring of the implementation of these procedures, which ensure confidentiality and secrecy of the reports or comments received. It should be noted that a special e-learning program was developed regarding the content of the Whistleblowing Policy of the Bank and the Group, in order to further strengthen the Whistleblowing culture of the Bank's employees.

 
Anti-Fraud Policy

NBG Management has among its highest priorities the prevention and combating of fraud as well as of any other irregular activity, and accounting and auditing practice inconsistent with international practices and applicable provisions, activities which are contrary to the fundamental values and principles governing the Bank and the Group's business activities.

Prevention of conflicts of interest

The Bank and the Group Companies place emphasis and take the appropriate measures to handle cases that may cause or lead to conflict of interest within the context of the services they provide. With the purpose of preventing real or potential cases of conflict of interest, the Bank and the Group has adopted the following Policies:

• Policy for avoiding Conflicts of Interest for Board Members, Senior Executives and other Related Parties of NBG
• Conflict of Interest Policy
• Policy for Connected Borrowers of the Bank and the Group in Greece

 
Anti-corruption and anti-bribery policy

Group Anti-bribery Policy

The Group Anti-bribery Policy has been set according to the requirements of the legal framework for combating bribery as well as the international best practices and guidelines of international organizations and bodies for preventing and combating financial crime

NBG Customer Complaints Management Policy

To manage effectively customer complaints, the Bank has introduced a Customer Complaints Management Policy governing in detail customer complaints management and its key principles. Also, the Client Conduct Sector undertakes to respond promptly to grievances filed either directly by the Bank's customers or by other bodies

See more: NBG_SUSTAINABILITY REPORT 202... p. 11, 30, 101, 123-136

See also: Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr).

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7. Monitoring

ADMINISTRATIVE PRACTICES

The bank uses relevant metrics to monitor its ESG strategy implementation. In 2021, NBG also incorporated in its NBG ESG Report 2020 SASB & TCFD key metrics in order to further enhance the quality and the transparency of its disclosures.

Reports

The latest 2020 Sustainability Report (annual reporting cycle) is the 14 Sustainability Report of the Group of the National Bank and is available on www.nbg.gr  The Report presents the sustainable actions implemented by the Group of the National Bank, their results, as well as the Bank's commitments for the coming years and, is addressed to all Group stakeholders.  The goal is to meet the needs of the Group of the National Bank stakeholders, highlighting the Bank's commitment to Sustainable Development.

The Board of NBG ensures that material environmental and social considerations are integrated into the Bank's strategy, business model and risk management system and addressed in its public disclosures.

NBG Group Corporate Governance and Corporate Social Responsibility Division is responsible for the calculation, collection and consolidation of quantitative data as well as for the accuracy and completeness of the quantitative and qualitative data included in the report. The report has been prepared in accordance with the GRI Standards and covers all NBG business activities in Greece. The activities of NBG subsidiaries, institutions, suppliers and further activities of joint ventures, in general, are not included in the Report. The financial data in the Report concern the Bank's domestic activities as well as these of NBG branches in Egypt and the United Kingdom. In addition, for completeness reasons and to disclose comparable information, indicative data from 2018 to 2020.

To determine the content of the Report, the Bank conducted an internal and external Materiality Analysis in 2021, based on GRI standards, and the Material Topics that arose from the materiality analysis are analyzed in the Report.

Any restatements of information included in previous reports have been indicated within the report in the respective sections. The report has been subject to external assurance.

Please see NBG_SUSTAINABILITY REPORT 202...

• GRI indicators in the GRI table of contents, p. 139-149,
• SASB Index, p. 152-157
• Indicators from other standards, p. 157-158
• Report for the independent assurance statement, p. 159-163

See also: Principles-for-Responsible-Banking.pdf (nbg.gr), ATHEX ESG REPORTING GUIDE (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr)

ESG Ratings

NBG follows:

ESG related qualitative and quantitative risk metrics have been introduced to the Risk Appetite Framework of the Bank. The Bank’s Risk Appetite Framework, which is discussed and approved at Board level, includes ESG related metrics. More information about this metric is available in the following sources:

1. Compliance, Ethics and Culture Committee Charter, page 9 2.
2. Innovation & Sustainability Committee Charter, pages 4, 6 3.
3. Corporate Governance Code, pages 3-8, 23-27 4.
4. Group and Bank Annual Financial Report 2021, pages 95, 128, 134-141 5.
5. NBG Group Sustainability Policy, pages 7-8

Monitor

NBG continuously seeks to strengthen and enhance the Internal Control System (ICS) at Group level. The ICS comprises a set of control mechanisms and procedures that cover on an ongoing basis every activity and contribute to the efficient and secure operation of the Bank and the Group. The Bank uses as a reference the COSO 2013 Internal Control Integrated Framework and the ICS is based on the five main, per COSO components of internal control: Control Environment, Risk Assessment, Control Activities, Information and Communication as well as Monitoring Activities.

The Group endeavours to safeguard its systems and processes and strives to continuously monitor and develop them to protect its technology infrastructure and data. The Bank, in order to certify that follows best practices regarding information security and to strength its security footprint has been certified against ISO 27001 for the scope of IT infrastructure and services.

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8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

Policies

The Group Remuneration Policy sets out the general framework for remuneration throughout the Group and defines the basic principles on which the NBG Group approaches issues regarding the remuneration of executives and employees.

NBG Board of Directors’ & Senior Managers’ Remuneration Policy sets out the general framework for the remuneration of the members of the Board of Directors and Senior Managers (General & Assistant General Managers), in accordance with the applicable legal and regulatory provisions, and in alignment with the principles set out in the NBG Group Remuneration Policy, and covers the total remuneration awarded to all Board Directors (Executive and Non-Executive), i.e. fixed and variable remuneration, including benefits, participation in Committees fees and other potential compensation, as well as the total remuneration awarded to all members of Senior Management (i.e. General Managers and Assistant General Managers).

Remuneration policy

NBG is strongly opposed to any form of discrimination and is vigilant in ensuring that there is no discrimination in terms of pay or other matters between men and women. The Bank has established Policies, Regulations and Procedures to deal with employees' issues, including working hours, leave, overtime, remuneration and other issues related to the general working status of the Bank's employees, in compliance with the applicable legislative and regulatory framework.

Remuneration of Board Members

The remuneration of Board members is determined and approved by the Bank's Annual General Meeting of Shareholders, following the proposal of the Board of Directors (non-executive members), in accordance with the legislative and regulatory framework to which the Bank is subject to.

The nomination of candidates for the Bank's Board of Directors is carried out in accordance with the Board Nominations Policy, the Policy and Procedure for the Assessment of Suitability of the Board of Directors, the provisions of the Bank's Articles of Association, the Corporate Governance Code, the Charter of the Corporate Governance & Nominations Committee, and the provisions of the relevant regulatory framework, also taking into account international best practices. The Board of Directors, alongside the Corporate Governance & Nominations Committee (CGNC), conducts an annual self-evaluation process to assess the effectiveness of the Board's and its Committees' work, as well as collective bodies, and the individual contribution of each member thereof, on the basis of a method developed and approved by CGNC, while taking into account the applicable legal and regulatory framework. Every three years the evaluation is conducted by an external advisor, whose selection falls within the responsibilities of the CGNC. The questionnaires used in the Board's annual self-evaluation are reviewed and approved by the CGNC on an annual basis before commencing the evaluation, so as to ascertain that they continue to correspond to the conditions each time prevailing, including the Bank's priorities, the applicable regulatory framework and the best corporate governance practices. Within this context, during 2020 the Board with the assistance of the CGNC and the facilitation of an external consultant conducted the annual collective evaluation of the Board and its Committees, while particular emphasis was given on including evaluation criteria with respect to ESG, highlighting the importance of this area in the Board strategy and oversight. In response to the evaluation conducted, particularly with respect to ESG respective actions, initiatives that have already been followed up on included:

• adding a distinct initiative on ESGs to the Bank's Transformation Program, through which there is ongoing monitoring and tracking of the Bank's actions in the context of ESGs
• enhancing the level of information flow at Board level
• fostering a deeper integration of ESG matters into the Bank's business strategy.

In order to ensure that remuneration policy and practices stimulate behaviour consistent with the climate related and environmental risk approach and with voluntary commitments of the Bank, we are in the process of embedding ESG criteria in our Performance Management framework, starting from senior management:

• NBG’s Variable Remuneration Scheme, introduced in 2021, rewards NBG staff in line with the level of achievement of annual performance outcomes, as per the Bank’s respective Performance Management System.
• In 2022, ESG related targets and KPIs were introduced in the 2022 PMS for the Top Management.
• Our Remuneration Policy is currently in the process of being updated along these lines and in compliance with the relevant EU and local legislation.

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PERFORMANCE INDICATORS

SRS-102-35a: Πολιτική αποδοχών

In accordance with Directive (EU) 2017/828, as this has been (partly) transposed into the Greek legal framework with Greek Law 4548/2018 on Sociétés Anonymes, listed companies are required, among others, to establish a remuneration policy as regards directors and shareholders have the right to vote on the remuneration policy at the General Meeting. Additionally, in accordance with article 110 para. 1 of Greek Law 4548/2018, by statutory provision the Policy may also include in its scope the key management personnel, as defined in International Accounting Standard (IAS) 24 para. 9. Within this context and with the aim at further enhancing transparency in the remuneration framework of the Bank’s management structure especially by extending the scope of the Policy so as to include not only Board members but also Senior Managers, the Bank’s Annual General Meeting of Shareholders, held on 31 July 2020, following proposal of the Board of Directors, as assisted by the Corporate Governance and Nominations Committee and the Human Resources and Remuneration Committee, approved the revised NBG Board of Directors’ & Senior Managers’ Remuneration Policy. With this revision, the Board aims to offer shareholders and the market the highest level of transparency and clarity in the remuneration scheme applicable to Senior Manager, further strengthening the investment profile of the Bank in order to ensure external competitiveness. The NBG Board of Directors’ & Senior Managers’ Remuneration Policy shall be applicable for a period of four years, unless revised earlier or in cases of temporary derogations, in alignment with the relevant applicable provisions. The NBG Board of Directors’ & Senior Managers’ Remuneration Policy is available on the Bank’s website, at www.nbg.gr (https://www.nbg.gr/en/group/esg/corporate-governance/corporate-governance-framework).

SRS-102-38: Συνολικές αποζημιώσεις ετησίως

The ratio of the regular first NBG salary, as per the latest Business Collective Labor Agreement, to the statutory minimum wage as applicable under the National General Collective Labor Agreement ranges between 129.69% and 146.46% irrespective of gender, age and geographical region.

According to the latest National Labor Collective Agreement, the statutory minimum wage stands at €650. In National Bank of Greece, currently, the statutory minimum wage for the employees stands at €952, for the auxiliary employees at €883 and for the cleaning employees at €843. In any other case, remuneration issues are determined by the Bank's remuneration Policy in line with the applicable regulatory framework.

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9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

NBG's stakeholders are comprised of persons and legal entities who influence and are influenced or are likely to be influenced by NBG's business decisions and activities. The Bank applies specific procedures in order to identify its stakeholders. Accordingly, it recognizes the following basic groups as stakeholders:

1. Investors and Shareholders 2. Customers 3. Employees 4. Suppliers and Partners 5. Business Community (i.e. Business Associations, Peers, Rating Agencies/ Analysts) 6. State and Regulators (i.e. Ministries, State Bodies, Regulatory Authorities, Intergovernmental organizations) 7. Society - Communities (i.e. Media, NGOs, Civil Society Organizations, Local Authorities).

