Annual Financial Report
for the year
January 1 - December 31, 2024
The information contained in this Annual Financial Report has been translated from the original
Annual Financial Report that has been prepared in the Greek language. In the event that
differences exist between this translation and the original Greek language Annual Financial
Report, the Greek language will prevail over this document.
TABLE OF CONTENTS
I. Statement of the members of the Board of Directors ...................................................................... 1
II. Board of Directors’ Annual Report .................................................................................................. 3
Board of Directors’ Annual Report for the period ended 31 December 2024 ............................................. 4
Statement of Corporate Governance ................................................................................................... 38
Alternative performance measurement indicators (‘APMs’) at Group level .............................................. 94
Board of Directors’ explanatory report of Optima bank S.A. .................................................................. 95
Optima bank’s Group Sustainability statement ..................................................................................... 98
III. Independent Auditor’s limited assurance Report on Sustainability Statement ................................ 246
IV. Independent Auditor's Report.................................................................................................... 252
V. Financial statements for the year ended December 31, 2024 ...................................................... 262
I. Statement of the members of the Board of Directors
2
Statement by the members of the Board of Directors pursuant to Article 4 par. 2 of Law
3556/2007
It is hereby certified and stated that, to the best of our knowledge:
- The annual financial statements of the société anonyme "Optima bank S.A." and its Group, for the
year ended 31 December 2024, were prepared in accordance with the applicable accounting
standards, present in a true and fair manner the assets and liabilities, the net worth and the profit
and loss account of Optima Bank SA and the undertakings included in the consolidation taken as a
whole.
- The annual report of the Board of Directors for 2024 gives a true and fair view of the development,
performance and position of Optima Bank SA, as well as of the companies included in the consolidation
taken as a whole, including a description of the main risks and uncertainties they face and was
prepared in accordance with the sustainability reporting standards referred to in 154A of Law
4548/2018 and with the specifications approved pursuant to paragraph 4 of article 8 Regulation (EU)
2020/852.
Athens, 20 March 2025
The Chairman of the Board of
Directors
The Chief Executive Officer
Executive Member of the
Board of Directors
Georgios I. Taniskidis
Dimitrios A. Kyparissis
Angelos N. Sapranidis
3
II. Board of Directors’ Annual Report
4
Board of Directors’ Annual Report for the period ended 31 December 2024
Dear shareholders,
We hereby submit the annual report of the Board of Directors for the financial year from 1/1/2024 to
31/12/2024. This report briefly describes information of the Optima bank S.A. Group, financial information
aimed at providing shareholders with general information on the financial situation and results, the overall
course and the changes that occurred during the financial year (1/1/2024 to 31/12/2024), as well as significant
events that took place and their impact on the financial statements of the year. It also describes the main
risks and uncertainties that the Group and the Bank may face in the future and lists the most important
transactions concluded between the Bank and its related parties.
International environment | 2024
Despite the successive crises (wars, extreme weather events and the largest pandemic of the 21st century),
the global economy is showing remarkable resilience. The immediate consequences of the crises have been
mitigated, with governments and monetary authorities having to take unprecedented measures to address the
crises in energy, public health, and supply chains, yet the effects regarding prices, income and public finances
remain.
Global GDP is estimated to have slowed marginally in 2024 but to remain at satisfactory levels, while inflation
continued to decelerate in the course of 2024, as a result of the restrictive monetary policy and the gradual
fight against the effects of the energy crisis. Overall, global GDP is estimated by the IMF (October 2024) to
have increased by 3.2% per year in 2024, up from 3.3% in 2023, and is projected to remain at this level also
in 2025 (3.2%). Major economies in 2024 experienced heterogeneity in GDP developments, as advanced
economies are estimated to have accelerated, while emerging and developing economies have slowed down.
According to IMF estimates, growth for 2024 as a whole accelerated slightly in advanced economies to 1.8%
from 1.7% in 2023, as the US economy slowed less than initially projected and the UK recovery was stronger
than projected
1
. Japan’s economy slowed significantly, while Germany’s economy is estimated to have
recorded zero growth for the year as a whole, acting as a drag on euro area GDP. In emerging and developing
economies as a whole, GDP growth is estimated to have slowed to 4.2% in 2024 from 4.4% in 2023, mainly
due to lower growth in China and India. Real GDP growth for 2025 is expected, according to the IMF, to remain
1
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
5
stable and to stand at 1.8% for advanced economies in 2025, and at 4.2% for emerging and developing
economies
2
.
Global inflation, after having been estimated to have declined to 5.8% in 2024, from 6.7% in 2023, is
expected to decline further to 4.3% in 2025 according to the IMF (October 2024). According to estimates in
emerging and developing economies, inflation remained high at 7.9% in 2024, slightly down from 8.1% in
2023. In advanced economies, where central banks took decisive action, it is estimated to have declined to
2.6% in 2024 and to reach 2.0% in 2025. Inflation fell significantly in 2024, with goods inflation close to zero,
while services inflation remains high, with monetary authorities in many economies in the process of lowering
key interest rates. For 2025, amid uncertainty mainly about international trade, a further decline in advanced
economies’ inflation, stronger real incomes and a change in economic policy are expected, with fiscal policy
tightening and monetary policy easing
2
.
In the United States, GDP increased by 3.0% in the second quarter of 2024 from 1.6% in the first quarter
of 2024. This improvement was driven mainly by strong private consumption, due to declining inflation and
rising real incomes, and investment. In the third quarter of 2024 growth declined slightly to 2.8%, mainly
driven by a decline in private inventories and residential investment. Annual CPI inflation increased to 2.7%
in November 2024, after six months of decline leading to 2.4% in September 2024, its lowest level since
February 2021. Further disinflation is expected, but at a slow pace. For the whole of 2024, according to the
IMF forecast (October 2024), GDP growth for the United States is estimated at 2.8%, supported by growth in
real wages, consumption and investment, while in 2025 it is expected to decline to 2.2%, due to a weakening
labour market. More generally, in the US, growth is expected to benefit from the commitment to extend the
tax breaks decided in 2017, while geopolitical tensions in the Middle East and trade disputes, combined with
uncertainty due to possible changes in the new US leadership’s international trade policy, appear to have a
downward effect
2
.
In China, the economic slowdown is expected to continue in 2025, as GDP growth is estimated to slow down
to 4.5%, from 4.8% in 2024
3
. The recovery in industrial production and exports does not seem to be able to
compensate for the weakness in private consumption, which is weighed down by the correction in the real
estate sector.
2
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
3
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
6
In Japan, the agreement in early 2024 to increase wages annually by more than 5% contributed to the
temporary rise in wages in June and July 2024, against successive reductions since March 2022. Wage
increases have supported private consumption since the second half of 2024, partly offsetting the impact of
restrictive fiscal and monetary policies. However, in August and September wages declined again, amid
inflationary pressures, while in October they remained stable. According to the IMF (October 2024), growth is
estimated to have declined to 0.3% in 2024, from 1.7% in 2023, due to temporary disruptions in the
automotive industry and the downturn in tourism, and to strengthen to 1.1% in 2025, reflecting rising wages
and consumption
3
.
In the United Kingdom, after contracting in the second half of 2023, GDP grew at a decelerating pace in the
course of 2024, by 0.7% in the first quarter, 0.5% in the second quarter and 0.1% in the third quarter (quarter
on quarter), as a result of the recovery in business investment and consumer spending. The easing of monetary
policy is expected to further boost business investment in the coming quarters. Based on the IMF forecast
(October 2024), GDP growth will strengthen to 1.1% in 2024 and 1.5% in 2025, from 0.3% in 2023. The
factors driving this increase are stronger investment and consumption amid lower inflation and more
favourable financial conditions. Annual consumer price index (CPI) inflation remained stable at 3.8% in
February and March 2024, having declined markedly from high levels in 2023. Services inflation increased in
August and declined in September. In October, it rose slightly, driving inflation to 3.3%. According to the IMF
(October 2024), inflation is expected to be 3.1% for 2024 and 2.4% for 2025. The unemployment rate declined
to 4.0% in August 2024, but reached 4.3% in September due to an increase in short-term unemployment
3
.
The Eurozone economy rebounded in 2024 with resilience, driven mainly by the energy crisis and geopolitical
developments. In the first half of 2024, the improvement in foreign demand and international trade led to GDP
growing at an accelerated pace in the third quarter (0.4% quarter on quarter)
3
, supported by a recovery in
domestic demand. While services supported growth, industry contributed negatively. The labour market
remains resilient, but employment growth is declining as there are fewer job vacancies. Employment growth
was low in 2024, standing at 0.1% in the second quarter and 0.2% in the third quarter, and is projected by
Eurosystem staff (December 2024) to be 0.8% in 2024 and 0.4% in 2025, compared with 1.4% in 2023. The
unemployment rate stood at a historical low of 6.4% in 2024 and is expected to be around the same level of
7
6.5% in 2025. In the Eurosystem staff baseline scenario (December 2024), GDP is estimated to have increased
to 0.9% for 2024, from 0.5% in 2023, mainly on account of improving foreign demand and international trade.
It is projected to increase further to 1.1% in 2025, supported by rising real incomes, stronger external demand
and weakening monetary policy effects
4
.
Inflation in the euro area continues to decelerate. Following its expected temporary increase in the fourth
quarter of 2024, it is estimated to gradually decline to below 2.0% in 2026. According to the Eurosystem staff
forecasts (December 2024), inflation will be 2.4% in 2024 and 2.1% in 2025, from 5.4% in 2023. The easing
of pressures stemming from labour costs, as well as the unwinding of secondary pressures stemming from the
energy crisis and the pandemic, will contribute to this decline in inflation. The disinflation in the euro area is
expected to continue, but to be higher than overall inflation
4
.
Greek Economy |2024
The Greek economy continued to grow at a satisfactory pace in 2024, despite international geopolitical
turbulence and natural disasters, outpacing the euro area growth rate. Growth was mainly driven by private
consumption, exports of services and investment, while exports of goods contributed negatively. Headline
inflation in the course of 2024 de-escalated, but nevertheless remained above the euro area, as persistently
high services inflation limited its de-escalation. As regards the labour market, employment continues to show
positive rates of change in 2024, unemployment is declining further, but job vacancies are increasing.
The fiscal policy pursued in recent years by the Greek economy and efforts to combat tax evasion seem to
pay off, as high primary surpluses are achieved without the need for restrictive measures leading to the
reduction of public debt as a percentage of GDP. Risks to public debt sustainability appear to be contained
over the medium term, subject to a commitment to fiscal targets and an efficient use of European resources.
However, in the longer term, there is increased uncertainty, as the gradual refinancing of debt obligations will
increase the exposure of the Greek State to interest rate and market risk, which eliminates the scope for fiscal
easing.
The Greek economy should continue with commitment to a fiscal path within the framework of European rules
and to further strengthen fiscal sustainability in the long term. At the same time, reforms should be pursued,
the extroversion of the economy strengthened and the use of NextGeneration EU (NGEU) resources
accelerated, in order to boost the productivity and growth rates of the Greek economy.
4
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
8
More specifically, GDP continued to grow in the nine-month period of 2024 by 2.3% compared to the same
period of 2023, with private consumption and to a lesser extent investment contributing positively and
increasing domestic demand while government consumption recorded a significant decline. The external
sector made a negative contribution to GDP change, although exports of services were positive, as exports of
goods declined significantly and imports of goods and services increased at the same time
5
.
Inflation fell in December 2024 to 2.7% from 3.5% in 2023
6
. The main characteristics of inflation for the
available period of 2024 are that it started in January from lower levels (3.2%) than the average of the previous
year (4.2%), but also compared to December 2023 (3.7%), and that it mainly moved horizontally. All its main
components contributed to its de-escalation. However, the marginal decline in the average rate of increase in
services prices was essentially an obstacle to a faster disinflation of headline inflation
5
.
Private consumption continued to grow in the nine months of 2024 (1.8% year-on-year) and to be a key
component of the pick-up in economic activity, driven by the strengthening of households’ real income
supported by continued employment growth, nominal wage growth and lower inflation, while government
consumption recorded a significant decline
5
. Consumer expenditure continued to increase in the nine months
of 2024 as reflected in the annual increase in retail trade volume by 1.7% in September 2024 compared to
the corresponding index of September 2023
7
.
In the nine-month period of 2024, investment continued to grow, but at relatively low pace. More specifically,
gross fixed capital formation increased by 2.2% in 2024, compared with an increase of 9.3% in the same
period of 2023. Investment in “Engineering equipment and weapon systems” contributed positively to this
increase (8.1%) while investment in “Other construction”, which increased by 5.6% did also have a secondary
positive contribution. By contrast, “Housing” investment fell by 4.6%, following a strong increase in 2023,
while “Transport equipment” fell by 1.3%. Finally, investment in “Information Communications Technology
Equipment” decreased by 1.8% and investment in “Other products” increased by 1.7%.
5
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
6
Source: ELSTAT Consumer Price Index, December 2024
7
Source: ELSTAT Turnover Index of Retail Trade, November 2024
9
The decline in the share of gross fixed capital formation in GDP was a consequence of the economic crisis and
has not yet been overcome. Before the crisis, this share was higher in Greece than the euro area average and
in 2019 it reached its lowest level, 11% of GDP, compared to 21.9% of GDP in the euro area. Since then, the
share has continuously increased and stood at 14.4% in the nine-month period of 2024, but well below the
euro area average (20.9% of GDP in the nine-month period of 2024)
8
.
As regards the current account balance, its deficit widened in the nine months of 2024 relative to the
corresponding period of 2023 as, despite an increase in the period April-September 2024, exports of goods
decreased and imports of goods increased. Primarily, the deficit of the balance of goods was widened by a
deterioration in the balance of other goods and, to a lesser extent, in the fuel balance. More specifically, the
value of exports decreased by 2.7% despite the increase recorded (mainly non-fuel exports of goods) in the
period April-September 2024, while the value of imports increased by 1.9%. The decline in both fuel exports
and imports reflects to some extent the decline in their international prices. For the year as a whole, the
current account balance is expected to deteriorate slightly compared to 2023 as a percentage of GDP (0.3%)
8
.
The labour market has shown strong growth in recent years, resulting in a decline in the unemployment rate
to 11.1% in 2023, while further de-escalation continued in 2024 with the unemployment rate reaching 10.3%
in the nine months of 2024. It is noteworthy that in the second and third quarters of 2024 the unemployment
rate reached a single-digit level for the first time since 2009. The unemployment rate declined for both men
and women, but remained significantly higher for women than for men. It was 8.1% for men and 13% for
women. At the same time, the unemployment rate for young people aged 20-29 fell to 18.1% and the long-
term unemployment rate to 5,5%
8
.
Employment increased by 1.9% in the nine-month period of 2024, compared to the same period of 2023 when
it rose by 1.3%. More specifically, self-employed with staff contributed positively with an increase of 3.4%,
while salaried personnel, who make up about two-thirds of employees, grew at a milder rate of 1.8%. It should
be noted that at sectoral level employment growth in the nine months of 2024 was mainly driven by an
increase in the number of persons employed in construction (13.5%), tourism (5.5%) and wholesale and retail
trade (2.4%). By contrast, a decrease in employment was observed in public administration/defense and
education
9
.
8
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
10
According to data from the ERGANI information system, the balance of salaried employment flows in the nine-
month period of 2024 remained at high levels, although it was slightly lower than in the corresponding period
of 2023. Figures show 302,744 new jobs created in 2024 compared to 312,112 in 2023. The largest hiring
increase occurred in tourism as the industry performed higher than in 2023. Finally, hirings in flexible forms
of employment outpaced those in full-time employment, accounting for 53.2% of all hirings (compared to
52.0% in the nine months of 2023)
9
.
In December 2024, the economic sentiment index declined slightly to 106.0 from 106.2 in November 2024,
according to the latest IOBE data. This marginal weakening comes from the industrial and retail sectors, while
construction, services and consumer confidence improved. Overall for 2024, the average of the index is close
to 108 points, a level higher than the corresponding 107.6 in 2023 and at the same time the highest since the
economic crisis that started in 2008
10
.
According to forecasts by the Bank of Greece, the growth momentum of the Greek economy will continue in
the coming years and growth rates will be about double the euro area average. The growth rate of the Greek
economy is expected to be 2.2% in 2024, to accelerate to 2.5% in 2025 and to decline slightly to 2.3% in
2026 and 2.0% in 2027
9
. Consumption will continue to be the main driver of economic activity in the coming
years, while investment and exports will continue to make a positive contribution.
Greek Economy | developments and outlook 2024
The growth momentum of the Greek economy in 2024 is expected to continue in the coming years, as the
Greek economy will continue to recover from the long-term crisis, according to the Bank of Greece forecasts.
The growth rate of the Greek economy is estimated to have stood at 2.2% in 2024, and is expected to
accelerate to 2.5% in 2025 and to decline slightly to 2.3% in 2026 and to 2% in 2027. The main driver of
growth in the coming years is private consumption, while investment and exports will continue to make a
positive contribution. On the other hand, the contribution of the external sector is expected to be marginally
negative, as strong investment activity is expected to drive up imports at rates similar to exports
11
.
9
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
10
Source: Economic Conjunctural Survey Results (December 2024), IOBE
11
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
11
Inflation continued to slow in 2024 but stood at a higher level in Greece than in the euro area, as service
inflation, which remained at high levels, limited its decline. According to the Harmonised Index of Consumer
Prices (HICP), it is estimated to have stood at 3% in 2024, up from 4.2% in 2023, reflecting the large slowdown
in food inflation. Inflation in Greece is projected to converge towards the European Central Bank's 2 percent
target by 2026, but will remain marginally above it. However, in 2027, due to the integration of the impact of
the Emissions Trading System into the energy component of the HICP, a temporary acceleration of the index
to 2.5% is expected. Services inflation is expected to be more persistent due to expected increases in wages.
Finally, core inflation is expected to decline significantly to 3.5% in 2024 and 3.1% in 2025, driven mainly by
the disinflation of non-energy industrial goods
11.
Private consumption is expected to grow in the coming years on average at a rate close to 2.1%, supported
by a strengthening of households’ real disposable income, as employment is expected to continue to recover,
wages to rise and inflation to gradually decline. However, there are risks surrounding developments in private
consumption associated with heightened uncertainty. Sources of uncertainty could be a worsening of the
geopolitical crisis in Ukraine and the Middle East and possible disruptions in international value chains, which
would have a negative impact on commodity prices and thus on the cost of living for households. At the same
time, as a result of the climate crisis, prices may rise, negatively affecting the purchasing power of
households
11
.
Domestic investment is projected to continue growing at high rates, averaging 6.5% until 2026. For 2027,
however, a significant reduction in the pace of total investment is expected as there will be a large reduction
in government investment, as the end of grants from the Resilience and Development Fund (RRF) is expected
in 2026. Private investment is projected to grow at a rate of around 7.8%, supported primarily by available
European
11
funds. Housing investment is expected to continue to grow at high rates in the coming years, as
it is still much lower in size than in the pre-crisis period. It is noteworthy that although high, the investments
of the last decade are not enough for Greece to approach the European average in terms of investment as a
percentage of GDP at the end of 2027. Efforts must therefore be stepped up to attract more, mainly productive,
investment in order to maintain the country's growth potential.
12
Total exports of goods and services in the coming years are projected to continue growing at an average rate
of 3.3%, combined with the enhanced competitiveness of Greek products and the expected increase in foreign
demand. However, the external sector’s contribution to GDP is estimated to be marginally negative in the
coming years, owing to strong investment activity, which will drive import growth rates close to export growth
ones. Finally, the composition of imports should be carefully monitored, as excessive import growth in the
coming years risks seriously deteriorating the current account balance
12
.
Unemployment is estimated to have stood at 10.6% in 2024 according to the ELSTAT Labour Force Survey,
while it will gradually decline to 8.5% by 2027. This reflects the ongoing economic recovery. Regarding labour
costs, the Bank of Greece estimates that in the coming years, for the economy as a whole, nominal wages per
employee will increase at rates of around 4.5% per year, as a result of the tightening labour market and recent
collective bargaining agreements in various branches of the private sector. By contrast, labour productivity for
the economy as a whole is expected to grow at a lower rate. These trends will put pressure on business
margins and the competitiveness of the Greek economy
12
.
The Greek Banking System | 2024
The Bank of Greece’s Monetary Policy Report for 2024 states that the main factors that shaped and positively
impacted the prospects of Greek banks are the good performance of the Greek economy and the upgrade of
Greece’s credit rating to the Investment Category (hereinafter referred to as the “upgrade”) in 2023. Credit
rating agencies upgraded significant banks to investment grade in 2024, keeping the outlook positive.
In this favourable environment, the Greek banking sector strengthened profitability, liquidity and capital
adequacy ratios in the nine months of 2024, while the quality of their loan portfolio improved on an annual
basis. In the nine months of 2024, the Greek banking system was characterized by the following: a) an increase
in deposits, b) a decrease in lending rates and c) an increase in lending.
Profitability of Greek banks remained high in 2024, but remained almost unchanged from the nine-month
period of 2023, on the one hand, due to higher net interest and commission income and, on the other hand,
due to an increase in other provisions, mainly due to non-recurring factors, while credit risk provisions declined.
The capital ratios of Greek banks improved in the nine months of 2024 compared to the end of 2023, mainly
due to an increase in core profitability and the issuance of securities taken into account regarding capital
adequacy, while risk-weighted assets remained almost unchanged. In the nine months of 2024, the non-
12
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
13
performing loan ratio of Greek banks declined significantly, mainly due to the securitization of loans under the
Hercules government guarantee scheme and the reduction in the share of Stage 2 loans. As regards bank
liquidity, Greek banks’ liquidity coverage ratios (LCR) and net stable funding ratios (NSFR) increased further
year-on-year, remaining above the mandatory regulatory requirement and higher than those of euro area
banks. It is noteworthy that Greek banks maintain sufficient liquidity, despite a further reduction in Eurosystem
funding (repayment of TLTRO operations). In addition, the loan-to-deposit ratio is significantly lower in Greek
banks compared to banks in the eurozone.
More specifically, in the nine months of 2024, the profitability and return on equity of Greek banks remained
almost unchanged, on an annual basis, as banks recorded profits after taxes and discontinued operations of
€2.98 billion compared to €3.02 billion in the corresponding period of 2023
13
.
As shown in the table below, Greek banks' operating income increased by 10% compared to the same period
of the previous year. Net interest income increased by 8.1%, mainly due to higher loan interest income.
Interest income increased by 19.4% to €12 billion due to high interest rates (despite the ECB’s decreases
within 2024) and credit expansion. Interest payment expenses increased to €5.5 billion compared to around
€4 billion in the corresponding period of 2023, a 36.8% change. An increase of 16.5% can be observed in net
commission income as well as in income from financial operations, which shows a large increase of 106.1%
13
.
As regards operating expenses, they increased by 4.7%, due to an increase in personnel costs of 11.7%, and
depreciation which increased by 6.6%, while the cost of administrative expenses decreased by 5.2%
13
.
In the nine months of 2024, the cost of credit risk declined significantly from last year. Specifically, provisions
were made for credit risk totaling EUR 843 million, compared with EUR 1.2 million in the nine months of
2023
14
.
Taking all of the above into account, banks’ profitability remained almost unchanged in the nine months of
2024, as the strengthening of net interest and commission income was offset by an increase in other provisions
due to non-recurring factors. Significant euro area banks recorded an increase in net profitability and return
on equity, mainly driven by an increase in net interest income but at a lower pace than in 2023. They also
increased their credit risk provisions, reflecting the marginal deterioration in the quality of the loan portfolio in
13
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
14
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
14
some countries and the low level of credit risk coverage. For Greek banks, the increase in the financing of the
economy is expected to offset the pressure on the net interest margin from the reduction in key Eurosystem
interest rates. Finally, banks’ financial results may be positively affected by enhanced competition in the
domestic banking market.
Below is the profit and loss account of Greek banks:
Profit and loss account of the Greek banking sector
amounts in EUR million
(Nine months 2024)
9M 2024
2023
9M 2023
Operating income
8,750
11,006
7,955
Net interest income
6,719
8,505
6,213
- interest income
12,177
14,196
10,202
- interest costs
-5,457
-5,692
-3,988
Net income from non-interest-bearing operations
2,031
2,501
1,742
- net commission income
1,537
1,798
1,319
- revenue from financial operations
299
307
145
- other revenue
195
396
278
Operating costs
-2,961
-3,896
-2,828
Personnel costs
-1,490
-1,920
-1,334
Administrative costs
-986
-1,361
-1,040
Impairment
-485
-616
-455
Net income (operating income - operating expenses)
5.790
7,109
5,127
Provisions for credit risk
-843
-1,690
-1,178
Other impairment losses
1
-1,006
-381
-208
Non-recurring gains/losses
3
96
113
Profit/loss before tax
3,944
5,135
3,854
Taxes
-1,017
-1,219
-863
Profit/loss from discontinuing operations
54
82
25
Profit/loss after tax
2,980
3,834
3,016
Source: processed data from the Interim Monetary Policy Report (December 2024) of the Bank of Greece where financial statements were
used for the 4 major banks (SIs) and regulatory data for less significant banks (LSIs).
1
Impairment of securities and tangible and intangible assets
15
On the liquidity side, conditions for the Greek banking system improved further in 2024. Customer deposits
continued their upward trend, albeit at a reduced pace compared to 2023, reflecting good economic growth.
The increase in deposits contributed significantly to keeping the liquid assets of Greek credit institutions at a
high level, despite the repayment of the amounts raised through the TLTRO III operations.
More specifically, the balance of private sector deposits (households and businesses) amounted to
€203.8 billion in December 2024 (a new high since February 2011 amounting to €202.9 billion), of which
€150.4 billion were deposits from individuals and non-profit institutions (INPIs), €49.1 billion were deposits
from non-financial undertakings (NFUs), €0.6 billion were deposits from insurance companies and professional
insurance funds and €3.7 billion were deposits from financial institutions. More specifically, the stock of private
sector deposits recorded a cumulative increase of approximately €9 billion, due to the recovery of business
deposits (NFUs) by €5.1 billion, while the increase of deposits of households and non-profit institutions (INPIs)
was more limited and recorded a cumulative increase of €3.7 billion. Finally, General Government deposits
also increased by 4.7% year-on-year, reaching €211 billion (an increase of €9.5 billion)
15
.
The comparatively small increase in household and INPI deposits relative to businesses is due to the pressure
on family budgets due to the increase in the cost of living, and the shift of their saving behavior towards
alternative investments that offer higher returns. Banks’ deposits continue to consist predominantly of liquid
assets held in overnight accounts, accounting for 78% of private sector deposits in December 2024. In
December 2024, the balance of overnight deposits increased by 15% for NFUs compared with December 2023,
while for households the corresponding increase was 3%. For the remaining deposits, the change compared
to 2023 was 1% for NFUs and 1% for households and INPIs
15
.
In the period ahead, demand for deposits is expected to increase, in line with GDP developments. In addition,
disinflation will boost individuals’ saving incentives and thus demand for deposits, even when nominal deposit
rates start to fall, should further reductions in ECB policy rates be decided. Moreover, it should not be
overlooked that the yields of many of the alternative investments that currently compete with deposits will
also decline. Of course, lowering deposit rates in real terms would also reduce the attractiveness of bank
deposits in relation to, for example, cash as a means of holding wealth.
Total financing of the private sector (households and businesses) in the Greek banking system
amounted to €122.7 billion in December 2024, of which financing to businesses amounted to €83.7 billion,
accounting for approximately 68% of total private sector financing by Greek credit institutions. The largest
concentration concerns non-financial undertakings (NFUs) €74.3 billion, which account for 89% of total
financing to enterprises. More specifically, private sector financing recorded a cumulative increase of
15
Source: https://www.bankofgreece.gr/statistika/nomismatikh-kai-trapezikh-statistiki/katatheseis-twn-pistwtikwn-idrymatwn
16
approximately EUR 4.7 billion
16
, amounting to an increase of EUR 7.4 billion in financing to enterprises and a
decrease of EUR 2.2 billion in financing to individuals and private non-profit institutions. Funding to individuals
and private non-profit institutions amounted to €34.9 billion, accounting for 28% of total private sector
funding, while funding to self-employed persons, farmers and sole proprietorships amounted to €4.1 billion
(3% of total funding)
17
.
The acceleration of financing to firms is linked to the strengthening of demand for bank loans, mainly from
large firms. As regards the supply of bank loans, in 2024 Greek banks maintained their liquidity at levels that
support their ability to lend to the private sector, despite the reduction in the outstanding amount of credit
received from the Eurosystem – as a result of the repayment of the TLTROs. Greek credit institutions have
drawn resources from inflows of retail deposits, through bond issuance and from the foreign interbank market.
Also, the provision of business credits was reinforced by the co-financing and guarantee programmes of
development agencies as well as the bank loans co-financing the investment projects that are part of the
Recovery and Resilience Facility (RRF).
The decline in financing to private non-profit institutions is mainly due to mortgage loans, as bank interest
rates on housing loans remained at a higher average level in 2024 than in 2023 and their impact on demand
for housing credit was negative. However, demand on the part of households for housing needs, as well as
total financing, whether bank or public, exists and this is shown more specifically by the loans channeled
through the “My Home” programme, which are mostly financed from public funds (and only by a quarter from
banks). These loans were quickly absorbed and amounted to €339 million, of which the bank participation was
€85 million. Also, in 2025, the extension of this programme is expected to begin, the “My House II” housing
programme, with a total budget of €2 billion, of which €1 billion in borrowed funds will come from the Recovery
and Resilience Facility (RRF) and €1 billion from banks. 50% of the loan financed by the RRF will be interest-
free and the rest will be provided with interest-bearing bank loans. As regards consumer loans and other loans,
they decreased by €0.2 million compared to 2023
18
.
Looking ahead to credit growth, the annual growth rate of financing to NFUs is expected to remain high in the
near term. GDP growth is expected to continue to support credit growth, while the high level of bank lending
rates should continue to weigh on it in the months ahead. Furthermore, the positive contribution to bank
credit from banks’ participation in the co-financing of investment projects under the Recovery and Resilience
Facility (RRF) is projected to increase, as the value of already concluded contracts is already high, given that
16
Source: https://www.bankofgreece.gr/statistika/nomismatikh-kai-trapezikh-statistiki/xrhmatodothsh-ths-ellhnikhs-oikonomias
17
Source: https://www.bankofgreece.gr/statistika/nomismatikh-kai-trapezikh-statistiki/xrhmatodothsh-ths-ellhnikhs-oikonomias
18
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
17
more loan disbursements will be expected, provided of course that the implementation of the relevant
investment projects is also accelerated. Finally, the positive effect on credit growth is expected to be
maintained from the financing resources of the credit institutions and the EIB Group that will be channeled
under the 2021-2027 Regional Development Partnership (NSRF), as well as from the funds managed by the
Hellenic Development Bank.
In 2024, the quality of the loan portfolio of Greek banks improved even further. The decline in non-
performing exposures (NPEs) continued, resulting in a ratio of non-performing exposures to total loans of
4.6% in the nine-month period of 2024, compared with 7.9% in the nine-month period of 2023 (6.7% in the
12-month period of 2023). The factors that led to the reduction in non-performing exposures were the
securitisation of loans under the Hercules government guarantee scheme and the decrease in the share of
Stage 2 loans in total loans on an individual basis.
The NPE ratio in Stage 2 stood at 7.9% in the nine-month period of 2024, compared with 9.6% in the nine-
month period of 2023 and 9.3% in the 12-month period of 2023
19
.
The capital adequacy of Greek banks, according to the Bank of Greece’s Monetary Policy Report, increased
significantly in 2024, due to an increase in regulatory capital. Regulatory own funds were strengthened mainly
through internal capital creation and the issuance of capital instruments included therein, while risk-weighted
assets remained virtually unchanged. Specifically, the Common Equity Tier 1 ratio (CET1 ratio) on a
consolidated basis remained stable at 15.5% in the nine months of 2024 compared to December 2023, while
compared to September 2023 it increased to 14.3%. The Total Capital Ratio (TCR) stood at 19.4% in
September 2024 from 17.6% in September 2023 and increased compared to December 2023 (18.8%). It is
worth noting that the regulatory capital of Greek banks so far consists by 40% of final and liquidated deferred
tax credits (DTCs), however, the quality of capital is expected to improve over the medium term amid banks’
expected high profitability, based on banks’ announcements to accelerate the amortisation of DTC
19
.
Regarding the liquidity of Greek banks, it remained at high levels both on an annual basis and at the level of
nine months 2024, surpassing the mandatory requirements and the corresponding indicators of banks in the
Eurozone for the same periods. According to the latest available data from the Bank of Greece, the liquidity
coverage ratio of Greek banks stood at 219.5% in the nine-month period of 2024, from 215,6% in the nine-
month period of 2023 and 220.7% for the whole year 2023, while the ratios for the corresponding periods in
19
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
18
the euro area amounted to 159.4% (nine-month period of 2024) against 158% (nine-month period 2023) and
to 164.3% (for the whole of 2023)
20
.
The priorities for banks in Greece in 2025 will be the following:
a) the effort to achieve further consolidation of banks' assets, leading to further convergence towards the
average of eurozone banks.
(b) the avoidance of new net inflows of non-performing loans, which should contribute to further improving
capital ratios.
(c) the maintenance of high profitability that is expected to be achieved by increasing the financing of the
economy, which will offset possible pressures on the net interest margin.
Developments concerning the Optima bank SA Group|2024
Ordinary General Meeting of the shareholders of OPTIMA BANK S.A.
Optima bank held on 23/05/2024 the 1
st
Ordinary General Meeting of its shareholders after the admission of
its shares to trading on the Athens Stock Exchange. The General Meeting approved the financial statements
for 2023, where net profits for the bank of €103 million were presented and it was decided to distribute a
dividend of €0.44 per share, which corresponds to 32% of the profits for the year 2023. The same General
Meeting also mentioned the expansion of Optima bank's branch network with the addition of a new branch in
Crete and specifically in the city of Chania. The branch started its operation in September 2024.
Announcement of dividend distribution of profits for the year 2023
The Ordinary General Meeting on 23/05/2024 decided to distribute a dividend from the profits of the fiscal
year 2023 amounting to €0.44 per share (gross), before withholding statutory tax, i.e. a total amount of
€32,425,422.48.
For the distribution of dividends, the General Meeting approved the dates of the ex-dividend right, the
identification of the beneficiaries of the dividend and the start of the payment of the dividend for the fiscal
year 2023 as follows:
i. Ex-dividend entitlement date: Tuesday 25 June 2024
ii. Date of identification of dividend beneficiaries: Wednesday 26 June 2024
iii. Dividend payment start date: Monday 1 July 2024.
20
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
19
The payment of the dividend for the financial year 2023 was made through the Bank itself, acting as the
paying bank.
The same General Meeting authorized the Board of Directors to take any necessary or appropriate action in
the context of the implementation of the aforementioned decision of the Ordinary General Meeting.
Free distribution of shares, through capitalization of profits for the year 2023 and distribution of
part of the profits for the year 2023 to members of the Board of Directors and staff
The General Meeting of Shareholders decided the free distribution of shares of the Bank through the
capitalization of part of the profits of the year 2023, up to the amount of €1,035,000.00, with an equal share
capital increase, divided by the amount of the increase, into up to 300,000 new nominal, ordinary, voting
shares, with a nominal value of €3.45 each (the "New Shares"), in order for the New Shares to be distributed
free of charge, under the conditions of the Law, to members of the Board of Directors, to senior executives of
the Bank (Executive Committee Members), as well as to the regular staff of the Bank ("Beneficiaries"). It also
authorized and instructed the Board of Directors to take all necessary actions for the share capital increase by
capitalization of profits and to determine the specific terms for the free distribution of shares to the
Beneficiaries.
Finally, the General Meeting approved the distribution of part of net profit of the financial year 2023 as a one-
off extraordinary remuneration (Bonus) of a total amount of up to €4,000,000.00 to members of the Board of
Directors and the Bank's staff, as a reward for their contribution to the achievement of the Bank's profitability
and objectives during the financial year 2023, and provided the relevant authorizations to the Board of
Directors to determine the specific terms of distribution of the above amounts and to deal with the procedural
issues for the payment of the extraordinary remuneration (Bonus).
Capitalisation of profits / Share capital increase of the Bank
Accordingly, for the purpose of the Free Shares Programme under Article 114 of Law 4548/2018 in the current
financial year, the Ordinary General Meeting of 23/05/2024 decided to increase the share capital of the Bank
by the amount of two hundred and seventy-six thousand (€276,000) Euros, by issuing eighty thousand
(80,000) new, ordinary, registered voting shares, with a nominal value of €3.45 each, by capitalization of an
equal part of undistributed profits for the financial year 2023 and amending Article 5 of the Bank's Articles of
Association.
At the same time, it authorized and instructed the Board of Directors to take all necessary actions for (i) the
implementation of the above share capital increase of two hundred and seventy-six thousand (€276,000) Euros
with capitalization of profits, and (ii) the determination of the specific terms and conditions of the Program, at
20
its discretion and in compliance with the applicable legislation, as well as to take any relevant action and take
any relevant decision regarding the purpose of implementation and application of the program.
In the context of the above decision, the New Shares were allocated to a total of twelve (12) Beneficiaries, in
accordance with the terms of Article 114 of Law 4548/2018.
The nominal share capital of the Bank amounts, after the above share capital increase, to two hundred and
fifty-four million five hundred and twenty thousand seven hundred and eighty-nine euros and ninety cents
(€254,520,789.90) and is divided into seventy-three million seven hundred and seventy-four thousand one
hundred and forty-two (73,774,142) registered shares, each with a nominal value of three euros and forty-
five cents (€3.45). The New Shares are of the same class as the Bank's shares already traded on the Main
Market of the Athens Exchange (the "ATHEX").
The Bank followed the procedure for the listing of the New Shares on the Athens Stock Exchange (the
"ATHEX"), in accordance with the provisions of the ATHEX Regulation and the relevant decisions of the Board
of Directors of the ATHEX. The New Shares were listed on the second business day following the approval of
their listing by the ATHEX. The starting price of the Bank's shares on the ATHEX on the date of beginning of
trading was formed in accordance with the ATHEX Regulation and Decision No. 26 of the Board of Directors
of the ATHEX, as in force. The New Shares were registered on the date of beginning of trading in the records
of the Hellenic Central Securities Depository (ELKAT) and in the shares and accounts held by the Beneficiaries
in the Dematerialized Securities System (DSS) of the ATHEX, in accordance with the applicable legislation.
Addition of a Non-Executive Member to the Board of Directors
The Ordinary General Meeting of the shareholders of Optima bank approved the election and addition of Mr.
Nikolaos Giannakakis to the Board of Directors of the Bank as a Non-Executive Member, for the remainder of
the term of office of the current Board of Directors elected by the Ordinary General Meeting of the Shareholders
on 23/03/2023, i.e. by 10 September 2027 at the latest.
New acquisitions of performing loans
1. Acquisition of part of Tethys' performing loan portfolio
Optima bank completed the acquisition of part of the Tethys loan portfolio in January 2024. This performing
portfolio acquired by the Bank concerns loan obligations from four hotel units in Crete, Santorini and Kos.
After the necessary restructuring process of these business loans, these loans return to the banking system
on a performing basis through Optima bank, in order for these companies to have access to financing and,
above all, to restart from a sound basis the implementation of their business plans in the tourism market.
21
2. Acquisition of performing loans / Project Onassis
Optima bank in December 2024 considered the acquisition of a portfolio of performing and secured loans
under the name Project Onassis.
More specifically, in implementation of the Bank's strategy for the acquisition of loans in the secondary market,
the Bank, ensuring the prudent assessment of borrowers, proceeded to the acquisition of loans of 4 borrowers-
hotels (1 in Kefallonia, 1 in Mykonos, 1 in Heraklion, Crete and 1 in Zakynthos) from the total perimeter of this
portfolio. 10 borrower cases were examined, of which 4 were selected on the basis of banking criteria and on
the basis of the EBA guidelines on the classification of loans as performing. This transaction was completed in
2024.
Expansion of Optima bank branch network
In 2024, Optima bank continued the expansion of its branch network with the opening of a new bank branch
in Crete.
Specifically, the management of Optima bank inaugurated on Thursday, September 26, 2024 its new branch
in Chania, the second branch in Crete, and specifically on 1866 Square, as part of its growth strategy in the
region, substantially expanding its presence in the largest cities of Greece. With the new branch in Chania,
Optima bank has a network of a total of 29 branches, 8 of which are located in cities outside Athens.
Change in the composition of the Board of Directors
On 31 October 2024, Ms Clio Lymberi resigned from her position as Independent Non-Executive Member of
the Board of Directors of the Bank, as well as from her position as Chairman of the Risk Management
Committee and member of the Audit Committee and the Remuneration and Nominations Committee.
Following the above resignation, the Board of Directors of the Bank, at its meeting of 08/11/2024, decided,
pursuant to Article 82 of Law 4548/2018 and Article 10(2) of the Bank's Articles of Association, to continue
the management and representation of the Bank, without replacing Ms. Lymberi temporarily, until her
replacement by a new Board member, who will meet the criteria of individual and collective suitability, in
accordance with the applicable legislation and the Adequacy Policy of the Bank's Board Members. In this
context, the BoD was reconstituted as follows:
1. Georgios Taniskidis of Ioannis and Olga, Chairman, Non-Executive Member,
2. Petros Tzannetakis of Tzannibeis and Maria, Vice-Chairman, Non-Executive Member,
3. Dimitrios Kyparissis of Apostolos and Fotini, Chief Executive Officer, Executive Member,
4. Angelos Sapranidis of Nikolaos and Fotini, Executive Member,
5. Theofanis Voutsaras, of Christos and Eleni, Non-Executive Member,
6. Nikolaos Giannakakis of Konstantinos and Maria, Non-Executive Member,
22
7. Theodoros Efthis of Elias and Malama, Independent Non-Executive Member,
8. Pavlos Kanellopoulos of Dimitrios and Eleni, Independent Non-Executive Member,
9. Georgia Kontogianni of Vasilios and Anastasia, Independent Non-Executive Member and
10. Georgios Kyriakos of Konstantinos and Nadia, Independent Non-Executive Member.
In addition, at the above meeting of 08/11/2024, the Board of Directors decided to reconstitute the Bank's
Board of Directors committees as follows:
Audit Committee
It was decided to reconstitute the Audit Committee by appointing Mr Theodoros Efthis as a new member of
the Committee in replacement of Ms Lyberi. Following this, the composition of the Audit Committee was
defined as follows:
1. Theodoros Efthys, Independent Non-Executive Member,
2. Pavlos Kanellopoulos, Independent Non-Executive Member and
3. Petros Tzannetakis, Non-Executive Member.
Risk Management Committee
It was decided to reconstitute the Risk Management Committee with the remaining three members, namely:
1. Theodoros Efthys, Independent Non-Executive Member,
2. Pavlos Kanellopoulos, Independent Non-Executive Member and
3. Georgia Kontogianni, Independent Non-Executive Member
as it is not required, under its Rules of Procedure, to replace the resigning Member.
Business activity
Optima bank is active in the private and corporate finance market in Greece. The Bank, which is the Group's
parent company (see below 3.7 "Organizational Structure"), through its customer service network as well as
through its cooperation with the Group's individual companies, offers, from the fourth quarter of 2019 onwards,
a wide range of products and services covering the following areas:
• Private Banking or Retail Banking
The Bank includes in the activities of private banking all individuals, including freelancers and sole
proprietorships, focusing mainly on high-income clients (Affluent / Private clients), who hold significant funds
under management. Both Affluent customers and Private customers are served by relationship managers,
while enjoying preferential pricing on a variety of products and services. In addition, Affluent and Private
clients have the ability to receive exclusively investment analyses and strategies issued by specialized sections,
23
with the aim of better informing them and shaping their portfolio. The basic banking relationship is initiated
either by physical presence in the Bank's branch network or through the digital on boarding and includes the
provision of a deposit account, a debit card and access to the e-banking services offered. The Bank provides
retail clients with deposit accounts, debit/credit cards and loan products, payment services and investment
and stock exchange services.
• Corporate Banking
The Bank includes in its corporate banking activities legal persons of any kind, whether Greek or foreign,
focusing mainly on companies with an annual turnover of more than €2.5 million. The focus, in terms of
corporate banking, is on: (a) small businesses (Business Banking), with a turnover of over €2.5 million up to
€7.5 million, (b) small and medium-sized enterprises (SMEs), with a turnover of €7.5 million up to €50 million,
as well as (c) large companies (Large Corporates) with a turnover of at least €50 million.
This includes companies with an export character and with significant profitability characteristics that are active
in various sectors of the economy. The Bank offers corporate banking customers a set of products and services
with a view to fully serving the trading activity of the company, as well as covering its borrowing needs, of
any kind and form. Small businesses are assigned to relationship managers in the branch network who are
solely responsible for serving the relevant customers, while small and medium-sized enterprises and large
enterprises with specialized needs for more complex financing solutions / products are assigned to relationship
managers of the Company's competent unit. The Bank provides its clients, who are legal entities, with products
and services that meet the needs of a modern business, such as working capital and investment (short and
long-term), in the form of loan agreements and credit agreements with an open current account, the opening
of secured credits, the issuance of letters of guarantee of any kind, as well as bond loans and factoring
services, etc., and other banking services, including investment and stock exchange services. These forms of
financing are often accompanied by the provision of collateral by the Bank's borrower/counterparty, such as
the assignment of claims, the provision of collateral on dematerialised securities, the assignment of invoices,
personal or corporate guarantees and the pledging of deposits.
• Other services
Digital Banking: The Bank allows the customer to carry out transactions and receive services remotely via
the internet, with platforms such as "Optima e-banking" and "Optima mobile app". The possibilities of e-
banking include:
• Transfers within Optima bank and to other banks in Greece and abroad
• Payments to public & private entities
• Updating personal data of private clients through "eGov KYC"
• Push notifications for the secure approval of e-banking transactions and online purchases
24
• Trading with the digital wallets "Google Pay" and "Apple Pay"
• Online opening of a term deposit (e-term deposit)
• Digital card facilities such as card activation, card loss and re-issue, PIN sending, temporary locking/unlocking
• Easy access to digital statements (e-statements) of products
• "Live chat" for real-time communication with a representative of the bank
Regular update: The Bank provides free quarterly information to all its customers on balances and
movements of deposit, investment and loan accounts, through e-banking services. Cases of customers without
relevant access, receive the quarterly update via physical mail or e-mail.
Call Center: The call center representatives are at the disposal of customers to inform them about the use
of the Bank's services and products as well as about how to make seamless use of upgraded digital services.
ATMs: Every branch of the Bank's network has an external ATM for customers who wish to make cash
withdrawals or account balance queries with their debit/credit cards.
• Asset Management and Business Factoring
The Group manages mutual funds, which belong to the bond, equity, mixed and fund of funds categories.
It sells its products under the name Optima mainly through the branch network and the Private Banking of
Optima bank. It places particular emphasis on the design and development of investment products according
to the expected performance, time horizon and risk that each client wishes to assume. In addition to the
Optima fund series, it has developed two white label funds for two investment firms operating in the Greek
market. The fund management services are provided through the subsidiary Optima asset management,
owned by 99.44%, which is licensed by the Hellenic Capital Market Commission to offer its clients advisory
and discretionary portfolio management services.
• Business Factoring
The Group provides a range of services in the field of factoring, developing synergies with the credit sections
of the Optima bank Group with the aim of universally meeting the needs of businesses. The factoring services
are provided through the 100% subsidiary Optima factors.
Evolution of Optima bank S.A.'s aggregates and results|2024
During the financial year 01/01/2024 – 31/12/2024, the Group's key figures and results, as well as their
change, were as follows:
Balance sheet
On 31/12/2024, the total Assets of the Optima bank Group amounted to €5,540.9 million from €3,868.3
million, increased by €1,672.6 million compared to 31/12/2023. This change is further broken down into an
25
increase in customer credit claims as a result of an increase in deposit funding as well as an increase in cash
holdings.
Total loans and advances to customers before accumulated impairments amounted to €3,657.5 million on
31/12/2024 (including equity margin accounts), increased by €1,199 million compared to €2,458.5 million on
31/12/2023. The accumulated impairments appear to be increased by €17,3 million compared to
31/12/2023 and amounted to €44,9 million for the 12 months of 2024 compared to €27,6 million on
31/12/2023, due to the growth mainly of the Bank's loan portfolio.
In Liabilities, on 31/12/2024, total due to customers amounted to €4,643.4 million (recording an increase
of €1,451.6 million compared to 31/12/2023).
The ratio of loans to deposits after provisions as at 31/12/2024 stood at 0.78% (compared to 0.76%
as at 31/12/2023).
Total equity in the 12 months of 2024 amounted to €620.3 million compared to €510.1 million in 2023,
improved by €110.2 million. The improvement is mainly due to the formation of profits for the Optima bank
group of approximately €140.2 million after taxes, increased by €37.2 million compared to the year 2023.
Statement of profit and loss
Regarding the Group's profit and loss account:
Optima bank Group's net interest income amounted to €189.9 million from €142.2 million, an increase of
33.54% compared to 31/12/2023 mainly due to the increase of interest on loans in amortised cost due to the
Bank's credit expansion.
Net Fee and commission income on 31/12/2024 amounted to €41.3 million from €32.1 million in the
corresponding period last year, showing an increase of 28.66% mainly due to an increase in net commissions
related to the granting / renewal of loans, stock exchange commissions and letters of guarantee.
Optima bank Group's total operating expenses for the reporting period amounted to €57.9 million from
€56.9 million in the corresponding period of 2023, recording an increase of 1.76%. The increase in operating
expenses resulted from the increase in remuneration and personnel costs (+7.42%) due to the increase in
human resources (the number of employees gradually increased from 500 on 31/12/2023 to 575 on
31/12/2024 at Group level) with the biggest part of hiring taking place in order to meet the Bank's operational
needs. At 31/12/2024 impairment is also increased compared to 31/12/2023 (+13.69%) and amounted to
€8.3 million from €7.3 million at Group level mainly due to impairment of buildings-installations with a right of
use and impairment of multi-annual impairment costs.
The amount of new investments (additions) in fixed assets of Optima bank Group amounted to €1.8 million at
the end of 2024 compared to €1.5 million at the end of 2023 at the consolidated level. Accordingly, the
26
amount of new investments (additions) in intangible assets amounted to €3.7 million in 2024 compared to €3
million in 2023, at a consolidated level
21
.
As a result of the above, the profit before provisions and taxes for 31/12/2024 amounted to €196.8
million compared to €136 million on 31/12/2023 for the Optima bank Group. Taking into account the provisions
for credit risk, the profit before tax of Optima bank Group for the year that ended on 31/12/2024 amounted
to €176.6 million compared to the profit before tax for the corresponding year 2023 which amounted to €125.9
million. The profit after tax for the 12-month period of 2024 of the Optima bank Group amounts to €140.2
million compared to 103 million in the 12-month period of 2023.
Regulatory indicators
At the end of December 2024, the Bank's total regulatory capital amounted to €559.48 million (€574.2 million
for the Group) while the risk-weighted assets (RWAs) amounted to €3,880.7 million (€3,988.2 million for the
Group) resulting in Optima bank's Total Requirement Capital Ratio of 14.42% (14.40% for the Group),
influenced by the expansion of the Bank's loan and investment portfolio as well as the overall results of this
year. As of 1/1/2025, the CRR III regulatory framework marks a revision of the existing Basel III standards.
The aim of this package is to ensure that EU banks become more resilient to potential future economic shocks,
while contributing to the recovery of the European economy from the COVID-19 pandemic and the transition
towards climate neutrality. The revised framework introduces key amendments to ensure adequate minimum
capital requirements by revising the RWA calculations for credit and operational risk (from 1/1/2025) and
market risk (from 1/1/2026). Optima bank is examining the above impacts on the capital adequacy ratio with
the help of a specialized consultant, a project that is ongoing.
At the Bank level, the liquidity coverage ratio (LCR) stood at 242.14% (against the minimum threshold: 100%)
and the net stable funding ratio (NSFR) stood at 121.57% (against the minimum threshold: 100%) on
31/12/2024.
21
The item "Other Intangibles" includes the recognition of intangible assets attributable to customer relationships and trademarks from
the acquisitions of the subsidiaries Optima Factors and Optima asset management (AEDAK).
27
The regulatory indicators for both the Bank and the Group are summarized in the table below for
both the reference period 31/12/2024 and the corresponding period of the previous year
(31/12/2023):
Bank
Group
31/12/2024*
31/12/2023
31/12/2024*
31/12/2023
CET-1 (%)
14.42%
17.82%
14.40%
17.67%
TRCR (%)
14.42%
17.82%
14.40%
17.67%
LCR (%)
242.14%
242.07%
251.44%
248.88%
NSFR (%)
121.57%
127.99%
124.83%
131.83%
Source: Financial Department Optima bank
*
The amounts have been calculated by including the period profits and the distribution of dividend on the 2024 profits, which is subject
to the approval of the competent bodies.
Conclusion on the going concern
The Board of Directors of the Bank, after taking into account the main business risks related to Optima bank,
which stem mainly from the macroeconomic environment in which Optima bank operates and develops in
conjunction with its strategy, liquidity and capital position, concluded that for the Bank and the Optima bank
Group the principle of going concern does apply.
In addition, for the smooth implementation of its business plan, the Bank's management and its shareholders
are considering the most appropriate options for strengthening its capital base in the short and long term, so
that its regulatory capital and ratios exceed the requirements set by the regulatory authorities.
Employees
Employees are particularly important for Optima bank’s course. The Bank continues to be staffed with the
appropriate staff in order to have the critical mass for the achievement of its operational objectives and to
establish long-term and mutually beneficial cooperation relations with them.
The number of employees of Optima bank on 31/12/2024 amounted to 550 people (575 for the Group),
compared to 500 for the Group and 478 for the Bank on 31/12/2023.
Out of this figure, at Group level, 49% are women and 89% of employees have a higher education and post
graduate diploma.
28
Number of branches / Central services
On 31/12/2024 the Bank operated 29 branches. More specifically, out of the 29 branches, 21 operate in
Athens, 3 in Thessaloniki, 1 branch in Corinth, 1 branch in Larissa, 1 branch in Patras and 2 branches in Crete.
From the point of view of central services, until October 2024, there was no need to lease new space. The
central services remained in the building of 32 Aigialeias Street and on the 4th floor of the Paradise building,
both in the area of Maroussi, Attica.
At the same time, in October 2024, in order to serve the Bank's operational needs, the Bank's competent
bodies decided to lease additional office space in Maroussi, Attica. In particular, additional space was leased
for the transfer of part of the central services to Kifissias Avenue, No 44, on the 3rd floor of the second building
complex Monumental Plaza. The date of beginning of operations of the new office spaces was December 16,
2024.
Share capital
The share capital on 31/12/2024 amounts to €254,521 thousand divided into 73,774,142 shares with voting
rights with a nominal value of €3.45. On 31/12/2024 the bank owned 9,193 own shares.
Number of shares
Company
Group
Issued shares
Own shares
Net number of
shares
Balance 1 January 2023
7,524,840
7,524,840
Decrease of share capital by offsetting losses
(7,524,840)
(7,524,840)
Decrease in the nominal value of a share
while increasing the number of shares
(1 old to 5 new)
37,624,200
37,624,200
Equity increase through conversion of a bond
loan
14,084,435
14,084,435
Capitalisation of profits
985,507
985,507
Share capital increase
21,000,000
21,000,000
Purchases of own shares
(107,972)
(107,972)
Sales of own shares
84,674
84,674
Balance 31 December 2023
73,694,142
(23,298)
73,670,844
Balance 1 January 2024
73,694,142
(23,298)
73,670,844
Capitalisation of profits
80,000
80,000
Purchases of own shares
(302,174)
(302,174)
Sales of own shares
316,279
316,279
Balance 31 December 2024
73,774,142
(9,193)
73,764,949
29
The share capital on January 1st 2023 amounted to €160,279 thousand divided into 7,524,840 shares with
voting rights with a nominal value of €21.30 per share.
In March 2023, by decision of the Extraordinary General Meeting ("EGS"), the share capital was reduced by
offsetting losses of previous years by €30,476 thousand and the nominal value of the share was reduced from
€21.30 to €17,25. After offsetting, the share capital amounted to €129,803 thousand divided into 7,524,840
shares. The same decision of the General Meeting reduced the nominal value of a share (share split) from
€17,25 to €3,45 with a simultaneous increase in the number of shares (1 old to 5 new). As a result, the share
capital amounted to €129,803 thousand divided into 37,624,200 voting shares with a nominal value of €3.45
per share.
In addition, it was decided to convert the Convertible Bond Loan into share capital by €48,591 thousand
divided into 14,084,435 shares with a nominal value of €3.45 and into a premium reserve by €11,409 thousand.
By decision of the Ordinary General Meeting dated 07/6/2023, the share capital of the Bank was increased on
26/7/2023, through the capitalization of part of the profits of the year 2022, amounting to €3,399,999.15 with
the issuance of 985,507 new registered, ordinary, voting shares.
On Friday, September 29, 2023, the share capital increase of Optima bank was successfully completed through
a public offer for the listing of its shares on the Athens Stock Exchange. The final disposal price was €7.2 per
share and the total amount of funds raised was €150.9 million. A total of 21,000,000 new ordinary registered
shares of the Bank were issued.
On 23/05/2024, the Ordinary General Meeting of the Bank decided to increase the share capital (of the Bank)
by the amount of €276,000, by issuing 80,000 new, ordinary, registered shares with voting rights, with a
nominal value of €3.45 each, capitalizing an equal part of undistributed profits for the year 2023. The nominal
share capital of the Bank amounts, after the above share capital increase, to €254,520,789.90 and is divided
into 73,774,142 registered shares, with a nominal value of each share of three euros and forty-five cents
(€3.45). The trading of the new shares on the Athens Stock Exchange started on 20/06/2024.
Important events after 2024
Launch of Optima Leasing
Optima bank, on January 13, 2025, announced the launch of Optima Leasing S.A. Optima Leasing S.A. is a
100% owned leasing subsidiary of the Optima bank Group and offers specialized solutions for growth-oriented
30
businesses and professionals. It is addressed to all sectors of the economy, such as industry, commerce,
transport, tourism, service provision and construction.
Optima Leasing S.A. introduces modern services and leasing products for real estate, movable assets and
equipment for businesses and freelancers, adapted to the Greek market, focusing on the needs and business
objectives of each business. The solutions provided cover investment projects, liquidity enhancement and the
ability to adjust rents to the company's seasonal flows. In addition, active participation in development laws
is covered for the utilization of investment programs that maximize the potential of the business.
Related party transactions
In accordance with the relevant regulatory framework, this report should include the most important related
party transactions. All transactions of related parties are made in the context of normal business activities, are
carried out under market conditions and terms, are approved by the competent bodies and beyond what is
detailed below (note 39 of the financial statements) are not considered significant for the size and results of
the Group.
Risk management
The Group recognizes that the risk management it undertakes in the context of its activities is a strategic tool
of business tactics and philosophy that distinguishes its operation. Therefore, its management has established
a specific Risk Appetite Framework (RAF) and ensures that risk management is carried out within its limits. In
this Policy, the timely identification of risk, its measurement and management methods are compatible with
the Group's strategic choices and are based on day-to-day business decisions.
By carefully monitoring the dynamic nature of the economic and institutional environment in which it operates,
the Group adapts and develops its risk management mechanisms, in terms of organisational structure, policies,
procedures and IT systems, in such a way that these mechanisms remain effective in terms of day-to-day
banking operations, compatible with the principle of independence and functional for internal and institutional
supervision purposes.
Governance
The Risk Management Committee (RMC) of the Board of Directors (BoD) supports the BoD in defining a risk
management strategy, based on the applicable Business Plan and Risk Tolerance Policy.
31
The RMC recommends to the Board of Directors the current and future risk-taking strategy of the institution,
defines the principles that should govern the management of risks in terms of identifying, anticipating,
measuring, monitoring, controlling and addressing them, based on the current business strategy and the
adequacy of available resources.
In addition, the RMC guides the Risk Management Department (hereinafter also referred to as the RMD) in
the implementation of the risk appetite strategy, including compliance with the relevant capital adequacy
regulatory framework, and checks the independence, adequacy and effectiveness of the operation of this
Department.
The RMC shall ensure that the Board of Directors of the Bank is adequately informed of all matters relating to
the risk undertaking strategy, the tolerance level and the risk undertaking level in the performance of its
strategic and regulatory tasks.
Risk tolerance policy
The process of adapting to the evolving institutional environment and the concern to upgrade the functions
that determine the level of risk management (policies, systems, etc.) requires the investment of significant
resources, which the Group uses through transparent evaluation procedures, so that the produced result
corresponds to the intended and the relevant expenditure stays within the framework of the budget.
All risks are defined by the Bank's Risk Tolerance Policy, which (like all policies) has been approved by the
Board of Directors. This Policy distinguishes the levels of maximum risk tolerance, the desired degree of risk
undertaking and its actual level, orienting and coordinating the work of individual units so that it converges in
the direction of management's strategic choices. To serve this objective, the Risk Tolerance Policy provides
for the observance of specific values for an important number of ratios, which reflect the structural image of
all areas of high interest, both for the Bank and for the regulatory authorities (capital adequacy, liquidity, loan
portfolio quality, profitability, etc.). This policy shall be updated on an annual basis and on an ad hoc basis
whenever deemed appropriate.
Credit risk
Credit risk is defined as the potential risk of losses that may arise from the breach of a counterparty's
contractual obligations to the Bank and the Group.
In addition to the credit risk arising from all forms of lending, the Group, as part of its overall credit risk
management, recognises that the following risks are also managed:
32
• Concentration risk
• Counterparty risk
At the lending level, the Bank assesses each credit risk undertaking, determining the creditworthiness of its
customers, both by applying one of the most reliable models of independent credit rating, and by using a
series of techniques and criteria compatible with the current institutional framework. These tools are described
and implemented in the context of the Credit Risk Management Policy, the Credit Policy and the Credit Risk
Management Policy of Institutional Counterparties. In this context, the approval process and the approval
levels are also clearly defined, while the role of the credit committees is clearly delimitated.
Operational risk
Operational Risk (OR) is defined as the risk of losses due to:
• the inadequacy or failure of internal procedures;
• a human factor,
• IT systems, as well as
• external events.
In addition, it includes legal risk, as well as credit or market risk events with operational causes.
The Bank has established appropriate policies and procedures for the management of operational risk. In
addition, the Bank maintains an application for keeping a log of operational risk events. (Operational Loss
Database). In addition, Key Risk Indicators (KRIs) have been set in business units. By monitoring the course
of indicators, mainly in cases of sharp fluctuations, the Risk Management Department monitors the reasons
for the change and, if it identifies operational risks, it sets measures to reduce them. Finally, the Bank uses
the Risk and Control Self Assessment (RCSA) method annually.
Market risk
Market risk is defined as the potential loss that may be caused to the Bank's portfolio by unexpected
fluctuations in market value in individual areas of that portfolio. The portfolios facing this possibility are those
exposed to interest rate and/or monetary and/or price risk.
Through its activity in financial products, the Bank is exposed to market risk, which may cause capital losses
from changes in interest rates, stock/bond prices, equity indices and exchange rates. It therefore seeks to
effectively control market risks arising from all its activities through a risk management framework consisting
of policies, procedures and methodologies for assessment, measurement, monitoring and risk management,
as well as limit structures, which are compatible with the requirements of the regulatory authorities.
33
In view of the effective management of market risk, the Risk Management Department calculates on a daily
basis the Value at Risk (VAR) using the variance-covariance method with a 99% confidence level and a holding
period of one day, and informs the competent units and the Bank’s Management accordingly. Based on the
composition of the portfolios, the methods used for hedging open positions, the day-to-day measurement,
monitoring and analysis of results, as discussed below, it is established that the Bank’s exposure to market
risk is within the tolerance level of undertaking of that risk, which has been determined by the Risk
Management Committee through a well-defined limit framework (RAF).
Liquidity risk
Liquidity risk is defined as a risk for a Bank, albeit solvent, to not have sufficient financial resources to meet
its obligations when they fall due, or to be able to secure them only with high borrowing costs.
The Treasury & Capital Markets Department shall ensure the management of the Bank’s liquidity through
monitoring and management of basic accounts, loan capital and capital market investments, in accordance
with the desired level of risk assumed as determined by the Assets-Liabilities Committee (ALCO) of the Risk
Management Committee and the Board of Directors of the Bank. The Risk Management Department controls
the liquidity of the Bank in relation to the established limits.
Climate and Environmental Risks
The Bank recognizes the importance of risks stemming from environmental factors, in particular climate
change. In line with the EBA guidelines on climate-related and environmental risks, it has started the process
of working on this type of risk along with the integration of the other elements of the ESG (Environmental,
Social, Governance) triptych, which is social and corporate governance.
The bank is aware that ESG factors can affect the organization positively or negatively, while at the same time
increasing compliance requirements add complexity. In addition, ESG risks may have a direct impact on the
operations and/or performance of the Bank, may lead to potential capital needs to address them, and may
have an impact on its reputation.
Climate-related and environmental risks include two key risk determinants:
• Physical hazard: It refers to the financial impact of climate change, including more frequent extreme
weather events and gradual changes in climate, as well as environmental degradation. Classified as:
• Acute: when it stems from specific extreme events, in particular weather-related events such as
droughts, storms, floods, fires or heatwaves;
34
• Chronic: when it stems from progressive long-term climate changes, such as temperature changes,
sea level rise, reduced water availability, biodiversity loss, changes in soil productivity and resource
scarcity.
• Transitional: It refers to the financial loss that can occur, directly or indirectly, from the process of
adaptation to a more environmentally sustainable economy.
In line with regulatory guidelines, the bank recognizes that climate-related and environmental risks directly
affect other key risks to which it is exposed, such as credit, market, operational and liquidity risks. Indicatively,
the following should be mentioned:
• Credit risk: Default probabilities and loss in case of default regarding exposures within sectors or
geographical areas vulnerable to physical risk may be affected, for example, through lower
collateral valuations in real estate portfolios due to increased flood risk;
• Market risk: Severe natural events may lead to changes in market expectations and could result
in a sharp repricing, an increase in volatility and a decrease in the value of assets in some markets;
• Operational risk: The activities of the institution may be disrupted by a natural disaster at its
premises, branches and data centres due to extreme weather events.
• Liquidity risk: Liquidity risk may occur if customers withdraw money from their accounts to fund
damage repairs.
The liability risks of institutions’ counterparties can arise not only from environmental and climate-related risks,
but also from social and governance factors. The latter concern the following:
• Social Responsibility: It is the impact and relationship of a business or investment with
stakeholders such as people and communities. The impact and consequences on labour practices,
human rights, diversity and social inclusion;
• Corporate Governance: It relates to how an organisation is run and managed in relation to risk
management, sustainability opportunities, leadership and transparency.
At this stage, the bank, assessing credit risk as the most significant risk that can be directly affected by climate
change, initially conducted a materiality assessment to identify the sectors of the economy where its
outstanding loan balances are most sensitive to climate-related and environmental risks, taking into account
both physical and transitional risks.
35
The Bank also estimates that the market risk arising from the implementation of climate risk
policies/regulations is insignificant, since most of the securities included in its liquidity buffer are
Greek/sovereign bonds and its exposure to corporate bonds is insignificant.
Other risks
At regular intervals, as specified in the Risk Appetite Framework, the Bank calculates and monitors risk
tolerance indicators based on financial results and confirms that it operates in accordance with the risk levels
provided for by the Board of Directors. If a breach of one of the indicators is observed, the activity that burdens
the indicator is identified and appropriate actions are applied to bring the risk back to acceptable levels. It is
worth noting that the RMD under the supervision of the RMC has launched an extensive programme to meet
the requirements of Regulation (EU) 2024/1623 31.05.2024 (CRR 3). In addition, in the context of the
implementation of Regulation (EU) 2022/2554, in cooperation with the competent units, a programme has
been launched to meet its requirements, as well.
The relevant regulatory reports shall summarise and systematise the risk management framework, in all its
aspects. Financial risk management is described in detail in note 4 to the Financial Statements and
Consolidated Financial Statements 31.12.2024.
Outlook |2025
Global economy
The global economy proved to be more resilient than expected in 2024 as it faced successive crises such as
the most severe pandemic of the last century, wars and extreme weather events. Since 2020, monetary
authorities and governments have taken important measures to address public health, energy and supply
chain crises. The immediate effects of the crises were mitigated, but the effects on income, prices and the
public economy remained.
Global GDP growth, although estimated to have decelerated marginally in 2024 to 3.2%, from 3.3% in 2023,
continues to be at satisfactory levels. For 2025 it is estimated to remain stable at 3.2%. There is, however,
considerable disparity between the major economies. Advanced economies are estimated to have accelerated,
while emerging and developing economies have slowed down. According to IMF estimates, growth in 2024 in
advanced economies is projected to increase slightly to 1.8%, from 1.7% in 2023, and is expected to remain
at this level also in 2025. The US economy slowed down less than expected, the UK recovery was stronger
than forecast, the euro area economy showed signs of recovery and Japan’s economy slowed down
considerably. As regards emerging and developing economies, GDP growth is projected by the IMF to slow to
4.2% in 2024, from 4.4% in 2023, and is expected to remain at this level also in 2025, mainly due to lower
36
growth rates in China and India. In China, the economic slowdown is projected to continue into 2025, mainly
due to weaker private consumption
22
.
Global inflation continued to decline in the course of 2024, mainly on account of a tightening monetary policy
and the gradual unwinding of the impact of the energy crisis on aggregate supply. Advanced economies
experienced a larger decline in price growth despite a marginal pick-up in their growth rate, while inflation
declined more slowly, driven by services inflation, which remains high in several major economies. Global
inflation is expected to decline to 5.8% in 2024 and 4.3% in 2025 from 6.7% in 2023. Its de-escalation will
be faster in advanced economies because of monetary policy's determination to fight inflation
23
.
Risks to growth and inflation in the global and European economies remain severe and are likely to continue
to have a negative impact on economic activity in 2025. In particular, heightened geopolitical uncertainty (the
war in Ukraine and the conflicts in the Middle East), geo-economic fragmentation and the eventual
strengthening of trade protectionism may lead to a renewed increase in import prices, harming international
trade and investment and undermining the productivity and resilience of economies in the long term. In
addition, extreme weather events and climate change in general could lead to higher food prices. Rising real
interest rates as well as the deflationary effort may have a larger than projected impact on employment and
growth. Serious challenges for the economic policy of most economies are a return to fiscal stability to ensure
the sustainability of public finances, and the build-up of sufficient reserves to address potential risks in the
future. Mainly for the EU, major challenges will be implementing structural reforms and boosting investment
in research and innovation to tackle low productivity growth and increase competitiveness. In contrast to the
above risks, a gradual increase in real incomes may have a positive impact, as it will contribute to strengthening
consumer confidence and private consumption.
Greek economy
According to the Bank of Greece’s current forecast,
GDP growth in 2024 is expected to be 2.2%, to accelerate
in 2025 to 2.5% and to decline slightly to 2.3% in 2026. According to the same source, inflation will continue
to decline and is expected to stand at 2.9% in 2024, 2.2% in 2025 and 2.1% in 2026
23
.
In the Greek economy, risks to growth are mainly on the downside. In particular, risks to the prospects of the
Greek economy according to the forecasts of the Bank of Greece are: any worsening of the geopolitical crisis
in Ukraine and the Middle East and the resulting impact on the international economic environment, (b) the
22
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
23
Source: Monetary Policy - Interim Report 2024, (December 2024), Bank of Greece
37
lower than expected rate of absorption and utilisation of the Recovery and Resilience Facility funds, (c) the
delay in the implementation of reforms, which would slow down the process of enhancing the productivity of
the economy and the competitiveness of businesses, (d) extreme weather events (floods and fires, as
happened in 2023), (e) the strengthening of trade protectionism internationally, and (f) labour market
tightness and possible wage pressures. In the near future, risks to public debt sustainability appear to be
contained, provided that fiscal targets are met and European funds are used efficiently. In the longer term,
however, uncertainty is estimated to remain increased, as the gradual refinancing of debt obligations will
increase the exposure of the Greek State to interest rate risk and market risk, which reduces the scope for
fiscal easing.
For 2025, Optima bank aims to continue the successful course of the previous years, having as a guide the
prospects of the market in which it operates, but mainly its business plan for the period 2025-2027. Optima
bank's main strategic objectives continue to be to increase business volumes, strengthen market shares,
increase revenues through the utilization of all alternative channels of customer outreach, find new sources of
revenue, rigorously control operating costs, with the aim of further enhancing profitability and increasing
shareholder value.
Optima bank's management constantly assesses the macroeconomic environment in which it operates in order
to achieve its goals in the long term.
Maroussi, 20 March 2025
FOR THE BOARD OF DIRECTORS
The Chairman of the
Board of Directors
The Chief Executive Officer
Georgios Taniskidis
Dimitrios Kyparissis
38
Statement of Corporate Governance
1. Introduction
In accordance with Article 152(1) and Article 153(3) of Law 4548/2018, Law 4706/2020 and the Greek
Corporate Governance Code, the Annual Management Report of the Board of Directors of "Optima bank S.A."
(hereinafter the "Bank") includes the Corporate Governance Statement for the fiscal year 01.01.2024-
31.12.2024. The reference date of the Statement is December 31, 2024 (hereinafter referred to as the
‘Reporting Date’).
This Consolidated Corporate Governance Statement concerns the Bank and the companies in which the Bank
participates directly or indirectly and which are included in its consolidated financial statements as defined in
IFRS 10 "Consolidated Financial Statements", and includes the Bank itself (hereinafter the "Group").
The information required under Article 4(7)(c), (d), (e), (g) and (h) of Law 3556/2007 shall be set out in detail
in the Annual Management Report of the Board of Directors.
2. Overview | 2024
During 2024, inter alia, the following events related to corporate governance took place:
❖ the granting of a license for the establishment and operation of a leasing company under Law
1665/1986, a wholly owned subsidiary of the Bank, under the name "Optima Leasing Single-member
Société Anonyme" and the distinctive title "Optima Leasing S.A."
❖ The extension of the number of members of the Board of Directors of the Bank from ten (10) to eleven
(11), with the election and addition of Mr Nikolaos Giannakakis as a Non-Executive Member whose
term of office will expire at the same time as the term of office of its other Members, and therefore
the reconstitution of the Board of Directors.
❖ The amendment of the Bank's Articles of Association following the increase of the Bank's share capital
through the capitalization of part of the profits of the year 2023 and the free allocation of the new
shares issued to the Chairman and the Executive Members of the Board of Directors (excluding the
Independent Non-Executive Members) as well as to the Bank's senior management (Executive
Committee Members), in accordance with the provisions of article 114 of Law 4548/2018 through a
Share Free Allocation Program.
39
❖ The approval of the Program for the free distribution of shares to members of the Board of Directors
and staff, in accordance with the provisions of Article 114 of Law 4548/2018, through the capitalization
of profits for the year 2023.
❖ The amendment of the Adequacy Policy of the members of the Board of Directors of the Bank.
❖ The amendment of the Bank's Staff Remuneration Policy.
❖ The establishment of an operational Sustainable Development Management Committee and the
approval of its Rules of Procedure.
❖ The resignation of the member of the Board of Directors, Ms Clio Lymberi, and the reconstitution of
the Board of Directors with the other Members, without the replacement of the resigned member
temporarily, in accordance with Article 10(2) of the Bank’s Articles of Association.
❖ The reconstitution of the Committees of the Board of Directors of the Bank, i.e. the Audit Committee,
the Risk Management Committee and the Remuneration and Nominations Committee, following the
resignation of Ms Clio Lyberi, acting Chair of the Risk Management Committee and Member of the
Audit Committee and Remuneration and Nominations Committee of the Bank.
❖ Approval of the revised Rules of Procedure of the Audit Committee.
❖ Approval of the revised Rules of Procedure of the Risk Management Committee.
❖ The approval and submission to the Bank of Greece of the revised Action Plan (ESG Roadmap) for the
gradual integration of the first four out of the thirteen expectations included in a guidance document
of the Single Supervisory Mechanism (SSM) for the effective management of ESG risks, which credit
institutions are required to implement in order to meet the objectives set in the Paris Agreement with
the United Nations Framework Convention on Climate Change.
❖ Informative presentation – training for the members of the Board of Directors on ESG issues.
3. General meeting of shareholders
In accordance with Article 116 of Law 4548/2018 and Article 22 of the Bank's Articles of Association, as last
amended by the resolution of the Ordinary General Meeting of the Bank's shareholders of 23.05.2024 and
posted on the Bank's website
(https://www.optimabank.gr/media/mqrfsf4i/katastatiko_optima_bank_tgs_230524_akrives_antigrafo_gemi.
pdf ), the Bank's supreme body is the General Meeting of its Shareholders.
The General Meeting has the exclusive responsibility to decide on the following matters:
(a) to amend the Articles of Association, including to increase or reduce the share capital;
(b) to elect the members of the Board of Directors and the auditors;
(c) to approve the overall management in accordance with the legislation in force and the discharge of auditors,
(d) to approve the annual and any consolidated financial statements of the Bank;
40
(e) to dispose of annual profits;
(f) to approve the remuneration or advance payment pursuant to Article 109 of Law 4548/2018 and approve
the remuneration policy pursuant to Article 110 et seq. of Law 4548/2018;
(g) to decide on a merger, division, conversion, revival, extension of the duration or dissolution of the Bank;
(h) to appoint the liquidators; and
(i) to decide on any other matter provided for by law or by these Articles of Association.
The procedures and rules of convening, participation and decision-making by the General Meeting, its
responsibilities as well as the rights of shareholders at the General Meetings of the Bank are regulated in detail
by the provisions of the Bank's Articles of Association, as in force from time to time and Law 4548/2018.
2024 General Meetings
During 2024, the General Meeting convened once, in ordinary session on May 23, 2024, in which shareholders
representing 68.29% of the Bank's share capital participated either in person or through a proxy, with the
following agenda items for which the following decisions were taken:
S/N
AGENDA ISSUES
DECISIONS
VOTING RESULTS
1
Submission and
approval of the Annual
Financial Report (Bank
& Group) in
accordance with the
International Financial
Reporting Standards
for the fiscal year
01.01.2023 to
31.12.2023, following
the relevant Reports of
the Board of Directors
and the Certified Public
Accountants.
The General Meeting approved the Annual Financial
Report of the Bank and the Group for the fiscal year
01.01.2023 until 31.12.2023, following the relevant
Reports and Statements of the Board of Directors
and the Audit Report of the Certified Public
Accountant.
IN FAVOR: 99.96%
AGAINST: 0.04%
ABSTENTION: -
2
Approval of the overall
management that took
place during the
financial year
01.01.2023 –
31.12.2023, in
accordance with Article
108 of Law 4548/2018
and discharge of the
Certified Public
Accountants for the
same financial year, in
accordance with Article
117 of Law 4548/2018.
The General Meeting approved the overall
management carried out by the Board of Directors
during the fiscal year 2023 and the discharge of the
Certified Public Accountants of the Bank from any
liability for the activities of that fiscal year.
IN FAVOR: 99.96%
AGAINST: 0.04%
ABSTENTION: -
41
S/N
AGENDA ISSUES
DECISIONS
VOTING RESULTS
3
Election of Certified
Public Accountants for
the audit of the
Financial Statements
for the fiscal year
2024.
The General Meeting decided to assign the regular
audit of the Bank's annual financial statements for
the fiscal year 2024, the tax audit for the same fiscal
year as well as the reports of pre-agreed procedures
for the remuneration report of the members of the
Board of Directors, the Hellenic Deposit and
Investment Guarantee Fund (TEKE) and the
Guarantee Fund to the company of Certified Public
Accountants "DELOITTE SOCIETE ANONYME OF
CERTIFIED AUDITORS ACCOUNTANTS", which is
based in Maroussi, Attica, 3a Fragokklissia str. &
Granikou, with No. G.E.MI. 001223601000, Tax
Identification Number 094394788, SOEL Reg. No:
E120, for a total fee of EUR 390 000.00 plus VAT,
broken down as follows:
➢ € 287,000 for the regular audit of the
financial year 2024,
➢ €78 000 for the tax audit for the period
01.01.2024 to 31.12.2024,
➢ € 15,000 for the remuneration report of the
members of the Board of Directors as well
as
➢ €10,000 for the pre-agreed procedure
reports for TEKE and the Guarantee Fund.
After consultation of the Bank with the said auditing
company, the Ordinary Auditor and the Alternate
Auditor of the Bank will be appointed. Furthermore,
the General Meeting authorised the Board of
Directors of the Bank to negotiate with the audit firm
any deviations from the above mentioned
remuneration relating to any additional audit work
that may be required and to send the written
notice/order to the selected audit firm within five (5)
days from the date of its selection.
FOR: 100%
AGAINST: -
ABSTENTION: -
4
Approval of distribution
of profits and
distribution of dividend
for the year 2023.
The General Meeting approved the distribution of
profits for the year 2023 up to the total amount of
€ 38,175,422.48, for the distribution of dividend for
the year 2023 amounting to € 0.44 per share and
for the purposes set for discussion and voting under
items 10 and 11 of the Agenda below. It also
decided that the total cost to be borne by the Bank
for items 10 and 11 of the Agenda should not
exceed a total of €5,750,000.
For the distribution of dividends, the General
Meeting approved the dates of the ex-dividend right,
the identification of the beneficiaries of the dividend
and the start of the payment of the dividend for the
fiscal year 2023 as follows:
i. Ex-dividend entitlement date: Tuesday,
June 25, 2024
IN FAVOR: 100%
AGAINST: -
ABSTENTION: -
42
S/N
AGENDA ISSUES
DECISIONS
VOTING RESULTS
ii. Date of identification of dividend
beneficiaries: Wednesday, June 26, 2024
iii. Dividend payment start date: Monday, July
1
st
2024.
The payment of the dividend for the financial year
2023 must be made through the Bank itself, acting
as the paying bank. Finally, the General Meeting
authorized the Board of Directors to take any
necessary or appropriate action in the context of the
implementation of the present decision of the
Ordinary General Meeting.
5
Decision to extend the
number of members of
the current Board of
Directors of the Bank
from ten (10) to eleven
(11), with the election
and addition of a new
Member, whose term
of office will expire at
the same time as the
term of office of its
other Members.
The General Meeting approved the election and
addition of Mr. Nikolaos Giannakakis to the Board of
Directors of the Bank as a Non-Executive Member,
for the remainder of the term of office of the current
Board of Directors elected by the Ordinary General
Meeting of Shareholders on 23.03.2023, i.e. by 10
September 2027 at the latest.
IN FAVOR: 91.38%
AGAINST: 8.62%
ABSTENTION: -
6
Submission of the
Audit Committee’s
activity report for
2023, in accordance
with Article 44(1),
point Law 4449/2017.
The BoD took note of the Audit Committee’s activity
report for 2023, in accordance with Article 44(1),
point (ι). Law 4449/2017.
WITHOUT VOTE
7
Submission of the
Report of the
independent non-
executive members of
the Board of Directors
in accordance with
Article 9(5) of Law
4706/2020.
The BoD took note of the Report of the independent
non-executive members of the Board of Directors in
accordance with Article 9(5) of Law 4706/2020.
WITHOUT VOTE
8
Submission for
discussion of the
Remuneration Report
for the financial year
2023, in accordance
with Article 112 of Law
4548/2018.
The BoD voted in favor on the Remuneration Report
for the financial year 2023, in accordance with
Article 112 of Law 4548/2018, without expressing
any comment or remark on its content.
IN FAVOR: 93.47%
AGAINST: 6.53%
ABSTENTION: -
9
Approval of the fees of
the Members of the
Board of Directors for
the year 2023 and
determination of the
amount of these fees
through participation in
The BoD decided to approve the fees and expenses
in general and any kind of compensation paid to the
members of the Board of Directors for the period
01.01.2023 to 31.12.2023 and to determine the
amount and pre-approve these fees for the year
2024 and until the Annual General Meeting for the
year 2025, in accordance with the relevant
IN FAVOR: 94.58%
AGAINST: 5.42%
ABSTENTION: -
43
S/N
AGENDA ISSUES
DECISIONS
VOTING RESULTS
the profits for the year
2024 until the Annual
General Meeting for
the year 2025, in
accordance with the
provisions of article
109 of Law 4548/2018.
recommendation of the Board of Directors, which
the General Meeting accepted and approved in full.
10
Free distribution of
shares to members of
the Board of Directors
and staff, in
accordance with the
provisions of article
114 of Law 4548/2018,
through capitalization
of profits for the year
2023 (Program of Free
distribution of shares).
Corresponding
amendment to Article 5
of the Bank's Articles of
Association.
(a) The BoD approved the relevant recommendation
of the Remuneration and Nominations Committee of
the Bank and decided the free distribution of shares
of the Bank through capitalization of part of the
profits of the year 2023, up to the amount of €
1,035,000.00, with an equal share capital increase,
divided by the amount of the increase, to up to
300,000 new registered, common, voting, shares,
with a nominal value of each share of € 3.45 (the
"New Shares"), in order for the New Shares to be
distributed free of charge, under the conditions of
the Law, to the Chairman and the executive
members of the Board of Directors (excluding the
Independent Non-Executive Members) as well as to
the senior management of the Bank (Executive
Committee Members) ("Beneficiaries"), in
accordance with the provisions of Article 114 of Law
4548/2018, as in force and subject to the receipt of
the relevant approvals from the competent
regulatory authorities. Specifically, it approved a
free share allocation program in accordance with
Article 114 of Law 4548/2018 with the following
features:
Number and class of shares available: up to 300,000
new registered, common, voting, shares, with a
nominal value of each share of €3.45.
Origin of the shares available: capitalization of part
of the profits for the year 2023 up to the amount of
€ 1,035,000.00, with an equal share capital
increase.
Beneficiaries / Categories of Beneficiaries:
Chairman, Executive Members of the Board of
Directors, senior executives of the Bank (Executive
Committee Members), as follows:
a) Chairman: up to 45,000 shares
b) Executive Members of the Board of Directors:
(ba) Managing Director: up to 5,000 shares,
(bb) Executive Member of the BoD/CFO: up to 3,000
shares
c) Senior Management of the Bank (Executive
Committee Members): up to 3,000 shares each.
Specifically with regard to the Chairman of the Bank,
in accordance with Article 86 of Law 4261/2014, it
approved a higher than 100% maximum ratio
between the fixed and variable components of
IN FAVOR: 91.03%
AGAINST: 8.97%
ABSTENTION: -
44
S/N
AGENDA ISSUES
DECISIONS
VOTING RESULTS
his/her remuneration, amounting to two hundred
percent (200%).
(b) Consequently, due to the share capital increase
with capitalization of profits, for the purpose of
offering free shares in accordance with Article 114
of Law 4548/2018, the BoD decided to amend
Article 5 on share capital (amendment of paragraph
1 and addition of paragraph 1.13) of the Bank's
Articles of Association.
(c) The BoD authorized and instructed the Board of
Directors to take all necessary actions to increase
the share capital by capitalization of profits, up to
the amount of € 1,035,000,00, to draft the new text
of the Bank's Articles of Association and to
determine the specific terms for the free distribution
of shares to the Beneficiaries, in accordance with
the Law and the applicable Remuneration Policy of
the Bank's Board of Directors Members and
Personnel, respectively.
11
Distribution of part of
the profits for the year
2023, as a one-off
special fee (Bonus) due
to the achievement of
objectives to members
of the Board of
Directors and staff of
the Bank – Provision of
authorisations.
Following the decision taken on the 4th item of the
Agenda, the BoD approved the distribution of part
of the net profits of the year 2023 as a one-off
extraordinary remuneration (Bonus) of a total
amount of up to Euro 4,000,000.00 to members of
the Board of Directors (excluding independent non-
executive members) and the Bank's staff, as a
reward for their contribution to the achievement of
the Bank's profitability and objectives during the
year 2023 and granted the relevant authorisations
to the Board of Directors to determine the specific
terms of allocation of the above amounts and to deal
with the procedural issues for the payment of the
extraordinary remuneration (Bonus).
IN FAVOR: 94.47%
AGAINST: 5.53%
ABSTENTION: -
12
Approval of the
amendment of the
Adequacy Policy of the
Members of the Board
of Directors.
The BoD approved the amendment of the Adequacy
Policy of the members of the Board of Directors of
the Bank.
IN FAVOR: 95.31%
AGAINST: 4.69%
ABSTENTION: -
13
Update of the Bank's
Remuneration Policy.
The BoD approved the amendment of the Bank's
Staff Remuneration Policy.
IN FAVOR: 87.76%
AGAINST: 12.24%
ABSTENTION: -
14
Other matters -
Miscellaneous
There were no other issues or announcements.
WITHOUT VOTE
45
4. Shareholders
The shareholding structure of the Bank (for descriptive, non-regulatory purposes) was as follows at the
Reporting Date:
5. Administrative, Management and Regulatory Bodies and Senior Management
In accordance with Article 9 of the Bank's Articles of Association and Article 77(1) of Law 4548/2018, the Bank
is governed by the Board of Directors.
The Bank’s Administrative, Management and Regulatory Bodies are the Board of Directors and its committees
(i.e. the Remuneration and Nominations Committee, the Audit Committee and the Risk Management
Committee), the Executive Committee and the Head of the Internal Audit Department, Ms Aphrodite Samara.
In addition, all members of the Executive Committee are members of the senior management of the Bank.
Implementation of an institutional framework for corporate governance
The Bank has adopted and complies with the legal framework on corporate governance of companies with
securities listed on a Regulated Market as well as credit institutions in accordance with Law 4261/2014, Law
4706/2020 and Article 44 of Law 4449/2017 as in force for the Audit Committee, and the delegated acts and
decisions of the competent authorities. In this context, the Bank has adopted the Greek Corporate Governance
Canelo Holdings Limited and
Baynoun Cyprus 7.3%
Private individuals
57.9%
Institutional
Investors 25.8%
Ireon Investments
LTD 8.9%
Shareholders' Composition 31.12.2024
46
Code for listed companies drawn up by the Hellenic Corporate Governance Council (HCGC) as published in
June 2021 and meets the requirements of the applicable regulatory framework as the HCGC has been
recognised as a body of recognised prestige in accordance with Article 17 of Law 4706/2020 and Decision
2/905/3.3.2021 of the Board of Directors of the Hellenic Capital Market Commission. The above Corporate
Governance Code is posted on the Bank's website
(http://www.optimabank.gr/media/0ehjz5zv/esed_kodikas_etairikis_diakybernisis_2021.pdf).
In addition, the Bank features the Rules of Procedure, in accordance with the provisions of Article 14 of Law
4706/2020. A summary of the Bank's Rules of Procedure is posted on the Bank's website
(https://www.optimabank.gr/media/2w1hv32k/c33_kanonismos_leitoyrgias_perilipsi.pdf). The Bank's Rules
of Procedure include, in accordance with par. 3 of the same article, the organisational structure, the objects
of the units and committees operating in the Bank, as well as the duties of their heads and their reporting
lines, the description of the main features of the internal audit system, including the operation of the Internal
Audit Department, the Risk Management Department and the Regulatory Compliance Department, as well as
all the policies and procedures referred to in paragraph 3 of article 14 of Law 4706/2020. In addition, the
Rules of Procedure include the Policy and Procedure with adequate and effective mechanisms for
communication with shareholders, in order to facilitate the exercise of their rights and the active dialogue with
them (shareholder engagement), which has been drafted in accordance with article 13 par. 1 (b) of Law
4706/2020, as well as the procedure for the evaluation of the Bank's corporate governance system prepared
in accordance with Article 4 of Law 4706/2020. By virtue of the decision of the Board of Directors of the Bank
dated 16.01.2025, the Bank has already adopted a Sustainable Development Policy, which is included in the
Rules of Procedure. At the same meeting of the Board of Directors, the updated Rules of Procedure of the
Bank were approved following the incorporation of the Sustainable Development Policy and the amendment
of the following procedures that form part of the Rules of Procedure:
1) the compliance procedure for persons exercising managerial responsibilities and persons with close links to
them, as defined in points 25 and 26, respectively, of Article 3(1) of Regulation (EU) No 596/2014, which
include the obligations arising from the provisions of Article 19 of Regulation (EU) No 596/2014; and
2) the procedure for managing inside information and properly informing the public.
It is noted that according to the assessment carried out by the Board of Directors at its meeting of 20.03.2025
on the basis of the financial data of the subsidiaries at the Reporting Date, it was found that no subsidiary is
considered to be a Significant Subsidiary, in accordance with Article 2 of Law 4706/2020
The Bank features an Internal Audit Department headed by Mrs. Aphrodite Samaras, appointed by the
11.04.2013 decision of the Bank's Board of Directors, a Regulatory Compliance Department headed by Mr.
Alexandros Diolis as appointed pursuant to the decision of the Board of Directors of the Bank dated 10.08.2023,
47
as well as the Risk Management Department, headed by Mr. Sotirios Papakonstantinou, as appointed by the
decision of the Board of Directors of the Bank dated 30.06.2022. At the same time, the Bank also features an
Investor Relations, Shareholder and Corporate Communications Section, headed by Mr Konstantinos Vatousis,
appointed by decision of the Bank's Board of Directors of 16 May 2023 as the person responsible for
communicating with shareholders and investors, and whose details are posted on the Bank's website
(http://www.optimabank.gr/en/about-us/investor-relations).
Finally, by virtue of the resolution of the Extraordinary General Meeting of Shareholders dated 22.03.2023,
the Bank has approved and has since then implemented a Remuneration Policy for the Members of its Board
of Directors, with a four-year validity period, which is subject to periodic reassessment for updating purposes
in accordance with the applicable regulatory framework. Similarly, it has adopted and applies an Adequacy
Policy for the Members of the Board of Directors, which has been drawn up and updated in accordance with
the provisions of: a) Article 3 of Law 4706/2020 and the guidelines of the Hellenic Capital Market Commission
(Circular No. 60/18.9.2020), b) it was updated in the Act of the Executive Committee of the Bank of Greece
No. 224/1/21.12.2023 on the procedure for the adequacy assessment for the position of a member of the
Board of Directors and Head of Critical Functions and c) the Joint Guidelines of the European Banking Authority
and the European Securities and Markets Authority on the adequacy assessment of members of the
management body and key function holders in accordance with Directive 2013/36/EU and Directive
2014/65/EU (EBA/GL/2021/06), Law 4261/2014. The policies can be found on the Bank's website
(http://www.optimabank.gr/about-us/corporate-governance/principles).
The Bank maintains the following documents posted on the website (https://www.optimabank.gr/about-
us/corporate-governance/principles), in accordance with the provisions of Law 4706/2020: the current Articles
of Association, the Remuneration Policy and the Adequacy Policy of the Members of the Board of Directors,
the Rules of Procedure of its Committees, a summary of its Rules of Procedure, the CVs of the members of
the Board of Directors of the Bank, as well as the contact details of the Head of the Investor Relations,
Shareholder and Corporate Communications Section for communication with the Bank's shareholders and
investors.
Board of Directors
Composition and functioning of the Board of Directors
According to the Bank's Articles of Association (Article 9), the Bank is governed by a Board of Directors
consisting of three (3) to fifteen (15) members. The Board of Directors consists of executive, non-executive,
and independent non-executive members, in accordance with Law 4706/2020 on corporate governance, as in
force. The status of the members of the Board of Directors as executive or non-executive is defined by the
48
Board of Directors. The independent non-executive members are elected by the General Meeting of the Bank's
shareholders or appointed by the Board of Directors, in accordance with Article 9(4) of Law 4706/2020, as in
force, they must not be less than one third (1/3) of the total number of members of the Board of Directors
and, in any case, they may not be less than two (2). In case of a fraction, it shall be rounded to the nearest
whole number.
The members of the Board of Directors are elected for a four-year term, which starts from their election and
ends with the election of a new Board of Directors by the ordinary General Meeting that meets in the year of
the end of their term. The term of office may not be extended beyond five (5) years.
The Board of Directors of the Bank was elected by the decision of the Extraordinary General Meeting of
22.03.2023, with a four-year term, ending with the election of the new Board of Directors by the Ordinary
General Meeting in the year of the end of their term (i.e. until 10.09.2027) and was constituted as a body by
its decision of 23.03.2023. Pursuant to the decision of the Ordinary General Meeting of May, 23, 2024, the
number of members of the Board of Directors of the Bank was extended from ten (10) to eleven (11), with
the election and addition of Mr Nikolaos Giannakakis as a Non-Executive Member, for the remainder of the
term of the Board of Directors elected by the Ordinary General Meeting of Shareholders on March, 23, 2023,
i.e. by 10 September 2027 at the latest, and the Board of Directors was reconstituted as a body by its decision
of May, 27, 2024. On 31.10.2024, Ms. Clio Lymberi resigned from her position as Independent Non-Executive
Member of the Board of Directors of the Bank, as well as from her positions as Chairman of the Risk
Management Committee and member of the Audit Committee and the Remuneration and Nominations
Committee. Following this, the Board of Directors of the Bank, at its meeting of 08.11.2024, decided, pursuant
to Article 82 of Law 4548/2018 and Article 10(2) of the Bank's Articles of Association, to continue the
management and representation of the Bank, without the temporary replacement of Ms. K. Lyberi, until her
replacement by a new member of the Board of Directors, who will meet the criteria of individual and collective
adequacy, in accordance with the applicable legislation and the Adequacy Policy of the Members of the Board
of Directors of the Bank and was reconstituted as a body with its other Members. Therefore, on the Reporting
Date, the Board of Directors of the Bank consisted of ten (10) members, namely eight (8) non-executive
members, of which four (4) are independent non-executive members, and two (2) executive members.
The Remuneration and Nominations Committee of the Bank, having completed the steps to identify a person
suitable for acquiring the status of member of the Board of Directors of the Bank in replacement of the
resigning member Ms. Klio Lymberis at its meeting of 18.02.2025, nominated Ms. Ioanna Zour as candidate
for the position of Independent Non-Executive Member of the Board of Directors of the Bank. Subsequently,
the Board of Directors of the Bank at its meeting of March 20,2025 elected Ms. Ioanna Zour as Independent
Non-Executive Member of the Board of Directors in replacement of the resigned member and was reconstituted
into a body and now consists of eleven (11) members, namely nine (9) non-executive members, of which five
49
(5) are independent non-executive members, and two (2) executive members. In the person of Mrs. Ioanna
Zour, the independence criteria are met, as well as the conditions of individual and collective suitability, in the
context of the application of the provisions of Article 9 of Law 4706/2020, the Act of the Executive Committee
of the Bank of Greece No. 224/1/21.12.2023 and the Policy of Adequacy of the members of the Board of
Directors of the Bank. The election of the new Independent Non-Executive member of the Board of Directors
will be announced at the next General Meeting of the Bank's Shareholders.
Consequently, the current Board of Directors of the Bank consists of the following Members:
Νame and surname
Position on the Board of
Directors
Status
Georgios Taniskidis, father’s name
Ioannis
Chairman
Non-Executive Member
Petros Tzannetakis, father’s name
Tzanibeis
Vice-Chairman
Non-Executive Member
Dimitrios Kyparissis, father’s name
Apostolos
Chief Executive Officer
Executive Member
Angelos Sapranidis, father’s name
Nikolaos
Member
Executive Member
Theophanis Voutsaras, father’s name
Christos
Member
Non-Executive Member
Nikolaos Giannakakis, father’s name
Constantinos
Member
Non-Executive Member
Theodoros Efthis, father’s name Ilias
Member
Independent Non-Executive
Member
Ioanna Zour, father’s name Christos
Member
Independent Non-Executive
Member
Pavlos Kanellopoulos, father’s name
Dimitrios
Member
Independent Non-Executive
Member
Georgia Kontogianni, father’s name
Vasileios
Member
Independent Non-Executive
Member
Georgios Kyriakos, father’s name
Konstantinos
Member
Independent Non-Executive
Member
According to article 13(2) of the Bank's Articles of Association, the Chairman, when absent or impeded, is
replaced by the Vice-Chairman and in the event that more than one are elected, by one of them, according to
a decision of the Board of Directors. In the event of absence or impediment of the Vice-Chairmen, the Chairman
shall be replaced by another member of the Board of Directors appointed by it.
The Independent Non-Executive Members of the Board of Directors met on the date of their election and
continue to meet the independence requirements of Article 9 of Law 4706/2020. Two (2) women participate
in the Board of Directors of the Bank, i.e. a percentage corresponding to 25% of its total members, after
rounding, in accordance with Article 3(1)(b) of Law 4706/2020.
50
Furthermore, it is noted that the above composition of the Board of Directors is in accordance with the
provisions of the Adequacy Policy of the members of the Board of Directors, which was amended in
accordance with the provisions of Article 3(1) of Law 4706/2020, with the decision of the Board of Directors
of 30.04.2024 and submitted for approval to the Ordinary General Meeting of the Shareholders of 23.05.2024
in accordance with Article 3(3) of the same Law and is available on the Bank's website
(https://www.optimabank.gr/media/troekoet/p56_politiki_katallilothtas_melon_ds_optima_bank.pdf). In
addition, the CVs of the members of the Board of Directors are posted on the Bank's website,
http://www.optimabank.gr/en/about-us/corporate-governance/board-of-directors.
The Board of Directors exercises its responsibilities in accordance with the Bank's Articles of Association, the
provisions of Law 4548/2018, Law 4261/2014 and Law 4706/2020 and the relevant national legislation in
general, the Bank's Rules of Procedure and the Board of Directors' Rules of Procedure.
The CVs of the members of the Board of Directors are as follows:
- Georgios Taniskidis, Chairman of the Board of Directors, Non-Executive Member: With 30
years of experience in banking, Georgios Taniskidis holds the position of Optima bank’s Chairman
since July 2019. He began his career as a lawyer at Rogers & Wells Law Firm in New York City.
Returning to Greece, he joined Motor Oil Hellas. His career in banking began in 1990 at Xiosbank, as
Head of Consumer Business Group and Branch Network. Following the acquisition of Xiosbank (end of
1998) by Piraeus Bank, Mr. Taniskidis took over the position of General Manager and participated in
the Strategic Planning Committee. From 2002 to June 2010, in his capacity as Chairman and CEO of
Millennium bank Greece, Mr. Taniskidis led the Bank to the achievement of its objectives much earlier
than expected. At the same time, he led the acquisition of a banking institution in Turkey that was
renamed Millennium bank Turkey and served as a member of its Board of Directors. From late July to
October 2011, Mr. Taniskidis served as Interim CEO of Proton Bank during the transition period, where
he successfully maintained the bank’s liquidity and market access amid the turbulent period until its
break-up. From 2003 to 2005, he was a Member of the Board of Directors of Visa International Europe.
He has been a member of the Board of Directors of the Hellenic Bank Association for many years.
Today he participates in Boards of Directors in various companies in the fields of commerce,
manufacturing and shipping. He played a key role in the acquisition of Marfin Bank Romania (now
VISTA BANK). He envisioned the creation of a bank not carrying the weight of the past in Greece. He
pursued his goal and eventually succeeded in acquiring the Investment Bank of Greece (now Optima
bank). Already in its more than five years of operation, the Bank has an admirable course and is a
reference bank in the Greek banking scene. Mr Taniskidis holds a Law degree from the Law School of
the University of Athens, where he graduated first in class, and a Master of Laws (LL.M.) from the Law
School of the University of Pennsylvania.
51
- Petros Tzannetakis, Vice-Chairman, Non-Executive Member: Mr Petros Tzannetakis holds the
position of Deputy CEO of Motor Oil. He has over 34 years of experience in the private sector. His
career began in 1986 at Motor Oil, as a Senior Financial Analyst. In 1991 he assumed the position of
Chief Financial Officer (CFO) and in 2005 the position of Deputy Chief Executive Officer of the Motor
Oil Group of Companies. He is a Member of the Board of Directors and the Executive Committee of
the Group. He leads all Corporate, Financial, Cash, Banking and Investor Relations functions and
participates in all corporate decisions, in addition to financial ones. Among his significant achievements
are the initial public offering of Motor Oil (Greece) in the years 1999 – 2001, the introduction of the
Group into the Greek, European and American investment community, the placement of Motor Oil
(Greece) shares, which doubled the company's free float by attracting institutional investors abroad
in September 2005, when Saudi Aramco sold its stake. He is a Member of the Boards of Directors of
all subsidiaries of Motor Oil Hellas Corinth Refineries S.A. (Avin Oil Industrial Commercial & Maritime
Oil Company S.A., Motor Oil Holdings LTD, Coral S.A. (formerly Shell Hellas S.A.), Coral Gas S.A., LPC
S.A., Petroventure Holdings Limited). He is also Chairman of the Board of Korn Ferry International
S.A. He was a Member of the Board of Directors of M.J. Mailis S.A. (packaging company), Incadea
Group GmBH (company providing solutions in the retail car market), and Olympic DDB Holding S.A.
(advertising company). Mr Tzannetakis holds a BA in Economics from the University of Surrey (UK)
and a MA in European Union Economics from the University of Sussex (UK).
- Dimitris Kyparissis, Managing Director, Executive Member: With over 25 years of experience
in the banking sector, Mr Dimitris Kyparissis holds the position of CEO of the Bank. He began his career
at Xiosbank in 1993, where he set up the car financing section before taking responsibility for the
entire retail credit. In 2000, Mr Kyparissis, as a member of the founding team of the newly established
Novabank, created the credit sections of the bank. In 2002 he was in Turkey where he launched
Novabank's newly established subsidiary, BankEuropa. Returning in 2004, he held various positions at
Millennium bank and became a member of the board of directors responsible for credit and operations.
In 2010 he became General Manager of the Hellenic Post Bank, responsible for the retail banking
sector. Between 2016 and 2018, he headed Eurobank's retail branch network. Since January 2019, he
has been involved in the acquisition of the Investment Bank of Greece, with the aim of transforming
it into a successful commercial bank, the current Optima bank, in which he holds the position of
Managing Director. Mr Dimitris Kyparissis holds a B.Sc. in Accounting & Finance from the American
College of Greece and an MBA in Financial Services Management from the University of Sheffield, UK.
52
- Angelos Sapranidis, Executive Member of the Board of Directors: With over 35 years of
experience in banking, Mr. Angelos Sapranidis currently holds the position of Chief Financial Officer of
Optima bank. He started his career in 1981 in the Finance & Accounting Department of the Bank of
Macedonia-Thrace S.A. and left it in 1991 as Deputy Director of the Finance & Accounting Department.
In 1991 he joined the founding team of Egnatia Bank as Head of the Financial Services Department.
He was then promoted to Deputy General Manager, reporting directly to the Managing Director, taking
additional responsibility for the Departments of Central Works and Administrative Services. In 2007
he became a CFO of the Marfin Egnatia Bank Group. In 2013 he moved to the Financial Services
Department of Piraeus Bank Group, responsible for the proper transfer and financial liquidation of the
transferred assets of the Greek activities of the Cypriot Banks. In 2018 he became Deputy Managing
Director at Investment Bank of Greece S.A. (currently Optima bank). Mr Sapranidis holds a degree in
Economics from the Faculty of Law and Economics of the Aristotle University of Thessaloniki.
- Theofanis Voutsaras, Non-Executive Member: He was born in 1963. He is a graduate of Boston
College (USA) and holds a Master's degree (MSc) from the London School of Economics (UK)
specializing in Industrial Relations & Personnel Management. He has 30 years of experience in
managerial positions (Banking, Construction). He has been working for Motor Oil since 2010.
- Nikolaos Giannakakis, Non-Executive Member: He was born in 1971. He holds a Bachelor’s
degree in Physics, a Master’s degree in Industrial Systems Organisation and Management and a degree
from the International Institute for Management Development – IMD (Lausanne, Switzerland). He has
15 years of international experience in positions of Director and General Manager of Informatics in
distinguished Multinational Groups. He was named one of the Top 100 Chief Information Officers for
2019. He has been working for Motor Oil since November 2019.
- Theodoros Efthys, Independent Non-Executive Member: With over 30 years of experience in
the banking sector, Mr Theodoros Efthys holds the positions of non-executive member of the Board
of Directors of Optima bank, Chairman of the Audit Committee and member of the Risk Management
Committee. He began his career in 1990 at Merrill Lynch International Bank in London as a Financial
Advisor, where he remained for 13 years and left as Vice Chairman. He then moved to Geneva,
Switzerland, where he worked for 2 years at EFG International Bank as First Vice Chairman,
responsible for Portfolio Management. In 2005 he was in Greece, where he worked as an independent
advisor. In 2008 he joined the Hellenic Post Bank, in the position of Deputy Treasurer & Bond trader,
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while after the merger of Hellenic Postbank with Eurobank, he worked in the Asset Management &
Depository sectors. Since 2019, Mr. Efthys has been a non-executive member of the Board of Directors
of VISTA Bank Romania, a member of the Nominations Committee and Chairman of the Bank's Internal
Audit & Risk Management Committee. Mr Efthys holds a B.Sc. in Economics from Queen Mary College,
University of London. He also holds an FSA (UK Capital Markets), Series 3 & 7 (NASD USA), a level C
certification (Bank of Greece) & a certificate from the Board of Directors of the National Bank of
Romania.
- Ioanna Zour, Independent Non-Executive Member: Ms. Zour has over 30 years of experience
in banking, specializing in strategic marketing, corporate communication and business transformation.
She started her career in 1989 at Procter & Gamble Hellas S.A. in the field of marketing and financial
analysis, and held senior positions in leading multinational companies (PepsiCo IVI S.A., Stet Hellas
S.A.) From 1999-2004 she served as Deputy General Manager & Marketing Director at Novabank,
while from 2004 to 2006 she held the position of Assistant General Manager and Head of Strategic
Marketing at EFG Eurobank Ergasias. Afterwards, she worked at the National Bank of Greece initially
as Assistant General Manager of Retail Banking and then from 2012 to 2019 as Assistant General
Manager of Communications and Marketing of the Group. She has been distinguished for her
pioneering initiatives in digital banking and corporate social responsibility. In addition, she has received
multiple Marketing Excellence Awards for product innovation and the effectiveness of the campaigns
she led. Ms Zour holds a bachelor's degree in Economics from the University of Bristol, a master's
degree from the London School of Economics and has completed doctoral studies in Economics at the
University of Oxford (Thesis: Greek Banking Policy from 1958 to 1980).
- Pavlos Kanellopoulos, Independent Non-Executive Member: Mr Kanellopoulos has more than
25 years of experience in accounting and finance, mainly at a senior level. He started his career in
1996 in the International Banking Department of Bank of Tokyo-Mitsubishi in London. Since 2003 he
has served as a CFO in various companies listed on the Athens Stock Exchange and the New York
Stock Exchange, which are active in various sectors, such as manufacturing, shipping and TMT. In
2017 he was appointed Chief Financial Officer of Stoiximan, a betting company based in Greece, which
is considered to be one of the leading online gambling platforms in Europe and is a subsidiary of OPAP
S.A. Mr. Kanellopoulos holds a degree in Economics from the Athens University of Economics, a
Master's degree from the University of Warwick and a Master's degree in Behavioural Science from
the London School of Economics.
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- Georgia Kontogianni, Independent Non-Executive Member: With over 10 years of experience
in banking and investment, Ms Georgia Kontogianni currently holds the positions of non-executive
member of the Board of Directors of Optima bank and member of the Risk Management Committee.
She started her career in 2008 in the Capital Markets Department of Alpha Bank responsible for
covering corporate clients in the bond, interest rate and foreign exchange markets and continued in
the Capital Markets Departments of Marfin Egnatia Bank in Greece and England. In 2013 she moved
to Zurich where she joined Tallon Trading Group as Director of Global Markets, specializing in oil and
emissions trading products. Since 2018 she has been in London continuing her successful career at
Tallon Commodities as Director of Trading, Head of Energy Commodity Derivatives Trading and
Corporate Customer Risk Management. Ms Kontogianni holds a postgraduate degree from the London
School of Economics and Political Sciences (LSE). She also holds a Level C Investment Management
Certificate from the Chartered Institute of Securities & Investment (CISI), approved by the Financial
Conduct Authority (FCA) in the United Kingdom and a Level C Portfolio Manager certification from the
Bank of Greece & the Hellenic Capital Market Commission.
- Georgios Kyriakos, Independent Non-Executive Member: With 30 years of experience, Mr.
Georgios Kyriakos assumed senior and senior management positions in Greek and multinational
companies as well as in the banking sector, in Greece and abroad. He is currently a non-executive
member of the Board of Directors of Optima bank and Chairman of the Remuneration and Nominations
Committee. He served as a Secretary of the Ministry of Finance for State-Owned Enterprises and
Privatizations. Born in 1961, he is a graduate of Athens College, the University of Denver and holds a
Master's degree in Business Administration from Boston University, while he has attended a number
of Executive Trainings at INSEAD in Business Administration.
Meetings of the Board of Directors in 2024
In 2024, the Board of Directors met twenty-two (22) times. The average participation rate of the members of
the Board of Directors in the meetings was 97.5%.
Adequacy Policy of Members of the Board of Directors
The Bank applies an Adequacy Policy for the Members of the Board of Directors, which has been drawn up
in accordance with the applicable legislative and regulatory framework, amended by decision of the
Ordinary General Meeting of Shareholders of 23 May 2024 and posted as in force on the Bank's website
(http://www.optimabank.gr/en/about-us/corporate-governance/principles).
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Policy objectives
The objectives of the Policy are:
i. To determine the principles and rules governing the selection or replacement of the members of
the Board of Directors, as well as the renewal of the term of office of the existing members.
ii. To assist the Remuneration and Nominations Committee in the performance of its duties regarding
the selection, control and formulation of nominations of BoD Members of the Bank for their
election by the General Meeting (or by the BoD), in accordance with the Bank's Articles of
Association and the law, as well as regarding the replacement of BoD Members by establishing a
transparent, effective and time-efficient procedure for the adequacy and nomination of
candidates.
iii. To define transparent and effective criteria for the selection and assessment of the adequacy of
applications and the internal adequacy assessment process.
iv. To ensure that the composition of the Board of Directors of the Bank meets high standards of
adequacy (both individually and collectively), moral prestige and competence.
v. To define the diversity criteria for the selection of Board Members.
Individual and Collective Adequacy
The Bank seeks to staff the Board of Directors with persons who have guarantees of morality, reputation and
increased reliability and this is the responsibility of the Board of Directors and in particular the Remuneration
and Nominations Committee. Members of the Board of Directors have a good reputation and possess sufficient
knowledge, skills and experience to be able to understand the Bank's activities, while at the same time having
the necessary time to perform their duties.
The composition of the Board of Directors as a whole covers a sufficiently wide range of knowledge and
experience per subject, so that the Board of Directors can collectively understand the Bank's activities,
including the main risks to which it is or may be exposed. The principles governing the Policy are compliance
with the legislative and regulatory framework, transparency, diversity and meritocracy. In particular:
Individual adequacy
The individual adequacy of Board Members shall be assessed in particular on the basis of the extent to which
a person is deemed to have:
i. adequate knowledge, skills, experience;
ii. reputation, honesty, integrity and morality guarantees;
iii. independence of judgment;
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iv. the absence of a conflict of interest for the performance of his/her duties, and
v. sufficient time to carry out his/her duties at the Bank.
Collective adequacy
The adequacy of the Board Members as a whole constitutes the collective adequacy. The Board of Directors
should be adequate for the exercise of its responsibilities and its composition should ensure the effective
management of the Bank and a balanced decision-making. BoD Members collectively should be able to take
appropriate decisions taking into account the business model, risk appetite, strategy and markets in which the
Bank operates, in order to effectively monitor and judge the decisions of senior management.
Succession plan
In compliance with the current legislative and regulatory framework governing its operation and in order to
ensure the smooth continuity of the management of its affairs and the decision-making after withdrawals or
other cases of loss of the status of members of its Board of Directors and its committees, the Bank has
established and applies an appropriate procedure (succession plan) for members of the Board of Directors and
Board of Directors committees. The selection of new BoD members and committees is carried out in
accordance with the specific provisions of the Bank's BoD Members' Adequacy Policy and the applicable legal
and regulatory framework, in order to meet all the criteria of individual and collective adequacy.
The succession framework of the BoD members varies depending on the categorization and the basic qualities
of the BoD members as a) Executive BoD Members, b) Non-Executive BoD Members and c) Independent Non-
Executive BoD Members. Especially with regard to the Managing Director, the Committee ensures that the
required qualitative characteristics that should in any case be met in the person of the Managing Director are
identified. Regarding the identification and nomination of candidates for Independent Non-Executive BoD
Members (which, in addition, participate as a majority in the BoD committees of the Bank) and in order to
identify persons who meet the conditions of independence, the Committee, in cooperation with the Human
Resources Department, may appoint a qualified expert consultant with expertise in identifying senior
management.
The succession procedure and any amendment thereto shall be approved by the Board of Directors on the
recommendation of the Remuneration and Nominations Committee.
Diversity and Representation regardless of gender
The Bank gives priority to diversity in the Board of Directors and at all levels, in accordance with the applicable
legislative and regulatory framework, in order to promote independent opinions and sound decision-making in
the Board of Directors.
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In particular, measures shall be taken to ensure that there is no exclusion on the grounds of discrimination
based on sex, race, colour, ethnic or social origin, religion or belief, property, birth, disability, age, sexual
orientation or any other aspect not related to employment. The individual adequacy criteria specified in the
Adequacy Policy shall play an exclusive role regarding selection. Achieving substantial and not only formal
diversity within the Board of Directors is an important guarantee for the overall effectiveness of the Board of
Directors.
The Bank is committed to promoting equality and diversity within the Board of Directors, as well as promoting
a culture that values and respects diversity and recognises that people from diverse backgrounds and
experiences can make valuable contributions to the work of the Board of Directors. The Bank's broader
objective is to be an inclusive organisation that provides equal opportunities in all aspects of employment
within the Bank, including recruitment, training and development of Board Members and employees
In this context, provision is also made for adequate representation by gender at least as defined by the relevant
legislation in terms of a percentage on the total number of BoD Members. In particular, each gender shall be
adequately represented in the BoD, at least by 25 per cent (25%). If this number is a fraction, it shall be
rounded down to the nearest whole number. The Committee will lay down the objectives for achieving the
diversity of the BoD and will recommend their adoption by the BoD, which will take care of the improvement
of one or more diversity elements and evaluate the corresponding progress.
More generally, the criteria of diversity concern not only the BoD members but also the top or senior managers.
In fact, the Remuneration and Nominations Committee, in cooperation with the Human Resources Department,
shall submit proposals and the BoD shall approve specific representation targets by gender, as well as
timetables for achieving them.
Information on the diversity applied by the Bank in its administrative, management and regulatory bodies in
terms of gender representation, as well as at all levels, can be found in the sustainability report of the Optima
bank Group management report for the year 2024.
Approval of the Adequacy Policy of the members of the Board of Directors – Policy Review – Implementation
at Group level
The Policy is approved by the Board of Directors and submitted for approval to the General Meeting of the
Bank. Amendments to the Policy shall be approved by the Board of Directors and, if they are material, shall
be submitted to the General Meeting for approval in accordance with Article 3(3) of Law 4706/2020. The Policy
and any substantial amendments thereto shall enter into force upon its approval by the General Meeting.
The Policy that applies each time is posted on the Bank's website.
The Policy is in line with the general corporate governance framework, corporate culture and risk appetite set
by the Bank.
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The Policy is adopted at the level of the Bank's group, i.e. it is also adopted and applied to the extent possible
(based on their size, internal organization, scale and complexity of their operation) by the subsidiaries
appearing in the Bank's consolidated financial statements.
Implementation of the Adequacy Policy
The composition of the Board of Directors as a whole covers a wide range of knowledge and experience per
subject and ensures the effective management of the Bank and a balanced decision-making. For the individual
and collective adequacy of the members of the Board of Directors, the following were taken into account:
- their detailed CVs, which record their knowledge, skills, experience and other qualifications;
- other professional obligations and commitments;
- their cooperation and their functioning as a whole in the performance of their duties;
- general assessment of their individual and collective abilities; and
- the provisions of the applicable legislative and regulatory framework, the approved Adequacy Policy
of the Bank and the Greek Corporate Governance Code.
Furthermore, it was established that in 2024:
- the number of independent non-executive members of the Board of Directors at the Reporting Date
was higher than the number set by the applicable legislation, which ensures a high level of
independence of the Board of Directors and its Committees (4 out of 10 BoD Members, i.e. 40%, were
independent ones);
- by 30.10.2024, each gender was adequately represented on the Board of Directors, by at least twenty-
five percent (25%), with the female gender being represented with the participation of two (2) women
in the Board of Directors (10 members x 25% = 2,5 rounded up to the previous smaller whole number,
in accordance with Article 3(1b) of Law 4706/2020).
Following (i) the resignation of Ms Clio Lyberi from the position of Independent Non-Executive Member
of the Board of Directors, as well as from all her responsibilities and in particular from the position of
Chair of the Risk Management Committee and Member of the Audit Committee and Remuneration and
Nomination Committee with effect from 31.10.2024, as well as (ii) the decision taken at the meeting
of the Board of Directors No 435 of 08.11.2024, following the relevant recommendation of the
Remuneration and Nomination Committee, to continue the management and representation of the
Bank with the other members of the Board of Directors, without the replacement of Ms K. Lyberi
temporarily, until her replacement by a new member of the Board of Directors, the Remuneration and
Nomination Committee immediately initiated actions in accordance with the approved current Policy
on the Adequacy of Members of the Board of Directors of the Bank to identify a person adequate for
59
obtaining the status of member of the Board of Directors of the Bank in replacement of the resigned
member.
The Remuneration and Nominations Committee of the Bank, having completed the actions to identify
a person adequate for acquiring the status of member of the Board of Directors of the Bank in place
of the resigned member Ms. Klio Lyberis, at its meeting of 18 February 2025, nominated Ms. Ioanna
Zour, father’s name Christos, as a candidate for the position of Independent Non-Executive Member
of the Board of Directors of the Bank, who was elected as an Independent Non-Executive Member of
the Board of Directors at its meeting of 20 March 2025. Given this, each gender is adequately
represented on the Board of Directors, by at least twenty-five percent (25%), with the female gender
being represented with the participation of two (2) women on the BoD, in accordance with Article
3(1b) of Law 4706/2020.
- the number of independent non-executive members of the current Board of Directors of the Bank is
higher than the number set as a mandatory minimum by the current legislation, which ensures a high
level of independence of the Board of Directors and its Committees (5 out of the 11 BoD Members,
i.e. 45%, are independent ones) and
- the adequacy criteria set out in the current legislative and regulatory framework and in the Bank's
Adequacy Policy have been met and continue to be met in full.
Committees
Committees of the Board of Directors
Audit Committee
The Audit Committee has been established on the basis of BoG Governor’s Act 2577/2006 and Article 44 of
Law 4449/2017, as amended by Law 4706/2020. The type of the Audit Committee, the term, the number and
the capacities of its members are defined by the General Meeting. The resolution of the Extraordinary General
Meeting of the Bank's Shareholders of 22.03.2023 stipulated that the Audit Committee of the Bank shall be a
committee of the Board of Directors, consisting of three non-executive members of the Board of Directors,
independent in their majority, within the meaning of Article 9 of Law 4706/2020 and its term shall coincide
with the term of office of the Board of Directors of the Bank, i.e. it shall be four years, automatically extended
until the first ordinary General Meeting after the end of their term, but not exceeding five years.
The members of the Audit Committee were appointed by decision of the Board of Directors of 23.03.2023 of
the BoD, and the Committee was constituted by its decision of 30.03.2023. Its composition in as follows:
• Pavlos Kanellopoulos, father’s name Dimitrios, Independent Non-Executive Member of the Board of
Directors, Chairman of the Audit Committee;
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• Clio Lymberi, father’s name Konstantinos, Independent Non-Executive Member of the Board of
Directors, Member of the Audit Committee and
• Petros Tzannetakis, father’s name Tzanibeis, Non-executive member of the Board of Directors,
Member of the Audit Committee.
Following the resignation of the Independent Non-Executive Member of the Board of Directors and Member
of the Audit Committee Ms. Klio Lymberi with effect from 31.10.2024, the Board of Directors at its meeting of
08.11.2024 decided to reconstitute the Audit Committee by appointing Mr. Theodoros Efthys as a new member
of the Committee in replacement of Ms. Lymberi and the Committee was reconstituted by its decision of
11.11.2024 as follows:
1. Theodore Efthys, father’s name Elias, Independent Non-Executive Member,
Chairman of the Audit Committee;
2. Pavlos Kanellopoulos, father’s name Dimitrios, Independent Non-Executive
Member, Member of the Audit Committee and
3. Petros Tzannetakis, father’s name Tzanibeis, Non-Executive Member, Member of
the Audit Committee.
The above members are all non-executive, while two of the three, namely Theodoros Efthys and Pavlos
Kanellopoulos, are independent. The above members of the Audit Committee have sufficient knowledge in the
field in which the Bank operates, i.e. in the field of banking operations, due to their professional status and
experience, as can be seen from the above CVs (see section "Board
of Directors"/"Composition and functioning
of the Board of Directors").
In addition, the Chairman of the Audit Committee, Mr Theodoros Efthys, has sufficient knowledge and
experience in auditing and accounting, as can be seen from his CV above.
Therefore, the composition of the Audit Committee meets the requirements of Article 44 of Law 4449/2017,
as amended and in force.
The Rules of Procedure of the Audit Committee are currently in force as amended by the decision of the Audit
Committee of 17.12.2024 and the decision of the Board of Directors of the Bank of 20.12.2024 and have been
posted on the Bank's website
http://www.optimabank.gr/media/tpbmqtoy/c3_kanonismos_leitourgias_epitropis_elegxou.pdf.
Meetings of the Audit Committee in 2024
In 2024, the Audit Committee met sixteen (16) times. The average attendance rate of Members of the
Committee at meetings was 94%. According to its rules of procedure, the Audit Committee meets six (6)
times a year or extraordinarily, if circumstances so require.
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Proceedings of the meetings of the Audit Committee for the year 2024
During 2024, the Audit Committee met sixteen (16) times and all its decisions were taken unanimously, based
on a thorough review of the supporting material and further clarifications of the meetings provided by the
Chief Financial Officer, the Chief Internal Audit Officer, the Chief Compliance Officer, relevant managers,
statutory auditors and other external auditors. The Audit Committee reviewed and submitted to the Board of
Directors for approval the updated terms governing its rules of procedure.
In addition, the Audit Committee:
Has reviewed the interim quarterly, interim six-month and annual financial statements before publication. It
reviewed and proposed to the BoD Deloitte’s remuneration for audit and non-audit work for the year ended
31 December 2024 and was informed about Deloitte’s audit plan and procedures.
Has approved the assignment to the audit firm Mazars of the reports on (a) the three-year evaluation of the
Internal Audit System, in accordance with BoG Governor’s Act 2577/2006 and (b) the annual audit on the
safekeeping of financial instruments and client funds and the product monitoring obligations based on the Act
of the Executive Committee Act 147/2018 of the Bank of Greece, on the findings of which it was informed.
It took note of the 2023 annual report of the Regulatory Compliance Department and the 2023 annual report
of the Internal Inspection Unit assessing the adequacy of the Internal Audit System.
It has monitored the implementation of the Internal Audit Annual Programme for the year 2024. It took note
of the analysis of the Internal Audit Annual Plan for the year 2025. It pre-approved its implementation and
submitted it for further approval to the Bank's Board of Directors.
It has monitored the implementation of the annual Regulatory Compliance programme for the year 2024 and
was informed about the annual Regulatory Compliance work plan for the year 2025.
It was informed about the important audit findings (from regular and specific audits) and the replies of the
directions in relation to the timetable and the actions taken to resolve the findings.
It reviewed and pre-approved the Annual Report of the Responsible Manager on Money Laundering,
Countering Money Laundering and Terrorist Financing for 2023 submitted to the Bank of Greece.
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It commissioned the audit firm Deloitte to prepare an assurance report on the sustainability information to be
included in the sustainability report of Optima bank group’s management report for the financial year 2024
and approved a remuneration for it.
Remuneration and Nominations Committee
The Remuneration and Nominations Committee of the Bank shall consist of at least three (3) members,
appointed by the Board of Directors. These members are all non-executive members of the Board of Directors
and in their majority independent within the meaning of Article 9 of Law 4706/2020. An independent non-
executive member of the Board of Directors shall be appointed Chairman of the Committee. By decision of the
Board of Directors of 23.03.2023, a single Remuneration and Nominations Committee was established, in
accordance with Article 10(2) of Law 4706/2020 and its members were appointed, and then by decision dated
31.03.2023 the Remuneration and Nominations Committee was constituted as follows:
• Georgios Kyriakos, father’s name Konstantinos, Independent Non-Executive Member of the Board of
Directors, Chairman of the Remuneration and Nominations Committee;
• Theofanis Voutsaras, father’s name Christos, Non-executive member of the Board of Directors,
Member of the Remuneration and Nominations Committee;
• Pavlos Kanellopoulos, father’s name Dimitrios, Independent Non-Executive Member of the Board of
Directors, Member of the Remuneration and Nominations Committee and
• Clio Lymberi, father’s name, Konstantinos, Independent non-executive Member of the Board of
Directors, Member of the Remuneration and Nominations Committee.
Following the resignation of the Independent Non-Executive Member of the Board of Directors and Member
of the Remuneration and Nominations Committee Ms. Klio Lymberi with effect from 31.10.2024, the Board of
Directors at its meeting of 08.11.2024 decided to reconstitute the Remuneration and Nominations Committee
of the Bank with its remaining three (3) Members and the Committee was reconstituted by its decision of
21.11.2024 as follows:
• Georgios Kyriakos, father’s name Konstantinos, Independent Non-Executive Member of the Board of
Directors, Chairman of the Remuneration and Nominations Committee;
• Theofanis Voutsaras, father’s name Christos, Non-executive member of the Board of Directors,
Member of the Remuneration and Nominations Committee and
• Pavlos Kanellopoulos, father’s name Dimitrios, Independent non-executive Member of the Board of
Directors, Member of the Remuneration and Nominations Committee.
The above members are all non-executive, while two of the three members including its Chairman are
independent. Therefore, the composition of the Remuneration and Nominations Committee is in accordance
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with Article 10 of Law 4706/2020. The term of office of the members of the Remuneration and Nominations
Committee coincides with the term of office of the Board of Directors of the Bank, i.e. it is four years,
automatically extended until the first ordinary General Meeting after the end of their term, but may not exceed
five years.
The current Rules of Procedure of the Remuneration and Nominations Committee were approved by decision
of the Remuneration and Nominations Committee dated 21.04.2023 and by decision of the Board of Directors
of the Bank dated 02.05.2023 and have been posted on the Bank's website
http://www.optimabank.gr/media/cuslmnfi/kanonismos_leitourgias_epitropis_apodoxon_ypopsifiotiton.pdf.
Meetings of the Remuneration and Nominations Committee in 2024
In 2024, the Remuneration and Nominations Committee met seven (7) times. The average attendance rate of
Members of the Committee at the meetings was 97%.
Proceedings of the meetings of the Remuneration and Nominations Committee in 2024
In 2024, the Remuneration and Nominations Committee made recommendations to the competent corporate
bodies on the following issues:
− the granting of a special childbirth allowance to Bank employees, as a measure to support the family
in accordance with the Bank's current Staff Remuneration Policy;
− the extension of the number of Members of the Board of Directors of the Bank from ten (10) to eleven
(11), with the election and addition of a new Member (Mr Nikolaos Giannakakis), whose term of office
will expire at the same time as the term of office of its other Members;
− the approval of the fees of the Members of the Board of Directors for the fiscal year 2023 and the
determination of the amount of these fees through participation in the profits for the fiscal year 2024
until the Annual General Meeting for the year 2025, in accordance with the provisions of article 109
of Law 4548/2018;
− the free distribution of shares to members of the Board of Directors and to staff executives (Senior
Management, in accordance with the provisions of Article 114 of Law 4548/2018, through the
capitalization of profits for the financial year 2023 (Program of free distribution of shares) and provided
clarifications setting out the basic characteristics and the main terms of the Program of free distribution
of shares to members of the Board of Directors and staff, in accordance with the provisions of Article
114 of Law 4548/2018, through the capitalization of profits for the financial year 2023
− the distribution of part of the profits of the financial year 2023, as a one-off special fee (Bonus) due
to the achievement of objectives to Executive Members of the Board of Directors and Bank staff
− the modification of the Adequacy Policy of the Members of the Board of Directors; and
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− the update of the Bank's Remuneration Policy
− the creation of a Variable Remuneration scheme for the payment of variable remuneration approved
by the Ordinary General Meeting to the Executive Members of the BoD and senior staff of the Bank as
a one-off extraordinary remuneration (Bonus) for the 2023 profit and loss;
− the adjustment of the variable remuneration system of the Bank's Brokerage General Department;
− the salary adjustment of the Chairman and Non-Executive Member of the Board of Directors of the
Bank;
− the adjustment of the remuneration of the Chief Executive Officer and Executive Member of the Board
of Directors of the Bank;
− following the resignation of the Member of the Board of Directors, Ms. Klio Lymberi, it recommended
i) the continuation of the management and representation of the Bank temporarily without the
replacement of the resigned member in accordance with paragraph 2 of Article 10 of the Bank's Articles
of Association and the reconstitution of the Board of Directors with its remaining members and ii) the
reconstitution of the Committees of the Board of Directors.
Furthermore, the Remuneration and Nominations Committee:
- expressed its agreement to the Board of Directors to submit to the Ordinary General Meeting of the
Bank's Shareholders the Remuneration Report for the financial year 2023, in accordance with Article
112 of Law 4548/2018;
- was reconstituted after the change of its composition by the Board of Directors;
- attended an information session on the provisions of the new Act of the Executive Committee of the
Bank of Greece No 231/15.07.2024 adopting the guidelines of the European Banking Authority (EBA)
on sound remuneration policies.
Finally, the Remuneration and Nominations Committee, at its meeting of 18 February 2025:
- established the Procedure (plan) for the succession of Board Members and Committees of the Board
of Directors in accordance with the Bank's Board of Directors Adequacy Policy and recommended its
approval to the Bank's Board of Directors; and
- assessed the individual adequacy of the candidate member of the Board of Directors Ms. Ioanna Zour
and the collective adequacy of the Board of Directors and recommended to the Board of Directors the
election of a new member of the Board of Directors to replace the resigned member Ms. Klio Lyberi
and, in particular, recommended the nomination of Ms. Ioanna Zour for the position of Independent
Non-Executive Member of the Board of Directors.
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Risk Management Committee
The Risk Management Committee of the Bank shall consist of at least three (3) non-executive members of the
Board of Directors, who shall be appointed by decision of the Board of Directors. Members of the Risk
Management Committee shall have appropriate knowledge, skills and expertise to understand and monitor the
institution’s risk-taking strategy. The Chairman of the Committee shall be appointed by the Board of Directors.
By decision of the Board of Directors of 10.08.2023, the composition of the Risk Management Committee as
initially appointed pursuant to the decision of the Board of Directors of 23.03.2023 was amended, the term of
office of its members was renewed and its Chairman was appointed, while at its meeting on 05.09.2023, the
Risk Management Committee was reconstituted as follows:
• Clio Lymberi, father’s name Konstantinos, Independent Non-Executive Member of the Board of
Directors, Chairman of the Risk Management Committee;
• Theodoros Efthys, father’s name Ilias, Independent Non-Executive Member of the Board of Directors,
Member of the Risk Management Committee;
• Pavlos Kanellopoulos, father’s name Dimitrios, Independent Non-Executive Member of the Board of
Directors, Member of the Risk Management Committee and
• Georgia Kontogianni, father’s name Vassilios, Independent Non-Executive Member of the Board of
Directors, Member of the Risk Management Committee.
Following the resignation of the Independent Non-Executive Member of the Board of Directors and Chairman
of the Risk Management Committee Ms. Klio Lymberi with effect from 31.10.2024, the Board of Directors at
its meeting of 08.11.2024 decided to reconstitute the Bank's Risk Management Committee with its remaining
three (3) Members and the Committee was reconstituted by its decision of 11.11.2024 as follows:
• Pavlos Kanellopoulos, father’s name Dimitrios, Independent Non-Executive Member of the Board of
Directors, Chairman of the Risk Management Committee;
• Theodoros Efthys, father’s name Ilias, Independent Non-Executive Member of the Board of Directors,
Member of the Risk Management Committee and
• Georgia Kontogianni, father’s name Vassilios, Independent Non-Executive Member of the Board of
Directors, member of the Risk Management Committee.
66
All the above members of the Committee have appropriate knowledge, skills and expertise to understand and
monitor the Bank's risk-taking strategy.
The Rules of Procedure of the Risk Management Committee, as amended and in force by decision of the Bank’s
Board of Directors of 10 August 2023, were amended again by decision of the Bank’s Board of Directors of 20
December 2024 and have been posted on the Bank’s website at
https://www.optimabank.gr/media/nzhfmpzq/c5_epitropi_diaxeirisis_kindinon.pdf.
The term of office of the members of the Risk Management Committee coincides with the term of office of the
members of the Board of Directors.
Meetings of the Risk Management Committee in 2024
In 2024, the Risk Management Committee met sixteen (16) times. The average attendance rate of Members
of the Committee at the meetings was 98%.
Executive Committee
The Executive Committee consists of executives of the Bank with the following qualities and its current
composition is as follows, following the decision of the Board of Directors of 09.03.2020:
Νame and surname
Member of
the Board of
Directors /
non-member
Position at the Bank
Dimitrios Kyparissis, father’s name
Apostolos
Member of the
Board of
Directors
Chief Executive Officer (CEO), Executive
Member of the Board of Directors
Angelos Sapranidis, father’s name
Nikolaos
Member of the
Board of
Directors
Executive Member of the Board of Directors,
Head of Financial Services Sector (Finance)
Theodoros Georgakopoulos father’s
name Nikolaos
Non-Member
of the Board of
Directors
Head of Credit & Recoveries Department
Ioannis Parnis, father’s name
Dimitrios
Non-Member
of the Board of
Directors
Head of Human Resources Department
Konstantinos Vatousis, father’s
name Charalambos
Non-Member
of the Board of
Directors
Head of Strategy, Shareholder Relations and
Sustainable Development
Alexandros Vlagoulis, father’s name
Panagiotis
Non-Member
of the Board of
Directors
Head of Marketing & Products Sector
67
Paschalis Giouchas, father’s name
Pelopidas
Non-Member
of the Board of
Directors
Head of Technology & Operations Sector
Paris Economou, father’s name
Polycarpos
Non-Member
of the Board of
Directors
Head of Wholesale Banking
Dimitrios Papageorgopoulos,
father’s name, Georgios
Non-Member
of the Board of
Directors
Head of Retail Network
Anastasia Petsinari, father’s name
Theocharis
Non-Member
of the Board of
Directors
Head of Corporate Governance & Legal
Services (General Counsel)
Antonios Mouzas, father’s name
Athanasios
Non-Member
of the Board of
Directors
Head of Brokerage
The Executive Committee has its Rules of Procedure, which were approved by the decision of the Board of
Directors of the Bank dated 12.12.2019 and updated by the decision of the Board of Directors of the Bank
dated 16.05.2023.
According to the Rules of Procedure of the Executive Committee:
• The Executive Committee shall meet regularly every fifteen days and extraordinarily whenever the
needs of the Bank so require, at the invitation of its Chairman. A quorum requires the participation of
more than fifty percent (50%) of the members of the Committee in person or by means of
videoconferencing. In the absence of the Chairman, he or she shall be substituted by a member of
the Committee appointed by decision of the Chairman and acting as Chairman of the Executive
Committee.
• Its decisions shall be taken by an absolute majority of the participating members. In the event of a
tie, the Chairman of the Committee shall have the casting vote.
• Following the authorization of the Board of Directors of the Bank, the Executive Committee has i) the
responsibilities of Administrative Planning, i.e. indicatively: monitoring the implementation of the
Bank's Business Plan and taking the necessary decisions to achieve the objectives included therein,
pre-approving the budget guidelines and recommending the budget to the Board of Directors and (ii)
approval responsibilities (within its responsibilities and within its respective approval limits), i.e.
indicatively: approval of the marketing strategy, the Rules of Operation of the Units, the Bank's Basic
Policies, in accordance with the applicable institutional and regulatory framework (indicatively: File
Management Policy, Customer Complaint Management Policy, Customer Asset Safekeeping Policy,
Procurement Policy, Outsourcing, etc.), expenses, investments, liquidations and strategic or non-
strategic ventures (acquisition, change, exit) within a budget of EUR 300 000 to EUR 1 000 000,
excluding expenses and investments for IT systems or matters which fall under the approval
68
competence of another committee. The above responsibilities may be delegated or assigned by
decision of the Executive Committee to administrative committees, members of the Committee or
executives of the Bank.
The CVs of the members of the Executive Committee (other than the members of the Executive Committee
who are also members of the Board of Directors, for which see Section “
BoD”/Composition and functioning
of
the Board of Directors”
) are as follows:
- Theodoros Georgakopoulos, Head of Credit & Recoveries: With over 25 years of experience in
the banking sector and particularly in Corporate & Retail Credit Risk Management, Mr. Theodoros
Georgakopoulos holds the position of Head of the Credit & Recoveries Section of Optima bank. He
started his career in 1994 in Ergasias Bank, where he worked in the Business Banking sector as a
Senior Credit Analyst in the areas of Small and Medium Enterprises and Small Business Loans. In 2001
he joined the Novabank team, where he designed and implemented the design and creation of the
Bank's Credit Sector. From 2005 to 2008 he was Head of Business Banking Credit at Millennium Bank.
He was subsequently promoted to Deputy Chief Credit Officer of the Bank and remained in that
position until 2012. In 2012 he created from scratch the Corporate Recovery & Collections Unit of
Millennium Bank. After the merger of Millennium Bank with Piraeus Bank in 2013, he became Director
of the Mortgage Credit Sector of Piraeus Group. In 2018 he moved to Romania, where he assumed
the position of Deputy CEO of Marfin Bank Romania (now Vista Bank) following the acquisition of the
Bank by the Vardinoyannis Group. Since May 2019, he participated in the acquisition of the Investment
Bank of Greece, now Optima bank. Mr Georgakopoulos holds a degree in Economics from the National
and Kapodistrian University of Athens.
- Ioannis Parnis, Head of Human Resources: With over 35 years of experience in banking, Mr.
Yannis Parnis holds the position of Head of Human Resources at Optima bank. He started his career
at Barclays PLC Shipping Branch in 1984, where he worked in various positions in the Customer Service
Sector. In 1991 he joined Xiosbank as Branch Manager, while in 1996 he moved to the Personal
Banking Section, where he remained until 2000. In 2000 he briefly moved to Telesis Investment Bank
as Director of the Private Network and Personal Banking. Later in 2001, Mr Parnis joined Millennium
bank where he remained for almost 13 years, initially as Regional Retail Network Manager. He then
moved to the Human Resources sector where he took the position of Head, contributing to the
awarding of the 3rd "Best Working Environment" Award to the Bank (2009), giving the impetus for an
organizational structure of transparency and meritocracy, combined with a pleasant everyday
69
environment. At the end of 2013, when Millennium bank merged with Piraeus Bank, he assumed the
position of Senior Director Group Human Resources & Organizational Health. Since April 2019, he has
been involved in the transformation of the Investment Bank of Greece into Optima bank as responsible
for all Human Resources issues. Mr Parnis holds a degree in Surveying Engineering from the University
of West Attica.
- Konstantinos Vatousis, Head of Strategy, Shareholder Relations and Sustainable
Development: With over 20 years of experience in the financial sector (Investment Banking), Mr
Konstantinos Vatousis holds the position of Head of Strategy and Shareholder Relations at Optima
bank. He started his career in 2000 at KPMG Advisors, where he was an executive in the Corporate
Finance section, specializing in mergers and acquisitions, valuations and fairness opinions, due
diligence and debt restructurings. In 2007 he became Head of Investment Banking at Millennium bank,
where he successfully completed a series of transactions in the field of mergers and acquisitions,
valuations and capital market operations. In 2011 he joined the independent financial consulting firm
Core Capital Partners as a Senior Investment Banker, specializing in the design and execution of
complex transactions, including the acquisition of the Investment Bank of Greece (now Optima bank)
in an international tender. In 2019, Mr. Vatousis joined the executive team of Optima bank (formerly
IBG) as Head of Strategy & IR, leading the development of the Bank’s long-term strategic plan and
the transformation of the Investment Bank of Greece from a brokerage bank to a modern commercial
bank (Optima bank) as well as the Bank’s relationship with its investors/shareholders. Mr Vatousis
holds a degree in Economics from the University of Macedonia (Thessaloniki) and a Master's degree
in Money, Banking & Finance from the University of Sheffield.
- Alexandros Vlagoulis, Head of Marketing & Products: With 20 years of experience in the fields
of Asset Management and Retail Banking, Mr. Alexandros Vlagoulis is currently Head of Marketing &
Products at Optima bank. He started his career at Citibank International Plc in 2000, as a Citigold
executive and took on various roles within Citibank Greece in the following years. In 2005 he was
appointed as a member of the Asset Management Committee. In 2008 he became Vice Chairman and
Head of Citigold. In 2014 he joined Eurobank Ergasias S.A. as Head of Personal Banking Business
Development. In 2016 he was appointed Head of Personal Banking and in 2018 he became Head of
Affluent segment & Analysis with the task, among other things, to design and implement the Strategy
for Affluent Customers. Since February 2019, he participated in the transformation of the Investment
Bank of Greece into a commercial bank. Mr Vlagoulis holds a Bachelor's degree in Business Economics
from the University of East London and a Master's degree in Management from the University of
Surrey.
70
- Paschalis Giouchas, Head of Technology & Operations: With over 20 years of experience in the
banking sector, Mr Akis Giouchas holds the position of Chief Operating Officer of Optima bank. He
started his career at Accenture (Germany) in 1995, where he participated in major transformation and
reorganization projects of major German banks and credit card processing companies. In 2001 he
joined the founding team of the then newly established Proton Bank (Greece) as a CIO, installing the
bank's IT systems and expanding its (investment) services and branch network. In 2013, he returned
to Accenture (Greece), where he was responsible for providing technology advice in the context of
Accenture’s financial services, and in that capacity, he implemented several strategic IT projects. Later,
he became Head of Infrastructure, Operations and Security for all branches. In June 2019, he joined
Optima bank's executive team with a mandate to turn IT operations and systems into the bank's digital
driving force. Mr. Giouchas holds a Master's degree in Computer Science from the Technical University
of Berlin.
- Paris Economou, Head of Wholesale Banking: With over 15 years of experience in the financial
sector, Paris Economou is currently Head of Wholesale Banking at Optima bank. In 2004 he joined
Laiki Bank of Cyprus as an analyst in the Section of Large Enterprises. In 2006 he assumed the position
of Relationship Manager in the Corporate & Investment Banking section of Millennium Bank, where
he remained until 2013. In 2013 after the merger of Millennium Bank with Piraeus Bank, he joined the
Large Corporations Section in which he served as Head and which he represented in a number of
important transactions and debt restructurings in various sectors. In 2017 he joined Ernst & Young as
Associate Partner of Transaction Advisory Services and worked on a number of restructuring and
consulting projects. He joined Optima bank's management team in March 2019 as Head of Wholesale
Banking. Mr Economou holds a Master’s degree in Economics from the University of Aberdeen and a
Master’s degree in Economics and Finance from the University of Warwick.
- Dimitrios Papageorgopoulos, Head of Retail Networks: With over 30 years of experience in
banking, Mr Dimitris Papageorgopoulos currently holds the position of Head of Retail Networks at
Optima bank. He started his banking career at the National Real Estate Bank of Greece in 1989. From
1990 to 2006, he worked at XiosBank and Piraeus Bank, where he held the position of Branch Manager
for 10 years. In 2006 he joined Millennium Bank as Head of Housing Credit and Network Manager of
Southern Greece until 2011. In 2011 he assumed the position of Deputy General Manager at Hellenic
Postbank, where he was responsible for the Bank's retail banking activities. Between 2013 and 2018,
he was Head of the Hellenic Postbank Branch Network and Eurobank Network Manager in Athens and
Western Greece. From February 2019 to July 2019, he participated in the acquisition of the Investment
71
Bank of Greece. Mr Dimitris Papageorgopoulos holds an Advanced Diploma in Business Administration
from London City College.
- Anastasia Petsinari, Head of Corporate Governance & Legal Services: With over 25 years of
significant experience in the banking sector, Ms Anastasia Petsinari is currently Head of Legal &
Corporate Governance at Optima bank, as well as Corporate Secretary. Since the beginning of her
professional career in 1997 she has been involved in financial law, providing her legal services to
domestic and foreign credit institutions. Since 2003 she held important positions as a bank legal officer,
such as Head of the Legal Service of Omega Bank (2003-2006), Proton Bank (2006-2011) and then
New Proton Bank (2011-2013). In 2013 she joined Eurobank and took over the position of Deputy
Director in the Legal Services Department and then in 2014 she was hired at Alpha Bank, where she
remained until 2019, initially as Deputy Director and then as Director in the Senior Legal Services
Division of Alpha Bank, with responsibilities for the legal support of the entire range of Alpha Bank's
banking operations. In the past she also provided legal services as Of Counsel, mainly in investment,
construction of large projects, claims management, and specializes in information and communication
technologies. She has extensive experience in formulating organizational and business strategies
based on corporate governance principles, as well as in-depth knowledge of Greek and European
banking legislation, having a deep knowledge both of the legal and business specificities of banking.
Ms Anastasia Petsinari holds a Law degree and a Master’s in Law (LL.M) in Banking & Finance from
the Faculty of Law, Economics and Political Sciences of the Aristotle University of Thessaloniki and in
International Trade & Investment Law from the Panteion University of Social & Political Sciences. She
also holds an MBA from the National Technical University of Athens and the Athens University of
Economics and Business and finally a Master of Science (MSc) in Management in Science & Technology
from the Athens University of Economics and Business. She is also trained and certified in Negotiations,
at the Harvard Law School, Program on Negotiations, and is an Accredited Mediator of the Ministry of
Justice, Transparency & Human Rights.
- Antonios Mouzas, Head of Brokerage Services: Mr Mouzas has a long experience in management
positions in banks and multinationals and as a member of the Boards of Directors of Greek and foreign
banks. He currently holds the position of Chief Brokerage Officer of Optima bank. He started in the
banking sector from the Consumer Credit Section of XiosBank in 1994, and then worked in the Toyota
Hellas Group. In 2000 he moved to Millennium Bank as Director of Credit Products, Head of Housing
Credit, and in 2013 after his return from abroad, as General Manager of Corporate and Investment
Banking. From 2006 to 2013, he has worked as General Manager and BoD member at Millennium
Bank in Turkey and Romania with different responsibilities, such as Large and Small Business
72
Financing, Credit, I.T., Branch Network, Restructuring and Arrears. Between 2014 and 2017 he has
worked in investment banking transactions (Core Capital Partners & Fedra Capital) mainly in
syndicated loan restructurings and acquisitions of companies in Greece, Turkey and Romania, with a
total transaction value of over 1 billion euros. In 2017 he joined the Vardinoyannis Group team that
acquired Marfin Bank Romania (later Vista Bank), where he worked as CEO until 2020. Mr Mouzas
holds a degree in Economics from the Faculty of Economics & Law of the Aristotle University of
Thessaloniki, an MBA from the ALBA Business School and a postgraduate education from INSEAD.
Professional obligations & number of shares of members of administrative, management and
regulatory bodies, Senior Management
The following shall apply to the members of the Board of Directors of the Bank, the members of the Audit
Committee, the Head of the Internal Audit Department, Ms Aphrodite Samaras, the members of the
Remuneration and Nomination Committee and the Risk Management Committee, which are the administrative,
management and regulatory bodies of the Bank, as well as the senior management of the Bank, as set out
above in the ‘
Administrative
,
Management and Regulatory Bodies and Senior Management’
section, on the
Reporting Date:
1. Apart from their activities related to their status and position in the Bank, and their activities related to
participations in administrative, management and regulatory bodies referred to in point 2 of this Section,
they shall not engage in any other professional activities, other than those of the Bank and its subsidiaries,
that are significant to the Bank, with the exception of the following:
- Mr Petros Tzannetakis, Vice-Chairman, Non-Executive Board Member and Member of the Audit
Committee, holds the position of Deputy CEO of Motor Oil.
- Mr Theofanis Voutsaras, Non-Executive Member of the BoD and member of the Remuneration and
Nominations Committee, holds the position of General Manager of Human Resources of Motor Oil
Group (MOH Group).
- Mr Nikolaos Giannakakis, Non-Executive Member of the BoD, holds the position of General Manager
of Informatics of Motor Oil Group (MOH Group).
2. On the Reporting Date, they were members of administrative, management and regulatory bodies of
another company or legal person, with the exception of subsidiaries of the Bank, according to the
following table:
73
NAME
S/N
NAME OF LEGAL PERSON
CAPACITY
Georgios
Taniskidis,
father’s name
Ioannis
1
CORE CAPITAL PARTNERS S.A.
Chairman of the
Board of Directors
2
LOULIS FOOD INGREDIENTS S.A.
Independent Non-
Executive Member
of the BoD
3
EUROSEAS LTD
Director
4
EURODRY LTD
Director
Petros
Tzannetakis,
father’s name
Tzanibeis
1
MOTOR OIL (HELLAS) CORINTH
REFINERIES S.A.
Executive Member
of the Board of
Directors
2
MOTOR OIL INVESTMENTS LIMITED
(CYPRUS)
Director
3
MOTOR OIL HOLDINGS LTD
(CYPRUS)
Director
4
PETROVENTURE HOLDINGS
LIMITED (CYPRUS)
Director
5
AVINOIL SINGLE MEMBER AVENEP
Non-executive
member of the
Board of Directors
6
CORAL S.A.
Non-executive
member of the
Board of Directors
7
CORAL GAS SINGLE MEMBER
AEVEY.
Non-executive
member of the
Board of Directors
8
LPC SINGLE MEMBER S.A.
Non-executive
member of the
Board of Directors
9
MOTOR OIL RENEWABLE ENERGY
(MORE) SINGLE MEMBER SA
Executive member
of the Board of
Directors
10
Wind RES SINGLE MEMBER S.A.
Executive
Chairman of the
BoD
11
MOTOR OIL MIDDLE EAST DMCC
(HAE)
Director
12
MOTOR OIL FINANCE PLC (UK)
Director
13
MEDPROFILE LIMITED (CYPRUS)
Director
14
KORN FERRY INTERNATIONAL S.A.
Chairman of the
BoD Non-
executive
15
NRG SUPPLY & TRADING S.A.
Non-executive
member of the
Board of Directors
16
CORINTHIAN OIL LIMITED (UK)
Director
17
TALLON COMMODITIES LTD (UK)
Director
74
NAME
S/N
NAME OF LEGAL PERSON
CAPACITY
18
VERNT SINGLE-MEMBER
SUSTAINABLE PRODUCTS AND
SERVICES SOCIETE ANONYME
Member of the
Board of Directors
Demetrios
Kyparissis,
father’s name
Apostolos
1
HELLENIC BANK ASSOCIATION
Member of the
Board of Directors
George Kyriakos,
father’s name
Constantinos
1
NOTOS COM HOLDINGS S.A.
Member of the
Board of Directors
2
OTROPAY PAYMENT FOUNDATION
SINGLE MEMBER SA
Non-Executive
Chairman of the
BoD
3
Faros Advisor (IKE)
Sole Partner and
Manager
4
GREEK WINERY SOCIETE ANONYME
Member of the
Board of Directors
5
GAMING SUPERVISION AND
CONTROL COMMITTEE (EEEP)
Member
Pavlos
Kanellopoulos,
father’s name
Dimitrios
1
KAIZEN DIGITAL SERVICES S.A.
Chief Executive
2
KAIZEN GAMING LTD
Chief Executive
3
DIGIFY INTERNATIONAL LTD
Member of the
Board of Directors
Theodore Efthis,
father’s name
Ilias
1
VISTA BANK (ROMANIA) SA
Independent Non-
Executive Member
of the BoD;
Chairman of the
Joint Audit & Risk
Committee
Theofanis
Voutsaras,
father’s name
Christos
1
AVINOIL SINGLE MEMBER AVENEEP
Member of the
Board of Directors
2
MOTOR OIL RENEWABLE ENERGY
(MORE) SINGLE MEMBER S.A.
Member of the
Board of Directors
3
KORAKIA S.A.
Vice-Chairman
4
LPC SINGLE MEMBER S.A.
Member of the
Board of Directors
5
KTIMA S.A.
Member of the
Board of Directors
6
CORAL GAS SINGLE MEMBER
AEVEY.
Member of the
Board of Directors
Nikolaos
Giannakakis,
father’s name
Constantinos
1
MOTOR OIL RENEWABLE ENERGY
(MORE) SINGLE MEMBER S.A.
Non-Executive
Member of the
BoD
75
NAME
S/N
NAME OF LEGAL PERSON
CAPACITY
2
NOVA INFORMATION AND
COMMUNICATION TECHNOLOGIES
S.A.
Non-Executive
Member of the
BoD
3
THREATSCENE GREECE SINGLE
MEMBER SOCIETE ANONYME
Chairman of the
BoD Non-
executive
Theodoros
Georgakopoulos,
father’s name
Nikolaos
1
TEIRESIAS SA
Member of the
Board of Directors
Antonios Mouzas,
father’s name
Athanasios
1
ELTON INTERNATIONAL TRADE
AEVE
Independent
Member of the
Board of Directors
3. At the reporting date of 31 December 2024, the following persons from the Bank’s administrative,
management and regulatory bodies held shares in the Bank:
NAME
CAPACITY
NUMBER OF
SHARES
Georgios Taniskidis, father’s name
Ioannis
Chairman, Non-Executive Member
595,000
Petros Tzannetakis, father’s name
Tzanibeis
Vice Chairman, Non-Executive Member
of the BoD
40,000
Dimetrios Kyparissis, father’s name
Apostrolos
Executive Member of the BoD,
Managing Director
122,707
Angelos Sapranidis, father’s name
Nikolaos
Executive Member of the BoD, Head of
Financial Services Sector
19,000
Theofanis Voutsaras, father’s name
Christos
Non-executive member of the Board of
Directors
8,728
Pavlos Kanellopoulos, father’s name
Dimitrios
Independent Non-Executive Member of
the BoD
7,000
Konstantinos Vatousis, father’s name
Charalambos
Head of Strategy, Shareholder
Relations and Sustainable
Development
25,205
Alexandros Vlagoulis, father’s name
Panagiotis
Head of Product & Communications
Sector
29,008
Theodoros Georgakopoulos, father’s
name Nikolaos
Head of Credit & Recoveries
22,268
76
Paschalis Giouchas, father’s name
Pelopidas
Head of Central Operations and
Technology
42,303
Antonios Mouzas, father’s name
Athanasios
Head of Brokerage Services
34,000
Dimitrios Papageorgopoulos, father’s
name Georgios
Head of the Retail Network
48,000
Ioannis Parnis, father’s name Dimitrios
Head of Human Resources
29,600
Anastasia Petsinari, father’s name
Theocharis
Head of Corporate Governance & Legal
Services
28,522
Aphrodite Samara, father’s name
Vasilios
Head of Internal Audit Department
290
Paris Economou, father’s name
Polycarpos
Head of Wholesale Banking
53,917
6. Evaluation of the corporate Governance System
Given the Bank's listing on the Athens Stock Exchange in 2023, the first review of the Corporate Governance
System (CGS) will take place with a reporting date of 31.12.2025.
7. Group Internal Audit System
The responsibility the operation of an adequate and effective Internal Audit System is carried out by the Audit
Committee and the Board of Directors of the Bank.
The Internal Audit System (IAS) according to BoG Governor’s Act 2577/9.3.2006 is a set of audit mechanisms
and procedures that covers on a continuous basis every activity of the Bank and contributes to its effective
and safe operation. The IAS shall also be adopted and applied on the basis of the size, internal organisation,
scale and complexity of operation by the Group'subsidiaries.
In particular, it aims to ensure the following objectives:
• The effective operation of the Internal Audit Department.
• Consistent implementation of the operational strategy with effective use of available resources.
• Identify and address all types of risks taken, including operational risk.
77
• Ensuring the completeness and reliability of the data and information required for the accurate and
timely determination of the Bank's financial position and the production of reliable financial statements.
• Compliance with the institutional framework governing its operation, including internal regulations and
ethical rules.
• The prevention and avoidance of misconduct and irregularities that could endanger the reputation and
interests of the Bank, its shareholders and its business partners.
In order to ensure the IAS, the Bank has delegated responsibilities to independent units (Risk Management,
Internal Audit and Regulatory Compliance) and to the BoD Committees. For the implementation of the IAS,
the Bank shall apply the ‘Three Lines Model’.
First line of defense: It concerns operational and functionally responsible units, which in their day-to-day
operations manage risks. They are also responsible for developing procedures and control points to effectively
address risks and for implementing corrective actions in cases of recognized weaknesses in procedures and
control points.
Second line of defense: It concerns the operational functions defined and staffed by the Management for
the supervision of risks, in order to support the further strengthening and/or monitoring of procedures and
checkpoints developed by the first line of defense. Such functions are the Department: Risk Management and
Regulatory Compliance.
The Risk Management Department of the Bank approaches methodically the risks related to its activity, in
order to contribute to the continuation of its activities and its sustainable development. The Risk Management
Department has the relevant Rules of Procedure. The purpose of the Risk Management Department's
procedures is to evaluate and highlight all types of risks that may affect the smooth operation and viability of
the Bank, to identify and clearly allocate roles and limits of responsibility in risk management, to effectively
manage risks and take immediate measures to eliminate them where necessary, to timely report and consult
with the Management or Supervisor on critical issues, as well as to continuously communicate and inform on
new potential risks.
At the same time, the Bank has a Regulatory Compliance Department which reports to the Bank's Board of
Directors. Compliance refers to compliance with the letter and especially the spirit of laws, institutional and
regulatory rules and principles, codes of conduct, market best practices, in order to minimize the risk of non-
compliance, financial or reputational damage that the Bank may suffer as a result of its failure to comply with
a rule.
Third line of defense: Having a high degree of independence, the Internal Audit Department provides
objective assurance on the effectiveness of the internal audit system, including how the first and second lines
of defense achieve their purpose.
78
The Internal Audit Department operates in the manner defined by the Code of Conduct and the International
Professional Practices Framework (IPPF) of the Institute of Internal Auditors, Law 4706/2020 and the relevant
decisions of the Hellenic Capital Market Commission and has the relevant Rules of Procedure.
Internal Audit Department
The Internal Audit Department is an objective, independent organizational unit for the purpose of monitoring
and improving the Bank's operations and policies regarding the Internal Audit System. It shall be operationally
subordinate to the Audit Committee of the Bank and administratively subordinate to the Managing Director.
The Department has its Rules of Procedure, which are approved by the Audit Committee and the Board of
Directors. The Internal Audit Department's Rules of Procedure are attached as an Annex to the Bank's Rules
of Procedure and form an integral part thereof, and any amendment thereto does not entail any amendment
to the Bank's Rules of Procedure.
Responsibilities
Indicatively, the Department has the following main responsibilities:
• monitoring, control and evaluation of implementation of the following:
1) the Bank's Rules of Procedure and
2) the adequacy and effectiveness of the Internal Audit System of the Bank and the Group's
subsidiaries;
3) quality assurance mechanisms; and
4) the corporate governance mechanisms and compliance with the commitments contained in the
Bank's prospectuses and business plans regarding the use of funds raised from the regulated market
and the submission of reports to the Audit Committee at least every three (3) months on the most
important issues and its proposals for the above;
• drafting reports to the audited units with any findings, and the risks arising from them and proposals
for improvement, if any.
• Adoption and establishment of a unified audit methodology of the Internal Audit Department.
• Carrying out all kinds of audits on all units, activities and providers of essential activities of the Bank's
Group.
• Informing the Board of Directors, through the Audit Committee and the Management, of the progress
and results of the audits.
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• Informing on the results of the audits carried out by the statutory auditors for the year, the statutory
auditors who carry out every three years the assessment of the adequacy of the internal audit system,
as well as other annual reports submitted to the Regulatory Authorities.
• Recommendation to the Audit Committee for the selection of external auditors to carry out the three-
yearly assessment of the adequacy of the internal audit system for the Bank and the Group and
informing the Bank of Greece of the scope of the audit.
• Conduct of audits as defined by the Hellenic Capital Market Commission.
Head of Internal Audit Department
The Head of the Internal Audit Department is appointed by the Board of Directors of the Bank, on a proposal
from the Audit Committee, is a full-time employee, personally and functionally independent and objective in
the performance of his/her duties and has the appropriate knowledge and relevant professional experience.
He/she is administratively subordinate to the Chief Executive Officer and functionally subordinate to the Audit
Committee. As Head of the Internal Audit Department, he/she may not be a member of the Board of Directors
or a voting member of committees of a permanent nature of the Bank and have close links with anyone holding
one of the above capacities in the Bank or in a Group company.
His/her main responsibilities are described in the Department’s Rules of Procedure.
The Board of Directors of the Bank, at its meeting on 11.04.2013, on the recommendation of the members of
the Audit Committee, appointed Ms Aphrodite Samara, father’s name Georgios, head of the Internal Audit
Department, in accordance with the applicable legal framework. Ms. Aphrodite Samaras is a full-time employee
of the Bank, personally and operationally independent and objective in the performance of her duties, she has
the appropriate knowledge and relevant professional experience and does not have close links with any
member of the Board of Directors of the Bank, as well as any Group company, or a member with voting rights
in committees of a permanent nature.
Ms Aphrodite Samara has many years of professional experience in financial and investment services and has
been the Internal Auditor of the Bank since 2004. She is registered with the Economic Chamber, in the register
of internal auditors of the private sector under Law 4849/21, with registration number 604. She started her
career in 1991 in the company Exelixis Investment, where she worked in the field of Stock Exchange
Investments and then in 1995 she joined ABN AMRO Bank N.V., where she took up positions of responsibility
until 1999. From 2000 to 2004 she worked as Operations Manager at ARTION A.Χ.E.P.E.Y., while in 2004 she
was appointed Head of Internal Audit at the Investment Bank of Greece S.A. (now Optima bank), a position
she holds to this day. Ms Samara holds significant expertise and professional training certifications in audit
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methods, best international internal audit practices and housing credit issues, and has been assessed for her
competence and suitability as Head of Internal Audit of the Bank by the regulatory authority (Bank of Greece).
Regulatory Compliance Department
The Regulatory Compliance Department shall be administratively independent in order to ensure the
prevention of conflicts of interest in the exercise of its responsibilities and shall be able to have unhindered
access to all data and information necessary for the fulfilment of its mission.
The Regulatory Compliance Department consists of the following sections:
• Prevention and Suppression of Money Laundering & Terrorist Financing and Reporting
(AML/CFT & Authorities Investigations) and
• Monitoring of the institutional framework (Regulatory Compliance).
Each section is led by a head.
The Regulatory Compliance Department reports operationally to the Bank's Board of Directors through the
Audit Committee, while for administrative matters it reports to the Chief Executive Officer.
The Department has its own Rules of Procedure, which are approved following a recommendation of the Audit
Committee by the Board of Directors. The Rules of Procedure of the Regulatory Compliance Department are
attached as an Annex to the Bank's Rules of Procedure and form an integral part thereof, and any amendment
thereto does not entail any amendment to the Bank's Rules of Procedure.
Responsibilities
The Regulatory Compliance Department (RC) ensures that the Bank and its subsidiaries comply with the
applicable institutional, legal and regulatory framework, codes of conduct, ethics and standards of good
practice in the provision of the banking and investment services for which they are licensed. In addition, the
Regulatory Compliance Department identifies, assesses and monitors the risks that the Bank and its
subsidiaries may face in the event of non-compliance and assists, supports and advises the Management, the
business units and the BoD officers of the subsidiaries in fulfilling the obligations arising from the above
framework. The main responsibilities of the Department are:
• Ensuring the Bank's compliance with the legal and regulatory framework related to the prevention and
suppression of money laundering and terrorist financing.
• To provide assistance and appropriate guidance to the Departments in dealing with matters within its
remit.
• The establishment and implementation of appropriate procedures and the preparation of an annual
programme in order to achieve full and continuous compliance of the Bank with the applicable
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regulatory framework and internal regulations in a timely manner and to have at all times a complete
picture of the extent to which this objective has been achieved.
• Making recommendations to the Management on issues related to the formulation and implementation
of policies and procedures of the Bank, taking into account the regulatory framework for the
supervision of the financial system.
• Ensuring that staff are constantly informed of developments in the regulatory framework relevant to
their responsibilities and providing relevant instructions for the corresponding adaptation of the
regulations and internal procedures applied by the Bank's Management and its subsidiaries, in the
event of amendments to the applicable regulatory framework.
• The position on issues of conflict of interest.
• Supervision of compliance with the deadlines for fulfilling the obligations provided for by the above
regulatory framework.
• Monitoring and checking the compliance of the Departments with the applicable regulatory framework,
Codes and Policies of the Bank, relating to the provision of the services for which it is licensed.
• Informing the Management and the Board of Directors of the Bank of any identified significant breach
of the regulatory framework or any significant deficiencies.