NBG communicates on a regular basis with each stakeholder group understanding the importance of this communication in obtaining the necessary information to improve its actions. Stakeholder engagement aims at identifying key topics and mutually acceptable solutions with benefits for all parties through correct business practices. The expectations of stakeholders, as well as the business environment in which the Bank operates, are constantly evolving. Evaluating the key issues helps us to identify and prioritize the environmental, socioeconomic and governance issues that are of highest concern to stakeholders and the Bank. This process is carried out annually or no later than every two years and was last completed in 2021. The main issues of concern, as recorded through the Bank's communication channels and assessed by the Bank in the context of implementing the AA1000AP (2018) (AccountAbility Principles Standard), are presented below, including the basic engagement methods and their frequency.

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PERFORMANCE INDICATORS

SRS-102-44: Σημαντικά θέματα και προβληματισμοί που προέκυψαν.

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10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

The Bank

• places emphasis on promoting sustainable finance and investment and enhancing its "green" banking offering, partnerships and investment options, reacting to and foreseeing further growing interest in products, services and instruments that contribute to environmental protection, sustainable development, and cyclical economies, in response to climate change
• enhances its lending policies and processes, introducing environmental (including climate-related), social and governance risks assessment, applied both at the obligor and the transaction level (with the latter based on Sustainable Lending Criteria aligned with the EU Taxonomy and the Sustainability Linked Loan Principles)

Encouraging sustainable practices

NBG fully recognizes its role in supporting sustainable growth for its customers and has increasingly been applying practices aiming to promote economic development, foster environmentally friendly growth, offer more efficient services to customers, and contribute, in general, to the community. The Bank supports business activities that build on and enhance the energy and environmental potential of Greece, such as:

• ‘Green’ financing through an array of products and services, such as the Green Loan, Estia Green Home, Energy Saving at Home II" Program, Credit approvals for participation in financing renewable energy sources investments

The Bank supports business activities that boost the overall environmental potential of Greece, such as:

• Production of “green”, traditional and organic products.
• Environmental infrastructure projects (via central government or local authorities' organizations).
• Investment in environmental protection, “clean” technology, certification of environmental management systems, saving energy and natural resources.
• Participation in joint funding packages for environmental programs for the enhancement of entrepreneurship
• Research and Development (R&D) of environmental products and practices.
• Green Bond Issuance: Within the first year of the issuance, 70% of the proceeds have been allocated to 42 renewable energy projects across Greece, in total: o Environmental infrastructure projects (via central government or local authorities' organizations). o Investment in environmental protection, “clean” technology, certification of environmental management systems, saving energy and natural resources.
• Participation in joint funding programs for environmental programs for the enhancement of entrepreneurship
• Innovation, via its focus on financing initiatives with a strong innovation and know-how component, as well as research programs on environmental technologies that contribute to the country's efforts to improve its environmental footprint
• Renewable Energy: the Bank has set up a special team that handles applications for funding of Renewable Energy Sources (RES) projects and provides advice to potential project finance investors, as well as to SMEs.
• ESG incorporation in Loan Origination & Credit Assessment: via the introduction of a series of selected and tailored ESG criteria in assessing new financing applications in Corporate Banking, the Bank is starting the ‘sustainability’ dialogue with its customers, urging them to consider sustainability aspects of their own model and activities and working with them to improve environmental and social footprint.

Sustainable Lending Criteria Framework

The Bank has enhanced its lending policies and processes, incorporating environmental (including climate change), social and governance criteria, applied both at the obligor and the transaction level. Specifically, in alignment with its broader sustainability strategy, NBG has established a Sustainable Lending Criteria Framework (SLCF), in order to identify and classify the activities included in its corporate lending portfolio, that contribute to the transition towards a more sustainable economy. The Framework outlines the logic of classification of an activity as sustainable, building upon the EU Taxonomy Regulation and Sustainability-Linked Loan Principles (SLLP). In conjunction with the SLCF, the Bank introduced in April 2022, new ESG Questionnaires and relevant assessment procedures (including sector-specific ones) to its lending processes. The aim is not only to fulfil existing and forthcoming regulatory requirements, but also to address the issue of ESG data availability and granularity by implementing a robust data collection process which sources client data useful for multiple purposes. By collecting and storing customer-level ESG data, NBG will be better placed to identify and address the environmental impact of its corporate lending portfolio, to balance economic and environmental objectives in its financing decisions, and to actively foster sustainable growth and transition towards a low-carbon economy, in line with its core values, vision and strategy.

Increase its positive impact of financing activities on inclusive and healthy economies

NBG has significantly expanded and will maintain its financial support to Medium and Large Enterprises, actively contributing to mitigating the adverse financial consequences of the Covid-19 pandemic and supporting the businesses affected by it, while offering a steady flow of liquidity to enterprises that continue to invest in competitiveness, innovation, export potential and sustainability, in line with its long-term strategy. The Bank supports its customer groups/segments through different programs, products, initiatives and infrastructure, such as:

➢ Business Financing - TEPIX II

➢ Covid- 19 Business Guarantee Fund Program

➢ Micro-credits via the EaSI Guarantee Instrument Program

➢ COSME Loan Guarantee Facility in cooperation with the European Investment Fund (EIF)

➢ POS Financing Product

➢ Supporting entrepreneurship and innovation through Business Seeds and other actions

➢ Supporting digitalization of customers key processes and offering

➢ Cards – Issuing Business

➢ Widespread customer service network (with particular initiatives in support of remote regions and islanders, as well as people with special needs)

➢ NBG Loan for Female Empowerment

Supporting entrepreneurship and innovation

• NBG Business Seeds

NBG Business Seeds is an integrated program designed to foster innovative and export-oriented entrepreneurship.  Executives of the program participate in the Advisory Board of OK! Thess and the Archimedes Center of the National and Kapodistrian University of Athens (NKUoA) as well as in the Education, Innovation and Entrepreneurship Committee of the American-Hellenic Chamber of Commerce. In 2020 the Hub to Business Hub program (H2B HUB) of the Heraklion Chamber of Commerce and Industry, the EIT Climate-Kic Hub Greece and its facilitator, Athena Research Center, as well as the Greek branch of the international body Entrepreneurs' Organization (EO) joined NBG as partners. The cooperation of the program with faculty members from 11 universities for the evaluation of the 265 proposals of the 11th Innovation & Technology Competition continued for yet another year.

• Supporting Digitalization

The Bank places special emphasis on supporting its customers through the designing of smart digital solutions that meet customer needs. Our electronic banking services benefit all of our customers, whether individuals or businesses, and at the same time help reduce our environmental footprint.

• Supporting customers in response to Covid-19 pandemic

The Bank supports Medium and Large Enterprises aiming to support those hardest hit by the adverse financial consequences of the Covid-19 pandemic, while maintaining a steady flow of liquidity to enterprises that continue to invest in competitiveness, innovation, export potential and sustainability, in line with its long-term strategy. In this context the Bank actively participated in the utilization of financing programs offering favorable terms to companies, in cooperation with European and domestic organizations, such as:

• the Hellenic Development Bank (HDB) including NBG’s participation to the Covid-19 Business Guarantee Fund, the TEPIX II Subprogram 3 and TEPIX II Subprogram 4
• the European Investment Bank (EIB) (financing investments that contribute to the achievement of climate action objectives and promote female entrepreneurship)
• and the European Investment Fund (EIF).

Launching new products & services and updating of existing ones

In its endeavour to remain fully compliant on an ongoing basis with the legal and regulatory framework, the Bank also implements a procedure for controlling newly-launched products and services as per the Regulation governing the introduction, modification, withdrawal of the products and services of the Bank. According to this Regulation, established in the framework of the Bank's harmonization to the applicable legislative and regulatory framework and aiming at the best customer service, with a view to establishing and adopting the basic principles governing the Bank's operations, the Bank follows a specific procedure for the introduction, modification, withdrawal of NBG products and services. Accordingly, the Proposing Units request written reports from the Units involved in order to express their opinion. It is worth noting at this point that in any case where the above-described procedure is implemented, special emphasis is placed on identifying and managing issues related to the current regulatory framework regarding the protection of individuals against processing of personal data, as well as the general protection of consumers in order to preserve, ensure and promote the continuous compliance of the Bank with the relevant institutional framework and to strengthen the customer centric approach of the Bank in relation to its general activities. It is pointed out that, in the case of financial instruments and insurance distribution, the specific provisions of the Financial Instruments and Insurance Products Monitoring Policy are taken into account, prepared and implemented by the Bank in compliance with the regulatory and legislative framework of the MiFID II Directive for Markets in Financial Instruments and on the Insurance Distribution Directive (IDD), which were incorporated into Greek legislation respectively with Law 4514/2018 and Law 4583/2018.

In 2020, National Bank of Greece introduced a research program to record Customer Experience (Customer Experience Project). According to the results of this survey, 64% of customers positively evaluate the overall experience with NBG. Digital channels provide the most positive experience (83% positive rating for internet banking and 84% for mobile banking), while lower ratings are recorded for the experience in branches and the Contact Center (68% positive rating for both channels).

Economy/innovation support

Recognizing that science, research and innovation are the drivers of economic growth and prosperity, and that our era, in particular, is the starting point of transformational innovations and new challenges, the Bank supports programs and initiatives that promote innovation, technological development and entrepreneurship.

See in detail NBG_SUSTAINABILITY REPORT 202... p. 40-41, 60-73, 102, 108-109 & Principles-for-Responsible-Banking.pdf (nbg.gr)

See also: ATHEX ESG REPORTING GUIDE (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr)

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PERFORMANCE INDICATORS

• The total percentage of sustainable products revenue as part of the total revenue is not available. However, NBG provides a number of sustainable products and the revenue per product category, available below:

• In 2021, NBG produced electrical energy from solar panels, operating in three of its buildings amounting to 242.52 MWh. This energy is sold to the grid through net metering. In 2021, NBG’s total energy consumption was 201,175,135 MJ, reduced by 5.3% compared to 2020 (212,498,242 MJ) and by 15.3% compared to 2019 (237,522,980 MJ).

See NBG_SUSTAINABILITY REPORT 202... p. 51

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11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

In alignment with our core values of Growth and Responsiveness we are building on NBG’s leading position in energy to address climate impact & support transition to a sustainable economy through initiatives where we:

1. Lead the market in sustainable energy financing,
2. Accelerate transition to a sustainable economy
3. Role-model environmentally responsible practices.

NBG recognizes that its operation has direct and indirect economic, social and environmental impacts on its stakeholders, as well as wider impacts on the economy, society and the natural environment. We also acknowledge the importance of our role as a financial institution in the transition to a sustainable economy, complying with regulatory requirements, adapting access to finance, facilitating the transition to a net-zero carbon economy and developing new products and services that meet the needs of our customers to create long-term value and manage their environmental impact.

NBG, guided by its values, principles and vision is constantly adjusting to the requirements of our era, contributing to sustainable development by implementing best practices in environmentally responsible banking. Standing by its commitment to play a key role to the economic and social development of the country, NBG has established and implements the Group Sustainability Policy, the Code of Ethics, the Code of Ethics for Financial Professionals and the Corporate Governance Code, while it has developed since 2004 an Environmental Management System which is in conformity with the requirements of the international standard ISO 14001. NBG believes that environmental responsibility and the reduction of its environmental footprint are cornerstones of sound corporate behaviour and, therefore, vital to sustainable development and to addressing climate change. This responsible approach is an essential and indispensable part of the Bank's ESG Strategy, which actively pursues the realization of wider environmental goals as these are stipulated through the Paris Agreement on climate change and the UN Sustainable Development Goals.

In the context of the Environmental Management System, the Bank's environmental impact was analysed and led to the formation of the following five key principles of NBG's action program:

1. Conservation of natural resources and energy
2. Rationalization of work-related travel and commuting
3. Effective management of paper and solid waste
4. Adoption of environmental standards in procurement
5. Deployment of an environmental risk assessment policy in investment and credit processes.

Environmental impacts of financing, products and services

NBG appreciates that there are environmental impacts arising from the provision of financing by the Bank. Sustainable finance required for the transition to a sustainable economy is gathering significant momentum globally, rapidly becoming an immediate-term strategic priority and operational reality for all types of financial services organizations. Considering the risks, as well as the compelling opportunities, the necessity for financial services organizations to set a clear and forward-looking business strategy for sustainable finance and their role in the transition to net-zero, is more prominent than ever.

In the context of implementing the UNEP FI Principles for Responsible Banking (PRB), NBG used the UNEP FI Portfolio Impact Analysis Tool to identify the potential environmental and socioeconomic impacts caused from finance and services provided to the corporate, business and retail clients.

The results of the impact analysis showed that the most significant potential negative environmental impact areas of our financing activities are on climate change and resource efficiency/security.

Additionally, the above potential impacts were prioritized through the stakeholder engagement that took place as part of the materiality analysis survey performed in 2021. More specifically, these impacts are described as follows:

1. Impacts of products and services to climate change: Financing provided by NBG to certain sectors, such as energy trade and production, transport, industry (including construction) and real estate, etc. can have an impact on the composition of the global atmosphere and its exposure to greenhouse gas (GHG) emissions as a direct factor contributing to climate change

2. Impacts of products and services to the acceleration of the circular economy (resource efficiency/security): Financing provided by NBG to certain sectors, such as the production and generation of energy/electricity, the transport sector, the construction sector, etc. can have an impact on the efficient use of limited, non-renewable natural resources (which cannot be regenerated after exploitation)

• Protecting Biodiversity

Nature and biodiversity are important drivers of our economy. Financial institutions can play a critical role by shifting their financing and investment away from nature-negative activities and towards nature-positive ones. Additionally, F s are in the process of assessing physical and transition nature-related risks, their portfolio's impact on biodiversity and integrating relevant considerations into their processes. Ι NBG implements a policy for the analysis and assessment of environmental risks involved in investment and credit processes and is committed to fully complying with the relevant environmental legislation, turning down applications for financing investments in protected areas. Moreover, in line with its traditional awareness of social and environmental responsibility issues, NBG donates funds for the protection and best management of some of the country's most important nature reserves.

• Responsible financing

NBG fully recognizes its role in supporting sustainable growth for its customers and has increasingly been applying practices aiming to promote economic development, foster environmentally friendly growth, offer more efficient services to customers, and contribute, in general, to the community. The Bank supports business activities that build on and enhance the energy and environmental potential of Greece, such as:

• ‘Green’ financing through an array of products and services, such as the Green Loan, Estia Green Home, Energy Saving at Home II" Program, Credit approvals for participation in financing renewable energy sources investments
• Green Bond Issuance: Within the first year of the issuance, 70% of the proceeds have been allocated to 42 renewable energy projects across Greece, in total: o Environmental infrastructure projects (via central government or local authorities' organizations). o Investment in environmental protection, “clean” technology, certification of environmental management systems, saving energy and natural resources.

• Principle of Prevention

NBG takes into account the principle of proactive prevention in its business planning, in developing new products and in its financing decision-making process. The Bank's activity as a financial institution does not inherently generate increased likelihood of direct environmental risk (such as in the case of a heavy industry). Nevertheless, NBG undertakes proactive measures adopting the key principles of the applicable legal and regulatory framework.

• Training – enhancing stakeholder awareness

With a view towards continuous improvement, implementing our Environmental Management System, enhancing our business environmental culture and promoting stakeholder awareness on environmental protection issues, we carried out the following actions in 2021:

Employees

To enhance effective application of its Environmental Management System, the Bank has appointed since 2011, Environmental Management System Officers in all its Units (Administration and Branches).

In addition, during 2021, the Bank’s employees were provided with updates on sustainability, through 24 intranet announcements, of which 19 were related to the Bank’s environmental management, as well as to general environmental topics.

WWF's global “Earth Hour” campaign

The Bank participates in the WWF's global “Earth Hour” campaign, in order to encourage its personnel and customers towards supporting this significant initiative.

In-house environmental impacts

According to NBG's Sustainability Policy, the Bank aims at reducing its environmental footprint and its impacts (including on climate, water, air, land, biodiversity, use of resources) resulting from its own operations and management of its own infrastructure. In this context, priority issues are:

• • Improving the energy efficiency of its buildings.
  • Conservation of natural resources and energy.
  • Efficient management of paper and solid waste.
  • Rationalization of business-related travel and encouraging the use of public transport.
  • Enhancement of the employees’ environmental awareness.
  • Compliance with environmental legislation.

• Resolving environmental complaints

In 2021, the Bank did not identify any non-compliance with environmental laws and/or regulations, and no fines were imposed on the Bank regarding the environment. Furthermore, 10 complaints regarding the Bank’s environmental impact were filed via official grievance mechanisms and were settled

within the year. The complaints were related to the following issues: condition of external areas/facades of branches, repair of damages and cleaning inside the branches.

• Energy

Within the context of buildings' energy management, we aim to reduce electricity consumption and consequently air pollution. The energy consumption concerns non-renewable such as Electricity, Natural Gas, Heating oil, Diesel, Petrol, LPG and renewable sources, such as Electricity from RES. NBG produced electrical energy from photovoltaic panels, operating in two of its buildings. This energy is sold to the grid through net metering.

The total amount of energy consumed within the organization (MWh) was 54,422 in 2021.

• Water

NBG fully recognizes the importance of water efficiency, as it is a valuable natural resource, which will gradually be under pressure as a result of the impact of climate change in Greece and abroad. The Bank's water supply comes from the public water supply network. Because of the nature of the Bank's activities, the water is mainly used in rest room facilities and for cleaning work areas, while the use of watercooled air-conditioning systems is limited. As a result, the Bank's actions focused mainly on preventing and avoiding leakages by regularly maintaining its piping network. The water discharged from Bank's buildings is wastewater managed by the local wastewater treatment networks.

• Raw materials

As a financial institution, the Bank uses and is supplied with materials which mainly concern office equipment and consumables. The main categories of the Bank's office supplies are: writing materials, light bulbs, UPS, batteries, office consumables (including toner and ink cartridges for printers), paper, computers and other electrical and electronic devices.

NBG's daily activities produce mainly paper as solid waste. Since 2011, the Bank's correspondence (internal and to third parties) is fully managed by the Internal Electronic Document Management System, resulting in a significant reduction in printing and paper consumption.

In order to minimize the environmental impact of toner and other equipment disposal (computer and other furniture and appliances), the Bank proceeds to recycling or donation. The Bank systematically recycles via its partner companies (“SYDESYS S.A.”, “Appliances Recycling S.A.”, “Fotokyklosi S.A.”, “AFIS S.A.”) accumulators, small batteries, low-energy light bulbs and electrical/electronic appliances (computers and other equipment). Recycling of the above mentioned materials was carried out through the local collection points (Administration Buildings and Branches) present in almost all of its buildings. The partner companies which manage the recycling process do so in a way that is in line with contractual and legislative obligations.

See in detail NBG_SUSTAINABILITY REPORT 202... p. 37-57

See also: ATHEX ESG REPORTING GUIDE (nbg.gr), & Principles-for-Responsible-Banking.pdf (nbg.gr), Annual-Financial-Report-2021-EN.pdf (nbg.gr)

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PERFORMANCE INDICATORS

SRS-301-1: Υλικά που χρησιμοποιούνται κατά βάρος ή όγκο.

SRS-302-1: Κατανάλωση ενέργειας εντός του οργανισμού.

SRS-303-1: Κατανάλωση νερού

The impact on water resources is regarded as low since the water intensity of the Bank's operations is lower than the average water use of 35 liters per person per day as proposed by WHO.

See more: ATHEX ESG REPORTING GUIDE (nbg.gr).

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12. Resource Management

ADMINISTRATIVE PRACTICES

NBG has set short/mid-term Environmental commitments

In the context of UNEP FI’s commitments and following the Impact Analysis process, the impact areas of “Climate “and “Inclusive, Healthy Economies” were prioritized as potentially the most significant impact areas. NBG has initially set 2 SMART targets on these impact areas {€600 million financing of renewable energy in 2022-25 and 3 million active digital users (12-month) by the end of 2024} and is in the process of revisiting and enhancing these targets following further analysis.

In the context of the implementation of its Sustainability Policy and Environmental Management System, the Bank also carried out the following actions in 2020 - 2021:

• NBG achieved for 2020 a reduction in total energy consumption by 10.2% compared to 2019, and by 18.9% compared to the energy consumed in 2018, which is mainly due to a series of energy saving actions.
• In addition, NBG achieved in 2020 a reduction of it’s related to energy consumption CO2e emissions (Scope 1, Scope 2 and Scope 3) by 4.6% compared to 2019. The corresponding reduction between 2020 and 2018 was 10.8%.
• Effective energy management and reduction in energy consumption in our buildings are significant components of our actions that form part of our ESG strategy. Through energy saving actions implemented in 2021, NBG avoided 133,397,852 kg CO2 emissions and saved 156,939 kWh.
• Recycling programs were implemented with the participation of employees. Indicatively, 93 tonnes of paper, 2,361 kg of small and large batteries, and approximately 196 tonnes of electronic and electrical equipment were recycled. In addition, 2,681 kg of low voltage lamps and lighting equipment and 160 kg of plastic and aluminum were recycled through the expansion of recycling across the Bank’s branch network. All these recycling programs were implemented in cooperation with licensed contractors.

In the context of the «NBG Environmental Footprint» initiative, a series of actions were carried out aiming at saving energy and natural resources that are presented below:

➢ Plug-In Hybrid Cars: In 2021, a total of 54 Plug-in Hybrid cars were acquired, with their average carbon emissions amounting to 34gr CO2 / km. The annual carbon emission reduction is estimated at 108,000 kg CO2 / year.

➢ Discontinuation of plastics from NBG Canteens: By discontinuing plastic material usage in 4 NBG canteens, it is estimated that the use of 123,850 pieces of plastic (utensils, cups etc.) was avoided per year.

➢ Ecological cleaners: By replacing the existing cleaning materials with 100% ecological, the usage of 15,250 lt of harmful cleaners was avoided per year.

➢ WC photocell taps: By installing 343 WC photocell taps in 6 Administrative buildings, it is estimated that approximately 4,600 m³ (or 4,600,000 lt) are saved per year.

➢ Recycling bins (paper / plastic / aluminum): By installing recycling bins in 10 buildings, the following were collected (and recycled as appropriate) on an annual basis: o Ungraded paper: 4,500 kg. o Plastic / Aluminum: 160 kg.