• The participation (at least by providing advice) in the design of new procedures on issues related to
business decision-making, together with the other Departments of the Internal Audit System.
• Receiving information from the competent Departments on deviations from the regulatory framework
identified during audits carried out by Regulatory Authorities, Internal and External Auditors, and
monitoring the implementation of the required corrective actions.
• Communicating and maintaining good relations with regulatory authorities. The Regulatory
Compliance Department has been appointed by the Bank's Management as the central point of contact
with regulatory bodies.
Head of Compliance
The Head of the Regulatory Compliance Department is a selected person with sufficient knowledge in banking
and investment activities, the placement and replacement of which is carried out by the Board of Directors of
the Bank and communicated to the Bank of Greece (hereinafter the "BoG"), together with his/her contact
details.
The Head of the Regulatory Compliance Department has also been appointed as the Bank's Competent
Manager within the meaning of Article 38 of Law 4557/2018 on the "Prevention and Suppression of Money
Laundering (ML) and Terrorist Financing (TF)". This competent Manager, as well as his/her alternate, are
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appointed by the Board of Directors of the Bank on the basis of their morality, integrity, prestige, scientific
competence, experience in corresponding work and knowledge of the Bank’s operations.
The competent Manager, as well as his/her alternate, shall not hold any other position in the Bank that conflicts
with the obligations arising from their position.
Thus, the Head of the Department has the following duties:
A) As head of the Regulatory Compliance Department, among others:
• He/she exercises supervision, control and is responsible for the proper performance of the duties
of the Compliance Officers and the proper functioning of the Department.
• He/she shall make recommendations in order to meet the identified needs in terms of material
and human resources.
• He/she supervises and monitors compliance with the regulatory framework regarding banking and
investment services, for which the Bank and its subsidiaries have been licensed. He/she notifies
the Management of any significant breach of the regulatory framework or significant deficiencies
in compliance with it.
• He/she draws up an annual programme with the aim of achieving full and continuous compliance
of the Bank with the applicable regulatory framework and its internal regulations in a timely
manner.
• He/she acts as a liaison with the regulators.
• He/she draws up an annual Action Plan and a Plan for Regulatory Compliance Audits, which is
approved by the Board of Directors after prior information and assessment by the Audit
Committee.
B) As the responsible manager:
• He/she evaluates the effectiveness of the applicable regulations in the area of ML & TF and
submits, through the Audit Committee, to the Board of Directors of the Bank an annual report on
issues of Combating Money Laundering and Terrorist Financing. This report, after evaluation by
the members of the Audit Committee, is sent to the BoG.
• He/she supervises, coordinates, monitors and manages the effective response to money
laundering and terrorist financing risks.
• He/she evaluates the findings of the Internal Audit Department, the external auditors and the
regulatory authorities and recommends corrective measures in matters of prevention and
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suppression of ML and TF. He/she submits Suspicious/Unusual Transactions Reports to the Anti-
Money Laundering Authority under Article 47 of Law 4557/2018.
• He/she maintains direct contact with the Anti-Money Laundering Authority under Article 47 of Law
4557/2018.
• He/she assesses the adequacy of knowledge on ML & TF issues of the Bank's Associated
Representatives.
• He/she investigates the training needs of staff in ML and TF and cooperates with the competent
Department to prepare and implement an appropriate annual training programme.
• He/she oversees the organisation of appropriate training sessions or seminars on ML.
• The duties of the Head of the Regulatory Compliance Department are detailed in the Department’s
Rules of Procedure.
• The Board of Directors of the Bank, at its meeting on 10.08.2023, appointed Mr. Alexandros Diolis,
father’s name Vassilios as Head of the Regulatory Compliance Department, in accordance with
the applicable legal framework. Mr. Diolis had been appointed as the Responsible Manager within
the meaning of Article 38 of Law 4557/2018 and Coordinator as per Article 38(2) of Law 4557/2018
of the Group's Responsible Managers at the meeting of the Board of Directors on 23.03.2023. He
has been assessed for his adequacy and appropriateness by the regulatory authority (Bank of
Greece).
Risk Management Department
The Risk Management Department shall have the following sections, the operation and responsibilities of which
shall be specified in its Rules of Procedure:
• Credit Risk
• Market & Liquidity Risk
• Operational Risk
• Capital Adequacy Management.
• Regulatory Relations
• Models.
The Risk Management Department reports directly to the Risk Management Committee and through it to the
Bank's Board of Directors. The Risk Management Department is administratively part of the Bank's Credit &
Recoveries Sector.
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The Department has its Rules of Procedure, which are approved following a recommendation of the Risk
Management Committee by the Board of Directors of the Bank. The Rules of Procedure of the Risk
Management Department are attached as an Annex to the Bank’s Rules of Procedure and form an integral
part thereof, and any amendment thereto does not entail any amendment to the Bank’s Rules of Procedure.
Responsibilities
The Risk Management Department is responsible for the design, specification and implementation of the risk
management and capital adequacy policy, in accordance with the guidelines of the BoD. More specifically and
indicatively, the Department:
• uses appropriate methods to manage the risks that the Bank generally assumes or to which it may be
exposed, including the use of models to predict, recognise, measure, monitor, hedge, reduce and
report them.
• specifies (with the cooperation of the competent departments/sections) the risk limits of the Bank by
identifying/determining the individual parameters by type of risk and by category of counterparty,
industry, country, currency, type of lending, form of financial securities, shares, derivatives, business
space, operation, activity, product, system, etc. and monitors their compliance, establishing the
appropriate procedures.
• defines early warning system criteria in individual and overall portfolios and recommends appropriate
procedures and measures for increased monitoring, continuously or periodically, depending on the
nature of the risks.
• recommends to the Risk Management Committee the appropriate techniques for adjusting risks to
acceptable levels.
• periodically assesses the adequacy of risk identification, measurement and monitoring methods and
systems and proposes corrective measures where appropriate.
• carries out annual stress tests (with end-of-year or half-year data) with scenarios adapted to the
nature of the Bank's activities and/or following instructions from the Bank of Greece for all types of
risks, in particular credit, market, interest rate and liquidity, analyzes their results, recommends
appropriate policies and submits the relevant results to the Bank of Greece (Credit System Supervision
Department) as defined from time to time.
• draws up the reports required for the adequate information of the Management and the Board of
Directors on matters within its competence, at least every three months. It identifies the capital
requirements and the general development of methodologies for their assessment to cover all the
risks to which the Bank is exposed and recommends their management policies.
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Head of Risk Management
The Head of the Department is appointed by the Board of Directors (on the recommendation of the Risk
Management Committee) and his/her appointment and any replacement thereof are notified to the Bank of
Greece.
Regarding the responsibilities of the Head of the Risk Management Department, indicatively, he/she:
• is involved in the decision-making process to determine the terms of financing that is not subject to
predefined or general parameters.
• reports annually to the BoD, through the Risk Management Committee, on the matters falling within
the Department's remit.
• participates in the formulation of recommendations and proposals directly to the Management and
through the Risk Management Committee of the Board of Directors for changes in the composition of
the Bank's portfolios for the restructuring/regulating of existing loans and the diversification of the
provisioning policy.
• is involved in the process of assessment by the regulatory authorities of the adequacy of financial and
regulatory capital.
• supervises and coordinates the activity of the risk management sections in the group companies.
• contributes to the prevention of incidents and generally failures and malfunctions, related to risks.
• participates in the development of quantitative and qualitative metrics, analysis, control and
management to monitor all forms of risk.
His/her detailed responsibilities are described in the Department’s Rules of Procedure.
The Board of Directors of the Bank, at its meeting on 30.06.2022, following a recommendation from the
members of the Risk Management Committee, has appointed Mr. Sotirios Papakonstantinou, father’s name
Ilias as head of the Risk Management Department, in accordance with the applicable legal framework. Mr
Papakonstantinou has been assessed for his competence and adequacy by the regulatory authority (Bank of
Greece).
Evaluation of the Internal Audit System
The Bank has established a Policy and a procedure for carrying out a periodic evaluation of the Internal Audit
System (IAS), which is included in its Rules of Procedure, in accordance with the relevant legislative framework
(Article 14(3) of Law 4706/2020), which describes how to assess the adequacy of the IAS. The Policy and
procedure shall include a description of the audit topics, the periodicity of the IAS evaluation, the scope of the
evaluation, and the assignment and monitoring of its results.
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The latest Group Internal Audit System Adequacy Assessment Report for the three-year period 2021 – 2023,
which was carried out in accordance with the provisions of BoG Governor’s Act 2577/2006, in June 2024 by
Forvis Mazars S.A., was submitted to the Bank’s Board of Directors through the Audit Committee and
subsequently to the Bank of Greece. As a result of the evaluation based on the audit procedures carried out,
nothing came to the attention of Forvis Mazars S.A. that would lead to the conclusion that there are material
weaknesses in the adequacy of the Internal Audit System of the Bank and its two subsidiaries, "Optima Factors
S.A." and "Optima asset management".
8. Remunerations Policy
The Bank has established a Remuneration Policy for the Members of its Board of Directors in accordance with
the provisions of articles 109-112 of Law 4548/2018, as in force, which has been approved by the Extraordinary
General Meeting of 22.03.2023 and fully complies with the provisions of Law 4548/2018. The Remuneration
Policy applies to the payment of fees from the fiscal year 2023 and onwards with a validity of four years, is
subject to periodic reassessment for updating purposes, in accordance with the applicable regulatory
framework and is posted, as in force, on the Bank's website
https://www.optimabank.gr/media/bzkpmf0r/p43_politiki_apodoxon_melon_ds.pdf. The Remuneration Policy
is gender neutral, as defined in Article 84(2) of Law 4261/2014.
The Remuneration Report of the members of the Board of Directors of the Bank for each financial year is
posted and remains available on the Bank's website for a period of ten years, in accordance with the applicable
law.
9. Environment, Society and Governance (ESG)
In the context of the implementation of the Bank’s action plan for the gradual integration of the expectations
set out in Annex 1 to the Single Supervisory Mechanism’s (SSM) guidance on the effective management of
ESG risks (ESG Roadmap):
A. In 2024, the Bank took the following actions with regard to the first four of the thirteen expectations:
I. Strengthening existing governance to integrate climate and environmental risk management
(CR&E risks)
A. Establishment of a Sustainable Development Management Committee
Pursuant to the decision of the Board of Directors of the Bank of 03.10.2024, a Sustainable Development
Management Committee was established at executive level as the Bank's operational committee and its Rules
of Procedure were approved and posted on the Bank's website
https://www.optimabank.gr/media/l55cyso2/c35_epitropi_diaxeirisis_viosimis_anaptyxis.pdf.
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The purpose of the Committee is:
• To provide strategic direction to the Board of Directors for the ESG (Environmental, Social and
Corporate Governance) initiatives of the Bank and the Group.
• The evaluation of the ESG Strategy before its adoption.
• The integration of the elements of the ESG Strategy into the business plan and operations of the Bank
and the Group's companies.
• Ensuring the proper implementation of the Bank's and Group's policies and procedures related to ESG,
in accordance with regulatory requirements and relevant best practices.
Composition of the Committee
The current composition of the Sustainable Development Management Committee is as follows:
Name and surname
Member of the
BoD/ non-
member
Position at the Bank
Position in the
Sustainable
Development
Management
Committee
Dimitrios Kyparissis,
father’s name Apostolos
Member of the
BoD
Chief Executive Officer (CEO),
Executive Member of the
Board of Directors
Chairman
Angelos Sapranidis,
father’s name Nikolaos
Member of the
Board of Directors
Executive Member of the
Board of Directors, Head of
Financial Services Sector
(Finance)
Permanent Member
Theodoros
Georgakopoulos, father’s
name Nikolaos
Non-Member of
the Board of
Directors
Credit & Recoveries
Permanent Member
Ioannis Parnis, father’s
name Dimitrios
Non-Member of
the Board of
Directors
Head of Human Resources
Permanent Member
Konstantinos Vatousis,
father’s name Charalambos
Non-Member of
the Board of
Directors
Head of Strategy,
Shareholder Relations and
Sustainable Development
Permanent Member
Alexandros Vlagoulis,
father’s name Panagiotis
Non-Member of
the Board of
Directors
Head of Marketing & Products
Permanent Member
Paschalis Giouchas,
father’s name Pelopidas
Non-Member of
the Board of
Directors
Head of Technology &
Operations
Permanent Member
Paris Economou, father’s
name Polycarpos
Non-Member of
the Board of
Directors
Head of Wholesale Banking
Permanent Member
Dimitrios
Papageorgopoulos, father’s
name Georgios
Non-Member of
the Board of
Directors
Head of Retail Networks
Permanent Member
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Anastasia Petsinari,
father’s name Theocharis
Non-Member of
the Board of
Directors
Head of Corporate
Governance & Legal Services
(General Counsel)
Permanent Member
Antonios Mouzas, father’s
name Athanasios
Non-Member of
the Board of
Directors
Head of Brokerage
Permanent Member
Sotirios Papakonstantinou,
father’s name Ilias
Non-Member of
the Board of
Directors
Head of Risk Management
Ordinary Participant
(non-voting)
The Chairman of the Committee may invite to its meetings any member of the Board of Directors, a member
of the Bank or a subsidiary of its Group, or any other person (employee, associate) whom the Committee
considers able to assist it in carrying out its work.
Responsibilities of the Committee
The main tasks and responsibilities of the Committee are as follows:
1. To evaluate the ESG strategy and recommend to the Board of Directors initiatives related to ESG, in
line with the strategic orientations set out in the overall Business Plan of the Bank as well as of the
Group.
2. Ensuring regulatory compliance and alignment of the Bank and the Group with the applicable
legislation at Greek and European level on ESG issues (e.g. the EU Taxonomy, the ECB's expectations
for CR&E, the Corporate Sustainability Reporting Directive (CSRD), the ESG Pillar 3 Report, and the
National Climate Action Plan of Greece, etc.).
3. Approval and monitoring of the implementation of specific ESG action plans and projects, which must
be in line with the Bank's and the Group's ESG strategy and objectives, as well as assignment of tasks
to the appropriate Departments/Units on ESG-related issues.
4. Adoption of relevant ESG policies, such as the Sustainability Policy, amendments to credit policies
incorporating ESG factors, etc.
5. Regularly review ESG-related performance indicators (KPIs), monitor the progress of ESG targets and
performance and ensure that all relevant commitments are met.
6. Adherence to the terms of the Cooperation on Alignment with International Standards and Initiatives
(e.g. Sustainable Development Goals (SDGs), UN Principles for Responsible Banking (UNPRB), UN
Global Compact, etc.) when the Committee so decides or where appropriate.
7. Assess and approve ESG reports and ensure that ESG reports comply with the relevant Standards and
Guidelines (Sustainability Report, Environmental Report, etc.).
8. Evaluation and adoption of ESG-related education and information initiatives.
9. Establish any ESG-related KPIs associated with variable remuneration schemes and performance
incentives and submit them to the relevant committees of the Bank for final approval.
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10. Update the risk management frameworks and policies of the Bank and the Group to incorporate
processes for identifying, measuring and effectively managing climate-related and environmental risks
(CR&E risks) and identifying activities and assets of the Bank and the Group exposed to CR&E risks,
as well as measuring impacts. The Risk Management Department is ultimately responsible for this
planning, but the Committee will provide support and input when needed.
11. Approval of the import of Green Products and Services.
12. Development of Sustainability Communications through reporting and external communication
campaigns.
Functioning of the Committee
The Committee shall meet regularly four times a year and/or on an ad hoc basis when necessary.
Meetings of the Sustainable Development Management Committee in 2024
In 2024, the Sustainable Development Management Committee met once (1). The participation rate of the
Members of the Committee in the above meeting was 92%.
B. Participation of the Risk Management Committee and the Audit Committee
The Bank's Risk Committee oversees climate-related and environmental risks (C&E risks), while the Bank's
Audit Committee assesses the effectiveness of internal audit, governance and risk management practices in
relation to ESG risks.
C. Department for Strategy, Shareholder Relations and Sustainable Development
The Strategy & Shareholder Relation Department, which was renamed to Strategy, Shareholder Relation and
Sustainable Development Department, was assigned the responsibilities of planning, meeting targets related
to sustainable development, as well as the monitoring of key performance indicators (KPIs) for ESG issues,
and consequently the Department's Rules of Procedure were updated.
An independent Sustainable Development Section was established with main responsibility for formulating
and recommending to the senior management and the Board of Directors of the Bank and the Group
companies, the sustainable development strategy (i.e. the alignment of the Bank's business objectives with
the creation of value for society and the environment) and the alignment of initiatives undertaken with best
good practices.
The Section of Sustainable Development of the Bank's Strategy, Shareholder Relations and Sustainable
Development Department, indicatively and not restrictively, has the following individual responsibilities:
▪ The development of the Group's sustainable development strategy.
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▪ The design of targets in line with the sustainable development strategy and the ESG (Environment-
Society- Governance) criteria set for their monitoring.
▪ The monitoring of best practices at national and international level on sustainable development issues
and corresponding ESG criteria.
▪ The submission of recommendations and the internal coordination for the integration of the Bank into
non-financial indicators and international initiatives.
▪ The drafting of regulatory or other non-financial reports on matters within its remit.
▪ The drafting, in cooperation with the relevant departments/sections of the Bank, of communication
content and reports on sustainable development issues and ESG indicators.
▪ The coordination of the involved sections, departments and Group companies for the collection of
non-financial data.
▪ To respond to requests/questions received from investors or other interested parties regarding the
Bank's performance on sustainable development issues and ESG indicators.
▪ The coordination of the development of training material for employee training programs on
sustainable development issues.
D. Definition of specific roles
i. ESG Coordinator
A position of ESG Coordinator was established in the Department for Strategy, Shareholder Relations and
Sustainable Development with responsibilities, inter alia, to participate in the formulation and
recommendation of the Group’s sustainable development strategy, to manage ESG initiatives, to monitor
the broader ESG framework with a view to submitting proposals for integrating standards or best practices,
to ensure alignment with regulatory and preventive requirements, to promote the Bank’s sustainable
development to its stakeholders (investment community, customers, shareholders, etc.), to communicate
with institutional bodies and regulatory authorities on ESG issues, to coordinate employee training
programmes on sustainable development issues, to cooperate with the competent Department to identify
any risks related to environmental, social or governance issues (ESG), as well as opportunities that the
Bank could take advantage of, etc. The responsibilities of the ESG Coordinator are detailed in the
Department’s revised Rules of Procedure, which were approved by the Bank’s Executive Committee at its
meeting on 06-12-2024.
ii. ESG Risk Officer
A position of ESG Risk Officer was also established in the Regulatory Relations Section of the Risk Management
Department, with the following responsibilities described in the revised Rules of Procedure of the Risk
Management Department, which were approved by decision of the Board of Directors of 16.01.2025:
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▪ To work closely with other sections of the Department and internal teams, including regulatory
compliance, legal services, Credit & Recoveries and sustainable development, in order to ensure
smooth integration of ESG requirements.
To prepare risk reports for internal and external stakeholders, highlighting trends, vulnerabilities and
proposed mitigation actions.
▪ To review and update risk policies, procedures and limits by integrating CR&E risks and aligning them
with the Bank's broader strategic objectives.
▪ To support the design and implementation of scenario analysis exercises, stress testing, development
of ICAAP / ILAAP sections and assist wherever required with ESG risks.
E. Sustainable Development Policy
By decision of the Board of Directors of 16.01.2025, following a relevant recommendation of the Sustainable
Development Management Committee, the Bank adopted a Sustainable Development Policy which is included
in its Rules of Procedure and is posted on its website:
https://www.optimabank.gr/media/wegdtzyo/p60_politiki_viosimis_anaptyxis.pdf
This Policy was drawn up on the basis of Directive (EU) 2022/2464 of the European Parliament and of the
Council of 14
th
of December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive
2006/43/EC and Directive 2013/34/EU, as regards corporate sustainability reporting, which was already
transposed into Greek law by Law 5164/2024 and in accordance with Article 14(3)(l) of Law 4706/2020.
The purpose of the Policy is to lay the foundations for the integration of sustainability into all of the Bank's
operations, with the aim of creating value for the protection of the environment, promoting social welfare and
strengthening governance practices.
II. Training of the Board of Directors and senior management on CR&E risks.
A. On November 8, 2024, a specialized external consultant of the Bank conducted an informative presentation
- training program for the members of the Board of Directors on ESG issues. The programme included a full
presentation of climate-related and environmental risks, how CR&E risk assessments should be integrated into
decision-making, the importance of CR&E risk management and integration into strategy development, and
the role of the BoD in overseeing CR&E risk management.
B. In addition, a special training session for the Executive Committee (ExCo) and other senior management
executives was held on 6 December 2024 to provide the above persons with the necessary knowledge and
tools to effectively oversee any ESG-related issues and address CR&E risks within their strategic and
operational responsibilities.
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III. Carrying out high-level analysis scenarios
The Bank completed a Qualitative Materiality Assessment, in the context of which a comprehensive qualitative
materiality assessment was carried out to assess the potential magnitude of the impact of climate-related and
environmental risks (CR&E) on all other existing risk categories of the Bank and the associated risks were
assessed. In addition, the Bank has already started and is carrying out a quantitative analysis exercise of CR&E
risk scenarios.
IV. Business environment analysis
The Bank has adopted a structured approach to the analysis of the business environment taking into account
climate-related and environmental risks (CR&E). In this context, a business environment analysis report
assessing the potential impact of CR&E risk on Greece, the financial services sector, the Bank itself, as well as
its customers was finalised in 2024, and a process was further defined to review the completeness and
timeliness of the analysis in the future (with the analysis being assessed at least annually). Under this
approach, the Bank ensures that information on its CR&E risks is kept up-to-date and aligned with evolving
factors.
B. In January 2025, the Bank submitted a progress report to the Bank of Greece on the progress made in
implementing the Bank's updated action plan (ESG Roadmap).
C. In February 2025, the Sustainable Development Management Committee at its meeting of 21 February
2025:
- Decided to extend the roadmap in order to meet the expectations of SSM No 5,6,7,8,9,11 on the effective
management of ESG risks (ESG Roadmap). In this context, it approved a timeline for the implementation of
these expectations through which the Bank seeks to improve its understanding of the impact of environment
and climate-related risks (CR&E) on its business model and on existing risks. The Bank aims to integrate
climate-related and environmental (CR&E) risks into its risk management framework by identifying existing
risk management processes that should take into account CR&E risk. In addition, the distribution of
responsibility across all three lines of defense is planned, for the holistic monitoring of climate and
environmental risks. This action plan (ESG Roadmap) incorporating the above expectations of the SMM was
approved by the Board of Directors of the Bank at its meeting on 05.03.2025 and was subsequently submitted
to the Bank of Greece.
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- Recognized, in accordance with the guidelines of the European corporate sustainabiltiy reporting directive
(CSRD), through the Double Materiality Analysis process, the following issues as the most important for the
sustainable operation of the Bank:
Identified Material Topics 2024:
- E1 - Climate Change
- E5 - Circular Economy
- S1 - Own Workforce
- S4- Consumers and end-users
- Sector Specific - Innovation and Digitalization
- G1 - Business Conduct
Based on these issues, the Bank makes specific disclosures within the sustainability report that is part of the
Optima bank Group’s annual management report for the year 2024.
- It has adopted a comprehensive sustainable development strategy (with specific commitments, targets and
performance indicators) to monitor the implementation of the objectives set in the fields of the environment
(E), society (S) and corporate governance (G), as formulated by the Department for Strategy, Shareholder
Relations and Sustainable Development, in cooperation with the relevant business areas and the guidance of
an external consultant. The above targets are based on 2024, are planned to be implemented on a two-year
horizon (2026) and are incorporated in the sustainability report that is part of the Optima bank Group’s annual
management report for the year 2024.
Other information on ESG matters can be found in the sustainability report that is part of the Optima bank
group management report for the year 2024.
10. Transactions with Related Parties
The Bank has established and applies policies and procedures regarding Transactions with Related Parties in
order to properly identify, assess, approve and disclose its Related Party transactions. Detailed information is
included in note 39 to the financial statements.
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Alternative performance measurement indicators (‘APMs’) at Group level
In conjunction with the financial information reported under IFRSs, this Board of Directors Report also includes
financial indicators that are alternative performance measurement indicators that seek to follow the orientations of
the APMs issued by the European Securities and markets Authority (‘ESMA’). In accordance with the definition of
ESMA, a non-IFRS size is a measure for the calculation of historical or future financial performance, financial position
or financial flows that excludes or incorporates amounts that would not have the corresponding adjustments to the
comparative IFRS.
The following AIMA shall include or exclude amounts non defined by IFRSs, with the aim of a consistent basis for
comparison between economic periods or uses and the provision of information on events of non recurring nature.
However, performance measurement indicators not defined in IFRSs are not a substitute for IFRSs.
Amounts in EUR 000
Name
Description
2024
2023
Loans and
receivables from
pre-provisions
customers
Loans and receivables from clients measured at amortised cost before provisions for
impairment of loans and other receivables from clients - Calculation: Loans and receivables
from customers + Provisions for impairment of loans and other receivables from customers
3,657,499
2,458,509
Provisions for
write-downs of
loans and other
claims by clients
Provisions for write-downs of loans and other claims by clients
44,901
27,595
Obligations to
customers
Customer deposits and checks payable -
Calculation: Demand Deposits + Savings Deposits + Term Deposits + Restricted Deposits +
Other Deposits + Checks Payable
4,643,412
3,191,804
Index of loans
after provisions to
deposits (LDR)
Carrying amount of loans and receivables from clients measured at amortised cost after
provisions to customer deposits and checks payable - Calculation: Loans and receivables
from customers / (Cash deposits + Savings deposits + Term deposits + Restricted deposits
+ Other deposits + checks payable)
77.80%
76.16%
Total operating
costs
Total operating costs
57,879
56,939
Profit or loss
before tax
Total results before provisions and taxes
196,844
136,018
Risk weighted
assets (RWAs)
Assets and off-balance sheet items, determined on a risk-weighted basis, in accordance
with Regulation (EU) 575/2013
3,988,249
2,685,788
Common Equity
Tier 1 capital ratio
(CET 1)
Common equity Tier 1 capital, under Regulation (EU) 575/2013, including the profit in the
period and the supervisory transitional arrangements for the effect of IFRS 9 on risk-
weighted assets.*
14.40%
17.67%
Total capital
adequacy ratio
(TCR)
Total supervisory capital, applying the provisions of Regulation (EU) 575/2013 and the
supervisory transitional arrangements for the effect of IFRS 9, in respect of risk-weighted
assets, integrating period profits.*
14.40%
17.67%
Liquidity coverage
Ratio (LCR)
The liquidity coverage ratio as defined by Directive (EU) No 2015/61 (amended by Directive
(EU) No 2018/1620) is the amount of the pool of unencumbered high-quality liquid assets
held by a credit institution, toward the projected net cash outflows, in order for a bank to
survive a one-month stress test scenario.
251.44%
248.88%
Net stable funding
ratio (NSFR)
The net stable funding ratio is defined as the amount of available stable funding in relation
to the amount of fixed funding required.
124.83%
131.83%
* The funds have been calculated by including the profits of the period by incorporating a dividend distribution provision, which is
under the approval of the regular General Assembly.
95
Board of Directors’ explanatory report of Optima bank S.A.
This Explanatory Report of the Board of Directors of Optima bank S.A. (hereinafter the "Bank") on the 2024
financial year submitted to the Ordinary General Meeting of the Bank's shareholders contains detailed
information with reference date 31.12.2024, in accordance with Article 4(7) of Law 3556/2007 and following
the order of presentation in that provision.
A) Structure of the Bank's share capital
On December, 31
st
2024, the Bank’s share capital amounted to two hundred and fifty-four million five
hundred and twenty thousand seven hundred and eighty-nine euros and ninety cents (EUR
254.520.789.90), divided into seventy-three million seven hundred and seventy-four thousand one hundred
and forty-two (73.774.142) common registered voting shares with a nominal value of three euros and forty-
five cents (EUR 3.45) each.
The Bank's shares are registered, dematerialized and admitted to trading on the Main Market of the Athens
Exchange in their entirety.
Each share incorporates all the rights and obligations arising from Law 4548/2018 and the Bank's Articles
of Association.
Each share confers the right to one vote at the General Meeting of the Bank's shareholders. The shares are
indivisible.
B) Restrictions on the transfer of shares of the Bank
The Bank's shares are admitted to trading on the Main Market of the Athens Stock Exchange and may be
transferred in accordance with the Law.
The Bank's Articles of Association do not provide for any restrictions on the transfer of its shares.
C) Significant direct or indirect participations within the meaning of Law 3556/2007
As of 31 December 2024, the Bank had been notified, in accordance with the provisions of Law 3556/20027,
of the following significant shareholdings in its share capital:
96
Note
Number of
shares
Participation rate
MOTOR OIL (HELLAS) S.A.
1
6,602,168
8.95%
IOANNIS VARDINOYANNIS
2
5,355,525
7.26%
1. The above 6,602,168 shares of the Bank are indirectly held by MOTOR OIL (HELLAS) CORINTH
REFINERIES S.A., through its 100% owned subsidiary IREON INVESTMENTS LTD,
2. The above 5,355,525 shares of the Bank are held indirectly by Mr Ioannis V. Vardinoyannis, through
his controlled companies within the meaning of Article 3(1c) of Law 3556/2007:
- CANELO HOLDINGS LIMITED (holder of 4,298,167 shares of the Bank, i.e. 5.83%) and
- BAYNOUN LIMITED (owner of 1,057,358 shares of the Bank, i.e. 1.43%).
D) Shares conferring special control rights
There are no shares of the Bank which confer special control rights on their holders.
E) Restrictions on the right to vote
The Bank’s Articles of Association shall not contain any restrictions on the voting rights attached to the
shares of the Bank or on the time limits for their exercise.
F) Agreements of the Bank’s Shareholders
No agreements between the Bank’s shareholders involving restrictions on the transfer of shares or on the
exercise of voting rights resulting from them have been notified to the Bank.
G) Rules for the appointment and replacement of members of the Board of Directors and
amendment of the Articles of Association
The rules set out in the Bank's Articles of Association for the appointment and replacement of members of
the Board of Directors, as well as for the amendment of its provisions, do not differ from the relevant
provisions laid down in Law 4548/2018 and Law 4706/2020, as in force.
H) Competence of the Board of Directors to issue new or purchase own shares
According to the Bank's Articles of Association:
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a) A decision of the General Meeting is required for the capital increase;
b) By decision of the General Meeting and for a period not exceeding five years, the Board of Directors may
be granted the right to decide by a majority of at least two thirds of its members to increase the share
capital, in whole or in part, by issuing new shares for an amount not exceeding three times the capital
existing at the date when the relevant authorization was granted to the Board of Directors. This
authorization to the Board of Directors may be renewed by decision of the General Meeting for a period not
exceeding five years for each renewal. Each renewal shall take effect on the expiry of the period of validity
of the previous one. The above shall apply mutatis mutandis in the case of a decision to issue a bond loan
with convertible bonds in accordance with Article 71 of Law 4548/2018.
The Bank did not establish an own share purchase programme in 2024.
I) Significant agreements that enter into force, are amended or expire in the event of a
change of control following a public offering
There are no significant agreements of the Bank which enter into force, are amended or expire in the event
of a change in the control of the Bank following a public offering.
J) Agreements concluded by the Bank with members of the Board of Directors or its staff
providing for compensation in the event of resignation or dismissal without valid reason or
termination of their term or employment due to a public offering
According to clause 5.4. of the approved Remuneration Policy of the Bank, contracts with members of the
Board of Directors of the Bank may include special terms providing for specific compensation in the event
of their termination without good reason, setting the reasonable amount thereof that may not exceed the
total of 24 gross monthly earnings.
In this context, the Bank has concluded agreements with Members of its Board of Directors (Chairman,
Managing Director) providing for the payment of compensation equal to the total of 24 gross monthly
earnings in the event of termination of the contract by the Bank without good reason.
Finally, there are no agreements concluded by the Bank with members of the Board of Directors or its staff
that provide for compensation in the event of resignation or termination of their term or employment due
to a public offering.
98
Optima bank’s Group Sustainability statement
General Information
ESRS 2 General Disclosures
Basis for Preparation
BP-1 – General basis for preparation of Sustainability Statement
The current Sustainability Statement outlines Optima bank's Group (“Group”) performance in the
Environment, Social and Governance (ESG) field covering the period from 1 January 2024 to 31 December
2024. The Sustainability Statement has been prepared on a consolidated basis, at the Group level, same
as the financial statements. The Group consists of Optima bank S.A. (“Bank” or “Optima bank”) and its
subsidiaries.
The Double Materiality Assessment (“DMA”), which has been conducted for the identification of Impacts,
Risks and Opportunities (“IROs”) extended to Group’s entire value chain, where feasible. The Sustainability
Statement covers the Group’s own operations and the upstream and downstream value chain. More
specifically, the Group's upstream activities encompass services and products that are provided by its
suppliers, and financing, geographical and regulatory environments in general. Moreover, Group’s own
operations (downstream) include all activities of the Bank and its subsidiaries, such as corporate banking,
retail banking, investment banking, asset management, factoring and leasing services. The Group's
downstream activities are also scrutinized, primarily involving corporate and retail customers.
No subsidiary included in the consolidation exempted from consolidated or individual sustainability
reporting. No information that corresponds to intellectual property, know-how, or innovation related has
been omitted. Furthermore, the Group doesn’t exempt from disclosure impending developments or matters
that are currently under negotiation.
BP-2 – Disclosures in relation to specific circumstances
The Group applies the definitions of the short-term, medium-term and long-term time-horizons as defined
by the European Sustainability Reporting Standards (“ESRS”).
The Sustainability Statement doesn’t include metrics related to upstream and/or downstream value chain
data or sources of estimation and outcome uncertainty.
The Sustainability Statement is the Group’s first sustainability related report, so there are no applicable
changes in preparation or presentation of sustainability information compared to the previous reporting
periods, nor any identification of reporting errors in prior periods. The Sustainability Statement discloses
information according to the Corporate Sustainability Reporting Directive (“CSRD”) which was incorporated
into the Greek legislation by Law 5164/2024. The Group also used a disclosure from the GRI Standards in
ESRS S4 (GRI 418-1 b).
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Incorporation by reference
Disclosure Requirement
Reference
GOV-1 – The role of the administrative, management
and supervisory bodies (GOV-1 21 c)
GOV-1 – The role of the administrative, management
and supervisory bodies (G1.GOV-1 5 b)
Statement of Corporate Governance
Statement of Corporate Governance
Even though the Group’s average number of employees does not exceed the average number of 750
employees during the fiscal year 2024, the Sustainability Statement discloses information as required by
ESRS S1 and ESRS S4, which have been assessed to be material from the DMA, due to the Group’s
commitment to enhance accountability and transparency.
Governance
GOV-1 – The role of the administrative, management and supervisory bodies
In accordance with Article 9 of the Articles of Association of Optima bank and Article 77 par. 1 of Law
4548/2018, Optima bank is governed by the Board of Directors (“BoD” or “Board”). The BoD, which
operates in compliance with Greek legislation and the Bank’s Articles of Association, was elected by the
Extraordinary General Meeting decision dated 22.03.2023 for a four-year term, ending upon the election
of the new Board of Directors by the Ordinary General Meeting in the year of its expiration (i.e., until
10.09.2027), and was constituted into a body by its decision dated 23.03.2023. Pursuant to the decision of
the Ordinary General Meeting of May 23, 2024, the number of BoD was increased from ten (10) to eleven
(11) with the election and addition of a Non-Executive Member for the rest of the Board’s term, which has
been elected by the Ordinary General Meeting of Shareholders of 23.03.2023, i.e. until 10.09.2027 at the
latest,and the Board was reconstituted into a body by its decision dated 27.05.2024, is comprised of eleven
(11) members elected by the General Meeting of Shareholders. Following the resignation of a female
Independent Non-Executive Member of the Board of Directors, as of 31st.10.2024, the Board of Directors
unanimously resolved pursuant to article 82 of Law 4548/2018 and article 10 par. 2 of the Bank's Articles
of Association, to continue the management and representation of the Bank, without replacing the resigned
Member temporarily, until its replacement by a new Board member who meets the individual and collective
suitability criteria in accordance with the applicable legislation and the Suitability Policy for Members of the
Board of Directors of the Bank, and was reconstituted into a body with the remaining members. Therefore,
on 31.12.2024, the Board of Directors consisted of ten (10) members, two (2) executives and eight (8) are
non-executives, of whom four (4) are independent, making up to 40% of the total.
The CVs of the BoD members are available on the corporate site of Optima bank and the Statement of
Corporate Governance, providing detailed information about their relevant experience in the sector.
Moreover, even though there is no employee representation at the BoD, trade unions do hold co-
determination rights. For any substantial operational changes, it is required to inform or consult with the
most representative trade unions, adhering to the applicable legislative framework in effect at that time.
To monitor, manage and oversee impacts, risks, and opportunities, during the reporting period,
responsibilities and roles have been developed throughout the Group, at the Board, Management, and
operational level. This governance structure enables sustainability issues to be embedded in the key
business processes and ensures the oversight of ESG related issues (including impacts, risks and
opportunities) across three levels: Board Level, Management level and operational level.
The administrative, management and supervisory bodies are the BoD and its committees: the
Remuneration and Nominations Committee, the Audit Committee the Risk Management Committee
(“RMC”), the Executive Committee (“ExCo”) and the Head of the Internal Audit. More specifically, regarding
100
the oversight of impacts, risks and opportunities, the Risk Management Committee, oversees climate-
related and ESG risks, the Audit Committee reviews the sustainability- related statements and directs the
internal audit of climate-related and ESG risks framework implementation and the Remuneration and
Nominations Committee, which is responsible for aligning the performance objectives of senior
management with the sustainable development strategy and risk appetite. For more information regarding
the administrative, management and supervisory bodies (expertise and relevant expertise), please refer to
the Corporate Governance Statement.
At senior management level, the Sustainability Management Committee (“SMC”) reviews, approves, and
monitors the implementation of Sustainability Strategy. At operational level, the Strategy, Investor
Relations (“IR”) and Sustainable Development Division, defines and leads any sustainability- related
initiatives. The Sustainable Development Department, that belongs to the aforementioned Division,
develops and recommends the sustainability strategy to senior management and the Board, ensuring
business goals align with social and environmental value creation while following best practices. On top of
this, the ESG Coordinator ensures the effective implementation of ESG objectives. Finally, there is a cross
functional ESG Community, which is responsible for incorporating climate-related and environmental risks
(“CR&E”) considerations into daily operations, decision-making and performance management.
Board of Directors
The BoD has the ultimate responsibility for overseeing the sustainability strategy and any CR&E related
issues, performance, and reporting. The Board also ensures that the sustainability strategy is aligned with
the Group’s vision, mission, and values. ESG elements are included in the Board meetings agenda, as per
the best international practices.
The Senior management is accountable for implementing the CR&E policies and procedures, and the CR&E
risks’ integration into the core business functions and operations of the Group. Senior management also
establishes a clear governance structure and assigns roles and responsibilities for CR&E at different levels
of the entity. Finally, senior management is fostering a culture of climate and environmental awareness
and commitment among the employees and stakeholders. The Management Body approves the institutions’
environmental strategy and risk management framework along with the corresponding policies and
oversees their implementation.
In specific, the Risk Management Committee oversees ESG risks, advises the Board on setting and
monitoring risk tolerance levels and assesses the application of the risk strategy by senior management.
RMC, also reviews the entity’s solvency and liquidity profile and submits for final approval to BoD the Risk
Appetite Framework (RAF). The Audit Committee provides assurance to the Board of Directors regarding
ESG risks thus it assesses the effectiveness of internal controls and governance framework, and reviews
established risk management practices with respect to ESG risks.
Sustainability Management Committee
In the context of the enhanced Corporate Governance structure for ESG issues, a Sustainability
Management Committee was established in 2024. The SMC consists of the Chief Executive Officer who
chairs the committee, and heads of departments as permanent members such as Strategy, IR and
Sustainable Development, Legal and Corporate Governance, Credit and Recoveries, Technology and
Operations, Retail Networks, Wholesale banking, Brokerage, Finance, Human Resources (“HR”), Products
and Marketing, and the Head of Risk Management (as a non-voting attendee). The Chairman may invite
any Board member, executive, or other relevant individuals to attend the meetings. SMC members must
act in the Group's best interest, maintain confidentiality, disclose conflicts of interest, prepare for and attend
meetings, and align their operation with ESG targets.
101
Main duties and responsibilities include:
• Evaluating and suggesting ESG strategies to the BoD.
• Ensuring regulatory compliance with national and European ESG legislation.
• Approving and monitoring ESG action plans and projects.
• Approving ESG policies and amendments.
• Reviewing ESG performance indicators and goals.
• Engaging with international ESG standards and initiatives.
• Evaluating and approving ESG reports.
• Approving ESG-related training and awareness initiatives.
• Setting ESG-related Key Performance Indicators (“KPIs”) to be linked to remuneration schemes.
• Updating risk management frameworks to integrate climate-related and environmental risks.
• Approving the introduction of Green Products and Services.
• Developing sustainability-related communications.
The SMC meets regularly on a quarterly basis or as needed. Meetings require a quorum of half plus one of
its members. Decisions are made by absolute majority vote of the present members, with the Chairman
having a casting vote in case of a tie. The SMC is supported by a secretary, who manages meeting logistics,
prepares agendas, and documents minutes. The SMC reports significant issues to the Executive Committee
and submits quarterly reports to the Board of Directors. It has full access to necessary information and
resources, including external advisors, to fulfill its mandate.
Strategy, IR and Sustainable Development Division
The Strategy, IR and Sustainable Development Division reports to the Chief Executive Officer
(“CEO”) of the Bank and is supervised by the Head of Strategy, IR and Sustainable Development Division.
Its key responsibilities include defining the strategic direction of the Group, developing strategic and
business plans aligned with the Group’s vision, driving business growth, managing shareholder relations
and investor communications, while also setting sustainability goals and monitoring ESG performance.
The Sustainable Development section of the Strategy, IR and Sustainable Development Division,
formulates and proposes the sustainable development strategy to senior management and the Board of
Directors, ensuring the alignment of business objectives with value creation for society and the
environment. It monitors best practices at national and international levels regarding sustainable
development, designs specific goals aligned with the strategy, and oversees their implementation. The
Sustainable Development Department coordinates the inclusion of the Group in non-financial KPIs and
international initiatives and prepares supervisory and regulatory non-financial reports.
The ESG Coordinator position has been assigned to the Strategy, Investor Relations and Sustainable
Development Division, with the aim of overseeing all sustainability initiatives and ensuring the faster, more
effective adoption of ESG practices, in collaboration with the Head of Strategy, Investor Relations, and ESG.
The ESG Coordinator proposes actions on sustainable development issues in cooperation with the relevant
departments and monitors the KPIs related to the targets set. Moreover, the ESG Coordinator participates
in the formulation of the sustainable development strategy and responds to requests from investors or
other interested parties regarding the Group’s ESG performance. The ESG Coordinator is also responsible
for the development of non-financial reports that arise as a legislative or regulatory requirement. The ESG
Coordinator collaborates with the relevant divisions (especially the Risk Management Division) to identify
any risks related to environmental, social, or governance (ESG) issues, as well as opportunities that the
Group could exploit. Communication with institutional bodies and supervisory authorities on ESG issues,
initiating the Group’s participation in international bodies and non-financial indicators, and coordinating
employee training programs on sustainable development issues to ensure that all employees are aware of
sustainability best practices, is among the coordinator’s responsibility as well.
102
Other business units
The business units and functions are responsible for incorporating ESG considerations into their daily
operations, decision-making and performance management.
It should be noted that there has been a definition of roles and responsibilities for CR&E risks management
within the Group at the individual level. Clear lines of communication throughout the Bank (committees)
are created, by reviewing the existing committee structure and producing alternative proposal / amended
committee structures and reporting lines (where appropriate) to support CR&E risk oversight including
allocation of responsibility for CR&E risk oversight to the relevant committees. The management of impacts,
risks, and opportunities is dynamically embedded in the organizational structure and continuously
integrated with internal functions and units. This ensures a comprehensive approach to ESG governance,
effective risk assessment, mitigation measures if needed and enhanced decision-making. The Group is also
continuously working on integrating dedicated controls and procedures into the management of ESG-
related issues to ensure better and more effective management.
The Sustainability Management Committee endorses for approval by the Board of Directors, the
sustainability goals and targets related to material impacts, risks, and opportunities. Internal experts from
various departments collaborate with the Strategy, IR and Sustainable Development Division to define
clear, measurable goals that align with the overall strategy. Once approved by the Sustainability
Management Committee, progress is monitored through regular reviews, data analysis, and key
performance indicators. This continuous evaluation enables both the Sustainability Management Committee
and the Board to track advancement, modify strategies as necessary, and ensure that the targets remain
pertinent. Instruments such as performance dashboards and sustainability statements offer valuable
insights, thereby maintaining a sustained focus on the achievement of sustainability objectives.
Training sessions are regularly conducted in order to enhance skills and expertise related to material
impacts, risks and opportunities and ESG issues in general. In 2024, two ESG related training sessions, one
dedicated to the BoD members and one addressed to all ExCo members (11 members including the CEO),
and the Heads of critical divisions (i.e. Risk, Regulatory Compliance and Internal Audit) for the
implementation of Sustainability strategy. Participation in conferences or other training courses are also
available either through the social network or other domestic and international associations that the Group
is a member.
At this point, special mention should be made to the Group’s dedication to adhering to the highest ethical
standards and corporate governance principles, to ensure transparency and responsible operations across
all aspects of its business. The goal is to enhance the effectiveness of its actions while fostering meaningful
communication with shareholders and stakeholders in general. The administrative, management, and
supervisory bodies are tasked with overseeing and guiding the ethical and business conduct of the Group.
The Board of Directors is responsible for evaluating the implementation and effectiveness of the Group’s
corporate governance system. It ensures compliance with ethical standards, legal requirements, and
corporate governance principles. Also, the Board is responsible for defining the core values, strategic
orientation, and business conduct, and continuously monitoring their observance. The BoD is also
responsible for approving the strategy and business plan and monitoring their execution. The BoD regularly
reviews and assesses the relevance of internal documents, regulations, policies, and procedures. It also
evaluates the Code of Ethics and Conduct and its implementation, aiming to promote a culture of integrity
and ethical behavior. This includes ensuring that the structure, responsibilities, and reporting lines of
relevant departments are clearly defined, fostering accountability, and supporting efficient decision-making.
Such an approach is essential for maintaining board-level accountability and strategic oversight.
103
Furthermore, the BoD regularly assesses potential opportunities and risks related to business conduct and
examines measures to avoid or mitigate such risks. It ensures that the Group's values and strategic plans
are aligned with its corporate strategy and organizational culture. The BoD and senior management set the
standard for the characteristics and behaviors that define the corporate culture and exemplify its
implementation. Together, they use various tools and techniques to embed the desired culture into the
relevant systems and processes.
The Audit Committee is responsible for overseeing overall compliance with regulatory obligations,
particularly with respect to the quarterly evaluations and reports required by regulatory authorities. These
reports cover various business conduct matters, including money laundering, conflicts of interest, anti-
monopoly measures, and customer/consumer protection and transparency, among others. The
Remuneration and Nominations Committee ensures that the interests of the shareholders are properly
protected regarding the selection and nomination of the members of BoD and the members of the Audit
Committee who are not members of the BoD and their remuneration. However, the Board of Directors
retains full responsibility to act and defend the interests of the Group.
The Risk Management Committee ensures the development and continuous effectiveness of the internal
risk management system and its integration into the process of making business decisions in all forms of
risks, including operational, across the full range of the Bank’s divisions and its subsidiaries (e.g.,
monitoring, reporting, and addressing business conduct issues). The Executive Committee and the Internal
Audit Division are responsible for implementing and enforcing policies and procedures related to business
conduct, ensuring that any issues are promptly identified and addressed.
The expertise of the administrative, management, and supervisory bodies in business conduct matters is
reflected in their CVs that exist in the Corporate Governance Statement. Additionally, for the Members of
the Board of Directors, specifically, the individual suitability criteria are met, namely in the adequacy,
knowledge, skills, and experience, as well as in the reputation, honesty, integrity, and assurances of ethical
integrity, as referred to in the Suitability Policy of the members of the Board of Directors. Additionally, the
Corporate Governance Statement includes the CVs of the Executive Committee Members and of the Head
of the Internal Audit Division.
GOV-2 – Information provided to and sustainability matters addressed by the administrative,
management and supervisory bodies
The Group begun in 2024 to set the foundations of its sustainability strategy through the development of
a comprehensive action plan that is about to be implemented within the reporting period and throughout
2025. To this end, and in full alignment with the CSRD requirements, the Group has identified the material
ESG related impacts, risks and opportunities. Based on this, a sustainability strategy is developed with
concrete goals and KPIs to monitor progress. These targets and KPIs are approved by the Sustainability
Management Committee. Progress will be monitored biannually. Alongside, there has been designed and
submitted to Bank of Greece an action plan for the four first expectations of the Single Supervisory
Mechanism (SSM) for the management of climate-related and environmental risks. On 5.3.2025, the BoD
approved the integration of the six remaining expectations, (Nos. 5, 6, 7, 8, 9.1 and 11) of the SSM into
the Bank's action plan and was submitted to the Bank of Greece.
The Risk Management Division uses appropriate methods to manage and address the risks associated with
business activity and the internal and external environment in a methodical manner, with a view to
contributing to the business continuity and to promotion of sustainable development. The Risk Management
Division suggests to the Risk Management Committee the appropriate techniques for adjusting risks to
acceptable levels. The RMC is responsible for keeping the BoD updated on all matters related to the risk
104
strategy and the level of risk tolerance in the performance of its operational tasks. This approach ensures
that all types of risks are effectively covered, controlled, managed, and coordinated across all functional
levels. RMC also ensures the development and ongoing effectiveness of the internal risk management
system. On top of this, RMC confirms the integration into the business decision-making process, regarding
all forms of risk management risks, throughout the range of activities and the units of the Group including
decisions on major transactions or/and investments. Therefore, BoD considers impacts, risks and
opportunities when overseeing strategy and risk management process.
The BoD regularly addresses all the material impacts, risks and opportunities by tracking and reviewing the
status and effectiveness of the management strategies and actions regarding sustainability matters.
According to the Rules of Procedures of Sustainability Management Committee. The Sustainability
Management Committee has the responsibility of submitting a quarterly report in writing to the BoD
regarding the progress of the matters within its scope of responsibility. This includes addressing the
sustainability matters identified by the DMA for the reporting period, the results and effectiveness of
policies, actions, metrics and targets.
GOV-3 – Integration of sustainability-related performance in incentive schemes
So far, there is no established link between remuneration and ESG criteria. The remuneration of the
members of the BoD is not directly influenced by the sustainability-related performance. However, as the
importance of sustainable business practices grows, Remuneration Policy for the members of the BoD will
incorporate ESG criteria to align incentives with the Group’s sustainability goals. This could involve setting
specific ESG targets and metrics, such as reducing carbon emissions, improving energy efficiency, and
enhancing social responsibility initiatives that, when achieved, would impact specific forms of variable
remuneration. As such, climate-related factors have not yet been considered in determining the
remuneration of members of the BoD. GHG emission reductions and other climate related considerations
do not constitute relevant KPIs in performance assessments and remuneration structures. However, the
Group intends to incorporate such criteria into its remuneration framework in the forthcoming years to
align with its sustainability objectives. The Human Resources Division in cooperation with the Strategy, IR
and Sustainable Development Division will proceed to the development of any ESG-related KPIs, which are
linked to variable remuneration schemes and performance incentives. These KPIs will be approved by the
relevant Committees (Sustainability Management Committee and Remuneration and Nominations
Committee). The proportion of variable remuneration dependent on sustainability-related targets and/or
impacts will be determined during this process.
GOV-4 – Statement on due diligence
CORE ELEMENTS OF DUE
DILIGENCE
PARAGRAPHS IN THE SUSTAINABILITY STATEMENT
a) Embedding due diligence in
governance, strategy and business
model
GOV-2 – Information provided to and sustainability matters addressed by
the administrative, management and supervisory bodies
GOV-3 – Integration of sustainability-related performance in incentive
schemes
SBM-3 – Material impacts, risks and opportunities and their interaction with
strategy and business model
b) Engaging with affected
stakeholders in all key steps of the due
diligence
GOV-2 – Information provided to and sustainability matters addressed by
the administrative, management and supervisory bodies
SBM-2 – Interests and views of stakeholders
IRO-1 – Description of the processes to identify and assess material
impacts, risks and opportunities
S1-2 – Processes for engaging with own workforce and workers’
representatives about impacts
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S4-2 – Processes for engaging with consumers and end-users about
impacts
E1-2 – Policies related to climate change mitigation and adaptation
E5-1 – Policies related to resource use and circular economy
S1-1 – Policies related to own workforce
S4-1 – Policies related to consumers and end-users
G1-1 – Corporate culture and business conduct policies and corporate
culture
ES – Policies related to entity specific topic
c) Identifying and assessing adverse
impacts
IRO-1 – Description of the processes to identify and assess material
impacts, risks and opportunities
SBM-3 – Material impacts, risks and opportunities and their interaction with
strategy and business model
d) Taking actions to address those
adverse impacts
E1-3 – Actions and resources in relation to climate change policies
S1-4 – Taking action on material impacts on own workforce, and
approaches to mitigating material risks and pursuing material
opportunities related to own workforce, and effectiveness of those action
e) Tracking the effectiveness of these
efforts and communicating
E1-5 – Energy consumption and mix
E1-4 – Targets related to climate change mitigation and adaptation
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
S1-5 – Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
S1-16 – Compensation metrics (pay gap and total compensation)
GOV-5 – Risk management and internal controls over sustainability reporting
Internal Control System (ICS) is composed of 3 independent Units (Internal Audit, Risk Management,
Regulatory Compliance) which are being oversighted by the BoD Committees (Audit and Risk Management).
They form an adequate and effective ICS, which policies and procedures are being approved by the BoD.
The ICS aims to ensure, inter alia, the recognition and management of all risks undertaken, and the
completeness and reliability of the data and information required to identify accurately and timely the
financial situation of the Group and the production of reliable financial statements. Moreover, delegated
powers have been placed to the above independent units (Risk Management, Internal Audit and Regulatory
Compliance) and to the committees of the BoD. Regarding sustainability reporting, internal departments
have the responsibility to prepare and collect the qualitative and quantitative data, ensuring accuracy and
completeness, while collaborating with the Strategy, IR & Sustainable Development Division, which
manages consolidation and oversees in detail the process to align with the sustainability strategy and CSRD
requirements. The Sustainability Management Committee ensures that all sustainability-related aspects are
accurately and effectively represented, prior to final approval by the Audit Committee and the BoD.
Furthermore, an independent third-party assurance provides limited assurance on the information included
in the Sustainability Statement to enhance its credibility, ensure compliance with ESRSs, and strengthen
stakeholder trust. This process underlines the Group's commitment to transparency, accuracy, and
accountability in relation to sustainability reporting. The above-mentioned approval process that is followed
for the Sustainability Statement is the same with the one followed for the financial statements, including
endorsement by the Sustainability Management Committee, prior to final approval by Audit Committee and
BoD which signs the highest level of oversight and accountability.
The Group takes a proactive approach to identifying and prioritizing sustainability risks. While an official
risk assessment framework or prioritization methodology for sustainability reporting has not yet been
established, the Group is committed to strengthening the risk management processes. Moving forward, the
Group will continue to enhance internal controls to ensure the integrity of the sustainability reporting and
effectively address any potential risks that may arise in future reporting periods. During this reporting
period, the Risk Management Division oversaw the Sustainability Statement. Given that the Sustainability
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Management Committee includes members from different operational areas, any findings identified during
the reporting period are quickly communicated to the relevant division. This ensures that appropriate
actions and measures are implemented effectively. Additionally, this approach fosters a culture of
continuous improvement and proactive management across ESG pillars. Continuous monitoring enables
close collaboration with the relevant divisions, addresses any issues, implementation of corrective actions,
and tracking of progress.
Regarding the Sustainability Statement, the administrative and supervisory bodies receive regular updates
from the Sustainability Management Committee and Risk Management Committee, in case of findings of
risk assessment and internal controls. Monthly, quarterly, or annual updates outline advancements,
obstacles, and new risks over sustainability reporting, keeping decision-makers well-informed.
Strategy
SBM-1 – Strategy, business model and value chain
The Group is actively engaged in the market for retail and business financing in Greece. As the parent
company of the Group, Optima bank leverages its customer service network and collaborates closely with
other group companies to deliver a comprehensive suite of products and services. The Group offers a
diverse range of financial solutions designed to meet the varied needs of its customers. These offerings
encompass the business activities of the parent company and its subsidiaries in the following areas:
Corporate banking, Retail banking, Asset Management, Factoring and Leasing Services, and Investment
banking. By offering this array of products and services, the Group aims to address and respond to the
diverse financial needs of its customers, building long-term relationships of trust for the banking experience,
and contributing to the economic growth and stability of the Greek market. On the same note, there are
no products and services that are banned in certain markets.
The number of employees of the Group on 31/12/2024 was 575 (550 for the Bank). All employees are
located in Greece.
Concerning the breakdown of total revenue by significant ESRS sectors, the European Commission has not
adopted a Delegated Act specifying the list of ESRS sectors. Consequently, nonadditional significant ESRS
sectors have been considered when performing the materiality assessment. Due to the Group’s business
activity, the disclosure requirements regarding revenues in fossil fuel, fossil gas, chemicals, controversial
weapons, and tobacco are not applicable.
The Group’s sustainability strategy is built on three key pillars, addressing critical sustainability-related
issues. It continually works to align its sustainability goals with significant product and service groups,
customer categories, and stakeholder relationships. In specific, the business model and the sustainability
strategy have been updated to define sustainability-related ambitions, commitments, targets, and key
performance indicators, considering the results of the Double Materiality Assessment and the current
significant products, services, markets, and customer groups. The strategy outlines the following ambitions
and the relevant targets that are presented in the relevant sections of the Sustainability Statement, each
with corresponding commitments:
•
Support the energy transition
The Group is committed to supporting the energy transition by minimizing its carbon footprint through
operational efficiencies and sustainable practices, integrating climate and environmental factors into
business and risk management to enhance resilience, and developing transition plans. These efforts deliver
positive outcomes across markets and customer segments, ensuring that offered financial products and
services are aligned with the sustainability objectives.
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•
Create value for people and society
The Group is committed to creating value for people and society by maintaining high levels of employee
and customer satisfaction, providing a diverse working environment and equal opportunities for all
stakeholders, while safeguarding stakeholders' data privacy. Additionally, the Group focuses on enhancing
customer satisfaction and improving operational efficiency through digitalization, ensuring that both
employees and customers experience positive, equitable outcomes while embracing technological
advancements to streamline processes.
•
Maintain a sound governance model
The Group is committed to maintaining a sound governance model by fostering a culture of ethics,
transparency, and integrity. It aims to embed sustainability within the corporate culture while strengthening
policies and procedures to prevent corruption and bribery, upholding a zero-tolerance approach. The Group
also ensures the protection of whistleblowers, encouraging transparency and accountability at all levels.
The updated strategy encompasses all significant impacts, risks, and opportunities while improving
essential solutions as needed to address sustainability concerns. Furthermore, the strategy incorporates
pertinent financial aspects, including associated revenues, thereby providing a comprehensive perspective
on the Group's sustainability efforts and initiatives.
INPUTS
VALUE
CREATION
OUTPUTS
OUTCOMES
Financial Capital
(Equity, Debt
Instruments, Deposits)
Corporate
banking
Retail banking
Asset
Management
Factoring
services
Investment
banking
Leasing
Services
Net interest income
Net fee/Net interest/
Trading income
Total Assets
Market share
Climate change
adaptation & mitigation
Energy/Waste
Working conditions
Equal treatment &
opportunities
Information related
impacts for consumers/
end- users
Innovation &
Digitalization
Corporate culture
Corruption and bribery
Protection of
whistleblowers
Manufactured Capital
(Branches & HQs, Data
Center, Leased Vehicles)
Investments in branches,
buildings & Data centers
Natural Capital
(Water, Energy sources,
paper)
Energy consumption
Emissions
Waste
Water
Social capital
(Stakeholders
engagement, Ethical
Business practices)
Customer growth rate
Customer satisfaction
Financial Access
Human Capital
(Management &
Leadership, Employees’
skills & capabilities,
Training & Development,
Employee well- being,
Talent acquisition &
recruitment)
Training hours
Payroll
Employee satisfaction &
development
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Intellectual Capital
(Processes & Procedures,
Technology integration &
innovation
Innovation & Digitalization
Social networks
Cloud transition
The Group operates within the financial sector, utilizing financial, manufactured, natural, social, human,
and intellectual capital to generate value. It acquires equity, debt, and deposits while employing physical
infrastructure, technology, and responsible resource management. Its operations are driven by ethical
practices, stakeholder engagement, employee development, and innovation. Key outputs include net
interest and fee income, asset growth, market share expansion, customer satisfaction and digital
transformation. Infrastructure investment, sustainability initiatives, and human capital development
support this overarching strategy. Its entire value chain involves the financial institutions, suppliers
(services and products) and depositors upstream of the value chain, while serving corporate and retail
customers, downstream of the value chain through branches and digital platforms. It maintains strong
partnerships, regulatory compliance, and sustainability initiatives, ensuring resilience and long-term value
creation.
SBM-2 – Interests and views of stakeholders
During every decision-making process, the role of stakeholders is critical. Therefore, to conduct the Double
Materiality Assessment, stakeholders that participate, influence and are affected by the business activities
have been redefined. Optima bank and the Group’s subsidiaries maintain continuous dialogue with its
stakeholders through various communication channels to ensure their views and concerns are incorporated
into decision-making processes. Key stakeholders are customers and clients, employees, investors &
shareholders, suppliers & partners, society & communities, and government & regulators. The Group
ensures that engagement occurs regularly and systematically for all categories of stakeholders.
The engagement is organized by dedicated responsible persons depending on the stakeholder category,
communication methods, and the affected area or/and activity/operation. These employees are responsible
for maintaining open lines of communication with each stakeholder group by using multiple channels and
methods as presented below.
STAKEHOLDER
GROUP
COMMUNICATION CHANNELS
Customer & Clients
• Customer satisfaction surveys
• Daily communication in Bank's branches
• Relationship Managers
• Call center
• "Send us your message" dedicated platform
• Complaint form in the Bank's website
• Materiality Analysis Process
Employees
• Human Resources representatives’ visits to Bank's branches
• Internal portal for daily communication
• Regular meetings with Human Resources Division
• Training sessions
• Materiality Analysis Process
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Investors &
Shareholders
• Financial Statements
• Annual Report
• Roadshows
• General meetings
• Press releases
• One to one meetings
• Investor Relations events
• Materiality Analysis Process
Suppliers & Partners
• One to one meetings
• Terms of supply agreements
• Annual Reports
• Materiality Analysis Process
Society &
Communities
• Financial Memberships in Associations
• Communication with representatives of the local communities via
branches
• Direct communication
• Annual Reports
• Donations/CSR programs
• Materiality Analysis Process
Government &
Regulators
• Communication with state authorities
• Cooperation with the BoG and other regulatory authorities
• Regulatory reports
• Meetings
• Inquiries
• Support of public initiatives
A key stakeholder group is the Group’s employees, where engagement is organized through Human
Resources Division visits to Bank branches, an internal portal for daily communication, regular meetings
with Human Resources Division, volunteering and CSR initiatives and training sessions. Regarding the
strategy and business model, while the interests, views, and rights of the Group’s workforce play a crucial
role in shaping them, the workforce does not directly participate in defining these areas. However, their
perspectives are always taken into consideration, including in the materiality analysis process. At the same
time, through various initiatives, actions, policies, and procedures, the Group is committed to ensuring
favorable working conditions and promoting equal treatment and opportunities for all.
For customers and clients, engagement is organized through customer satisfaction surveys, daily
communication in Bank’s branches, relationship managers, call centers, a dedicated "send us your
message" platform and complaints form on the Bank’s website. Similarly, with the Group’s own workforce,
the Group's strategy and business model are also informed by a commitment to respecting its customers’
human rights, particularly in the areas of privacy and access to quality information. The Group implements
rigorous data protection measures to safeguard personal information. Additionally, the Group strives for
transparency and provides easy access to information to all its customers. By actively engaging with
consumers through feedback mechanisms, the Group consistently improves its practices.
The purpose of stakeholder engagement is to gather feedback, understand stakeholder concerns, and
incorporate their views into the Group’s decision-making processes to align with their expectations and
enhance overall satisfaction. The Group has created a dynamic stakeholder breakdown that includes
information on the various channels of communication, engagement strategies, and the frequency of
communication with various stakeholder groups over the course of the year. Effective stakeholder
engagement is essential to the Group's success, as it provides valuable insights through ongoing
communication. The Group stays updated on changing needs, expectations, and potential risks as perceived
by its stakeholders by keeping lines of communication open. The outcomes of stakeholder engagement are
110
considered by integrating feedback into the Group ’s policies, strategies, and operations. This ensures that
the Group remains responsive to stakeholder needs and continuously improves its services and initiatives.
This approach is consistently incorporated into the new strategy for sustainable development. To reinforce
its commitment to sustainable development, a business model that aligns with the needs and expectations
of its stakeholders has been developed. This is achieved through the understanding of the interests and
views of its key stakeholders, which is integrated both into the strategy and the business model. The Group
actively engages in a due diligence process and materiality assessment process to analyze and understand
stakeholder interests and views through the above-mentioned methods. The information collected and the
feedback provided during these engagements is analyzed to identify key themes and issues that are
important to stakeholders and if any improvement actions, measures and initiatives are necessary to meet
their expectations. By integrating these insights into the Group’s business model and strategy, the Group
may address any potential impact, risk and opportunity.
As the Group sets the foundation for its sustainability journey and simultaneous response to regulatory
requirements and stakeholders’ needs, its strategy and business model are being updated. Specifically, it
has been revised to place a stronger emphasis on ESG pillars by supporting energy transition, creating
value for people and society and maintaining a sound governance model. To coherently incorporate the
above and to enhance sustainability reporting and transparency, the Group considers further alignment
with stakeholder interests through several additional initiatives. These initiatives are expected to positively
modify and enhance the engagement with stakeholders’ groups. By actively addressing their concerns and
incorporating their feedback into the strategy and business model, it is anticipated that increased trust and
stronger partnerships will be developed.
The administrative, management, and supervisory bodies are regularly informed and updated about the
views and interests of affected stakeholders regarding the sustainability-related impacts from the
Sustainability Management Committee. The Sustainability Management Committee has a critical role in
reviewing and addressing stakeholder feedback to the highest governance bodies through the submission
of quarterly reports and updated scheduled meetings during the year, when deemed necessary.
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SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model
The following table represents the material impacts derived from the DMA.
ESRS
topic
ESRS sub-topic
Impact description
Type of impact
Value chain stage
positive /
negative
actual/
potential
Upstre
am
Own
operations
Downstrea
m
E1
Climate change
mitigation
Contribution to climate change through its in-house operations inevitably contributes to
the release of emissions.
_
actual
E1
Climate change
adaptation
Contribution to climate adaptation, through providing environmentally friendly / green
financial products/services.
+
actual
E1
Energy
Provision of specific financial products/services that support energy consumption
reduction and energy efficiency.
+
actual
E1
Climate change
adaptation
Upgrade of the data center to achieve lower energy consumption.
+
actual
E5
Waste
Impacts through financial products/services to certain sectors that affect the ability to
manage and reduce waste.
+
actual
E5
Waste
Impacts through using ecofriendly- recyclable activities and initiatives
+
actual
S1
Working conditions
Positive impact which generates direct, indirect, and induced jobs across its value chain,
provide competitive wages and benefits in alignment with the remuneration policy.
+
actual
S1
Working conditions
Increase employee’s retention through the competitive remuneration of the employees
based on merit recognition.
+
actual
S1
Working conditions
Ensuring the right to free association of the employees.
+
actual
S1
Working conditions
Improved work/life balance through specific policies and initiatives.
+
actual
S1
Working conditions
Parental support (extra family days, child allowance, family support).
+
actual
S1
Working conditions
Support employees’ well-being through providing satisfying and high-quality working
conditions, including adequate workspace and respect of privacy.
+
actual
S1
Equal treatment and
opportunities for all
Established policies, measures and actions regarding gender / sexual / ethnic / racial
issues within its operations, potentially impacting the feeling of inclusivity in the
workplace.
+
actual
S1
Equal treatment and
opportunities for all
Impact to employees (dissatisfaction, not motivated to work) through gender pay gap.
_
actual
S1
Equal treatment and
opportunities for all
Support for training and skills development and enhancement of the potential and
uniqueness of employees, including through the definition of talent management and
+
actual
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development programs. Creation of job and professional development opportunities
inside and outside the Group.
S1
Working conditions
Positive impacts with access to finance through staff loans with low interest rates.
+
actual
S4
Information-related
impacts for consumers
and/or end-users
High quality of the services provided results in customer satisfaction.
+
actual
S4
Information-related
impacts for consumers
and/or end-users
Internal management systems, cybersecurity systems and initiatives protect and ensure
stakeholders' data privacy.
+
actual
S4
Information-related
impacts for consumers
and/or end-users
Established cybersecurity systems and processes lead to zero or restricted incidents of
data breach, leaks of personal data and confidential information.
+
actual
Entity
specific
Innovation &
digitalization
Adopting and offering innovative services by providing fast and user-friendly banking
solutions enhances customer experience and operational efficiency.
+
actual
G1
Corporate culture
Compliance within the organization and its value chain adhere to Ethical Conduct and
Ethics and ethical values results in absence of cases of human rights violations.
+
actual
G1
Corporate culture
Dissemination of a conscious and adequate culture of ethics and human rights by own
workforce, communicates and promotes corporate ethical behavior and culture.
+
actual
G1
Corporate culture
Positive impacts through zero or minor incidents of non-compliance with laws and
regulations
+
actual
G1
Corruption and
bribery
Established robust anti-corruption and anti-bribery policies, results in absence of related
incidents and promotes a culture of transparency, anti-competitive, anti-corruption and
anti-money laundering behavior.
+
actual
G1
Corruption and
bribery
Absence of corruption-related incidents that could result in operational disruptions,
ensuring business continuity and positively affecting day-to-day activities.
+
actual
G1
Protection of
whistleblowers
Protection of whistleblowers results to safe and protected working environment, without
fear of retaliation.
+
actual
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The following table represents the material risks and opportunities which have been derived from the DMA
ESRS
topic
ESRS sub-topic
Risk, opportunity description
risk /
opportunity
time horizon
short-term
mid-term
long-term
E1
Climate change
adaptation / Energy
Financing environmentally friendly/green projects or products/services aligned with the growing consumer
demand can attract customers who are looking for institutions who support sustainable practices.
opportunity
E1
Energy
Decrease in energy consumption through specific initiatives/ activities reduces operating costs.
opportunity
E1
Waste
Financing the waste management industry offers a new clientele and opportunities for profitability.
opportunity
E1
Climate change
adaptation/ Energy
Lack of strategic planning related to green financing which brings environmental benefits could affect its
competitiveness, market share, reputation, and profitability.
risk
S1
Working conditions
Work-life balance initiatives could strengthen the motivation to work, could increase the reputation as a
family-friendly employer, could improve the retention of employees and/or attraction of future employees
and increase employees' productivity.
opportunity
S1
Working conditions
Adequate wages could increase motivation and retention rates for employees and enhance the Group's
reputation and performance.
opportunity
S1
Equal treatment and
opportunities for all
Promotion of gender equality, diversity, inclusion and adoption of ethical principles and behaviors that
create a desirable workplace, can lead to employee attraction and retention and generally improve
reputation.
opportunity
S1
Equal treatment and
opportunities for all
A well-trained and specialized workforce leads to higher productivity and profits, encourages new and
innovative ideas, and helps the Group to reach its goals.
opportunity
S1
Equal treatment and
opportunities for all
The need for continuous training to keep up the development of employees with specialized expertise and
experience in a specific field creates increased training costs.
risk
S4
Information-related
impacts for consumers
and/or end-users
System failures that could lead to service disruption, unauthorized access and data breaches could cause
reputational damage and affect the group's financial performance.
risk
S4
Information-related
impacts for consumers
and/or end-users
Continuously satisfied customers lead to higher customer loyalty, trust and market share growth.
opportunity
Entity
specific
Innovation &
digitalization
High dependency on digitalization could lead to operational disruptions in the event of a system failure,
affecting the Bank's performance.
risk
G1
Corporate culture
Sustainability regulations and trends could lead to misinformation or communications that do not clearly
and fairly reflect the sustainability profile of the organization and/or the financial products and services
provided. This may confuse consumers, investors, and other stakeholders for the organizations' sustainable
practices, causing reputational damage and operational costs.
risk
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In total 74 IROs were identified and evaluated as part of the DMA. Out of these, 39 were deemed material
across the ESRS topics: E1 Climate change, E5 Circular Economy, S1 Own workforce, S4 Consumers, and/or
end- users and G1 Business Conduct and innovation & digitalization as entity specific topics. Specifically,
regarding Impact Materiality, 26 impacts were assessed as material. In terms of Financial Materiality, 13
risks and opportunities were assessed as material, which are presented throughout the Sustainability
Statement.
The DMA process and the identified material impacts, risks, and opportunities ensure that sustainability
considerations are thoroughly integrated into the Group’s own operations and across the entire value chain.
This integration drives resilience and adaptability in a changing landscape. These factors and the underlying
impacts, risks and opportunities underscore their significance for the Group's sustainability strategy. The
DMA process has highlighted the critical areas where the business model, value chain, strategy, and
decision-making processes are impacted by sustainability-related factors. By focusing on material impacts,
risks, and opportunities, the Group is going to allocate resources effectively and monitor progress against
its sustainability goals. This ensures that the actions and initiatives are both impactful and aligned with
stakeholders’ expectations.
The Group’s material impacts inevitably affect, positively and/or negatively, people and the environment in
many ways across value chain through its operations (e.g. energy consumption), financing activities (e.g.
financial products and services) and the internal environment (e.g. social related matters) in short-term,
mid-term and long-term. As mentioned above, these impacts are interconnected and may interact with the
strategy and business model through the Group’s strategic focus to support sustainable development. For
example, the adoption of energy-efficient practices, eco-friendly- recyclable activities and initiatives,
provision of specific financial products and services, support of wellbeing of employees etc., demonstrate
a comprehensive approach to addressing sustainability-related challenges and create positive outcomes.
As of the current reporting period, the Group has found no financial effects from its material risks and
opportunities on its financial position, performance, or cash flow. As per ESRS 2 SBM-3 paragraph 48 (e),
the Group applies the phased-in provision as listed in Appendix C of ESRS 1.
The adaptation of the business model to address significant sustainability issues and the updated strategy
that integrates ESG factors into strategic planning strengthen the Group's resilience. Considering ESG
factors that affect or could affect the strategy, safeguards that the Group is prepared for a wide range of
challenges and opportunities. Also, implementing a robust risk management system that encompasses all
business operations and includes ESG risks according to the action plan, further enhances resilience. This
comprehensive approach to risk management demonstrates the Group's preparedness for potential
disruptions and its ability to mitigate risks effectively. The resilience of the business model and strategy is
also enhanced by a set of documented processes, operational resources, and actions for business continuity
purposes. These elements are developed and maintained to ensure the uninterrupted delivery of critical
products and services in the event of foreseeable disruption. This preparedness ensures that the Group
can continue to operate smoothly and meet stakeholder expectations even during challenging times.
This is the first time the Group has conducted a materiality assessment to identify material impacts, risks
and opportunities.
Impact, risk and opportunity management
IRO-1 – Description of the processes to identify and assess material impacts, risks and
opportunities
Materiality assessment is crucial for identifying and assessing the Group’s priorities for sustainable
development. This evaluation allows the Group to identify and manage the impacts of its operations and
115
its business relationships across the value chain. Τhe first assessment was made to identify its impacts,
risks, and opportunities and assess which ones are material, by conducting a DMA, based on ESRS. The
exercise was implemented across two dimensions:
Impact Materiality (inside-out perspective):
How business affects people and/or the environment
through positive and negative impacts
Financial materiality (outside-in perspective):
How sustainability matters can affect businesses’
financial results through risk and opportunities.
To identify the IROs, the Group conducted several workshops in which 10 different divisions and
departments participated.
Impact Materiality
Through the impact materiality process, the Group identified, assessed, and prioritized the positive and
negative, actual and potential impacts of its activities and business relationships, on people and the
environment. Peer analysis, sector analysis, internationally recognized standards and ratings were also
considered for identifying the impacts. This process was informed by the Group's due diligence efforts and
continuous stakeholder engagement throughout the year, ensuring that the views and perspectives of
stakeholders were incorporated. The impact materiality process focused on Group’s activities and business
relationships, which present a heightened risk of adverse impacts. The impact materiality considered
impacts arising from the Group's own operations as well as those resulting from its portfolio and business
relationships across the value chain. As previously mentioned, the Group has continuous engagement with
affected stakeholders throughout the year. This engagement enables the Group to incorporate their views
and perspectives during the impact materiality process. The impacts were evaluated using criteria such as
scale, scope, and irreversibility (in case of negative impacts), collectively known as severity, along with the
likelihood in case of potential impacts, as described in the ESRS. During the evaluation process, the time
horizons, short-term, mid-term and long-term as indicated by the ESRS were also addressed. The impacts
have been assessed based on their importance, and a materiality threshold was defined to determine which
impacts are material for the Group. The impact materiality identified 26 positive & negative, actual material
impacts.
Financial Materiality
In the context of financial materiality, the Group considered risks and opportunities arising from impacts,
dependencies, and other relevant factors. The identification process took into consideration benchmarks,
using sustainability reports from peers, sector analysis by analyzing industry best practices and standards,
and rating agencies. The Group considered the connections between its impacts and dependencies and the
risks and opportunities that may arise from them. By understanding how these elements are interrelated,
the Group identified risks and opportunities most relevant to its operations and strategic objectives. Risks
and opportunities were evaluated based on their magnitude and likelihood as prescribed by ESRS. The
evaluation process considered the above three-time horizons, ensuring a comprehensive understanding of
the potential financial effects over different periods. The Group is integrating ESG risks into its overall risk
management process to continuously improve them. Although specific risk-assessment tools were not
available during the financial materiality assessment, senior level employees from the Risk Management
Division, Strategy, IR and Sustainable Development Division and Financial Services Department with
expertise and specialized skills prioritized sustainability-related risks by evaluating their relative severity
and likelihood. Next, a materiality threshold was defined to determine which risks and opportunities are
material for the Group. The financial materiality identified 13 material risks and opportunities.
Scoring Impacts, Risks, and Opportunities
The evaluation of impacts, risks, and opportunities was conducted following the principles set forth in ESRS
1 and ESRS 2. Once they were identified, documented, and validated, the next step was to assign scores
116
based on their materiality. This approach allowed the differentiation between impact materiality and
financial materiality, ensuring a thorough assessment of sustainability issues.
Validation of Impacts, Risks, and Opportunities
The DMA results were reviewed and validated by members of the Sustainability Management Committee.
Based on their evaluations, the materiality threshold was established. Each threshold was determined to
make the final validation and approval of the material IROs by the Sustainability Management Committee.
The decision-making process for addressing identified risks and opportunities involves multiple levels of
review and approval. Initially, risks and opportunities were identified and assessed. It followed a structured,
multi-step approach that began with the identification and assessment of these risks and opportunities.
More specifically, the Strategy, IR and Sustainable Development Division, in cooperation with internal
experts, validated the descriptions and scoring of the impacts, risks and opportunities. This step ensured
accuracy and clarity. The Risk Management Division and the Financial Services Department conducted a
detailed review and confirmed those risks inter alia, while placing particular emphasis on Environmental,
Social, and Governance (ESG) factors. The expertise of these divisions guaranteed that ESG-related risks
were comprehensively evaluated and taken into consideration according to the broader risk management
framework. Finally, the results of financial materiality were reviewed by the Sustainability Management
Committee, ensuring all significant financial implications were addressed. The Sustainability Management
Committee also approved the results, thereby verifying top-level accountability.
The process of identifying, assessing, and managing impacts and risks followed the DMA methodology,
with input from experts as previously mentioned. However, it has not yet been fully integrated into the
Group’s overall risk management framework or used to assess its overall risk profile. The Group is actively
working on incorporating climate and environmental factors into its business and risk management
processes in line with ECB expectations. As part of this effort, the Bank conducts qualitative analyses to
evaluate the significance of climate, environmental, and resilience risks in relation to other risk categories
within its Risk Management Framework. Inter alia, the Group is assessing the impact of Climate Related
and Environmental risks on credit risk and is working to integrating it into the loan process, evaluating its
effect on operational metrics, analyzing market risk exposure, and reviewing its influence on various risk
categories. Similarly, the identification of opportunities has been derived through the DMA process,
incorporating insights from stakeholder engagements, business operations and activities, and the active
participation of internal experts. The DMA for this Sustainability Statement was conducted through
comprehensive research, which included references to numerous studies and reports, benchmarking along
with the active engagement of both internal and external stakeholders. As it is the first time the DMA is
being conducted to identify, assess and manage IROs, no comparison with previous years is applicable.
Description of the Processes to Identify and Assess Material Entity Specific- related impacts,
risks and opportunities
The process of identifying material Innovation and Digitalization-related impacts, risks, and opportunities
is guided by the structured methodology outlined above. This process incorporates both qualitative and
quantitative analyses to identify areas of significant impact and risk, ensuring alignment with the Group's
sustainability strategy. Assumptions are based on internal performance data, stakeholder input, and
alignment with global standards. The approach focuses on key factors such as digital service offerings,
risks related to reliance on third-party providers, and the social benefits of digital initiatives. The areas of
heightened risk, particularly concerning its digital transformation initiatives. These areas are closely
evaluated for their potential impacts on both people and the environment. Special attention is given to the
reliance on third-party technology and service providers, particularly regarding cybersecurity risks and
dependence on external systems, which could lead to business disruptions in emergencies. This process
considers both the direct impacts of the operations and the indirect impacts resulting from its business
117
relationships. The Group also consults affected stakeholders to understand the full scope of potential
effects. Engagement of various stakeholder groups ensures that their views and concerns are incorporated
into decision-making processes. The Group’s approach prioritizes impacts based on their relative scale,
scope, and likelihood, as mentioned above.
Description of the Processes to Identify and Assess Material Business Conduct- related
impacts, risks and opportunities
During the DMA process, the Group monitored the business conduct areas to identify material impacts,
risks and opportunities. Among the key strategic areas of focus are corporate culture, where adherence to
the Corporate Governance Code and ethical values ensures there are no human rights violations. The Group
has also anti-corruption and anti-bribery policies that foster a culture of anti-money laundering behavior
and prevent any related incidents. Additionally, the Group is dedicated to protecting whistleblowers,
ensuring they can report unethical behavior without fear of retaliation. Detailed information for policies and
procedures is provided in section G1.
Description of the processes to identify and assess material environmental impacts, risks and
opportunities
The Group has thoroughly screened its assets and activities for actual and potential impacts, risks, and
opportunities within its operations and along with its value chain. This assessment focuses on activities,
business relationships, geographic areas, and other factors with a high risk of adverse impacts. It evaluates
its direct operations as well as its role in wider business relationships to identify its direct and indirect
impacts. A key element of this process involves stakeholder consultation to enable the Group to gain
valuable insights from affected stakeholders and external experts.
For identifying, assessing, and prioritizing risks and opportunities with financial implications, the Group has
aligned key aspects of its operations with corresponding financial risks and opportunities. Following a
Double Materiality Assessment, the Group identified two actual impacts and one significant opportunity
under the sub-topic of Waste.
• Actual Impacts: Through the financing, which is being provided to specific sectors, the Group supports
its counterparties’ waste management practices through the enhancement of their ability to manage and
reduce waste. In its own activities, the Group promotes eco-friendly and recyclable initiatives such as
recyclable debit cards and the use of digital signatures, to reduce printed documents.
• Opportunity: The financial waste management industry represents a new way of client acquisition and
profitability, as the demand for sustainable financial services grows in this sector.
The methodologies and tools applied in this screening and analysis process are aligned with the principles
of the CSRD and ESRS, ensuring robust identification of impacts as well as financial risks and opportunities.
The Group has consulted with relevant stakeholders as part of its ongoing commitment to sustainable
practices regarding circular economy. Using an external stakeholder questionnaire, the Group engaged with
key stakeholders to gather insights on material sustainability topics, among which is the topic of circular
economy and the sub-topic of waste which lies beneath it. The questionnaire included the understanding
of the stakeholders’ perspectives on how the Group’s operations and financial products/services align with
and impact the circular economy, specifically in relation to waste reduction and management.
These consultations were conducted to ensure that the views of the stakeholders related to the circular
economy align with those of the Group and have been incorporated in the DMA. The stakeholder feedback
contributes to guiding the Group's strategy towards resource efficiency, waste minimization, and overall
environmental impact reduction. This inclusive approach ensures that stakeholder concerns and insights
are integrated into the Group’s decision-making processes related to sustainability.
Also, Optima bank is a member of the Hellenic Bank Association (HBA), a key industry body that facilitates
dialogue and exchange of best practices among financial institutions on sustainable practices. Through this
118
engagement, the Group gains insights into the developments of the sector, regulatory expectations, and
collective action opportunities, aligned with circular economy principles.
Through the DMA the Group identifies and assesses its actual impacts on climate change. In alignment
with ESRS E1, the Group has screened its operations and activities to identify significant sources of
greenhouse gas (GHG) emissions. This screening identified three material impacts:
• Contribution to Climate Change Through In-House Operations: GHG emissions have been traced to
internal operations - especially energy consumption in office spaces and branch networks. The Group’s
ambition for climate action is to continuously monitor and reduce emissions from these sources by
improving energy efficiency in the buildings and using renewable sources where possible.
• Upgrade of Data Center to Lower Energy Consumption: Recognizing the energy intensity of data centers,
the data center is being upgraded. Additionally, the use of virtual servers is also promoted in order to
significantly reduce IT infrastructure energy use and contribute to GHG emissions reduction targets.
• Financial Products for Energy Efficiency: The contribution to global efforts to reduce global energy use
and GHG emissions through financing oriented to energy efficient equipment and modern machinery.
Through the above, the Group has evaluated its actual contribution to climate change by reducing emissions
in its own operations and through financial solutions offered to clients. Total GHG emissions are monitored
and reported to keep track of the Group’s climate goals and align with the Group’s sustainability strategy
and commitments.
Physical risks were identified as part of its CR&E Risk - Qualitative Materiality Assessment at the Bank level
as the assessment applies to significant assets and business activities that concern the Bank. Physical risks
are categorized into chronic risks (e.g., persistent changes in precipitation patterns, sea level rise) and
acute risks (e.g., extreme weather events such as hurricanes and flash floods). These hazards were
considered under high-emission climate scenarios, aligning with the Hot House World scenario from the
Network for Greening the Financial System (“NGFS”) framework, which represents a pathway where policy
action is insufficient, leading to severe physical climate impacts. The Bank assessed how these hazards
may impact its assets and business activities, determining that credit risk is the most vulnerable category,
as clients’ financial stability may be affected by climate-induced disruptions. Additionally, conduct, ethics,
and reputational risk was identified as areas of concern due to potential stakeholder scrutiny over the
Bank’s handling of climate-related financial risks. The assessment has aligned with the qualitative
materiality assessment approach integrated into the Bank’s Risk Appetite Framework, with scenario-based
quantification planned as a next step to further evaluate financial impacts.
The Bank has considered climate-related hazards over the short-term (0-1 year), medium-term (1-5 years),
and long-term (>5 years) horizon, assessing whether assets and business activities may be exposed to
these hazards. These time horizons align with the Group’s time horizons definitions as per the CSRD,
strategic planning horizons, and capital allocation plans, ensuring consistency with its broader risk
management framework. A qualitative assessment was conducted to evaluate the magnitude of physical
risks incorporating extreme scenario analysis based on NGFS pathways.
The Bank has identified climate-related transition risks which include policy and regulatory shifts, litigation
risks, market risks due to changing demand and supply dynamics, and reputational risks tied to stakeholder
perceptions of climate action. To assess exposure to these transition risks, the Bank has performed a
qualitative materiality assessment using expert judgment, comparative evaluation, and an analysis of
competitive data, financial statements, and environmental factors. Generally, if pphysical risk is higher,
transition risk may be lower (as policy and regulation is insufficient to reduce physical risk) and conversely,
if physical risk is lower, it is likely that transition risk is higher as policy and regulatory changes are more
extreme such that they are successful in reducing the effects of climate change. In this assessment, the
Bank combined at a high-level both the NGFS scenarios of Disorderly (with high transition risk and low
physical risk) and Hot House World (with low transition risk and high physical risk) to identify the high
119
transition risk and high physical risk impacts. The assessment has identified credit risk and conduct, ethics
and reputational risk as the most impacted risk categories, while other risk areas, such as market risk,
liquidity risk, and Interest Rate Risk in the Banking Book (IRRBB), have been identified as lower risk, given
the Group’s business model. The assessment aligns with the Bank’s Risk Appetite Framework and CSRD
financial materiality magnitude scoring, ensuring consistency in evaluating transition risk exposure. A key
next step will be the running of scenario analysis to support more granular risk rating allocation as well as
beginning to quantify potential financial impacts within a defined time horizon. It is worth noting that
transition risks may present opportunities for financing sustainable investments, supporting green lending
products, and enhancing the Bank’s reputation in sustainability within the sector.
The Bank has employed scenario analysis to assess both physical and transition risks over short-, medium,
and long-term horizons. By using NGFS scenarios (Disorderly and Hot House World), the analysis ensures
that high-risk impacts are considered. While this assessment remains qualitative at this stage, the next
steps include quantifying potential financial impacts across different climate scenarios to refine risk ratings.
Further governance processes will be undertaken to validate and incorporate the findings into the Group’s
strategic planning and risk management framework.
The Group has not made any critical climate-related assumptions in its financial statements for the reporting
period. As a result, there is no direct compatibility between the climate scenarios used in the resilience
analysis and any financial assumptions.
It is noted that during the DMA, the Group took into account the actual and potential impacts, risks, and
opportunities related to pollution, water and marine resources, as well as biodiversity and ecosystems, by
analysing its business activities. This was actively supported by meetings with the responsible departments
and divisions.
IRO-2 – Disclosure requirements in ESRS covered by the Group’s Sustainability Statement
Following the results of the DMA, which identified the material impacts, risks, and opportunities, the Group
assessed the information that is significant in relation to the material IROs, as well as its ability to meet
the decision-making needs of its stakeholders. This includes the needs of investors, regulators, users of
the Sustainability Statement and all stakeholders focused on understanding the Group’s impacts, risks, and
opportunities. The Group discloses that only information meeting the criteria -relevant, significant, and
capable of supporting users' decision-making and the requirements of the ESRSs, was disclosed. The
resulting disclosures reflect both the Group’s priorities and the interests of those who rely on this
information. Finally, it should be noted that there is no disclosed information containing disclosure
requirements related to ESRSs E2, E3, E4, S2, and S3. These topical standards were considered during the
Double Materiality Assessment but were deemed not material.
120
The following table contains a list of the Disclosure Requirements complied with in preparing the Sustainability Statement, following the outcome of
the materiality assessment and their location in the Sustainability Statement
Disclosure Requirements
Location in the Sustainability Statement
ESRS 2 General
Requirements
Disclosure Requirement BP-1 – General basis for preparation of sustainability
statements
BP-1 – General basis for preparation of Sustainability Statement
ESRS 2 General
Requirements
Disclosure Requirement BP-2 – Disclosures in relation to specific circumstances
BP-2 – Disclosures in relation to specific circumstances
ESRS 2 General
Requirements
Disclosure Requirement GOV-1 – The role of the administrative, management
and supervisory bodies
GOV-1 – The role of the administrative, management and supervisory bodies
ESRS 2 General
Requirements
Disclosure Requirement GOV-2 – Information provided to and sustainability
matters addressed by the undertaking’s administrative, management and
supervisory bodies
GOV-2 – Information provided to and sustainability matters addressed by the administrative,
management and supervisory bodies
ESRS 2 General
Requirements
Disclosure Requirement GOV-3 – Integration of sustainability-related
performance in incentive schemes
GOV-3 – Integration of sustainability-related performance in incentive schemes
ESRS 2 General
Requirements
Disclosure Requirement GOV-4 – Statement on due diligence
GOV-4 – Statement on due diligence
ESRS 2 General
Requirements
Disclosure Requirement GOV-5 – Risk management and internal controls over
sustainability reporting
GOV-5 – Risk management and internal controls over sustainability reporting
ESRS 2 General
Requirements
Disclosure Requirement SBM-1 – Strategy, business model and value chain
SBM-1 – Strategy, business model and value chain
ESRS 2 General
Requirements
Disclosure Requirement SBM-2 – Interests and views of stakeholders
SBM-2 – Interests and views of stakeholders
ESRS 2 General
Requirements
Disclosure Requirement SBM-3 – Material impacts, risks and opportunities and
their interaction with strategy and business model
SBM-3 –Material impacts, risks and opportunities and their interaction with strategy and business
model
ESRS 2 General
Requirements
Disclosure Requirement IRO-1 – Description of the processes to identify and
assess material impacts, risks and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS 2 General
Requirements
Disclosure Requirement IRO-2 – Disclosure requirements in ESRS covered by the
undertaking’s sustainability statement
IRO-2 – Disclosure requirements in ESRS covered by the Group’s Sustainability Statement
121
ESRS 2 General
Requirements
Minimum disclosure requirement - Policies MDR-P – Policies adopted to manage
material sustainability matters
E1-2 – Policies related to climate change mitigation and adaptation
E5-1 – Policies related to resource use and circular economy
S1-1 – Policies related to own workforce
S4-1 – Policies related to consumers and end-users
G1-1 – Corporate culture and business conduct policies and corporate culture
ES – Policies related to entity specific topic
ESRS 2 General
Requirements
Minimum disclosure requirement - Actions MDR-A – Actions and resources in
relation to material sustainability matters
E1-3 – Actions and resources in relation to climate change policies
E5-2 – Actions and resources related to resource use and circular economy
S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material
risks and pursuing material opportunities related to own workforce, and effectiveness of those actions
S4-4 – Taking action on material impacts on consumers and end-users, and approaches to managing
material risks and pursuing material opportunities related to consumers and end- users, and
effectiveness of those actions
ES – Taking action on material impacts and approaches to managing material risks related to entity
specific topic, and the effectiveness of these measures and approaches
G1-4 – Confirmed incidents of corruption or bribery
ESRS 2 General
Requirements
Minimum disclosure requirement – Metrics MDR-M – Metrics in relation to
material sustainability matters
E1-5 – Energy consumption and mix
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
E5-5 – Resource outflows
S1-6 – Characteristics of the Group’s employees
S1-7 – Characteristics of non-employee workers in the Group’s own workforce
S1-8 – Collective bargaining coverage and social dialogue
S1-9 – Diversity metrics
S1-10 – Adequate wages
S1-11 – Social protection
S1-15 – Work-life balance metrics
S1-16 – Compensation metrics (pay gap and total compensation)
S1-17 – Incidents, complaints and severe human rights impacts
S4-5 – Targets related to advancing positive impacts, and managing material risks and opportunities
ES – Targets related to advancing positive impacts, and managing material risks
G1-4 – Confirmed incidents of corruption or bribery
ESRS 2 General
Requirements
Minimum disclosure requirement – Targets MDR-T – Tracking effectiveness of
policies and actions through targets
E1-4 – Targets related to climate change mitigation and adaptation
E5-3 – Targets related to resource use and circular economy
S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
ES – Targets related to advancing positive impacts, and managing material risks
G1-4 – Confirmed incidents of corruption or bribery
122
ESRS E1 Climate
Change
Disclosure requirement related to ESRS 2 E1.GOV-3 Integration of sustainability-
related performance in incentive schemes
GOV-3 – Integration of sustainability-related performance in incentive schemes
ESRS E1 Climate
Change
Disclosure Requirement E1-1 – Transition plan for climate change mitigation
E1-1 – Transition plan for climate change mitigation
ESRS E1 Climate
Change
Disclosure Requirement related to ESRS 2 E1.SBM-3 – Material impacts, risks and
opportunities and their interaction with strategy and business model
E1.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business
model
ESRS E1 Climate
Change
Disclosure requirement related to ESRS 2 E1.IRO-1 – Description of the processes
to identify and assess material climate-related impacts, risks and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS E1 Climate
Change
Disclosure Requirement E1-2 – Policies related to climate change mitigation and
adaptation
E1-2 – Policies related to climate change mitigation and adaptation
ESRS E1 Climate
Change
Disclosure Requirement E1-3 – Actions and resources in relation to climate
change policies
E1-3 – Actions and resources in relation to climate change policies
ESRS E1 Climate
Change
Disclosure Requirement E1-4 – Targets related to climate change mitigation and
adaptation
E1-4 – Targets related to climate change mitigation and adaptation
ESRS E1 Climate
Change
Disclosure Requirement E1-5 – Energy consumption and mix
E1-5 – Energy consumption and mix
ESRS E1 Climate
Change
Disclosure Requirement E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
ESRS E1 Climate
Change
Disclosure Requirement E1-9 – Anticipated financial effects from material
physical and transition risks and potential climate-related opportunities
phased-in
ESRS E2
Pollution
Disclosure requirement related to ESRS 2 E2.IRO-1 – Description of the processes
to identify and assess material pollution-related impacts, risks and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS E3 Water
and marine
resources
Disclosure requirement related to ESRS 2 E3.IRO-1 – Description of the processes
to identify and assess material water and marine resources-related impacts, risks
and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS E4
Biodiversity and
ecosystems
Disclosure requirement related to ESRS 2 E4.IRO-1 – Description of processes to
identify and assess material biodiversity and ecosystem-related impacts, risks
and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
123
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement related to ESRS 2 E5.IRO-1 – Description of the processes
to identify and assess material resource use and circular economy-related
impacts, risks and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement E5-1 – Policies related to resource use and circular
economy
E5-1 – Policies related to resource use and circular economy
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement E5-2 – Actions and resources related to resource use and
circular economy
E5-2 – Actions and resources related to resource use and circular economy
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement E5-3 – Targets related to resource use and circular
economy
E5-3 – Targets related to resource use and circular economy
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement E5-5 – Resource outflows
E5-5 – Resource outflows
ESRS E5
Resource Use
and Circular
Economy
Disclosure Requirement E5-6 – Anticipated financial effects from resource use
and circular economy-related impacts, risks and opportunities
phased-in
ESRS S1 Own
Workforce
Disclosure Requirement related to ESRS 2 S1.SBM-2 – Interests and views of
stakeholders
SBM-2 – Interests and views of stakeholders
ESRS S1 Own
Workforce
Disclosure Requirement related to ESRS 2 S1.SBM-3 – Material impacts, risks and
opportunities and their interaction with strategy and business model
S1.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business
model
ESRS S1 Own
Workforce
Disclosure Requirement S1-1 – Policies related to own workforce
S1-1 – Policies related to own workforce
ESRS S1 Own
Workforce
Disclosure Requirement S1-2 – Processes for engaging with own workers and
workers’ representatives about impacts
S1-2 – Processes for engaging with own workers and workers’ representatives about impacts
ESRS S1 Own
Workforce
Disclosure Requirement S1-3 – Processes to remediate negative impacts and
channels for own workers to raise concerns
S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns
ESRS S1 Own
Workforce
Disclosure Requirement S1-4 – Taking action on material impacts on own
workforce, and approaches to mitigating material risks and pursuing material
opportunities related to own workforce, and effectiveness of those actions
S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material
risks and pursuing material opportunities related to own workforce, and effectiveness of those actions
124
ESRS S1 Own
Workforce
Disclosure Requirement S1-5 – Targets related to managing material negative
impacts, advancing positive impacts, and managing material risks and
opportunities
S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
ESRS S1 Own
Workforce
Disclosure Requirement S1-6 – Characteristics of the undertaking’s employees
S1-6 – Characteristics of the Group’s employees
ESRS S1 Own
Workforce
Disclosure Requirement S1-7 – Characteristics of non-employee workers in the
undertaking’s own workforce
S1-7 – Characteristics of non-employee workers in the Group’s own workforce
ESRS S1 Own
Workforce
Disclosure Requirement S1-8 – Collective bargaining coverage and social dialogue
S1-8 – Collective bargaining coverage and social dialogue
ESRS S1 Own
Workforce
Disclosure Requirement S1-9 – Diversity metrics
S1-9 – Diversity metrics
ESRS S1 Own
Workforce
Disclosure Requirement S1-10 – Adequate wages
S1-10 – Adequate wages
ESRS S1 Own
Workforce
Disclosure Requirement S1-11 – Social protection
S1-11 – Social protection
ESRS S1 Own
Workforce
Disclosure Requirement S1-13 – Training and skills development metrics
phased-in
ESRS S1 Own
Workforce
Disclosure Requirement S1-15 – Work-life balance metrics
S1-15 – Work-life balance metrics
ESRS S1 Own
Workforce
Disclosure Requirement S1-16 – Compensation metrics (pay gap and total
compensation)
S1-16 – Compensation metrics (pay gap and total compensation)
ESRS S1 Own
Workforce
Disclosure Requirement S1-17 – Incidents, complaints and severe human rights
impacts
S1-17 – Incidents, complaints and severe human rights impacts
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement related to ESRS 2 S4.SBM-2 – Interests and views of
stakeholders
SBM-2 – Interests and views of stakeholders
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement related to ESRS 2 S4.SBM-3 – Material impacts, risks and
opportunities and their interaction with strategy and business model
S4.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business
model
125
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement S4-1 – Policies related to consumers and end-users
S4-1 – Policies related to consumers and end-users
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement S4-2 – Processes for engaging with consumers and end-
users about impacts
S4-2 – Processes for engaging with consumers and end-users about impacts
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement S4-3 – Processes to remediate negative impacts and
channels for consumers and end-users to raise concerns
S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise
concerns
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement S4-4 – Taking action on material impacts on consumers
and end-users, and approaches to managing material risks and pursuing material
opportunities related to consumers and end- users, and effectiveness of those
actions
S4-4 – Taking action on material impacts on consumers and end-users, and approaches to managing
material risks and pursuing material opportunities related to consumers and end- users, and
effectiveness of those actions
ESRS S4
Consumers
and/or end-
users
Disclosure Requirement S4-5 – Targets related to managing material negative
impacts, advancing positive impacts, and managing material risks and
opportunities
S4-5 – Targets related to advancing positive impacts, and managing material risks and opportunities
Entity Specific -
Innovation &
Digitalization
Disclosure Requirement ESRS 2 ES.SBM-3 – Material impacts, risks and
opportunities and their interaction with strategy and business model
ES.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business
model
ESRS G1
Business
Conduct
Disclosure Requirement related to ESRS 2 G1.GOV-1 – The role of the
administrative, supervisory and management bodies
GOV-1 – The role of the administrative, management and supervisory bodies
ESRS G1
Business
Conduct
Disclosure Requirement related to ESRS 2 G1.IRO-1 – Description of the
processes to identify and assess material impacts, risks and opportunities
IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities
ESRS G1
Business
Conduct
Disclosure Requirement G1-1– Corporate culture and business conduct policies
and corporate culture
G1-1 – Corporate culture and business conduct policies and corporate culture
ESRS G1
Business
Conduct
Disclosure Requirement G1-3 – Prevention and detection of corruption and
bribery
G1-3 – Prevention and detection of corruption and bribery
ESRS G1
Business
Conduct
Disclosure Requirement G1-4 – Confirmed incidents of corruption or bribery
G1-4 – Confirmed incidents of corruption or bribery
126
The following table discloses all data points derived from other EU legislation as outlined in ESRS 2 Appendix B, specifying where these data
points can be found in our report and highlighting those assessed as “Not material”.
DISCLOSURE
REQUIREMENT &
RELATED DATA POINT
SFDR REFERENCE
PILLAR 3 REFERENCE
BENCHMARK
REGULATION
REFERENCE
EU Climate Law
reference
Location in the
Sustainability
Statement / Not
material
ESRS 2 GOV-1
Board's gender diversity
paragraph 21 (d)
Indicator number 13 of
Table #1 of Annex 1
Commission Delegated
Regulation (EU)
2020/1816(5), Annex II
GOV-1 The role of the
administrative,
management and
supervisory bodies
ESRS 2 GOV-1
Percentage of board
members who are
independent paragraph 21
(e)
Delegated Regulation (EU)
2020/1816, Annex II
GOV-1 The role of the
administrative,
management and
supervisory bodies
ESRS 2 GOV-4
Statement on due diligence
paragraph 30
Indicator number 10 Table
#3 of Annex 1
GOV-4 Statement on due
diligence
ESRS 2 SBM-1
Involvement in activities
related to fossil fuel
activities paragraph 40 (d) i
Indicators number 4 Table
#1 of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU)
2022/2453(6) Table 1:
Qualitative information on
Environmental risk and
Table 2: Qualitative
information on Social risk
Delegated Regulation (EU)
2020/1816, Annex II
SBM-1 Strategy, business
model and value chain
127
ESRS 2 SBM-1
Involvement in activities
related to chemical
production paragraph 40
(d) ii
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1816, Annex II
SBM-1 Strategy, business
model and value chain
ESRS 2 SBM-1
Involvement in activities
related to controversial
weapons paragraph 40 (d)
iii
Indicator number 14 Table
#1 of Annex 1
Delegated Regulation (EU)
2020/1818(7), Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
SBM-1 Strategy, business
model and value chain
ESRS 2 SBM-1
Involvement in activities
related to cultivation and
production of tobacco
paragraph 40 (d) iv
Delegated Regulation (EU)
2020/1818, Article 12(1)
Delegated Regulation (EU)
2020/1816, Annex II
SBM-1 Strategy, business
model and value chain
ESRS E1-1
Transition plan to reach
climate neutrality by 2050
paragraph 14
Regulation (EU) 2021/1119,
Article 2(1)
Not material
ESRS E1-1
Undertakings excluded
from Paris-aligned
Benchmarks paragraph 16
(g)
Article 449a
Regulation (EU) No
575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 1:
Banking book-Climate
Change transition risk: Credit
quality of exposures by
sector, emissions and
residual maturity
Delegated Regulation (EU)
2020/1818, Article12.1 (d)
to (g), and Article 12.2
Not material
ESRS E1-4
GHG emission reduction
targets paragraph 34
Indicator number 4 Table
#2 of Annex 1
Article 449a
Regulation (EU) No
575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template
3: Banking book – Climate
change transition risk:
alignment metrics
Delegated Regulation (EU)
2020/1818, Article 6
E1-4 – Targets related to
climate change mitigation
and adaptation
128
ESRS E1-5
Energy consumption from
fossil sources
disaggregated by sources
(only high climate impact
sectors) paragraph 38
Indicator number 5 Table
#1 and Indicator n. 5
Table #2 of Annex 1
Not material
ESRS E1-5 Energy
consumption and mix
paragraph 37
Indicator number 5 Table
#1 of Annex 1
E1-5 – Energy
consumption and mix
ESRS E1-5
Energy intensity associated
with activities in high
climate impact sectors
paragraphs 40 to 43
Indicator number 6 Table
#1 of Annex 1
Not material
ESRS E1-6
Gross Scope 1, 2, 3 and
Total GHG emissions
paragraph 44
Indicators number 1 and 2
Table #1 of Annex 1
Article 449a; Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 1: Banking book
– Climate change transition
risk: Credit quality of
exposures by sector,
emissions and residual
maturity
Delegated Regulation (EU)
2020/1818, Article 5(1), 6
and 8(1)
E1-6 – Gross Scopes 1, 2,
3 and Total GHG emissions
ESRS E1-6
Gross GHG emissions
intensity paragraphs 53 to
55
Indicators number 3 Table
#1 of Annex 1
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
Template 3: Banking book
– Climate change transition
risk: alignment metrics
Delegated Regulation (EU)
2020/1818, Article 8(1)
E1-6 – Gross Scopes 1, 2,
3 and Total GHG emissions
ESRS E1-7
GHG removals and carbon
credits paragraph 56
Regulation (EU)
2021/1119, Article 2(1)
Not material
129
ESRS E1-9
Exposure of the benchmark
portfolio to climate-related
physical risks paragraph 66
Delegated Regulation (EU)
2020/1818, Annex II
Delegated Regulation (EU)
2020/1816, Annex II
Not material
ESRS E1-9
Disaggregation of monetary
amounts by acute and
chronic physical risk
paragraph 66 (a)
ESRS E1-9
Location of significant
assets at material physical
risk paragraph 66 (c)
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraphs 46 and 47;
Template 5: Banking book
- Climate change physical
risk: Exposures subject to
physical risk.
Not material
ESRS E1-9
Breakdown of the carrying
value of its real estate
assets by energy-efficiency
classes paragraph 67 (c)
Article 449a Regulation
(EU) No 575/2013;
Commission Implementing
Regulation (EU) 2022/2453
paragraph 34; Template
2:Banking book -Climate
change transition risk:
Loans collateralised by
immovable property -
Energy efficiency of the
collateral
Not material
ESRS E1-9
Degree of exposure of the
portfolio to climate- related
opportunities paragraph 69
Delegated Regulation (EU)
2020/1818, Annex II
Not material
ESRS E2-4
Amount of each pollutant
listed in Annex II of the E-
PRTR Regulation (European
Pollutant Release and
Transfer Register) emitted
to air, water and soil,
paragraph 28
Indicator number 8 Table
#1 of Annex 1 Indicator
number 2 Table #2 of
Annex 1 Indicator number
1 Table #2 of Annex 1
Indicator number 3 Table
#2 of Annex 1
Not material
130
ESRS E3-1
Water and marine
resources paragraph 9
Indicator number 7 Table
#2 of Annex 1
Not material
ESRS E3-1
Dedicated policy paragraph
13
Indicator number 8 Table
2 of Annex 1
Not material
ESRS E3-1
Sustainable oceans and
seas paragraph 14
Indicator number 12 Table
#2 of Annex 1
Not material
ESRS E3-4
Total water recycled and
reused paragraph 28 (c)
Indicator number 6.2
Table #2 of Annex 1
Not material
ESRS E3-4
Total water consumption in
m3 per net revenue on own
operations paragraph 29
Indicator number 6.1
Table #2 of Annex 1
Not material
ESRS 2- IRO 1 - E4
paragraph 16 (a) i
Indicator number 7 Table
#1 of Annex 1
Not material
ESRS 2- IRO 1 - E4
paragraph 16 (b)
Indicator number 10 Table
#2 of Annex 1
Not material
131
ESRS 2- IRO 1 - E4
paragraph 16 (c)
Indicator number 14 Table
#2 of Annex 1
Not material
ESRS E4-2
Sustainable land /
agriculture practices or
policies paragraph 24 (b)
Indicator number 11 Table
#2 of Annex 1
Not material
ESRS E4-2
Sustainable oceans / seas
practices or policies
paragraph 24 (c)
Indicator number 12 Table
#2 of Annex 1
Not material
ESRS E4-2
Policies to address
deforestation paragraph 24
(d)
Indicator number 15 Table
#2 of Annex 1
Not material
ESRS E5-5
Non-recycled waste
paragraph 37 (d)
Indicator number 13 Table
#2 of Annex 1
E5-5 – Resource outflows
ESRS E5-5
Hazardous waste and
radioactive waste
paragraph 39
Indicator number 9 Table
#1 of Annex 1
Not material
ESRS 2- SBM3 - S1
Risk of incidents of forced
labour paragraph 14 (f)
Indicator number 13 Table
#3 of Annex I
ESRS 2 SBM-3 - Material
IROs and their Interaction
with Strategy and Business
Model
132
ESRS 2- SBM3 - S1
Risk of incidents of child
labour paragraph 14 (g)
Indicator number 12 Table
#3 of Annex I
ESRS 2 SBM-3 - Material
IROs and their Interaction
with Strategy and Business
Model
ESRS S1-1
Human rights policy
commitments paragraph 20
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
S1-1 – Policies related to
own workforce
ESRS S1-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8,
paragraph 21
Delegated Regulation (EU)
2020/1816, Annex II
S1-1 – Policies related to
own workforce
ESRS S1-1
processes and measures for
preventing trafficking in
human beings paragraph
22
Indicator number 11 Table
#3 of Annex I
S1-1 – Policies related to
own workforce
ESRS S1-1
workplace accident
prevention policy or
management system
paragraph 23
Indicator number 1 Table
#3 of Annex I
S1-1 – Policies related to
own workforce
ESRS S1-3
grievance/complaints
handling mechanisms
paragraph 32 (c)
Indicator number 5 Table
#3 of Annex I
S1-3 – Processes to
remediate negative
impacts and channels for
own workforce to raise
concerns
133
ESRS S1-14
Number of fatalities and
number and rate of work-
related accidents paragraph
88 (b) and (c)
Indicator number 2 Table
#3 of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
Not material
ESRS S1-14
Number of days lost to
injuries, accidents, fatalities
or illness paragraph 88 (e)
Indicator number 3 Table
#3 of Annex I
Not material
ESRS S1-16
Unadjusted gender pay gap
paragraph 97 (a)
Indicator number 12 Table
#1 of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
S1-16 – Remuneration
metrics (pay gap and total
remuneration)
ESRS S1-16
Excessive CEO pay ratio
paragraph 97 (b)
Indicator number 8 Table
#3 of Annex I
S1-16 – Remuneration
metrics (pay gap and total
remuneration)
ESRS S1-17
Incidents of discrimination
paragraph 103 (a)
Indicator number 7 Table
#3 of Annex I
S1-17 – Incidents,
complaints and severe
human rights impacts
ESRS S1-17
Non-respect of UNGPs on
Business and Human Rights
and OECD paragraph 104
(a)
Indicator number 10 Table
#1 and Indicator n. 14
Table #3 of Annex I
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818 Art 12 (1)
S1-17 – Incidents,
complaints and severe
human rights impacts
ESRS 2- SBM3 – S2
Significant risk of child
labour or forced labour in
the value chain paragraph
11 (b)
Indicator number 12 and n.
13 Table #3 of Annex I
Not material
134
ESRS S2-1
Human rights policy
commitments paragraph 17
Indicator number 9 Table
#3 and Indicator n. 11
Table #1 of Annex 1
Not material
ESRS S2-1
Policies related to value
chain workers paragraph
18
Indicator number 11 and
n. 4 Table #3 of Annex 1
Not material
ESRS S2-1
Non-respect of UNGPs on
Business and Human Rights
principles and OECD
guidelines paragraph 19
Indicator number 10 Table
#1 of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818, Art 12 (1)
Not material
ESRS S2-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8,
paragraph 19
Delegated Regulation (EU)
2020/1816, Annex II
Not material
ESRS S2-4
Human rights issues and
incidents connected to its
upstream and downstream
value chain paragraph 36
Indicator number 14 Table
#3 of Annex 1
Not material
ESRS S3-1
Human rights policy
commitments paragraph 16
Indicator number 9 Table
#3 of Annex 1 and
Indicator number 11 Table
#1 of Annex 1
Not material
ESRS S3-1
non-respect of UNGPs on
Business and Human
Rights, ILO principles or
and OECD guidelines
paragraph 17
Indicator number 10 Table
#1 Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818, Art 12 (1)
Not material
135
ESRS S3-4
Human rights issues and
incidents paragraph 36
Indicator number 14 Table
#3 of Annex 1
Not material
ESRS S4-1
Policies related to
consumers and end-users
paragraph 16
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex 1
S4-1 – Policies related to
consumers and end-users
ESRS S4-1
Non-respect of UNGPs on
Business and Human Rights
and OECD guidelines
paragraph 17
Indicator number 10 Table
#1 of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II
Delegated Regulation (EU)
2020/1818, Art 12 (1)
S4-1 – Policies related to
consumers and end-users
ESRS S4-4
Human rights issues and
incidents paragraph 35
Indicator number 14 Table
#3 of Annex 1
S4-4 – Taking action on
material impacts on
consumers and end- users,
and approaches to
managing material risks
and pursuing material
opportunities related to
consumers and end-users,
and effectiveness of those
actions
ESRS G1-1
United Nations Convention
against Corruption
paragraph 10 (b)
Indicator number 15 Table
#3 of Annex 1
G1-1– Corporate culture
and business conduct
policies and corporate
culture
ESRS G1-1
Protection of whistle-
blowers paragraph 10 (d)
Indicator number 6 Table
#3 of Annex 1
G1-1– Corporate culture
and business conduct
policies and corporate
culture
136
ESRS G1-4
Fines for violation of anti-
corruption and anti-bribery
laws paragraph 24 (a)
Indicator number 17 Table
#3 of Annex 1
Delegated Regulation (EU)
2020/1816, Annex II)
G1-4 – Confirmed incidents
of corruption or bribery
ESRS G1-4
Standards of anti-
corruption and anti- bribery
paragraph 24 (b)
Indicator number 16 Table
#3 of Annex 1
G1-4 – Confirmed incidents
of corruption or bribery
137
Environmental Information
ESRS E1 Climate Change
Strategy
E1-1 – Transition plan for climate change mitigation
As of now, no transition plan for climate change mitigation has been established by the Group yet, but it
acknowledges the need to align its business strategy with climate targets and is in the process of measuring
its financed emissions and developing a transition plan. This plan will define the Group's long-term strategy
to minimize Greenhouse Gas (GHG) emissions, embed climate risks and opportunities into its financial
planning and support the low-carbon economy transition. The Group will complete and disclose this
transition plan in the 2026 reporting cycle (for the 2025 reporting year), in accordance with regulations
and best practices for climate change mitigation and will align its sustainability strategy with relevant EU
and national regulations and frameworks, such as the National Climate Law, ensuring its activities support
the transition to a low-carbon economy.
Ε1.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and
business model
Climate-related risks might fall under either physical or transition risk categories. Physical risks can arise
from extreme weather or longer-term climate change impacts to physical assets and infrastructure.
Transition risks include: policy risks that come with the evolution of policies and regulations that promote
the adaptation to a less carbon intensive and sustainable economy, and those that constrain actions that
lead to climate instability and harm the environment, litigation risks that relate to litigation claims against
institutions and their representatives who fail to mitigate and adapt to climate change, and who fail to
disclose material climate-related & environmental information, market risks that arise through changing
demand and supply for commodities, products and services, reputation risk that relates to the changing
stakeholder (mainly customer) perception of institutions’ commitments to climate and environmental action
or inaction.
The Group identified one material negative climate risk in respect of climate change adaptation, related to
green financing, which classifies as a transition risk. It includes a reputational risk arising from a shift in
customers’ preferences who tend to demand sustainable banking solutions and a risk concerning the
changing market expectations regarding financial products. Since the Group recognizes those risks, it makes
sure to follow market trends and adjust to market expectations to secure its reputation and avoid
operational costs or possible loss in profitability. In short, the Group defines the climate risk related to
green financing as a transition risk, reflecting its exposure to market changes in the context of a larger
transition towards a low-carbon economy.
Furthermore, the Bank has conducted a CR&E Risk - Qualitative Materiality Assessment to evaluate the
significance of climate-related and environmental risks across its existing risk categories. It is worth noting
that the assessment was conducted at a Bank level as the assessment applies to significant assets and
business activities that concern the Bank. This assessment considers both physical and transition risks,
examining their potential impact on credit risk, market risk, liquidity risk, IRRBB, profitability risk (including
strategic risk), capital risk, compliance risk, operational risk, conduct, ethics & reputational risk, and ICT
risk. Given that CR&E risk is a cross-cutting risk that manifests through other existing risk categories, the
analysis assesses its impact holistically, ensuring alignment with the Bank’s Risk Appetite Framework. This
analysis contributes to the assessment of the strengths and weaknesses of the Bank’s risk policy, as it is a
comprehensive approach that considers competitive data, the overall performance of the Bank, the financial
138
statements of counterparties, environmental factors, and a range of additional information depending on
their relevance to the assessed risk.
The resilience analysis has been conducted in 2024 as part of the Bank’s broader risk assessment
framework, aligning with guidance from the European Central Bank and supervisory expectations from the
Bank of Greece. The Bank has integrated climate-related scenario analysis based on the NGFS scenarios,
specifically the Disorderly (high transition risk, low physical risk) and Hot House World (high physical risk,
low transition risk) pathways. The Bank has followed this approach to ensure that all potential transition
and physical risk impacts are considered in this qualitative assessment. The qualitative assessment involved
expert judgment, comparative sectoral evaluation, and consideration of financial and environmental data.
The Risk Management division, along with the Credit & Recoveries division and other business units,
collaborated to ensure a comprehensive approach. The Bank has identified climate risks over short (0-1
year), medium (1-5 years), and long-term (>5 years) horizons and is in the process of refining this
assessment through quantitative scenario analysis.
The analysis indicates that CR&E risk has the most significant impact on credit risk and conduct, ethics &
reputational risk. Credit risk is particularly susceptible to both physical and transition risks, given the
potential for regulatory changes, shifts in market demand, and exposure to climate-related hazards
affecting counterparties and is anticipated to be potentially impacted over the short, medium, and long
term. Thus, it is the credit risk that has been identified with the most potential vulnerability to CR&E risk.
Market risk, liquidity risk and IRRBB risk have been assessed as lower risk, particularly from a transition
risk perspective, considering the Group’s business model. Shifting its products and services portfolio by
addressing strategic gaps in green financing and capitalizing on emerging opportunities will be critical for
long-term success and will ensure that the Group’s strategy is resilient over the short, medium, and long-
term. The Group continues to refine its approach to integrating climate-related considerations into financial
decision-making and risk management. While this initial assessment remains qualitative, further refinement
through scenario-based financial impact quantification is planned. The findings will undergo governance
review, with final approval by the Risk Management Committee.
The following tables represent the results of the resilience analysis.
TRANSITION RISK
Risks assessed
Magnitude rating
Score
Time horizon of impact
Credit risk
High
4
S / M / L
Profitability risk (inc. Strategic risk)
Moderate
3
M / L
Market risk
Low
2
M / L
Liquidity risk
Low
2
M / L
Operational risk
Moderate
3
S / M / L
Conduct, Ethics & Reputational risk
High
4
S / M / L
Capital risk
High
4
M / L
IRRBB risk
Low
2
M / L
Compliance risk
High
4
S / M / L
ICT risk (Information and Communication
Technology risk)
High
4
M / L
139
PHYSICAL RISK
Risks assessed
Magnitude rating
Score
Time horizon of
impact
Credit risk
High
4
S / M / L
Profitability risk (inc. Strategic risk)
Moderate
3
M / L
Market risk
Moderate
3
M / L
Liquidity risk
Moderate
3
M / L
Operational risk
Moderate
3
S / M / L
Conduct, Ethics & Reputational risk
High
4
M / L
Capital risk
High
4
M / L
IRRBB risk
Moderate
3
M / L
Compliance risk
Low
2
M / L
ICT risk (Information and Communication
Technology risk)
Moderate
3
M / L
140
The following table is an analytical view of the tables above representing the potential magnitude rating of each risk category (transition or physical
risk), disaggregated by all risk sub-categories.
Potential Magnitude Ratings
[1]
– Summary View
CR&E risk
category
CR&E risk sub-
category
Credit risk
Profitability
risk (incl.
Strategic
risk)
Market
risk
Liquidity
risk
Operational
risk
Conduct,
Ethics &
Reputational
risk
Capital
risk
IRRBB
(Interest
rate risk in
the
banking
book) risk
Compliance
risk
ICT risk
Transition
risk
Policy and regulation
High
Moderate
Low
Low
Moderate
High
High
Low
High
Moderate
Market sentiment
High
Moderate
Low
Low
Low
High
Moderate
Low
Moderate
Low
Technology
Moderate
Low
Low
Low
Moderate
Low
Low
Low
Low
High
Physical
risk
Floods/sea level rises
High
Moderate
Low
Low
Moderate
High
High
Low
Low
Moderate
Droughts/extreme
heat
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Low
Moderate
Storms/hurricanes
High
Moderate
Low
Low
Moderate
Moderate
Moderate
Low
Low
Moderate
Water stress
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Low
Moderate
Biodiversity loss and
land usage
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Low
Moderate
[1]
While mitigating actions/factors have been considered in allocating a potential magnitude rating, as mitigants are in development and or/are to be enhanced in the coming year(s),
ratings have not been based on net risk and a prudent approach to allocation of ratings has been applied.
141
Impacts risks and opportunities management
E1-2 – Policies related to climate change mitigation and adaptation
The Group values environmental stewardship and has incorporated environmental and climate
commitments into its Sustainable Development Policy. Its objectives address material impacts, risks and
opportunities across the three ESG pillars, including adaptation and mitigation to climate change, improving
thus internal energy efficiency, and advancing sustainable banking. To ensure its effectiveness, the
Sustainability Management Committee monitors the implementation of the targets set and reports to the
Board of Directors, while regular monitoring and stakeholder feedback lead to continuous improvements.
The Sustainable Development Policy applies to all business partners and stakeholder groups, as well as the
subsidiaries with no exclusion. It covers banking operations and extends across its value chain, ensuring
sustainability considerations are integrated throughout all activities and regions where the Group operates.
Moreover, the policy aligns with international standards and recognized frameworks, including the United
Nations Sustainable Development Goals (SDGs). It is worth mentioning that the policy takes into
consideration the interests, views, and perspectives of stakeholders in its development and implementation.
To ensure transparency and accessibility, the Sustainable Development Policy is available on Optima bank's
corporate website and internal Portal, making it available to all stakeholder groups.
Through the Sustainable Development Policy, there is a commitment to minimizing the carbon footprint
through energy-efficient operations, responsible energy sourcing, and the adoption of technologies that
reduce greenhouse gas emissions. It aims to integrate green energy considerations into the strategic
orientation, in line with legal requirements and best practices. In addition, the policy highlights the
commitment to financing projects that support renewable energy, energy efficiency and other sustainability
goals. Climate-related considerations are also incorporated into the Group's decision making in order to
align with energy-efficient and sustainable solutions. Through its financing activities, advisory services, and
tailored products the Group supports SMEs and large corporations in moving to sustainable business models
and clean technologies. Going forward, the Group plans to develop and adopt a dedicated and robust
Environmental Policy which will be disclosed in the following reporting years. The policy will support its
environmental commitments by providing a framework for addressing climate-related risks and
opportunities in line with regulatory requirements and best practices.
The Sustainable Development Policy addresses climate change mitigation and adaptation, energy efficiency
and renewable energy deployment. Specifically, the policy underlines the commitments to:
• Minimize its carbon footprint through energy-efficient operations,
• Responsible energy sourcing,
• Adopt technologies that reduce greenhouse gas emissions,
• Integrate green energy considerations in its strategic planning,
• Finance projects that support renewable energy, energy efficiency and other sustainability goals,
• Make resource efficiency a priority
E1-3 – Actions and resources in relation to climate change policies
The Group aims to contribute effectively to climate change mitigation through concrete actions, that will
mark its way to climate neutrality, in line with the goals of the Paris Agreement. Through a thorough
decarbonization plan the Group contributes to the creation of a sustainable planet.
Group’s approach
The Group implements effective decarbonization strategies to minimize the carbon footprint of its own
operations and reduce greenhouse gas emissions to the highest extent possible. Through targeted ongoing
actions across divisions, the Group significantly decreases its energy consumption, an objective that
requires a multilevel and comprehensive approach. Through upgrading the data center and using virtual
servers, the IT Division profoundly supports energy consumption reduction and efficiency. An innovative
142
solution which contributes to energy efficiency is the HPE GreenLake. A hybrid cloud by design by which
resources across clouds can be managed while retaining control of data and providing flexibility on the
Group’s management of services.
Numerous operational activities of the Group support energy consumption reduction and energy efficiency
such as the use of biological detergents as well as the use of LED lighting and daylight/motion and sensors
in specific areas, to control the operating time of lighting, air conditioning and other equipment. Also,
regular inspection and evaluation of mechanical equipment in central services is being conducted to control
and reduce energy consumption without affecting the quality of service to consumers. A significant part of
the decarbonization plan towards climate neutrality contains the use of Plug-in hybrid and electric company
cars that, currently, constitute 70% of the Group’s fleet.
Regarding the preventive maintenance of electrical appliances, the Group uses environmentally friendly
refrigerants for its A/C units. The effort to make to a successful transition into a more sustainable era does
not lie solely on the operational actions but is also imprinted on the Group’s financial products. To be able
to assess the impact of climate change, the Group is about to integrate climate and environmental criteria
in its credit assessment process. Among others, it is currently financing environmentally friendly projects
and green financial products, for instance in the renewable energy sector. More specifically, 10.99% of the
Bank’s loan portfolio concerns financing projects which are active in the energy and renewable energy
sectors, such as Renewable Energy Sources (RES) and energy efficient buildings.
Group's key actions can be categorized into several decarbonization levers:
1. Energy Efficiency Improvements and GHG emissions reduction:
The Group has taken significant steps to reduce energy consumption and therefore reduce its emissions
through upgrading its data center and using virtual servers. The IT Division's implementation of the HPE
GreenLake system further enhances energy efficiency by optimizing resource management across cloud
platforms. Additionally, LED lighting and daylight/motion sensors in various facilities help to control lighting,
air conditioning, and other energy-consuming machines and significantly contribute to the lever's objective
without affecting service quality. The use of biological detergents and regular inspections of mechanical
equipment to monitor energy consumption as well as the adoption of environmentally friendly refrigerants
for A/C units also support this lever.
2. Electrification:
A notable action within this category is Group's use of Plug-in hybrid and electric company cars, which
currently make up around 50% of its fleet. This shift reduces reliance on traditional fossil fuels and directly
contributes to lowering the Group’s carbon footprint.
3. Circular Economy Practices:
By reducing waste through recyclable materials (e.g., in debit cards), and through the establishment of
recycling of specific material (papers, plastic, etc) in the Group’s buildings and branches, the Group is
embedding circular economy principles into its operations.
4. Product and Service Innovation:
In line with the transition to more sustainable finance, the Group offers green financial products, particularly
in the renewable energy sector, providing clients with funding opportunities for energy-efficient and
environmentally friendly projects. The Group's financing of renewable energy projects, particularly within
its loan portfolio, is a direct contribution to energy transition. Approximately 10.99% of the Bank's company
loan portfolio is dedicated to financing projects in the renewable energy sector, including Renewable Energy
Sources (RES) and energy-efficient buildings.
143
5. Nature-Based Solutions:
Through its collaboration with the circular economy movement 'Just Go Zero' by Polygreen, the Group
recycled organic waste and transformed it into 664.46 kg of soil fertilizer. This initiative supports nature-
based decarbonization by enhancing soil health, contributing to carbon sequestration, and reducing
methane emissions from organic waste in landfills.
These actions collectively support the Group's overarching goal of transitioning to climate neutrality,
aligning with its decarbonization plan and its commitment to mitigate climate change, in line with the Paris
Agreement. The Group is committed to building on these efforts, aiming for continuous improvement in its
sustainability journey through future key actions.
The current reporting year (2024) has been established as the base year for measuring Group's greenhouse
gas (GHG) emissions. It aims to reduce its overall emissions through initiatives targeting both operational
efficiency and sustainable financial product offerings. The impact of these efforts will be captured and
disclosed in next year's report, where the Group plans to demonstrate measurable progress in its climate
and environmental targets. These actions align with the Group's commitment to supporting climate change
mitigation in line with the EU's sustainability standards under ESRS.
The implementation of the Group’s climate-related actions, including its energy transition and fleet
electrification plans, depends on the availability and allocation of financial resources. This is managed
through an internal budgeting process, where a budget specifically related to procurement and operational
adjustments is approved. Based on this approved budget, relevant departments proceed with the necessary
investments. This structured approach ensures that there is an effective management of the climate
mitigation and adaptation initiatives while maintaining financial stability and responding to potential supply
and demand changes.
The Group’s actions (taken or planned) do not require significant monetary amounts of Capital Expenditures
(CapEx) and Operational Expenditures (OpEx) and therefore are not related to relevant line items or notes
in its financial statements.
Capital expenditures and operating expenditures reflect the initiatives to reduce emissions from its own
operations and achieve decarbonization. As part of the compliance with the EU Taxonomy regulation,
required under Commission Delegated Regulation (EU) 2021/2178, Optima bank Group has started
assessing the alignment of its loans with the Technical Screening Criteria (TSC), the Do No Significant Harm
(DNSH) principle and the Minimum Social Safeguards (MSS). In the context of the Green Asset Ratio (GAR),
the Bank aligns its loan portfolio with the EU Taxonomy requirements and analyzes the eligible and aligned
assets, according to the publicly available data of its counterparties.
Metrics and targets
E1-4 – Targets related to climate change mitigation and adaptation
Target description at Group level
Time frame
Base year
Base value
100% renewable energy in its own operations
by 2026
2026
2024
0%
34% reduction of Scope 1 location-based
emissions
2030
2024
93.244 tCO2eq
The Group has set GHG emission reduction targets that align with its Sustainable Development Policy and
its objectives regarding climate change and the environment, focusing on reducing operational emissions
through renewable energy adoption and fleet electrification. The targets contribute to the Group’s policy
144
objectives while supporting the transition to low-carbon energy sources and aligning with broader
sustainability commitments. As of now, the Group’s targets focus on climate change mitigation at its own
operations in alignment with the Sustainable Development Policy. No additional time-bound and measurable
targets related to other IROs have been set and thus until now it was not necessary to track the
effectiveness of relevant actions and policies. These targets include achieving 100% renewable energy in
its own operations by 2026 and replacing conventional vehicles with electric or plug-in hybrid electric
vehicles (PHEVs) in its fleet by 2030, leading to a 34% reduction of scope 1 location-based emissions.
The renewable energy target applies to Scope 2 market-based emissions from electricity consumption,
while the fleet electrification target addresses Scope 1 emissions from company-owned vehicles. The Group
ensures consistency with its GHG inventory boundaries by following standardized reporting frameworks,
and all reduction targets are gross, meaning no GHG removals, carbon credits, or avoided emissions are
included in achieving them. The scope of the targets is limited to the Group’s own operations, covering all
locations where the Group controls energy procurement and fleet management.
The targets do not extend to the upstream or downstream value chain. The base year is 2024, and baseline
values will be determined based on data collected in 2024. The base year will be updated every five years
from 2030 onwards as required. The renewable energy target applies from 2024 to 2026 considering that
from 2026 until 2030 market- based emissions will be zero. The fleet transition target spans from 2024 to
2030. The Group has not yet established additional interim milestones or set long-term targets for 2050.
The methodology used to define these targets is based on the Group’s operational energy consumption
data and fleet composition, considering industry trends, regulatory requirements, and technology
availability. The targets are aligned with national and EU policy goals regarding renewable energy and
sustainable mobility, but further assessment will follow to confirm full alignment with international
decarbonization pathways. At present, the Group has not established its targets in alignment with science-
based pathways limiting global warming to 1.5°C. The framework and methodology used for target setting
have included a benchmarking analysis of the banking sector and an evaluation of the Group’s overall
operations and activities through internal workshops with relevant departments. The targets have not been
externally assured. Critical assumptions in setting these targets include expected advancements in
renewable energy capacity, market availability of electric vehicles, and potential regulatory incentives or
constraints. Changes in customer preferences, economic conditions, and technological progress may also
impact emissions reduction efforts, and these factors will be monitored over time.
The target-setting process has primarily involved internal assessments. The Group has not yet conducted
formal stakeholder consultations with external parties such as regulators, customers, or industry
associations for these targets but is committed to doing so in the future.
Since 2024 is the base year, there are currently no changes to report in targets, metrics, or underlying
methodologies. However, any future adjustments will be disclosed along with the rationale for such
changes. Similarly, performance against these targets has not yet been assessed, but monitoring
mechanisms and key metrics will be established to track progress over time.
The primary decarbonization levers include transitioning to 100% renewable energy to reduce Scope 2
emissions and replacing conventional vehicles with PHEVs or electric vehicles to reduce Scope 1 emissions.
The expected impact of these measures will be quantified as data becomes available.
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E1-5 – Energy consumption and mix
Table 1: Energy consumption and mix (2024)
ENERGY CONSUMPTION
UNIT
AMOUNT
Fossil energy consumption
MWh
2,227.57
Share of fossil sources in total energy consumption
%
100
Consumption from nuclear sources
MWh
-
Share of consumption from nuclear sources in total energy consumption
%
-
Fuel consumption for renewable sources, including biomass (also comprising
industrial and municipal waste of biologic origin, biogas, renewable hydrogen,
etc.)
MWh
-
Consumption of purchased or acquired electricity, heat, steam, and cooling from
renewable sources
MWh
-
Consumption of self-generated non-fuel renewable energy
MWh
-
Total renewable energy consumption
MWh
-
Share of renewable sources in total energy consumption
%
-
Total energy consumption
MWh
2,227.57
Note: The Group does not consume energy from renewable or nuclear sources.
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
Table 2: Gross Scopes 1, 2 and Total GHG emissions (2024)
Emissions
unit
amount
Scope 1 emissions
tCO
2
eq
128.32
Location-based Scope 2 emissions
tCO
2
eq
872.01
Market-based Scope 2 emissions
tCO
2
eq
636.11
Total GHG emissions (location-based)
tCO
2
eq
1,000.33
Total GHG emissions (market-based)
tCO
2
eq
764.43
Total GHG emissions (location-based) intensity
tCO
2
eq/net revenue K €
0.0039
Total GHG emissions (market-based) intensity
tCO
2
eq/net revenue K €
0.003
Net Revenue
K €
254,723
As there have been no significant changes in the definition of the reporting Group and its upstream and
downstream value chain, there is no impact on the comparability of the reported GHG emissions between
the current and previous reporting periods. The base year for reporting is the current year, and no
reductions have been reported.
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The calculation of GHG emissions follows the methodology outlined in the National Climate Law and ISO
14064-1:2018 Standard with emission factors sourced from the Ministry of Energy's official guidelines and
the National Inventory Report (NIR). The emission factors used are derived from the NIR and DAPEEP,
ensuring compliance with the national framework for climate-related data. For Scope 2 emissions, two
approaches are applied:
• Location-based method: The remaining energy mix of the country is used, reflecting the national
grid’s overall emissions.
• Market-based method: The provider’s energy mix is used, focusing on the specific emissions
associated with the electricity purchased by the organization.
These methodologies were chosen to ensure accuracy and consistency with national reporting
requirements, in alignment with the country’s climate targets. The tools and documents used for the
calculations are those provided by the Ministry of Energy.
There are no differences between the reporting periods of the Group and the entities in its value chain.
Therefore, there are no significant events or changes in circumstances relevant to the GHG emissions that
occurred between the reporting dates of the entities in the value chain and the date of the Group’s general
purpose financial statements.
The Commission Delegated Regulation (EU) 2023/2772 states in Appendix C that undertakings or groups
not exceeding on their balance sheet dates the average number of 750 employees during the financial year
(on a consolidated basis where applicable) may omit the datapoints on Scope 3 emissions and total GHG
emissions for the first year of preparation of their sustainability statement. As the Group falls into the
aforementioned category it may omit data points relevant to Scope 3 emissions.
The net revenue used to calculate the intensity of GHG emissions is fully reconciled with the Group’s
financial statements as it was obtained from the Group's annual report for 2024.
All the above metrics of the section are not validated by an external body.
ESRS E5 Resource use and circular economy
Impacts, risks and opportunities management
E5-1 – Policies related to resource use and circular economy
The Group is committed to protecting the environment and has embedded its climate and environmental
goals into its Sustainable Development Policy. Covering all three ESG pillars, the policy addresses key
impacts, risks, and opportunities across its value chain, including waste. The policy highlights, among
others, resource efficiency, waste reduction and circular economy, as core environmental objectives. The
Group places significant emphasis on resource efficiency to reduce virgin resource use, decrease waste,
recycle, and follow proper disposal protocols throughout its operations and value chain. Internal awareness
programs are implemented to promote responsible practices within the organization, while sustainable
sourcing and the use of renewable and recycled materials are being promoted.
The Group prioritizes preventing waste and reusing materials over disposal or treatment. In its own
operations the Group switched to electronic documents, use of recycled materials for printed items, dropped
paper-based advertising, and introduced recyclable debit cards. At Group's headquarters a recycling and
upcycling system in partnership with external organizations has been placed to support waste management
and circular economy initiatives. These actions represent further steps towards environmental sustainability
and circular economy principles.
147
The Group aims to develop and implement a standalone Environmental Policy in the next reporting years.
This forward-looking approach aligns the Group's operations and value chain with sustainable and
responsible environmental practices.
Further information regarding the Sustainable Development Policy’s Minimum Disclosure Requirements
(MDRs) can be found in ESRS E1.
E5-2 – Actions and resources related to resource use and circular economy
The Group has implemented various initiatives to minimize waste generation both within its own operations
and throughout its upstream and downstream value chain. These efforts include:
• The adoption of a "no-paper" policy in numerous activities and interactions with clients and the exclusive
use of digital signatures along with the promotion of electronic copies for accounts and contracts, where
feasible, the use of recycled materials in its printed forms
• The replacement of all debit cards with recyclable ones
• The reduction and restriction of paper-based advertising materials, brochures, and printouts. Waste
management is further supported by internal initiatives such as battery recycling in collaboration with AFIS
(ΑΦΗΣ) company.
• Partnership with the first circular economy movement in Greece "Just Go Zero" by Polygreen and
creation of a recycling and upcycling system at the Group's headquarters for paper, plastic, aluminum,
glass, coffee capsules, cigarette butts, food and organic waste.
• Collaboration with GreenFence – MetalLogic Single member S.A. for the recycling of old electronic
equipment, including the destruction of 1,440 kg of servers and PCs, of which 837 kg will provide a return
benefit. Financing of waste management and circular economy projects in municipalities and regions.
These actions reflect the Group's commitment to waste reduction throughout its value chain.
The Group actively integrates waste prevention measures throughout its operations and value chain,
focusing on minimizing waste generation at every stage. A core element of these efforts is the
implementation of a "no-paper" policy, which reduces reliance on physical documents across numerous
activities and client interactions. The Group has adopted digital signatures and promotes the use of
electronic copies for accounts and contracts wherever feasible, thus significantly decreasing paper usage.
Further actions include the elimination of paper-based advertising materials, brochures, and printouts, as
well as the incorporation of recycled materials in printed forms. Additionally, the Group has replaced all
debit cards with recyclable ones, demonstrating its commitment to reducing waste from physical products.
These measures reflect the Group’s proactive approach to waste generation prevention across its value
chain.
The Group implements a series of initiatives to optimize waste management processes across its operations.
Internally, the Group has established battery waste collection points with AFIS (ΑΦΗΣ) buckets, enabling
proper disposal and recycling. Through its collaboration with "Just Go Zero" by Polygreen, the Group
ensures the efficient handling and recycling of various materials through the implementation of a recycling
and upcycling system. Additionally, the partnership with GreenFence – MetalLogic Single member S.A..
focuses on the responsible recycling of electronic equipment, including servers and PCs, ensuring minimal
electronic waste and resource recovery, wherever possible. These initiatives demonstrate the Group’s
commitment to streamlining waste management practices, improving recycling efficiency, and minimizing
environmental impact from waste disposal.
The Group contributes to the circular economy through targeted partnerships and structured initiatives that
emphasize resource recovery and waste repurpose. At the Group’s headquarters, collaboration with "Just
Go Zero" by Polygreen has resulted in significant outcomes, including:
148
• Diverting thousands of kilograms of waste from landfills
• Transforming organic waste into soil fertilizer
• Saving thousands of liters of water from paper processing and textile industries
Additionally, the responsible recycling of electronic equipment through GreenFence – MetalLogic ensures
valuable materials are recovered and reintegrated into production cycles rather than being discarded. These
actions reflect the Group’s commitment to circularity, focusing on measurable environmental benefits and
sustainable resource use across its operations and partnerships.
While the Group has not yet participated in collective actions specifically focused on circular economy and
resource use, Bank’s membership in the Hellenic Bank Association (HBA) provides a platform for engaging
in industry-wide discussions and exploring future collaboration opportunities aligned with circular economy
principles. Through this membership, the Group remains informed about sectoral developments and
emerging best practices, laying the groundwork for potential collective initiatives in the future.
E5-3 – Targets related to resource use and circular economy
The Group understands the importance of setting clear environmental targets and tracking progress to
drive meaningful change. While it has not yet formally adopted an Environmental Policy, its core
environmental principles are adequately described in the Sustainable Development Policy, which sets
priorities for resource efficiency, waste reduction, and circular economy principles across operations and
the value chain. Currently, the Group does not have a system in place to track the effectiveness of its
environmental policies and actions through targets. However, it plans to develop a structured approach,
including clear monitoring processes.
E5-5 – Resource outflows
Table 1: Waste
WASTE OVERVIEW
unit
amount
Total waste generated
kg
2,240.94
Non-recycled waste
kg
470.36
Percentage of non-recycled waste
%
21
WASTE DIVERTED FROM DISPOSAL (non-hazardous waste)
Types of recovery
unit
amount
Preparation for reuse
kg
-
Recycling
kg
1,770.58
<Other recovery operations>
kg
470.36
Total waste diverted from disposal
kg
2,240.94
WASTE DIRECTED TO DISPOSAL (non-hazardous waste)
Types of treatment
unit
amount
Incineration
kg
-
Landfill
kg
-
<Other disposal operations>
kg
-
Total waste directed to disposal
kg
-
*Note: Due to the nature of its operations, the Group does not produce any kind of hazardous or radioactive waste. The only amount
of waste measured is waste diverted from disposal. Waste directed to disposal is not being measured since its amount is not considered
significant due to the nature of the Group’s operations.
149
The above metrics of the section have not been validated by any external body.
The waste composition primarily consists of recurring waste streams generated through its daily operations.
They are predominantly non-hazardous and typical of office-based operations including administrative
processes, customer service interactions, and day-to-day office functions. Key waste streams include paper
waste from documentation processes, plastic and aluminum waste from packaging and consumables, and
organic waste from employee facilities. These waste streams are systematically managed through the
recycling and upcycling system in collaboration with 'Just Go Zero' by Polygreen. Additionally, it ensures
proper disposal of battery waste through dedicated collection points (AFIS (ΑΦΗΣ) buckets) within its
facilities. Specific initiatives, such as eliminating paper-based advertising materials and replacing debit cards
with recyclable materials, have been implemented to reduce waste generation.
The materials present in the recurring waste streams include paper, plastic, aluminum, glass, organic
matter, and small electronic components such as batteries. While electronic waste, including servers, PCs,
and hard drives, is not part of the Group’s regular waste streams, it is managed periodically through
specialized collaborations, such as the one with GreenFence – MetalLogic Single member S.A., ensuring
secure disposal and recycling of decommissioned equipment.
Since the Group does not produce any products, no criteria and assumptions were used to determine and
classify products designed along circular principles. Regarding methodologies that have been used, all
waste is picked up by a waste management partner and weighed in kilograms. As far as assumptions are
concerned, from the total amount of waste materials, food waste, coffee, capsules, and cigarette butts are
considered to undergo recovery operations from the waste management partner. Food waste, coffee and
capsules are directed towards composting or biogas production and cigarette butts are directed towards
energy recovery. Lastly, paper/cardboard, plastic and aluminum are led to recycling.
Disclosures pursuant to Article 8 of EU Regulation 2020/852 (“EU Taxonomy Regulation”)
The EU Taxonomy Regulation, adopted by the European Parliament in 2020, establishes a unified
classification system to help investors and businesses determine the environmental sustainability of specific
economic activities. On June 4, 2021, the European Commission adopted Delegated Regulation (EU)
2021/2139, setting out the technical screening criteria for climate change mitigation and adaptation.
Additionally, on July 6, 2021, the Commission adopted Delegated Regulation (EU) 2021/2178 ("Disclosures
Delegated Act"), which supplements Article 8 of the Taxonomy Regulation and defines the content,
methodology and presentation of disclosures related to the proportion of environmentally sustainable
economic activities in financial and non-financial undertakings.
On July 15, 2022, a Complementary Climate Delegated Act was published in the Official Journal of the EU,
expanding the Taxonomy framework to include specific nuclear and gas energy activities under strict
conditions (“Complementary Climate Delegated Act”). Sequentially, in November 2023, a new Delegated
Act was introduced, extending the Taxonomy to cover four additional environmental objectives: sustainable
use and protection of water, transition to a circular economy, pollution prevention and control, and
protection and restoration of biodiversity and ecosystems. Further amendments were made to incorporate
additional economic activities that contribute substantially to climate change mitigation and adaptation and
to clarify reporting requirements related to the new objectives.
As a cornerstone of the EU’s sustainable finance framework, the EU Taxonomy serves as a vital market
transparency tool, directing investments toward economic activities essential for achieving the European
Green Deal objectives. It establishes clear criteria for identifying activities aligned with a net-zero trajectory
by 2050 while also supporting broader environmental goals beyond climate change.
Under EU Taxonomy Regulation, the term "eligible" applies to economic activities covered by the relevant
Delegated Acts. However, eligibility alone does not imply that an activity is environmentally sustainable.
The concept of an "environmentally sustainable activity or investment" is linked to alignment, which
150
requires a more in-depth assessment. For an economic activity to be considered taxonomy-aligned, it
should:
i. meet all applicable Technical Screening Criteria (TSC) to at least one of the six environmental
objectives;
ii. ensure the principle of Do No Significant Harm (DNSH) to all other environmental objectives; and
iii. comply with Minimum Social Safeguards.
In accordance with the EU Taxonomy Regulation, credit institutions are required to disclose taxonomy
eligibility and alignment data for all six environmental objectives based on publicly available disclosures of
counterparties. The key metric for measuring alignment is the Green Asset Ratio (GAR) for on-balance
sheet covered assets, which must be reported with a detailed breakdown by environmental objective,
counterparty type and category of eligible and environmentally sustainable (aligned) assets.
Application of the Taxonomy Regulation to the Group
The taxonomy eligibility assessment shows the proportion of the Group’s assets financed and invested in
taxonomy-eligible economic activities, relative to the total covered assets. The taxonomy alignment
assessment, specifically the Green Asset Ratio (GAR), reflects the proportion of the Group’s assets financing
and investing in taxonomy-aligned economic activities as a percentage of total covered assets. The
numerator includes loans and advances, debt securities, equities and repossessed collaterals that finance
taxonomy-aligned activities, based on relevant Turnover and CapEx KPIs. The following categories of
exposures are excluded from the GAR ratio calculation as appropriate:
• Exposures to central governments, central banks, and supranational issuers (excluded from both
the numerator and denominator of KPIs);
• Exposure in trading portfolio securities (excluded from both the numerator and denominator of
KPIs);
• Exposures in derivatives (excluded from the numerator of KPIs);
• Exposures to entities not obligated to publish non-financial information under Article 19a or Article
29a of Directive (EU) 2013/34 (excluded from the numerator of KPIs);
• On-demand interbank loans (excluded from the numerator of KPIs);
• Cash and cash-related assets (excluded from the numerator of KPIs);
• Other categories of assets (e.g., Goodwill, commodities, etc.), (excluded from the numerator of
KPIs).
The Group publishes the relevant KPIs based on publicly available disclosures from the financial and non-
financial counterparties limited to undertakings subject to the Non-Financial Reporting Directive (“NFRD”).
Therefore, the respective KPIs do not include exposures to SMEs. The information on eligible and aligned
economic activities is derived from the publicly disclosed Turnover and CapEx of the counterparties. Due
to the unavailability of required data for the financial year 2024, the disclosed information is based on the
2023 annual reports of the counterparties.
For specific-purpose funding, which is defined as exposures allocated to particular identified activities
(“known use of proceeds”), project-specific KPIs are applied in the taxonomy-eligibility and alignment
assessment. For retail exposures relevant to the EU Taxonomy, only loans collateralized by residential real
estate, loans for renovation purposes and loans for purchasing vehicles have been considered for taxonomy
alignment. In terms of off-balance sheet exposures, the Group included financial guarantees and assets
under management for guarantee and investee non-financial undertakings. Other off-balance sheet
exposures, such as commitments, are excluded from this calculation.
151
Summary of KPIs
The table below contains the summary of the main KPIs according to the EU Taxonomy Regulation for the
reference year 2024.
Total
environmentally
sustainable
assets****
Total
environmentally
sustainable
assets*****
KPI****
KPI*****
% coverage
(over total
assets)***
% of assets
excluded
from the
numerator
of the GAR
(Article 7(2)
and (3) and
Section
1.1.2. of
Annex V)
% of assets
excluded
from the
denominator
of the GAR
(Article 7(1)
and Section
1.2.4 of
Annex V)
Main KPI
Green
asset ratio
(GAR)
stock
55
108
1.26%
2.51%
77.89%
60.44%
22.11%
Total
environmentally
sustainable
activities****
Total
environmentally
sustainable
activities*****
KPI****
KPI*****
%
coverage
(over
total
assets)
% of assets
excluded
from the
numerator
of the GAR
(Article
7(2) and
(3) and
Section
1.1.2. of
Annex V)
% of assets
excluded
from the
denominator
of the GAR
(Article 7(1)
and Section
1.2.4 of
Annex V)
Additional
KPIs
GAR (flow)
10
56
2.13%
12.25%
8.23%
-
-
Trading book*
N/A
N/A
N/A
N/A
Financial
guarantees
29
53
14.79%
27.43%
Assets under
management
6
81
1.51%
20.19%
Fees and
commissions
income**
N/A
N/A
N/A
N/A
* For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR
**Fees and commissions income from services other than lending and AuM
Instutitons shall dislcose forwardlooking information for this KPIs, including information in terms of targets, together with relevant explanations on the methodology applied.
*** % of assets covered by the KPI over banks´ total assets
****based on the Turnover KPI of the counterparty
*****based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
As of year-end 2024, the Group’s total GAR based on turnover stood at 1.26% of total covered assets,
while GAR based on CapEx reached 2.51%. The Group intends to progressively align its goals with the EU
Taxonomy.
In line with the Disclosures Delegated Act and the Complementary Climate Delegated Act, Appendix C
includes the reporting templates, Annexes VI and XII respectively.
152
Social Information
ESRS S1 Own Workforce
Strategy
S1.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and
business model
The Group’s impacts, risks, and opportunities regarding its own workforce, as identified in the DMA, are
closely connected to its business model. These factors shape and support the Group’s ongoing adaptive
approach, reflected in its updated strategy, which aims to enhance positive impacts, mitigate negative
ones, and effectively manage the risks and opportunities which arise from these impacts.
All people in the Group’s workforce who can be materially impacted are included in the scope of disclosure
under ESRS 2. The material impacts include impacts connected with the Group’s own operations and related
to its workforce. The Group employs a diverse workforce that includes both employees and non-employees,
depending on the nature of their collaboration with the Group. The Group's employees and executives are
the Group’s cornerstone as their role is crucial for its daily operation and development. They are employed
on fixed- or indefinite-term contracts, depending on the needs of the Group and the type of their role.
Their positions cover a wide range of responsibilities, from administrative and operational tasks to strategic
decisions. They also have additional employment benefits such as health care, insurance coverage and
professional development programs. Non-employees of the Group are provided by third-party companies
and cover specialized needs or participate in the implementation of specific projects. Non-employees are
mainly engaged in projects that require technical or specialized knowledge, such as customer service, the
development of digital infrastructure, the maintenance of technical systems or the provision of other
support services. Although they are not part of the Group's staff, their contribution is important for the
completion of projects that serve the strategic and operational needs of the Group.
Groups’ operations have substantial implications for both employees and non-employees. For the former,
the Group ensures professional stability and long-term career development opportunities. For the latter,
the Group provides opportunities to participate in challenging projects, helping them to broaden their
professional experience in a highly demanding banking institution. The human resources management
strategy focuses on creating a supportive environment for the own workforce, ensuring that they contribute
effectively to the achievement of the Group's goals.
The results of the DMA identified one material negative impact which refers to the gender pay gap. The
negative impact is not connected to either widespread/systemic or related to individual incidents. It reflects
the difference between the average pay of men and women as this is observed in specific positions.
Through the DMA, the Group identified positive impacts for its own employees and across value chain in
Greece, where the Group operates. Positive impacts mainly highlight the Group's commitment to the
creation of a healthy work environment, support employees' well-being and work-life balance, provide
competitive remuneration based on merit recognition, ensure the right to free association for employees
and implement policies for inclusivity and equal opportunities for all. The Group also contributes to job
creation across its value chain by generating direct, indirect, and induced jobs across its value chain. The
Group’s actions focus on enhancing employee well-being, career development, financial security, and work-
life balance through various activities. These include policies for parental support, remote work options,
comprehensive health benefits, extra paid leaves, such as leave for blood donations. Employees are
engaged through company events, athletic events, and cultural initiatives like free tickets to performances
153
and museums. Career growth is supported by structured performance reviews, internal job postings, and
trainings. The Group also promotes diversity and women’s empowerment through mentoring programs.
With regards to opportunities, arising from related impacts, work-life balance initiatives, adequate wages
and promotion of equality have been identified as main opportunities since they may increase the reputation
as a family-friendly employer, improve the retention of employees, attract future employees and increase
employees' productivity. Simultaneously, continuous training aims to the professional development of
employees with specialized expertise and experience may lead to increased training costs, which emerges
as a significant risk.
None of the Group’s material impacts on employees arise from transition plans concerning the reduction of
negative impacts on the environment or achievement of greener and climate- neutral operations.
Furthermore, due to the nature and location of the institution, the Group does not identify significant risk
of incidents of forced labor, compulsory labor or child labor. In addition, there are no people with
characteristics, working in specific contexts, or Group’s specific activities who may be at greater risk of
harm. The Group ensures a safe and inclusive working environment for all employees. Consequently, there
are no material risks or opportunities arising from impacts that relate to specific groups of people.
Impacts, risks and opportunities management
S1-1 – Policies related to own workforce
The Group is committed to ensuring fair and safe working conditions, as well as equal treatment of all its
employees. In this context, the Group has adopted the following policies that reflect its values and
commitments:
•
Policy for the Prevention and Combating of Incidents of Violence and Harassment at Work
- Complaint Management
: The policy for the Prevention and Combating of Incidents of Violence and
Harassment at Work - Complaint Management aims to prevent incidents of violence and harassment in the
work environment, promoting and considering the well-being and safety of all employees. The objective of
the Policy for the Prevention and Combating of Incidents of Violence and Harassment at Work - Complaint
Management is to prevent and combat all forms of violence and harassment that occur in the workplace,
whether it takes place in the designated workplaces or anywhere else. This includes, but is not limited to,
private places where work is performed, during training activities, travel, and work-related social events,
through communications using technology, etc. Regarding the procedures for monitoring incidents of
violence and harassment, a whistleblowing channel is available for all employees where they can report
relevant incidents with emphasis on the protection of personal data while ensuring equitable treatment for
all. At the same time, this practice provides a clear procedure for managing and investigating complaints,
measures to prevent, control and limit risks, and protection against retaliation to ensure fair treatment.
The Group is committed to evaluating this policy in a manner consistent with the requirements of applicable
laws and regulations, ensuring that it is constantly updated on relevant developments. The Policy for the
Prevention and Combating of Incidents of Violence and Harassment at Work - Complaint Management
applies to the Group employees regardless of their contractual status, including those employed under a
contract of employment, through third-party service providers, and those attending training, including
trainees and apprentices’ employees. For any information, clarification, or questions regarding this policy,
interested parties may contact the reference person, who is the Head of Human Resource Division and is
accountable for the implementation of this policy. The Policy for the Prevention and Combating of Incidents
of Violence and Harassment at Work - Complaint Management is available on the intranet and the corporate
website of Optima bank.
•
Remuneration Policy for the members of BoD
: Defines the principles and procedures for shaping
the remuneration of Board members, ensuring compliance with regulatory requirements and transparency
principles. The policy aims to establish a comprehensive remuneration framework for Board Members of
Optima bank, including both executive and non-executive members. Its purpose is to ensure adherence to
regulatory standards. The Remuneration Policy for the members of BoD is aligned with the corporate
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strategy with the intention to promote sustainable and long-term prosperity. To ensure alignment with the
latest regulations and market dynamics, the policy is being reviewed and reassessed by the Remuneration
and Nomitations Committee and is being approved by the General Assembly of shareholders. The
Remuneration Policy for the members of BoD is updated when it is necessary to comply with laws and
regulations. The Remuneration Policy for the members of BoD applies to the Bank’s BoD members. The
Remuneration and Nominationss Committee is responsible for the implementation of this policy. The
Remuneration Policy for the members of BoD is aligned with the corporate strategy with the intention to
promote sustainable and long-term prosperity. Moreover, this policy supports the establishment of
equitable and competitive remuneration, cultivating increased motivation and company retention. The
Remuneration Policy for the members of BoD is available on the intranet as well as on the Optima bank
website. There is, also, Remuneration Policy for the members of BoD for Optima bank's subsidiary Optima
Factors S.A., which is aligned with the Bank's Remuneration Policy for the members of the BoD.
•
Staff Remuneration Policy:
The Staff Remuneration Policy’ objective is to ensure fair, competitive
and transparent remuneration of staff, based on the principles of equality and meritocracy. The Staff
Remuneration Policy aims to establish a comprehensive remuneration framework for senior and executive
management and employees. The Staff Remuneration Policy supports the establishment of equitable and
competitive remuneration, cultivating increased motivation and company retention, while generating direct,
indirect and induced employment opportunities across its entire value chain by offering competitive
compensation. Optima bank, as part of its overall employee framework practices, offers beneficial housing
loan terms to its employees. The policy is updated when it is necessary to comply with laws and regulations.
The Staff Remuneration Policy applies to all employees of the Bank and is approved by Optima bank's
Board of Directors, following endorsement by the Remuneration and Nominations Committee, underlying
the importance of continuous compliance with the regulatory framework and market dynamics. The Staff
Remuneration Policy is available on the intranet. There is, also, the Remuneration Policy for Group's
subsidiary OPTIMA ASSET MANAGEMENT Α.Ε.D.Α.Κ, which is aligned with the Bank’s Remuneration Policy
for the Employees of Optima bank.
•
Code of Ethical Conduct and Ethics
: Defines the values, principles and ethical standards that guide
the behavior of the employees and the executives, promoting an environment of respect, integrity, and
responsibility, while ensuring the right of free association of the organization’s employees in an appropriate
manner and safeguarding the company’s reputation. It applies to all employees and every employee is
required to adhere to it. Additionally, a declaration of acceptance and commitment to adherence to the
principles outlined in the Code
of Ethical Conduct and Ethics, is obtained by all staff members upon issuance
or any modification of the Code of Ethical Conduct and Ethics. The Code of Ethical Conduct and Ethics
outlines the relationship between the Group and its employees, clients, shareholders, associates, and
competitors. It is approved by the BoD and its implementation is assigned to the Human Resources Division.
The Code of Ethical Conduct and Ethics is available on Optima bank's portal, where all employees have
access and is part of the onboarding materials.
•
Whistleblowing Policy:
Ensures the protection of employees who wish to report unfair practices by
providing a confidential and secure framework for making and investigating such reports. In this manner,
the Group ensures the well-being of all its employees by providing high quality working conditions, including
adequate workspace and respect for their privacy. The Whistleblowing Policy is updated when it is
necessary to comply with laws and regulations. The Whistleblowing Policy applies to all stakeholders of the
Group. The Whistleblowing policy is founded on the provisions of Law 4990/2022 and is approved and
overseen by Optima bank's Executive Committee. It establishes a secure environment in which employees
shall confidentially report unethical practices. However, it does not encompass cases of rumors,
disagreements on the Group’s policies and decisions, personal disputes between employees, or customer
complaints concerning service quality. The Whistleblowing Policy is available on the intranet.
•
Absenteeism Policy
: Informs the Group’s employees about the most common types of entitled leave
days and the conditions for granting them. The Absenteeism policy applies to all activities within the Group,
covering both upstream and downstream value chains and affects all employee groups within the
organization. The Heads of Departments are accountable for the implementation of this policy and
155
responsible for the timely planning of the annual regular leave (recreational leave) of employees in their
area of responsibility. The Absenteeism policy is available on the intranet.
•
Sustainable Development Policy
: The Sustainable Development Policy prioritizes fair working
conditions and equal opportunities for all. By fostering better working conditions, and supporting work-life
balance, the Group demonstrates its dedication to employee well-being. More information regarding the
Minimum Disclosure Requirements of the Sustainable Development Policy can be found in ESRS E1.
The above policies reinforce the Group's commitment to provide a supportive and non-discriminatory
working environment that promotes equality, meritocracy, and transparency.
There is no specific human rights policy in place which is aligned with relevant internationally recognized
instruments such as UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental
Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises, including processes
and mechanisms to monitor compliance with the relevant internationally recognized instruments. The Group
promotes equal opportunities, fair treatment, and respect for freedom of expression among its employees,
through the implementation of its policies. The Sustainable Development Policy advances respect for human
rights and provides an inclusive, discrimination-free work environment while ensuring that every employee
feels appreciated, supported, and empowered to achieve their full potential respect for human rights.
Additionally, according to the Whistleblowing Policy, employees can report violations of human rights and
instances of discrimination. Finally, the adopted corporate governance practices and the Greek Corporate
Governance Code which promote transparency, accountability, and sustainable operation, have seet the
foundations and momentum to fully integrate standards such as the UN Guiding Principles, further delving
into the field of social responsibility.
The Group opposes all forms of discrimination, including harassment and unprofessional conduct. It
engages with its workforce through all available communication channels, ensuring that all employees are
well informed. This comprehensive engagement includes regular updates, discussions, feedback
mechanisms, and secure communication channels. By maintaining open lines of communication, it can
effectively identify and address potential risks of human rights violations if they occur. There are also robust
measures in place to provide and/or enable remedies for human rights impacts, such as the Whistleblowing
Policy. All employees are well informed about their rights and the processes available to them for reporting
concerns. Each report submitted through these channels is thoroughly reviewed by the Internal Audit
Division of Optima bank to ensure that appropriate actions are taken. This systematic approach not only
helps in promptly addressing any human rights violations, in case they occur, but also reinforces the
commitment to maintaining a safe and respectful work environment for all employees.
Regarding trafficking in human beings, forced labor or compulsory labor and child labor, the Group has not
yet adopted standalone policies which address such issues, due to the nature and location of its operations,
but it should be noted that the Code of Ethical Conduct and Ethics refers to the respect for human dignity
and human rights and opposes child labor.
The group’s business activities do not require any specific workplace accident prevention policy or
management system. However, all prerequisites required by Greek legislation regarding workplace safety
and security are met. Evacuation plans are designed and communicated to employees in advance, so they
are aware of emergency procedures. Evacuation drills are conducted on a regular basis to train personnel
and ensure readiness in the event of an emergency, occupational doctor and safety technician scheduled
visits are carried out, as provided by law, ensuring the monitoring and prevention of health and safety
issues.
The Group plans to develop a concrete policy to address issues related to diversity & inclusion and the
elimination of discrimination. However, explicit references to discrimination issues, such as racial and ethnic
origin, color, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction
156
or social origin, or other forms of discrimination, exist in the Sustainable Development Policy. Prevention
of discrimination regarding gender is also reflected in the Policy for the Prevention and Combating of
Incidents of Violence and Harassment at Work - Complaint Management, which clearly prohibits any
repeated, improper behavior directed at an employee or group of employees, or at third parties (e.g., a
partner, a provider, a supplier, etc.), that poses a risk to their health and safety. Although there is no
specific policy commitments related to inclusion or positive action for people from groups at particular risk
of vulnerability in its own workforce, the Group treats all employees equally. The forthcoming policy for
diversity & inclusion and the elimination of discrimination will address specific procedures to ensure that
discrimination is prevented, mitigated, and solved upon detected, as well as to advance diversity and
inclusion on a broader perspective.
S1-2 – Processes for engaging with own workforce and workers’ representatives about
impacts
The Group engages directly with its employees through various communication methods, including general
management's visits to branches, access to internal portal for daily communication, regular meetings with
HR, and training sessions. This direct engagement ensures that all needs and requirements of employees
are considered in decision-making processes regarding the impacts. The Group actively monitors and
evaluates its workforce initiatives through structured feedback mechanisms and ongoing engagement. Key
assessment methods include formal annual performance evaluations with discussions and HR reporting,
and monthly catch-up meetings providing real-time feedback and issue resolution. Direct communication
with HR Division is facilitated via immediate phone calls and an open email channel for concerns and
requests. Employee engagement and workplace feedback are also gathered through network branch visits,
where senior directors (affluent RMs, business RMs, assistant RMs) visit branches four times per year. The
HR Director visits branches twice per year to collect direct employee feedback. Additionally, there is a
dedicated email contact for talent acquisition concerns and workforce-related inquiries. This proactive
approach ensures that any issues are promptly recognized and managed, thereby upholding commitment
to protecting human rights within its workforce. These engagements provide continuous opportunities for
employees to share their views and feedback and discuss actual and potential impacts. The Human
Resources Division ensures that engagement happens, while the Head of Human Resources Division holds
the most senior role in operational responsibility. Specifically, the Head of Human Resources Division
ensures that the results of these engagements are considered in the broader context of work-related
impacts management. The Group has established collective bargaining agreements with employees'
representatives regarding labor rights and issues. These agreements enable the Group to gain valuable
insights into the perspectives of its employees. Dialogues are held 1-2 times per year and feedback is
provided by employees’ representatives. The effectiveness of the engagement is assessed through regular
feedback surveys, performance reviews, and follow-up meetings when deemed necessary, as those
mentioned above. The outcomes of these assessments are also used to manage employees’ concerns and
material impacts. Any agreements or outcomes resulting from these engagements are used to ensure
continuous improvement in addressing work-related issues and enhancing overall employee satisfaction.