➢ 100% recycled A4 paper: From consuming 22,880 bundles of 100% recycled paper, the following were saved on an annual basis:

• • Wood: 680,000 kg.
  • Water: 2,000,000 lt.
  • Energy: 680,000 kWh.
  • CO2 emissions: 129,500 kg CO2.

Also, within 2021, the following actions were completed, the results of which are not yet calculated:

1. Initiation of a procedure for the issuance of a LEED certificate for the Karatza Mansion.
2. Energy upgrade studies in 14 Administration buildings.
3. Implementation of energy upgrade actions in 2 Administration buildings.
4. Installation of a central platform for measuring and monitoring electricity consumption in 49 NBG buildings.
5. Configuration of an energy policy strategy for NBG buildings.
6. Installation of a Photovoltaic Park in the facilities of the warehouses of PAEGAE in Magoula with a capacity of 1.8 MWp, whose connection to the HEDNO network and its activation is pending.
7. Integration in all new projects (adaptations, relocations, etc.) of new energy actions such as installation of motion detectors and new air conditioning systems.

The development of processes/transactions with a view to reducing operating costs, rationalizing printing and saving natural resources (paper) was continued in 2021.

As regards prevention of consumption of natural resources, note that in the course of the Bank's normal business activity the bulk of solid waste is paper. Since 2011, the Bank’s correspondence (internal and to third parties) is fully managed by the Internal Electronic Document Management System, resulting in a significant reduction in printing and paper consumption. In 2021, 520,533 documents were exchanged through the Internal Electronic Document Management System, thus saving almost 1,301,332 page prints. Furthermore, the use of the e-signature application also contributed towards limiting paper consumption (c. 9.5 million print-outs during 2021). Additionally, during 2021, the connection of myNBG system and internet banking with e-Gov was implemented, enabling customers to update their data digitally, without the need to submit documents.

As regards toner management, the Bank has arranged since 2014 the outsourcing of Managed Print Services (“MPS”) printing needs of Central NBG Services hosted in central buildings and its Branch Network. Environmentally friendly management of waste originating from the device consumables, is also part of this outsourcing arrangement. This program leads to the reduction of printouts and, as a consequence, the reduction of paper and toner consumption. The project establishes centralized management of printing needs. The number of the system's current users amounts to c. 7,365 individuals. In 2021, the toners supplied through the MPS. system totalled 6,045 items, while 1,791 items were recycled through the 2,829 MPS units. It is anticipated that the future benefit for the Bank will be a 25% - 35% reduction in printing costs.

Aiming at environmental protection, the Bank launched its i-bank statement service whereby its customers receive electronic statements regarding their credit cards and mortgage or consumer loans and savings accounts and stopped receiving printed statements. The i-bank statement service has been activated for more than 2 million statements. Moreover, NBG's i-bank delivery channels are being enriched on an ongoing basis with new services and more transactions enabling customers to carry out transactions 24/7 from home or with their mobile phone. Note that more than 450,000 new users were registered in 2021 for NBG's Internet/Mobile Banking services.

See also: ATHEX ESG REPORTING GUIDE (nbg.gr), & Principles-for-Responsible-Banking.pdf (nbg.gr)

Annual-Financial-Report-2021-EN.pdf (nbg.gr),  p. 108-109.

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PERFORMANCE INDICATORS

SRS-302-4: Μείωση της κατανάλωσης ενέργειας.

• NBG achieved for 2020 a reduction in total energy consumption by 10.2% compared to 2019, and by 18.9% compared to the energy consumed in 2018, which is mainly due to a series of energy saving actions.

SRS-306-2: Συνολικό βάρος των αποβλήτων, με βάση τον τύπο και τη μέθοδο διάθεσης.

See more: ATHEX ESG REPORTING GUIDE (nbg.gr).

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13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

Recognizing climate change as a major environmental challenge of our times, NBG is committed to reducing any adverse impact on the environment arising, primarily, from its financing activities, but also from its own operations and infrastructure. This commitment aligns with the Bank’s transition effort towards a net-zero economy, more circular and with less dependency on natural resources.

Following the results of the impact analysis and subsequent engagement of a wide group of stakeholders, to whom the Bank communicated a range of issues/topics as derived from the impact analysis with the aim to identify the ones of top importance (via the GRI Materiality principle), NBG has made a series of committing decisions to align its strategy and activity with the identified priority-impact areas. In particular, the impact areas of “Climate“ and “Inclusive, Healthy Economies” have been prioritized, given the strategic orientation of the Bank and the country needs assessment, as the most significant impact areas, upon which NBG will align its strategy and set SMART targets. On the former, the aim will be to reduce negative impact and, inversely, on the latter the aim will be to increase positive impact, as follows:

In order to reduce its negative impact of financing activities on climate, the Bank:

➢ Places emphasis on promoting sustainable finance and investment and enhancing its "green" banking offering, partnerships and investment options, reacting to and foreseeing further growing interest in products, services and instruments that contribute to environmental protection, sustainable development, and cyclical economies, in response to climate change

➢ Enhances its lending policies and processes, introducing environmental (including climate-related), social and governance risks assessment, applied both at the obligor and the transaction level (with the latter based on Sustainable Lending Criteria aligned with the EU Taxonomy and the Sustainability Linked Loan Principles)

➢ The Bank recognises that in order to be able to apply effective measures to reduce its negative impacts on climate, it needs to have a good understanding of its total carbon footprint. Undoubtedly, the emissions generated from our financing activities (Scope 3 emissions - category 15), constitute the highest percentage of our total GHG emissions. For this reason and building on the results of the impact analysis, we are currently in the process of measuring our carbon footprint for Scope 1, 2 and 3 emissions for 2021 and recalculating it for 2020.

Climate risk stress test

In January 2022, the ECB launched a supervisory Climate Risk Stress Test to assess how banks are prepared for dealing with financial and economic shocks stemming from climate risk. The exercise was conducted in the first half of 2022, after which, the ECB published aggregate results. This test was a learning exercise for banks and supervisors as well. It aimed to identify best practices, as well as vulnerabilities and challenges banks face when managing climate-related risks. Importantly, this was not a pass or fail exercise, nor did it have direct capital implications for supervised institutions. The exercise consisted of three distinct modules:

1. a questionnaire on banks’ climate stress test capabilities
2. a peer benchmark analysis to assess the sustainability of banks’ business models and their exposure to emission-intensive companies, and
3. a bottom-up stress test with forward-looking projections

To ensure the proportionality of the exercise, smaller banks were not asked to provide their own stress test projections. The stress test targeted specific asset classes exposed to climate risk, rather than the banks’ overall balance sheets. It focused on exposures and income sources that are most vulnerable to climate-related risks, combining traditional loss projections with new qualitative data collections.

The results will feed into the Supervisory Review and Evaluation Process (“SREP”) from a qualitative point of view. This means that this stress test could indirectly impact Pillar 2 requirements1 through the SREP scores but will not directly impact capital through Pillar 2 Guidance (“P2G”). In July 2022, NBG announced the successful completion of the 2022 Climate Risk Stress Test, with NBG’s overall performance being in line with the average of the EU-wide participating institutions. In terms of advancement in the internal climate stress-testing capabilities (qualitative part of the Exercise), the Bank ranked above the average of the total EU sample, at Medium-Advanced level, while in the domestic banking sector, NBG’s overall transition impact on Business Model viability was assessed as of relatively lower risk (Advanced scoring). The 2022 Climate Risk Stress Test outcome reflects the firm commitment and progress made by NBG, setting the basis for an effective climate risk management framework and timely adaptation of processes and strategies, via ambitious plans for substantial investment in human and technical capabilities.

 
Sustainable Lending Criteria Framework and Impact

The Bank has enhanced its lending policies and processes, incorporating environmental (including climate change), social and governance criteria, applied both at the obligor and the transaction level. Specifically, in alignment with its broader sustainability strategy, NBG has established a Sustainable Lending Criteria Framework (SLCF), in order to identify and classify the activities included in its corporate lending portfolio, that contribute to the transition towards a more sustainable economy. The Framework outlines the logic of classification of an activity as sustainable, building upon the EU Taxonomy Regulation and Sustainability-Linked Loan Principles (SLLP).

Energy management

Effective energy management and reduction in energy consumption in our buildings are significant components of our actions that form part of our ESG strategy and this is reflected in our recently updated Sustainability Policy and our implemented Environmental Management System. To this end, the following actions were taken during 2020:

• Energy upgrade of all elevators (program in progress).
• LEED certification (Gold level) of the bank's IT building in Gerakas.
• Replacement of heating oil with natural gas (in large buildings where the boilers were maintained) such as in Central Administration Building and in IT building in Gerakas.
• Installation of photovoltaic panels for net metering in IT building in Gerakas (the project is in completion phase).

Furthermore, within the context of buildings' energy management, aiming to reduce electricity consumption and consequently air pollution, the following actions were taken during the last 5 years with long term contribution to the decrease of the Bank's energy and environmental footprint:

• Replacement of boilers and air conditioners with new, low consumption and new technology equipment.
• Replacement of all lamps (indoor, outdoor and floodlights) with LED ones.
• Control of WC lighting with motion detectors.
• Energy upgrade of the bank's IT building in Gerakas.
• Execution of energy audits for NBG in accordance with Law 4342/2015.
• Replacement of air conditioners running with R22 by new ones that run on environmentally friendly refrigerants.
• Development of mechanical equipment specifications according to international energy and eco standards.

Some of these actions led to measurable results which are listed below:

• LEED Certification of Gerakas building complex

In 2020, the Bank completed the LEED certification of the building complex at Gerakas. The LEED certification system for Existing Buildings - Operation & Maintenance (EBOM) applies to existing buildings, which are fully operational. The System was developed by the U.S. Green Building Council (USGBC) and is one of the most internationally recognized green building certification systems. The building was certified in the GOLD grade. It is noteworthy, that it is the only IT office building in Greece that holds LEED certification.

Emission reduction

It should be noted that over and above its financing activities, the Bank has already been active in reducing negative climate impact via its own operations, by implementing key ESG-related approaches/best practices with respect to its own carbon footprint.

2020

NBG continued in 2020 its effort to reduce CO e emissions by taking measures aiming at:

• Reducing consumption of energy for the operation of its buildings.
• Acquiring new and upgrading existing equipment.
• Rationalizing its officers' and customers' travel.

At the same time, in order to meet the needs of its workforce and minimize its environmental footprint, the Bank rents buses to transport its employees to and from the workplace for some of the Bank's premises located outside the center of Athens. In particular, during 2020, 4,876 routes were made, transporting a total number of ~500 employees on a daily basis.

• Direct emissions

Certification of Corinth Branch as climate neutral

The Bank, as part of its commitments and with a sense of responsibility for an environmentally responsible operation, proceeded to the certification of Corinth Branch as climate neutral. The aim of the project was to calculate and offset the greenhouse gas emissions from the operation of the building during 2019. Emissions' accounting and offsetting is achieved voluntarily by companies as part of the Kyoto Protocol mechanism. The project was carried out in accordance with the internationally recognized standards ISO 14064 and Greenhouse Gas Protocol.

Furthermore, during 2020, the Bank carried out the following actions:

• Completion (100%) of the project for the replacement of the air conditioning units running on Freon R22.
• Replacement of FM-200, with environmentally friendly extinguishing means NOVEC, during modification projects at the Local Extinguishing systems.

By means of these actions the Bank aims at running systems posing the lowest possible pollution threat to the environment.

• Indirect emissions

The provision of services by the Bank is directly linked to travel and transport needs of customers who visit its Branches. The Bank has enabled the reduction of such travel by reducing the need for frequent visits by customers to its branches and ATMs, as well as the distances that need to be covered. As regards the Bank's role in reducing unnecessary travel, this was made possible by increasing the number of available transactions through the internet and mobile banking services. During 2020 transactions through internet banking increased by 13% compared to the previous year, while transactions through mobile banking rose by 120%. Additionally, in 2020 the number of users registered with NBG alternative channels (internet and mobile banking) exceeded 3 million, corresponding to an increase by 26%, while active users increased by 45%. It is noted that, in 2020, more than 620,000 new users registered in the internet/ mobile Banking of the Bank.

Aiming at environmental protection, the Bank launched its i-bank statement service whereby its customers

receive electronic statements regarding their credit cards and mortgage or consumer loans and savings accounts and stopped receiving printed statements. The i-bank statement service has been activated for more than 2 million statements. Moreover, NBG's i-bank delivery channels are being enriched on an ongoing basis with new services and more transactions enabling customers to carry out transactions 24/7 from home or with their mobile phone. Note that more than 450,000 new users were registered in 2021 for NBG's Internet/Mobile Banking services.

2021

A series of actions were carried out in 2021 aiming at saving energy and natural resources, including:

• migration of corporate car fleet to plug-in hybrid cars (-108,000 kg CO2 / year)
• discontinuation of plastic material usage in NBG canteens
• usage of 100% ecological cleaning materials
• installation of WC photocell taps in head office buildings to save on water consumption
• continuation of recycling programs and installation of recycling bins in head office buildings for paper, plastic and aluminium
• sourcing of 100% recycled paper
• initiation of a procedure for the issuance of a LEED certificate for the main head office building
• energy upgrade studies in 14 head office buildings
• implementation of energy upgrade actions in 2 Administration buildings
• installation of a central platform for measuring and monitoring electricity consumption in 49 NBG buildings
• configuration of an energy policy strategy for NBG buildings
• installation of a Photovoltaic Park in the facilities of the warehouses of PAEGAE (subsidiary of NBG) with a capacity of 1.8 MWp
• Integration in all new projects (adaptations, relocations, etc.) of new energy actions such as installation of motion detectors and new air conditioning systems.
• deal for sourcing 100% of energy from renewable resources

See in detail NBG_SUSTAINABILITY REPORT 202... p. 44-46

See also: ATHEX ESG REPORTING GUIDE (nbg.gr), & Principles-for-Responsible-Banking.pdf (nbg.gr)

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS-305-1: Άμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο εφαρμογής 1).

SRS-305-2: Ενεργειακές έμμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο Εφαρμογής 2).

SRS-305-3: Άλλες έμμεσες εκπομπές αερίων του θερμοκηπίου (GHG) (Πεδίο Εφαρμογής 3).

Scope 3 non-financed emissions are presented in the table below.

SRS-305-5: Μείωση (GHG) των εκπομπών αερίων του θερμοκηπίου.

NBG achieved in 2020 a reduction of its tCO emissions (Scope 1, 2 and 3 emissions) by 4.6% compared to 2019 (52,768 tCO in 2020 compared to 55,287 tCO in 2019). The corresponding reduction between 2020 and 2018 was 10.8% (52,768 tCO in 2020 compared to 59,135 tCO in 2018).

See more: ATHEX ESG REPORTING GUIDE (nbg.gr).

Attached Files: There are no files

14. Employment Rights

ADMINISTRATIVE PRACTICES

The Code of Ethics sets out clearly the ethical principles and values, as well as the rules of conduct upheld by the Bank and Group. To this end, the Bank, is aware of its responsibility to respect human rights, meaning avoiding infringing the human rights of others and addressing such impacts where they occur.

A mandatory seminar for the Code of Ethics, took place, with a total of 3,513 participations (3,233 Βank employees only). Total training hours (man-hours) amounted to 10,539.

 
Labor rights

• On 1.1.2020 the unused regular days of leave for the year 2019 amounted to 206,302 days, 99.85% of which were used within the year and 0.15% were paid.
• Employees with disability over 50% are entitled, besides regular leave, to an additional 10-day special paid leave.
• The Bank provides, in any case, the legal time off to its employees who are parents with or about to have a new child.
• The Bank provides maternity/paternity leave to full-time employees.

• Maternity leave

In 2020, 180 women working at the Bank were entitled to and granted maternity leave (each mother is entitled to 134 consecutive calendar days)

• Reduced work schedule - cumulative leave

After the end of maternity leave, mothers are entitled to choose between a reduced work schedule (by 2 hours for the first 2 years and 1 hour for the next 2 years) or a cumulative leave of equal time (6+3 months, respectively). Fathers are also entitled to the said reduced work schedule or cumulative leave, if the mother waives this benefit. Moreover, in 2020, 282 employees, 240 women and 42 men, were entitled to and granted cumulative shorter working hours. All employees who are granted one of the aforementioned time off categories, continue to work for the Company after the lapse of 12 months as of their return to work.

• Parental leave

In 2020, 2,621 employees were entitled to parental leave, of which 899 men and 1,722 women. 834 employees of these, 444 women and 390 men, used the said special leave. The specific leave for parent-school teacher meetings was increased by two more days per year for every child, beyond the first. These two additional days are granted on condition that the employee has used up all regular days of leave for the relevant calendar year, otherwise they are offset with the said regular leave. The working parents of children aged up to 4 years old are entitled to an additional 2-day special paid leave, irrespective of the number of children.

• Educational leave

The Bank, in supporting employee development, allows for its employees to take time off from work for specific periods in order to complete their studies.

Union Organizations – Collective Labour Agreements (CLAs)

The Bank respects and promotes the unquestionable constitutional right of employees to freedom of association, i.e. to form and participate in associations and unions. Specifically, in 2021, more than 84% of NBG employees were members of an employee union, while 86.52% were covered by CLAs. Representatives from all employees’ unions are invited during the training of new employees to welcome them and inform them on labor relations and their rights. The active participation of employees in decision-making and their ongoing communication with senior management is ensured, in line with statutory procedures, through the participation of employees’ representatives on the Bank’s Board. Following deliberation and negotiations with the employee Unions, minutes of agreements, CLAs and Business CLAs that cover a wide range of labor relations are entered. Furthermore, employee representatives participate in panels that take decisions on issues that involve employees, such as disciplinary issues, promotions, appointments and so on, as established in the Bank’s Labor Regulation.

Negotiations with employees' representatives for the signing of a Special CLA

In 2019, the Business CLA for the period 01.04.2019 to 31.03.2022 was signed. The updated Business CLA for the period 01.04.2022 – 31.03.2025 was signed in 2022. The following unions operate within the framework of bank employee representation:

• NBG Employees Union (“SYETE”).
• NBG Workers’ Union (“SYTATE”).
• NBG Graduate Employees Union (“SEPETE”).
• Employees Union of former NBG Real Estate (“SYPETE-PPETHNAK”).
• NBG Employees Union of former National Administration and Organization S.A.-Ethnokarta (“SEETE-PPE”).
• NBG Employees Union of former Ethnodata

 
Management of Covid-19 pandemic

In 2021, the Bank continued to immediately respond to the challenges arising from the pandemic and extraordinary circumstances that brought to our work. Beyond the internal reporting line that it set up, the Bank used the dedicated intranet webpage which operated as an information platform regarding prevention and compliance with safety measures putin place by scientific and government bodies. Leveraging on our Crisis Management Plan (“CMP”) and capabilities, the health and safety of our customers and employees as well as, ensuring the servicing of our customers and other stakeholders of the Bank and the Group without disruption, are of primary importance for us. This was achieved through the following actions:

• We ensured that the majority of our employees at headquarters were able to work remotely, activating our Crisis Management Plan (“CΜP”) sites to decongest critical on-site based operations.
• We activated rigorous incident management processes.
• We ensured required protective and cleaning materials were made available to employees.
• We deployed extensive internal communications.
• We secured uninterrupted operations by redesigning critical processes to facilitate remote work while at the same time ensuring that emerging risks were mitigated by adequate and efficient controls.
• We shifted towards digital banking platforms to ensure nationwide service availability to our customers.
• We redirected resources to prepare for the necessary financial support to our customer base, mitigating the immediate impact of the COVID-19 pandemic.
• We implemented payment moratoria for corporate and retail customers. We participated in all COVID-19 State Support Schemes.
• We deployed extensive external communications.
• We kept our employees, customers, shareholders, investors and regulatory bodies always informed by raising awareness about key hygiene measures, travel restrictions and policies.
• We encouraged and educated our customers to use digital channels.

Health and Safety

In accordance with the provisions of the current legislative and regulatory framework (Law 3850/2010) the Bank systematically seeks to promote health and safety at work and takes all necessary measures to prevent occupational hazards, highlight the importance of health and safety of employees at work through shared information, consultation, balanced participation in health and safety issues and the training of employees and their representatives. The Health and Safety system of the Bank’s employees covers all the staff who have a dependent employment relationship with the Bank as well as all of its facilities. The Bank has also set up the Health and Safety Committee of NBG Employees constituted by elected employees’ representatives as well as a representative of the Bank with responsibility for the protection of Health and Safety of employees appointed by the Board of Directors of the Bank.

• NBG Employees Health Fund (TYPET)

During 2021 TYPET carried out an important and multifaceted project with longterm targeting and benefits for its members in the context of a well-planned action program. Throughout the year all health institutions continued to encounter problems that disrupted their regular operations due to the COVID-19 pandemic which up to this day remains a serious health concern worldwide. TYPET, backed by the flexibility of its self-managed status, its efficient structure, the support of NBG, and the confidence and trustit enjoys among its members, succeeded once again in meeting major challenges and new increased needs. It is worth noting that in NBG’s Employee Experience Survey conducted in December 2020, NBG employees not only have mentioned TYPET, but they also highlighted its importantrole in theirlives,thus confirming the reliability ofthe health insurance provider in meeting their needs, and then proceeded in listing TYPET as the second most important reason for working at NBG.

• NBG Employees Insurance Organizations (AOPETE)

ΝBG Employees Insurance Organizations (“AOPETE”) are constantly evolving and modernizing their methods, to ensure ongoing quality upgrade of their services. With a view to offering reliable, prompt, full and immediate information to all Bank’s employees and pensioners, the AOPETE website (www.aopete.gr) has been launched and in 2021 completed twelve consecutive years of operation. Throughout 2021, the AOPETE website posted a high number of visits, reaching a total of 835,000 visits.

 
Employee experience survey

In order to strengthen internal communication, advance open dialogue and further improve the working environment, NBG has been conducting the Employee Experience Survey since October 2020. In line with our values, we are aiming to be a Bank that seeks to be close to its customers and is perceived as trustworthy, focusing on the prosperity of our people. In 2021 we held internal discussions of the 2020 Employee Experience Survey’s results in groups, identified particular focus areas and prepared targeted action plans. 68% of the planned actions were completed or set in motion during 2021.

The 2nd Survey, regarding the Employee’s working experience throughout the year 2021 and early 2022, launched in May 2022 and the results are presented in the following table. We plan to identify particular focus areas and prepare targeted action plans with regards to the new Survey results, which will be discussed in the coming year.