The Group remains committed to fostering a supportive work environment for all employees. The above
communication channels are also used to address any potential employees’ vulnerability to impacts.
S1-3 – Processes to remediate negative impacts and channels for own workforce to raise
concerns
Mitigating the material negative impact of gender pay gap is essential not only for promoting fairness and
equality but also for sustaining a motivated, engaged, and efficient workforce. By implementing measures
to eliminate the gender pay gap, the Group boosts employee satisfaction, increases motivation, and
cultivates a positive workplace environment. The employee wages are aligned with the Staff Remuneration
Policy and take multiple criteria into consideration such as the level of position, job specialization, personal
157
development and advancement opportunities, performance appraisal, value in the labor market, fixed
remuneration paid by the competition for identical positions, tasks and skills, collective and company labor
agreements (where applicable), and labor legislation. Gender discrimination does not exist in remuneration
policy. Human Resources Division regularly performs reviews to identify disparities in compensation among
male and female employees. To identify instances of gender pay gap, a monitoring process is in place to
record such cases. Once a discrepancy is observed, its scope and underlying causes are assessed. This
assessment contributes to the development of a comprehensive record for future strategic planning and
policy adjustments. The main reason for the gender pay gap is that lower positions, especially in branches,
are predominantly held by women and therefore the ratio is affected. The Group is designing targeted
actions to address gender pay gap in cases where there are identified disparities in similar roles.
Recruitment practices, promotion rates, performance evaluations, and other relevant factors are some of
the practices being considered. This may also include salary adjustments and enhancing training and
development opportunities. Salary adjustments will be communicated transparently to the affected
employees, along with the rationale behind the changes.
To promote open communication at all levels, employees engage with the above methods for
communication and information, including internal web resources and continuous communication with the
Human Resources Division. Employees can use any method they prefer to discuss pay disparities or
highlight issues they want to address.
Complaints regarding employee-related matters are handled by the HR Division. Complaints are reported
through email, by phone or by one-to-one meetings with HR Representative.
At this point, it should be noted that the Group has established communication channels for reporting and
raising concerns. Reports can be submitted either anonymously or via postal mail or email to a dedicated
email address. The reports include, but are not limited to, the following cases: violation of Group policies,
violations or behaviors that harm the reputation of the Group, violation of legal and regulatory framework,
fraud, corruption, bribery, abuse of power, other unethical behavior, etc. These communication channels
are always available. Any issues are directed to the Head of Internal Audit (HIA) of Optima bank and
subsequently submitted to the Audit Committee.
The Group ensures that all employees are informed about the content of the Whistleblowing Policy. The
information is provided through the distribution of relevant material. Additionally, information about the
policy is published in a prominent place on the Optima bank's website and on the internal portal.
The complaints are promptly investigated, ensuring actions are taken to hold the party responsible
accountable and to protect the person who raises concern or report, in line with legal requirements and
the Group’s Whistleblowing Policy. The Complaints Handling Procedure is described in the Whistleblowing
Policy. More information is provided in ESRS G1. The Head of Internal Audit is responsible for receiving,
investigating, registering, and maintaining a record of reports at all levels and for all Group companies. In
the case of a personalized report, the confidentiality of the identity of the reporting party and any third
party named in the report is ensured. Access to the report is restricted to authorized members only. The
Group enhances internal communication through meetings with employees, tracks and monitors issues
raised and addressed and ensures the effectiveness of the communication channels.
By promoting internal communication through regular employee meetings, the Group can effectively track
and monitor issues that are raised and addressed. These internal meetings help employees raise their
concerns, share feedback, and discuss any challenges they may be experiencing. This proactive approach
not only facilitates the prompt identification and resolution of relative issues but also ensures that
communication channels remain effective and responsive to employees' needs.
158
Also, the Group is committed to safeguarding the anonymity of the whistleblower and other involved parties
and refraining from any actions that could reveal their identity. However, disclosure of the whistleblower’s
identity may be required by judicial or legal processes during the investigation. All reports are being
reviewed under due diligence procedures, impartial judgment, and objectivity. If complaints are confirmed,
the Group implements all necessary corrective actions. Anonymous reports are being evaluated based on
the quality of their documentation and the potential to locate the reported irregularity. Individuals who
submit reports in good faith are protected from any form of retaliation, discrimination, or unfair treatment,
regardless of the investigation's outcome. Reports are submitted without any promise of payment or
reward. If the whistleblower participated in the reported event, this does not exempt them from
accountability; however, their role in uncovering and investigating the irregularity is taken into account.
The Group respects the fundamental rights of individuals involved in the reporting process and ensures
that actions and procedures comply with applicable legislation. Furthermore, the legal rights and protections
provided under the legislative framework cannot be waived or restricted by any individual agreement,
policy, form, or term of employment. This protection also extends to third parties associated with the
whistleblowers who might face retaliation in a work context, such as colleagues or family members of those
involved. If the whistleblower is an external partner, early termination, or cancellation of contracts for
goods or services due to the report is not permitted.
S1-4 – Taking action on material impacts and approaches to managing material risks and
opportunities related to one's own workforce, and the effectiveness of these measures and
approaches
The Group takes proactive actions to prevent or mitigate any material negative impacts on its workforce,
specifically addressing concerns related to the gender pay gap. It strictly follows its Staff Remuneration
Policy across all subsidiaries to ensure equal pay for equal work, regardless of gender, thus eliminating any
form of discrimination. Furthermore, it fosters a supportive and inclusive workplace across all units, where
both male and female employees are equally valued.
The Group implements a variety of initiatives to deliver positive impacts for its workforce, aimed at
enhancing employee well-being, career development and work-life balance. These initiatives support direct,
indirect, and induced jobs across the value chain, ensure competitive wages and benefits, and contribute
to employee retention and satisfaction. The key actions that took place in 2024 include:
Work-life balance & parental support:
• Implementation of Absenteeism Policy: Additional annual leave, leave for single-parent families,
cumulative maternity leave, extra leave for new fathers, and six days of paid leave for first-degree relatives'
hospitalization.
• "Family Day" Initiative: Employees can choose one day in May to leave work earlier to spend time with
their families.
• Remote work options based on each Division’s needs and upon Head’s approval.
Employee well-being & benefits:
• Comprehensive health insurance for employees and dependents.
• Monetary gifts & financial aid (€1,000/month for 12 months upon childbirth or marriage, allowance for
employees with disabilities).
• Blood donation leave day: Paid leave day for employees with an active donor card or in case of
emergency donations
Employee engagement & community-building initiatives:
• Annual Group event with the CEO, providing strategic updates and a Q&A session
• Running team participation in major events such as the 41st Authentic Marathon of Athens, the "Race
for the Cure" by Alma Zois, the "Sykareios" Memorial Race
159
• Cultural initiatives, such as free tickets for employees to theatrical performances (Veakeio Theatre) and
museums (Acropolis Archaeological Site).
Career development & internal mobility:
• Structured performance reviews, like annual performance evaluations with documented discussions with
the Human Resources Division and goal setting, formalized through HR and monthly catch-up meetings for
ongoing feedback.
• Career development opportunities, through internal mobility, as all job openings are posted internally
via intranet and all internal mobility requests are tracked in the Hunan Resources talent database.
• Specialized external training programs for all analysts in the wholesale banking division.
Diversity, inclusion & women empowerment:
• Participation in Mastercard’s "Live a Legacy" initiative, in collaboration with Women On Top, empowering
female employees through mentoring and skills development.
The above actions didn’t require significant operational or capital expenditure. These actions are applicable
to all employees, with direct benefits for those in varying geographies and units, and extend to affected
stakeholder groups, including families and the wider community through events and cultural initiatives. The
time horizon for key actions is typically annual, with longer-term plans such as the 2025 postgraduate
sponsorship policy. Specific initiatives, such as performance reviews and career mobility opportunities, are
ongoing.
As mentioned above, the Group monitors its workforce initiatives through structured feedback mechanisms
and ongoing engagement. This includes annual performance evaluations, monthly catch-up meetings,
direct communication with HR, and branch visits by senior directors and the Human Resources Director.
Employees can also reach out through a dedicated email for talent acquisition and workforce-related
inquiries.
The Group ensures that its practices do not cause or contribute to material negative impacts on its
workforce by investing in its employees' well-being, career development, and work-life balance. Through
initiatives such as comprehensive health benefits, parental support, career advancement opportunities, and
engagement in community-building activities, the Group fosters a positive and supportive work
environment.
The Group allocates dedicated resources to the management of its material impacts, including specialized
personnel such as the Talent Acquisition team, which focuses on addressing related actions and initiatives.
Additionally, a specific annual budget is allocated for this purpose, ensuring that resources are directed
toward the effective management of material impacts. A significant portion of these resources is directed
to LinkedIn, providing employees with access to a wide range of training opportunities based on their
individual needs and preferences.
Metrics and targets
S1-5 – Targets related to addressing material negative impacts, promoting positive impacts,
and managing material risks and opportunities
Based on the outcome of the DMA and following a series of internal communications with representatives
of the HR Division, Strategy, IR, and the Sustainable Development Division, specific time-bound and
outcome-oriented targets have been set. To define targets related to increasing women's representation,
the Group first conducted a baseline assessment of current women’s representation at various levels within
the organization (e.g., senior leadership, management, entry-level) to understand any barriers that might
160
be faced by women. To identify achievable targets, the Group then proceeded to a benchmarking analysis
against peers and industry standards. Based on internal HR data, external reports (i.e. industry reports,
studies conveyed by international organizations) and international standards and frameworks (i.e. SDGs,
EU directives, etc) that showcase how different levels of representation may affect the organization’s
performance and culture, the Group proceeded to this target setting. The Group is always assuming the
leadership remains committed to the creation of an inclusive working environment and that a sufficient
pool of qualified candidates exists, to meet the targets set for women's representation. The Group aims,
though, to assess these targets on a regular basis to ensure that their implementation is on track and
remains aligned with the Group’s policies, objectives and strategy.
The targets are presented in the following table.
GROUP TARGET DESCRIPTION
TIME FRAME
BASE YEAR
BASE VALUE
>50% of women employees
2026
2024
49%
>40% of women employees in top
management level*
2026
2024
34%
* CEO, CISO (“Chief Information Security Officer”), Heads, Branch managers, Investment Banking Managers, Team leaders,
Legal Counsel
As of now, the Group’s targets focus on ensuring equal treatment and opportunities for all employees,
aligning with its policies and strategy to promote gender equality and diversity at all levels. No additional
time-bound and measurable targets related to IROs have been set, and thus it was not necessary to track
the effectiveness of relevant actions and policies.
S1-6 – Characteristics of the Group’s employees
Table 1: Employee headcount by gender
GENDER
NUMBER
OF
EMPLOYEES
Male
295
Female
280
Total number of employees
575
The number of Group employees for FY 2024 is reported in head count and concerns the number at the
end of the reporting period as of 31.12.2024. The Group has significant employment in Greece (headcount
575). The number of the employees is also presented in Note 10 “Staff costs” of Financial Statements.
Table 2: Employee headcount by contract type, broken down by gender
EMPLOYEES BY CONTRACT TYPE
FEMALE
MALE
TOTAL
Number of employees
280
295
575
Number of permanent employees
253
277
530
Number of temporary employees
27
18
45
Number of non-guaranteed employees
0
0
0
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The total number of employees who have left voluntarily, retirement, or death in service during the
reporting period is 31 and the rate of employee turnover is 6% in the reporting period. During the reporting
period, there were no significant fluctuations in employee headcount in the Group.
S1-7 – Characteristics of non-employees in the Group’s own workforce
To meet the predefined needs of the Group’s companies, specific technical, administrative, financial and
informatics support work / services are provided through third-party companies – external associates –
contractors. It is hereby noted that the employees of the third companies – external associates are not
controlled by the Group. The total number of non-employees of the Group for FY 2024 is 26. The number
of non-employees is reported in headcount and concerns the number of non-employees at the end of the
reporting period (as of 31.12.2024). There were no significant fluctuations in the number of non-employees
in the Group’s own workforce during the reporting period.
S1-8 – Collective bargaining coverage and social dialogue
Collective agreements cover numerous issues enhancing equitability and productivity in the workplace.
There are two collective agreements and they cover a wide range of topics including salaries, allowances,
family support benefits and other benefits, additional remuneration, loans, job protection, working hours,
leave, health and safety. The percentage of employees in the Group covered by collective bargaining
agreements is 100%.
Social dialogue plays a significant role in facilitating communication, negotiation, and consultation between
employees and management representation that advocates for their rights and interests within the Group.
They ensure that employees' concerns are addressed and in a timely and effective manner. It also helps
to foster a more inclusive and participatory work environment, where employees feel valued and
empowered to contribute to the Group’s success. 100% of Group employees are covered by workers’
representatives.
Table 3: Collective bargaining coverage and social dialogue
COLLECTIVE BARGAINING COVERAGE
SOCIAL DIALOGUE
Coverage
Rate
Employees – EEA (for
countries with >50
employees
representing > 10%
total employees)
Employees – Non-EEA
(estimate for regions
with >50 employees
representing >10%
total employees)
Workplace representation
(EEA only-for countries
with >50 employees
representing >10% total
employees)
0-19%
20-39%
40-59%
60-79%
80-100%
Greece
Greece
S1-9 – Diversity metrics
Table 4: Gender distribution in number (headcount) and percentage at top management level
GENDER
NUMBER OF EMPLOYEES
PERCENTAGE OF EMPLOYEES
Female
47
34%
Male
91
66%
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Table 5: Distribution of employees (headcount) by age group
AGE GROUP
NUMBER OF EMPLOYEES
PERCENTAGE OF EMPLOYEES
under 30 years old
96
17%
30-50 years old
354
62%
over 50 years old
125
22%
S1-10 – Adequate wages
All Group employees receive fair and competitive wages, reflecting the Group's commitment to equitable
compensation practices. The wages provided are consistently above the minimum thresholds defined by
Greek legislation, ensuring that all employees are compensated fairly in accordance with legal standards.
This means that employees receive more than the minimum requirements negotiated through these
agreements, highlighting the Group's dedication to providing superior remuneration and high-level working
conditions.
S1-11 – Social protection
All employees of the Group are covered by social protection through public social programs in the following
events as provided by Greek legislation: sickness, unemployment starting from when the employee is
working for the Group, employment injury with and acquired disability, parental leave and retirement.
The Group also provides an additional group program that offers financial assistance to employees in cases
of loss of income due to illness. This approach, in conjunction with public social protection, underscores
the Group’s commitment to the protection and well-being of its workforce, ensuring continued financial
stability for employees even during recovery periods. The Group's medical and life insurance program also
covers all employees against loss of income due to occupational injury with disability effect on top of any
public social security coverage. The Group’s insurance program is particularly valuable during the recovery
period, providing a lifeline for employees and their families. Whether dealing with a temporary injury or a
long-term disability, employees can rely on the Group's support to navigate these challenges and maintain
their quality of life. This approach reflects the Group's strong commitment to employee well-being,
promoting a sense of security and stability during challenging situations. The Group also maintains a highly
supportive approach to its employees during parental leave, ensuring that they continue to receive their
full income through its payroll. This policy goes beyond compliance with legislative requirements and
highlights the Group’s commitment to supporting its employees, enhancing family well-being and their
commitment to the organization. In this way, the Group promotes work-life balance, actively contributing,
thus, to the creation of an environment that supports the development and satisfaction of its employees.
S1-15 – Work-life balance metrics
All employees (100%), regardless of gender, are entitled to take family-related-parental leave through
social policy or/and collective bargaining agreements.
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Table 6: Entitled employees (%) that took family-related leave, and a breakdown by gender
GENDER
PERCENTAGE OF
ENTITLED
EMPLOYEES FOR
FAMILY-
RELATED LEAVE*
Male
1%
Female
3%
Total employees
2%
*maternity and paternity leave
S1-16 – Remuneration metrics (pay gap and total remuneration)
The Group operates a remuneration system that does not take into consideration gender discrimination.
Committed to the principle of equality, the Group ensures no discrimination or pay disparities across the
Bank and its subsidiaries. In 2024, the gender pay gap within the Group was 38%. As previously mentioned,
there is no salary discrimination between men and women in the same positions. The gender pay gap
exists due to the differing representation of men and women in positions with varying pay levels. The
Group's average annual total compensation ratio is 19 and it has a structured compensation framework
that aligns with performance, responsibilities, and prevails market standards. The calculation of the
remuneration metrics included the gross salary and the benefits in cash and in kind. The pay level was
calculated by dividing the remuneration metric by the annual working hours, as derived from the working
hours specified in employee contracts.
S1-17 – Incidents, complaints and severe human rights impacts
The Group’s policies are designed to uphold ambitious standards of workplace conduct, ensuring full
compliance with applicable labor law and internal codes of ethics. In line with these practices, the Group
has not faced any incident, complaint or human rights issue, resulting in zero (0) fines or financial liabilities.
The Group’s commitment to ethical conduct includes a well-defined grievance mechanism for reporting
violations, and a robust monitoring system to ensure a safe and respectful work environment. As a result
of these preventative measures, the Group has avoided situations that could lead to severe human rights
violations, thus ensuring that no related financial liabilities appear in its financial statements. Specifically,
the Group reported zero (0) incidents of discrimination, including harassment, during the reporting period.
There were zero (0) complaints from the Group’s workforce and zero (0) concerns were raised (including
grievance mechanisms). Consequently, no fines, penalties, or compensation for non-compliance resulted
from incidents and complaints. In addition, the absence of human rights incidents and related fines,
penalties and compensation connected to Group employees, reflects the Group's proactiveness on
compliance and its ongoing efforts to mitigate any potential risks associated with human rights abuses in
the workplace. By maintaining adherence to these standards, the Group continues to foster a fair and
equitable workplace, free from human rights violations.
All the above metrics have not been validated by an external body.
ESRS S4 Consumers and end-users
Strategy
S4.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and
business model
The updated business model reflects information-related impacts for customers, such as data privacy and
customer satisfaction. The use of customer data in a responsible and secure manner has positive impacts.
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Specifically, it enhances data security and addresses any customer concerns through transparent and
secure processes. These impacts are aligned with the Group’s business model, which prioritizes data-driven
insights and a customer-centric approach. Furthermore, the strategy’s orientation to deliver high-quality
customer experiences directly improves customer satisfaction and formulates their overall experience. In
addition, the Group’s business model is designed to address the challenge of mitigating risks while
capitalizing on opportunities. By continuously focusing on customer-centric initiatives, the Group not only
reduces the likelihood of disruptions by system failures and data breaches but also strengthens its market
position and enhances customer trust and loyalty over time.
All customers who are likely to be materially impacted by the Group’s operations, including those affected
through its value chain, its products and services, and its business relationships, have been included in the
scope of this disclosure, in accordance with ESRS 2. The Group primarily serves corporate banking clients,
who receive a range of products and services to support their business operations and loan requirements,
as well as retail banking customers, primarily high-income individuals managing significant funds under the
Group’s supervision. In assessing potential material impacts, the Group has determined that certain
customers may be subject to impacts related to their rights to privacy and personal data protection.
However, the Group does not serve consumers or end-users of products that are inherently harmful to
people or that increase the risk of chronic disease. Likewise, the Group does not have customers who could
be negatively affected in terms of their rights to freedom of expression or non-discrimination, nor does it
serve consumers or end-users who rely on accurate and accessible product- or service-related information,
such as manuals or product labels, to avoid potentially damaging use. Additionally, the Group does not
have customers who are particularly vulnerable to health impacts, privacy risks, or the effects of marketing
and sales strategies, such as children or financially vulnerable individuals.
Based on the Double Materiality Assessment, no negative material impacts were identified in relation to
customers, therefore, no customers with particular characteristics could be negatively affected. Conversely,
the positive material impacts derive from commitment to delivering high-quality services, protecting data
privacy, and ensuring robust cybersecurity measures. At the same time, internal management systems and
cybersecurity initiatives safeguard stakeholders’ data privacy, fostering trust and confidence. Established
systems and processes further ensure minimal incidents of data breaches or leaks of personal and
confidential information, creating a secure environment for all stakeholders, including customers,
employees, and business partners. In addition, the continuous improvements to the service provided
enhance customer satisfaction. Furthermore, the DMA identified an opportunity and a risk arising from the
material impacts which are relevant to all the Group’s customers. The opportunity is associated with
continuous customer satisfaction, as it drives higher customer loyalty, fosters trust, and supports market
share growth. Satisfied customers are more likely to remain engaged with the organization’s services,
strengthening long-term relationships and enhancing business resilience. In addition, through the DMA, a
risk was identified that is associated with system failures, which could lead to service disruptions,
unauthorized access, or data breaches. Such incidents could lead to reputational damage, a loss of
customer trust, and adverse effects on the Group's financial performance.
Impacts, risks and opportunities management
S4-1 – Policies related to consumers and end-users
The Group is committed to protecting customers’ privacy and ensuring their satisfaction by delivering high-
quality services. In this context, the Group has adopted the following policies that reflect its values and
commitments. There are no significant changes to policies, relating to new expectations for business
customers, new or additional due diligence and remediation approaches.
•
Information Security Policy:
The Information Security Policy is designed to effectively manage
essential performance metrics and mitigate risks impacting end users and customer groups. This
Information Security Policy demonstrates the Group’s unwavering commitment to protecting sensitive
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information, maintaining customer trust, and ensuring the integrity, confidentiality, and availability of its
services. The key objectives are based on the following pillars:
o Confidentiality: Ensuring customer data is accessible exclusively by authorized personnel.
o Integrity: Preventing unauthorized modifications, corruption, or destruction of data.
o Availability: Guaranteeing uninterrupted access to systems and services.
These pillars serve as the foundation for managing potential risks and delivering enhanced value to
customers. The Information Security Policy proactively addresses risks such as cyber threats by
implementing advanced preventive measures, including state-of-the-art security protocols, regular system
updates, and rigorous stress testing. Furthermore, it ensures strict adherence to GDPR (General Data
Protection Regulation) and other privacy regulations while safeguarding customer experiences from
operational disruptions. The implementation of the Information Security Policy is monitored through regular
internal audits, quarterly security assessments and periodic reporting to the Executive Committee. The
scope of Information Security Policy, along with its supplementary policies, implementation guidelines, and
procedures apply to all employees, operational units, and affiliated entities such as subsidiaries, regional
offices, controlled or associated companies, external suppliers, and partners. It covers the creation,
processing, communication, distribution, storage, and availability of information related to the organization,
including both its internal operations and external interactions. This encompasses customer data, personal
data, and other sensitive information shared with or processed by third parties, collaborators, suppliers, or
contractors. The Information Security Policy applies to all systems, applications, and network infrastructure
used by the organization, regardless of format (digital, physical, or otherwise), as well as any locations or
facilities where information is stored. It encompasses the entire value chain, both upstream and
downstream, to ensure compliance and the implementation of security measures across all affected
stakeholder groups. The Executive Committee and the CISO are entrusted with the implementation and
oversight of the Information Security Policy, ensuring consistent compliance across all departments,
employees, and external partners. This policy aligns with European standards, as outlined by EU directives
and regulations, including GDPR, PSD2, and the Basel II guidelines established by the Basel Committee. At
the same time, it follows internationally recognized standards, such as ISO/IEC 27001:2013 and PCI DSS,
which support compliance with EU requirements and ensure high levels of security. Stakeholders’ interests,
including feedback from customers and employees, are taken into consideration throughout the
development of the Information Security Policy, ensuring it aligns with their expectations and concerns.
The Information Security Policy is delivered to employees automatically through a dedicated platform upon
their employment contract signing, requiring mandatory electronic acknowledgment and acceptance,
ensuring comprehensive understanding and compliance from day one. Implementation support is provided
through regular training sessions and dedicated help desk services. It is readily available on the intranet
and key provisions are shared with external stakeholders through secure portals and documented
procedures
•
Information Security Incident Management Policy:
The Information Security Incident
Management Policy encompasses various aspects related to managing material sustainability matters.
Firstly, this policy outlines its main objectives, which include the effective and efficient recording and
management of security incidents, in accordance with the relevant contractual, social, and legal obligations.
The Information Security Incident Management Policy covers all the activities, employees, and partners,
while excluding systems that do not belong to the Group. Additionally, the Group has established a Security
Incident Response Procedure, enabling timely communication with affected customers and efficient incident
management. The highest level in the organization accountable for the implementation of the Information
Security Incident Management Policy is the Executive Committee of the Bank, while the Chief Information
Security Officer is responsible for ensuring the Information Security Incident Management Policy's
implementation. This policy also references third-party standards such as ISO 27001:2013, which the Group
commits to adhere to through its implementation. The Information Security Incident Management Policy
takes into consideration the interests of key stakeholders in its formulation, ensuring that their needs and
concerns are integrated into the incident management processes. Finally, the Information Security Incident
Management Policy is made available to potentially affected stakeholders and those who need to help
implement it through internal communications and training programs.
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•
Communication and Networks Security Policy:
The Communication and Networks Security Policy
establishes a framework for the design, management and support of the network infrastructure, with a
primary focus on security and uninterrupted operation. Stringent measures to safeguard the architecture,
use, and controls of its network, ensuring the confidentiality, integrity, and availability of information during
transfer or transmission. This policy applies to all communication networks that interconnect the
Information Systems with systems inside and outside the Bank and its subsidiaries, network applications,
and related infrastructure. All users and administrators of the information systems and networks of the
Bank and its subsidiaries, including employees, external partners, suppliers, and service providers, must
comply with this policy. The Executive Committee serves as the sole authority for the approval and
implementation of Communication and Networks Security Policy, while the CISO oversees the enforcement
of this policy, conducting regular reviews to ensure its effectiveness is responsible for its continuous review
and proper enforcement. The Communication and Networks Security Policy adheres to international
standards such as ISO 27001 and incorporates industry best practices for network security and
management Incorporating international standards. Secure data transmission channels and clear
demarcation lines between network systems are prioritized to be used to minimize risks. Stakeholder
interests (such as secure communication protocols and vendor accountability) are protected through robust
security measures and controls. clear communication protocols are integral to the Communication and
Networks Security Policy’s design. Its implementation is provided through dedicated IT support teams,
technical documentation, and regular training sessions. Compliance is monitored through automated
network monitoring tools, regular security assessments, and periodic audits to ensure effective
implementation across all systems and users. It is supported by training programs for employees and
contractual agreements with external partners, ensuring consistent application across all levels.
•
Logical Access Management Policy
: The Logical Access Management Policy establishes a
comprehensive framework to protect information assets through robust security measures that ensure
confidentiality, integrity, and availability. The Logical Access Management Policy applies to all systems,
networks, and applications, including local and remote access, and extends across the entire value chain.
Accountability for the Logical Access Management Policy lies with the CISO, who is responsible for enforcing
the Logical Access Management Policy and ensuring its effectiveness. Alignment with ISO 27001
underscores the Group’s dedication to adhering to internationally recognized security standards and
industry’s best practices. The Logical Access Management Policy prioritizes stakeholder interests, including
the security of employees, vendors, and customer groups. Regular training programs equip all stakeholders
with the knowledge required to comply with this policy. The Logical Access Management Policy is
communicated internally through the intranet and training programs, while key provisions are shared
externally with vendors and customers via contractual agreements and clear documentation.
•
Acceptable Use Policy:
The Acceptable Use Policy outlines the framework for the responsible use of
Group’s information systems, focusing on safeguarding data, mitigating risks related to human error, and
promoting a culture of security awareness. The Acceptable Use Policy applies to all users, including
employees and external collaborators, across all organizational activities and geographies. The Executive
Committee holds ultimate responsibility for the Acceptable Use Policy’s implementation, supported by the
IT Steering Committee and the CISO, who ensures its enforcement. Aligned with ISO 27001, the Acceptable
Use Policy reflects the Group’s commitment to adopting international best practices for information security
and risk management. Stakeholders’ interests are integral to the Acceptable Use Policy, which emphasizes
the importance of security awareness and responsibility. Comprehensive training programs enhance
stakeholders’ ability to adhere to the Acceptable Use Policy effectively. The Acceptable Use Policy is
delivered to employees automatically through a dedicated platform upon their employment contract
signing, requiring mandatory electronic acknowledgment and acceptance. The above ensures
comprehensive understanding and compliance from day one. Implementation support is provided through
regular training sessions, dedicated help desk services, and detailed guidance materials.
•
Sustainable Development Policy:
The Sustainable Development Policy promotes customer
satisfaction by placing innovation and digitalization at the core of the Group’s mission to improve and
optimize operations. By providing accessible, efficient, and tailored banking solutions, the Group ensures
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outstanding customer experience. Information regarding the MDRs of the Sustainable Development Policy
can be found in ESRS E1.
The above policies regarding customers are not aligned with internationally recognized instruments relevant
to customers, including the United Nations (UN) Guiding Principles on Business and Human Rights.
However, through these policies, the Group strengthens trust and demonstrates its commitment to its
customers and employees, promoting their rights and fostering a modern and responsible operating
environment. In addition, although there are no specific human rights policy commitments relevant to
customers, including processes and mechanisms to monitor compliance with the UN Guiding Principles on
Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the
OECD Guidelines for Multinational Enterprises, the Group's commitment to sustainable development
incorporates human rights principles. This underscores its dedication to creating a framework where
security, transparency, and respect are fundamental values.
The Group adopts a structured and customer-centric approach to engaging with customers, utilizing various
methods to ensure open communication and effective problem resolution. These methods include customer
satisfaction surveys, daily interactions in the Bank’s branches with customers, a dedicated Call Center, the
"Send us your message" online platform, and a complaint form available on the Optima bank's website.
The procedure for handling complaints is systematic and thoroughly described in the Complaints
Management Policy and Procedure, with oversight at the highest level of management. Specifically, the
CEO of Optima bank takes cognizance of the complaints received and oversees the effective resolution of
any issues addressed. Relevant divisions are tasked with direct communication with the customer to
address and resolve any issues efficiently, demonstrating commitment to providing excellent customer
service and fostering trust through transparent engagement practices. It is important to note that no
measures are deemed necessary to provide or enable remedies for human rights impacts, as no such
impacts have occurred. This conclusion has been confirmed through the Double Materiality Assessment.
S4-2 – Processes for engaging with consumers and end-users about impacts
The Products and Marketing Sector is responsible for enhancing customer experience and loyalty through
the strategic design of products, services, commercial initiatives, and communication strategies. It focuses
on planning and delivering optimal customer experience across all sales and communication channels. The
Products and Marketing Division actively incorporates customer perspectives into its decisions and activities
by engaging directly with consumers through surveys and feedback mechanisms. Customer satisfaction
measurement is systematically managed by dedicated teams, using structured surveys and key
performance indicators such as the Net Promoter Score (NPS). These tools enable the Group to capture
the customer sentiment, identify priorities, and translate insights into actionable improvements. This
engagement occurs regularly, including the evaluation period of products and services, ensuring that
customer needs are identified and addressed effectively. The Products and Marketing Sector organizes and
coordinates events for both employees and customers, fostering engagement and strengthening
relationships. Furthermore, to better understand customer needs and enhance their experience, the
Products and Marketing Sector develops innovative methods and creates models to automate the feedback
analysis process, providing deeper insights into customer preferences. Feedback is gathered daily and
informs improvements to the customer experience. Engagement results are communicated internally to
relevant teams on a regular basis, and when deemed necessary, ensuring alignment with a customer-
focused approach.
The operational responsibility for ensuring meaningful engagement with customers and utilizing its results,
as well as incorporating them into the Group’s strategic approach is implemented through a combined top-
down and bottom-up framework across divisions with oversight at the highest level of leadership, ensuring
that feedback insights are integrated into strategic decisions. Each area within the organization is
accountable for safeguarding and enhancing the customer’s experience, ensuring a holistic and integrated
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approach. The HR Division is responsible for employee training and fostering their engagement, equipping
them with the skills and mindset necessary to deliver exceptional customer experience. The Products and
Marketing Sector’s units have various responsibilities for the engagement with customers. The Digital
Channels and Cards Division ensures optimum customer service through the call center and digital channels
and the Customer Segments Division are tasked with measuring customer satisfaction through dedicated
metrics and surveys. Additionally, the Retail Networks General Division safeguards the optimum customer
experience within the bank’s branch network. These results are regularly discussed with Executive
Committee Members, ensuring alignment with strategic priorities. Furthermore, an annual presentation to
the Executive Committee meeting is being deployed, providing a comprehensive review of customer
satisfaction metrics and highlighting areas for improvement. Furthermore, as the CEO’s office handles
customer complaints at the highest level, ensuring swift resolution and strategic oversight. All these teams
operate in close collaboration, with the senior management serving as the key custodian of this process.
Senior leadership ensures alignment, provides strategic direction, and facilitates cross-functional
cooperation to achieve consistent and effective engagement.
The evaluation of the engagement processes' effectiveness is achieved by analyzing each initiative's impact
on customer satisfaction and loyalty. Dedicated to delivering exceptional customer experience, the Group
follows a continuous cycle of listening, analyzing, and evolving. Customer feedback is actively gathered
with every available touchpoint, serving as a foundation for enhancing, developing, and improving services.
The engagement with customers is systematically assessed to ensure their feedback drives meaningful
enhancements to products and services. The effectiveness of this engagement is measured through
structured mechanisms as mentioned above. The increase in the NPS satisfaction score in digital channels,
and the absence of negative/relevant comments highlight the positive impact of ongoing improvements.
Outcomes from these engagements are used to refine internal processes, enhance communication
strategies, and continually improve the overall customer experience across all interaction points, including
branches and electronic channels. An indicative example relates to mobile applications, where customer
feedback led to a significant reduction in login times, ensuring a smoother and faster user experience.
Similarly, the customer demand for greater convenience led to enhanced features for bill and IRIS
payments. Each initiative highlights the ability to transform customer input into practical, high-impact
solutions that improve the overall customer experience. These enhancements are regularly reviewed to
ensure their sustained relevance and effectiveness, reflecting the unwavering commitment to meeting and
exceeding customer expectations. This proactive, feedback-driven approach strengthens trust and loyalty,
underlining the Group’s position as a responsive and forward-thinking financial institution.
No customers were identified as particularly vulnerable to impacts and/or marginalized by the Group’s
activities (for example, people with disabilities, children, etc.). Therefore, no specific steps were deemed
applicable or necessary to gain further insight into their perspectives.
S4-3 – Processes to remediate negative impacts and channels for consumers and end-users
to raise concerns
The Group has not identified any material negative impacts on customers through the Double Materiality
Assessment. However, specific channels are in place for customers to raise their concerns or needs directly.
The Complaint Form, available on Optima bank's corporate website, outlines the ways customers can
submit complaints, including email, phone, or mail. Additionally, the website provides detailed information
with regards to the complaint’s submission process, including the procedure which is followed after the
submission of a complaint, how the customer receives a response and any available contact method.
Customers can submit a complaint through one of the following channels:
• Visit the Optima bank branch, which is close to each customer, and fill in the Complaints Form.
• Contact the Optima bank Complaints Department either by calling on +30 210-8173199 or by e-mail
(wearelistening@optimabank.gr)
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• Send a letter to Optima bank Complaints Department, 32 Aigialeias Str. & Paradissou, 15125
Amaroussion, for the attention of the Complaints Department.
Upon receiving the complaint, the Head of the Complaints Department contacts the customer within two
working days to verify his/her identity, confirm receipt of the complaint, and provide an estimated time
frame for its review. Upon collecting any relevant information and supporting documentation, the complaint
is being investigated in collaboration with any other engaged divisions of the Group or, with relevant
authorities (e.g. the Ombudsman), if deemed necessary. The employees who are in charge of handling,
ensure a fully documented, clear, and transparent response. They strive to provide a fair solution that
meets the customer's needs in accordance with the applicable regulatory framework and the Group’s
policies. Through the above procedure, the Group tracks and monitors complaints and any issues that may
arise and proceed to any relevant actions to improve the processes if needed. As things stand, there is no
need to develop a specific procedure to assess the effectiveness of the channels or customers' awareness
and trust in the above processes as a means of raising their concerns or addressing their needs.
Information regarding the protection of whistleblowers and whistleblowing policy is provided in ESRS G1
and ESRS S1.
Furthermore, customers are fully informed regarding the protection of their personal data and the General
Data Protection Regulation through Optima bank's corporate website, specifically through the following:
• Customer Information on the processing of personal data in accordance with the General Data Protection
Regulation.
• Notice on the Processing of Personal Data through the video surveillance system (CCTV).
• Request for Exercising Rights regarding personal data recorded by the closed-circuit video surveillance
(CCTV) system.
• Announcement by TIRESIAS S.A. on the implementation of the General Data Protection Regulation.
S4-4 – Taking action on material impacts on consumers and end-users, and approaches to
managing material risks and pursuing material opportunities related to consumers and end-
users, and effectiveness of those actions
The Group remains committed to high standards of data privacy and cybersecurity, continuous investing in
advanced technologies, policies, and training to safeguard sensitive information and foster trust among all
stakeholders’ groups. The Group implements actions to enhance data security, ensuring the protection of
sensitive information and reducing the risk of unauthorized access or data breaches across all areas of
operation. These actions include robust internal management systems and established cybersecurity
processes, which effectively protect and ensure stakeholders' data privacy. Specialized critical systems
safeguard business continuity, allowing consistent service delivery to customers and business operations.
Through these actions, the Group has restricted incidents of data breaches, leaks of personal data, or
exposure of confidential information. Through actions and initiatives, operational efficiency has been
improved.
In 2024, the Group implemented the following actions:
File Integrity Monitoring (FIM) on critical systems
Includes continuous tracking of essential system files to detect unauthorized changes, potential security
breaches, or unexpected modifications, ensuring the integrity of core banking systems and protecting
sensitive information. The scope of coverage includes monitoring and safeguarding critical system files
from unauthorized modifications, with a primary focus on internal system integrity within the downstream
operations. This initiative is implemented bank-wide, covering all operational regions. Affected stakeholders
include internal personnel such as IT staff and system administrators, while customers benefit indirectly
through enhanced protection of their data.
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Network and Application Layer DDoS protection
Includes advanced mechanisms to detect, mitigate, and prevent Distributed Denial of Service (DDoS)
attacks, ensuring the continuous availability of digital banking services and safeguarding against cyber
threats. The scope of coverage includes cybersecurity defense measures targeting DDoS attacks, positioned
midstream to downstream to protect both network infrastructure and customer-facing applications. This
protection extends comprehensively across all of the Bank’s digital touchpoints. Affected stakeholders
include internal teams such as IT security personnel and network administrators, while external
stakeholders, including customers, online banking users, and digital service consumers, benefit from
uninterrupted and secure access to banking services.
New Vulnerability Assessment Platform
The action refers to an advanced platform for continuous scanning, identification, and assessment of
potential security vulnerabilities across its entire digital ecosystem, enabling proactive risk mitigation. The
scope of coverage includes comprehensive security vulnerability identification and management, positioned
upstream and midstream to detect and address potential security risks before they impact operations. This
initiative is implemented bank-wide, covering all operational regions. Affected stakeholders include internal
teams such as IT security personnel and risk management departments, while external stakeholders,
including customers and suppliers, benefit from enhanced security and reduced risk exposure.
Privileged Access Management (PAM) platform
The action concerns a sophisticated platform to manage, monitor, and control access to critical systems by
high-privilege users, reducing the risk of internal security breaches and unauthorized system modifications.
The scope of coverage includes stringent access control and monitoring measures, positioned upstream
and midstream to enhance internal security and prevent unauthorized access. This platform is
comprehensively implemented across the Bank’s critical systems. Affected stakeholders include internal
personnel such as employees with elevated system access and IT administrators, while external
stakeholders, including customers, benefit indirectly through enhanced protection of their sensitive data.
The above actions didn’t require significant operational or capital expenditure.
The Group has in place robust security procedures to safeguard customer data and maintain operational
resilience. The Information Systems Monitoring Procedure aims to ensure the smooth operation and
reliability of the information systems, providing the best possible services to customers and employees
while maximizing their performance. At the same time, it aims to protect the integrity, confidentiality, and
availability of the information processed, including personal data. Additionally, it ensures the
implementation of security measures decided upon to maintain the Group’s business continuity. The
Security Incident Response Process ensures the effective management of information security incidents
where any incidents are reported, investigated, and resolved swiftly to mitigate potential harm to
consumers and end-users. The purpose of the Incident Response Procedure is to describe the necessary
actions to be taken in the event of a security incident for immediate and effective response. The Logical
Access Policy Implementation Control procedure further strengthens security by regulating access to
sensitive data. By granting permissions only to authorized individuals and conducting regular access
reviews, the possibility of unauthorized access is significantly mitigated. This process helps to mitigate risks
and ensures that consumer data always remains protected. Additionally, Group’s Information Systems
Support Process provides exceptional service continuity and reliability, addressing technical issues promptly.
This proactive approach strategy directly benefits consumers by ensuring that all services remain
operational and efficient, with a focus on improving system reliability and customer service. The analysis
of recurring technical issues informs ongoing improvements and system upgrades.
In addition, the Group has undertaken additional actions and initiatives aiming at a positive contribution to
improved social outcomes for its customers through cybersecurity protection enhancement. The Group’s
current security approach is designed to ensure a secure and reliable environment for customers, leveraging
advanced technologies and services to positively contribute to improved social outcomes for consumers
and end-users. These measures mitigate the risk of cybersecurity threats, safeguard personal data, and
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maintain trust in digital services. The framework includes the deployment of a 24/7 External Security
Operations Center (SOC) and Security Information and Event Management (SIEM) systems, which monitor
and respond to security threats in real time, ensuring uninterrupted service and user safety. Endpoint
Detection and Response (EDR) and Antivirus (AV) solutions are implemented across all workstations and
servers, alongside Managed Detection and Response services that proactively identify and mitigate potential
risks. Perimeter security is reinforced through Firewalls and a Web Application Firewall (WAF),
complemented by advanced email filtering and sandboxing techniques to combat email-based threats and
phishing attempts. In addition, dedicated fraudulent URLs, ads, and social media pages takedown service
is also in place to protect consumers from malicious online activity. The Group also conducts regular security
awareness training and exercises for employees to ensure that everyone is equipped with the knowledge
to recognize and respond to potential threats. It also provides “Work From Anywhere” laptops based on
security best practices, ensuring employees can securely access systems and services from any location.
Furthermore, the Group implements actions to promote customer education and awareness. This approach
also strengthens stakeholder engagement by providing accessible and transparent information. The digital
presence supports this effort by offering critical resources and guidance on the corporate website such as:
• Online anti-fraud instructions to help customers recognize and avoid electronic fraud.
• Security guidelines for e-banking and online transactions, promoting safe digital behaviors.
• General Data Protection Regulation (GDPR) guidelines, ensuring transparency about data handling
practices and customer rights.
The Group also leverages its LinkedIn platform to enhance communication with customers. Posts cover key
topics such as data protection, with insights from the Data Protection Officer (DPO), and electronic fraud
awareness campaigns that align with broader educational efforts. These posts serve to amplify the
implemented initiatives and foster trust among its customers.
In 2024, newsletters served as another vital touchpoint, with the Group distributing three targeted editions
to many e-banking users (individuals and legal entities). These communications played a pivotal role in
addressing prevalent electronic fraud scenarios, offering actionable tips for online fraud prevention, and
promoting safe online shopping practices. Furthermore, the newsletters showcased the digital tools and
features available to customers, empowering them to navigate the banking services securely and with
confidence.
To track and assess the effectiveness of these actions and initiatives in delivering intended outcomes for
customers through the provision of a safe digital environment, the Group employs continuous monitoring
through real-time analysis and automated reporting of security incidents. This approach helps measure
system effectiveness and identify areas for improvement. Also, the Group established a Full Disaster
Recovery site to ensure business continuity in critical incidents. Regular penetration and vulnerability
assessments are conducted, along with periodic Red Teaming exercises that simulate real-world
cyberattacks. These activities enhance preparedness against evolving threats and provide valuable insights
to evaluate the success of security initiatives.
Furthermore, to continue delivering superior service, safety, and satisfaction to consumers, the Group
provides a range of tailored solutions, ensuring its offerings remain responsive and aligned with customer
needs. More specifically:
•
Call Center Operations
: Daily reporting ensures performance is closely monitored, allowing the Group
to respond quickly to customer needs and maintain high-quality service.
•
Customer Satisfaction Tracking
: Platforms such as e-satisfaction and PowerBI gather and analyze
feedback from branches, digital services, and business banking. This allows the Group to proactively
enhance customer experience.
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•
Campaigns:
The Group uses a specialized platform to design and execute campaigns that align with
customer needs and strategic objectives, ensuring impactful communication.
•
Contact Form Monitoring
: The GA4 system tracks customer interactions through contact forms,
ensuring inquiries are handled efficiently and any issues are resolved promptly.
To further mitigate the material risk associated with system failures—such as service disruptions,
unauthorized access, and data breaches—that could result in reputational damage and impact on the
organization's financial performance, the Group has planned the following actions for 2025:
•
Data Loss Prevention (DLP) and Azure Information Protection (AIP) implementation:
Data
Classification has been conducted. The Group is exploring advanced DLP solutions to prevent unauthorized
data exfiltration.
•
ISO 27001 certification:
Initial gap assessment has been completed. The group is undergoing
preparation for the formal certification process.
•
DORA regulation compliance
: A DORA gap assessment has been conducted. The identified gaps are
now undergoing remediation with a vendor's help.
•
Threat Intelligence Solution
: The Group is evaluating a comprehensive range of threat intelligence
solutions.
•
Cybersecurity Assessment Platform:
The Group aims to enhance its continuous security capabilities
and is currently evaluating various Cybersecurity Assessment solutions.
•
Firewall Management and Network Security Policy platform:
The Group evaluates few
candidate platforms to determine its suitability for firewall management and network security policy
requirements
Customer feedback mechanisms are being enhanced, proactively improving services, personalizing
customer experience, and investing in technology and innovation to ensure continuous customer
satisfaction that leads to higher loyalty, trust, and market share growth. To this end, it is noted that no
severe human rights issues or incidents have ever been identified connected with customers.
The Group allocates resources to effectively manage its material impacts, ensuring that users gain a clear
understanding of how these impacts are addressed. One of the key resources is a dedicated platform
designed to measure customer satisfaction across all channels. This platform plays a central role in
managing material impacts by providing comprehensive insights into customer experiences and satisfaction
levels. By leveraging this platform, the Group ensures continuous monitoring, evaluation, and improvement
of services, which is essential for addressing customer-related impacts. Additionally, the Group has assigned
personnel with expertise in the Products and Marketing Sector, the Data Protection Officer and Information
Security Section to oversee critical processes and services. These divisions have dedicated personnel
responsible for ensuring compliance with legal and regulatory requirements, implementing operational
frameworks, and managing customer-related impacts. To further support the management of these
impacts, the Group allocates a budget for implementing individual measures, actions, and initiatives. This
budget is tailored to the Group's needs and ensures that sufficient resources are available to address
material impacts effectively.
Metrics and targets
S4-5 – Targets related to advancing positive impacts, and managing material risks and
opportunities
The Group uses Net Promoter Score as a metric for measuring customer loyalty and satisfaction in the
banking experience. The NPS measurement is event-triggered, capturing customer experience across all
service channels. Additionally, it is conducted at regular intervals to assess overall satisfaction within the
Bank. The NPS is a single, easy-to-understand metric assessing customer loyalty, through the likelihood to
recommend, and general satisfaction on an international scale, the NPS scale (0-10). The customers are
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categorized based on their responses in detractors (0-6), passives (7-8) and promoters (9-10). The NPS is
calculated as the percentage of promoters minus the percentage of detractors. The Net Promoter Score
NPS ranges from -100 to +100. NPS above zero signifies that the entity has more promoters than
detractors, reflecting overall customer loyalty. Conversely, NPS below zero indicates a higher number of
detractors compared to promoters, suggesting potential customer dissatisfaction. An NPS of zero shows an
equal balance between promoters and detractors.
For 2024, the Bank’s branch NPS was 82.5. It measured customer loyalty for customers who visit a branch
of Optima bank after the following services: loan disbursement, investment account opening, credit card
issuance, account opening, or debit card issuance. The metric is not validated by an external body.
Based on the continuous commitment to providing the best customer experience and following the outcome
of the DMA and a series of internal communications with representatives from the Products and Marketing
Sector and the Strategy, IR, and Sustainable Development Division, a specific outcome-oriented and
ongoing target has been set. The Group aims to continue delivering optimal customer service as outlined
in the Sustainable Development Policy. To establish this target, a benchmarking analysis was conducted
against peers and industry standards. This target-setting process underscores the Group’s dedication to
enhancing the customer experience. Customer feedback mechanisms are being strengthened to proactively
improve services, personalize customer interactions, and invest in technology and innovation. These efforts
ensure continuous customer satisfaction, leading to higher loyalty, trust, and market share growth. The
top management regularly evaluates this target (monthly, quarterly, and annually) to ensure it remains on
track and aligned with the Group’s policies, objectives, and strategy.
The target is presented in the following table
TARGET DESCRIPTION (Optima bank)
TIME FRAME
BASE YEAR
BASE VALUE
Maintain branch NPS>80
ongoing
2024
82.5
The Group has not set any measurable outcome-oriented targets regarding data privacy issues, but it
continuously tracks the effectiveness of its policies and actions through the measurement of data privacy
incidents and following the Security Incident Management Policy and the Security Incident Response
Procedure. All employees and external partners with access to the Group’s information resources must
promptly report any incident or weakness affecting information security. To ensure this, employees receive
training to detect and address security threats. Incidents are reported through designated channels
accessible to all staff. The Head of Information Security assigns the Security Incident Response Team,
comprising skilled executives based on the incident’s criticality. Any medium- or high-risk incident is treated
as a top priority. In confirmed cases, a Root Cause Analysis is conducted to identify causes and implement
preventive measures, such as policy updates, enhanced security controls, and awareness initiatives.
For the reporting period 2024, the Group had zero number of identified leaks, thefts, or losses of customer
data according to the GRI 418-1 b disclosure.
Entity Specific (“ES”)
Innovation & Digitalization
Strategy
ES.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and
business model
The Group acknowledges the importance of digital transformation in its business plan and strategy. These
continuous updates and changes aim to enhance operational efficiency while addressing key challenges
such as anti-corruption, bribery prevention, and effective risk management. By integrating advanced
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technologies into its operations, the Group seeks to deliver exceptional services, optimize processes, and
build a framework rooted in transparency and resilience.
According to the first Group’s Double Materiality Assessment, “Innovation and Digitalization” is identified
as material topic with significant impact and risk. The material topic concerns the banking activity of the
Group; therefore, the related disclosures pertain mainly to Optima bank. The material IROs corresponds
across the business model, operations, and value chain of the Group. By leveraging digital tools and services
to offer innovative solutions the Group gains multiple advantages. The Group has invested in secure digital
banking platforms and AI-powered customer support systems, making sure that services are delivered
seamlessly and efficiently across all digital channels. These upgrades allow the Group to meet customer
needs quickly and effectively, while upholding the highest standards of security and reliability. In terms of
risk management, the Group has adopted cutting-edge technologies like AI, machine learning, and
blockchain to better monitor, assess, and manage risks. This helps the Group stay ahead by addressing
potential issues in its upstream and downstream value chains. Through this proactive approach, the Group
increases transparency and strengthens its resilience, protecting both its operations and relationships with
partners. Additionally, the Group has placed a strong focus on accessibility and innovation by developing
user-friendly digital services that respond to customers’ changing needs. By prioritizing digital channels,
the Group ensures its services are accessible to a wide range of customers, all while staying ahead of the
competition in the fast-evolving banking industry.
The Group also recognizes the risk that comes with implementing innovation and digitalization. One of the
main concerns is cyberattacks, which could disrupt operations, compromise sensitive data, and damage
the Group's reputation. To address this, the Group has strong cybersecurity measures, such as advanced
threat detection systems. Another challenge is the dependency on third-party providers, which could lead
to vulnerabilities if there are disruptions or failures in the supply chain. To manage this risk, the Group has
embraced advanced third-party risk management practices, such as those mentioned above. As the Group
inevitably depends on digital systems like any modern organization that strives to remain continuously
adapted to technological and innovation advancements, business continuity becomes a priority. To mitigate
the risk of operational disruptions, the Group has developed a detailed business continuity plan. This
ensures that even in the face of emergencies, critical services can continue smoothly.
The Group is actively addressing the significance of its material impacts and risks on its business model,
value chain, strategy, and decision-making processes. The Group anticipates further improvements in
service delivery and customer satisfaction as digital adoption increases. To respond to these positive
impacts, the Group is also driving digital transformation to improve operational effectiveness. However, to
address the risks, the Group is investing in emerging technologies to enhance third-party risk management
processes, monitoring, and risk assessment frameworks. In terms of strategic changes, the Group plans to
increase customer digital engagement by a certain percentage within a specified number of years. This
initiative is expected to drive higher adoption of digital services, leading to improved customer satisfaction
and loyalty. To achieve this, the Group plans to increase the use of digital services by a targeted percentage.
As already stated in ESRS 2, there are no current financial effects, and the anticipated financial effects are
under the phased-in provision.
The adoption and offer of innovative services through digital tools create positive impact and may
significantly benefit both people and the environment. Digital banking services enable customers to access
financial products and manage their finances remotely, making banking more inclusive and convenient.
Moreover, innovative tools provide seamless, personalized, and efficient services, meeting diverse customer
needs and increasing satisfaction. When it comes to the impact on the environment, the transition to digital
services minimizes the need for paper, reducing deforestation and waste. Additionally, digital banking
reduces energy consumption compared to traditional banking infrastructure, particularly by eliminating the
energy demands associated with paper-based processes. The impact aligns directly with Group's strategic
focus on innovation and digital transformation. The Group hopes to increase customer satisfaction, boost
operational effectiveness, and foster sustainable growth by integrating digital tools and services—like digital
onboarding, mobile banking apps, 24/7 customer support (connect with a bank representative anytime
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through innovative features like live chat or video banking) and automated platforms, into its core business
processes. These digital initiatives are integral to the Group’s business model, which prioritizes leveraging
technology to deliver innovative financial solutions. Adopting digital services is a clear part of the Group 's
strategy to satisfy changing client demands and maintain market competitiveness. This strategic focus on
digital transformation not only drives the Group’s operational improvements but also supports its long-term
sustainability goals by reducing operational costs and increasing accessibility for customers. As a result,
the Group’s overall strategy and business model are closely linked to the effects of implementing and
providing cutting-edge services through digital tools and services. The Group is directly involved in this
impact through its core activities, as the development and the provision of digital services are central to its
operations. The Group also collaborates with technology partners to make sure these innovative solutions
are delivered smoothly, building a network that drives both innovation and sustainability.
The Group updates its strategy and business model to effectively manage significant impacts and risks,
particularly in the context of innovation and digitalization. As already mentioned, by adopting and
offering innovative services such as digital onboarding, mobile banking apps, and automated customer
support platforms, the Group enhances customer satisfaction and promotes sustainable growth. Yet, as
already mentioned, digitalization introduces new risks, including cyberattacks and a high dependency on
third-party providers, which could lead to business discontinuity during emergencies and affect
performance. To ensure resilience, the Group has developed comprehensive documented processes,
operational resources, and actions for business continuity. These include detailed procedures to
manage and mitigate risks, adequate resources for critical operations, and regularly reviewed actions to
address potential disruptions.
ES – Policies related to entity specific topic
The Group recognizes the importance of digital transformation and innovation for sustainable development
and has incorporated these principles into its Sustainable Development Policy. By integrating innovation
and digitalization into its Sustainable Development Policy, the Group ensures that its approach to digital
transformation not only enhances customer satisfaction and operational efficiency but also contributes to
environmental sustainability and robust security measures. By providing accessible, efficient, and tailored
banking solutions, the Group enables customers to seamlessly access services, whether managing
accounts, conducting transactions, or obtaining personalized financial insights and assistance. With a strong
focus on customer needs, the Group delivers a smooth and satisfying experience at every touchpoint.
Committed to innovation and digitalization, the Group invests in cutting-edge technologies to ensure
efficiency and reliability. Additionally, the Group supports the environment through innovative practices,
aligning digitalization and innovation with security to maintain the highest standards of protection. These
are the key contents of the Sustainable Development Policy, that are related to innovation and digitalization
and its material impacts and risks. More information regarding the MDRs of the Sustainable Development
Policy can be found in ESRS E1.
ES – Taking action on material impacts and approaches to managing opportunities related to
entity specific topic, and the effectiveness of these measures and approaches
Digital transformation and innovation are the top Group’s priorities. The Group implements actions in order
to manage the material impacts and risks related to innovation and digitalization. In the reporting year,
key actions taken include the development and enhancement of digital solutions that prioritize customer
experience, aiming to simplify daily banking through advanced technologies. These actions are expected
to result in the achievement of the policy objectives and targets. The Group provides seamless and
innovative banking experience while prioritizing environmental sustainability, social impact, and robust
governance. Here are the key actions the Group is taking to achieve the above:
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• Enhanced Card Features (2023-2024): Customers can take full control of their cards with features like
temporary blocks, instant activation, loss and re-issue services, PIN reminders, and tailored card controls
to manage in-store purchases, online transactions, and ATM cash withdrawals.
• Smart Payment Solutions (2023-2024): They can enjoy fast, secure payment options such as contactless
transactions, digital wallets (Apple Pay/Google Wallet), and standing orders for both personal and
organizational needs. Recurring payments are simplified with subscription management tools. Proactive
Security Measures (2024): Financial protection is enhanced with cutting-edge antifraud tools, including a
Kill Switch, customizable daily or per-transaction limits, and the ability to block transfers abroad. Security
is further reinforced through alerts delivered via push notifications, email, Viber, or SMS.
• Innovative Business Solutions (2023-2024): Businesses can leverage advanced features such as complex
access rights and single sign-on for multiple users, streamlining workflows. Mass transactions, including
payroll, payments, and transfers, are efficiently managed with tailored enterprise tools.
• Seamlessly Manage Accounts (ongoing): Account holders can effortlessly oversee their finances, execute
secure money transfers, and track payments, including IRIS payments, through an intuitive and user-
friendly interface. Real-time personalized financial insights further enhance account management.
• Sustainability and Impact (ongoing): Paper consumption is reduced, and resource utilization is optimized
through digital processes, contributing to environmental sustainability. Financial inclusion and accessibility
are improved, supporting underserved communities.
• Advanced Cybersecurity (ongoing): Client data is safeguarded with state-of-the-art measures, including
encryption, multi-factor authentication, and real-time fraud detection, ensuring financial information
remains secure.
In addition, the upcoming functionalities for future developments in 2025 include eKYB, designed
exclusively for businesses, along with the launch of innovative Business Debit and Business Credit products
tailored to the evolving needs of corporate clients.
These actions cover various activities including customer service, account management, transaction
processing, and cybersecurity. Currently, actions are focused on the midstream value chain, specifically
within the Group’s operations and customer interactions. These actions are also, implemented across all
regions where the Group operates. The key stakeholder groups affected include individual customers and
employees.
The digital banking platform and account-opening process enhancements were implemented in the
reporting year and will continue to be improved in the coming years. The above actions didn’t require
significant operational or capital expenditure.
Metrics and targets
ES – Targets related to advancing positive impacts, and managing material risks
As for now, there haven’t been any measurable, outcome-oriented targets for Innovation and Digitalization.
However, the effectiveness of its actions and progress is monitored by using relevant metrics, such as the
percentage of financial transactions conducted through digital networks, with FY 2024 serving as the
baseline year for this metric. This approach underlines the clear level of ambition in providing and adopting
innovative and digital services and solutions while enabling effective tracking and transparent reporting of
results. The metric is calculated by dividing the number of financial transactions made through digital
networks (web and mobile banking) by the total financial transactions conducted via both digital networks
and Bank’s branches without the use of cash. Financial transactions include money transfers and bill
payments. In 2024, 90.9% of financial transactions were conducted through digital networks. The metric
is not validated by an external body.
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Governance Information
ESRS G1 Business Conduct
Impacts, risks and opportunities management
G1-1 – Corporate culture and business conduct policies and corporate culture
The Group’s primary goal is to safeguard the interests of its shareholders, and all stakeholders associated
with the Bank and its subsidiaries, including customers, employees, and partners. Recognizing the
importance of corporate governance principles and the benefits derived from their application, the Group
adopts regulations, policies, and practices that align with the regulatory framework, integrating them into
its corporate culture.
Additionally, the evaluation process of the Corporate Governance System enhances the credibility of the
Group among shareholders and stakeholders, showcases transparency in corporate governance and
decision-making and safeguards the effective application of rules, principles, and internal mechanisms
across management and shareholders. This process also ensures the development and maintenance of an
efficient organizational structure and operational model that supports the Group's strategic objectives and
promotes sustainable growth. It focuses on the timely identification of deficiencies or operational issues,
enabling prompt corrective actions, as well as effective monitoring and management of significant risks
associated with business activities and operations.
Optima bank has adopted the Hellenic Corporate Governance Code for listed companies, established by the
Hellenic Corporate Governance Council (HCGC) and published in June 2021. The Hellenic Corporate
Governance Code follows the "comply or explain" principle, guiding companies in adopting best practices
and formulating corporate governance policies and practices tailored to their specific circumstances. In line
with the Corporate Governance Principles of the Organization for Economic Co-operation and Development
(OECD), a global reference and key influence on the Hellenic Corporate Governance Code, corporate
governance is defined as the system of relationships between a company’s management, shareholders,
employees, and other stakeholders. The aim is to create, sustain, and grow strong, competitive businesses.
Furthermore, Optima bank has adopted detailed Rules of Procedure, which define the organizational
structure, the roles of the units and committees, and the functions of their leaders and reporting lines.
These rules outline key features of the internal control system including the Internal Audit Division, the
Risk Management Division, and the Compliance Regulatory Division, as well as all the referenced policies
and procedures of paragraph 3 of Article 14 of Law 4706/2020. Additionally, the Rules of Procedure include
Policy and Procedure with adequate and effective communication mechanisms with shareholders, aimed at
facilitating the exercise of their rights and fostering active dialogue with them, as well as the process for
evaluating the Bank's corporate governance system. Already, by virtue of the decision of the Bank's Board
of Directors dated 16.01.2025, a Sustainable Development Policy has been adopted, which is included in
the Bank’s Operating Regulation. These rules complement existing regulations and ensure the
transparency, integrity, functionality, and effectiveness of the corporate governance and internal control
systems. Optima bank Group promotes trust, transparency, and adaptability through its values and policies
in the Bank and its subsidiaries. The daily communication between the HR Division and employees
consistently reinforces its corporate culture. This culture is also conveyed by the CEO of the Bank during
every corporate event. Additionally, the corporate culture is reflected in the employee benefits.
Ethical practices are embedded in every aspect of the Bank and its subsidiaries’ business, spanning decision-
making processes and interactions with customers, employees, business partners, and the community. The
Group has implemented the following policies to foster a robust corporate culture and promote ethical
business conduct:
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•
Code of Ethical Conduct and Ethics:
Detailed information regarding the MDRs of the Code
of Ethical Conduct and Ethics is included in ESRS S1.
•
Whistleblowing Policy
: Detailed information regarding the MDRs of the Whistleblowing
Policy is included in ESRS S1.
•
Anti-Bribery and Anti-Corruption Policy:
The key components of Anti-Bribery and Anti-Corruption
Policy include its purpose, governance structure, scope of application, key concepts and definitions,
fundamental principles, rules for implementation, and procedures for reporting illegal activities and Anti-
Bribery and Anti-Corruption Policy’s violations. The Anti-Bribery and Anti-Corruption Policy aligns with
applicable bribery and corruption legislation and aims to define rules of conduct on corruption issues,
encourage confidential reporting of incidents or suspicions through dedicated communication channels,
raise awareness among employees and partners, identify and address actions related to corruption and
bribery and protect employees and safeguard the Group’s reputation. Accountability for the Anti-Bribery
and Anti-Corruption Policy implementation rests with heads of business units, who oversee compliance
within their respective areas of responsibility. Beyond legal requirements, the Anti-Bribery and Anti-
Corruption Policy adheres to international and national standards, such as the definition of a public official
under the United Nations Convention. It also addresses corruption issues within the international
community and considers stakeholders' interests. Continuous stakeholder engagement ensures their
concerns and expectations are understood, fostering compliance with legal and ethical standards while
maintaining transparency. The Anti-Bribery and Anti-Corruption Policy applies to all employees of the Bank,
as well as any other individual providing services to the Bank or on its behalf. It applies to all activities and
operations of the Bank, including customer relations, partnerships with third parties, and the outsourcing
of tasks. The Anti-Bribery and Anti-Corruption Policy is available on the internal.
•
Policy on the Prevention and Suppression of Money Laundering
: The core elements of the
Policy on the Prevention and Suppression of Money Laundering include but are not limited to definitions
and key concepts, measures to prevent and suppress money laundering and terrorist financing, application
of due diligence by third parties, monitoring and detection of unusual or suspicious transactions, submission
of suspicious transaction reports, controls, whistleblower protections, staff training, and record-keeping.
The Policy on the Prevention and Suppression of Money Laundering aims to prevent sanctions resulting
from inadvertent involvement in money laundering activities. It serves as a comprehensive guide to the
Bank’s procedures for mitigating money laundering risks and protecting the Group’s interests and
reputation. The Policy on the Prevention and Suppression of Money Laundering provides a detailed record
of the corporate practices and controls implemented and is reviewed and updated as necessary to comply
with legal requirements. The Policy on the Prevention and Suppression of Money Laundering incorporates
best practices, such as the Wolfsberg Group principles and FATF Guidelines, applying a risk-based
approach. CEO has the responsibility for the implementation of Anti Money Laundering related provisions,
in compliance with relevant legislation. The Policy on the Prevention and Suppression of Money Laundering
applies to all employees to prevent oversights that could compromise the Group’s reputation. The Policy
on the Prevention and Suppression of Money Laundering is available on the intranet. Training programs
educate employees and associates on relevant legislation, obligations, and procedures, including customer
identification, record-keeping, and internal reporting. Key stakeholders' instructions and expectations have
been taken into consideration through the application of the risk-based approach, which has been adopted
in the design, development, and implementation of Anti Money Laundering procedures. The Policy on the
Prevention and Suppression of Money Laundering is available on the Bank’s intranet and is available to all
employees.
•
Suitability Policy for Members of the Board of Directors of the Bank
: The Suitability Policy for
Members of the Board of Directors of the Bank policy includes objectives, principles for BoD selection,
procedures for nominating candidates, suitability assessments, succession planning, diversity and gender
representation, and corrective measures. Its goals include ensuring high recruitment standards, supporting
effective BoD operations aligned with the Bank’s medium- and long-term business objectives and complying
with legislative and regulatory obligations. The BoD monitors the implementation of the Suitability Policy
for Members of the Board of Directors of the Bank, while the Internal Audit Division reviews its adequacy
and effectiveness. This policy is available on the intranet and corporate website. The expectations of
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stakeholders and those affected by this policy are taken into consideration during the preparation and the
establishment of the policy. The Suitability Policy for Members of the Board of Directors of the Bank applies
to the members of the BoD of the Bank.
•
Policy for the Prevention and Combat of Violence and Harassment in the Workplace –
Complaint Management:
Detailed information regarding the MDRs of this policy is included in ESRS S1.
•
Remuneration Policy for the Bank’s members of the BoD:
Detailed information regarding the
MDRs of this policy is included in ESRS S1.
•
Staff Remuneration Policy:
Detailed information regarding the MDRs of this policy is included in ESRS
S1.
•
Sustainable Development Policy:
The Sustainable Development Policy outlines the organization’s
approach to assessing how factors related to sustainable development may impact the Group, its services
and products, as well as decision-making processes. The Sustainable Development Policy lays the
foundation for integrating sustainability into the Group’s operations, with the aim of creating value for
environmental protection, promoting social welfare, and strengthening governance practices. The Group is
committed to maintaining a sound governance model by fostering a strong corporate culture of ethical
behavior and integrity, while maintaining a zero-tolerance culture towards corruption and bribery.
Information regarding the MDRs of this policy is included in the ESRS E1.
The mechanisms for identifying, reporting, and investigating concerns about unlawful behavior or behavior
in contradiction of Code of Ethical Conduct and Ethics or similar internal rules are outlined in the Complaints
Handling Procedure, which is an integral part of the Whistleblowing Policy. The Head of Internal Audit is
responsible for receiving, investigating, registering, and maintaining a record of reports at all levels and for
all Group companies. In the case of a personalized report, the confidentiality of the identity of the reporting
party and any third party named in the report is ensured. Access to the report is restricted to authorized
members only. The Head of the Internal Audit Division conducts an initial investigation into the issues
raised. Then, according to the procedure, the Complaints Management Committee reviews all reports
submitted by the Head of the Internal Audit Division for all Group companies. During the investigation
process, the Complaints Management Committee may seek assistance from the head of the reporting
person or unit, other departments, or external professional support. Additional expertise may be obtained
from Group executives or external partners as needed. The Complaints Management Committee provides
the results of both the initial and final investigations to the Audit Committee and the Board of Directors.
The Committee is also responsible for investigating any reports of retaliatory acts. The Group encourages
the submission of named or anonymous reports and complaints regarding serious irregularities, omissions,
or criminal acts brought to the attention of any employee, regardless of their hierarchical level. Such reports
can be submitted via all communication channels by all stakeholder groups.
Reports of irregularities, omissions, or criminal offenses may include, but are not limited to, the following
cases:
• Theft, embezzlement, fraud, corruption, and bribery.
• Improper use of assets, breaches of banking secrecy, and misrepresentation of data.
• Abuse of power, violations of Group policies, or conduct detrimental to the reputation or purpose of the
Group.
• Violations of the legal and regulatory framework, human rights violations, or instances of discrimination.
• Other unethical conduct or deliberate concealment of information related to any of the above.
Reports are reviewed with due diligence, impartial judgment, and objectivity. In cases where complaints
are confirmed, the Group is obliged to take all appropriate corrective measures. Anonymous reports are
examined based on the quality of their documentation and the ability to trace the irregular action being
reported.
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The Group has established communication channels, available at any time, to accommodate both named
and anonymous reports. Specifically, The Group has established the following dedicated reporting channels,
which are available 24/7 and allow for both anonymous and named reports to be submitted:
• By postal mail, either anonymously or with identification, to P.O. Box No. 61371, maintained by the
Group at ELTA Amaroussion.
• By email to a designated whistleblowing address: whistleblowing@optimabank.gr. Furthermore, if an
employee receives a report through any other communication channel, it must be immediately forwarded
to the Head of Internal Audit.
Corruption and bribery are recognized as critical issues of concern. The Global Program against Corruption
promotes international transparency and accountability through the establishment of an audit mechanism,
the provisions included in the UN Convention on Corruption of 31.10.2003, and the adoption of coherent
strategies by the international community to fight corruption through shared experiences and information.
Greece approved the above Convention by Law no. 3666/2008 (FEK A105/10/6/08) and signed the United
Nations Convention against Corruption on 10 December 2003. Generally accepted rules of international law
and international conventions, when ratified by an act and in effect, form an integral part of Greece's
domestic law and override any other contrary provision of domestic law.
The Anti-Bribery and Anti-Corruption Policy is based on international banking practices and existing legal
obligations. The Anti-Bribery and Anti-Corruption Policy is aligned with the principles of the United Nations
Convention against Corruption, although the principles of the United Nations Convention against Corruption
have not yet been officially incorporated in this existing policy. Full adherence to the UN Convention against
Corruption is expected to be completed withing 2025 and disclosed in the next Sustainability Statement.
The Anti-Bribery and Anti-Corruption Policy includes prohibitions, preventive measures, reporting
mechanisms, and procedures for investigation and enforcement, all aimed at promoting transparency,
accountability, and ethical conduct.
The reporting channels enable stakeholders to report concerns confidentially and anonymously. All
employees are informed through the intranet for these reporting channels. The employees designated to
receive reports are trained to handle them appropriately, ensuring confidentiality and conducting thorough
investigations. Furthermore, the Human Resources Division is responsible for communicating the policy.
The Group has implemented measures to protect whistleblowers who make reports in good faith and
respect their anonymity, as required by applicable law transposing Directive (EU) 2019/1937 of the
European Parliament and the Council. These measures include safeguarding the employment status of
whistleblowers and ensuring that no adverse actions are taken against them because of their reporting.
In this context, any negative behavior directed towards someone who has made a report, such as demotion
or deprivation of promotion, negative performance appraisal or negative professional recommendation,
non-renewal or early termination of a temporary employment contract, coercion, intimidation, harassment,
or marginalization, is forbidden, even if the report is later proven to be incorrect. The same level of
protection applies to third parties associated with the whistleblower, such as colleagues or family members,
who may face retaliation in the workplace. If the whistleblower is an external contractor, early termination
or cancellation of contracts for goods or services because of the report is also prohibited.
The Group has specific procedures for investigating business conduct incidents promptly, independently,
and objectively. Employees who become aware of a violation of regulations should report it to their
supervisor. The report is then forwarded to the Head of Human Resources and the Head of Regulatory
Compliance. In cases involving fraud, the Head of Internal Audit should be also informed accordingly.
Additionally, if anyone becomes aware of illegal activities or policy violations, as outlined in the Anti-Bribery
and Anti-Corruption Policy, reports it immediately to his/ her supervisor or uses other appropriate channels,
maintaining their anonymity. The relevant information is then communicated to the top management to
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implement the appropriate procedures. Furthermore, the Group has established a Complaints Policy and
Procedures that describe the management and dispute resolution process for complainant banking
customers or external parties, as well as the description of all procedural actions required for this purpose.
The Group's activities are carried out with integrity, transparency, and accountability. This commitment
helps build trust with stakeholders and supports sustainable growth. To reinforce this, employees
participate in awareness sessions related to business conduct, where necessary, along with relevant training
sessions provided by the Group.
In general, the functions that are potentially most at risk of corruption and bribery are those dealing directly
with customers, suppliers, providers, contractors and associates.
G1-3 – Prevention and detection of corruption and bribery
The Group has established a comprehensive framework consisting of policies, procedures, and control
mechanisms to mitigate the risks of corruption and bribery, as well as to prevent, detect, and address
allegations related to these issues. Ensuring transparency in corporate governance and the business
decision-making process is a top priority. The Group employs best practices, adhering to both national and
international regulations, to promote an anti-corruption culture and maintains a firm stance against such
practices. To reinforce this commitment, the Group has adopted a zero-tolerance approach to corruption
and bribery, ensuring that all employees, contractors, and business partners strictly adhere to the principles
outlined in the Anti-Bribery and Anti-Corruption Policy. This policy is clearly communicated at all
organizational levels, and any violations are met with immediate and decisive action. The Anti-Bribery and
Anti-Corruption Policy is disseminated to employees, contractors, and business partners through internal
communication, training sessions, and regular updates.
Furthermore, the Internal Audit Division monitors and oversees the procedures through which anonymous
or identified complaints are made via reporting mechanisms regarding potential breaches in the processes
of collecting, processing, and disclosing financial information. This includes complaints related to
accounting, auditing, internal financial controls, and significant allegations of misconduct. In addition,
internal controls are implemented to monitor financial transactions and detect unusual or suspicious
activities. Regular preventive and corrective audits, as well as compliance checks, are conducted to ensure
adherence to the anti-bribery and anti-corruption policy and related procedures. This comprehensive
approach helps maintain the integrity of financial information and underscores the Group’s commitment to
preventing and addressing corruption and bribery.
Τo enhance its efforts in combating money laundering and financial crime, an Anti-Money Laundering (AML)
Policy has been established, along with control and reporting systems. The matrix of compliant procedures
together with appropriate supervision with systems and controls, segregation of duties and appropriate
staff training are the key pillars in addressing the risks of money laundering and terrorist financing. These
systems are designed to detect and prevent illicit activities by monitoring transactions and identifying
suspicious behavior. The Internal Audit Division conducts audits tailored to the identification, assessment,
monitoring, and management of money laundering and terrorist financing risks across the units. These
audits are reported to the Bank’s Management, and the findings are communicated to the Regulatory
Compliance Division for evaluation and action. By integrating these robust measures, the commitment to
maintaining the highest standards of integrity and compliance is demonstrated, thereby safeguarding the
financial system, and protecting its customers from financial crime.
Disciplinary actions may also be taken depending on the seriousness of misconduct related to corruption
and bribery incidents. Non-compliance can result in disciplinary measures against the individuals involved.
These actions may include written warnings, termination of employment, or, if necessary, legal actio
n
depending on the nature and severity of the incident.
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Additionally, the Group applies rigorous due diligence standards to its customers, suppliers, outsourcing
partners, and third parties to ensure compliance with anti-corruption and bribery standards. Anti-corruption
clauses are included in contracts and agreements with business partners to minimize the risk of corruption
and to ensure that all business relationships are conducted with the highest level of integrity.
The procedures in place to prevent, detect, and address allegations or incidents of corruption and bribery
include the Anti-Bribery and Anti-Corruption Policy, which ensures compliance with applicable anti-
corruption and anti-bribery laws. This policy sets clear guidelines for appropriate behavior in line with the
Group’s values and principles and raises awareness of the various forms of corruption and bribery. It also
promotes confidential reporting of suspected or actual incidents, encourages vigilance among employees
and partners, and ensures the protection of employees and the organization’s reputation. Additionally, the
Risk & Control Self-Assessment (RCSA) Methodology is implemented, outlining the process for identifying
and assessing risks and conducting internal self-assessments. The Operational Risk Management Policy and
the Risk Management Policy are also in place to manage and mitigate risks associated with corruption and
bribery. These policies and methodologies serve as effective controls and mechanisms for detecting
incidents of corruption and bribery.
The Internal Audit Division is responsible for investigating cases of bribery and corruption as dictated in
the 3
rd
line of defense. To ensure the integrity of the Internal Audit System, the Group has delegated
powers to independent units and the Committees of the Board of Directors, applying the “Three Lines of
defense Model.” It operates distinctively from the first and second lines of defense to ensure impartiality
and objectivity. This discretion guarantees that investigations are independent from the chain of
management involved in the prevention and detection of corruption or bribery. The Internal Audit Division
thoroughly examines allegations of corruption and bribery, ensuring that all findings are based on factual
evidence and that appropriate actions are taken, based on the investigation outcomes. Additionally, it
evaluates the effectiveness of the measures and controls implemented by the first and second lines of
defense in the prevention and detection of corruption and bribery.
The Internal Audit Division is also responsible for reporting the outcomes of investigations in accordance
with its manuals and procedures. This process ensures that findings and recommendations are
communicated to the relevant administrative, management, and supervisory bodies. By adhering to
established reporting protocols, the Internal Audit Division provides assurance that investigation outcomes
are transparently and effectively communicated. This reporting process ensures that appropriate actions
are taken based on the investigation outcomes, while maintaining compliance with relevant laws and
regulations.
Additionally, the Internal Audit Division reports monthly results to the Bank's Management, annual and
half-yearly results to the Capital Market Commission and the Guarantee Fund, and annual results to the
Ministry of Development. This reporting structure ensures that all relevant internal and external bodies and
authorities are kept informed of investigation outcomes and the actions taken.
The Anti-bribery and Anti-corruption Policy is communicated to relevant stakeholders to ensure it is easily
accessible and fully understood. Employees are informed about the policy through the intranet, internal
emails, and training programs. The governance of the policy underscores its importance and involves the
BoD, the ExCo, relevant divisions and departments, and business units. Specifically, the BoD holds overall
responsibility for defining, approving, and overseeing the policy’s implementation. It ensures that the policy
aligns with the principles and values of the Group. The Regulatory Compliance Division is tasked with
reviewing and amending the policy as necessary and, in collaboration with the Human Resources Division,
developing training and awareness programs for staff.
183
The Internal Audit Division investigates reports of policies violations across all levels. It evaluates the
adequacy of control mechanisms and ensures compliance with the policy through independent preventive
and corrective audits. The Risk Management Division assesses the risks of corruption and bribery as part
of conducting Risk and Control Self-Assessments (RCSA) within relevant units. It also coordinates the "self-
assessment of corruption and bribery risk" process in collaboration with the Regulatory Compliance Division
and the Internal Audit Division, with final approval by the ExCo. Business units are responsible for ensuring
compliance with the policy within their areas of operation. In case of identified deviations, they are required
to promptly report them to Management and the Internal Audit Division.
The Human Resources Division is responsible for disseminating, updating, and providing training to all
employees regarding the Anti-bribery and Anti-corruption Policy. During the 2024 financial year, the Group
conducted a seminar on Anti-Money Laundering (AML) and anti-corruption through "The Hellenic Banking
Institute" via an online platform. The seminar was aligned with the Group's policy and mandatory for
employees in at-risk functions, while voluntary participation was encouraged for other workers. The seminar
covered the following sections: prevention and suppression of money laundering and terrorist financing
and combatting corruption. On top of the theoretical training, the seminar also provided practical tips and
case studies to help participants enrich their knowledge and skills, enabling them to respond more
effectively to the challenges they face in their daily work. The section on combating corruption aimed to
raise awareness among participants on this subject by providing a historical overview of its national and
international dimensions. In this section, participants were also informed about the key points of the
relevant policy. The seminar aimed to equip employees with the knowledge and practical skills necessary
to identify and mitigate risks and incidents associated with corruption and bribery. It included tips, case
studies, and assessments to ensure a thorough understanding of the issues. The seminar was attended by
all Group employees across all levels, including those in at-risk functions. It successfully covered a
significant percentage (95%) of functions-at-risk, which are identified as functions vulnerable to corruption
and bribery due to their tasks and responsibilities. This ensured that employees in these functions received
the necessary training to effectively manage and mitigate risks. The seminar also made reference to the
members of the administrative, management, and supervisory bodies, in order to emphasize the oversight
and the responsibilities of these bodies in preventing and addressing corruption and bribery.
Metrics and targets
G1-4 – Confirmed incidents of corruption or bribery
During 2024, the Group recorded zero convictions for violations of anti-corruption and anti-bribery laws,
and no fines were imposed for such violations. Consequently, no actions were required to address breaches
in procedures and standards related to anti-corruption and anti-bribery. Therefore, there has been no need
for action or further prevention measures. The Group continues to monitor the situation and implement
and modify policies as necessary in the future. The Group has adopted a zero-tolerance approach to
corruption and bribery but has not set measurable, outcome-oriented targets in this regard. It ensures full
compliance with the principles outlined in the Anti-Bribery and Anti-Corruption Policy by all employees,
contractors, and business partners, and actively monitors adherence. The Group continuously evaluates its
practices and its commitment to integrity and transparency, fostering a culture of ethical behavior across
the organization.
184
APPENDIX
ANNEX VI - Disclosures Delegated Act
0. Summary of KPIs to be disclosed by credit institutions under Article 8 of EU Taxonomy Regulation
The GAR summary presents the Green Asset Ratio based on alignment data from the Group’s clients, including Turnover and Capital Expenditures (CapEx). It
also provides additional proportions related to the scope of GAR.
Total
environmentally
sustainable
assets****
Total
environmentally
sustainable
assets*****
KPI****
KPI*****
% coverage
(over total
assets)***
% of assets excluded
from the numerator of
the GAR (Article 7(2)
and (3) and Section
1.1.2. of Annex V)
% of assets
excluded from the
denominator of the
GAR (Article 7(1)
and Section 1.2.4 of
Annex V)
Main
KPI
Green asset ratio
(GAR) stock
55
108
1.26%
2.51%
77.89%
60.44%
22.11%
* For credit institutions that do not meet the conditions of Article 94(1) of the CRR or the conditions set out in Article 325a(1) of the CRR
**Fees and commissions income from services other than lending and AuM
Instutitons shall dislcose forwardlooking information for this KPIs, including information in terms of targets, together with relevant explanations on the methodology applied.
*** % of assets covered by the KPI over banks´ total assets
****based on the Turnover KPI of the counterparty
*****based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
Total
environmentally
sustainable
activities****
Total
environmentally
sustainable
activities*****
KPI****
KPI*****
% coverage
(over total
assets)
% of assets excluded
from the numerator of
the GAR (Article 7(2)
and (3) and Section
1.1.2. of Annex V)
% of assets excluded
from the denominator
of the GAR (Article
7(1) and Section 1.2.4
of Annex V)
Additional KPIs
GAR (flow)
10
56
2.13%
12.25%
8.23%
-
-
Trading book*
N/A
N/A
N/A
N/A
Financial
guarantees
29
53
14.79%
27.43%
Assets under
management
6
81
1.51%
20.19%
Fees and
commissions
income**
N/A
N/A
N/A
N/A
185
The main EU Taxonomy table is divided into eight sections, each providing a detailed breakdown of the various components that contribute to the Green Asset Ratio
(GAR).