2021 Employee Experience Survey results

• 73% Employee engagement
• 76% of employees feel proud to work for NBG
• 67% of employees consider NBG as first choice employer
• 78% of employees recognize NBG’s Socialresponsibility
• 76% of employees feel proud for their contribution to NBG’s Transformation Program.

Initiatives and actions with the participation of Senior Management

We hear our people and take into consideration the feedback from our frequent and open communication regarding our strategy and orientation, the Transformation Program and, in general, the strengthening of the dissemination of information in open and direct ways. The aim is to provide reliable and prompt information regarding current developments and the establishment of dialogue within the work environment promoting meaningful collaboration, constructive relationships, and trust.

In 2020, NBG launched CEO Breakfasts, an initiative encouraging different groups to contact and discuss with the CEO on issues concerning NBG strategy and priorities. In addition, they are offered the option to have an open discussion on issues arising in their everyday professional life.

The same initiative includes the visits of the Management team to the Branch Network aiming at informing the front line officers about current issues and at generating closer contact between the Management and Branch Network officers.

 
Annual Network meeting

This has become a regular NBG event held within the first quarter of each year with the participation of managers from the Branch Network and Senior Management. The purpose of this meeting is to review the goals achieved in the previous year, and to provide information on and the alignment with the priorities of the next year. A special moment is the award ceremony in recognition of the efforts of the Branch Network.

The Bank is each and every one of us

Since 2019, we established a new communication platform posting announcements for the entire NBG employees, under the motto “The Bank is each and every one of us”. In 2020, we continued and intensified our efforts to foster open communication regarding crucial strategic initiatives with a view to enhancing inclusion, collaboration and a sense of common purpose in pursuing the actions to which we all contribute

See in detail NBG_SUSTAINABILITY REPORT 202... p. 74-99

See also: ATHEX ESG REPORTING GUIDE (nbg.gr)

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS 405-01: Δείκτες διαφορετικότητας στα διοικητικά όργανα και στους εργαζόμενους.

See in detail NBG_SUSTAINABILITY REPORT 202... p. 100-101, 119.

Attached Files: There are no files

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Equal Opportunities and Diversity

The Bank places emphasis on ideas and prospects of employees of different backgrounds talents and traits that contribute to the growth of the business and provides for equal opportunities for all, regardless of gender and other diversity features. According to the : “…The Bank and Group companies are aware of their responsibility to respect human rights, meaning avoiding infringing on the human rights of others and addressing such impacts where they occur…”. Code of Ethics In the context of providing equal opportunities for both genders and ensuring equal treatment of all employees, the Bank has developed a meritocratic system for the assessment of performance, promotions and remuneration of employees and supports the ongoing improvement of the employees' skills by holding significant training and educational programs for the employees’ professional development.

For the sixth consecutive year the Bank’s participation in the international index Bloomberg Gender Equality Index (GEI), proves the constant dedication to ESG issues, as well as its commitment to continuing and strengthening gender equality initiatives and eliminating all forms of discrimination. During 2021, 54 hours were devoted to training concerning human rights, with the participation of 6 employees (0.1% of total employees).

In 2020, 52% of the total employees were women and 48% men.

Remuneration policy

NBG is strongly opposed to any form of discrimination and is vigilant in ensuring that there is no discrimination in terms of pay or other matters between men and women. The Bank has established Policies, Regulations and Procedures to deal with employees' issues, including working hours, leave, overtime, remuneration and other issues related to the general working status of the Bank's employees, in compliance with the applicable legislative and regulatory framework.

 
Support for vulnerable members of the population

To support vulnerable members of the population in cooperation with the competent bodies, the Bank employed 190 individuals with special needs, corresponding to 2.5% of the total employees.

As regards their access to the Bank's premises, the following actions were taken:

• Installation of a special elevator at the Bank's Head Offices (Aiolou 86), so that individuals with special needs can easily access the building.
• Installation of a special ramp at the Units to facilitate access for persons with special needs.
• Installation of handrails in the Bank's Units for easier access.
• Placement of non-slip strips in the Bank's Units to prevent falls.

Social benefits for employees

Considering that work-life balance has a beneficial impact on employee performance, the Bank has established and implements a range of benefits and relevant policies for employees and their families, as described below.

• Provides financial awards to employees' children for outstanding school performance
• Assists employees by providing the option of flexi-time when there is a need.
• Provides benefits for care of children of employees during working hours.
• Provides general childcare allowance to employees.
• Provides one-off financial benefit to its active and retired employees whose children are accepted, after successfully passing university entrance exams, in a university in a different city from their place of residence.
• Provides special annual paid leave of ten business days besides the regular days of leave to employees: (a) who are parents of children with disability over 67% or children suffering from insulin-dependent diabetes mellitus (type 1), with disability over 50%, (b) whose spouse has disability over 80% and is supported by the employee and (c) have been appointed as curators of persons with disabilities who are declared under full privative judicial support and are supported by the said employees.

All NBG full-time employees are provided with additional insurance cover by Ethniki Insurance in the event of death or accident (partial or total disability), besides the obligatory insurance in TYPET, IKA, etc. Also, the Bank provides specific personnel categories (e.g. senior executives) with additional medical care schemes through Ethniki Insurance. The cost of the aforementioned insurance schemes is covered by NBG and amounted to €1,129,663 in 2020. Additional benefits are provided by the Bank (i.e. travel expenses, meals etc.) only to full-time employees, provided that they meet the criteria set for such benefits (i.e. job position etc.).. In addition to the above, and having fully met the legislative requirements regarding employees pay and other benefits, within the context of its far-reaching social policy the Bank has chosen to offer a range of further benefits to its employees. The additional benefits available to the Bank's employees via TYPET include the following:

1. Financial support/allowance for the seriously ill. In 2020, the amount of €57,831.53 was paid for the support of seriously ill employees.
2. Additional medical care support worth €4,995.16 was paid to three beneficiaries.
3. Summer camp programs for employees' children. However, in 2020, TYPET's summer camps did not operate due to the pandemic.

Supporting employees' health and safety

In seeking to address health and safety issues as efficiently as possible, NBG holds seminars on related issues, such as fire safety (including legislation), crisis management, etc. According to the NBG Workplace Doctors and Safety Technicians' observations-suggestions for 2020 (896 total visits by workplace doctors, 995 total visits by safety technicians in 454 buildings), there is no record of musculoskeletal disorders or other similar diseases in the Bank's Units.

• Employee Psychological Assistance Program

The wellbeing of our people is one of our key priorities. In March 2020, we launched the 24/7 consulting – psychological support service for the entire NBG employees and their families. This service, operating essentially as helpline, is provided through Hellas EAP, a recognised mental health organization. Through this initiative, we aim at providing specialized, round the clock support and consulting by health specialists to address any personal and/or workplace issues that may prove detrimental to our employees, but, above all, to the sense of well-being and mental and emotional stability.

• Supporting employees who have experienced violent incidents

The Bank has launched a series of procedures, programs and actions to support employees who have been traumatized by the experience of violent incidents (such as bank robberies and verbal or physical violence by customers), including:

• • Installation of Access Control Vestibules in the Branches
  • Presence of security guards in selected branches and installation of controlled access system in other buildings.
  • Publishing short guides for:
    • Prevention and management of robberies.
    • Course of action and behavior in case of robbery.
    • Actions subsequent to a robbery
  • Program for the psychological support of employees that have experienced such incidents.

Employees training & development

In 2020, the outbreak of the pandemic and the unprecedented health crisis caused significant changes in the training procedure, as a result of the lockdown and the suspension of in-class seminars in the normal working environment. Our Bank, with a view to continuing its employees training initiatives, as well as protecting employees' health and safety, adopted e-learning methods (asynchronous and synchronous). New training technologies were used to facilitate interactive online attendance of all training programs. In this context, the Bank designed new and/or extensively redesigned, many of the existing training programs for Certifications provided for by Law, and Housing Loans, and at the same time adopted cutting-edge trends in training, such as social learning, training videos, etc

Special emphasis was placed on the following seminars: Arrears Management, Branch Reconciliation, Customer Hosting and Service, AML, as well as training programs with regard to the “New Employee Evaluation and Development System (part A)”. Training seminars on Operational Risk, and Finacle (training about NBG's new core banking system) and RedHat systems (training at RedHat Openshift platform) were also held. The participations in the in-house webinars exceeded 5,000, plus the participations in classroom seminars, in the context of the implementation of the Bank's strategic objectives and business transformation program.78 e-learning courses in many new subject areas were designed and developed almost exclusively by NBG's e-Learning Subdivision using the method of asynchronous training.

As regards outsourced training, emphasis was placed on subject areas related to the pandemic crisis and how to respond to the new circumstances, including: labor issues, management of remote groups, impacts on economy, digital and security issues, new training methods and tools, user interface design for e-seminars, etc.

Distance training courses corresponded to 98.46% of total training, far outperforming the target set prior to the pandemic. Accordingly, the outcome of the crisis included a significant reduction in operating costs, the training of a great number of employees within a very short period, and reduction of employees travel (and CO emissions).

• NBG Academy

In 2020, the NBG HR Development and Academies Division reformulated its training strategy through the “NBG Academy” program in collaboration with the Transformation Program. NBG Academy aims at providing continuous and implementable training, meeting in full the needs of employees, in line with their positions and duties. Within the year, the Bank drew up a map of key skills that the Bank's employees need to develop based on six main development areas. All active training programs (circa 500) were mapped and categorized according to their main characteristics (e.g. the skills developed though each program, training methodology, level of knowledge and demands, as well as the complexity of the subject area, etc.), while a skills gap analysis was carried out. The Bank established detailed training programs covering the said basic subject areas, and the training offered covers the six subject areas listed below, with a view to developing the respective knowledge and skills, taking into consideration the strategic priorities of the Bank and international best practices:

• NBG Organizational Culture: knowledge of the strategy, values and policies of the Bank.
• Mandatory knowledge : key knowledge of security, risk management, etc. as well as compulsory professional accreditation for various job positions.
• Leadership skills: how to inspire, lead and make our team more effective.
• Behavioral skills: how to behave in our work environment and how to perform our duties.
• Digital skills: use of everyday digital tools and knowledge of the changes taking place in the new digital era.
• Technical skills: banking/specialized knowledge and skills for different work positions.

Support for continuity of employment and development

Driven by respect for its human resources and in an effort to support employees that participated in the Voluntary Exit Scheme, the Bank held a Professional Transition and Support Services program in collaboration with a specialized consulting company. The primary goal of the specific program was to provide participants with support and guidance counselling in order to manage the change in their occupational status more efficiently. Accordingly, participants could also take advantage of consulting services, free of charge, depending on their needs as follows: their professional skills, the presentation and communication method of their professional profile, labor market, use of professional and social networking sites, preparation of business initiatives as well as the preparation of a financial management plan.

See in detail NBG_SUSTAINABILITY REPORT 202... p. 74-101

See also: ATHEX ESG REPORTING GUIDE (nbg.gr)

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS 403-2: Τύπος και ποσοστά τραυματισμών, επαγγελματικών ασθενειών, απώλειας ημερών εργασίας και απουσιών εργαζομένων και αριθμός θανατηφόρων εργατικών ατυχημάτων.  

In 2020, six on-the-job injuries, only four of which occurred inside the Bank's facilities, and the rest occurred upon employees' arrival/departure from their workplace, corresponding to 31 calendar days of absence from work. In 2020 the following absences were also recorded:

• 54,441 lost days due to special purpose leave for employees in vulnerable groups
• 270,856 lost man-hours due to special purpose leave for employees in vulnerable groups.

SRS 403-4: Θέματα Υγείας & Ασφάλειας που καλύπτονται στις επίσημες συμβάσεις με τα συνδικάτα.

SRS 404-1: Μέσος όρος ωρών εκπαίδευσης ανά έτος ανά εργαζόμενο.

SRS 406-1: Περιστατικά διακρίσεων και διορθωτικές ενέργειες.

No incidents of discrimination have been recorded or reported across the entire NBG employees and no complaints have been filed by employees or third parties on discrimination incidents.

Attached Files: There are no files

16. Qualifications

ADMINISTRATIVE PRACTICES

HR Selection & Development

For yet another year, NBG continued to systematically review employees' qualifications, skills and professional abilities, for their best possible leverage to meet the Bank's needs for specific job positions and the creation of a pool of employees with great potential through group and customized actions on the basis of the “Personal Development” initiative. In this context, 54 Selection Programs were held through the conduct of 1,120 targeted interviews and 516 IQ tests and written examinations. At the same time, the Bank carried out 58 individualized feedback and advisory/ coaching meetings with the Bank's employees and officers, and enhanced the systematic assessment and the creation of a pool of employees with great potential and/or suitability for the Organization's key positions. Lastly, the HR Selection Subdivision enhanced its outward-looking orientation by participating in digital Career Fairs and by leveraging the digital platform for conducting interviews and on-line candidate assessment tools, following the restrictions imposed due to the pandemic crisis.

The Bank's employees employed in Greece in 2020 totaled 7,711 employees, down by circa 7% vis-a-vis the previous year, due to regular retirement, the voluntary exit scheme and the termination of employment contracts.

Hiring and turnover of employees in NBG

In 2020, a total of 209 new employees were hired.

Employment opportunities and internships

The implementation of targeted and structured Internship Programs is part of the Bank's strategy for offering employment and development opportunities to young people, rewarding excellence based on meritocratic and transparent criteria, and creating an effective link between the education sector and the labor market.

• Throughout the year the Bank hired senior students of Greek Universities and Technological Educational Institutions as interns (318 in total in 2020, 219 from Greek Universities and 99 from Technological Educational Institutions) in collaboration with 14 universities and 40 different faculties, while the four-year IKY (State Scholarships Foundation)-NBG 2018 Scholarship Program was continued, involving the internship and employment of the scholarship holders in the NBG Branch Network and Administration Units, implemented in two phases:

Phase A - Internship and

Phase B - Hiring the scholarship holders under a two-year employment contract with NBG. Note that the majority of participants ( 86 out of 94) in Phase A were hired under a full-time two-year term contract (Phase B), following completion of their studies.

• It is worth noting that 76 out of the 99 participants in the IKY (State Scholarship Foundation)–NBG 2014 scholarship progam continue to be employed in the Bank post completion of the Program.
• In the same year, the Bank also announced and implemented the “i-work@nbg” Internship Program. The new program focused on IT and offered the opportunity to 26 holders of bachelor and master degrees to gain professional experience through full-time salaried practical training of 6 to 12-month duration.
• In addition, officers of NBG HR Division participated in digital Career Days, conducting interviews and presenting youth employment programs implemented by the Bank. Lastly, the Bank took part for the second time in the “Live a Legacy” Mastercard program offering 2 positions for women of salaried practical training of 6-month duration in Retail Banking and, in particular, in the Debit-Credit Cards Division. The aim of this action is to enhance the inclusion of women in the labor market, as well as the enhancement of female entrepreneurship.

Human capital development

Placing emphasis on the development of the employees, the Bank provides financial support to its employees encouraging participation in training programs that lead to international professional certification and/or the attainment of postgraduate degrees combined with internationally acclaimed certifications such as CFA etc.

• Accreditation of professional skills required under the applicable legal framework

In line with the current legal framework for the smooth functioning of the credit system and the financial sector, procedures are provided for by the competent bodies to certify the suitability and update the knowledge of banking officers on insurance intermediation and the provision of investment products and services. In 2020, due to the pandemic, only a few exams were held and as a result the employees' participation for obtaining new or higher level certificates was reduced. NBG's participations in the accreditation exams in (re)insurance intermediation totaled 188 with the success rate standing at 55.85%. Further, with a view to re-certification on insurance intermediation Accreditation of professional skills required under the applicable legal framework In line with the current legal framework for the smooth functioning of the credit system and the financial sector, procedures are provided for by the competent bodies to certify the suitability and update the knowledge of banking officers on insurance intermediation and the provision of investment products and services. In 2020, due to the pandemic, only a few exams were held and as a result the employees' participation for obtaining new or higher level certificates was reduced. NBG's participations in the accreditation exams in (re)insurance intermediation totaled 188 with the success rate standing at 55.85%. Further, with a view to re-certification on insurance intermediation Regarding the accreditation for the provision of investment services, in compliance with the Markets in Financial Instruments Directive (MiFID EU Directive) one series of exams was held by the relevant bodies. NBG's participations in the accreditation exams were 191 and the results by certificate are set out below:

Regarding the accreditation for the provision of investment services, in compliance with the Markets in Financial Instruments Directive (MiFID EU Directive) one series of exams was held by the relevant bodies. NBG's participations in the accreditation exams were 191. In the context of updating skills of already accredited individuals, as per the relevant legal framework, a total of 448 certificates held by NBG employees were renewed in 2020, through the successful participation in the Hellenic Banking Institute's respective e-seminar (Certificates A1-D).

Performance Management System (PMS)

In light of the implementation – starting from 2021 – of the new Evaluation and Development System, and with a view to a smooth transition to the new System, as well as the training/information of both appraisers and the employees under evaluation, fifty (50) interactive workshops entitled "New Evaluation & Development System - Part I” were held in 2020 and were attended by 928 officers. Accordingly, the trial implementation of the PMS for the Bank's top & senior ranking officers was scheduled to begin in January 2021.

Rights

• Employees with disability over 50% are entitled, besides regular leave, to an additional 10-day special paid leave.
• The Bank provides, in any case, the legal time off to its employees who are parents with or about to have a new child.
• The Bank provides maternity/paternity leave to full-time employees.

All NBG full-time employees are provided with additional insurance cover by Ethniki Insurance in the event of death or accident (partial or total disability), besides the obligatory insurance in TYPET, IKA, etc. Also, the Bank provides specific personnel categories (e.g. senior executives) with additional medical care schemes through Ethniki Insurance. The cost of the aforementioned insurance schemes is covered by NBG and amounted to €1,129,663 in 2020. Additional benefits are provided by the Bank (i.e. travel expenses, meals etc.) only to full-time employees, provided that they meet the criteria set for such benefits (i.e. job position etc.).

See in detail NBG_SUSTAINABILITY REPORT 202... p. 74-99

See also: ATHEX ESG REPORTING GUIDE (nbg.gr)

Attached Files: There are no files

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Standing by its longstanding commitment to responsible operations, NBG has adopted policies, regulations and processes which are given formal substance in relevant Codes of Conduct ensuring transparency and impartiality as well as avoidance of conflicts of interest in its supplies and implementation of technical projects. NBG uses a state-of-the-art Suppliers Relationship Management System (SRM-SAP), which facilitates cooperation with its suppliers representing most of the business sectors.

Pursuant to the institutional framework, all parties involved in procurement and technical projects must be aware of and conform with the Bank's and the Group's Code of Ethics, which now also applies to purchasing and technical projects. Additionally, in 2020 the Bank's Purchasing Regulation review was implemented, while the deployment of a Code of Conduct for Suppliers and relevant audit procedures are in progress during 2021.

The Bank reviews and evaluates its suppliers (in terms of quality, certifications, respect for human/employee rights, etc.) on an ongoing basis. In the event that inspections of facilities/data security are required, special teams visit these facilities and certify their suitability. Regular sample qualitative and quantitative controls are carried out for every order and delivery of goods/equipment, etc

Prospective suppliers are under the obligation to comply with Corporate Social Responsibility requirements (documenting compliance by sending relevant supporting material), as these are stipulated in the relevant EU Directives, on issues such as:

• Environmental protection
• Child labour
• Work health and safety
• Social equality/solidarity

All NBG suppliers resulting from tender procedures comply with this obligation. Based on the above mentioned, it is estimated that 97% of the suppliers, associated with the Bank, have been assessed against environmental criteria as well.

See in detail NBG_SUSTAINABILITY REPORT 202... p. 71-72

See also: ATHEX ESG REPORTING GUIDE (nbg.gr)

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS 412-3: Σημαντικές επενδυτικές συμφωνίες και συμβάσεις που περιλαμβάνουν όρους για τα ανθρώπινα δικαιώματα ή έχουν υποβληθεί σε έλεγχο σχετικά με το σεβασμό των ανθρωπίνων δικαιωμάτων.

NBG Group Code of Ethics to all Board members, Senior Management officers and employees of the Bank, under any kind of employment relationship, as well as any third party collaborating with the Bank or a Group company, either within the context of providing services or performing a project (including associates, vendors, intermediaries, agents and any other entity cooperating with NBG within the context of outsourcing or other kinds of agreements).

SRS 414-1: Νέοι προμηθευτές που έχουν υποβληθεί σε έλεγχο με βάση κοινωνικά κριτήρια.

In 2020 NBG signed contracts with 153 unique suppliers and with a further 177 unique suppliers, during 2021. Therefore, they were all advised of the terms and agreed to them.

Attached Files: There are no files

18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

In 2020 the total amount allocated by the Group for sponsorship actions during the year, for the completion of projects of previous years, but also for the support of the activities taken by the Cultural Foundation (MIET, €2.1million per year) and Historical Archives amounted to €7.3 million (net amount).

Responding to this unprecedented health crisis, NBG, focuses its actions on the recovery of the Greek reality, through the three pillars of the Corporate Social Action Program "RESPONSIBILITY": Man - Culture – Environment.

Responsibility for our community

With the NBG “Responsibility for the Community” program, the National Bank, adopting the three pillars “economic growth - sustainability - social cohesion”, acquired an intervening role to address the Covid-19 virus crisis actions and initiatives to strengthen the National Health System . This was achieved by supporting , as well as the values of family, education and our fellow human beings in need, especially the vulnerable social groups.

Responsibility for our environment

• Sponsorship support of "Eco-Fest 2020", a conference dedicated to “Green Cities, Sustainable Development and E-mobility”, aiming to highlight the benefits of a society consisting of environmentally informed and conscious citizens, the benefits of environmentally friendly energy and transportation alternatives and new, environmentally friendly technologies and products as well as innovations, trends and challenges in the field of e-mobility. The conference was co-organized by the Hellenic Association of Energy Economics, the financial magazine “Insider.gr” and the “Technopolis” of the Municipality of Athens.
• Sponsorship support of the “5 Annual Energy Transition Symposium”, organized by the Hellenic Association for Energy Economics. The event was focused on energy, financial and environmental issues, aiming at the creation of an international forum where ideas, technological expertise and research results will be exchanged.
• At the same time, the Bank reuses or donates (in case of depreciation or replacement) its equipment to various organizations and public services that need support in kind, in order to reduce its environmental impact and to enhance circular economy initiatives.