Table 1 - Turnover
1. Assets for the calculation of GAR based on Turnover
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying amount
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for
GAR calculation
967
337
55
0
0
9
1
0
0
0
2
Financial undertakings
171
48
3
0
0
0
1
0
0
0
3
Credit institutions
165
42
3
0
0
0
1
0
0
0
4
Loans and advances
24
5
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
140
36
3
0
0
0
1
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
7
Other financial corporations
7
7
0
0
0
0
0
0
0
0
8
of which investment firms
7
7
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including Up
7
7
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
0
14
Debt securities, including Up
0
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including Up
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
20
Non-financial undertakings
548
159
52
0
0
9
1
0
0
0
21
Loans and advances
463
128
50
0
0
9
0
0
0
0
22
Debt securities, including UoP
85
30
2
0
0
0
1
0
0
0
23
Equity instruments
0
0
0
0
0
0
0
0
24
Households
221
130
0
0
0
0
0
0
0
0
25
of which loans collateralized by residential immovable property
130
130
0
0
0
0
0
0
0
0
26
of which building renovation loans
0
0
0
0
0
0
0
0
0
0
27
of which motor vehicle loans
0
0
0
0
0
0
28
Local governments financing
27
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
30
Other local government financing
27
0
0
0
0
0
0
0
0
0
186
1. Assets for the calculation of GAR based on Turnover
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying amount
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
31
Collateral obtained by taking possession: residential and commercial
immovable properties
0
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
3349
33
Financial and Non-financial undertakings
2813
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
2768
35
Loans and advances
2748
36
of which loans collateralized by commercial immovable property
0
37
of which building renovation loans
0
38
Debt securities
20
39
Equity instruments
0
40
Non-EU country counterparties not subject to NFRD disclosure obligations
45
41
Loans and advances
45
42
Debt securities
0
43
Equity instruments
0
44
Derivatives
2
45
On demand interbank loans
133
46
Cash and cash-related assets
16
47
Other categories of assets (e.g. goodwill, commodities etc.)
384
48
Total GAR assets
4316
337
55
0
0
9
1
0
0
0
49
Assets not covered for GAR calculation
1225
50
Central governments and Supranational issuers
206
51
Central banks exposure
781
52
Trading book
238
53
Total assets
5541
337
60
0
0
9
1
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
194
70
29
0
1
1
0
0
0
0
55
Assets under management
401
14
6
0
0
0
4
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
401
14
6
0
0
0
4
0
0
0
187
1. Assets for the calculation of GAR based on Turnover
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources (WTR)
Circular economy (CE)
Pollution prevention and control (PPC)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for
GAR calculation
0
0
0
0
0
0
0
0
0
0
0
0
2
Financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
3
Credit institutions
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
0
0
0
0
0
0
0
0
8
of which investment firms
0
0
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
14
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
21
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
22
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
23
Equity instruments
0
0
0
0
0
0
0
0
0
24
Households
0
0
0
0
25
of which loans collateralized by residential immovable property
0
0
0
0
26
of which building renovation loans
0
0
0
0
27
of which motor vehicle loans
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
30
Other local government financing
0
0
0
0
0
0
0
0
0
0
0
0
188
1. Assets for the calculation of GAR based on Turnover
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources (WTR)
Circular economy (CE)
Pollution prevention and control (PPC)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
35
Loans and advances
36
of which loans collateralized by commercial immovable property
37
of which building renovation loans
38
Debt securities
39
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR assets
0
0
0
0
0
0
0
0
0
0
0
0
49
Assets not covered for GAR calculation
50
Central governments and Supranational issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
0
0
0
0
0
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
0
0
0
0
0
0
0
0
55
Assets under management
0
0
0
0
1
0
0
0
0
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
0
0
0
0
1
0
0
0
0
0
0
0
189
1. Assets for the calculation of GAR based on Turnover
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for GAR
calculation
0
0
0
0
338
55
0
0
9
2
Financial undertakings
0
0
0
0
49
3
0
0
0
3
Credit institutions
0
0
0
0
42
3
0
0
0
4
Loans and advances
0
0
0
0
5
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
37
3
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
7
0
0
0
0
8
of which investment firms
0
0
0
0
7
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
7
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
14
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
159
52
0
0
9
21
Loans and advances
0
0
0
0
128
50
0
0
9
22
Debt securities, including UoP
0
0
0
0
31
2
0
0
0
23
Equity instruments
0
0
0
0
0
0
0
24
Households
130
0
0
0
0
25
of which loans collateralized by residential immovable property
130
0
0
0
0
26
of which building renovation loans
0
0
0
0
0
27
of which motor vehicle loans
0
0
0
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
30
Other local government financing
0
0
0
0
0
0
0
0
0
190
1. Assets for the calculation of GAR based on Turnover
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
31
Collateral obtained by taking possession: residential and commercial
immovable properties
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for GAR calculation (covered in the
denominator)
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
35
Loans and advances
36
of which loans collateralized by commercial immovable property
37
of which building renovation loans
38
Debt securities
39
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR assets
0
0
0
0
338
55
0
0
9
49
Assets not covered for GAR calculation
50
Central governments and Supranational issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
338
55
0
0
9
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
70
29
0
1
1
55
Assets under management
0
0
0
0
19
6
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
0
0
0
0
19
6
0
0
0
191
Table 1 - CapEx
1. Assets for the calculation of GAR based on CapEx
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying amount
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for
GAR calculation
967
402
108
0
2
31
1
0
0
0
2
Financial undertakings
171
64
11
0
0
0
1
0
0
0
3
Credit institutions
165
58
11
0
0
0
1
0
0
0
4
Loans and advances
24
8
2
0
0
0
0
0
0
0
5
Debt securities, including UoP
140
49
9
0
0
0
1
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
7
Other financial corporations
7
7
0
0
0
0
0
0
0
0
8
of which investment firms
7
7
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
7
7
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
0
14
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
20
Non-financial undertakings
548
208
97
0
2
31
0
0
0
0
21
Loans and advances
463
165
86
0
2
30
0
0
0
0
22
Debt securities, including UoP
85
42
11
0
1
1
0
0
0
0
23
Equity instruments
0
0
0
0
0
0
0
0
24
Households
221
130
0
0
0
0
0
0
0
0
25
of which loans collateralized by residential immovable property
130
130
0
0
0
0
0
0
0
0
26
of which building renovation loans
0
0
0
0
0
0
0
0
0
0
27
of which motor vehicle loans
0
0
0
0
0
0
28
Local governments financing
27
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
30
Other local government financing
27
0
0
0
0
0
0
0
0
0
31
Collateral obtained by taking possession: residential and commercial
immovable properties
0
0
0
0
0
0
0
0
0
0
192
1. Assets for the calculation of GAR based on CapEx
a
b
c
d
e
f
g
h
i
j
Million EUR
Total [gross]
carrying amount
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which enabling
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
3349
33
Financial and Non-financial undertakings
2813
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
2768
35
Loans and advances
2748
36
of which loans collateralized by commercial immovable property
0
37
of which building renovation loans
0
38
Debt securities
20
39
Equity instruments
0
40
Non-EU country counterparties not subject to NFRD disclosure obligations
45
41
Loans and advances
45
42
Debt securities
0
43
Equity instruments
0
44
Derivatives
2
45
On demand interbank loans
133
46
Cash and cash-related assets
16
47
Other categories of assets (e.g. goodwill, commodities etc.)
384
48
Total GAR assets
4316
402
108
0
2
31
1
0
0
0
49
Assets not covered for GAR calculation
1225
50
Central governments and Supranational issuers
206
51
Central banks exposure
781
52
Trading book
238
53
Total assets
5541
402
108
0
2
31
1
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
194
118
53
0
1
22
0
0
0
0
55
Assets under management
401
150
80
0
0
61
2
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
401
150
80
0
0
61
2
0
0
0
193
1. Assets for the calculation of GAR based on CapEx
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources (WTR)
Circular economy (CE)
Pollution prevention and control (PPC)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for
GAR calculation
0
0
0
0
0
0
0
0
0
0
0
0
2
Financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
3
Credit institutions
0
0
0
0
0
0
0
0
0
0
0
0
4
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
5
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
0
0
0
0
0
0
0
0
8
of which investment firms
0
0
0
0
0
0
0
0
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
14
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
0
0
0
0
0
0
0
0
21
Loans and advances
0
0
0
0
0
0
0
0
0
0
0
0
22
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
0
0
0
23
Equity instruments
0
0
0
0
0
0
0
0
0
24
Households
0
0
0
0
25
of which loans collateralized by residential immovable property
0
0
0
0
26
of which building renovation loans
0
0
0
0
27
of which motor vehicle loans
28
Local governments financing
0
0
0
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
0
0
0
30
Other local government financing
0
0
0
0
0
0
0
0
0
0
0
0
194
1. Assets for the calculation of GAR based on CapEx
k
l
m
n
o
p
q
r
s
t
u
v
Million EUR
31 December 2024
Water and marine resources (WTR)
Circular economy (CE)
Pollution prevention and control (PPC)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
31
Collateral obtained by taking possession: residential and
commercial immovable properties
0
0
0
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for GAR calculation (covered in
the denominator)
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
35
Loans and advances
36
of which loans collateralized by commercial immovable property
37
of which building renovation loans
38
Debt securities
39
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR assets
0
0
0
0
0
0
0
0
0
0
0
0
49
Assets not covered for GAR calculation
50
Central governments and Supranational issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
0
0
0
0
0
0
0
0
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
0
0
0
0
0
0
0
0
55
Assets under management
0
0
0
0
1
0
0
0
0
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
0
0
0
0
1
0
0
0
0
0
0
0
195
1. Assets for the calculation of GAR based on CapEx
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and denominator
1
Loans and advances, debt securities and equity instrument no HfT eligible for GAR
calculation
0
0
0
0
403
108
0
2
31
2
Financial undertakings
0
0
0
0
65
11
0
0
0
3
Credit institutions
0
0
0
0
58
11
0
0
0
4
Loans and advances
0
0
0
0
8
2
0
0
0
5
Debt securities, including UoP
0
0
0
0
50
9
0
0
0
6
Equity instruments
0
0
0
0
0
0
0
7
Other financial corporations
0
0
0
0
7
0
0
0
0
8
of which investment firms
0
0
0
0
7
0
0
0
0
9
Loans and advances
0
0
0
0
0
0
0
0
0
10
Debt securities, including UoP
0
0
0
0
7
0
0
0
0
11
Equity instruments
0
0
0
0
0
0
0
12
of which management companies
0
0
0
0
0
0
0
0
0
13
Loans and advances
0
0
0
0
0
0
0
0
0
14
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
16
of which insurance undertakings
0
0
0
0
0
0
0
0
0
17
Loans and advances
0
0
0
0
0
0
0
0
0
18
Debt securities, including UoP
0
0
0
0
0
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
20
Non-financial undertakings
0
0
0
0
208
97
0
2
31
21
Loans and advances
0
0
0
0
165
86
0
2
30
22
Debt securities, including UoP
0
0
0
0
42
11
0
1
1
23
Equity instruments
0
0
0
0
0
0
0
24
Households
130
0
0
0
0
25
of which loans collateralized by residential immovable property
130
0
0
0
0
26
of which building renovation loans
0
0
0
0
0
27
of which motor vehicle loans
0
0
0
0
0
28
Local governments financing
0
0
0
0
0
0
0
0
0
29
Housing financing
0
0
0
0
0
0
0
0
0
30
Other local government financing
0
0
0
0
0
0
0
0
0
196
1. Assets for the calculation of GAR based on CapEx
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
31 December 2024
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
31
Collateral obtained by taking possession: residential and commercial
immovable properties
0
0
0
0
0
0
0
0
0
32
Assets excluded from the numerator for GAR calculation (covered in the
denominator)
0
0
0
0
0
33
Financial and Non-financial undertakings
34
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations
35
Loans and advances
36
of which loans collateralized by commercial immovable property
37
of which building renovation loans
38
Debt securities
39
Equity instruments
40
Non-EU country counterparties not subject to NFRD disclosure obligations
41
Loans and advances
42
Debt securities
43
Equity instruments
44
Derivatives
45
On demand interbank loans
46
Cash and cash-related assets
47
Other categories of assets (e.g. goodwill, commodities etc.)
48
Total GAR assets
0
0
0
0
403
108
0
2
31
49
Assets not covered for GAR calculation
50
Central governments and Supranational issuers
51
Central banks exposure
52
Trading book
53
Total assets
0
0
0
0
403
108
0
2
31
Off-balance sheet exposures-Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
0
0
0
0
118
53
0
1
22
55
Assets under management
0
0
0
0
159
81
0
0
61
56
Of which debt securities
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
0
0
0
0
159
81
0
0
61
197
The tables below show the proportion of environmentally sustainable assets compared to the covered assets recorded in the main EU Taxonomy. The purpose of these
tables is to show the proportion of total assets covered by the GAR.
Table 2 - Turnover
2. GAR sector information based on Turnover
a
b
c
d
Breakdown by sector - NACE 4 digits level (code and label)
Climate change mitigation (CCM)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCM)
Million EUR
Of which environmentally
sustainable (CCM)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
2
1
4
C2442 Manufacture of aluminum
8
2
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
16
4
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
3
2
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
33
28
9
F4120 Construction of residential and non-residential buildings
25
0
10
F4211 Construction of roads and motorways
45
8
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
23
23
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
5
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
1
0
17
J6201 Computer programming activities
1
1
18
J6209 Other information technology and computer service activities
1
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
34
10
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
1
0
198
2. GAR sector information based on Turnover
e
f
g
h
Breakdown by sector - NACE 4 digits level (code and label)
Climate change adaptation (CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCA)
Million EUR
Of which environmentally
sustainable (CCA)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
199
2. GAR sector information based on Turnover
i
j
k
l
Breakdown by sector - NACE 4 digits level (code and label)
Water and marine resources (WTR)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (WTR)
Million EUR
Of which environmentally
sustainable (WTR)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
200
2. GAR sector information based on Turnover
m
n
o
p
Breakdown by sector - NACE 4 digits level (code and label)
Circular economy (CE)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CE)
Million EUR
Of which environmentally
sustainable (CE)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
201
2. GAR sector information based on Turnover
q
r
s
t
Breakdown by sector - NACE 4 digits level (code and label)
Pollution prevention and control (PPC)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (PPC)
Million EUR
Of which environmentally
sustainable (PPC)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
202
2. GAR sector information based on Turnover
u
v
w
x
Breakdown by sector - NACE 4 digits level (code and label)
Biodiversity and ecosystems (BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (BIO)
Million EUR
Of which environmentally
sustainable (BIO)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
203
2. GAR sector information based on Turnover
y
z
aa
ab
Breakdown by sector - NACE 4 digits level (code and label)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCM + CCA + WTR
+ CE + PPC + BIO)
Million EUR
Of which environmentally
sustainable (CCM + CCA + WTR
+ CE + PPC + BIO)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
2
1
4
C2442 Manufacture of aluminum
8
2
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
16
4
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
3
2
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
33
28
9
F4120 Construction of residential and non-residential buildings
25
0
10
F4211 Construction of roads and motorways
45
8
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
23
23
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
5
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
1
0
17
J6201 Computer programming activities
2
1
18
J6209 Other information technology and computer service activities
1
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
34
10
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
1
0
204
Table 2 - CapEx
2. GAR sector information based on CapEx
a
b
c
d
Breakdown by sector - NACE 4 digits level (code and label)
Climate change mitigation (CCM)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCM)
Million EUR
Of which environmentally
sustainable (CCM)
1
C1393 Manufacture of carpets and rugs
1
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
2
2
4
C2442 Manufacture of aluminum
31
10
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
25
10
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
3
3
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
26
9
9
F4120 Construction of residential and non-residential buildings
39
0
10
F4211 Construction of roads and motorways
67
30
11
F4221 Construction of utility projects for fluids
5
3
12
F4299 Construction of other civil engineering projects
28
28
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
3
2
14
H5010 Sea and coastal passenger water transport
5
2
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
2
0
17
J6201 Computer programming activities
1
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
46
40
23
N8121 General cleaning of buildings
1
1
24
S9999 Other services
0
0
205
2. GAR sector information based on CapEx
e
f
g
h
Breakdown by sector - NACE 4 digits level (code and label)
Climate change adaptation (CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCA)
Million EUR
Of which environmentally
sustainable (CCA)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
206
2. GAR sector information based on CapEx
i
j
k
l
Breakdown by sector - NACE 4 digits level (code and label)
Water and marine resources (WTR)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (WTR)
Million EUR
Of which environmentally
sustainable (WTR)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
207
2. GAR sector information based on CapEx
m
n
o
p
Breakdown by sector - NACE 4 digits level (code and label)
Circular economy (CE)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CE)
Million EUR
Of which environmentally
sustainable (CE)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
208
2. GAR sector information based on CapEx
q
r
s
t
Breakdown by sector - NACE 4 digits level (code and label)
Pollution prevention and control (PPC)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (PPC)
Million EUR
Of which environmentally
sustainable (PPC)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
209
2. GAR sector information based on CapEx
u
v
w
x
Breakdown by sector - NACE 4 digits level (code and label)
Biodiversity and ecosystems (BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (BIO)
Million EUR
Of which environmentally
sustainable (BIO)
1
C1393 Manufacture of carpets and rugs
0
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
0
0
4
C2442 Manufacture of aluminum
0
0
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
0
0
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
0
0
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
0
0
9
F4120 Construction of residential and non-residential buildings
0
0
10
F4211 Construction of roads and motorways
0
0
11
F4221 Construction of utility projects for fluids
0
0
12
F4299 Construction of other civil engineering projects
0
0
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
0
0
14
H5010 Sea and coastal passenger water transport
0
0
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
0
0
17
J6201 Computer programming activities
0
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
0
0
23
N8121 General cleaning of buildings
0
0
24
S9999 Other services
0
0
210
2. GAR sector information based on CapEx
y
z
aa
ab
Breakdown by sector - NACE 4 digits level (code and label)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
Million EUR
Of which environmentally
sustainable (CCM + CCA + WTR
+ CE + PPC + BIO)
Million EUR
Of which environmentally
sustainable (CCM + CCA + WTR
+ CE + PPC + BIO)
1
C1393 Manufacture of carpets and rugs
1
0
2
C2020 Manufacture of pesticides and other agrochemical products
0
0
3
C2420 Manufacture of tubes, pipes, hollow profiles, and related fittings, of steel
2
2
4
C2442 Manufacture of aluminum
31
10
5
C2550 Forging, pressing, stamping, and roll-forming of metal; powder metallurgy
25
10
6
C2630 Manufacture of communication equipment
0
0
7
C2732 Manufacture of other electronic and electric wires and cables
3
3
8
D3511 Production of electricity within the electricity, gas, steam, and air conditioning supply sector
26
9
9
F4120 Construction of residential and non-residential buildings
39
0
10
F4211 Construction of roads and motorways
67
30
11
F4221 Construction of utility projects for fluids
5
3
12
F4299 Construction of other civil engineering projects
28
28
13
G4671 Wholesale of solid, liquid, and gaseous fuels and related products
4
2
14
H5010 Sea and coastal passenger water transport
5
2
15
H5221 Service activities incidental to land transportation
0
0
16
I5510 Hotels and similar accommodation
2
0
17
J6201 Computer programming activities
1
0
18
J6209 Other information technology and computer service activities
0
0
19
K6430 Trusts, funds, and similar financial entities
0
0
20
L6820 Renting and operating of own or leased real estate
0
0
21
M7112 Engineering activities and related technical consultancy
0
0
22
M7490 Other professional, scientific and technical activities
46
40
23
N8121 General cleaning of buildings
1
1
24
S9999 Other services
0
0
211
Table 3 - Turnover
3. GAR KPI stock based on Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instrument no HfT eligible for
GAR calculation
34.82%
5.64%
0.00%
0.01%
0.95%
0.12%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2
Financial undertakings
28.15%
1.70%
0.00%
0.05%
0.12%
0.34%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
25.27%
1.77%
0.00%
0.06%
0.12%
0.36%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
21.99%
1.43%
0.00%
0.16%
0.18%
0.23%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including UoP
25.84%
1.82%
0.00%
0.04%
0.11%
0.38%
0,01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial
corporations
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including UoP
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
212
3. GAR KPI stock based on Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance
undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial undertakings
28.94%
9.41%
0.00%
0.01%
1.64%
0.10%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
27.71%
10.70%
0.00%
0.00%
1.91%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities, including UoP
35.60%
2.45%
0.00%
0,06%
0.19%
0.62%
0,01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
58.83%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralized
by residential immovable
property
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building renovation
loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
213
3. GAR KPI stock based on Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31
Collateral obtained by
taking possession:
residential and commercial
immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
7.80%
1.26%
0.00%
0.00%
0.21%
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
214
3. GAR KPI stock based on Turnover
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator
and denominator
1
Loans and advances, debt securities and
equity instrument no HfT eligible for GAR
calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
34.93%
5,64%
0.00%
0,01%
0.95%
17.46%
2
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28.50%
1.70%
0.00%
0.05%
0.12%
3.09%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25.63%
1.77%
0.00%
0.06%
0.12%
2.97%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22.22%
1.43%
0.00%
0.16%
0.19%
0.44%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26.22%
1.83%
0.00%
0.04%
0.11%
2.53%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0.12%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0,12%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0.12%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29.04%
9.41%
0.00%
0.01%
1.64%
9.90%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27.71%
10.70%
0.00%
0.00%
1.91%
8.36%
22
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
36.23%
2.46%
0.00%
0.06%
0.19%
1.54%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
58.83%
0.00%
0.00%
0.00%
0.00%
3.98%
25
of which loans collateralized by residential
immovable property
100.00%
0.00%
0.00%
0.00%
0.00%
2.34%
215
3. GAR KPI stock based on Turnover
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
26
of which building renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.48%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.48%
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7.83%
1.26%
0.00%
0.00%
0.21%
77.89%
216
Table 3 - CapEx
3. GAR KPI stock based on CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instrument no HfT eligible for
GAR calculation
41.56%
11.17%
0.00%
0.25%
3.22%
0.08%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2
Financial undertakings
37.55%
6.54%
0.00%
0.13%
0.24%
0.39%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
35.05%
6.80%
0.00%
0.14%
0.25%
0.40%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
34.38%
8.50%
0.00%
0.30%
0.33%
0.24%
0,03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including
UoP
35.16%
6.51%
0.00%
0.11%
0.23%
0.43%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial
corporations
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
217
3. GAR KPI stock based on CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
10
Debt securities, including
UoP
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance
undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial
undertakings
37.86%
17.66%
0.00%
0.39%
5.60%
0.01%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
35.70%
18.65%
0.00%
0.35%
6.40%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities, including
UoP
49.54%
12.31%
0.00%
0.64%
1.27%
0.09%
0,09%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
58.91%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralized
by residential immovable
property
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
218
3. GAR KPI stock based on CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total covered
assets in the denominator)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Of which Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
26
of which building renovation
loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31
Collateral obtained by
taking possession:
residential and
commercial immovable
properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
9.31%
2.50%
0.00%
0.06%
0.72%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
219
3. GAR KPI stock based on CapEx
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator
and denominator
1
Loans and advances, debt securities and
equity instrument no HfT eligible for GAR
calculation
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
41.64%
11.18%
0.00%
0.25%
3.22%
17.46%
2
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
37.94%
6.54%
0.00%
0.13%
0.24%
3.09%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
35.45%
6.80%
0.00%
0.14%
0.25%
2.97%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
34.63%
8.53%
0.00%
0.30%
0.33%
0.44%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
35.59%
6.51%
0.00%
0.11%
0.23%
2.53%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0.12%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0.12%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0.12%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial undertakings
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
37.89%
17.68%
0.00%
0.39%
5.60%
9.90%
21
Loans and advances
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
35.73%
18.65%
0.00%
0.35%
6.40%
8.36%
22
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
49.63%
12.40%
0.00%
0.64%
1.27%
1.54%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
58.91%
0.00%
0.00%
0.00%
0.00%
3.98%
220
3. GAR KPI stock based on CapEx
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
25
of which loans collateralized by residential
immovable property
100.00%
0.00%
0.00%
0.00%
0.00%
2.34%
26
of which building renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
28
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.48%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.48%
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9.33%
2.51%
0.00%
0.06%
0.72%
77.89%
221
Table 4 - Turnover
4. GAR KPI flow based on Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total
eligible assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instrument no HfT eligible for
GAR calculation
26.68%
4.42%
0.00%
0.00%
0.31%
0.08%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2
Financial undertakings
21.67%
1.28%
0.00%
0.00%
0.12%
0.40%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
21.67%
1.28%
0.00%
0.00%
0.12%
0.40%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including
UoP
21.67%
1.28%
0.00%
0.00%
0.12%
0.40%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial
corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance
undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
222
4. GAR KPI flow based on Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total
eligible assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
18
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial
undertakings
20.08%
5.87%
0.00%
0.00%
0.41%
0.02%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
16.39%
5.78%
0.00%
0.00%
0,47%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities, including
UoP
33.67%
6.21%
0.00%
0.00%
0,20%
0,11%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
69.41%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralized
by residential immovable
property
100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building renovation
loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31
Collateral obtained by
taking possession:
residential and
commercial immovable
properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
26.68%
4.42%
0.00%
0.00%
0.31%
0.08%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
223
4. GAR KPI flow based on Turnover
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion
of total new
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instrument no HfT eligible for GAR calculation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31.71%
2.13%
0.00%
0.00%
0.08%
100.00%
2
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22.07%
1.29%
0.00%
0.00%
0.12%
14.49%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22,07%
1.29%
0.00%
0.00%
0,12%
14.49%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22,07%
1.29%
0.00%
0.00%
0.12%
14.49%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26.97%
2.69%
0.00%
0.00%
0.09%
72.12%
21
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25.12%
1.71%
0.00%
0.00%
0,06%
56.74%
22
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
33.78%
6.32%
0.00%
0.00%
0,20%
15.38%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
69.41%
0.00%
0.00%
0.00%
0.00%
13.05%
25
of which loans collateralized by residential
immovable property
100.00%
0.00%
0.00%
0.00%
0.00%
9.06%
26
of which building renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
224
4. GAR KPI flow based on Turnover
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion
of total new
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.34%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.34%
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31.71%
2.13%
0.00%
0.00%
0.08%
100.00%
225
Table 4 - CapEx
4. GAR KPI flow based on CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total
eligible assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instrument no HfT eligible for
GAR calculation
34.96%
12.25%
0.00%
0.03%
2.27%
0.08%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
2
Financial undertakings
31.68%
7.04%
0.00%
0.10%
0.26%
0.47%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
3
Credit institutions
31.68%
7.04%
0.00%
0.10%
0.26%
0.47%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including
UoP
31.68%
7.04%
0.00%
0.10%
0.26%
0.47%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial
corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management
companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance
undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
226
4. GAR KPI flow based on CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to flow of total
eligible assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered
assets funding taxonomy
relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
18
Debt securities, including
UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial
undertakings
29.64%
15.57%
0.00%
0.02%
3.09%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
21
Loans and advances
24.33%
16.16%
0.00%
0.02%
3.64%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
22
Debt securities, including
UoP
49.23%
13.36%
0.00%
0.01%
1.05%
0.11%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
68.88%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
25
of which loans collateralized
by residential immovable
property
99.24%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
26
of which building renovation
loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
27
of which motor vehicle
loans
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government
financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
31
Collateral obtained by
taking possession:
residential and
commercial immovable
properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
34.96%
12.25%
0.00%
0.03%
2.27%
0.08%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
227
4. GAR KPI flow based on CapEx
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion
of total new
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instrument no HfT eligible for GAR calculation
0.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
35.07%
12.25%
0.00%
0.03%
2.27%
100.00%
2
Financial undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32.15%
7.04%
0.00%
0.10%
0.26%
14.49%
3
Credit institutions
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32.15%
7.04%
0.00%
0.10%
0.26%
14.49%
4
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
5
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32.15%
7.04%
0.00%
0.10%
0.26%
14.49%
6
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
7
Other financial corporations
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
8
of which investment firms
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
9
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
11
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
12
of which management companies
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
13
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
14
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
15
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
16
of which insurance undertakings
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
17
Loans and advances
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
18
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
19
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
20
Non-financial undertakings
0.04%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
29.70%
15.57%
0.00%
0.02%
3.09%
72.12%
21
Loans and advances
0,05%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24.38%
16.16%
0.00%
0.02%
3.64%
56.74%
22
Debt securities, including UoP
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
49.34%
13.36%
0.00%
0.01%
1.05%
15.38%
23
Equity instruments
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
24
Households
68.88%
0.00%
0.00%
0.00%
0.00%
13.05%
25
of which loans collateralized by residential
immovable property
99.24%
0.00%
0.00%
0.00%
0.00%
9.06%
26
of which building renovation loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
228
4. GAR KPI flow based on CapEx
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to flow of total eligible assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion
of total new
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
27
of which motor vehicle loans
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
28
Local governments financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.34%
29
Housing financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30
Other local government financing
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.34%
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
32
Total GAR assets
0,03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
35.07%
12.25%
0.00%
0.03%
2.27%
100.00%
229
Table 5 - Turnover
5. KPI off-balance sheet exposures based on
Turnover
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off-balance sheet
assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
36.17%
14.79%
0.00%
0.42%
0.42%
2
Assets under management
0.05%
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
4.75%
1.51%
0.00%
0.00%
0.04%
5. KPI off-balance sheet exposures based on
Turnover
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off-balance sheet
assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
36.00%
14.79%
0.00%
0.42%
0.42%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.17%
0.00%
0.00%
0.00%
2
Assets under management
3.56%
1.49%
0.00%
0.00%
0.04%
0.96%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.18%
0.01%
0.00%
0.00%
230
Table 5 - CapEx
5. KPI off-balance sheet exposures based on
CapEx
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off-balance sheet
assets)
31 December 2024
Pollution prevention and control (PPC)
Biodiversity and ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use of
Proceeds
Of which transitional
Of which
enabling
1
Financial guarantees (FinGuar KPI)
0.17%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
60.85%
27.43%
0.00%
0.36%
11.35%
2
Assets under management
1.62%
0.02%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
39.54%
20.19%
0.00%
0.00%
15.25%
5. KPI off-balance sheet exposures based on
CapEx
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
% (compared to total eligible off-balance sheet
assets)
31 December 2024
Climate change mitigation (CCM)
Climate change adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which Use of
Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
Of which Use
of Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
60.65%
27.43%
0.00%
0.36%
11.35%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0,03%
0.00%
0.00%
0.00%
2
Assets under management
37.33%
20.03%
0.00%
0.00%
15.25%
0.55%
0.12%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0,03%
0,02%
0.00%
0.00%
231
ANNEX XII - Complementary Climate Delegated Act
Nuclear and fossil gas related activities
The tables below present taxonomy reporting on activities related to nuclear energy and fossil gas. Given the
ongoing discussion regarding their classification as environmentally sustainable activities, these activities are
reported separately from other activities detailed in the preceding tables. The scope of disclosures related to
nuclear and fossil gas is limited to non-financial corporations subject to the NFRD and local governments.
The reporting of eligibility and alignment for nuclear and fossil gas-related activities follows a distinct approach
compared to other activities. Notably, only six specific activities aimed at accelerating the transition to climate
neutrality qualify for alignment under the EU Taxonomy. These activities undergo the same assessment criteria
as other activities, with differences primarily in the reporting framework. The tables below outline taxonomy
eligibility and alignment for nuclear and fossil gas-related activities. Furthermore, exposures to these activities
are compared with the total covered assets reported under the Green Asset Ratio, highlighting the proportion
of financing associated with nuclear and fossil gas activities.
Template 1: Nuclear and fossil gas-related activities
Row
Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development,
demonstration and deployment of innovative electricity generation facilities that produce
energy from nuclear processes with minimal waste from the fuel cycle.
NO
2.
The undertaking carries out, funds or has exposures to construction and safe operation of
new nuclear installations to produce electricity or process heat, including for the
purposes of district heating or industrial processes such as hydrogen production, as well
as their safety upgrades, using best available technologies.
NO
3.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear
installations that produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production from nuclear energy, as well
as their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of
electricity generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and
operation of combined heat/cool and power generation facilities using fossil gaseous
fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and
operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.
NO
232
Template 2: Taxonomy-aligned economic activities (denominator)
Based on Turnover
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.26
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.27
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.28
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.29
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
26
0.60%
26
0,60%
0
0.00%
233
5.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.30
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
6.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.31
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6 above
in the
denominator of
the applicable
KPI
34
0.79%
34
0.79%
0
0.00%
8.
Total applicable
KPI
60
1.39%
60
1.39%
0
0.00%
234
Based on CapEx
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.26
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.27
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.28
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.29
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
26
0.60%
26
0.60%
0
0.00%
5.
Amount and
proportion of
taxonomy-
aligned economic
0
0.00%
0
0.00%
0
0.00%
235
activity referred
to in Section 4.30
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
6.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.31
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6 above
in the
denominator of
the applicable
KPI
85
1.98%
85
1.98%
0
0.00%
8.
Total applicable
KPI
111
2.57%
111
2.57%
0
0.00%
236
Template 3: Taxonomy-aligned economic activities (numerator)
Based on Turnover
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.26
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.27
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.28
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.29
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
26
43.07%
26
43.07%
0
0.00%
5.
Amount and
proportion of
0
0.00%
0
0.00%
0
0.00%
237
taxonomy-
aligned economic
activity referred
to in Section 4.30
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
6.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.31
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6
above in the
numerator of the
applicable KPI
34
56.93%
34
56.93%
0
0.00%
8.
Total amount
and proportion
of taxonomy-
aligned economic
activities in the
numerator of the
applicable KPI
60
100.00%
60
100.00%
0
0.00%
238
Based on CapEx
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.26
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.27
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.28
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.29
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
26
23.17%
26
23.17%
0
0.00%
5.
Amount and
proportion of
taxonomy-
aligned economic
0
0.00%
0
0.00%
0
0.00%
239
activity referred
to in Section 4.30
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
6.
Amount and
proportion of
taxonomy-
aligned economic
activity referred
to in Section 4.31
of Annexes I and
II to Delegated
Regulation
2021/2139 in the
numerator of the
applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6
above in the
numerator of the
applicable KPI
85
76.83%
85
76.83%
0
0.00%
8.
Total amount
and proportion
of taxonomy-
aligned economic
activities in the
numerator of the
applicable KPI
111
100.00%
111
100.00%
0
0.00%
240
Template 4: Taxonomy-eligible but not taxonomy-aligned economic activities
Based on Turnover
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.26 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.27 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.28 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.29 of
14
0,33%
14
0.33%
0
0.00%
241
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
5.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.30 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
6.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.31 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
eligible but not
taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6 above
in the
denominator of
the applicable
KPI
264
6.11%
263
6.09%
1
0.02%
8.
Total amount and
proportion of
taxonomy eligible
but not
taxonomy-
aligned economic
activities in the
denominator of
the applicable
KPI
278
6.44%
277
6.42%
1
0.02%
242
Based on CapEx
Ro
w
Economic
activities
Amount and proportion (the information is to be presented in monetary amounts and as
percentages)
CCM + CCA
Climate change mitigation
(CCM)
Climate change adaptation
(CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.26 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
2.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.27 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
3.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.28 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
4.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.29 of
4
0.10%
4
0.10%
0
0.00%
243
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
5.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.30 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
6.
Amount and
proportion of
taxonomy-
eligible but not
taxonomy-aligned
economic activity
referred to in
Section 4.31 of
Annexes I and II
to Delegated
Regulation
2021/2139 in the
denominator of
the applicable KPI
0
0.00%
0
0.00%
0
0.00%
7.
Amount and
proportion of
other taxonomy-
eligible but not
taxonomy-
aligned economic
activities not
referred to in
rows 1 to 6 above
in the
denominator of
the applicable
KPI
288
6.66%
287
6.64%
1
0.02%
8.
Total amount and
proportion of
taxonomy eligible
but not
taxonomy-
aligned economic
activities in the
denominator of
the applicable
KPI
292
6.77%
291
6.74%
1
0.02%
244
Template 5: Taxonomy non-eligible economic activities
Based on Turnover
Row
Economic activities
Amount
Percentage
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
629
14.57%
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
629
14.57%
245
Based on CapEx
Row
Economic activities
Amount
Percentage
1.
Amount and proportion of economic activity referred to in row 1 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
2.
Amount and proportion of economic activity referred to in row 2 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
3.
Amount and proportion of economic activity referred to in row 3 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
4.
Amount and proportion of economic activity referred to in row 4 of
Template 1 that is taxonomy non-eligible in accordance with Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
5.
Amount and proportion of economic activity referred to in row 5 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
6.
Amount and proportion of economic activity referred to in row 6 of
Template 1 that is taxonomy-non-eligible in accordance with Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
0
0.00%
7.
Amount and proportion of other taxonomy-non-eligible economic
activities not referred to in rows 1 to 6 above in the denominator of
the applicable KPI
564
13.07%
8.
Total amount and proportion of taxonomy-non-eligible economic
activities in the denominator of the applicable KPI
564
13.07%
III. Independent Auditor’s limited assurance Report on Sustainability
Statement
Deloitte Certified Public
Accountants S.A.
3a Fragkokklisias & Granikou str.
Marousi Athens GR 151-25
Greece
Tel: +30 210 6781 100
www.deloitte.gr
TRANSLATION FROM THE ORIGINAL IN THE GREEK LANGUAGE
Independent Auditor’s Limited Assurance Report on Optima bank S.A.’s Sustainability Statement
INDEPENDENT AUDITOR’S LIMITED ASSURANCE REPORT
To the Shareholders of Optima bank S.A.
We have conducted a limited assurance engagement on the consolidated Sustainability Statement of Optima bank S.A.
(henceforth the “Company”) and its subsidiaries (collectively the “Group”), included in section “Sustainability Statement
2024” of the consolidated Board of Directors’ Annual Report (the “Sustainability Statement”), for the period from
01/01/2024 to 31/12/2024.
Limited assurance conclusion
Based on the procedures we have performed, as described below in the “Scope of Work Performed” paragraph, and
the evidence we have obtained, nothing has come to our attention that causes us to believe that:
• the Sustainability Statement has not been prepared in all material respects, in accordance with Article 154 of
Law 4548/2018, as amended and in force by Law 5164/2024, based on which, Article 29(a) of EU Directive
2013/34 was transposed into Greek legislation,
• the Sustainability Statement does not comply with the European Sustainability Reporting Standards (hereinafter
“ESRS”), in accordance with EU Regulation 2023/2772 of the Commission of 31 July 2023, and EU Directive
2022/2464 of the European Parliament and the Council of 14 December 2022,
• the process carried out by the Group to identify and assess material impacts, risks and opportunities (the
“Process”), as set out in Note “IRO-1 – Description of the processes to identify and assess material impacts, risks
and opportunities” of the Sustainability Statement, does not comply with the “Disclosure Requirement IRO-1-
Description of the process to identify and assess material impacts, risks and opportunities” of ESRS 2 “General
Disclosures”,
• the disclosures included in sections “Disclosures pursuant to Article 8 of EU Regulation 2020/852 (“EU Taxonomy
Regulation”)”, “ANNEX VI - Disclosures Delegated Act” and “ANNEX XII - Complementary Climate Delegated Act””
of the Sustainability Statement, do not comply with Article 8 of EU Regulation 2020/852.
This assurance report does not extend to information in respect of earlier periods.
Basis for conclusion
We conducted a limited assurance engagement in accordance with International Standard on Assurance Engagements
3000 (Revised), “Assurance Engagements Other than Audits or Reviews of Historical Financial Information” (“ISAE
3000”).
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a
reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is
substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been
performed.
Our responsibilities are further described in the “Auditor’s Responsibilities” section of our report.
Professional Ethics and Quality Management
We are independent of the Company, during the whole period of this engagement and we have complied
with the requirements of the International Code of Ethics for Professional Accountants issued by the
International Ethics Standards Board for Accountants (IESBA Code), the ethical and independence
requirements of Law 4449/2017 and EU Regulation 537/2014.
Our audit firm applies the International Standard on Quality Management 1 (ISQM 1), “Quality
Management for firms that perform audits or reviews of financial statements, or other assurance or
related services engagements” and accordingly, maintains a comprehensive system of quality
management, including documented policies and procedures regarding compliance and ethical
requirements, professional standards and applicable legal and regulatory requirements.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Management’s responsibilities regarding the Sustainability Statement
Management of the Company is responsible for designing and implementing a process to identify the
information reported in the Sustainability Statement, in accordance with ESRS, and for disclosing this
Process in Note “IRO-1 – Description of the processes to identify and assess material impacts, risks and
opportunities” of the Sustainability Statement.
This responsibility includes:
• Understanding the context in which the Company’s and the Group’s activities and business
relationships take place and developing an understanding of its affected stakeholders.
• The identification of the actual and potential impacts (both negative and positive) related to
sustainability matters, as well as risks and opportunities that affect, or could reasonably be
expected to affect, the Company’s and the Group’s financial position, financial performance, cash
flows, access to finance or cost of capital over the short, medium, or long-term.
• The assessment of the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds.
• Making assumptions that are reasonable in the circumstances.
Management of the Company is further responsible for the preparation of the Sustainability Statement, in
accordance with Article 154 of Law 4548/2018, as amended and in force by Law 5164/2024, based on
which, Article 29(a)
of EU Directive 2013/34 was transposed into Greek legislation.
In this context, Management’s responsibility includes:
• Compliance of the Sustainability Statement with ESRS.
• Preparing the disclosures in sections “Disclosures pursuant to Article 8 of EU Regulation 2020/852 (“EU
Taxonomy Regulation”), “ANNEX VI - Disclosures Delegated Act” and “ANNEX XII - Complementary Climate
Delegated Act” of the Sustainability Statement, in compliance with Article 8 of EU Regulation 2020/852.
• Designing, implementing and maintaining such internal controls that management determines are necessary
to enable the preparation of the Sustainability Statement is free from material misstatement, whether due to
fraud or error.
• The selection and application of appropriate sustainability reporting methods and making assumptions and
estimates about individual sustainability disclosures that are reasonable in the circumstances.
The Audit Committee of the Company is responsible for overseeing the sustainability reporting process of
the Group.
Inherent limitations in preparing the Sustainability Statement
As discussed in Note “Entity Specific (“ES”)” in the Sustainability Statement, sustainability information for
which the applicable criteria are self-defined, the nature of this sustainability information, and absence of
consistent external standards, allow for different, but acceptable, measurement methodologies to be
adopted which may result in variances between entities. The adopted measurement methodologies may
also impact the comparability of sustainability matters reported by different entities and from year to year
within an entity as methodologies develop.
In reporting forward-looking information in accordance with ESRS, Management of the Company is
required to prepare the forward-looking information based on disclosed assumptions about events that
may occur in the future and possible future actions by the Company and the Group. The actual outcome is
likely to be different since anticipated events frequently do not occur as expected.
As discussed in Note “ESRS E1 Climate Change”, the sustainability information includes, among others,
information based on climate-related scenarios, that is subject to inherent uncertainty regarding the
likelihood, timing or effect of possible future physical and transitional climate-related impacts.
Our work covered the subject matters listed in the section “Scope of Work Performed” for obtaining
limited assurance and is based on the procedures included in the Program, as defined in this section of our
report. Our work does not constitute an audit or review of historical financial information in accordance
with the applicable International Standards on Auditing or International Standards on Review
Engagements, and for this reason, we do not provide any other assurance beyond what is stated in the
section “Scope of Work Performed”.
Auditor’s responsibilities
This limited assurance report has been prepared based on the provisions of Article 154C of Law
4548/2018 and Article 32A of Law 4449/2017.
Our responsibility is to plan and perform the limited assurance engagement to obtain limited assurance
about whether the Sustainability Statement is free from material misstatement, whether due to fraud or
error and to issue a limited assurance report that includes our conclusion. Misstatements can arise from
fraud or error and are
considered material when, individually or in the aggregate, they could reasonably be expected to influence
the economic decisions of users taken on the basis of the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000, we exercise professional judgment
and maintain our professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• Performing risk assessment procedures, including obtaining an understanding of internal controls
relevant to the engagement, to identify risks in the Process applied by the Group to identify the
information reported in the Sustainability Statement does not address the applicable requirements of
the ESRS, but not for the purpose of providing a conclusion on the effectiveness of the Process,
including the outcome of the Process and
• Designing and performing procedures to evaluate whether the Process to identify the information
reported in the Sustainability Statement is consistent with the Company’s description of its Process as
disclosed in Note “IRO-1 – Description of the processes to identify and assess material impacts, risks
and opportunities”.
In addition, we are responsible for:
• Performing risk assessment procedures, including obtaining an understanding of internal control relevant to the
engagement, to identify disclosures where material misstatements are likely to arise, whether due to fraud or
error, but not for the purpose of providing a conclusion on the effectiveness of the Group’s internal controls.
• Designing and performing procedures responsive to disclosures in the consolidated Sustainability
Statement, where material misstatements are likely to arise. The risk of not detecting a material
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve
collusion, forgery, intentional omissions, misrepresentations, or the override of internal controls.
Scope of the Work Performed
Our work involves performing procedures and obtaining audit evidence to form a limited assurance
conclusion and are limited to the procedures listed in the limited assurance program issued by the Hellenic
Accounting and Auditing Supervisory Oversight Board according to its 262/22.01.2025 decision (hereinafter
the “Program”), developed for the purpose of issuing of a limited assurance report on the Group’s
Sustainability Statement.
Our procedures were designed for the purpose of obtaining a limited level of assurance to support our
conclusion but not for obtaining evidence that would be required to provide a reasonable level of assurance.
Athens, 21 March 2025
The Certified Public Accountant
Konstantinos Kakoliris
Reg. No SOEL: 42931
Deloitte Certified Public Accountants S.A.
3a Fragoklissias & Granikou Str.
15125 Marousi
Reg. No SOEL: E120
This document has been prepared by Deloitte Certified Public Accountants Societe Anonyme.
Deloitte Certified Public Accountants Societe Anonyme, a Greek company, registered in Greece with registered number 0001223601000 and its registered office at
Marousi, Attica, 3a Fragkokklisias & Granikou str., 151 25, is one of the Deloitte Central Mediterranean S.r.l. (“DCM”) countries. DCM, a company limited by guarantee
registered in Italy with registered number 09599600963 and its registered office at Via Tortona no. 25, 20144, Milan, Italy is one of the Deloitte NSE LLP geographies.
Deloitte NSE LLP is a UK limited liability partnership and member firm of DTTL, a UK private company limited by guarantee.
DTTL and each of its member firms are legally separate and independent entities. DTTL, Deloitte NSE LLP and Deloitte Central Mediterranean S.r.l. do not provide
services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms.
IV. Independent Auditor's Report
True Translation of the original in the Greek language
INDEPENDENT AUDITOR’S REPORT
To the Shareholders of the banking entity “Optima bank S.A.”
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We have audited the separate and consolidated financial statements of the banking entity “Optima bank S.A.” (the
Bank), which comprise the separate and consolidated statement of financial position as at 31 December 2024, and
the separate and consolidated statements of profit or loss and other comprehensive income, separate and
consolidated statements of changes in equity and separate and consolidated statements of cash flows for the year
then ended and notes to the financial statements, including material accounting policy information.
In our opinion, the accompanying separate and consolidated financial statements present fairly, in all material
respects, the separate and consolidated financial position of Optima bank S.A. and its subsidiaries (the Group) as at
31 December 2024 and its separate and consolidated financial performance and its separate and consolidated cash
flows for the year then ended in accordance with International Financial Reporting Standards (IFRSs), as endorsed by
the European Union.
Basis for Οpinion
We conducted our audit in accordance with International Standards on Auditing (ISAs) as they have been
incorporated into the Greek legislation. Our responsibilities under those standards are further described in the
“Auditor’s Responsibilities for the Audit of the Separate and Consolidated Financial Statements” section of our
report. We have been independent of the Bank and the Group during the whole period of our appointment, in
accordance with the International Ethics Standards Board for Accountants’ Code of Ethics for Professional
Accountants (IESBA Code), as incorporated into the Greek legislation and the ethical requirements in Greece,
relevant to the audit of the separate and consolidated financial statements. We have fulfilled our ethical
requirements in accordance with the applicable legislation and the abovementioned Code of Ethics. We believe that
the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Key Αudit Μatters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of
the separate and consolidated financial statements of the current year. These matters and the assessed risks of
material misstatements were addressed in the context of our audit of the separate and consolidated financial
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these
matters.
Deloitte Certified Public
Accountants S.A.
3a Fragkokklisias & Granikou str.
Marousi Athens GR 151-25
Greece
Tel: +30 210 6781 100
www.deloitte.gr
Key audit matters
How our audit addressed the Key audit matters
Allowance for expected credit losses (ECL) for loans and advances to customers at amortised cost
Loans and advances to customers at amortised cost of the Bank
and the Group amounted to € 3,640,985 thousand and €
3,657,499 thousand respectively as at 31 December 2024 (€
2,443,532 thousand and € 2,458,509 thousand respectively as at
31 December 2023) and allowance for expected credit losses of
the Bank and the Group amounted to € 44,385 thousand and €
44,901 thousand respectively as at 31 December 2024 (€ 27,460
thousand and € 27,595 thousand respectively as at 31 December
2023).
Measurement of expected credit losses on loans and advances to
customers at amortised cost is considered a key audit matter as
the determination of assumptions used involves critical
Management judgments and accounting estimates with inherent
risk, high level of subjectivity, and complexity.
The most significant Management judgements and accounting
estimates, relate to:
• The determination of credit risk parameters, such as Loss Given
Default (LGD), Probability of Default (PD) and the Exposure at
Default (EAD) which were used in the models to estimate the
expected credit losses.
• The criteria used for the staging allocation of loans and at
amortised cost (Significant Increase in Credit Risk – SICR and
Unlikeness to Pay – UTP)
• The forecast of each significant forward-looking information
used by Management in the models for calculation of expected
credit losses and the probability weightings used to estimate the
impact of multiple economic scenarios.
• The identification and measurement of the adjustments
(Management Overlays) made by Management to the estimation
of the expected credit losses models. These adjustments include
inherent uncertainty and significant degree of Management’s
judgment.
Management has provided further information about principles
and accounting policies for determining the ECL on loans and
advances to customers at amortised cost and management of
credit risk in Notes 2.4, 2.4.1, 2.12, 3.A, 4.1 and 20 to the
separate and consolidated financial statements.
Based on our risk assessment and following a risk-based
approach, we have evaluated the impairment
methodologies applied and assumptions made by
Management in relation to this key audit matter, and we
performed, inter alia, the following audit procedures:
• With the support of our financial risk modelling
specialists where appropriate, we assessed the design
and implementation of relevant internal controls over
the ECL estimate including the controls around:
- the significant assumptions used in the ECL models
- model monitoring and model validation
- governance and review of the adjustments
(Management Overlays) made by Management to
the results of the ECL models
- the staging allocation
- the selection of macro-economic scenarios and
probability weightings
• With the support of our financial risk modelling
specialists we:
- assessed the appropriateness of the Bank’s and the
Group’s IFRS9 impairment methodologies.
- assessed the appropriateness of the criteria used to
allocate loans to stages in accordance with IFRS9.
Our work included the evaluation of the criteria set
by Management regarding the identification of
significant increase in credit risk or unlikeliness to
pay. On a sample basis we tested the timely
identification of exposures with significant increase in
credit risk, unlikeliness to pay or other criteria use for
staging.
- we evaluated the appropriateness of the significant
parameters (Loss Given Default – LGD, Probability of
Default – PD and Exposure at Default – EAD) used in
models to estimate the expected credit losses and
we verified on a sample basis the accuracy of the
model calculations for estimating the expected credit
losses. In this context, we examined on a sample
basis the accuracy of the data used in the models,
including the collaterals used in to determine the
Loss Given Default (LGD).
- we examined on a sample basis whether the criteria
used for the timely identification of exposures with a
significant increase in credit risk and the timely
identification of credit impaired exposures have been
properly applied in accordance with the Bank’s
impairment policy of loans and advances to
customers.
- we assessed the reasonableness and appropriateness
of the significant forward-looking information used in
the models by comparing them to those included in
external sources.
Key audit matters
How our audit addressed the Key audit matters
Allowance for expected credit losses (ECL) for loans and advances to customers at amortised cost
- we evaluated the appropriateness of the
adjustments made by Management (Management
Overlays) on the measurement of the expected
credit losses, in order to incorporate the effect of
factors not captured in the models to estimate the
expected credit losses.
Given the complexity and granularity of the related
disclosures, we further assessed their completeness and
accuracy in accordance with the provisions of the
relevant accounting standards.
Key audit matters
How our audit addressed the Key audit matters
Information Technology General Controls and controls over financial reporting
The Bank’s and the Group’s financial reporting processes are
highly dependent on Information Technology (“IT”) systems of
the Bank and the Group supporting automated accounting and
reconciliation procedures, thus leading to a complex IT
environment, pervasive in nature and in which a significant
number of transactions are processed daily, across numerous
locations.
This is a key audit matter since it is important that controls over
general information systems related to access security,
protection against internal and external cyber security threats,
change management to information systems and management of
information technology daily operations, are designed and
operate effectively to ensure complete and accurate financial
records and information.
Based on our risk assessment, we have assessed the
design and implementation of General Information
Technology Controls (GITCs) relevant for financial
reporting. Our assessment included the evaluation of
user access over applications, operating systems and
databases, the process followed over changes made to
information systems, as well as the evaluation of the
management of IT daily operations.
In summary, our key audit activities included, among
others, testing of:
• User access provisioning and de-provisioning
process.
• Privileged access to applications, operating systems
and databases.
• Periodic review of user access rights.
• Change management process over applications,
operating systems and databases (i.e. user request,
user acceptance testing and final approval for
promotion to production).
• Management of IT daily operations.
Other Information
Management is responsible for the other information. The other information, included in the Annual Financial Report
prepared in accordance with Law 3556/2007, comprises the Board of Directors’ Annual Report, referred to in the section
“Report on Other Legal and Regulatory Requirements” and the Statement by the Members of the Board of Directors, but
does not include the separate and consolidated financial statements and our auditor’s report thereon.
Our opinion on the separate and consolidated financial statements does not cover the other information and we will not
express any form of assurance conclusion thereon.
In connection with our audit of the separate and consolidated financial statements, our responsibility is to read the other
information and, in doing so, consider whether the other information is materially inconsistent with the separate and
consolidated financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.
If, based on the work we have performed, we conclude that there is a material misstatement in this other information, we
are required to report that fact. We have nothing to report in this regard.
Responsibilities of Management and Those Charged with Governance for the separate and consolidated financial
statements
Management is responsible for the preparation and fair presentation of the separate and consolidated financial statements
in accordance with IFRSs, as endorsed by the European Union, and for such internal control as Management determines is
necessary to enable the preparation of separate and consolidated financial statements that are free from material
misstatement, whether due to fraud or error.
In preparing the separate and consolidated financial statements, Management is responsible for assessing the Bank’s and
the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the
going concern basis of accounting unless Management either intends to liquidate the Bank and the Group or to cease
operations, or has no realistic alternative but to do so.
The Audit Committee (article 44 of Law 4449/2017) of the Bank is responsible for overseeing the Bank’s and Group’s
financial reporting process.
Auditor’s Responsibilities for the audit of the separate and consolidated financial statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial statements as a
whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes
our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in
accordance with ISAs, as these have been incorporated into Greek legislation, will always detect a material misstatement
when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate,
they could reasonably be expected to influence the economic decisions of users taken on the basis of these separate and
consolidated financial statements.
As part of an audit in accordance with ISAs, as these have been incorporated into Greek legislation, we exercise
professional judgment and maintain professional scepticism throughout the audit.
We also:
• Identify and assess the risks of material misstatement of the separate and consolidated financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion,
forgery, intentional omissions, misrepresentations, or the override of internal control.
• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the
Bank’s and Group’s internal control.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and
related disclosures made by Management.
• Conclude on the appropriateness of Management’s use of the going concern basis of accounting and, based on
the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast
significant doubt on the Bank’s and Group’s ability to continue as a going concern. If we conclude that a material
uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the
separate and consolidated financial statements or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future
events or conditions may cause the Bank and the Group to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the separate and consolidated financial statements,
including the disclosures, and whether the separate and consolidated financial statements represent the
underlying transactions and events in a manner that achieves fair presentation.
• Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial
information of the entities or business units within the Group as a basis for forming an opinion on the separate
and consolidated financial statements. We are responsible for the direction, supervision and review of the audit
work performed for the purposes of the group audit. We remain solely responsible for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of
the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our
audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical
requirements regarding independence, and communicate with them all relationships and other matters that may
reasonably be thought to impair our independence, and where applicable, related safeguards applied.
From the matters communicated with those charged with governance, we determine those matters that were of most
significance in the audit of the separate and consolidated financial statements of the current year and are therefore the key
audit matters.
Report on Other Legal and Regulatory Requirements
1) Board of Directors’ Report
Taking into consideration that Management is responsible for the preparation of the Board of Directors’ Report
which also includes the Corporate Governance Statement, according to the provisions of paragraph 1, sub
paragraphs aa), ab) and b) of article 154G of Law 4548/2018, which however do not include the Sustainability
Report, for which we have issued a related limited assurance report according to International Standard on
Assurance Report 3000 (Revised) dated 21 March 2025, we note the following:
a) The Board of Directors’ report includes the Corporate Governance Statement which provides the
information required by article 152 of Law 4548/2018.
b) In our opinion, the Board of Directors’ report has been prepared in accordance with the applicable legal
requirements of articles 150 and 153 of Law 4548/2018, except for the provisions relating to the
submission of the Sustainability Report of paragraph 5A of article 150 of this Law, and its content is
consistent with the accompanying separate and consolidated financial statements for the year ended 31
December 2024.
c) Based on the knowledge we obtained during our audit of the Bank and the Group and its environment, we
have not identified any material inconsistencies in the Board of Directors’ Report.
2) Additional Report to the Audit Committee
Our audit opinion on the separate and consolidated financial statements is consistent with the additional report to
the Audit Committee of the Bank referred to in Article 11 of the European Union (EU) Regulation 537/2014.
3) Non-audit Services
We have not provided to the Bank and the Group any prohibited non-audit services referred to in Article 5 of EU
Regulation 537/2014.
The allowable non-audit services provided to the Bank and the Group during the year ended 31 December 2024
are disclosed in note 40 to the separate and consolidated financial statements.
4) Appointment
We were appointed as statutory auditors for the first time by the Annual General Assembly of shareholders of the
Bank on 21 July 2021. The year ended 31 December 2024 is the fourth consecutive year that we serve as
statutory auditors, based on the relevant Annual General Assembly.
5) Internal Regulation
The Bank retains an Internal Regulation according to the provisions of article 14 of Law 4706/2020.
6) Assurance Report on European Single Electronic Format Reporting
Subject Matter
We have undertaken the reasonable assurance work to examine the digital archives of the banking entity “Optima
bank S.A.” (hereinafter the Bank or/and the Group), which has been prepared in accordance with the European
Single Electronic Format (ESEF), Including the separate and consolidated financial statements of the Bank and the
Group for the year ended 31 December 2024, in XHTML format, as well as the envisaged XBRL file
(2138008NSD1X1XFUK750-2024-12-31-el.zip) with the appropriate tagging on the above consolidated financial
statements, including the notes to the financial statements(the Subject Matter), in order to conclude whether
they been prepared in accordance with the requirements set out in the section Applicable Criteria.
Applicable Criteria
The Applicable Criteria for the European Single Electronic Format (ESEF) are laid down in European Commission
Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 (the ESEF Regulation) and
2020/C 379/01 European Commission interpretative communication of 10 November 2020, as provide by Law
3556/2007 and the related announcements of the Securities and Exchange Commission and the Athens Stock
Exchange. In summary, these criteria provide, inter alia, that:
• Annual financial reports should be prepared in XHTML format.
• With respect to the consolidated financial statements prepared in accordance with International Financial
Reporting Standards, financial information included in the consolidated Statement of Financial Position,
Income statement, total comprehensive income, statement of changes in equity and statement of cash flows
as well as financial information included in the notes to these financial statements shall be tagged with XBRL
mark-up (“XBRL tags” and “block tags”) in accordance with ESEF Taxonomy, as currently in force. The
technical specifications of ESEF, including the related taxonomy, are included in ESEF Regulatory Technical
Standards.
Responsibilities of the Administration and Those Responsible for Governance
Management is responsible for the preparation and submission of these separate and consolidated financial
statements of the Bank and the Group for the year ended 31 December 2024, in accordance with the Applicable
Criteria, as well as for such internal control as Management determines is necessary to enable the preparation of
digital files free from material misstatement, whether due to fraud or error.
Αuditor’s Responsibilities
Our responsibility is to issue this report in relation to the assessment of the Subject Matter, based on the work
performed, as described below in the section Scope of work performed.
Our work has been conducted in accordance with International Standard on Assurance Engagements 3000
(revised) “Assurance engagements other than audits or review of historical financial information (“ISAE 3000”).
ISAE 3000 requires that we plan and perform our work in order to obtain reasonable assurance to assess the
Subject Matter in accordance with the Applicable Criteria. In the course of the assurance engagement, we assess
the risk of material misstatement in the information relating to the Subject Matter.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our reasonable
assurance opinion, as set out in this report.
Professional Ethics and Quality Management
We have been independent of the Bank and the Group during the whole period of our assignment and have
comply with the requirements of of the Code of Conduct for professional Auditors of the Board of International
standards of Conduct for Auditors (Code of Ethics), the ethical and independence requirements of Law 4449/2017
and Regulation (EU) 537/2014.
Our auditing firm implements the International Quality Management Standard (ISQM) 1 ‘Quality Management for
companies that perform audits or reviews of financial statements or other assurance or related service
assignments’ and therefore maintains an integrated quality management system that includes documented
policies and procedures related to compliance with ethical requirements, professional standards and applicable
legal and regulatory requirements.
Scope of work Performed
The assurance work performed, is limited to the items included in the ESEF Guidelines and has been performed in
accordance with Decision No 214/4/11-02-2022 of the Board of Hellenic Accounting and Auditing Oversight Board
(HAASOB) and the “Guidelines in connection with the procedures and the assurance report of the certified
auditors on the ESEF reported of Issuers with trading securities on a regulated market in Greece” dated
14/02/2022, as issued by the Institute of Certified Public Accountants, in order to obtain reasonable assurance
about whether the separate and consolidated financial statements of the Bank and the Group, prepared by
Management in accordance with ESEF, comply in all material respects with the Applicable Criteria.
Inherent Limitations
Our work covered the items mentioned in the section "Scope of work performed" in order to obtain reasonable
assurance based on the procedures described. In this context, the work performed could not provide an absolute
assurance that all matters that could be considered as material weaknesses are revealed.
Conclusion
On the basis of the work performed and the evidence obtained, we conclude that the separate and consolidated
financial statements of the Bank and the Group, for the year ended 31 December 2024, in XHTML format as well
as the envisaged XBRL file (2138008NSD1X1XFUK750-2024-12-31-el.zip) with the appropriate tagging on these
consolidated financial statements, including the notes, are prepared in all material respects in accordance with the
Applicable Criteria.
Athens, 21 March 2025
The Certified Public Accountant
Apostolos Kokkinellis
SOEL Reg. No. 44621
Deloitte Certified Public Accountants S.A.
Fragoklisias 3a & Granikou Str.
GR 151 25 Marousi
Reg. No. SOEL: E120
This document has been prepared by Deloitte Certified Public Accountants Societe Anonyme.
Deloitte Certified Public Accountants Societe Anonyme, a Greek company, registered in Greece with registered number 0001223601000 and its registered office at
Marousi, Attica, 3a Fragkokklisias & Granikou str., 151 25, is one of the Deloitte Central Mediterranean S.r.l. (“DCM”) countries. DCM, a company limited by guarantee
registered in Italy with registered number 09599600963 and its registered office at Via Tortona no. 25, 20144, Milan, Italy is one of the Deloitte NSE LLP geographies.
Deloitte NSE LLP is a UK limited liability partnership and member firm of DTTL, a UK private company limited by guarantee.
DTTL and each of its member firms are legally separate and independent entities. DTTL, Deloitte NSE LLP and Deloitte Central Mediterranean S.r.l. do not provide
services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms.
V. Financial statements for the year ended December 31, 2024
Financial Statements
for the year
January 1 - December 31, 2024
In accordance with the International Financial Reporting Standards (IFRS)
TABLE OF CONTENTS
CONSOLIDATED STATEMENT OF PROFIT OR LOSS AND OTHER COMPREHENSIVE INCOME ......................... 1
STATEMENT OF PROFIT OR LOSS AND OTHER COMPREHENSIVE INCOME .................................................. 2
CONSOLIDATED STATEMENT OF FINANCIAL POSITION .............................................................................. 3
STATEMENT OF FINANCIAL POSITION ....................................................................................................... 4
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY ............................................................................... 5
STATEMENT OF CHANGES IN EQUITY ........................................................................................................ 6
CONSOLIDATED CASH FLOW STATEMENT ................................................................................................. 7
CASH FLOW STATEMENT .......................................................................................................................... 8
NOTES TO THE FINANCIAL STATEMENTS AS OF 31 DECEMBER 2024 .......................................................... 9
1. General Information ....................................................................................................................... 9
2. Material accounting policies .......................................................................................................... 11
2.1. Basis of preparation ..................................................................................................................... 11
2.1.1. Going concern ............................................................................................................................. 11
2.1.2. Restatement of amounts .............................................................................................................. 13
2.1.3. New standards, amendments to standards and interpretations ....................................................... 13
2.2. Principles of Consolidation and Equity Method................................................................................ 14
2.3. Foreign currency translations ........................................................................................................ 16
2.4. Financial assets and liabilities ........................................................................................................ 17
2.4.1 Financial assets ............................................................................................................................ 18
2.4.2 Financial liabilities ........................................................................................................................ 22
2.5. Repurchase agreements and securities lending .............................................................................. 22
2.6. Own-used property and equipment ............................................................................................... 22
2.7. Intangible assets .......................................................................................................................... 23
2.8. Goodwill ...................................................................................................................................... 23
2.9. Impairment of non-financial assets................................................................................................ 23
2.10. Carbon emission rights ................................................................................................................. 24
2.11. Cash and cash equivalents ............................................................................................................ 24
2.12. Impairment of financial assets ...................................................................................................... 24
2.13. Financial guarantees .................................................................................................................... 33
2.14. Staff benefits ............................................................................................................................... 33
2.15. Provisions .................................................................................................................................... 34
2.16. Offsetting financial instruments ..................................................................................................... 34
2.17. Leases ......................................................................................................................................... 35
2.18. Interest income and expense ........................................................................................................ 36
2.19. Fee and commission income ......................................................................................................... 36
2.20. Gains/(losses) from financial transactions ...................................................................................... 37
2.21. Dividend income .......................................................................................................................... 37
2.22. Income tax and deferred tax......................................................................................................... 37
2.23. Share capital ................................................................................................................................ 38
2.24. Distribution of dividend ................................................................................................................ 38
2.25. Related parties ............................................................................................................................. 38
2.26. Earnings per share ....................................................................................................................... 39
2.27. Non-current assets held for sale and discontinued operations ......................................................... 39
2.28. Derivative financial instruments .................................................................................................... 39
2.29. Rounding ..................................................................................................................................... 40
3. Critical accounting estimates and assumptions for the implementation of the accounting principles ... 40
4. Financial Risk Management ........................................................................................................... 41
4.1. Credit risk .................................................................................................................................... 42
4.2. Market risk .................................................................................................................................. 76
4.3. Liquidity risk ................................................................................................................................ 85
4.4. Capital adequacy.......................................................................................................................... 87
5. Fair value of financial assets and liabilities ..................................................................................... 89
5.1. Financial assets and liabilities not carried at fair value .................................................................... 89
5.2. Fair Value Hierarchy ..................................................................................................................... 89
6. Net interest income ...................................................................................................................... 94
7. Net fee and commission income .................................................................................................... 95
8. Gains/ (losses) from financial transactions ..................................................................................... 96
9. Other operating income ................................................................................................................ 97
10. Staff costs ................................................................................................................................... 97
11. Other operating expenses ............................................................................................................. 98
12. Provision for expected credit losses ............................................................................................... 99
13. Other provisions ........................................................................................................................... 99
14. Income Tax ............................................................................................................................... 100
15. Earnings per share ..................................................................................................................... 101
16. Cash and balances with the central bank ..................................................................................... 102
17. Due from banks ......................................................................................................................... 103
18. Financial assets at fair value through profit and loss ..................................................................... 103
19. Derivative financial instruments .................................................................................................. 104
20. Loans and advances to customers ............................................................................................... 105
21. Financial assets at fair value through other comprehensive income ............................................... 106
22. Debt securities at amortised cost ................................................................................................ 108
23. Investments in subsidiaries and associates .................................................................................. 110
24. Property, plant and equipment .................................................................................................... 112
25. Intangible assets ........................................................................................................................ 113
26. Right of use assets and Lease liabilities ....................................................................................... 114
27. Deferred tax assets .................................................................................................................... 117
28. Other assets .............................................................................................................................. 119
29. Due to banks ............................................................................................................................. 120
30. Due to customers ....................................................................................................................... 120
31. Retirement benefit obligations .................................................................................................... 121
32. Other liabilities ........................................................................................................................... 122
33. Provisions .................................................................................................................................. 123
34. Share capital .............................................................................................................................. 124
35. Other reserves ........................................................................................................................... 124
36. Balance sheet items broken down by expected due date .............................................................. 125
37. Share based payments ............................................................................................................... 127
38. Commitments, contingent liabilities and assets............................................................................. 128
39. Related party transactions .......................................................................................................... 130
40. Auditor’s fees ............................................................................................................................. 133
41. Segment Reporting .................................................................................................................... 133
42. Irrevocable payment commitments to the Single Resolution Board (SRB) ...................................... 134
43. Distribution of dividend .............................................................................................................. 134
44. Disclosures of Law 4261/5.5.2014 ............................................................................................... 135
45. Disclosures of Law 4151/2013 .................................................................................................... 135
46. Events after the reporting period date ......................................................................................... 136
1
GROUP
CONSOLIDATED STATEMENT OF PROFIT OR LOSS AND OTHER COMPREHENSIVE INCOME
Amounts in Eur '000
Note
1/1/2024 -
31/12/2024
1/1/2023 -
31/12/2023
Interest and similar income
6
253,647
173,097
Interest expense and similar charges
6
(63,790)
(30,885)
Net interest income
189,857
142,212
Fee and commission income
7
47,743
38,580
Fee and commission expense
7
(6,411)
(6,461)
Net fee and commission income
41,332
32,119
Dividend income
512
245
Gains/(losses) from financial transactions
8
19,795
16,557
Gains from derecognition of financial assets measured at amortised cost
2,648
812
Other operating income
9
579
1,012
23,534
18,626
Total operating income
254,723
192,957
Staff costs
10
(32,638)
(30,383)
Other operating expenses
11
(16,912)
(19,244)
Depreciation & amortisation
(8,329)
(7,312)
Total operating expenses
(57,879)
(56,939)
Profit before provisions and taxes
196,844
136,018
Provisions for expected credit losses
12
(20,553)
(9,913)
Other provisions
13
0
29
Total provisions
(20,553)
(9,884)
Share of profit/(loss) of associates
349
(190)
Profit before tax
176,640
125,944
Income tax
14
(36,414)
(22,921)
Profit after tax (a)
140,226
103,023
Profits attributable to:
Shareholders of the parent company
140,224
103,021
Non-controlling interests
2
2
140,226
103,023
Other comprenhesive income
Items that may be reclassified subsequently to the income statement
Reserve of debt instruments measured at fair value through other
comprehensive income ("FVTOCI")
1,910
5,025
Deferred tax on reserve from valuation of debt instruments measured at fair value
through other comprehensive income ("FVTOCI")
(420)
(1,106)
Provision for expected credit losses for instruments measured at fair value through
other comprehensive income ("FVTOCI")
(19)
(127)
Total items that may be reclassified subsequently to the income statement
1,471
3,792
Items that will not be reclassified to the income statement
Actuarial losses of defined benefit obligations
31
(152)
(12)
Deferred tax on actuarial losses
34
3
Total items that will not be reclassified to the income statement
(118)
(9)
Other comprehensive income after tax (b)
1,353
3,783
Total comprehensive income after tax (a)+(b)
141,579
106,806
Total comprehensive income attributable to:
Shareholders of the parent company
141,577
106,804
Non-controlling interests
2
2
141,579
106,806
Earnings after tax per share - basic (in €)
15
1.90
1.93
Earnings after tax per share - adjusted (in €)
15
1.90
1.93
The notes on pages 9 to 136 form an integral part of these annual financial statements.
2
BANK
STATEMENT OF PROFIT OR LOSS AND OTHER COMPREHENSIVE INCOME
Amounts in Eur '000
Note
1/1/2024 -
31/12/2024
1/1/2023 -
31/12/2023
Interest and similar income
6
250,793
170,814
Interest expense and similar charges
6
(63,783)
(30,633)
Net interest income
187,010
140,181
Fee and commission income
7
43,004
34,986
Fee and commission expense
7
(6,312)
(6,455)
Net fee and commission income
36,692
28,531
Dividend income
500
245
Gains/(losses) from financial transactions
8
19,669
16,735
Gains from derecognition of financial assets measured at amortised cost
2,648
863
Other operating income
9
695
1,154
23,512
18,997
Total operating income
247,214
187,709
Staff costs
10
(31,281)
(29,361)
Other operating expenses
11
(15,779)
(18,576)
Depreciation & amortisation
(7,852)
(6,907)
Total operating expenses
(54,912)
(54,844)
Profit before provisions and taxes
192,302
132,865
Provisions for expected credit losses
12
(20,172)
(9,711)
Total provisions
(20,172)
(9,711)
Profit before tax
172,130
123,154
Income tax
14
(35,418)
(22,434)
Profit after tax (a)
136,712
100,720
Other comprenhesive income
Items that may be reclassified subsequently to the income statement
Reserve of debt instruments measured at fair value through other
comprehensive income ("FVTOCI")
1,910
5,025
Deferred tax on reserve from valuation of debt instruments measured at fair value
through other comprehensive income ("FVTOCI")
(420)
(1,106)
Provision for expected credit losses for instruments measured at fair value through
other comprehensive income ("FVTOCI")
(19)
(127)
Total items that may be reclassified subsequently to the income statement
1,471
3,792
Items that will not be reclassified to the income statement
Actuarial losses of defined benefit obligations
31
(141)
(12)
Deferred tax on actuarial losses
31
3
Total items that will not be reclassified to the income statement
(110)
(9)
Other comprehensive income after tax (b)
1,361
3,783
Total comprehensive income after tax (a)+(b)
138,073
104,503
Earnings after tax per share - basic (in €)
15
1.85
1.89
Earnings after tax per share - adjusted (in €)
15
1.85
1.89
The notes on pages 9 to 136 form an integral part of these annual financial statements.
3
GROUP
CONSOLIDATED STATEMENT OF FINANCIAL POSITION
Amounts in Eur '000
Note
31/12/2024
31/12/2023
ASSETS
Cash and balances with central bank
16
797,646
479,323
Due from banks
17
171,309
126,090
Financial assets measured at fair value through profit or loss
18
264,442
337,628
Derivative financial instruments
19
2,210
1,033
Loans and advances to customers
20
3,612,598
2,430,914
Financial assets measured at fair value through other comprehensive income
21
47,390
86,488
Debt securities at amortised cost
22
413,844
251,388
Investments in associates
23
609
260
Property, plant and equipment
24
10,717
10,903
Intangible assets
25
11,396
10,805
Right of use assets
26
19,595
19,508
Deferred tax assets
27
9,685
8,079
Other assets
28
179,506
105,850
Total assets
5,540,947
3,868,269
EQUITY AND LIABILITIES
Due to banks
29
115,563
81,079
Due to customers
30
4,643,412
3,191,804
Derivative financial instruments
19
5,318
8,497
Lease liabilities
26
21,220
20,861
Retirement benefit obligations
31
1,027
692
Income tax liabilities
5,573
12,226
Other liabilities
32
124,368
40,667
Provisions
33
4,167
2,366
Total liabilities
4,920,648
3,358,192
Shareholders equity
Share capital
34
254,521
254,245
Share premium
84,114
84,114
Fair value through other comprehensive income reserve
(1,464)
(2,935)
Less: Treasury shares
(112)
(164)
Other reserves
35
31,620
30,146
Retained earnings
251,598
144,651
Total equity attributable to the Company's shareholders
620,277
510,057
Non-controlling interests
22
20
Total equity
620,299
510,077
Total liabilities and equity
5,540,947
3,868,269
The notes on pages 9 to 136 form an integral part of these annual financial statements.
4
BANK
STATEMENT OF FINANCIAL POSITION
Amounts in Eur '000
Note
31/12/2024
31/12/2023
ASSETS
Cash and balances with central bank
16
797,645
479,322
Due from banks
17
160,157
123,625
Financial assets measured at fair value through profit or loss
18
261,626
336,994
Derivative financial instruments
19
2,210
1,033
Loans and advances to customers
20
3,596,600
2,416,072
Financial assets measured at fair value through other comprehensive income
21
47,390
86,488
Debt securities at amortised cost
22
413,844
251,388
Investment in subsidiaries and associates
23
23,972
9,134
Property, plant and equipment
24
10,588
10,738
Intangible assets
25
8,193
7,421
Right of use assets
26
19,561
19,478
Deferred tax assets
27
10,603
8,938
Other assets
28
179,804
104,575
Total assets
5,532,193
3,855,206
EQUITY AND LIABILITIES
Due to banks
29
115,563
79,055
Due to customers
30
4,654,064
3,196,911
Derivative financial instruments
19
5,318
8,497
Lease liabilities
26
21,188
20,834
Retirement benefit obligations
31
964
650
Income tax liabilities
4,961
11,491
Other liabilities
32
122,933
39,082
Provisions
33
4,157
2,356
Total liabilities
4,929,148
3,358,876
Shareholders equity
Share capital
34
254,521
254,245
Share premium
84,114
84,114
Fair value through other comprehensive income reserve
(1,464)
(2,935)
Less: Treasury shares
(112)
(164)
Other reserves
35
30,551
29,249
Retained earnings
235,435
131,821
Total equity
603,045
496,330
Total liabilities and equity
5,532,193
3,855,206
The notes on pages 9 to 136 form an integral part of these annual financial statements.
5
GROUP
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY
Amounts in Eur '000
Note
Share
capital
Share
Premium
Fair value
through other
comprehensive
income reserve
Treasury
shares
Other
reserves
Retained
earnings
Convertible
bond loan
Total
Non-
controlling
interest
Total
Balance as at 1 January 2023
160,279
0
(6,727)
0
19,810
19,573
60,000
252,935
18
252,953
Profit for the year, after income tax
0
0
0
0
0
103,021
0
103,021
2
103,023
Other comprehensive income
Gain from valuation of financial assets measured at
fair value through other comprehensive income
recognised directly in equity
0
0
5,025
0
0
0
0
5,025
0
5,025
Loss transferred directly to equity
0
0
(127)
0
0
0
0
(127)
0
(127)
Minus: related income tax
0
0
(1,106)
0
3
0
0
(1,103)
0
(1,103)
Net actuarial loss recognised directly in equity
31
0
0
0
0
(12)
0
0
(12)
0
(12)
Total comprehensive income (after taxes)
0
0
3,792
0
(9)
103,021
0
106,804
2
106,806
Share capital increase
72,450
78,410
0
0
0
0
0
150,861
0
150,861
Net off of losses carried forward with share capital
(30,476)
0
0
0
0
30,476
0
0
0
0
Expenses relating to share capital increase
0
(7,314)
0
0
0
0
0
(7,314)
0
(7,314)
Deferred tax on share capital increase expenses
0
1,609
0
0
0
0
0
1,609
0
1,609
Conversion of bond loan into share premium
48,592
11,409
0
0
0
0
(60,000)
0
0
0
Retained earnings capitalization
3,400
0
0
0
0
(3,400)
0
0
0
0
Transfer to statutory reserve
0
0
0
0
5,019
(5,019)
0
0
0
0
(Purchases)/sales treasury shares
0
0
0
(164)
0
0
0
(164)
0
(164)
Stock awards to personnel
0
0
0
0
5,326
0
0
5,326
0
5,326
Total transactions with equity shareholders
93,966
84,114
0
(164)
10,345
22,057
(60,000)
150,318
0
150,318
Balance as at 31 December 2023
254,245
84,114
(2,935)
(164)
30,146
144,651
0
510,057
20
510,077
Balance as at 1 January 2024
254,245
84,114
(2,935)
(164)
30,146
144,651
0
510,057
20
510,077
Profit for the year, after income tax
0
0
0
0
0
140,224
0
140,224
2
140,226
Other comprehensive income
Gain from valuation of financial assets measured at
fair value through other comprehensive income
recognised directly in equity
0
0
1,910
0
0
0
0
1,910
0
1,910
Loss transferred directly to equity
0
0
(19)
0
0
0
0
(19)
0
(19)
Minus: related income tax
0
0
(420)
0
34
0
0
(386)
0
(386)
Net actuarial loss recognised directly in equity
31
0
0
0
0
(152)
0
0
(152)
0
(152)
Total comprehensive income (after taxes)
0
0
1,471
0
(118)
140,224
0
141,577
2
141,579
Retained earnings capitalization
276
0
0
0
0
(276)
0
0
0
0
Transfer to statutory reserve
0
0
0
0
6,918
(6,918)
0
0
0
0
Dividend distribution
0
0
0
0
0
(32,461)
0
(32,461)
0
(32,461)
Transfers
0
0
0
(84)
(5,827)
5,911
0
0
0
0
(Purchases)/sales treasury shares
0
0
0
136
0
0
0
136
0
136
Stock awards to personnel
0
0
0
0
501
467
0
968
0
968
Total transactions with equity shareholders
276
0
0
52
1,592
(33,277)
0
(31,357)
0
(31,357)
Balance as at 31 December 2024
254,521
84,114
(1,464)
(112)
31,620
251,598
0
620,277
22
620,299
The notes on pages 9 to 136 form an integral part of these annual financial statements.