Responsibility for our cultural heritage

The National Bank of Greece, is a longtime supporter of actions and programs that highlight our National Heritage and promote culture, through the strengthening c of cultural values and actions in the field of Arts, which considers to be an inseparable part of NBG's business strategy and programs related to Corporate Social Responsibility. D NBG dedicated a noteworthy amount of its sponsorship budget to support a variety of projects and actions that promote history, arts, customs and traditions, through the support of significant cultural and intellectual projects. In connection with SDG 11 (Sustainable cities and communities) the Bank supported, among other social actions, the Olive Mill - Vrana Museum, the Greek National Opera, MEGARON the Athens Concert Hall, the Michael Cacoyannis Foundation and the Foundation of the Hellenic World. Within the context of the above sponsorships, 450 tickets were offered to the Bank's employees and their families for attending theatrical events and performances. National Bank of Greece – in light of its long history, which is closely linked to the creation and development of the Greek state and living up to the heritage of the philhellene individuals responsible for establishing the Bank launched “the Bicentennial Initiative 1821-2021”. This initiative is the fruit of collaboration between cultural and scientific institutions of the country and the National Bank, which have jointly developed a program that includes 130 events (starting in October 2020 and lasting until March 2022 - culminating in March 2021), focusing on science, cultural heritage, music, arts, and on showcasing the country's future prospects.

In the context of the celebration of our National Anniversary, NBG supports through its Corporate Social Responsibility program, the significant work of the Committee “Greece 2021” regarding the Country's preparation for the 200th anniversary of the 1821 Revolution. The Committee coordinates a comprehensive program of actions and events, aiming to re-introduce Greece, beginning from its modern history , presenting the Country's multiple achievements and potentials. to this day Furthermore, the National Bank of Greece hosted in its premises (the Small Exchange Building, the Melas Mansion, the Amphitheater of Karatzas Mansion and the Old Stock Exchange Building) a limited - due to Covid-19- number of events organized by associations and institutions.

The NBG cultural foundation (MIET) 2020

The significant work of the NBG Cultural Foundation (MIET) includes the promotion of literature, science and the arts. In 2020 MIET brought out 15 new publications and 11 reprints, as well as a series of actions.

NBG Historical Archive (NBG-HA)

In 2020, the NBG Historical Archive looked for new sources of inspiration and action as part of its efforts to achieve its goals, which include the collection, proper safekeeping, appropriate processing and promotion of the Bank's vast archive collection. The unprecedented situation due to Covid-19 lockdown resulted in the temporary suspension of some operations requiring the physical presence of employees, such as e.g. procedures applying to the receipt, classification, maintenance and digitization of archival/ book materials and collections materials. The Archive used all online and digital means available over the period of time that such operations were not possible. Accordingly, we focused on the processing of digital images that resulted from the conversion of analog microfilm images, so that we could upload them to the electronic system of archival and historical documents. The processing of 71,069 images was completed.

We enriched the Historical Archive with historical documents held in archives of third parties. The General State Archives, MIET-ELIA, Corfu's General State Archives as well as various publications, Government Gazettes and broadsheets of the 19 century. We carried out research into sources, we digitized documents, and transcribed 19 century handwritten documents. In total, we processed some 1,000 documents.

Supporting remote regions and islanders

NBG maintains a presence in frontier regions and on small islands with a population of less than 5,000 people, and is the only bank present on certain islands (e.g. Megisti, Oinousses, Alonnisos, Skyros, Skopelos and Antiparos). In these sparsely populated regions, as at 31.12.2020, NBG's network included 16 units, the same number as at 31.12.2019. In the course of 2020, the Bank also applied preferential pricing (zero charges) on transactions carried out via the ATM network of other banks, in delivering service to customers/residents of 29 small islands where NBG has no presence, by assuming the DIAS charges itself. The Bank considers as non-privileged population groups, population groups residing in low-populated remote areas. NBG off-site ATMs operate in 57 access points in the areas mentioned above. In addition, within 2020, 1 off-site ATM was installed in the Chios Refugee Reception and Identification Centre (RIC) in April 2020, following the request of the Greek Government and consultation with the other Banks through the HBA, to serve the transaction needs of refugees staying in the RIC.

See in detail all the actions implemented NBG_SUSTAINABILITY REPORT 202... p. 68, 107-114

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PERFORMANCE INDICATORS

SRS-201-1: Άμεση οικονομική αξία που δημιουργείται και διανέμεται.

See also NBG_SUSTAINABILITY REPORT 202... p. 72.

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19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

Since its establishment in 1841, NBG has supported the Greek society and economy through initiatives and actions for the benefit of its customers, shareholders and workforce. Today, with vision, strategy and dedication, it approaches Corporate Social Responsibility and Sustainable Development issues as follows:

• UNEP FI
• UN Principles for Responsible Banking (PRB)
• UN Global Combact
• UN Sustainable Development Goals
• Sustainable Development Committee of the Hellenic Bank Association
• Hellenic Network for Corporate Social Responsibility

The Group Anti-bribery Policy has been set according to the requirements of the legal framework for combating bribery as well as the international best practices and guidelines of international organizations and bodies for preventing and combating financial crime (OECD, FATF, Wolfsberg Group, etc.). The Anti-bribery Policy applies to any person working for the Group whether under a contract of employment or otherwise, and -among others:

• Adopts procedures which discourage bribery and corruption practices, such as procedures on bribery risk assessment, handling of gifts and business hospitality, donations to political parties and charitable institutions, evaluation of third parties etc.
• Encourages confidential reporting of suspicions, through the appropriate communication channels.

It should also be noted that the Bank's Corporate Social Action and its subsidiaries are independent of the various customer, shareholder or third-party interests. The Bank and its subsidiaries do not support or sponsor political parties, whether directly or indirectly.

See also NBG_SUSTAINABILITY REPORT 202... p. 28, 127

Attached Files: There are no files

PERFORMANCE INDICATORS

SRS-415-1: Συνεισφορά σε πολιτικά κόμματα

The Bank and its subsidiaries do not support or sponsor political parties, whether directly or indirectly.

Attached Files: There are no files

20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

Anti-corruption and anti-bribery policy and practices

The Group's fundamental values and principles governing its business activities strongly emphasize the importance of ensuring ethical conduct at all times, while the Group shows zero tolerance on corruption and bribery and it is of its high priorities to prevent and combat them. The Bank's activities entail exposure to corruption and bribery phenomena, which if not appropriately and timely managed, they may present a significant risk for the Bank and could adversely affect its financial results, with a serious impact on the Bank and its subsidiaries' reputation and the further development of its activities, while they could cause adverse effects on the interests of its clients, shareholders and employees. Towards this direction, preventive control mechanisms are applied to safeguard against any potential risk of bribery and corruption to which the Bank may be exposed in the course of its business/operations. To that end, the Bank's anti-bribery program consists of various essential components, such as anti-bribery and anti-corruption risk assessments, policies and procedures, tone from the top, financial and non-financial controls, raising concerns, management information and periodic reporting, and records' keeping. This approach is reflected in the Codes and Policies that the Bank has adopted, in the controls embedded within the procedures followed in the Bank's day-to-day operations and in the monitoring and audit processes applied. The Bank has in place procedures and internal controls which serve to mitigate potential risk and ensure that the Bank is compliant with laws and regulations, which in the event of non-compliance could have a material effect on the financial statements. The effective operation of these procedures and internal controls are independently monitored by the various control functions and audited by the Group Internal Audit Function, while the Audit Committee of the Bank's Board of Directors and the Board of Directors are duly informed through reporting on internal controls by the various control functions. In this context, with the Bank laying great emphasis on ensuring that the highest standards on ethics and integrity are applied throughout all of its activities in accordance with international best practices, the Bank has established the Compliance Ethics and Culture Committee of the Board of Directors.

A set of Codes and Policies which the Board of Directors has approved include several measures against the risk of bribery and corruption. Indicatively, such measures are incorporated in the NBG Group Code of Ethics, the Code of Ethics for Financial Professionals, the Anti-Fraud Policy, the Conflict of Interest Policy and the Anti-Bribery Policy.

Also, in the context of the controls of the transactions carried out by the respective Compliance Division, possible cases of corruption are also controlled.

The Board of Directors is committed to prevent bribery and corruption and promote the establishment of a culture against them, according to which any form of bribery and corruption is non-acceptable, while it is responsible for approving the relevant Policies, as well as overseeing its implementation and periodic assessment. Additionally, updates and evaluations of the System of Internal Control in general, as well as any material incidents identified are reported to the Bank's Audit Committee and the Board of Directors.

It should also be noted that the Bank's Corporate Social Action and its subsidiaries are independent of the various customer, shareholder or third-party interests. The Bank and its subsidiaries do not support or sponsor political parties, whether directly or indirectly.

The Anti-Bribery and Anti-Corruption Policy was revised within the first semester of 2021 and has been communicated to all (100%) employees (7,711 employees) and all (100%) governance body members in all regions.

 
Whistleblowing Policy

The Bank has adopted the Whistleblowing Policy for the Bank and the Group through which procedures are established for the submission of confidential reports or comments by any party, either anonymously or not, regarding behavior of the Bank and the Group's executives, which indicate the existence of an irregular activity or misconduct or omission relating to breaches in regard to internal Policies and Procedures. The Policy complies with the provisions of Greek Law 4261/2014 regarding the internal procedures for violation complaints. The Compliance, Ethics and Culture Committee of the Bank's Board of Directors is responsible for the establishment and the continuous monitoring of the implementation of these procedures, which ensure confidentiality and secrecy of the reports or comments received. It should be noted that a special e-learning program was developed regarding the content of the Whistleblowing Policy of the Bank and the Group, in order to further strengthen the Whistleblowing culture of the Bank's employees.

• Whistleblowing through internet and intranet

The purpose of these channels is to enable its employees, the Group companies and other stakeholders to report issues which indicate the existence of serious irregularity.

Within the context of the Bank's obligation to protect its own and its customers' interests, it has implemented the necessary measures to deal with cases of corruption and any employee involved in such cases.

Learning programs

Mandatory learning programs on the NBG Group's applicable Code of Ethics, which, focuses, among others, on bribery and corruption issues, are provided to all employees of the Bank, and all personnel has access to the internal e-communication network of the Bank (intranet), through which they are able to get prompt and full information on all key matters regarding NBG Group's developments and operations, including internal communication announcements, internal circulars, policies that the Bank has in place etc.

See also NBG_SUSTAINABILITY REPORT 202... p. 86, 125-128

Attached Files: There are no files

PERFORMANCE INDICATORS

It should be noted that throughout 2020, there were no pending or completed legal actions concerning anti-competitive behaviour, violations of anti-trust and monopoly legislations. In addition, there were no monetary losses as a result of business ethics violations.

In 2020, NBG's Internal Audit identified 7 cases of employee corruption, and the Bank immediately took the necessary measures. Specifically, within 2020 the Bank decided:

• the termination of the employment contract with payment of compensation to six of its employees, of which five were dismissed, as for one of them the required approval for this purpose is pending, for its case, by the competent Committee of OAED (the said employee was placed in the Bank as a protected person, according to provisions of Law 1648/86)
• the filing charge against a former employee, who had resigned before making the relevant decision.

In 2019 and in 2018, 12 and 8 relevant cases were identified respectively.

See also NBG_SUSTAINABILITY REPORT 202... p. 127-128, 131.

Attached Files: There are no files