6
BANK
STATEMENT OF CHANGES IN EQUITY
Amounts in Eur '000
Note
Share
capital
Share
Premium
Fair value
through other
comprehensive
income reserve
Treasury
shares
Other
reserves
Retained
earnings
Convertible
bond loan
Total
Balance as at 1 January 2023
160,279
0
(6,727)
0
19,027
8,930
60,000
241,508
Profit for the year, after income tax
0
0
0
0
0
100,720
0
100,720
Other comprehensive income
Gain from valuation of financial assets measured at
fair value through other comprehensive income
recognised directly in equity
0
0
5,025
0
0
0
0
5,025
Loss transferred directly to equity
0
0
(127)
0
0
0
0
(127)
Minus: related income tax
0
0
(1,106)
0
3
0
0
(1,103)
Net actuarial loss recognised directly in equity
31
0
0
0
0
(12)
0
0
(12)
Total comprehensive income (after taxes)
0
0
3,792
0
(9)
100,720
0
104,503
Share capital increase
72,450
78,410
0
0
0
0
0
150,860
Net off of losses carried forward with share capital
(30,476)
0
0
0
0
30,476
0
0
Expenses relating to share capital increase
0
(7,314)
0
0
0
0
0
(7,314)
Deferred tax on share capital increase expenses
0
1,609
0
0
0
0
0
1,609
Conversion of bond loan into share premium
48,592
11,409
0
0
0
0
(60,000)
0
Retained earnings capitalization
3,400
0
0
0
0
(3,400)
0
0
Stock awards to personnel
0
0
0
0
5,326
0
0
5,326
Transfer to statutory reserve
0
0
0
0
4,905
(4,905)
0
0
Purchases)/sales treasury shares
0
0
0
(164)
0
0
0
(164)
Total transactions with equity shareholders
93,966
84,114
0
(164)
10,231
22,171
(60,000)
150,318
Balance as at 31 December 2023
254,245
84,114
(2,935)
(164)
29,249
131,821
0
496,330
Balance as at 1 January 2024
254,245
84,114
(2,935)
(164)
29,249
131,821
0
496,330
Profit for the year, after income tax
0
0
0
0
0
136,712
0
136,712
Other comprehensive income
Gain from valuation of financial assets measured at
fair value through other comprehensive income
recognised directly in equity
0
0
1,910
0
0
0
0
1,910
Loss transferred directly to equity
0
0
(19)
0
0
0
0
(19)
Minus: related income tax
0
0
(420)
0
31
0
0
(389)
Net actuarial loss recognised directly in equity
31
0
0
0
0
(141)
0
0
(141)
Total comprehensive income (after taxes)
0
0
1,471
0
(110)
136,712
0
138,073
Retained earnings capitalization
276
0
0
0
0
(276)
0
0
Transfer to statutory reserve
0
0
0
0
6,739
(6,739)
0
0
Dividend distribution
0
0
0
0
0
(32,461)
0
(32,461)
Transfers
0
0
0
(83)
(5,828)
5,911
0
0
(Purchases)/sales treasury shares
0
0
0
135
0
0
0
135
Stock awards to personnel
0
0
0
0
501
467
0
968
Total transactions with equity shareholders
276
0
0
52
1,412
(33,098)
0
(31,358)
Balance as at 31 December 2024
254,521
84,114
(1,464)
(112)
30,551
235,435
0
603,045
The notes on pages 9 to 136 form an integral part
of these annual financial statement
7
GROUP
CONSOLIDATED CASH FLOW STATEMENT
Amounts in Eur '000
Note
1/1/2024 -
31/12/2024
1/1/2023 -
31/12/2023
Cash flows from operating activities
Profit before tax
176,640
125,944
Adjustments for:
Depreciation & amortisation
8,329
7,312
Fair value losses from financial assets measured at fair value
(9,001)
(8,548)
Interest and non-cash expenses
728
751
Dividend income
(512)
(245)
(Gain)/ loss from derivatives valuation
(4,424)
8,835
Share of profit/(loss) of equity method associates
(349)
190
Provision for retirement benefit obligations
31
184
225
Employee benefits & other staff provisions
968
5,326
Provision for expected credit losses
12
20,553
9,913
(Gain)/ loss from sale of assets
184
(574)
(Gain)/loss from carbon emission inventory at fair value
1,023
(5,290)
Income from provisions
13
0
(29)
Foreign exchange differences
(61)
3
(Gains)/losses from sale of financial assets at fair value
(33)
(35)
194,229
143,778
Changes in operating assets and liabilities
Financial assets measured at fair value through profit or loss
84,287
(116,793)
Loans and advances to customers
(1,199,941)
(766,317)
Due from banks
(41)
(5,791)
Other assets
(87,379)
(16,740)
Due to banks
36,508
(7,022)
Due to customers
1,451,608
1,014,596
Other liabilities
60,176
(11,655)
Paid staff compensation
31
0
(96)
Interest paid
(2)
(371)
Net cash flows from operating activities before income tax
539,445
233,589
Income tax paid
(8,918)
(8,653)
Net cash flows from operating activities
530,527
224,936
Investing activities
Acquisition of subsidiaries, associates, joint ventures and other investments
23
0
(1)
Disposal of participation percentage in subsidiaries and associates
2
0
Purchases of investment portfolio securities
(392,930)
(105,411)
Disposal/maturity of investment portfolio securities
252,584
31,300
Interest received from investment portfolio securities
16,407
8,001
Dividends received
512
245
Proceeds from PPE sales
1
1,000
Purchase of PPE
24
(1,766)
(1,486)
Purchase of intangible assets
25
(3,723)
(3,001)
Net cash flow from investing activities
(128,913)
(69,353)
Financing activities
Share capital increase
0
150,861
Share capital increase issue costs
0
(7,314)
Share capital decrease
(162)
0
Purchase of treasury shares
(2,757)
(759)
Proceeds from disposal of treasury shares
2,893
595
Dividend distribution
(32,461)
0
Proceed/(repayments) from loans issued/undertaken
(2,024)
(3,013)
Repayments of lease liabilities (capital and interest)
(3,703)
(3,319)
Net cash flow from financing activities
(38,214)
137,051
Effect of exchange rate changes on cash and cash equivalents
57
(67)
Net increase/(decrease) in cash and cash equivalents
363,457
292,567
Cash and cash equivalents at beginning of the year
16
577,613
285,046
Cash and cash equivalents at the end of the year
941,070
577,613
The notes on pages 9 to 136 form an integral part of these annual financial statements.
8
BANK
CASH FLOW STATEMENT
Amounts in Eur '000
Note
1/1/2024 -
31/12/2024
1/1/2023 -
31/12/2023
Cash flows from operating activities
Profit before tax
172,130
123,154
Adjustments for:
Depreciation & amortisation
7,852
6,907
Fair value losses from financial assets measured at fair value
(8,919)
(10,087)
Interest and non-cash expenses
730
749
Dividend income
(500)
(245)
(Gain)/ loss from derivatives valuation
(4,424)
8,835
Provision for retirement benefit obligations
31
173
207
Employee benefits & other staff provisions
968
5,326
Provision for expected credit losses
12
20,172
9,711
(Gain)/ loss from sale of assets
184
(575)
(Gain)/loss from carbon emission inventory at fair value
1,023
(5,290)
Foreign exchange differences
(57)
0
189,332
138,692
Changes in operating assets and liabilities
Financial assets measured at fair value through profit or loss
84,287
(116,793)
Loans and advances to customers
(1,198,404)
(768,325)
Due from banks
(41)
(5,791)
Other assets
(88,670)
(16,754)
Due to banks
36,508
(7,022)
Due to customers
1,457,152
1,017,331
Other liabilities
60,273
(10,875)
Paid staff compensation
31
0
(84)
Interest paid
0
(366)
Net cash flows from operating activities before income tax
540,437
230,013
Income tax paid
(8,094)
(8,204)
Net cash flows from operating activities
532,343
221,809
Investing activities
Acquisition of subsidiaries, associates, joint ventures and other investments
23
(15,000)
(1)
Disposal of participation percentage in subsidiaries and associates
2
0
Purchases of investment portfolio securities
(389,730)
(104,761)
Disposal/maturity of investment portfolio securities
251,451
31,249
Interest received from investment portfolio securities
16,407
8,001
Dividends received
500
245
Proceeds from PPE sales
1
1,000
Purchase of PPE
24
(1,739)
(1,478)
Purchase of intangible assets
25
(3,508)
(2,832)
Net cash flow from investing activities
(141,616)
(68,577)
Financing activities
Share capital increase
0
150,861
Share capital increase issue costs
0
(7,314)
Purchase of treasury shares
(2,757)
(759)
Proceeds from disposal of treasury shares
2,893
595
Dividend distribution
(32,461)
0
Repayments of lease liabilities (capital and interest)
(3,689)
(3,315)
Net cash flow from financing activities
(36,014)
140,068
Effect of exchange rate changes on cash and cash equivalents
57
(67)
Net increase/(decrease) in cash and cash equivalents
354,770
293,233
Cash and cash equivalents at beginning of the year
16
575,147
281,914
Cash and cash equivalents at the end of the year
929,917
575,147
The notes on pages 9 to 136 form an integral part of these annual financial statements.
9
Notes to the Financial Statements dated December 31, 2024
Group and Bank
NOTES TO THE FINANCIAL STATEMENTS AS OF 31 DECEMBER 2024
1. General Information
Optima Bank S.A. arose from the renaming of INVESTMENT BANK OF GREECE S.A.
The Bank provides a wide range of banking and brokerage services as well as investment banking services. It
operates in accordance with the provisions of Law 4261/2014 and Law 4548/2014, as in force, under the
supervision of the Bank of Greece, while being a member of the Athens Exchange and the Cyprus Stock
Exchange. As of 31/12/2024 it employed 550 persons in total, while its registered office is located in the
Municipality of Maroussi, Attica (32 Aigialeias St.)
The Investment Bank of Greece was established in 2000 and since 2012 its majority shareholder was Cyprus
Popular Bank, the remaining assets of which have been passed to the National Resolution Authority (NRA) of
Cyprus and was under special management.
In 2013, within the context of the plan to rescue the banks of Cyprus, all banking operations of Cyprus Popular
Bank in Greece were transferred to Piraeus Bank, while the Investment Bank of Greece was excluded and
remained an independent banking, investment and financial institution which continued its operation as a Greek
financial institution holding a banking license.
In March 2018, Cyprus Popular Bank hired an advisor and started the procedure to sell the Investment Bank of
Greece by conducting an international tender, such procedure was completed in October 2018 with the
signature of the SPA between the seller (Cyprus Popular Bank) and the buyer (Ireon Investments, a 100%
subsidiary of Motor Oil Hellas Group). The transfer procedure was completed in July 2019, following the receipt
of the relevant approvals of the regulatory authorities. The participation percentage of Ireon Investments
amounted to 97.08%.
Following its acquisition by Ireon Investments, Investment Bank of Greece SA was renamed to Optima Bank
S.A., in August 2019.
On March 26, 2020, the Board of Directors of Motor Oil (Hellas) SA granted a special permission to its subsidiary
IREON INVESTMENTS LTD so that the latter could proceed with a partial disinvestment by selling shares of
“Optima Bank SA”. From September to December 2020, IREON INVESTMENTS LTD transferred in total
2,546,006 shares issued by OPTIMA BANK S.A. to parties related to MOTOR OIL (HELLAS) and third parties.
Following the above transactions and combined with the share capital increase conducted by Optima Bank S.A.,
in accordance with the resolution dated 25.11.2020 of the Extraordinary General Assembly of its Shareholders,
the participation percentage of IREON INVESTMENTS LTD in Optima Bank amounted to 15.77% on 31/12/2020.
On 13/1/2021, MOTOR OIL (HELLAS) S.A. announced that its subsidiary IREON INVESTMENTS LTD transferred
another 61,500 shares issued by Optima Bank SA to individuals related to the company and 25,000 shares to
third parties.
On 15/1/2021, the Bank’s Board of Directors certified the share capital increase by cash of E
UR 80,139,546, which was decided by the extraordinary meeting of the shareholders on 25.11.2020. IREON
INVESTMENTS LTD did not participate in the aforementioned share capital increase.
10
Notes to the Financial Statements dated December 31, 2024
Group and Bank
As a result of the above corporate actions, the participation of IREON INVESTMENTS LTD in Optima Bank was
formed to less than 15%.
In October 2022, the issuance of a convertible bond loan of EUR 60,000,000 was successfully completed.
On 22/3/2023, by decision of the Extraordinary General Assembly, it was decided to list all of the Bank's common
shares on the Regulated Market (Main Market) of the Athens Stock Exchange, in accordance with the provisions
of Law 3371/2005. Furthermore, the decision to list the Bank's shares on the Athens Stock Exchange constituted
an activation event for the conversion of the Convertible Bond Loan issued in October 2022, in accordance with
its terms.
On 4/10/2023, the listing of all the Bank's shares on the Main Market of the Athens Stock Exchange was
completed.
On 11/11/2024, Optima Leasing S.A. was established which is a 100% subsidiary of the Optima Bank Group.
The duration of the Bank is ninety-nine (99) years from its establishment and its purpose, according to its
Articles of Association, is the performance of all banking services permitted by Law for its own or third parties’
account.
Branches operating in Greece:
Α/Α BRANCH ADDRESS 1 PSYCHIKO Olympionikon & 1 El. Venizelou St. - 15451 2 ILIOUPOLI A. Papandreou & 1 Gladstonos St. – 163 45 3 AGHIA PAARASKEVI D. Gounari & 6 Chalandriou St.- 153 43 4 MAROUSSI 46 Thisseos & 2 D.Rali St. - 151 24 5 AMPELOKIPOI 124 Vas. Sofias Ave. - 115 26 6 NEA SMIRNI 55 El. Venizelou St. - 171 23 7 PALAIO FALIRO 4 Ag. Alexandrou St. - 175 61 8 ΚALITHEA 2 Fornezi & El. Venizelou St. - 176 75 9 KALAMARIA – THESSALONIKI 51 Ethnikis Antistasseos St. - 551 34 10 PANEPISTIMOU – ATHENS 15 El.Venizelou St. - 105 64 11 CHALANDRI 1 Kosta Varnali St. - 152 33 12 NIKAIA 232 Petrou Rali St. - 184 53 13 KORINTHOS 21 Ethnikis Antistasseos St. - 201 00 14 ANO PATISSIA 376 Patission St. - 111 41 15 GLYFADA 8-10 Andrea Papandreou - 166 75 16 TSIMISKI-THESSALONIKI 17 I. Tsimiski St. - 546 24 17 KIFISSIA 242 Kifissias Ave. & 1 Panagitsas St. - 145 62 18 PIRAEUS 11 Vas. Georgiou - 185 32 19 MAROUSSI-ANAVRYTA 221 Kifissias Ave.- 151 24 20 NEA IONIA 346 Irakliou Ave - 142 31 21 EVOSMOS - THESSALONIKI 31 28th Oktovriou St. - 562 24 22 PERISTERI 16-20 Panagi Tsaldari St. - 121 34 23 EGALEO 259 Iera Odos & 25th Martiou St. - 122 44
11
Notes to the Financial Statements dated December 31, 2024
Group and Bank
24 PAGRATI 34 – 36 Eftichidou - 116 34 25 KOLONAKI 7 Patriarchou Ioakim & Herodotou - 106 74 26 HRAKLION CRETE 46 25th August - 712 02 27 LARISSA 78 Kyprou & Filellinon - 412 22 28 PATRA 42 Agiou Andreou - 262 21 29 CHANIA Kidonias 67 & Zamvrakakidon – 731 35
The consolidated and standalone financial statements as of 31/12/2024 were approved by the BoD on
20.03.2025 and are subject to the final approval of the General Assembly of the Shareholders, the annual
financial report in accordance with the European Single Electronic Format (“ESEF”) is available on the Group’s
website (www.optimabank.gr).
2. Material accounting policies
2.1. Basis of preparation
The consolidated and standalone financial statements are prepared in accordance with the International
Financial Reporting Standards (IFRS) and the interpretations of the International Financial Reporting
Interpretations Committee (IFRIC), as adopted by the European Union.
The consolidated and standalone financial statements have been prepared on a going concern basis and on a
historical cost basis, except for financial assets measured at fair value through profit or loss or measured at fair
value through other comprehensive income as presented in the consolidated and standalone statement of
financial position and the corresponding disclosures, derivative financial instruments assets and liabilities
The preparation of the financial statements in accordance with the IFRS requires the use of some important
accounting estimates and the judgment of the Management for the implementation of the accounting principles.
The points that pertain to complex transactions and are highly subjective or the affairs and estimates that are
particularly important for the financial statements are presented in note 3.
2.1.1. Going concern
The financial statements of 31/12/2024 were prepared on a going concern basis.
The Board of Directors evaluated the macroeconomic environment, the Group's strategy, its liquidity and capital
position.
Management took into consideration the following:
• The economic growth of the Greek economy during the first 9 months of 2024, the prospects of a
positive growth rate of Gross National Product, which is expected to be above the euro area average,
the inflow of private investment, the gradual disinflation process and the decreasing rate of
unemployment.
• The recovery of the state's credit rating to investment grade status and the restructuring of the banking
sector, which are important developments.
12
Notes to the Financial Statements dated December 31, 2024
Group and Bank
• The Group's diligent liquidity management, as reflected in the Group's Liquidity Coverage Ratio (LCR)
and Net Stable Funding Ratio (NSFR) ratios, which as of 31/12/2024 amounted to 251.4% and 124.8%
respectively, significantly higher than the regulatory limits that have been set (100%).
• The Group's capital adequacy, which exceeds the OCR including Pillar 2 Guidance ("P2G").
• Maintaining a high quality Balance Sheet structure, as reflected by the Non-Performing Loans (NPE)
ratio which amounts to 0.85%, as well as the increase in after-tax profits by 36%.
• The impact of the ongoing crisis in the Middle East and Ukraine (the Group has no exposure to these
countries) and the possible delays in the implementation of the Recovery and Resilience Plan.
Based on the above, the Board of Directors estimates that there are no doubts about the Group's ability to
continue its activities for the period of 12 months from the date of approval of the annual financial
statements and therefore the conditions for the application of the going concern basis of accounting for the
preparation of the financial statements are met.
Greek economy
Greek economy continued to grow at a satisfactory pace in 2024, despite international geopolitical turmoil
and natural disasters, exceeding the growth rate of the euro area. More specifically, GDP continued to
increase in the first nine months of 2024 by 2.3% compared to the corresponding period of 2023. Inflation
declined in December 2024 to 2.7% compared to 3.5% in 2023. The labor market has recorded strong
growth in recent years, resulting in a reduction in the unemployment rate to 11.1% in 2023, while further
de-escalation continued in 2024 with the unemployment rate reaching 10.3% in the first nine months of
2024. According to the Bank of Greece's forecasts, the growth momentum of the Greek economy will
continue in the coming years and will reach growth rates approximately double the eurozone average. The
growth rate of the Greek economy is expected to reach 2.2% in 2024, accelerate to 2.5% in 2025 and
decline slightly to 2.3% in 2026 and 2.0% in 2027. The main driving force of economic activity in the coming
years will continue to be consumption, while investments and exports will continue to contribute positively.
In 2023, Greece's credit rating regained investment grade and this positive attitude of the rating agencies
continued in 2024.The above factors had a positive impact on the prospects of Greek banks and this is
reflected in the strengthening of profitability, liquidity and capital adequacy ratios, as well as in the
improvement of the quality of their loan portfolio.
Liquidity
The Group's deposits on 31/12/2024 amounted to €4.6 billion. showing an increase of 45% from
31/12/2023 and the loan-to-deposit ratio stood at 77.8% from 76.2% on 31/12/2023. At the same time,
the Group has zero borrowings from the ECB, while its highly liquid assets amount to €1.1 billion.
Capital adequacy
As of 31/12/2024, the Group's Common Equity Tier 1 (CET1) and Total Capital Adequacy Ratio (TCR) under
the Basel III framework amounted to 14.40%. At the same time, the Bank's Management is examining the
13
Notes to the Financial Statements dated December 31, 2024
Group and Bank
most appropriate options for strengthening the capital base, so that regulatory capital and regulatory ratios
ensure the smooth implementation of the business plan.
2.1.2. Restatement of amounts
Changes in accounting principles and methods (policies) are accounted for by retrospectively restating the
financial statements of all periods presented with the current period's financial statements so that the amounts
presented to be comparable. In the comparative year ended 2024, no need for reclassification arose.
2.1.3. New standards, amendments to standards and interpretations
The amendments to the applicable standards as of 1/1/2024 are listed below:
‣ Amendment to International Financial Reporting Standard 16 “Leases”: Lease liability in a sale and
leaseback.
Effective for annual periods beginning on or after 1/1/2024.
The above amendment had no impact on the financial statements of the Group and the Bank
‣ Amendment to International Accounting Standard 7: “Statement of Cash Flows” and
International Financial Reporting Standard 7 “Financial Instruments: Disclosures”: Supplier finance
arrangements.
Effective for annual periods beginning on or after 1/1/2024.
The above amendment had no impact on the financial statements of the Group and the Bank.
‣ Amendment to International Accounting Standard 1 “Presentation of Financial Statements”:
Classification of liabilities as current and non-current.
Effective for fiscal years beginning on or after 1/1/2024.
The above amendment had no impact on the financial statements of the Group and the Bank.
‣ Amendment to International Accounting Standard 1 “Presentation of Financial Statements”:
Long-term contingent liabilities.
Effective for annual periods beginning on or after 1/1/2024.
The above amendment had no impact on the financial statements of the Group and the Bank.
Additionally, the International Accounting Standards Board has issued the following standards and amendments
to standards, which have not yet been adopted by the European Union and have not been early applied by the
Group and the Bank.
‣ Amendment to International Accounting Standard 21 “Lack of Exchangeability”: The Effects of
Changes in Foreign Exchange Rates.
Applicable for annual periods beginning on or after 1/1/2025.
The above amendment is not expected to have an impact on the financial statements of the Group and the
Bank.
‣ Amendment to International Financial Reporting Standard 9 and International Financial
Reporting Standard 7 “Classification and Measurement of Financial Instruments”: Classification of
Financial Assets and Financial Liabilities and Settlement Date.
Effective for annual periods beginning on or after 1/1/2026.
14
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The above amendment is not expected to have an impact on the financial statements of the Group and the
Bank.
‣ Amendment to International Financial Reporting Standard 9 and International Financial
Reporting Standard 7 “Contracts referencing nature-dependent electricity”: Under which conditions
can a contract for renewable electricity dependent on the natural environment be defined as a hedging
instrument.
Effective for annual periods beginning on or after 1/1/2026.
The above amendment will be examined to see if it will have an impact on the financial statements of the Group
and the Bank.
‣ New International Financial Reporting Standard 18 “Presentation and Disclosure in Financial
Statements”: Classification of Income and Expenses in Financial Statements.
Effective for annual periods beginning on or after 1/1/2027.
The above amendment is not expected to have an impact on the financial statements of the Group and the
Bank.
‣ New International Financial Reporting Standard 19 “Non-Publicly Accountable Subsidiaries”:
Disclosures of Non-Publicly Accountable Subsidiaries.
Effective for annual periods beginning on or after 1/1/2027.
The above amendment is not expected to have an impact on the financial statements of the Group and the
Bank.
2.2. Principles of Consolidation and Equity Method
(i) Subsidiaries -Consolidation
Subsidiaries are all entities controlled by the Bank (the Group's parent). The Bank controls an entity when it
has power over it, is exposed to or has rights to variable returns from its involvement with the entity and has
the ability to affect those variable returns through its ability to influence the activities of the entity through the
use of its power. Subsidiaries are fully consolidated from the date on which the Bank obtains control over them.
Consolidation ceases from the date on which control ceases.
Intercompany transactions, balances and unrealized gains from transactions between Group companies are
eliminated. Unrealized losses are also eliminated unless the transaction contains indications of impairment of
the transferred asset.
(ii) Acquisition of a Subsidiary
The Group uses the acquisition method for accounting for subsidiaries and their acquisition price consists of:
• the fair value of the assets that are transferred
• the liabilities undertaken by the acquirer from the previous owners
• the equity interest issued by the Group
• the fair value of the assets or liabilities that arise from agreements with contingent consideration, and
15
Notes to the Financial Statements dated December 31, 2024
Group and Bank
• the fair value of any interests in the subsidiary that existed before the acquisition.
The acquired identifiable assets and liabilities and any contingent liabilities assumed in a business combination
are initially recognised, with a few exceptions, at their fair value on the date of acquisition.
Acquisition-related costs are recognised in profit or loss.
The excess of the sum of
• the acquisition price
• the amount recognised as non-controlling interests a
• the fair value of any interest held by the Group in the subsidiary before the acquisition,
over the fair value of the net assets of the subsidiary acquired is recognised as goodwill. If these amounts are
less than the fair value of the net assets of the subsidiary acquired, the difference is recognised directly in profit
or loss as a gain on a bargain purchase.
(iii) Non-controlling interests
On an acquisition basis, the Group recognises any non-controlling interest in the subsidiary either at fair value
or at the value of the non-controlling interest's share as a percentage of the net assets of the subsidiary
acquired. Following the acquisition of control, the measurement of the carrying amount of non-controlling
interests is the amount of such interests at initial recognition and their proportion of changes in equity
subsequently.
(iv) Associates – Equity method
Associates are entities over which the Group has significant influence but not control, either individually or
jointly. This generally applies when the Group holds more than 20% of the voting rights. Investments in
associates are accounted for using the equity method and are initially recognised at cost.
Under the equity method, investments in an associate are initially recognised at cost and are subsequently
increased or decreased to recognise in the income statement the Group's share of the post-acquisition profits
or losses and to recognise in other comprehensive income the Group's share of the changes in the other
comprehensive income of the entity. Dividends received or receivable from associates and joint ventures are
recognised as a reduction in the carrying amount of the investment.
If the Group's share of losses on an investment accounted for using the equity method equals or exceeds the
value of the investment in the business, including any other unsecured long-term receivables, the Group does
not recognize additional losses, unless payments have been made or additional obligations have been assumed
on behalf of the investment.
Unrealized gains on transactions between the Group and associates are eliminated to the extent of the Group's
interest in those entities. Unrealized losses are also eliminated unless the transaction provides evidence of
impairment of the transferred asset. The accounting policies governing investments accounted for using the
equity method have been amended where necessary to align them with those adopted by the Group.
16
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The carrying amount of investments is reviewed for impairment in accordance with the policy described in note
2.9.
(v) Changes in controlling interests
A change in controlling interests results in an adjustment to the carrying amount of the controlling and non-
controlling interests to reflect the relationship of the interests in the subsidiary. Any difference between the
amount by which the non-controlling interests are adjusted and any consideration paid or received is recognised
in a separate reserve account within equity attributable to the owners of the Group.
(vi) Loss of control
The Group ceases to consolidate a subsidiary when it loses control of it either individually or jointly. In the event
of loss of control, the gain or loss on disposal is calculated as the difference between (a) the sum of the fair
value of the consideration and the fair value of the interest retained by the Group and (b) the carrying amount,
before disposal, of the assets (including goodwill), liabilities and non-controlling interests.
Any remaining interest is remeasured to its fair value, with any resulting differences recognised in profit or loss.
The asset is recognised as an associate if the Group has significant influence, a joint venture if there is a joint
arrangement whereby the parties that exercise joint control over the arrangement also have rights to the net
assets of the arrangement, or a financial asset at fair value. In addition, related amounts previously recognised
in other comprehensive income are accounted for in the same way as they would be accounted for if the assets
and liabilities in question were sold. This means that amounts previously recognised in other comprehensive
income may be reclassified to profit or loss.
2.3. Foreign currency translations
(i) Functional and presentation currency
The Group’s items on the financial statements are measured with the currency of the primary economic
environment in which the Group operates (“functional currency”). The financial statements are presented in
Euro, which is the functional currency.
(ii) Transactions and balances
Transactions in foreign currencies are translated to the functional currency at the exchange rate valid on the
dates these transactions were made. Monetary assets and liabilities denominated in foreign currencies are
translated to Euro in accordance with the exchange rate valid on the date the financial statements were
prepared. The exchange differences arising are recognised in the profit or loss. The profits and losses from
exchange differences are recognised on a net basis in the profit or loss, on the line of the gains/(losses) from
financial transactions (note 8).
The exchange differences from assets and liabilities measured at fair value are recognised as part of the fair
value profit or loss.
17
Notes to the Financial Statements dated December 31, 2024
Group and Bank
2.4. Financial assets and liabilities
Methods of measurement
The financial assets measured at amortised cost are:
• Debt securities at amortised cost
• Cash and balances with central bank
• Due from banks
• Loans and advances to customers
• Other receivables included in “Other assets”.
The financial liabilities measured at amortised cost are:
• Due to credit institutions
• Due to central bank
• Due to customers
• Other liabilities included in “Other Liabilities”.
Amortised cost and effective interest rate
The amortised cost is the amount that measures the financial asset or liability at its initial recognition less the
repayments of principal, plus or minus the accumulated depreciation using the effective interest rate method
for, any differences between the said initial amount and the amount at the end and, in the event of financial
assets, readjusted with any provision for impairment losses.
The effective interest rate is the rate that discounts future cash flows through the expected life of the financial
asset or financial liability so that the present value of all future cash flows equals the carrying amount of the
financial instrument, including any transaction costs. When calculating the effective interest rate, expected
credit losses are not taken into account (with the exception of "Purchased or originated as impaired loans and
advances to customers") and all fees paid or received between the parties and forming an integral part of the
effective interest rate, transaction costs and any increase or decrease in the nominal value of the financial asset
are included.
When the Group revises its estimates of future cash flows, the carrying amount of the related financial assets
and liabilities is adjusted to reflect the actual and revised estimated future contractual cash flows using the
original effective interest rate of the financial instrument as the discount rate. The adjustment is recognized in
the income statement as income or expense. In the event of a change in the base interest rate, the effective
interest rate is adjusted accordingly without affecting the results.
Initial recognition
18
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Regular purchases and sales of investments are recognised on the transaction date, which is the date on which
the Group commits to purchase or sell the asset. Loans and receivables from customers are recognised at the
time of disbursement.
At the initial recognition, the Group recognises a financial asset at fair value plus, in the event of a financial
asset not measured at fair value through profit or loss, the cost of the transactions directly attributed to the
acquisition of the financial asset. The transaction costs for the financial assets measured at fair value through
profit or loss are recognised directly in the profit or loss.
Where the fair value of the financial assets and liabilities is different than the transaction price, the Group
recognises the difference as follows:
a) if the fair value is proven by an official market price in an active market for a similar asset or liability (i.e. a
1st level input) or according to a technical assessment using only data from observable market prices, the
difference is recognised as profit or loss in the current year.
b) in all other cases, the difference is transferred and recognised as profit or loss only to the extent that it arises
from the variation of a factor (including time) that the participants in the market would have taken into account
to assess the asset or liability.
2.4.1 Financial assets
(i) Classification and subsequent measurement
The classification of financial assets and their subsequent measurement depend on:
(i) The business model of the Group for their management, and
(ii) The features of their contractual cash flows.
According to the above factors, the Group classifies its financial assets in one of the following three
measurement categories:
• Amortised cost: The financial assets are measured at their amortised cost, if they are held as part of a
business model aiming at holding the financial assets to collect their contractual cash flows and such
contractual cash flows concern solely payments of principal and interest (SPPI). Interest income,
realized profits and losses due to the derecognition and the changes in the expected credit losses from
assets classified at the amortised cost, are included in the profit or loss statement.
• Fair value through other comprehensive income: The financial assets are measured at fair value through
other comprehensive income if they are held as part of a business model aiming at both collecting the
contractual cash flows and at selling financial assets and such contractual cash flows concern solely
payments of principal and interest. After the initial recognition, they are measured at their fair value
through the other comprehensive income, except from their respective interest income, relevant profits
or losses from foreign exchange differences and the expected credit losses, which are recognised in the
profit or loss statement. The accumulated profits or losses previously recognised in the other
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
comprehensive income are transferred to the profit or loss statement when the financial instrument is
derecognised.
• Fair value through profit or loss: Financial assets that do not meet the criteria for classification as
measured at amortised cost or measured at fair value through other comprehensive income are
measured at fair value through profit or loss. Financial assets are mandatorily measured at fair value if
their contractual terms do not give rise to cash flows on specific dates that are solely payments of
principal and interest on the principal outstanding (SPPI Fail). In addition, the Group may designate a
financial asset at initial recognition as measured at fair value through profit or loss if this eliminates or
significantly reduces an accounting mismatch. After initial recognition, gains or losses arising from
changes in fair value are included in the income statement.
Investments in equity instruments
Investments in equity securities concern securities that fall within the definition of participation on the part of
the issuer, i.e. they do not involve any contractual payment obligation and demonstrate a right to the balance
remaining if the issuer's assets are deducted from its liabilities.
The Group measures all equity instruments at fair value upon initial recognition. When the Group irrevocably
elects upon initial recognition to recognise changes in the fair value of equity instruments in other
comprehensive income, any gains/losses from the measurement at fair value of equity instruments in other
comprehensive income are not reclassified to the income statement after the investment is derecognised.
Dividends are recognised in the income statement in other income when the Group establishes the right to
receive the proceeds.
Changes in the fair value of financial assets measured at fair value through profit or loss are recognised in the
income statement under the results of financial transactions.
Note 5 provides information on determining the fair value of financial assets.
Under IFRS 9, separation of an embedded derivative from its host contract is not applicable when the host
contract is a financial asset within the scope of the standard. Instead, the assessment of the classification of
the hybrid financial instrument is made in its entirety.
The Group reclassifies financial assets when, and only when, it changes the business model it applies to manage
those financial assets. The reclassification takes place from the beginning of the first reporting period following
the change. Such changes are not expected to be frequent. The above categories include investments in debt
securities, such as loans, government and corporate bonds.
(ii) Impairment
The Group measures the expected credit losses relevant to the financial assets measured at the amortised
costs, to the investments in debt instruments measured at fair value through comprehensive income, the
financial guarantee contracts and the loan commitments, as well as the irrevocable unutilized credit limits taking
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
into consideration the forecasts for the future economic conditions. The Group recognises a loss allowance for
expected credit losses at each reporting date. The calculation of the expected credit losses reflects:
• an defined and probability-weighted amount determined through the evaluation of a series of possible
outcomes;
• the time value of money, and
• reasonable and sound information available on the reporting date at no unreasonable cost or effort,
pertaining to past events, current conditions and forecasts for the future economic conditions.
The accounting policy of the Group regarding financial assets impairment is disclosed in detail in note 2.12.
(iii) Loan modifications
The Group and the Bank reviewed and updated in the fiscal year the accounting policy regarding the
modification of loan terms with the aim of providing more relevant information on the effects of the specific
transactions on the financial position and financial performance of the Bank and the Group in agreement and
compliance with the practices followed by the banking industry.
The Group and the Bank may modify the loan agreements and consequently, the contractual loan flows either
as a refinancing or loan restructuring of a customer facing or about to face financial difficulties or due to various
other factors such as changes in market conditions or commercial negotiation.
In the above cases, the Group and the Bank initially assess whether the new terms are substantially different
from the original terms of the contract. The new terms in the contractual flows of loans are considered to be
substantially different, in the following cases: change of creditor, change of loan currency, introduction or
removal of convertibility rights or profit sharing mechanisms, aggregation of non-similar contracts, the present
value of the modified contractual cash flows discounted at the original effective interest rate differs by more
than 10% from the carrying amount of the loan before the modification.
The Group and the Bank then consider whether the modification of the contracts is due to changes in market
conditions or for commercial reasons and is generally carried out at the request of the borrower in order to
apply the current market conditions or new commercial reasons to his loan.
The resulting new contract is considered a new transaction and consequently it is necessary to derecognise the
original financial asset (loan) and recognise a new financial asset.
The new financial asset is subject to the classification and measurement requirements specified by IFRS 9 and
is recognised at fair value, while the difference between the carrying amount of the old financial asset and the
fair value of the new one is recognised at income statement as gains or losses arising from the derecognition
of financial assets measured at amortised cost.
In case that the contract is modified due to a refinancing or financing restructuring in which the contractual
cash flows are modified to allow a customer experiencing financial difficulties (current or future) to meet its
payment obligations, and in case that the modification does not take place it was reasonably certain that the
creditor will not be able to meet the payment obligations of the initial contract, then the renegotiation or
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
modification does not result in derecognition of the aforementioned financial asset. The Group and the Bank
consider that the contractual cash flows have not changed materially and recalculate the pre-provisions carrying
amount of the financial asset (loan) based on the new cash flows, recognising in the results gains or losses
from modification of loans contractual terms, adjusting the pre-provisions carrying amount of the financial asset
(loan) after the modification accordingly. The carrying amount before provisions of the financial asset is
recalculated as the present value of the renegotiated or modified contractual cash flows discounted at the initial
effective interest rate (or the credit-adjusted effective interest rate for purchased or originated credit-impaired
financial assets) of the financial asset. Any costs or fees adjust the carrying amount of the modified financial
asset and are amortised over the remaining life of the modified financial asset.
The Group and the Bank in accordance with the requirements of the IAS 8 have adopted this decision
retrospectively as a change in accounting policy. The retrospective application of this accounting policy does
not have a significant effect on the Statement of Financial Position and the Statement of Profit and Loss and
Other Comprehensive Income as of December 31, 2023.
(iv) Derecognition, except the recognition arising from a modification
Except for the above case of loan modification, the Group shall derecognise a financial asset when, and only
when:
a) the contractual rights to the cash flows from the financial asset expire, or
b) transfers the financial asset and such transfer qualifies for derecognition.
When the Group retains the contractual rights to receive the cash flows of a financial asset (the “original asset”),
but assumes a contractual obligation to pay those cash flows to one or more entities (the “eventual recipients”),
the Group handles the transaction as a transfer of a financial asset if, and only if, all of the following three
conditions are met:
a) the Group has no obligation to pay amounts to the eventual recipients unless it collects equivalent amounts
from the original asset.
b) the Group is prohibited by the terms of the transfer contract from selling or pledging the original asset.
c) the Group has an obligation to remit any cash flows it collects on behalf of the eventual recipients without
material delay.
(v) Write offs
The Group writes off financial assets, in whole or in part, when it has exhausted all recovery efforts and
concluded that there is no reasonable expectation of recovery. Write-offs and partial write-offs represent
derecognition or partial derecognition events. The write-off reduces the carrying amount of the claim and the
respective allowance losses. Balances that were written off and recovered at a later stage reduce the amount
of the impairment loss in the income statement.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
2.4.2 Financial liabilities
(i) Classification and subsequent measurement
The financial liabilities of the Group pertain mainly to due to financial institutions and due to customers. The
Group classifies all financial liabilities as subsequently measured at amortised cost, apart from:
• Derivatives (note 2.28)
• Financial guarantee contracts (note 2.13).
(ii) Derecognition
A financial liability is derecognised when it is settled, canceled or expires.
2.5. Repurchase agreements and securities lending
The Group enters into agreements to purchase (sell) securities and resell (repurchase) substantially the same
securities on a certain date in the future, and at a fixed price. The purchased securities subject to a commitment
to resell them in future dates (reverse repos) are not recognised as investments. The amounts paid for such
purchases are recognised in receivables. The receivables are presented in the statement of financial position in
the line “Due from banks” with the title as collateral. Investments sold under repurchase agreements (repos)
continue to be recognised in the statement of financial position, given that the Group essentially continues to
undertake all their risks and benefits and are measured depending on their classification. Proceeds from the
sale of investments under repurchase agreements (repos) are shown as “Due to banks” or “Due to customers”.
The difference between the sale price and the repurchase value is recognized as interest in the line “Interest
and similar expenses” or “Interest and similar income” during the period of the repurchase or resale agreement,
using the effective interest method.
Securities that the Group lends to third parties continue to remain in financial assets and the income arising
from the lending is recognised in the Income Statement.
2.6. Own-used property and equipment
Tangible assets are recognised at acquisition cost less the accumulated amortisation and any impairments. The
acquisition cost includes all expenses directly attributable to the acquisition of the assets.
The amortisation of other categories of tangible assets is calculated in accordance with the straight-line method
to allocate their cost less their residual values during their useful life. The useful life has been defined as follows:
- Machinery and equipment: 5-10 years- Vehicles: 9-10 years
Improvements leased fixed assets are depreciated over the shorter of the useful life of the improvement and
the lease term of the lease.
The residual value and the useful life of a tangible asset shall be reviewed and adjusted, if necessary, at the
end of each reference period.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
The book value of an asset is written-down to its recoverable amount when its book value exceeds its estimated
recoverable amount (note 2.9).
Profits and losses on disposals are defined by comparing the proceeds with the book value and are presented
in the profit or loss.
2.7. Intangible assets
Software
Intangible assets include software and are recognised at acquisition cost less the accumulated amortisations
and any impairments. They are amortised using the straight-line method throughout their useful life ranging
from 1 to 5 years.
Other intangible assets
Intangible assets arising from the allocation of the purchase price (consideration) on the acquisition of
companies or which are individually acquired.
Such intangible assets are amortised over their useful lives when there is a defined useful life (e.g. a customer
base), which is set between 10 and 15 years.
When intangible assets do not have a defined useful life (e.g. a trademark), such assets are not subject to
amortisation.
All intangible assets are tested for impairment whenever there is an indication of impairment.
The Group does not calculate residual value for intangible assets. If an intangible asset is sold, it is derecognised,
while when no economic benefits are expected to flow to the Group, the asset is fully impaired. On disposal of
an intangible asset, the difference between the selling price and its carrying amount is recognised in profit or
loss.
2.8. Goodwill
Goodwill represents the difference between the total consideration paid plus the value of any non-controlling
interest and the fair value of the assets and liabilities of the acquired companies, as at the acquisition date.
Positive goodwill, resulting from acquisitions of companies, is recognised in the Balance Sheet account
"Goodwill", when it comes to the acquisition of a company that constitutes a subsidiary, and is examined for
any impairment of their value at each reporting date. When it comes to investment in associates or joint
ventures, goodwill is recognised in the Balance Sheet account "Investments in associates".
Negative goodwill is recognised as income in the profit or loss.
2.9. Impairment of non-financial assets
Amortised fixed assets are assessed for impairment when events or changes in conditions suggest that their
book value may not be recoverable. Where the book value of an asset exceeds its recoverable amount, its
relevant impairment loss is recognised on profit or loss. Recoverable amount is the higher of the fair value less
the selling expenses and its value in use. To define the impairment, the assets are classified to the lowest level
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
where the cash flows may be individually defined (cash generating units). Impairments recognised in previous
periods as non-financial assets are examined at each reporting date for any reversal.
2.10. Carbon emission rights
The Group acts as a broker – dealer with regards to carbon emission rights and as such these rights are
accounted for as inventories under IAS 2.
Carbon emission rights are classified in “Other assets” in the statement of financial position. The Group initially
recognises such rights at fair value and subsequently measures them at fair value less cost to sell. Any changes
in fair value less cost to sell are charged in the statement of profit or loss during the financial period that the
changes occur.
Carbon emission rights are derecognised from the statement of financial position upon disposal.
2.11. Cash and cash equivalents
Cash and cash equivalents include deposits in the central bank and due to bank balances with original maturities
of less than three months from the date of acquisition, which are readily convertible to cash and which are
subject to an insignificant risk of changes in value. Cash and cash equivalents are stated at amortised cost.
2.12. Impairment of financial assets
Expected credit losses for “Loans and advances to customers” and “Due from banks” are recognized using a
three-stage approach based on the increase in the credit risk of the customer and in relation to the initial
recognition of the financial asset and are summarized as follows:
• A financial asset that does not show a significant increase in risk and is not impaired was purchased
or originated while impaired is classified in “Stage 1”
• A financial asset that was purchased impaired or was already credit-impaired on its initial recognition is
classified in the “POCI – purchased or originated credit-impaired stage” and the expected credit losses
are measured throughout life the lifetime of the asset.
• If there is a significant increase in credit risk at the reporting date after the initial recognition of the
financial asset, it is classified in “Stage 2”.
• If the financial asset is non performing, then it is transferred to “Stage 3”;
• For the “Stage 1” financial assets, the expected credit losses are measured throughout the lifetime of
the assets, which losses arise from default events that may occur during the next 12 months after the
reporting date.
• For the “Stage 2” financial assets, the expected credit losses are measured throughout the lifetime of
the assets, which losses arise from default events that may occur throughout the lifetime of the assets.
• For the “Stage 3” financial assets, the expected credit losses are measured throughout the lifetime of
the assets.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
• The fundamental principle for calculating the expected credit losses in accordance with IFRS 9 is the
measurement taking into consideration information about reasonable and valid forecasts for future
events and macroeconomic conditions.
The basic estimates adopted by the Group regarding the implementation of the Standard’s requirements are
presented below:
A) Significant increase in credit risk
Loans and advances to customers
A key element in the classification of a financial exposure at “Stage 1” is the assessment of whether there has
been a significant increase in credit risk (SICR) since its initial recognition under IFRS. 9. In the event of a
significant increase in credit risk, the Group classifies the financial exposure in “Stage 2” in order to recognise
expected credit losses for its entire lifetime (Lifetime ECL).
Specifically, the objective of impairment requirements is to recognise expected credit losses throughout the life
of financial exposures in which there has been a significant increase in credit risk since initial recognition. This
is considered regardless of whether the assessment is carried out on an individual or collective basis, always
considering all available and supporting information, including information on future economic developments.
The determination of the SICR is based on qualitative and quantitative criteria depending on the availability and
quality of information.
In order to classify the financial exposures into stages, the Group assesses the increase in credit risk (SICR) as
defined by the change in the probability of default of the financial exposures and the deterioration of their credit
rating (rating) on the reporting date compared to the date of initial recognition.
Cases that indicate the existence of SICR for the Group are the following:
• Financial exposures in which amounts are more than 30 days past due.
• Exposures are considered forborne exposures when concessions are granted to a borrower who faces
or is about to face financial difficulties in fulfilling his contractual obligations. These concessions are
characterized as a significant increase in credit risk, and since the financial exposure is classified as
Forborne Performing Exposure (FPE) it is allocated to “Stage 2”.
• The significant deterioration of a creditor in the Group’s financial exposure assessment model is used
as an indication of a significant increase in credit risk. In order to determine whether an exposure
presents SICR for corporate loans, the Bank considers whether this assessment implies a real
deterioration in the credit quality of the exposure. To perform the assessment, the Group and the Bank
compare the default risk at the reporting date with the corresponding risk at the date of initial
recognition. The significant increase in the probability of default is determined by moving to the risk
zones of the table in section 4.1.
• Special case of assessment in the business portfolio: For customers whose total exposure (on and off
balance sheet) exceeds €1 million, the Bank may individually review their transactional behavior and
26
Notes to the Financial Statements dated December 31, 2024
Group and Bank
their latest available financial data for these exposures. If the Bank determines that, according to their
latest available financial data, they deviate significantly (positive or negative) from their current credit
rating and the customers appear as non-delinquent in the bank’s systems (pre-delinquency stage 0-30
days, no indication of adjustment – Forborne), then the Bank may assess the existence or not of SICR
without taking into account the risk level of the loan according to the applicable rating scale (ICAP).
The decision following the recommendation of the competent business unit is approved by the
corresponding credit scale/committee of the Bank.
Securities
A key element in the classification of a security at a stage is the assessment of whether there has been a
Significant Increase in Credit Risk (SICR) compared to its initial recognition. At each reporting date the Group
assesses whether there has been a significant increase in credit risk since the initial recognition of a security,
taking into account reasonable and reliable information concerning past events, current conditions and forecasts
of future economic conditions.
In assessing the credit risk of securities, the Group relies on the credit rating scale of the credit rating
agencies/institutions or on the internal credit rating of the issuer/counterparty if the securities are corporate
debt securities of companies for which the Group has granted loans. In addition, at each reporting period the
Group uses the same external credit rating agencies to ensure that the securities are rated using the same
criteria as they were rated at initial recognition.
The credit rating scales of the External Credit Assessment Institutions (hereinafter "ECAI"), namely Fitch,
Moody's, S&P and ICAP used are listed in the Table below.
Investment Moody’s S&P Global Fitch ICAP type Aaa – Baa3 AAA – BBB- AAA – BBB- AAA – BBB Investment Grade Ba1 – Caa3 BB+ – CCC- BB+ – CCC- BB - CC Non - Investment Grade Ca, C CC – D CC – D C - D Default
Table: Investment grade rating of the securities according to External Credit Assessment Institutions
There are cases of securities that are unrated instruments by an ECAI. If there is no credit rating for corporate
security, the Group assigns to it the credit rating of the issuing company or the industry to which the issuing
company belongs or the country where the issuing company is domiciled and operates (if available). In the case
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
of sovereign debt securities, the country’s rating shall also be assigned to security. The Group makes use of
these ratings in the following order of priority:
• Credit rating of the security (if available);
• Credit rating of the issuer (if available), and
• Credit rating of the financial sector of activity or the country of origin of the issuer.
If the corporate securities are not rated by an ECAI, but the issuer is a borrower of the Group, then the securities
will be classified at the same level as the issuer's loan products.
If none of the above conditions is met, in which case the securities are considered to be unrated, the Group
shall based on the internal rating of the securities. In particular, the Group compares the characteristics of the
unrated securities (e.g. coupon rate, yield to maturity) with similar rated securities held by the Group to
determine its credit quality.
Therefore, the information that the Group assesses to determine whether the credit risk has significantly
increased is presented in the following non-exhaustive list:
• The downgrade of the credit rating of the issuer/counterparty or the security at the reporting date
compared to the credit rating at the date of initial recognition;
• the increase in the probability of default of the issuer/counterparty at the reporting date compared to the
relevant probability of default at the date of initial recognition;
• the change in the credit spread of the security at the reporting date compared to the date of initial
recognition.
More specifically, the Group recognises a significant increase in credit risk (SICR), and classifies the security at
Stage 2 (Lifetime ECL), in the following circumstances:
• Debt securities for which their assessment on the reporting date has been downgraded by two notches
(or more) in relation to their initial assessment according to the ECAI credit rating and do not fall under
the following case.
Regarding the securities that maintain a high credit rating (remain in investment grade / Investment Grade in
the table above) or their probability of default remains low (less than or equal to 3%), the Group considers that
there is no significant increase in credit risk.
• Securities for which the Probability of Default (PD) at the reporting date has a percentage increase of at
least 50% in relation to the Probability of Default at initial recognition.
• Securities for which the credit spread has increased by more than 5% in absolute value at the reporting
date compared to the date of initial recognition.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
B) Definition of default and perimeter of credit-impaired financial assets
Loans and advances to customers
According to the Credit Policy, the Bank's Provision Policy and the New Definition of Default Policy of the Loan
Portfolio, a loan is considered impaired and classified at "Stage 3", when it is characterized as non-performing–
- in a state of default (Non-Performing Exposure - NPE).
Definition of Default
A debtor or a financial exposure is in 'default' if at least one of the following conditions applies:
➢ The debtor or a financial exposure is more than 90 days in material arrears in the payment of any material
obligation to the Group.
➢ The Group considers that the debtor or a financial exposure meets the Unlikely to Pay (UtP) and that it is
unlikely to meet its obligation to the Group in full, without the Group resorting to actions such as the
enforcement of collateral.
➢ The Group has classified the debtor's loan as Forborne Non-Performing Exposure.
The Group's basic principle regarding the application of the definition of default is to apply at the debtor level
(one obligor) for Corporate Banking products, while for Retail Banking products the definition of default is
applied at loan product level.
Materiality thresholds
The materiality thresholds determine whether a financial exposure in arrears will be considered to be a default
or not. Materiality thresholds apply at the financial exposure level for retail banking customers and at the debtor
level for corporate banking customers.
The materiality thresholds for retail portfolio are presented in the table below:
Absolute criterion Relative criterion The total on-balance sheet default balance of the The absolute amount in default must exceed EUR account must exceed 1% of the total on-balance 100. sheet balance.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
The materiality thresholds for the corporate portfolio are presented in the following table:
Absolute criterion Relative criterion The total on-balance default balance of the debtor The absolute amount in default must exceed EUR must exceed 1% of the total on-balance sheet 500. balance.
In this case, when the above relative and absolute criteria are simultaneously met, all on and off balance sheet
financial exposures of the corporate debtor are considered in default.
In addition, where the Group has on balance sheet financial exposures in default to a retail customer whose
gross carrying amount represents more than 20% of the gross carrying amount of all on-balance sheet financial
exposures to that customer, all on and off balance sheet financial exposures to that customer are considered
to be in default. This means that if the above threshold is met, then default status is extended to the debtor
level for all financial exposures to the retail debtor.
Securities
A security is considered to be in 'default' if at least one of the following conditions applies:
• Payments on the security are more than 14 days overdue (relates to Best Practices) against the Group.
• The Group considers that the creditor or the security meets the Unlikely To Pay (UTP) criteria and it is
unlikely to fully perform its credit obligation to the Group unless the Group resorts to measures such as
liquidation of the collateral.
• The rating of the quality of the security by a certified External Credit Rating Institution, if available,
corresponds to a non-investment grade default according to the table below of note 2.12(A). Note that
if an external rating is not available, the internal rating is used, based on the Bank's internal data.
C) Reclassification of stages
Loans and advances to customers
The stage reclassification is applied when the criteria of the initial classification of the loan no longer exist, and
the relevant probation period has successfully passed. The probation period is defined as the period in which
the loan is not overdue for more than 30 days.
In case the credit risk of an exposure improves then it can be moved from “Stage 2” to “Stage 1”. Movements
from “Stage 3” to “Stage 2” are rare and strong documentation needed, as the (below) expectation of successful
completion of the monitoring period is not fully met. Both cases have positive effects on the Group's overall
forecasts.
According to the IFRS 9, we have the following criteria for the reclassification of stages:
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
• For the transition from “Stage 2” to “Stage 1”, of credit exposures which are characterized as "Forborne
Performing Exposures (FPEs)”, the successful completion of a twenty-four (24) month probation period
is required.
• For the transition from “Stage 3” to “Stage 2”, of credit exposures which are characterized as Non-
Performing Exposures (NPEs), the successful completion (with no delinquency) of a three (3) month
probation period is required.
• For the transition from “Stage 3” to “Stage 2”, of credit exposures which are characterized as Forborne
Non-Performing Exposures (FNPEs), the successful completion (with no delinquency) of a twelve (12)
month probation period is required.
Securities
The stage reclassification is applied when the criteria of the initial classification of the security no longer exist.
Stage reclassification in the case of securities depends on the downgrade or upgrade based on its rating, by
the ECAIs.
In cases where the credit quality of a security deteriorates significantly (SICR), the security is reclassified to a
lower credit rating stage, negatively affecting the Group's total provisions. Therefore, security can be
downgraded from "Stage 1" to "Stage 2" when it is downgraded by two notches or from "Stage 2" to "Stage 3"
if it is rated at a level equivalent to default. Both cases have negative implications and increase the Group's
total provisions.
In case the credit risk of a security improves then it can move from “Stage 2” to “Stage 1”. Movements from
“Stage 3” to “Stage 2” or “Stage 1” are rare.
D) Measurement of the expected credit losses
The expected credit losses are measured either based on the likelihood that the default event will occur within
the next 12 months, or throughout the lifetime of the financial asset, depending on whether a significant
increase of the credit risk has occurred and on whether the items are considered as credit-impaired. The
expected credit losses are defined as the discounted product of the probability of default (PD), the exposure at
default (EAD) and the loss given default (LGD).
• Probability of Default (“PD”) represents the probability of default (as defined above) of the obligor's
obligation estimated based on prevailing economic conditions at the reporting date, adjusted to the
estimates of future economic conditions that may affect the risk of default, in a given time horizon.
• Exposure at default (“EAD”) is an estimate of exposure at a future date of default, taking into account
expected changes in the exposure after the reference date, including repayments of principal and
interest and expected disbursements of loan commitments. Exposure at default (“EAD”) includes both
on and off balance sheet exposures. The on balance sheet report corresponds to the total amount
committed and payable, which includes the principal owed, accrued interest and past due amounts. Off
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
balance sheet exposure represents credit available for drawdown in addition to on balance sheet
exposure.
• The loss given default (“LGD”) expresses the extent of the loss that the Group expects for exposures
that are in default and is defined as the difference between the contractual cash flows and those that
the Group expects to collect including amounts from the liquidation of collateral. LGD, which is usually
expressed as a percentage of Exposure at default (“EAD”), varies according to the type of counterparty,
the type and priority of the claim, the existence of collateral and other credit enhancements.
The Bank, in accordance with the Provision Policy and the methodology for calculating the expected loss based
on IFRS 9, evaluates and calculates the expected loss individually per credit exposure.
E) Determination of macroeconomic variables, scenarios and probability-weights (forward looking
information)
Analysis of elements in the expected credit loss model under multiple economic scenarios
The Bank uses the data provided by Moody's Analytics as a source for the evolution of macroeconomic variables,
such as GDP, the main market index of the Athens Stock Exchange (ASE), and unemployment that will affect
the amount of expected credit losses (ECL) of the loan portfolios under multiple economic scenarios. The
Management, when calculating the expected credit losses (ECL), calculates three (3) different scenarios
(Favorable – Base –Unfavorable), each of which is associated with different probabilities of default (PDs) and
different losses in case of default (LGDs). Management has assigned the following weightings to each scenario:
Base 40%, Favorable 30% and Unfavorable 30%.
The key parameter is the change per quarter of GDP and per annual scenario for the next 3 years presented in
the table below.
Base Favorable Unfavorable scenario scenario scenario % annual change 2024 2.6% 2.6% 2.6%* 2025 1.8% 4.2% -4.0% 2026 1.8% 1.5% 2.4% 2027 2.2% 2.0% 4.0%
* The time series are based on historical data of the Greek Economy and the forecast scenarios of Moody's Analytics start from the first
quarter of 2025, which is why there is no difference in the calculation basis of the three scenarios.
Multiple economic scenarios for calculating expected credit losses
Management assessed the sensitivity of the Group's impairment forecast for loans and advances to customers
at amortised cost to reasonably possible changes in the growth rate of Greece's GDP, compared to the forward-
looking scenarios used in the measurement of expected credit losses at 31 December 2024. The sensitivity
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
analysis was performed using alternative scenarios in the business portfolio which mainly affect the probability
of default (PD) parameter.
The following table includes the impact of expected credit losses as of 31 December 2024, for each alternative
hypothetical scenario. The impact per scenario is a comparison of the result of the Group's expected credit
losses against a calculation by replacing the base scenario with the alternative base in the calculation of the
weighted amount used by the Group while maintaining the same factors (40% -alternative base, 30% -
favorable / unfavorable to existing calculations).
GDP deviation from the Impact on ECL base scenario, % Stage 1 Stage 2 Stage 3 Α) Alternative Favorable scenario as base +1.1% -3.16% -1.03% -0.02% Β) Alternative Unfavorable scenario as base -2.0% 6.45% 1.35% 0.02%
The effect of the above scenarios on the expected credit losses by replacing the corresponding scenarios from
the alternatives in the basic calculations is for (A) decrease EUR 690 thousand and for (B) increase EUR 1,895
thousand.
Effect of LGD on expected credit loss calculation
Scenarios of a change in the LGD parameter by +/- 5% were performed in all the Bank's portfolios. The results
are:
LGD LGD Change in change by Change in ECL Total ECL change by Total ECL ECL +5% -5% Retail banking +25.75% +125 610 -14.61% -71 414 Corporate banking +8.86% +3,636 44,679 -7.35% -3,018 38,025
F) Criteria for grouping exposures based on common credit risk characteristics
For assessing impairment on a collective basis, loans are grouped according to similar credit risk characteristics
in sub-portfolios which have the greatest possible homogeneity and uniformity. The main parameters used in
the process of segmenting the portfolio and inclusion in the individual sub-portfolios are the following:
• loan product (retail banking)
• service status of the loan and
• loan classification as forborne.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
In order to determine the impairment provision of each sub-portfolio, not only its particular elements, but also
the effect on their final formation, of the main macroeconomic parameters are quantified. The recognised
impairment provision or reversal of provision is recorded in the profit or loss.
G) Management overlays
Adjustment of the results of the credit risk models used by the Group to measure expected credit losses (Post
Model Adjustments - PMA).
The Group's approach to estimating the expected credit loss measurement of Loans and advances to customers
for 2024 included qualitative and quantitative adjustments to the result produced by the credit risk models. The
Group implements an internal governance and framework for early recognition of any required adjustments as
well as supporting the implementation of these adjustments and the related calculation. The Group's governance
framework requires that such adjustments be adequately documented and approved by the Provisions
Committee.
2.13. Financial guarantees
Financial guarantees are contracts under which the issuer undertakes to compensate the holder of the contract
for a loss that he suffers, in the event that a specific debtor fails to fulfill his obligations in accordance with the
terms of a debt instrument.
Financial guarantees are recognised as financial liabilities initially at fair value. After the initial recognition, the
financial guarantees are measured at the highest value between:
(i) The amount of the provision for impairment according to the model of the expected credit losses
of IFRS 9, and
(ii) The value initially recognised less the accumulated amount of the commission recognised as income
according to IFRS 15, if any.
The liabilities arising from financial guarantee contracts are presented in the item “Other liabilities”.
2.14. Staff benefits
(i) Short-term staff benefits
Liabilities for wages and salaries that are to be fully settled within 12 months from the end of the period when
the employees provide the relevant service are recognised for the services of the employees until the end of
the reporting period and are measured at the amounts that are expected to be paid during the settlement of
the liabilities. The liabilities are presented in “other liabilities” of the statement of financial position.
(ii) Post-employment liabilities
The Group’s liabilities for post-employment pertain to both defined contribution plans and defined benefit plans.
The liability recognised in the statement of financial position for defined benefit plans is the present value of
the liability for the defined benefit at the reporting date. The defined benefit liability is calculated annually by
an independent actuary using the projected unit credit method.
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Notes to the Financial Statements dated December 31, 2024
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The present value of the defined benefit liability is calculated by discounting the estimated future cash outflows
using as discount rate interest rates of high ranking corporate bonds in the same currency and with the same
term to maturity as those of the liability.
The financial cost is calculated by applying the discount rate on the balance of the defined benefits liability. This
cost is included in the employee benefits of the profit and loss statement.
Gains or losses arising from empirical adjustments and changes in actuarial assumptions are recognised over
the period in which they arise, directly to the other comprehensive income. Are included in the other reserves
of the statement of changes in equity and the statement of financial position.
The changes in the present value of the defined benefit liability that arise from modifications or cuts of the plan
are recognised right away in the profit or loss, as past service cost.
Regarding defined contribution plans, the Group pays contributions to public or private pension insurance plans
on a mandatory, contractual or optional basis. Apart from the payment of contributions, the Group has no
further obligations. Contributions are recognised as staff costs when they become payable. Contributions that
are paid in advance are recognised as an asset if there is a possibility of returning the money or offsetting it
with future payments.
(iii) Employment termination benefits
The employment termination benefits become payable when the Group terminates employment before the
regular retirement date or when the employee accepts the voluntary termination of service against such
benefits. The Group recognises these benefits on the earlier of the following dates: a) when the Group cannot
recall the offer of the benefits anymore, and b) when the Group recognises a restructuring cost falling within
the scope of application of IAS 37 and includes the payment of the employment termination benefits. In the
event of an offer made to boost voluntary termination of service, the termination benefits are calculated on the
basis of the number of employees who are expected to accept the said offer. Any employment termination
benefits that will become payable 12 months after the end of the reporting period are discounted at their
present value.
(iv) Benefits in equity securities
Group employees may receive compensation in the form of equity securities through the provision of stock
awards or stock options. The total cost of these benefits is recognised as personnel expense in the reporting
period from the grant date to the maturity date of the relevant rights with a simultaneous increase in equity
and specifically in other reserves.
2.15. Provisions
Provisions are recognised when a present legal or constructive obligation exists as a result of past events, an
outflow of resources to settle the obligation is probable and the amount can be reliably estimated.
2.16. Offsetting financial instruments
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
Financial assets and financial liabilities are set off and the net amount is reported in the statement of financial
position only when there is a legal right to set off the recognised amounts and there is an intention to either
settle the net amount arising from the offset or to simultaneously settle the total amount of both the financial
asset and the liability.
2.17. Leases
The Group as Lessee
The agreements of the Group pertain to building and offices rentals, as well as to long-term leasing of vehicles
and machinery.
The assets and liabilities that arise from the lease are initially recognised at present value. The lease liabilities
include the net present value of the following rents:
• fixed rents (including the “essentially” fixed payments);
• variable rents that depend on a ratio or interest rate, which are initially measured using the ratio
or the interest rate on the commencement date of the lease term;
• amounts expected to be paid on the basis of guaranteed residual values;
• price at which the right to buy is exercised, if it is rather certain that the Group will exercise such
right, and
• payment of a penalty for termination of the lease, if the term of the lease reflects the exercise of
the Group’s right to terminate the lease.
The measurement of the lease liability includes also the payment of rents during the lease extension period, if
it is rather certain that the Group will exercise the right to extend.
Rent payments are discounted at the deemed interest rate of the rental or in the event that such interest rate
cannot be defined in the contract, at the lessee’s incremental borrowing rate, i.e. the rate the lessee would
have paid to borrow the necessary funds in order to acquire a asset of similar value with that of the leased
asset over a similar period of time, with similar collaterals and in a similar economic environment.
The Group is exposed to possible future increase of the variable rents which depend on a ratio or interest rate,
which are only included in the lease liability when accrued. When the above changes occur, the lease liability is
redefined and adjusted by relevantly adjusting the right to use the asset.
Any rent payment is allocated between the lease liability and the financial cost. The interests on the liability
arising from the lease for each lease period equal the amount that arises from the application of a fixed, periodic
interest rate on the outstanding balance of the lease liability.
After their initial measurement, the lease liabilities are increased by the financial cost and decreased by the
payment of rents. The lease liability is remeasured to reflect any reassessments or modifications of the lease.
The cost of the asset with right to use consists of:
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
• The amount of the initial measurement of the lease liability
• Any rents paid on the lease period commencement date or before it, less any lease incentives
already collected, and
• Any initial direct costs suffered by the Group as lessee.
The rights to use assets are measured at cost and amortised by the straight-line method during the shorter
period of time between the useful lifetime of the asset and the term of the lease.
The Group chose to use the recognition exceptions provided for in the Standard for the short-term leases, i.e.
leases with a term shorter than 12 months without any right of redemption, as well as for leases where the
subject asset presents a low value. For the above leases, the Group recognises the rents as expenses in the
profit or loss statement using the straight-line method throughout the term of the lease.
2.18. Interest income and expense
Interest income and expenses mainly relate to coupons from securities, interest from loans and advances to
customers, interest from financial institutions and interest from due to customers.
Interest income and expense are recognised in the profit or loss for all interest bearing instruments on an
accruals basis, using effective interest rate method or the relevant floating interest rate. The effective interest
method is a method to calculate the amortised cost of a financial asset or liability and to allocate the interest
income or expense over the reference period. Effective interest rate is the rate that discounts just the estimated
future payments or receipts throughout the expected life of the financial instrument, or during a shorter period,
when necessary, so that the discounted value would equal its book value, at the initial recognition including any
transaction costs.
In particular, as regards the financial assets, to calculate the effective interest rate, the Group calculates the
cash flows taking into consideration all contractual terms for the financial asset, excluding the expected credit
risk losses (except the “Purchased or Originated Credit-Impaired loans and advances to customers” where the
expected credit losses are taken into consideration).
2.19. Fee and commission income
Fee and commission income mainly include commissions on loans, letters of guarantee and brokerage
transactions, as well as commissions on investment banking and other transactions.
The Group applies the following five-step model to all contracts with customers other than leases and financial
instruments:
identification of the contract with the customer;
identification of the obligations arising from the contracts;
definition of the transaction price;
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
allocation of the transaction price to the obligations arising from the contracts, and
recognition of income as the entity fulfils its obligations.
Therefore, the Group recognises income when the performance obligation is fulfilled, i.e. when control of the
services or goods is transferred to the customer in accordance with the requirements of IFRS 15.
Fee and commission income is recognised in the income statement throughout the period in which the relevant
services were provided, unless they influence the effective interest rate.
2.20. Gains/(losses) from financial transactions
Gains/ (losses) on financial transactions include gains and losses arising from sales of financial assets and
liabilities measured at fair value through profit or loss and other comprehensive income. In addition,
gains/(losses) from and changes in the fair value of financial assets and liabilities measured at fair value through
profit or loss are included.
2.21. Dividend income
Dividend income is recognised in the profit & loss statement on the date the right to collect dividends is
established.
2.22. Income tax and deferred tax
The income tax of the fiscal period is the tax calculated on the taxable income of the current period based on
the tax rate applicable in each country, adjusted to any changes in the deferred tax assets and liabilities due to
provisional differences and unutilized tax losses. The fiscal year tax includes any tax audit differences pertaining
to additional income taxes and additional charges attributed by the tax authorities due to the redefinition of the
Group’s taxable income within the framework of an ordinary or extraordinary tax audit.
The liability arising from the current income tax is calculated according to the legislation in force or the legislation
that in fact applies at the end of the closing year in the countries where the Bank, and the subsidiaries and
associates of the Group have activities and produce taxable income. The Management periodically assesses the
positions in the tax returns in the event that the tax legislation is subject to any interpretation. Moreover, it
forms provisions, where necessary, for the amounts that are expected to be paid to the tax authorities.
The deferred income tax is defined using the liability method; such liability is defined by the temporary
differences between the tax assessment base and the carrying amount of the assets and liabilities presented
on the consolidated financial statements. However, the deferred tax liabilities are not recognised if they arise
at the initial recognition of goodwill. Moreover, the deferred income tax is not accounted for if it arises from the
initial recognition of an asset or liability in a transaction other than a business combination that at the time of
the transaction did not affect either the accounting or the taxable profit or loss. Deferred tax is measured at
the tax rates expected to apply on the financial year when the liability will be settled, considering the tax rates
(and tax laws) that have been enacted or are substantively in force at the end of the closing year.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
Deferred income tax assets are recognised to the extent that there will be a future taxable profit in order to
utilize the temporary difference generated by the deferred income tax asset.
Deferred tax receivables and liabilities are not recognised for any temporary differences between the carrying
amount and the tax base of investments in businesses abroad where the Bank controls the reversal of temporary
differenced and it is likely that the temporary differences will not be reversed in the foreseeable future.
Deferred tax receivables and liabilities are offset when there is an applicable legal right to offset the current tax
receivables and liabilities and when the deferred income taxes involve the same tax authority. The current tax
receivables and liabilities are offset when there is an applicable legal right to offset and an intention to settle
on a net basis or to acquire the asset and to settle the liabilities at the same time.
The current and deferred taxes are recognised in the profit or loss, unless they pertain to assets that are
recognised in the other comprehensive income or directly in equity. In such a case, the tax is also recognised
in the other comprehensive income or directly in equity, respectively.
2.23. Share capital
The share capital includes the Bank’s ordinary shares. The ordinary shares are presented under equity.
Additional expenses required for the issue of shares appear upon deduction of the relevant income tax, to the
reduction of the issue proceeds.
The cost of acquisition of treasury shares, including any attributable incremental transaction costs, is presented
as a reduction in equity according to the provisions of IAS 32, until the treasury shares are cancelled or disposed
of. The gains or losses from the sale of treasury shares (net of expenses) are included directly in the retained
earnings (equity).
The number of treasury shares held by the Group does not reduce the number of shares issued. Treasury shares
held by the Bank are not eligible to receive cash dividends.
2.24. Distribution of dividend
The distribution of dividend to the Bank’s shareholders is recognised as liability in the financial statements of
the Group over the period during which the distribution is approved by the General Assembly of the
Shareholders.
2.25. Related parties
In accordance with IAS 24, a related party is a person or an entity that is related to the Group.
More specifically for the Group, related parties are the following:
(a) subsidiaries;
(b) entities that control the Bank and entities that are controlled, jointly controlled or significantly influenced by
those entities, as well as the key management personnel of that entities and their close relatives;
(c) the key management personnel, their close relatives, and the entities controlled or jointly controlled by
them,
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
(d) the Bank's associates and joint ventures.
2.26. Earnings per share
The Earnings per share ratio (EPS) arises by dividing the profit or loss corresponding to the common
shareholders of the Group’s parent company by the weighted number of outstanding ordinary shares during
the reporting period.
Diluted earnings per share are calculated using the same method as the basic earnings per share ratio, however
earnings and number of shares are adjusted accordingly to reflect any potential reduction in earnings per share
that could result from the conversion of any convertible bonds or the exercise of stock options or other related
contracts into ordinary shares.
2.27. Non-current assets held for sale and discontinued operations
The Group classifies a non-current asset or a group of assets and liabilities as items held for sale if their value
is expected to be recovered mainly due to the sale of the said items and not through their use, while their sale
is considered very likely. They are measured at the lowest value between their book and fair value decreased
by the direct costs of sale, except from assets such as deferred tax liabilities and financial assets that are
explicitly excluded from the measurement requirements of the Standard.
The impairment losses arising are recognised in the profit or loss. Any possible increase of the fair value at a
subsequent remeasurement is recognised in the profit or loss but not for an amount higher than the initially
recognised impairment loss. Any profits or losses not recognised on the date of sale of the non-current asset
(or the group of assets) are recognised on the date of the derecognition.
As of the date when a non-current (amortised) asset (or the non-current assets that are included in a group of
assets and liabilities) is classified as held for sale, no amortisations are calculated on the said non-current assets.
The non-current assets and groups of assets classified as held for sale are presented separately in the statement
of financial position. The liabilities relevant to the groups of assets classified as held for sale are presented
separately from the other liabilities in the statement of financial position.
2.28. Derivative financial instruments
The derivative financial instruments mainly include futures, options, FΧ Swaps and Interest Rate Swaps (IRS-
IRCAP).
The derivatives are initially recognised in the statement of financial position at fair value on the date of entering
the contract and then are measured at their fair value. When the fair value is positive, the derivatives are
included in the assets, while when the fair value is negative they are included in the liabilities.
The fair value of the derivative financial instruments is defined on the basis of the market price, taking into
consideration recent transactions on the market or using other appropriate measurement techniques (see Note
5).
The Group does not apply any hedge accounting. Consequently, all derivatives held are recognised and
measured at their fair value through profit or loss.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
2.29. Rounding
The amounts are presented in thousands of euros, rounded to the nearest thousand, unless otherwise stated.
Any differences between the amounts in the financial statements and the corresponding amounts in the notes
are due to rounding.
3. Critical accounting estimates and assumptions for the implementation of the accounting
principles
In applying the Group's and the Bank's accounting policies, Management makes estimates and assumptions
that may significantly affect the amounts of assets and liabilities presented in the consolidated and stand alone
financial statements in the next reporting year. The estimates and assumptions are reviewed at each reporting
date and are based on historical data and other factors, including estimates of future events, which, based on
current circumstances, are considered reasonable. The estimates and assumptions in applying the accounting
policies mainly concern the following areas:
A. Impairment provisions for credit risks from loans and advances to customers
At each reporting date the Group and the Bank recognises an allowance for the expected credit risk losses from
loans and advances to customers.
The Group, when testing for impairment of loans and advances to customers, makes estimates regarding the
amount and timing of collection of future cash flows. Considering that these estimates are influenced by a
number of factors such as the financial condition of the borrower, the net realizable value of any collateral,
historical loss ratios per portfolio, actual results may differ from the estimates. Similar estimates are also
included in the assessment of the existence of impairment losses on securities classified as financial assets
measured at fair value through other comprehensive income or financial assets measured at amortised cost.
The measuring of the expected credit losses is based on the assumptions of the Management regarding the
recoverability of the exposure and the guarantees received. The Management makes assumptions on the
financial position of the counterparty, its credit risk, the recoverability of any collaterals and guarantees.
In the context of evaluating the credit risk increase, the Group also rates its borrowers based on the evidence
of financial difficulties and the possibility of a default, in accordance with its policy in force.
Additional information on the impairment provisions for credit risks from loans and advances to customers is
included in notes 2.4, 2.12, 4.1 and 20.
B. Recoverability of deferred tax assets
The Group recognises deferred tax assets to the extent that it assumes that it will have sufficient future taxable
profits available.
The recognition of the above deferred tax assets requires estimates regarding the future financial performance
of the Group’s companies to which the deferred tax assets have been recognised. In particular, the definition
of the deferred tax assets that may be recognised requires making significant estimates about the timing and
the amount of the future taxable profits.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
Further information about the deferred tax assets of the Group can be found in note 27.
C. Fair Value of financial assets
The fair value of financial assets for which there are no observable prices in an active market is determined
using valuation models. The valuation methodology used includes discounted cash flow methods that are based
primarily on observable data, where available. The fair value of the securitized loan bond depends on key
assumptions that include future income and cash flows, operating expenses and discount rates. The securitized
loan bond is classified as level 3.
Further information about the fair value of financial assets can be found in notes 5, 18, 19 and 21.
D. Subsidiaries impairment
The Bank reviews the value of its investments in subsidiaries for impairment by comparing the recoverable
amount of each investment (the higher of value in use and fair value less costs to sell) with its carrying amount.
4. Financial Risk Management
The Group, as any credit institution, is exposed to risks. Such risks are constantly monitored in different ways
to avoid the excessive accumulation of risks. The nature of these risks as well as their management are
explained below. Moreover, further financial information is given to describe the extent and the nature of the
financial risks faced by the Group, with relevant comparative information on the previous reporting year.
The strategy for undertaking and managing all types of risks is aligned with best international practices,
applicable legislation and the supervisory framework, while it is constantly evolving through the development
of a single risk management concept for the entire Group.
The Risk Management Framework is reviewed annually and on an ad hoc basis whenever special circumstances
require it in relation to internal events, the broader economic environment or the supervisory framework in
accordance with best practices and in any case within the applicable legal and regulatory framework. This
review is carried out in collaboration with the Risk Management Department and the Units that undertake the
various risks, the Risk Management Committee, the Executive Committee, as well as the Board of Directors.
The Risk Management Committee (RMC) and the Board of Directors (BoD) are responsible for approving and
periodically reviewing the risk profile undertaken by the Group.
The Risk Management Division operates in accordance with the provisions of BoG Governor’s Act 2577/06 and
its amendments. The Division in terms of organization, is accountable to the Risk Management Committee. The
Risk Management Division Manager is appointed by the Board of Directors, on the recommendation of the Risk
Management Committee, and his/her appointment, as well as any replacement, is notified to the Bank of Greece.
The objective of the Unit and consequently of the Risk Management Division is to identify, analyze and develop
effective systems for measuring, managing and controlling all forms of risk inherent in every task undertaken
by the Bank and, on a consolidated basis, by the Group.
The Unit consists of six (6) departments:
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
(i) Credit Risk: its main responsibility is to propose, implement and ensure compliance to the
framework of policies and procedures for the management of the Bank's credit risk arising from the
application of the credit process and the measurement and monitoring of tolerance limits.
(ii) Market Risks & Liquidity Department: is responsible for the formation of the uniform framework of
Policy and Procedures for the management of market, interest rate and liquidity risks at Group
level, for ensuring its compliance, as well as for monitoring and controlling the limits subject to its
responsibility.
(iii) Operational Risk Department: its main responsibility is to recommend, implement and ensure
compliance to the framework of policies and procedures for the management of operational risks
the Bank and the Group and to monitor compliance with the risk tolerance limits that have been
set.
(iv) The Capital Adequacy Management Department has as its main responsibility the recommendation,
implementation and compliance of the framework of policies and procedures for the calculation and
effective management of the Bank's capital adequacy.
(v) Supervisory Relations Department: Its objectives are the coordination, execution and monitoring of
the tasks: a) of the supervisory obligations regarding the Group's Risk Management (supervisory
reports, Pillars I / II and III of the framework, etc.), b) the collection, analysis and processing of
the necessary data for the execution of the tasks of the departments of the Risk Management
Division.
(vi) Modelling Department: Its purpose is to coordinate and monitor the work of external partners
regarding the certification of existing models, the flow of procedures and the correct execution,
today, of the ECL methodology, as well as the other systems that will be implemented in the future
in the area of Risk Management. Validation Reports, including findings and recommendations, are
submitted to the Risk Management Committee.
4.1. Credit risk
Credit risk is the risk of financial loss due to the potential inability or unwillingness of a counterparty to fulfill its
contractual obligations, resulting in the loss of capital and profit. Credit risk management focuses on ensuring
a disciplined culture, transparency and rational risk-taking, based on recognised international practices.
The credit risk management methodologies are adjusted to reflect the economic environment at any given time.
The various methods used are reviewed annually or whenever deemed necessary and are adjusted according
to the Group's strategy and the Group's short-term and long-term objectives.
The various analyses of sectors and sub-sectors of the economy, combined with economic forecasts, provide
the guidelines for determining credit policy. With the aim of minimizing credit risk, and taking into account the
creditworthiness of the borrower, the collateral and guarantees offered that reduce the Group's exposure to
credit risk, the type and duration of the credit facility, financial limits are set per borrower. As regards the
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
analysis of the creditworthiness of each borrower, this is carried out taking into account the risk of the country
and the sector of the economy in which it operates, as well as its qualitative and quantitative characteristics.
In addition, credit facility approval limits have been established and tasks have been defined during the lending
process to ensure objectivity, independence and control of new and existing loans.
During the approval process, the overall credit risk for each counterparty or group of counterparties that are
related to each other is examined and the credit limits approved by different companies of the Group are
aggregated.
The monitoring of the creditworthiness of counterparties and credit exposures, in combination with the
respective approved limits, is carried out on a systematic basis. In addition, any concentration is analyzed and
monitored on an ongoing basis, with the aim of limiting potential large exposures and dangerous concentrations.
A concentration of credit risk can be created at the level of an economic sector, counterparty or group of
counterparties, country, currency and type of collateral.
Balancing the risk-reward relationship is crucial to the Group's continued profitability. This relationship is
analyzed at the customer and product level through profitability measurement and pricing analysis, with the
aim of combining the risk taken with the expected profitability.
In addition, the Bank uses various techniques to limit its exposure to credit risk, such as taking collateral and
guarantees. Tangible collaterals provide the Bank with a right over the assets (movable or immovable assets)
owned by the debtor in order to obtain priority in the satisfaction from the liquidation proceeds of the property.
Tangible collaterals are divided into mortgages and mortgages prenotations on immovable property, as well as
pledges registered on movable property (e.g. merchandise, checks) or on receivables. Similarly, guarantees
refer to contractual agreements whereby a person or an entity undertakes the responsibility for the repayment
of debt of another person or entity.
The main types of collateral accepted by the Group in accordance with the Credit Policy Manual are broken
down into the following categories:
• mortgages on urban/non-urban real estate property, both in and outside the town plan, at a rate
proportionate to the security margin set by the Bank;
• pledging of cash, checks, bills of landing, receivables, goods with securities, etc.;
• guarantees provided by the Greek State, banks, the Hellenic Development Bank and by companies with
high credit-rating.
In addition, within the framework of the credit risk management policy, the effect of extreme but feasible
scenarios on the quality of the loan portfolio and on the available funds is evaluated by conducting stress tests.
Internal rating systems
The methods to evaluate the creditworthiness are classified in the following categories, depending on the type
of the counterparty: central governments (for purchase and holding of bonds), financial institutions, large and
small & medium-sized entities (SMEs) and individuals.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
As regards the rating of governments and financial institutions, there is detailed analysis in the sections
“Counterparty bank risk” and “Country risk”.
Individuals are rated following research conducted in the TIRESSIAS bank information system presenting the
background of the transaction activity of the customer and income criteria. Especially for the issuance of credit
card or the grant of mortgage loans, customers’ creditworthiness is evaluated using the scoring/rating system
based both on demographic factors and objective financial information (e.g. income, assets).
For the rating of large and SME businesses, a risk classification system is used. The system has been developed
by ICAP-CRIF SA and the internal rating ranges from 1 (low credit risk) to 10 (high credit risk).
The first dimension concerns the classification of the borrower's creditworthiness into ten levels based on
qualitative and quantitative criteria, determining the probability of default on its obligations. The weight of the
individual criteria varies depending on the nature and size of the borrower's activities.
IRP Mapping to Moody’s Debtor Impairment Studio© Risk Classification Score 1 Aa2 Low credit risk 2 A2 Low credit risk 3 Baa2 Low credit risk 4 Ba1 Low credit risk 5 Ba3 Average credit risk 6 B2 Average credit risk 7 B3 Average credit risk 8 Caa2 High credit risk 9 Caa3 High credit risk 10 Ca High credit risk
The second dimension of transaction risk assessment is the assessment of the quality and adequacy of collateral,
determining the expected loss in the event of default.
The creditworthiness of the customer is used in conjunction with the degree of collateral adequacy (i.e.
unsecured risk) in the credit approval process and the setting of the corresponding limits. In particular, the
creditworthiness rating at the corporate portfolio level is systematically monitored for the internal calculation of
default probabilities and for the early diagnosis of adverse shifts in the various quality/risk levels of the portfolio,
with a view to developing appropriate strategies to offset the risks undertaken.
Macroeconomic models
To calculate the forward-looking lifetime probability of default (PD) on the corporate portfolio, an appropriate
macroeconomic model from Moody’s Analytics™ is used. The model combines idiosyncratic exposure
45
Notes to the Financial Statements dated December 31, 2024
Group and Bank
characteristics with forecasts of specific macroeconomic variables, appropriately adjusting the probability of
default (PD) of the debtor/exposure taking into account future conditions. The model also incorporates industry
sensitivity in order to generate complementary information. For the final selection of scenarios, the company’s
scenario estimates are checked against those published by the European Central Bank (ECB), the European
Commission (EC) and the Greek Government for their relevance. The Risk Management Committee, following
the relevant approval by the Executive Committee, validates the scenarios and their severity on a quarterly
basis.
Collateral Valuation
The type of collateral and the percentage of coverage required depends on the financial situation, dynamics
and prospects of the borrower, the form and amount of the credit facility and the credit risk of each
counterparty.
The valuation of collateral is carried out by the Bank and the Group, systematically and with frequency
depending on the type of collateral, as defined in the Credit Policy Manual and special experts are used, where
required, such as real estate. For the valuation of the collateral, parameters related to the time and cost of
liquidation are taken into account.
Real estate
• Prenotated property values – property appraisals and revaluations
The value of the prenotated properties is estimated by the Bank's engineering appraisers in accordance
with international appraisal standards. With regard to the assessment and reassessment of the value
of the properties that are listed, the following apply:
o New Financing:
When a request for new financing secured by a property prenotation is being considered, the
assessment is carried out with a physical inspection/on-site visit by an independent authorized
appraiser.
o Existing Financing:
For existing financing that has as collateral a real estate prenotation and if it relates to a
residential house and other residential properties (e.g. plots of land, parcels of land), the value
of the property is monitored regularly, at least every 3 years, with a desktop assessment
(without a visit or physical inspection) or the statistical adjustment if market conditions have
not changed significantly.
For commercial property, the value of the property is monitored at least once a year with a
desktop valuation (without an on-site visit) and every 3 years with a physical inspection.
46
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Negotiable securities where there is a valuation in the market
Their value is adjusted daily within the Bank's systems and are taken into account in the ECL calculations.
Other Collateral
To calculate their value, appropriate impairment factors (haircuts) are applied in accordance with best practices.
47
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Maximum exposure to credit risk before collateral held and other credit enhancements
The following table presents the maximum exposure to credit risk arising from financial instruments presented in the statement of financial position of the Group
and the Bank, without taking into consideration any collaterals held or other credit enhancements. For the financial instruments presented in the statement of
financial position, the exposure to credit risk equals to their carrying amount.
Group
Maximum exposure Amounts in Eur ΄000 31/12/2024 31/12/2023 Exposure to credit risk from items on the SOFP: Deposits with central bank 797,646 467,679 Due from banks 171,309 126,090 Financial assets measured at fair value through profit or loss 264,442 337,628 Derivative financial instruments 2,210 1,033 Loans and advances to customers 3,612,598 2,430,914 Financial assets measured at fair value through other comprehensive income 47,390 86,488 Debt securities at amortised cost 413,844 251,388 Other financial assets 33,665 39,878 Total on balance sheet credit exposures 5,343,104 3,741,098 Total off balance sheet credit exposures: Letter of guarantee and unutilised credit limits 862,056 625,311 Total 6,205,160 4,366,409
48
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Maximum exposure Amounts in Eur ΄000 31/12/2024 31/12/2023 Exposure to credit risk from items on the SOFP: Deposits with central bank 797,645 467,679 Due from banks 160,157 123,625 Financial assets measured at fair value through profit or loss 261,626 336,994 Derivative financial instruments 2,210 1,033 Loans and advances to customers 3,596,600 2,416,072 Financial assets measured at fair value through other comprehensive income 47,390 86,488 Debt securities at amortised cost 413,844 251,388 Other financial assets 34,236 32,396 Total on balance sheet credit exposures 5,313,708 3,715,675 Total off balance sheet credit exposures: Letter of guarantee and unutilised credit limits 862,056 623,532 Total 6,175,764 4,339,207
49
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers
The following table presents the quality of the loans and advances to customers of the Group and the Bank.
Group
Loans and advances to customers and impairment provisions per IFRS 9 Stage Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total Loans and Gross loans Gross loans Gross loans Gross loans Gross loans advances to and and and and and customers 31/12/2024 Impairments Impairments Impairments Impairments Impairments advances to advances to advances to advances to advances to net value customers customers customers customers customers Individuals Consumer, personal & other 34,965 127 29 3 19 19 0 0 35,013 149 34,864 Mortgages 132,641 371 0 0 0 0 0 0 132,641 371 132,270 Corporate Large Corporate 1,606,696 10,559 99,297 4,072 11,720 4,096 0 0 1,717,713 18,727 1,698,986 SMEs 1,613,336 10,854 132,238 3,589 19,426 10,834 7,132 377 1,772,132 25,654 1,746,478 Total 3,387,638 21,911 231,564 7,664 31,165 14,949 7,132 377 3,657,499 44,901 3,612,598 Commitments relevant to credit risk Letters of guarantee 765,362 2,952 89,770 696 0 0 0 0 855,132 3,648 851,484 Loan commitments 10,525 0 47 0 0 0 0 0 10,572 0 10,572 Total 775,887 2,952 89,817 696 0 0 0 0 865,704 3,648 862,056
50
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total Loans and Gross loans Gross loans Gross loans Gross loans Gross loans advances to and and and and and customers 31/12/2023 Impairments Impairments Impairments Impairments Impairments advances to advances to advances to advances to advances to net value customers customers customers customers customers Individuals Consumer, personal & other 30,933 244 19 9 1,801 1,801 0 0 32,753 2,054 30,699 Mortgages 98,190 358 0 0 9 8 0 0 98,199 366 97,833 Corporate Large Corporate 1,012,694 6,866 40,182 506 1,980 1,980 0 0 1,054,856 9,352 1,045,504 SMEs 1,175,013 6,248 84,412 3,988 7,338 5,565 5,938 22 1,272,701 15,823 1,256,878 Total 2,316,830 13,716 124,613 4,503 11,128 9,354 5,938 22 2,458,509 27,595 2,430,914 Commitments relevant to credit risk Letters of guarantee 598,202 1,753 18,257 26 0 0 0 0 616,459 1,779 614,680 Loan commitments 8,790 0 62 0 0 0 0 0 8,852 0 8,852 Total 606,992 1,753 18,319 26 0 0 0 0 625,311 1,779 623,532
51
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total Loans and Gross loans Gross loans Gross loans Gross loans Gross loans advances to and and and and and customers 31/12/2024 Impairments Impairments Impairments Impairments Impairments advances to advances to advances to advances to advances to net value customers customers customers customers customers Individuals Consumer, personal & other 34,965 127 29 3 19 19 0 0 35,013 149 34,864 Mortgages 132,641 371 0 0 0 0 0 0 132,641 371 132,270 Corporate Large Corporate 1,685,176 10,492 92,428 4,064 11,720 4,096 0 0 1,789,324 18,652 1,770,672 SMEs 1,531,273 10,616 126,352 3,562 19,250 10,658 7,132 377 1,684,007 25,213 1,658,794 Total 3,384,055 21,606 218,809 7,629 30,989 14,773 7,132 377 3,640,985 44,385 3,596,600 Commitments relevant to credit risk Letters of guarantee 765,362 2,952 89,770 696 0 0 0 0 855,132 3,648 851,484 Loan commitments 10,525 0 47 0 0 0 0 0 10,572 0 10,572 Total 775,887 2,952 89,817 696 0 0 0 0 865,704 3,648 862,056
52
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total Loans and Gross loans Gross loans Gross loans Gross loans Gross loans advances to and and and and and customers 31/12/2023 Impairments Impairments Impairments Impairments Impairments advances to advances to advances to advances to advances to net value customers customers customers customers customers Individuals Consumer, personal & other 30,933 244 19 9 1,801 1,801 0 0 32,753 2,054 30,699 Mortgages 98,190 358 0 0 9 8 0 0 98,199 366 97,833 Corporate Large Corporate 1,074,318 6,856 40,182 506 1,980 1,980 0 0 1,116,480 9,342 1,107,138 SMEs 1,098,412 6,123 84,412 3,988 7,338 5,565 5,938 22 1,196,100 15,698 1,180,402 Total 2,301,853 13,581 124,613 4,503 11,128 9,354 5,938 22 2,443,532 27,460 2,416,072 Commitments relevant to credit risk Letters of guarantee 598,202 1,753 18,257 26 0 0 0 0 616,459 1,779 614,680 Loan commitments 8,790 0 62 0 0 0 0 0 8,852 0 8,852 Total 606,992 1,753 18,319 26 0 0 0 0 625,311 1,779 623,532
53
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Loans and advances to customers based on their quality (impairments under IFRS 9) Accumulated impairment Amounts in Eur ΄000 Gross loans and advances to customers Total value Total net value provisions Value of before after Individual Collective Individual Collective collaterals 31/12/2024 impairment impairment assesment assesment assesment assesment Individuals Consumer, personal & other 0 35,013 35,013 0 149 34,864 98,783 Mortgages 0 132,641 132,641 0 371 132,270 172,918 Corporate Large Corporate 0 1,717,713 1,717,713 0 18,727 1,698,986 1,173,174 SMEs 0 1,772,132 1,772,132 0 25,654 1,746,478 1,659,310 Total 0 3,657,499 3,657,499 0 44,901 3,612,598 3,104,185 Commitments relevant to credit risk Letters of guarantee 0 855,132 855,132 0 3,648 851,484 85,576 Loan commitments 0 10,572 10,572 0 0 10,572 0 Total 0 865,704 865,704 0 3,648 862,056 85,576
54
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers based on their quality (impairments under IFRS 9) Accumulated impairment Amounts in Eur ΄000 Gross loans and advances to customers Total value Total net value provisions Value of before after Individual Collective Individual Collective collaterals 31/12/2023 impairment impairment assesment assesment assesment assesment Individuals Consumer, personal & other 0 32,753 32,753 0 2,054 30,699 105,750 Mortgages 0 98,199 98,199 0 366 97,833 122,231 Corporate Large Corporate 0 1,054,856 1,054,856 0 9,352 1,045,504 871,094 SMEs 0 1,272,701 1,272,701 0 15,823 1,256,878 1,143,736 Total 0 2,458,509 2,458,509 0 27,595 2,430,914 2,242,811 Commitments relevant to credit risk Letters of guarantee 0 616,459 616,459 0 1,779 614,680 81,331 Loan commitments 0 8,852 8,852 0 0 8,852 0 Total 0 625,311 625,311 0 1,779 623,532 81,331
55
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Loans and advances to customers based on their quality (impairments under IFRS 9) Accumulated impairment Amounts in Eur ΄000 Gross loans and advances to customers Total value Total net value provisions Value of before after Individual Collective Individual Collective collaterals 31/12/2024 impairment impairment assesment assesment assesment assesment Individuals Consumer, personal & other 0 35,013 35,013 0 149 34,864 98,783 Mortgages 0 132,641 132,641 0 371 132,270 172,918 Corporate Large Corporate 0 1,789,324 1,789,324 0 18,652 1,770,672 1,073,554 SMEs 0 1,684,007 1,684,007 0 25,213 1,658,794 1,532,019 Total 0 3,640,985 3,640,985 0 44,385 3,596,600 2,877,274 Commitments relevant to credit risk Letters of guarantee 0 855,132 855,132 0 3,648 851,484 85,576 Loan commitments 0 10,572 10,572 0 0 10,572 0 Total 0 865,704 865,704 0 3,648 862,056 85,576
56
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers based on their quality (impairments under IFRS 9) Accumulated impairment Amounts in Eur ΄000 Gross loans and advances to customers Total value Total net value provisions Value of before after Individual Collective Individual Collective collaterals 31/12/2023 impairment impairment assesment assesment assesment assesment Individuals Consumer, personal & other 0 32,753 32,753 0 2,054 30,699 105,750 Mortgages 0 98,199 98,199 0 366 97,833 122,231 Corporate Large Corporate 0 1,116,480 1,116,480 0 9,342 1,107,138 786,563 SMEs 0 1,196,100 1,196,100 0 15,698 1,180,402 1,041,769 Total 0 2,443,532 2,443,532 0 27,460 2,416,072 2,056,313 Commitments relevant to credit risk Letters of guarantee 0 616,459 616,459 0 1,779 614,680 81,331 Loan commitments 0 8,852 8,852 0 0 8,852 0 Total 0 625,311 625,311 0 1,779 623,532 81,331
57
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Loans and advances to customers and impairment provisions per IFRS 9 Stage (per industry and geographical region) Greece Other countries Amounts in Eur ΄000 Gross Loans and Gross Loans and loans and advances loans and Stage Stage Stage Stage Stage Stage advances to POCI advances Impairments to POCI advances Impairments 31/12/2024 1 2 3 1 2 3 customers net to customers to value customers net value customers Individuals 156,045 28 19 0 156,092 499 155,593 11,561 1 0 0 11,562 21 11,541 Consumer, personal & other 34,550 28 19 0 34,597 148 34,449 415 1 0 0 416 1 415 Mortgages 121,495 0 0 0 121,495 351 121,144 11,146 0 0 0 11,146 20 11,126 Corporate 2,829,451 229,171 29,430 7,132 3,095,184 41,586 3,053,598 363,230 2,364 1,716 0 367,310 2,686 364,624 Financial institutions and other financial services 141,702 0 0 0 141,702 491 141,211 36,956 0 0 0 36,956 69 36,887 Manufacturing 320,478 33,986 3,054 0 357,518 6,517 351,001 0 0 0 0 0 0 0 Construction 249,219 26,516 4,529 0 280,264 5,290 274,974 1,340 0 0 0 1,340 5 1,335 Wholesale and retail trade 392,947 45,626 1,921 3,646 444,140 6,192 437,948 9,699 0 0 0 9,699 46 9,653 Accommodation and food service activities 295,565 27,730 2,451 2,600 328,346 3,306 325,040 0 0 0 0 0 0 0 Information and communication 142,064 41,037 81 0 183,182 4,197 178,985 3,993 0 0 0 3,993 1 3,992 Energy 500,862 6,246 7,148 0 514,256 3,347 510,909 248 0 0 0 248 0 248 Real estate activities 339,875 22,193 1,477 0 363,545 3,672 359,873 22,303 0 0 0 22,303 25 22,278 Services and other industries 446,739 25,837 8,769 886 482,231 8,574 473,657 288,691 2,364 1,716 0 292,771 2,540 290,231 Public sector 27,351 0 0 0 27,351 109 27,242 0 0 0 0 0 0 0 Total 3,012,847 229,199 29,449 7,132 3,278,627 42,194 3,236,433 374,791 2,365 1,716 0 378,872 2,707 376,165
58
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage (per industry and geographical region) Greece Other countries Amounts in Eur ΄000 Gross Loans and Gross Loans and loans and advances loans and Stage Stage Stage Stage Stage Stage advances to POCI advances Impairments to POCI advances Impairments 31/12/2023 1 2 3 1 2 3 customers net to customers to value customers net value customers Individuals 117,988 19 1,810 0 119,817 2,395 117,422 11,135 0 0 0 11,135 25 11,110 Consumer, personal & other 27,649 19 1,801 0 29,469 2,048 27,421 3,284 0 0 0 3,284 6 3,278 Mortgages 90,339 0 9 0 90,348 347 90,001 7,851 0 0 0 7,851 19 7,832 Corporate 1,922,320 118,504 7,690 5,938 2,054,452 22,770 2,031,682 237,771 6,090 1,628 0 245,489 2,321 243,168 Financial institutions and other financial services 31,031 0 0 0 31,031 95 30,936 66,978 0 0 0 66,978 129 66,849 Manufacturing 263,952 22,542 2,975 0 289,469 4,482 284,987 2,372 0 0 0 2,372 11 2,361 Construction 249,073 9,365 0 0 258,438 2,587 255,851 0 0 0 0 0 0 0 Wholesale and retail trade 319,136 32,990 2,529 3,224 357,879 5,355 352,524 4,458 0 0 0 4,458 9 4,449 Accommodation and food service activities 174,290 18,762 592 2,714 196,358 2,628 193,730 0 0 0 0 0 0 0 Information and communication 95,302 4,697 79 0 100,078 1,544 98,534 3,893 0 0 0 3,893 1 3,892 Energy 312,345 10,473 269 0 323,087 2,557 320,530 277 0 0 0 277 1 276 Real estate activities 285,791 5,453 0 0 291,244 1,322 289,922 17,497 0 0 0 17,497 52 17,445 Services and other industries 191,400 14,222 1,246 0 206,868 2,200 204,668 142,296 6,090 1,628 0 150,014 2,118 147,896 Public sector 27,616 0 0 0 27,616 84 27,532 0 0 0 0 0 0 0 Total 2,067,924 118,523 9,500 5,938 2,201,885 25,249 2,176,636 248,906 6,090 1,628 0 256,624 2,346 254,278
59
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage (per industry and geographical region) Greece Other countries Amounts in Eur ΄000 Gross Loans and Gross Loans and loans and advances loans and Stage Stage Stage Stage Stage Stage advances to POCI advances Impairments to POCI advances Impairments 31/12/2024 1 2 3 1 2 3 customers net to customers to value customers net value customers Individuals 156,045 28 19 0 156,092 498 155,594 11,561 1 0 0 11,562 22 11,540 Consumer, personal & other 34,550 28 19 0 34,597 147 34,450 415 1 0 0 416 2 414 Mortgages 121,495 0 0 0 121,495 351 121,144 11,146 0 0 0 11,146 20 11,126 Corporate 2,832,337 216,416 29,254 7,132 3,085,139 41,080 3,044,059 356,761 2,364 1,716 0 360,841 2,676 358,165 Financial institutions and other financial services 278,618 0 0 0 278,618 529 278,089 36,956 0 0 0 36,956 69 36,887 Manufacturing 302,557 32,436 3,054 0 338,047 6,487 331,560 0 0 0 0 0 0 0 Construction 246,691 21,974 4,529 0 273,194 5,277 267,917 1,340 0 0 0 1,340 5 1,335 Wholesale and retail trade 352,640 44,635 1,745 3,646 402,666 5,993 396,673 7,223 0 0 0 7,223 37 7,186 Accommodation and food service activities 295,565 27,730 2,451 2,600 328,346 3,306 325,040 0 0 0 0 0 0 0 Information and communication 98,244 35,442 81 0 133,767 4,006 129,761 0 0 0 0 0 0 0 Energy 500,862 6,246 7,148 0 514,256 3,347 510,909 248 0 0 0 248 0 248 Real estate activities 339,875 22,193 1,477 0 363,545 3,672 359,873 22,303 0 0 0 22,303 25 22,278 Services and other industries 417,285 25,760 8,769 886 452,700 8,463 444,237 288,691 2,364 1,716 0 292,771 2,540 290,231 Public sector 27,351 0 0 0 27,351 109 27,242 0 0 0 0 0 0 0 Total 3,015,733 216,444 29,273 7,132 3,268,582 41,687 3,226,895 368,322 2,365 1,716 0 372,403 2,698 369,705
60
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage (per industry and geographical region) Greece Other countries Amounts in Eur ΄000 Gross Loans and Gross Loans and loans and advances loans and Stage Stage Stage Stage Stage Stage advances to 31/12/2023 POCI advances Impairments to POCI advances Impairments 1 2 3 1 2 3 customers net to customers to value customers net value customers Individuals 117,988 19 1,810 0 119,817 2,395 117,422 11,135 0 0 0 11,135 25 11,110 Consumer, personal & other 27,649 19 1,801 0 29,469 2,048 27,421 3,284 0 0 0 3,284 6 3,278 Mortgages 90,339 0 9 0 90,348 347 90,001 7,851 0 0 0 7,851 19 7,832 Corporate 1,913,954 118,504 7,690 5,938 2,046,086 22,636 2,023,450 231,162 6,090 1,628 0 238,880 2,320 236,560 Financial institutions and other financial services 134,890 0 0 0 134,890 548 134,342 66,979 0 0 0 66,979 129 66,850 Manufacturing 244,272 22,542 2,973 0 269,787 4,475 265,312 2,372 0 0 0 2,372 11 2,361 Construction 229,598 9,365 0 0 238,963 2,272 236,691 0 0 0 0 0 0 0 Wholesale and retail trade 297,336 32,990 2,529 3,225 336,080 5,346 330,734 2,032 0 0 0 2,032 8 2,024 Accommodation and food service activities 174,290 18,762 592 2,713 196,357 2,628 193,729 0 0 0 0 0 0 0 Information and communication 69,067 4,697 79 0 73,843 1,444 72,399 0 0 0 0 0 0 0 Energy 312,345 10,473 269 0 323,087 2,557 320,530 277 0 0 0 277 1 276 Real estate activities 285,791 5,453 0 0 291,244 1,322 289,922 17,497 0 0 0 17,497 52 17,445 Services and other industries 166,365 14,222 1,248 0 181,835 2,044 179,791 142,005 6,090 1,628 0 149,723 2,119 147,604 Public sector 27,614 0 0 0 27,614 84 27,530 0 0 0 0 0 0 0 Total 2,059,556 118,523 9,500 5,938 2,193,517 25,115 2,168,402 242,297 6,090 1,628 0 250,015 2,345 247,670
61
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Movement in ECL allowance of loans and advances to customers measured at amortised cost 31/12/2024 Individuals Corporate Total Stage Stage Stage Stage Stage Stage Stage Stage Stage POCI Total POCI Total POCI Total Amounts in Eur ΄000 1 2 3 1 2 3 1 2 3 ECL allowance as at 1/1/2024 602 9 1,809 0 2,420 13,114 4,494 7,545 22 25,175 13,716 4,503 9,354 22 27,595 Transferred from Stage 1 to Stage 2 or Stage 3 0 0 0 0 0 (1,621) 1,495 126 0 0 (1,621) 1,495 126 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 5 (11) 6 0 0 1,481 (1,673) 192 0 0 1,486 (1,684) 198 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 8 2 (10) 0 0 1,824 2,390 (4,214) 0 0 1,832 2,392 (4,224) 0 0 Allowances: (117) 3 (1,739) 0 (1,853) 6,615 955 11,281 355 19,206 6,498 958 9,542 355 17,353 ECL impairment charge/(release) for the year (P&L) (717) 3 (1,739) 0 (2,453) (12,458) 886 11,281 51 (240) (13,175) 889 9,542 51 (2,693) ECL impairment charge for new financial assets originated or purchased (P&L) 600 0 0 0 600 19,073 69 0 304 19,446 19,673 69 0 304 20,046 Write-offs 0 0 (47) 0 (47) 0 0 0 0 0 0 0 (47) 0 (47) ECL allowance as at 31/12/24 498 3 19 0 520 21,413 7,661 14,930 377 44,381 21,911 7,664 14,949 377 44,901
Movement in ECL allowance of loans and advances to customers measured at amortised cost 31/12/2023 Individuals Corporate Total Stage Stage Stage Stage Stage Stage Stage Stage Stage POCI Total POCI Total POCI Total Amounts in Eur ΄000 1 2 3 1 2 3 1 2 3 ECL allowance as at 1/1/2023 750 3 305 0 1,058 11,924 2,719 3,205 0 17,848 12,674 2,722 3,510 0 18,907 Transferred from Stage 1 to Stage 2 or Stage 3 (2) 2 0 0 0 (1,185) 1,107 7 71 0 (1,187) 1,109 7 71 0 Transferred from Stage 2 to Stage 1 or Stage 3 3 (4) 1 0 0 1,204 (1,460) 256 0 0 1,207 (1,464) 257 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 36 (36) 0 0 2 131 (133) 0 0 2 167 (169) 0 0 Allowances: (149) (28) 1,725 0 1,548 1,169 1,997 4,780 (49) 7,897 1,020 1,969 6,505 (49) 9,444 ECL impairment charge/(release) for the year (P&L) (656) (28) 1,725 0 1,041 (11,685) 765 4,780 (49) (6,189) (12,341) 737 6,505 (49) (5,148) ECL impairment charge for new financial assets originated or purchased (P&L) 507 0 0 0 507 12,854 1,232 0 0 14,086 13,361 1,232 0 0 14,593 Write-offs 0 0 (186) 0 (186) 0 0 (570) 0 (570) 0 0 (756) 0 (756) ECL allowance as at 31/12/23 602 9 1,809 0 2,420 13,114 4,494 7,545 22 25,175 13,716 4,503 9,354 22 27,595
62
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Movement in ECL allowance of loans and advances to customers measured at amortised cost 31/12/2024 Individuals Corporate Total Stage Stage Stage Stage Stage Stage Stage Stage Stage POCI Total POCI Total POCI Total Amounts in Eur ΄000 1 2 3 1 2 3 1 2 3 ECL allowance as at 1/1/2024 602 9 1,809 0 2,420 12,979 4,494 7,545 22 25,040 13,581 4,503 9,354 22 27,460 Transferred from Stage 1 to Stage 2 or Stage 3 0 0 0 0 0 (1,598) 1,472 126 0 0 (1,598) 1,472 126 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 5 (11) 6 0 0 1,481 (1,674) 193 0 0 1,486 (1,685) 199 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 8 2 (10) 0 0 1,824 2,390 (4,214) 0 0 1,832 2,392 (4,224) 0 0 Allowances: (117) 3 (1,739) 0 (1,853) 6,422 944 11,104 355 18,825 6,305 947 9,365 355 16,972 ECL impairment charge/(release) for the year (P&L) (717) 3 (1,739) 0 (2,453) (12,606) 878 11,104 51 (573) (13,323) 881 9,365 51 (3,026) ECL impairment charge for new financial assets originated or purchased (P&L) 600 0 0 0 600 19,028 66 0 304 19,398 19,628 66 0 304 19,998 Write-offs 0 0 (47) 0 (47) 0 0 0 0 0 0 0 (47) 0 (47) ECL allowance as at 31/12/24 498 3 19 0 520 21,108 7,626 14,754 377 43,865 21,606 7,629 14,773 377 44,385
Movement in ECL allowance of loans and advances to customers measured at amortised cost 31/12/2023 Individuals Corporate Total Stage Stage Stage Stage Stage Stage Stage Stage Stage POCI Total POCI Total POCI Total Amounts in Eur ΄000 1 2 3 1 2 3 1 2 3 ECL allowance as at 1/1/2023 750 3 305 0 1,058 11,992 2,719 3,205 0 17,916 12,742 2,722 3,510 0 18,974 Transferred from Stage 1 to Stage 2 or Stage 3 (2) 2 0 0 0 (1,186) 1,108 7 71 0 (1,188) 1,110 7 71 0 Transferred from Stage 2 to Stage 1 or Stage 3 3 (4) 1 0 0 1,204 (1,460) 256 0 0 1,207 (1,464) 257 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 36 (36) 0 0 2 131 (133) 0 0 2 167 (169) 0 0 Allowances: (149) (28) 1,725 0 1,548 967 1,996 4,780 (49) 7,694 818 1,968 6,505 (49) 9,242 ECL impairment charge/(release) for the year (P&L) (656) (28) 1,725 0 1,041 (11,380) 765 4,780 (49) (5,884) (12,036) 737 6,505 (49) (4,843) ECL impairment charge for new financial assets originated or purchased (P&L) 507 0 0 0 507 12,347 1,231 0 0 13,578 12,854 1,231 0 0 14,085 Write-offs 0 0 (186) 0 (186) 0 0 (570) 0 (570) 0 0 (756) 0 (756) ECL allowance as at 31/12/23 602 9 1,809 0 2,420 12,979 4,494 7,545 22 25,040 13,581 4,503 9,354 22 27,460
63
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Movement in ECL allowance of commitments relevant to credit risk 31/12/2024 Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total ECL allowance as at 1/1/2024 1,753 25 0 0 1,779 Transferred from Stage 1 to Stage 2 or Stage 3 (192) 192 0 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 15 (15) 0 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 0 0 0 0 Allowances 1,375 494 0 0 1,869 ECL impairment charge/(release) for the year (P&L) 643 494 0 0 1,137 ECL impairment charge for new financial assets originated or purchased (P&L) 732 0 0 0 732 ECL allowance as at 31/12/24 2,951 696 0 0 3,648
Movement in ECL allowance of commitments relevant to credit risk 31/12/2023 Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total ECL allowance as at 1/1/2023 1,631 338 0 0 1,969 Transferred from Stage 1 to Stage 2 or Stage 3 (6) 6 0 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 229 (229) 0 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 0 0 0 0 Allowances (100) (90) 0 0 (191) ECL impairment charge/(release) for the year (P&L) (988) (89) 0 0 (1,077) ECL impairment charge for new financial assets originated or purchased (P&L) 887 0 0 0 887 ECL allowance as at 31/12/23 1,753 25 0 0 1,779
64
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Movement in ECL allowance of commitments relevant to credit risk 31/12/2024 Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total ECL allowance as at 1/1/2024 1,753 26 0 0 1,779 Transferred from Stage 1 to Stage 2 or Stage 3 (192) 192 0 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 15 (15) 0 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 0 0 0 0 Allowances 1,375 494 0 0 1,869 ECL impairment charge/(release) for the year (P&L) 643 494 0 0 1,137 ECL impairment charge for new financial assets originated or purchased (P&L) 732 0 0 0 732 ECL allowance as at 31/12/24 2,951 697 0 0 3,648
Movement in ECL allowance of commitments relevant to credit risk 31/12/2023 Amounts in Eur ΄000 Stage 1 Stage 2 Stage 3 POCI Total ECL allowance as at 1/1/2023 1,631 338 0 0 1,969 Transferred from Stage 1 to Stage 2 or Stage 3 (6) 6 0 0 0 Transferred from Stage 2 to Stage 1 or Stage 3 229 (229) 0 0 0 Transferred from Stage 3 & POCI to Stage 1 or Stage 2 0 0 0 0 0 Allowances (101) (89) 0 0 (191) ECL impairment charge/(release) for the year (P&L) (988) (89) 0 0 (1,077) ECL impairment charge for new financial assets originated or purchased (P&L) 887 0 0 0 887 ECL allowance as at 31/12/23 1,753 26 0 0 1,779
65
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Credit quality of Loans and advances to customers and value of collaterals Amounts in Eur ΄000 Strong credit quality Satisfactory credit quality Watch list Default Not rated Value of Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage collaterals 31/12/2024 POCI 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 Individuals Consumer, personal & other 8,344 0 0 27 0 0 134 29 0 0 0 19 26,460 0 0 0 98,783 Mortgages 0 0 0 132,641 0 0 0 0 0 0 0 0 0 0 0 0 172,918 Corporate Large Corporate 1,054,455 0 0 515,020 0 0 37,221 99,297 0 0 0 11,720 0 0 0 0 1,173,174 SMEs 670,629 0 0 868,677 0 0 63,069 132,238 0 0 0 19,426 10,961 0 0 7,132 1,659,310 Total 1,733,428 0 0 1,516,365 0 0 100,424 231,564 0 0 0 31,165 37,421 0 0 7,132 3,104,185
Credit quality of Loans and advances to customers and value of collaterals Amounts in Eur ΄000 Strong credit quality Satisfactory credit quality Watch list Default Not rated Value of Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage collaterals 31/12/2023 POCI 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 Individuals Consumer, personal & other 5,231 0 0 981 0 0 480 19 0 0 0 1,801 24,241 0 0 0 105,750 Mortgages 27,352 0 0 70,838 0 0 0 0 0 0 0 9 0 0 0 0 122,231 Corporate Large Corporate 578,286 0 0 362,745 0 0 71,663 40,182 0 0 0 1,980 0 0 0 0 871,094 SMEs 445,349 0 0 694,237 0 0 29,777 84,412 0 0 0 7,338 5,650 0 0 5,938 1,143,736 Total 1,056,218 0 0 1,128,801 0 0 101,920 124,613 0 0 0 11,128 29,891 0 0 5,938 2,242,811
66
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Credit quality of Loans and advances to customers and value of collaterals Amounts in Eur ΄000 Strong credit quality Satisfactory credit quality Watch list Default Not rated Value of Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage 31/12/2024 POCI collaterals 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 Individuals Consumer, personal & other 8,344 0 0 27 0 0 134 29 0 0 0 19 26,460 0 0 0 98,783 Mortgages 0 0 0 132,641 0 0 0 0 0 0 0 0 0 0 0 0 172,918 Corporate Large Corporate 1,170,292 0 0 482,778 0 0 32,106 92,428 0 0 0 11,720 0 0 0 0 1,073,554 SMEs 642,996 0 0 827,337 0 0 49,979 126,352 0 0 0 19,250 10,961 0 0 7,132 1,532,019 Total 1,821,632 0 0 1,442,783 0 0 82,219 218,809 0 0 0 30,989 37,421 0 0 7,132 2,877,274
Credit quality of Loans and advances to customers and value of collaterals Amounts in Eur ΄000 Strong credit quality Satisfactory credit quality Watch list Default Not rated Value of Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage Stage 31/12/2023 POCI collaterals 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 Individuals Consumer, personal & other 5,231 0 0 981 0 0 480 19 0 0 0 1,801 24,241 0 0 0 105,750 Mortgages 27,353 0 0 70,837 0 0 0 0 0 0 0 9 0 0 0 0 122,231 Corporate Large Corporate 665,714 0 0 336,942 0 0 71,662 40,182 0 0 0 1,980 0 0 0 0 786,563 SMEs 423,903 0 0 648,248 0 0 20,611 84,412 0 0 0 7,338 5,650 0 0 5,938 1,041,769 Total 1,122,201 0 0 1,057,008 0 0 92,753 124,613 0 0 0 11,128 29,891 0 0 5,938 2,056,313
67
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Individuals Amounts in Eur ΄000 Large corporates SMEs 31/12/2024 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 34,599 7 0 0 117,662 0 0 0 From 1 to 30 days 366 10 1 0 14,979 0 0 0 From 31 to 60 days 0 11 0 0 0 0 0 0 From 61 to 90 days 0 1 0 0 0 0 0 0 From 91 to 180 days 0 0 2 0 0 0 0 0 From 181 to 365 days 0 0 8 0 0 0 0 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 8 0 0 0 0 0 Total 34,965 29 19 0 132,641 0 0 0 Impairments 127 3 19 0 371 0 0 0 Net value 34,838 26 0 0 132,270 0 0 0 Collaterals 98,783 0 0 0 172,918 0 0 0
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Corporate Amounts in Eur ΄000 Large corporates SMEs 31/12/2024 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 1,466,481 88,026 1,469 0 1,518,348 116,945 2,289 7,030 From 1 to 30 days 140,215 6,709 4,991 0 94,988 3,261 3,578 0 From 31 to 60 days 0 4,562 0 0 0 11,961 1,547 102 From 61 to 90 days 0 0 134 0 0 71 1,593 0 From 91 to 180 days 0 0 1,414 0 0 0 6,570 0 From 181 to 365 days 0 0 3,712 0 0 0 176 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 0 0 0 0 3,673 0 Total 1,606,696 99,297 11,720 0 1,613,336 132,238 19,426 7,132 Impairments 10,559 4,072 4,096 0 10,854 3,589 10,834 377 Net value 1,596,137 95,225 7,624 0 1,602,482 128,649 8,592 6,755 Collaterals 1,087,832 68,682 16,660 0 1,521,063 98,923 29,658 9,666
68
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Individuals Amounts in Eur ΄000 Large corporates SMEs 31/12/2023 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 30,745 9 0 0 89,104 0 9 0 From 1 to 30 days 180 3 2 0 9,086 0 0 0 From 31 to 60 days 0 6 0 0 0 0 0 0 From 61 to 90 days 0 1 1 0 0 0 0 0 From 91 to 180 days 0 0 1 0 0 0 0 0 From 181 to 365 days 0 0 1,745 0 0 0 0 0 More than 365 days 0 0 13 0 0 0 0 0 Denounced 0 0 39 0 0 0 0 0 Total 30,925 19 1,801 0 98,190 0 9 0 Impairments 244 9 1,801 0 358 0 8 0 Net value 30,681 10 0 0 97,832 0 1 0 Collaterals 105,750 0 0 0 122,231 0 0 0
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Corporate Amounts in Eur ΄000 Large corporates SMEs 31/12/2023 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 791,849 30,512 0 0 999,431 68,298 845 5,938 From 1 to 30 days 220,845 9,670 1,980 0 175,582 15,057 140 0 From 31 to 60 days 0 0 0 0 0 839 881 0 From 61 to 90 days 0 0 0 0 0 218 155 0 From 91 to 180 days 0 0 0 0 0 0 317 0 From 181 to 365 days 0 0 0 0 0 0 1,628 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 0 0 0 0 3,372 0 Total 1,012,694 40,182 1,980 0 1,175,013 84,412 7,338 5,938 Impairments 6,866 506 1,980 0 6,248 3,988 5,565 22 Net value 1,005,828 39,676 0 0 1,168,765 80,424 1,773 5,916 Collaterals 831,832 37,816 1,446 0 1,067,957 63,659 2,806 9,314
69
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Individuals Amounts in Eur ΄000 Large corporates SMEs 31/12/2024 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 34,599 7 0 0 117,662 0 0 0 From 1 to 30 days 366 10 1 0 14,979 0 0 0 From 31 to 60 days 0 11 0 0 0 0 0 0 From 61 to 90 days 0 1 0 0 0 0 0 0 From 91 to 180 days 0 0 2 0 0 0 0 0 From 181 to 365 days 0 0 8 0 0 0 0 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 8 0 0 0 0 0 Total 34,965 29 19 0 132,641 0 0 0 Impairments 127 3 19 0 371 0 0 0 Net value 34,838 26 0 0 132,270 0 0 0 Collaterals 98,783 0 0 0 172,918 0 0 0
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Corporate Amounts in Eur ΄000 Large corporates SMEs 31/12/2024 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 1,544,961 81,157 1,469 0 1,436,285 111,059 2,289 7,030 From 1 to 30 days 140,215 6,709 4,991 0 94,988 3,261 3,578 0 From 31 to 60 days 0 4,562 0 0 0 11,961 1,547 102 From 61 to 90 days 0 0 134 0 0 71 1,593 0 From 91 to 180 days 0 0 1,414 0 0 0 6,570 0 From 181 to 365 days 0 0 3,712 0 0 0 0 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 0 0 0 0 3,673 0 Total 1,685,176 92,428 11,720 0 1,531,273 126,352 19,250 7,132 Impairments 10,492 4,064 4,096 0 10,616 3,562 10,658 377 Net value 1,674,684 88,364 7,624 0 1,520,657 122,790 8,592 6,755 Collaterals 998,304 58,590 16,660 0 1,401,726 90,969 29,658 9,666
70
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Individuals Amounts in Eur ΄000 Large corporates SMEs 31/12/2023 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 30,753 8 0 0 89,103 0 9 0 From 1 to 30 days 180 3 2 0 9,087 0 0 0 From 31 to 60 days 0 7 0 0 0 0 0 0 From 61 to 90 days 0 1 1 0 0 0 0 0 From 91 to 180 days 0 0 1 0 0 0 0 0 From 181 to 365 days 0 0 1,745 0 0 0 0 0 More than 365 days 0 0 13 0 0 0 0 0 Denounced 0 0 39 0 0 0 0 0 Total 30,933 19 1,801 0 98,190 0 9 0 Impairments 244 9 1,801 0 358 0 8 0 Net value 30,689 10 0 0 97,832 0 1 0 Collaterals 105,750 0 0 0 122,231 0 0 0
Loans and advances to customers and impairment provisions per IFRS 9 Stage - Corporate Amounts in Eur ΄000 Large corporates SMEs 31/12/2023 Stage 1 Stage 2 Stage 3 POCI Stage 1 Stage 2 Stage 3 POCI Performing 853,474 30,512 0 0 922,830 68,298 845 5,938 From 1 to 30 days 220,844 9,670 1,980 0 175,582 15,057 140 0 From 31 to 60 days 0 0 0 0 0 839 881 0 From 61 to 90 days 0 0 0 0 0 218 155 0 From 91 to 180 days 0 0 0 0 0 0 317 0 From 181 to 365 days 0 0 0 0 0 0 1,628 0 More than 365 days 0 0 0 0 0 0 0 0 Denounced 0 0 0 0 0 0 3,372 0 Total 1,074,318 40,182 1,980 0 1,098,412 84,412 7,338 5,938 Impairments 6,856 506 1,980 0 6,123 3,988 5,565 22 Net value 1,067,462 39,676 0 0 1,092,289 80,424 1,773 5,916 Collaterals 747,301 37,816 1,446 0 965,990 63,659 2,806 9,314
71
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Loan-to-value ratio (LTV) Amounts in Eur ΄000 31/12/2024 Mortgages Total loans Impairments < 50% 6,074 2 51% - 70% 17,217 8 71% -90% 98,312 322 91% - 100% 7,512 11 > 100% 3,526 28 Total 132,641 371 Simple average of LTV (%) 77% Loan-to-value ratio (LTV) Amounts in Eur ΄000 31/12/2023 Mortgages Total loans Impairments < 50% 3,519 1 51% - 70% 8,950 4 71% -90% 79,529 334 91% - 100% 2,894 8 > 100% 3,307 19 Total 98,199 366 Simple average of LTV (%) 79%
72
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Loan-to-value ratio (LTV) Amounts in Eur ΄000 31/12/2024 Mortgages Total loans Impairments < 50% 6,074 2 51% - 70% 17,217 8 71% -90% 98,312 323 91% - 100% 7,512 11 > 100% 3,526 28 Total 132,641 372 Simple average of LTV (%) 77% Loan-to-value ratio (LTV) Amounts in Eur ΄000 31/12/2023 Mortgages Total loans Impairments < 50% 3,519 1 51% - 70% 8,950 4 71% -90% 79,529 334 91% - 100% 2,894 8 > 100% 3,307 19 Total 98,199 366 Simple average of LTV (%) 79%
73
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Amounts in Eur ΄000 Government Real estate collaterals Financial collaterals Other collaterals Total collaterals 31/12/2024 guarantees Individuals 162,202 100,610 0 10,266 273,078 Corporate 1,239,830 226,543 42,443 1,407,867 2,916,683 Total 1,402,032 327,153 42,443 1,418,133 3,189,761
Amounts in Eur ΄000 Government Real estate collaterals Financial collaterals Other collaterals Total collaterals 31/12/2023 guarantees Individuals 113,432 107,762 0 8,862 230,056 Corporate 836,794 236,933 41,628 978,731 2,094,086 Total 950,226 344,695 41,628 987,593 2,324,142
Collaterals received include letters of guarantee of EUR 85,576 thousand. (31/12/23 EUR 81,331 thousand).
Bank
Amounts in Eur ΄000 Government Real estate collaterals Financial collaterals Other collaterals Total collaterals 31/12/2024 guarantees Individuals 162,202 100,610 0 10,266 273,078 Corporate 1,239,830 226,543 42,443 1,180,956 2,689,772 Total 1,402,032 327,153 42,443 1,191,222 2,962,850
Amounts in Eur ΄000 Government Real estate collaterals Financial collaterals Other collaterals Total collaterals 31/12/2023 guarantees Individuals 113,432 107,762 0 8,862 230,056 Corporate 836,794 236,933 41,628 792,233 1,907,588 Total 950,226 344,695 41,628 801,095 2,137,644
Collaterals received include letters of guarantee of EUR 85,576 thousand. (31/12/23 EUR 81,331 thousand).
Write-offs for the Bank and the Group for 2024 amounted to EUR 47 thousand (EUR 756 thousand 2023).
74
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bonds
Group
31/12/2024 Securities Expected measured at credit Expected Securities fair Securities loss at fair credit measured at Debt Securities value through measured at Total value through loss at Total ECL fair other amortised cost other amortised value comprehensive comprehensive cost income income Α- to ΑΑΑ 2,286 19,153 50,354 71,793 0 28 28 Β- to ΒΒΒ+ 44,839 191,199 333,685 569,723 62 485 547 C- to CCC+ 0 3,900 15,346 19,246 0 178 178 Not rated 0 38,066 15,263 53,329 0 112 112 Total 47,125 252,318 414,648 714,091 62 803 865
31/12/2023 Securities Expected measured at credit Expected Securities fair Securities loss at fair credit measured at Debt Securities value through measured at Total value through loss at Total ECL fair other amortised cost other amortised value comprehensive comprehensive cost income income Α- to ΑΑΑ 4,246 28,143 31,703 64,092 0 6 6 Β- to ΒΒΒ+ 81,972 250,999 215,085 548,056 81 306 387 C- to CCC+ 0 1,646 4,979 6,625 0 68 68 Not rated 0 46,503 0 46,503 0 0 0 Total 86,218 327,291 251,767 665,276 81 380 461
All securities in the portfolio measured through other comprehensive income and of the amortised cost portfolio
are classified at “Stage 1”.
75
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
31/12/2024 Securities Expected measured at credit Expected Securities fair Securities loss at fair credit measured at Debt Securities value through measured at Total value through loss at Total ECL fair other amortised cost other amortised value comprehensive comprehensive cost income income Α- to ΑΑΑ 2,286 19,153 50,354 71,793 0 28 28 Β- to ΒΒΒ+ 44,839 191,199 333,685 569,723 62 485 547 C- to CCC+ 0 3,900 15,346 19,246 0 178 178 Not rated 0 38,066 15,263 53,329 0 112 112 Total 47,125 252,318 414,648 714,091 62 803 865
31/12/2023 Securities Expected measured at credit Expected Securities fair Securities loss at fair credit measured at Debt Securities value through measured at Total value through loss at Total ECL fair other amortised cost other amortised value comprehensive comprehensive cost income income Α- to ΑΑΑ 4,246 28,143 31,703 64,092 0 6 6 Β- to ΒΒΒ+ 81,972 250,999 215,085 548,056 81 306 387 C- to CCC+ 0 1,646 4,979 6,625 0 68 68 Not rated 0 46,503 0 46,503 0 0 0 Total 86,218 327,291 251,767 665,276 81 380 461
All securities of the total income portfolio and the amortised cost portfolio are classified at “Stage 1”.
Counterparty banks risk
The Group is exposed to the risk of capital losses due to contingent delayed payments of outstanding and
contingent liabilities of counterparty banks. Through its daily operations, the Group deals with other banks and
financial institutions. By conducting such activities, the Group is exposed to the risk of capital losses due to
contingent delayed repayments to the Group of outstanding and contingent liabilities of counterparty banks.
According to the Policy and Procedure for Credit Risk Assessment of Institutional Counterparties the
responsibility of approving the relevant limits for counterparty risk and their classification per type of exposure
rests with the Bank's Credit Committee, following a recommendation from the unit which is competent for the
relationship, based on internal and/or external financial analyses.
The credit limit granted to each counterparty is divided into sub limits covering placements, bonds and shares
market, foreign exchange market and derivatives market. The open positions are compared to the limits on a
daily basis.
76
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Country risk
The Group is exposed to the risk of capital loss due to possible political, economic and other events that occur
in a specific country where the capital or cash of the Group have been placed or invested through various local
banks and financial institutions.
All countries are assessed according to size, economic data and prospectives of the country, as well as its credit
rating by international credit rating institutions (Moody’s). The actual positions per country are compared to
their limits on a daily basis. The limits are reviewed at the discretion of the Group, while countries with the
smaller size and lower solvency ratio are subject to a more thorough and frequent analysis and evaluation,
where considered necessary.
4.2. Market risk
Market risk is defined as the potential loss that can be caused to the Bank's portfolio by unexpected fluctuations
in the market value in individual areas of this portfolio. Portfolios facing this possibility are those exposed to
interest rate risk and/or currency risk and/or price risk. In many cases, the market risk may not be separated
from other types of risk or arise from them and the correlation between them.
The Group’s Asset Management Liability Committee (ALCO) approves the market risk management procedures
and has set the relevant limits for undertaking such a risk per product and portfolio. These limits are
systematically monitored and checked, while they are reviewed at least once a year; they are modified, if
necessary, depending on the Group’s strategy and prevailing market conditions.
The Risk Management Division proceeds with the measurement, control and monitoring of the Market Risk daily
and conducts measurements to estimate such risks for all individual portfolios.
(i)
Market risk of commercial and available-for-sale portfolios (portfolio measured at fair value through profit
and loss)
Measurements are made using various methodologies and measurement techniques such as Value At Risk –
VAR. The Value At Risk measurement determines the maximum potential loss of a portfolio the maximum
potential loss of a portfolio for a one-day time horizon with a 99% confidence level using the variance-covariance
method. The measurements cover all measured at fair value through profit and loss of the Group’s companies.
The market risk of the Group and the Bank, in terms of VaR, for the aforementioned positions on December 31,
2024, amounted to EUR 293 thousand and EUR 254 thousand respectively as analysed in the following table
77
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Amounts in Eur ΄00031/12/2024 31/12/2023 Foreign exchange risk 6 42 Bond portfolio interest rate risk 200 536 Stock market portfolio market risk 7 12 Commodities 91 27 Decrease due to correlation (50) (61) Subsidiaries price risk (Optima asset Management) 39 2 Total (Net Market Risk) 293 558
Bank
Amounts in Eur ΄00031/12/2024 31/12/2023 Foreign exchange risk 6 42 Bond portfolio interest rate risk 200 536 Stock market portfolio market risk 7 12 Commodities 91 27 Decrease due to correlation (50) (61) Total (Net Market Risk) 254 556
In addition to the above measurements, the market risk of the portfolios is monitored by a series of additional
limits, such as the maximum open position limit for each product and stop-loss limits for each portfolio.
Finally, at regular periods, and certainly at the end of each semester, measurements of various stress test
scenarios are carried out for the purpose of, on the one hand, the more effective management of such risk and,
on the other hand, the information of the Management and the supervisory authorities.
(ii)
Interest Rate Risk
The interest rate risk is the risk due to the fluctuations in interest rates which affect the exposure of the banking
portfolio and impacts both the capital and the profits of the Bank. The fluctuations in interest rates result in
changes in the Present Value (PV) and the future cash flows of the assets, the liabilities and the off-balance
sheet exposures of the Bank and consequently in the economic value of its equity (EVE). The fluctuations in
interest rates also affect the profit of the Bank, thus changing the income and expenses which are sensitive to
said fluctuations. Consequently, the net interest income (NII) is affected.
The following tables present the Group’s and the Bank’s exposure to interest rate risk. The tables present the
assets and liabilities of the Group and the Bank at their carrying amounts, classified according to the interest
rate repricing date, for floating interest rates or maturity date, for fixed interest rates.
78
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Non-Up to 1-33-121-22-5Over 5 interest Total 1 month months months yearsyearsyears Amounts in Eur ΄000bearing As at 31st December 2024 Assets Cash and balances with central bank 781,378 0 0 0 0 0 16,268 797,646 Due from banks 162,286 9,023 0 0 0 0 0 171,309 Financial assets at fair value through profit and loss 229,055 0 0 0 0 0 35,387 264,442 Loans and advances to customers 49,072 2,612,312 610,539 28,319 23,393 205,641 83,322 3,612,598 Financial assets at fair value through other comprehensive income 0 3,703 0 3,729 22,210 17,482 266 47,390 Debt instruments at amortised cost 0 39,845 30 16,754 207,211 150,004 0 413,844 Derivative financial instruments 0 0 0 0 0 0 2,210 2,210 Other assets 0 31,279 0 0 0 0 0 31,279 Total assets 1,221,791 2,696,162 610,569 48,802 252,814 373,127 137,453 5,340,718 Liabilities Due to banks 115,563 0 0 0 0 0 0 115,563 Due to customers 2,811,903 1,184,856 642,847 3,806 0 0 0 4,643,412 Derivative financial instruments 5,318 0 0 0 0 0 0 5,318 Other liabilities 0 0 0 0 0 0 717 717 Total liabilities 2,932,784 1,184,856 642,847 3,806 0 0 717 4,765,010 Total interest rate gap (1,710,993) 1,511,306 (32,278) 44,996 252,814 373,127 136,736 575,708
Non-Up to 1-33-121-22-5Over 5 interest Total 1 month months months yearsyearsyears Amounts in Eur ΄000bearing As at 31st December 2023 Assets Cash and balances with central bank 467,679 0 0 0 0 0 11,644 479,323 Due from banks 117,171 8,919 0 0 0 0 0 126,090 Financial assets at fair value through profit and loss 297,229 0 0 0 0 0 40,399 337,628 Loans and advances to customers 30,558 1,790,989 436,960 11,867 8,075 120,135 32,330 2,430,914 Financial assets at fair value through other comprehensive income 0 0 38,319 3,723 22,482 21,694 270 86,488 Debt instruments at amortised cost 0 0 22,701 12,141 133,122 83,424 0 251,388 Derivative financial instruments 0 0 0 0 0 0 1,033 1,033 Other assets 0 23,719 0 0 0 0 0 23,719 Total assets 912,637 1,823,627 497,980 27,731 163,679 225,253 85,676 3,736,583 Liabilities Due to banks 0 78,287 0 0 0 0 2,792 81,079 Due to customers 2,095,316 678,834 303,833 14,224 0 0 99,597 3,191,804 Derivative financial instruments 0 0 0 0 0 0 8,497 8,497 Other liabilities 0 0 0 0 0 0 181 181 Total liabilities 2,095,316 757,121 303,833 14,224 0 0 111,067 3,281,561 Total interest rate gap (1,182,679) 1,066,506 194,147 13,507 163,679 225,253 (25,391) 455,022
79
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Non-Up to 1-3 3-12 1-2 2-5 Over 5 interest Total 1 month months months years years years Amounts in Eur ΄000bearing As at 31st December 2024 Assets Cash and balances with central bank 781,378 0 0 0 0 0 16,267 797,645 Due from banks 151,204 8,953 0 0 0 0 0 160,157 Financial assets at fair value through profit and loss 226,239 0 0 0 0 0 35,387 261,626 Loans and advances to customers 70,027 2,633,687 610,539 23,393 28,319 205,641 24,994 3,596,600 Financial assets at fair value through other comprehensive income 0 3,703 0 3,729 22,210 17,482 266 47,390 Debt instruments at amortised cost 0 39,845 30 16,754 207,211 150,004 0 413,844 Derivative financial instruments 0 0 0 0 0 0 2,210 2,210 Other assets 0 30,430 0 0 0 0 0 30,430 Total assets 1,228,848 2,716,618 610,569 43,876 257,740 373,127 79,124 5,309,902 Liabilities Due to banks 115,563 0 0 0 0 0 0 115,563 Due to customers 2,822,555 1,184,856 642,847 3,806 0 0 0 4,654,064 Derivative financial instruments 5,318 0 0 0 0 0 0 5,318 Other liabilities 0 0 0 0 0 0 221 221 Total liabilities 2,943,436 1,184,856 642,847 3,806 0 0 221 4,775,166 Total interest rate gap (1,714,588) 1,531,762 (32,278) 40,070 257,740 373,127 78,903 534,736
Non-Up to 1-3 3-12 1-2 2-5 Over 5 interest Total 1 month months months years years years Amounts in Eur ΄000bearing As at 31st December 2023 Assets Cash and balances with central bank 467,679 0 0 0 0 0 11,643 479,322 Due from banks 114,705 8,920 0 0 0 0 0 123,625 Financial assets at fair value through profit and loss 296,595 0 0 0 0 0 40,399 336,994 Loans and advances to customers 30,558 1,775,609 436,960 11,867 8,075 120,135 32,868 2,416,072 Financial assets at fair value through other comprehensive income 0 0 38,319 3,723 22,482 21,694 270 86,488 Debt instruments at amortised cost 0 0 22,701 12,141 133,122 83,424 0 251,388 Derivative financial instruments 0 0 0 0 0 0 1,033 1,033 Other assets 0 23,719 0 0 0 0 0 23,719 Total assets 909,537 1,808,248 497,980 27,731 163,679 225,253 86,213 3,718,641 Liabilities Due to banks 0 78,287 0 0 0 0 768 79,055 Due to customers 2,095,316 678,834 303,833 14,224 0 0 104,704 3,196,911 Derivative financial instruments 0 0 0 0 0 0 8,497 8,497 Other liabilities 0 0 0 0 0 0 181 181 Total liabilities 2,095,316 757,121 303,833 14,224 0 0 114,150 3,284,644 Total interest rate gap (1,185,779) 1,051,127 194,147 13,507 163,679 225,253 (27,937) 433,997
(iii)
Foreign exchange risk
Foreign exchange risk is the risk of fluctuation of the value of financial instruments and assets and liabilities
due to changes in exchange rates. Foreign exchange transaction risk arises from an open position, positive or
negative, which exposes the Group to exchange rate changes. Such a risk could arise in the event of assets
being carried in one currency while financed by liabilities in another, or from forwards and swaps, as well as
derivatives, including options.
80
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The following tables present the Group’s and the Bank’s exposure to foreign exchange risk. The following tables
present the carrying amount of the assets and liabilities of the Group and the Bank, classified per currency.
Group
Other Amounts to Eur '000 EUR USD GBP CHF JPY Currencies Total As at 31st December 2024 Foreign exchange risk - Assets Cash and balances with central bank 795,752 1,127 163 515 44 45 797,646 Due from banks 50,716 96,276 9,821 189 1 14,306 171,309 Financial assets measured at fair value through profit or loss 264,442 0 0 0 0 0 264,442 Derivative financial instruments 2,085 125 0 0 0 0 2,210 Loans and advances to customers 3,510,921 96,665 5,012 0 0 0 3,612,598 Financial assets measured at fair value through other comprehensive income 47,390 0 0 0 0 0 47,390 Debt securities at amortised cost 403,831 10,013 0 0 0 0 413,844 Investment in subsidiaries and associates 609 0 0 0 0 0 609 Property, plant and equipment 10,717 0 0 0 0 0 10,717 Intangible assets 11,396 0 0 0 0 0 11,396 Right of use assets 19,595 0 0 0 0 0 19,595 Deferred tax assets 9,685 0 0 0 0 0 9,685 Other assets 172,776 5,160 734 339 170 327 179,506 Total assets 5,299,915 209,366 15,730 1,043 215 14,678 5,540,947 Foreign exchange risk - Liabilities Due to banks 109,263 174 6,120 6 0 0 115,563 Due to customers 4,149,662 469,650 9,612 950 215 13,323 4,643,412 Derivative financial instruments 5,315 3 0 0 0 0 5,318 Lease liability 21,220 0 0 0 0 0 21,220 Retirement benefit obligations 1,027 0 0 0 0 0 1,027 Income tax liability 5,637 (64) 0 0 0 0 5,573 Other liabilities 124,180 178 10 0 0 0 124,368 Provisions 4,167 0 0 0 0 0 4,167 Total liabilities 4,420,471 469,941 15,742 956 215 13,323 4,920,648 Net on balance sheet position 879,444 (260,575) (12) 87 0 1,355 620,299
81
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Other Amounts to Eur '000 EUR USD GBP CHF JPY Currencies Total As at 31st December 2023 Foreign exchange risk - Assets Cash and balances with central bank 477,887 1,025 158 172 0 81 479,323 Due from banks 45,080 45,932 10,389 24 86 24,579 126,090 Financial assets measured at fair value through profit or loss 337,628 0 0 0 0 0 337,628 Derivative financial instruments 1,029 4 0 0 0 0 1,033 Loans and advances to customers 2,401,649 21,250 8,015 0 0 0 2,430,914 Financial assets measured at fair value through other comprehensive income 86,488 0 0 0 0 0 86,488 Debt securities at amortised cost 251,388 0 0 0 0 0 251,388 Investment in subsidiaries and associates 260 0 0 0 0 0 260 Property, plant and equipment 10,903 0 0 0 0 0 10,903 Intangible assets 10,805 0 0 0 0 0 10,805 Right of use assets 19,508 0 0 0 0 0 19,508 Deferred tax assets 8,079 0 0 0 0 0 8,079 Other assets 99,648 5,283 225 296 57 341 105,850 Total assets 3,750,352 73,494 18,787 492 143 25,001 3,868,269 Foreign exchange risk - Liabilities Due to banks 33,138 42,136 5,799 6 0 0 81,079 Due to customers 2,797,276 355,926 13,164 441 223 24,774 3,191,804 Derivative financial instruments 8,482 15 0 0 0 0 8,497 Lease liability 20,861 0 0 0 0 0 20,861 Retirement benefit obligations 692 0 0 0 0 0 692 Income tax liability 12,316 (90) 0 0 0 0 12,226 Other liabilities 40,057 601 4 0 0 5 40,667 Provisions 2,366 0 0 0 0 0 2,366 Total liabilities 2,915,188 398,588 18,967 447 223 24,779 3,358,192 Net on balance sheet position 835,164 (325,094) (180) 45 (80) 222 510,077
82
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Other Amounts to Eur '000 EUR USD GBP CHF JPY Currencies Total As at 31st December 2024 Foreign exchange risk - Assets Cash and balances with central bank 795,751 1,127 163 515 44 45 797,645 Due from banks 39,572 96,268 9,821 189 1 14,306 160,157 Financial assets measured at fair value through profit or loss 261,626 0 0 0 0 0 261,626 Derivative financial instruments 2,085 125 0 0 0 0 2,210 Loans and advances to customers 3,493,440 98,147 5,012 0 0 0 3,596,599 Financial assets measured at fair value through other comprehensive income 47,390 0 0 0 0 0 47,390 Debt securities at amortised cost 403,832 10,013 0 0 0 0 413,845 Investment in subsidiaries and associates 23,972 0 0 0 0 0 23,972 Property, plant and equipment 10,588 0 0 0 0 0 10,588 Intangible assets 8,193 0 0 0 0 0 8,193 Right of use assets 19,561 0 0 0 0 0 19,561 Deferred tax assets 10,603 0 0 0 0 0 10,603 Other assets 173,074 5,160 734 339 170 327 179,804 Total assets 5,289,687 210,840 15,730 1,043 215 14,678 5,532,193 Foreign exchange risk - Liabilities Due to central bank 0 0 0 0 0 0 0 Due to banks 109,263 174 6,120 6 0 0 115,563 Due to customers 4,158,797 471,167 9,612 950 215 13,323 4,654,064 Derivative financial instruments 5,315 3 0 0 0 0 5,318 Lease liability 21,188 0 0 0 0 0 21,188 Retirement benefit obligations 964 0 0 0 0 0 964 Income tax liability 5,025 (64) 0 0 0 0 4,961 Other liabilities 122,745 178 10 0 0 0 122,933 Provisions 4,157 0 0 0 0 0 4,157 Total liabilities 4,427,454 471,458 15,742 956 215 13,323 4,929,148 Net on balance sheet position 862,233 (260,618) (12) 87 0 1,355 603,045
83
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Other Amounts to Eur '000 EUR USD GBP CHF JPY Currencies Total As at 31st December 2023 Foreign exchange risk - Assets Cash and balances with central bank 477,886 1,025 158 172 0 81 479,322 Due from banks 42,615 45,932 10,389 24 86 24,579 123,625 Financial assets measured at fair value through profit or loss 336,994 0 0 0 0 0 336,994 Derivative financial instruments 1,029 4 0 0 0 0 1,033 Loans and advances to customers 2,386,266 21,791 8,015 0 0 0 2,416,072 Financial assets measured at fair value through other comprehensive income 86,488 0 0 0 0 0 86,488 Debt securities at amortised cost 251,388 0 0 0 0 0 251,388 Investment in subsidiaries and associates 9,134 0 0 0 0 0 9,134 Property, plant and equipment 10,738 0 0 0 0 0 10,738 Intangible assets 7,421 0 0 0 0 0 7,421 Right of use assets 19,478 0 0 0 0 0 19,478 Deferred tax assets 8,938 0 0 0 0 0 8,938 Other assets 98,373 5,283 225 296 57 341 104,575 Total assets 3,736,748 74,035 18,787 492 143 25,001 3,855,206 Foreign exchange risk - Liabilities Due to central bank 0 0 0 0 0 0 0 Due to banks 30,574 42,676 5,799 6 0 0 79,055 Due to customers 2,802,369 355,940 13,164 441 223 24,774 3,196,911 Derivative financial instruments 8,482 15 0 0 0 0 8,497 Lease liability 20,834 0 0 0 0 0 20,834 Retirement benefit obligations 650 0 0 0 0 0 650 Income tax liability 11,581 (90) 0 0 0 0 11,491 Other liabilities 38,472 601 4 0 0 5 39,082 Provisions 2,356 0 0 0 0 0 2,356 Total liabilities 2,915,318 399,142 18,967 447 223 24,779 3,358,876 Net on balance sheet position 821,430 (325,107) (180) 45 (80) 222 496,330
The crisis simulation examines the negative effect on the Bank’s annual profit or loss using possible scenarios
of the fluctuation of the international exchange rates. The examined scenarios include the following fluctuations
in the key currencies: Eur/Usd +15.6%, Eur/Gbp +25.7%, Eur/Chf -12%, Eur/Jpy +16.10%, Eur/Aud +20.8%,
Eur/Nok +14.2%,Eur/Cad +16.4%, Eur/Sek +14.5%, Eur/Try +48.7%, Eur/Rub +34.3%, Eur/Dkk +20.8%,
Eur/Ron +19.5%, Eur/Hkd +17%, Eur/Czk +15,4%, Eur/Pln +17,5%, Eur/Aed +20.8%. With closing balances
as of 31/12/2024, the simulation results in losses of EUR 95.80 thousand.
Risk arising from share and other securities price changes
Group
The risk regarding the shares and other securities held by the Group arises from possible negative fluctuations
of the current prices of shares and other securities. The Group invests mainly in government bonds, corporate
bonds traded both on international markets and on the Athens Stock Exchange, as well as in equity securities
of the Athens Stock Exchange. Depending on the business purpose of the investment, they are allocated to the
appropriate portfolio (assessment at fair value through profit or loss or the other comprehensive income).
The Group, as a measure of price risk assessment, calculates the negative impact on its annual results after
taxes from a change in share prices.
84
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
The risk of share prices relates to adverse fluctuations of shares’ prices and derivatives on shares and stock
exchange ratios held by the Bank in the portfolio measured at fair value through profit or loss.
This risk is monitored through limits set for each share and/or group of shares and furthermore techniques are
applied to reduce it through derivatives on the respective shares and indices. Consequently, no significant
exposure to this risk has been observed in 2024 beyond the risk undertaking levels set by the net of levels dully
approved on the basis of the Bank’s strategy.
The following table presents the results of the stress test regarding share price risks conducted on the portfolio
held for trading and on the portfolio available for sale using balances as of 31/12/2024.
The scenarios examined are the following:
Regarding shares price risk (since the exposure of the portfolios focuses on the Greek market), the FTSE/ASE
Large Cap. +/-56% fluctuation scenario was examined, as well as the S&P +/-55% fluctuation scenario.
Risk factors Unfavorable Favorable Markets Amounts in Eur '000 scenario scenario ASE movement of FTSE/Stock Exchange 377 (220) Large Cap. Shares prices Change in S&P 655 (424) Total 1,032 (644)
The total bond portfolio held by the Bank on 31/12/2024 amounts to EUR 687,207 thousand and is analysed as
follows:
- Portfolio measured at fair value through profit or loss 226,238 - Portfolio measured at fair value through other comprehensive income 47,125 - Portfolio measured at amortised cost 413,844
The above amount does not include the "Bond from loan securitisation" of EUR 26.080 thousand.
In accordance with the business model followed by the Bank for the management of its securities, these are held
in separate portfolios with the aim of
• exclusive collection of contractual cash flows
• both the collection of contractual cash flows and their sale
• mainly the sale of securities
The positions in the above portfolios consist mainly of Greek and Italian government bonds, interest-bearing Greek
government bills as well as Greek corporate and bank bonds.
The Management of the Bank is informed on a daily basis about the bond transactions, the position and the
valuation of the bonds.
The following table presents the losses and gains that would arise on the bond portfolio measured at fair value
through profit or loss excluding the Bond from loan securitization and on the bond portfolio measured at fair value
through other income, in case of a parallel shift in the bond yield curve by +/- 200 basis points:
85
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Risk factors Scenario Portfolio +200 Bps -200 Bps Amounts in Eur ‘000 Fair Value through P&L Portfolio (FVTPL) (3,380) 3,679 Movement of Interest rate swaps 4,339 (5,393) Bond yield curves bonds’ yield Fair Value through other comprehensive curves (3,466) 3,499 income Portfolio (FVTOCI) Totals (2,507) 1,786
In 2024 the Bank was also involved in the trading of carbon emission rights.
As part of the simulation exercise for its positions, the Bank examined the scenario of the decrease in the
ICEDEU3 Index at a rate of -41%, with a time horizon of one day. The test resulted in gains of EUR 14.97
thousand.
4.3. Liquidity risk
Liquidity risk is the risk of not being able to find sufficient liquid assets to cover the Group’s immediate
obligations, or of finding them at a high financial cost to the Group.
The above risk is controlled through a developed liquidity management structure, consisting of various types
of controls, procedures and limits. In this way, compliance with the regulations on liquidity ratios of the
competent supervisory authorities, as well as with internal limits, is ensured.
The control and management of liquidity risk is achieved through the use and control of the following ratios:
(a) Liquidity Coverage Ratio (LCR): It is defined as the ratio of the high-quality liquid assets reserve to the net
cash outflows of 30 days, as specified in Regulation (EU) 575/2013.
(b) Net Stable Funding Ratio (NSFR): It is defined as the ratio of the available amount of stable funding to the
required amount of stable funding, as specified in Regulation (EU) No. 575/2013. A significant part of the assets
is financed by customer deposits. Immediate cash needs are financed mainly by demand and savings deposits.
The financing of long-term investments is mainly covered by long-term liabilities and by Equity.
Although these deposits can be withdrawn without notice if requested, the dispersion in number and type of
deposits ensures the absence of significant fluctuations and therefore they constitute a stable deposit base for
the most part. The Group carries out crisis simulations in the area of liquidity.
The following liquidity risk tables analyze the Group's and the Bank's liabilities to other banks, customer deposits
and other liabilities to customers in the relevant periods, depending on the remaining period from the reporting
date to their maturity. The amounts reported are the contractual undiscounted cash flows.
86
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Group
Up to 1-3 3-12 1-2 2-5 Over 5 Total Amounts in Eur ‘000 1 month months months years years years As at 31st December 2024 LIABILITIES Due to banks 115,563 0 0 0 0 0 115,563 Due to customers 2,811,903 1,184,856 642,847 3,806 0 0 4,643,412 Derivative financial instruments 5,318 0 0 0 0 0 5,318 Lease Liability 329 661 3,005 4,045 9,917 6,135 24,092 Retirement benefit obligations 0 0 0 0 0 1,027 1,027 Income tax liability 0 0 5,573 0 0 0 5,573 Other liabilities 0 96,144 28,224 0 0 0 124,368 Provisions 0 0 0 0 0 4,167 4,167 Total liabilities 2,933,113 1,281,661 679,649 7,851 9,917 11,329 4,923,520
Up to 1-3 3-12 1-2 2-5 Over 5 Total Amounts in Eur ‘0001 month months months years years years As at 31st December 2023 LIABILITIES Due to banks 81,079 0 0 0 0 0 81,079 Due to customers 2,194,913 678,834 303,833 14,224 0 0 3,191,804 Derivative financial instruments 8,497 0 0 0 0 0 8,497 Lease Liability 282 565 2,548 3,425 9,724 7,301 23,845 Retirement benefit obligations 0 0 0 0 0 692 692 Income tax liability 0 0 12,226 0 0 0 12,226 Other liabilities 0 10,480 30,187 0 0 0 40,667 Provisions 0 0 0 0 0 2,366 2,366 Total liabilities 2,284,771 689,879 348,794 17,649 9,724 10,359 3,361,176
Bank
Up to 1-3 3-12 1-2 2-5 Over 5 Total Amounts in Eur ‘0001 month months months years years years As at 31st December 2024 LIABILITIES Due to banks 115,563 0 0 0 0 0 115,563 Due to customers 2,822,555 1,184,856 642,847 3,806 0 0 4,654,064 Derivative financial instruments 5,318 0 0 0 0 0 5,318 Lease Liability 327 656 2,992 4,033 9,911 6,136 24,055 Retirement benefit obligations 0 0 0 0 0 964 964 Income tax liability 0 0 4,961 0 0 0 4,961 Other liabilities 0 95,570 27,363 0 0 0 122,933 Provisions 0 0 0 0 0 4,157 4,157 Total liabilities 2,943,763 1,281,082 678,163 7,839 9,911 11,257 4,932,015
Up to 1-3 3-12 1-2 2-5 Over 5 Total Amounts in Eur ‘0001 month months months years years years As at 31st December 2023 LIABILITIES Due to banks 79,055 0 0 0 0 0 79,055 Due to customers 2,200,020 678,834 303,833 14,224 0 0 3,196,911 Derivative financial instruments 8,497 0 0 0 0 0 8,497 Lease Liability 281 562 2,540 3,410 9,722 7,301 23,816 Retirement benefit obligations 0 0 0 0 0 650 650 Income tax liability 0 0 11,491 0 0 0 11,491 Other liabilities 0 9,816 29,266 0 0 0 39,082 Provisions 0 0 0 0 0 2,356 2,356 Total liabilities 2,287,853 689,212 347,130 17,634 9,722 10,307 3,361,858
87
Notes to the Financial Statements dated December 31, 2024
Group and Bank
4.4. Capital adequacy
The Group is subject to the supervision of Bank of Greece which sets and monitors the Group’s capital adequacy
requirements.
For the calculation of the capital adequacy the Basel III regulatory framework is applied, which was incorporated
into the legislation of the European Union (EU) with the adoption of Regulation (EU) 575/2013 of the European
Parliament and of the Council ("CRR") regarding the requirements of prudential supervision for credit institutions
and investment companies, as amended and in force, as well as Directive 2013/36 (Capital Requirements
Directive-CRD IV) and in Greek legislation by Law 4261/2014, as amended and in force.
According to this (Article 92 paragraph 1 of Regulation (EU) No 575/2013), the minimum capital adequacy ratios
that each credit institution shall satisfy are the following:
• Minimum Common Equity Tier 1-CET1 capital ratio of 4.5%,
• minimum Tier 1 capital ratio of 6%,
• and minimum total capital ratio (TCR) of 8%.
Under Pillar I, the Capital Adequacy Ratio is calculated as the ratio of regulatory capital to total weighted assets
related to credit, operational and market risk and related to on- and off- balance sheet items at an individual
and consolidated level.
By force of the July 5,2024 decision of the Credit and Insurance Committee of the Bank of Greece
("Determination of supervisory requirements for the credit institution "Optima bank A.E." based on the
Supervisory Examination and Evaluation Procedure (EDEA)" the Bank is obliged to maintain individually and
consolidated basis total capital requirement EDEA (Total SREP Capital Ratio - TSCR) 10.10% and overall capital
requirement (Overall Capital Ratio - OCR) 12.60%.
The same decision provides direction to the Group to maintain additional capital of 0.5%, in addition to the
total capital requirements of EDEA and the capital safety reserves, as Pillar 2 Capital Guidance which will be
covered by capital of common shares of the Tier 1 (CET1). The total capital requirements on an individual and
consolidated basis are detailed in the table below:
Total Capital Total Capital Requirements (%) Minimum Total Capital Ratio 8.00% Additional Pillar II Own Funds Requirements (P2R) 2.10% Total Capital Requirements EDEA (TSCR) 10.10% (Capital Conservation Buffer - CCB) 2.50% Overall Capital Requirements (OCR) 12.60% Pillar 2 Guidance – P2G 0.50% Overall Capital Requirements (OCR) & Pillar 2 Guidance (P2G) – (TRCR) 13.10%
88
Notes to the Financial Statements dated December 31, 2024
Group and Bank
More specifically, compliance with EDEA's overall capital requirements includes:
• The total capital requirements of Pillar I amounting to 8% which should be satisfied at all times in accordance
with article 92 paragraph 1 of Regulation (EU) no. 575/2013
• The additional capital requirements of Pillar II (P2R) amounting to 2.10% in the context of the implementation
of the provisions of article 96A paragraph 1 (a) of Law 4261/2014
• The capital requirement to maintain a capital conservation buffer (CCB) of 2.5% in accordance with article
122 of Law 4261/2014.
• the direction in terms of additional Equity (Pillar 2 Capital Guidance) of maintaining an amount of 0.5% plus
EDEA's total capital requirements and safety reserves.
The Capital Adequacy ratio of the Group and the Bank on 31/12/2024 and 31/12/2023 was structured as follows:
Group
Amounts in Eur ‘000 (1)31/12/202431/12/2024 31/12/2023 Share Capital 254,521 254,521 254,245 Share premium 84,114 84,114 84,114 Less: Treasury Shares (112) (112) (164) Other Reserves 30,155 30,152 27,211 Retained Earnings 210,582 160,282 112,961 Less: Intagible assets (10,775) (10,775) (10,116) Other regulatory adjustments 5,720 4,378 6,222 Common Equity Tier 1 Capital ( CET1) 574,205 522,560 474,473 Additional Tier 1 instruments (ΑΤ1) 0 0 0 Additional Tier 1 Capital (ΑΤ1) 0 0 0 Tier 1 Capital (TIER1) 574,205 522,560 474,473 Total regulatory capital 574,205 522,560 474,473 Total risk weighted assets 3,988,249 3,859,858 2,685,788 CET1 Capital Ratio 14.40% 13.54% 17.67% T1 Capital Ratio 14.40% 13.54% 17.67% Total Regulatory Capital Ratio (TRCR) 14.40% 13.54% 17.67%
Bank
(2)Amounts in Eur ‘000 31/12/202431/12/2024 31/12/2023 Share Capital 254,521 254,521 254,245 Share premium 84,114 84,114 84,114 Less: Treasury Shares (112) (112) (164) Other Reserves 29,087 29,084 26,314 Retained Earnings 194,422 145,676 100,133 Less: Intagible assets (8,193) (8,193) (7,421) Other regulatory adjustments 5,641 4,295 6,138 Common Equity Tier 1 Capital ( CET1) 559,480 509,385 463,358 Additional Tier 1 instruments (ΑΤ1) 0 0 0 Additional Tier 1 Capital (ΑΤ1) 0 0 0 Tier 1 Capital (TIER1) 559,480 509,385 463,358 Total regulatory capital 559,480 509,385 463,358 Total risk weighted assets 3,880,675 3,759,787 2,599,548 CET1 Capital Ratio 14.42% 13.55% 17.82% T1 Capital Ratio 14.42% 13.55% 17.82% Total Regulatory Capital Ratio (TRCR) 14.42% 13.55% 17.82%
(1) Items have been calculated including profits of the year (EUR 140,224 thousand) and incorporating a provision for dividend
distribution (EUR 41,014 thousand), which is subject to the approval of the Ordinary General Assembly.
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Notes to the Financial Statements dated December 31, 2024
Group and Bank
(2) Items have been calculated including profits of the year (EUR 136,712 thousand) and incorporating a provision for dividend
distribution (EUR 41,014 thousand), which is subject to the approval of the Ordinary General Assembly.
5. Fair value of financial assets and liabilities
5.1. Financial assets and liabilities not carried at fair value
The fair value represents the amount for which an asset could be replaced, or a liability settled, through an
orderly transaction on the main or most advantageous market on the date of the measurement and under
current market conditions (exit price). Differences may arise between the carrying amount and the fair value of
financial assets of the statement of financial position and liabilities. Loans and other advances, securities and
financial liabilities measured at amortised cost are not measured at fair value. The carrying amount of these
items, as presented in the financial statements, does not significantly differ from their fair value. In particular:
(a) Due from banks
Due from other banks mainly include short-term interbank placements as well as other receivables, such as
loans to credit institutions.
The vast majority of the placements have one-month maturity and therefore their fair value closely
approximates their carrying amount.
(b) Loans and advances to customers
Loans to customers are presented after deducting the provision for impairment. Most of the above are
charged at a floating rate and therefore their fair value closely approximates their carrying amount.
(c) Due to customers
The fair value of deposits without fixed maturity (savings and sight) is the amount that the Group should
repay upon whenever requested by the customer. Their fair value is equal to their carrying amount.
5.2. Fair Value Hierarchy
IFRS 13 defines the valuation and control procedures regarding the objectivity of the data used by these models.
The observable data are based on active markets and derived from independent sources, while non-observable
data refers to the Management assumptions and valuation models. These two methods for retrieving
information generate the following hierarchy:
Level 1 - Quoted prices in active markets for identical financial assets or financial liabilities. This level includes
listed shares, debt securities and listed derivatives.
Level 2 - Includes inputs other than the quoted prices included in Level 1. For similar financial asset or financial
liability, for prices from inactive markets and data which are available in the market and can be used in
calculating the value of the financial asset or financial liability. This level includes the majority of over-the-
counter (OTC) derivative contracts and various debt securities, the value of which is determined by valuation
models, discounted cash flows and similar techniques using data related to the prices of the underlying
securities, their volatility as well as interest rate curves such as ESTR and SOFR.
90
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Level 3 – Includes inputs that are not based on observable market data (unobservable inputs). The Group
adjusts the unobservable inputs according to the best possible information at its disposal and using in its
assessment assumptions that would be used by market participants for the valuation of the financial asset or
financial liability. This level includes capital investment and loan funds that are not traded in an active market,
and there are no similar products that are traded. The valuation is based on data, observations and assumptions
that require significant judgment from the Management.
Group
Fair value hierarchy as of December 31, 2024:
Financial assets measured at fair value
Amounts in Eur ‘000 31/12/2024 Total Level Level Level Total fair Financial assets measured at fair value accounting 1 2 3 value value Financial assets measured at fair value through profit and loss 238,362 0 26,080 264,442 264,442 Derivative financial instruments 56 2,154 0 2,210 2,210 Financial assets measured at fair value through other comprehensive income 47,390 0 0 47,390 47,390 Total 285,808 2,154 26,080 314,042 314,042
Level 3 includes a bond from loan securitisation which is calculated at fair value using the income approach
method through the application of the discounted cash flow method. Its valuation depends on unobservable
values which include future revenues, operating expenses and discount rates. The fair value of the bond from
loan securitisation held by the Group on 31/12/2024 was EUR 26,080 thousand and on 31/12/2023 EUR 30,696
thousand. For the valuation of the bond, 3 scenarios and the discount rate have been used rate”) ranges from
3% to 15% in the base scenario depending on the characteristics and quality of the loan portfolio.
If the discount rate increases by 2% in the categories where the discount rate used in the valuation is 15% and
increases by 1% in all other loan categories relative to the discount rate used in the valuation then the bond
price will be higher by EUR 600 thousand.
If the discount rate is reduced by 2% in the categories where the discount rate used in the valuation is 15%
and is reduced by 1% in all other loan categories relative to the discount rate used in the valuation then the
price of the bond will be smaller by EUR 600 thousand.
Amounts in Eur ‘000 31/12/2024 Total Level Level Level Total fair Financial liabilities measured at fair value accounting 1 2 3 value value Derivative financial instruments 37 5,281 0 5,318 5,318 Total 37 5,281 0 5,318 5,318
91
Notes to the Financial Statements dated December 31, 2024
Group and Bank
There was no transfer of financial assets and financial liabilities between Levels 1 and 2 during the periods
ended 31 December 2024 and 31 December 2023. During the periods ended December 31, 2024 and December
31, 2023, there was no transfer to and from Level 3.
Transfers between levels are considered to have occurred at the end of the reporting periods in which the
financial instruments were transferred.
Financial items not measured at fair value
Amounts in Eur ‘000 31/12/2024 Total Level Level Level Total fair Financial assets accounting 1 2 3 value value Due from banks 162,356 0 9,332 171,688 171,309 Loans and advances to customers 0 0 3,830,727 3,830,727 3,612,598 Debt securities at amortised cost 406,829 0 0 406,829 413,844 Total 569,185 0 3,840,059 4,409,244 4,197,751
The following methods and assumptions were used to estimate the fair value of the above financial instruments
on December 31, 2024 and 2023.
Due from banks: The vast majority of the interbank placements have one-month maturity and therefore
their fair value closely approximates their carrying amount. Fair value is calculated using discounted cash flow
models. Discount rates incorporate interest rate curves taking into account market data, expected credit risk
and specific Bank/customer parameters.
Loans and advances to customers at amortised cost: Fair value is calculated using discounted cash
flow models. Discount rates incorporate interest rate curves taking into account market data, expected credit
risk and specific Bank/customer parameters.
Debt securities at amortised cost: Fair value is calculated with prices traded in the market.
It is noted that at Group level there were no movements between levels.
Fair value hierarchy as of December 31, 2023:
Financial assets measured at fair value
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial assets measured at fair value accounting 1 2 3 value value Financial assets measured at fair value through profit and loss 306,932 0 30,696 337,628 337,628 Derivative financial instruments 131 902 0 1,033 1,033 Financial assets measured at fair value through other comprehensive income 86,488 0 0 86,488 86,488 Total 393,551 902 30,696 425,149 425,149
92
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial liabilities measured at fair value accounting 1 2 3 value value Derivative financial instruments 97 8,400 0 8,497 8,497 Financial liabilities measured at fair value through profit and loss 39 0 0 39 39 Total 136 8,400 0 8,536 8,536
Financial items not measured at fair value
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial assets accounting 1 2 3 value value Loans and advances to customers 0 0 2,621,878 2,621,878 2,430,914 Debt securities at amortised cost 246,881 0 0 246,881 251,388 Total 246,881 0 2,621,878 2,868,759 2,682,302
Movement of financial instruments at Level 3 Financial instruments measured at fair value through profit or loss Balance as at 1/1/2023 37,781 Gain/ (loss) recognised at profit or loss (135) Repayments (6,950) Balance as at 31/12/2023 30,696 Gain/ (loss) recognised at profit or loss 2,043 Repayments (6,659) Balance as at 31/12/2024 26,080
Bank
Fair value hierarchy as of December 31, 2024:
Financial assets measured at fair value
Amounts in Eur ‘000 31/12/2024 Total Level Level Level Total fair Financial assets measured at fair value accounting 1 2 3 value value Financial assets measured at fair value through profit and loss 235,546 0 26,080 261,626 261,626 Derivative financial instruments 56 2,154 0 2,210 2,210 Financial assets measured at fair value through other comprehensive income 47,390 0 0 47,390 47,390 Total 282,992 2,154 26,080 311,226 311,226
Level 3 includes a bond from loan securitisation which is calculated at fair value using the income approach
method through the application of the discounted cash flow method. Its valuation depends on unobservable
values which include future revenues, operating expenses and discount rates. The fair value of the bond from
loan securitisation held by the Group on 31/12/2024 was EUR 26,080 thousand and on 31/12/2023 EUR 30,696
thousand. For the valuation of the bond, 3 scenarios and the discount rate have been used rate”) ranges from
3% to 15% in the base scenario depending on the characteristics and quality of the loan portfolio.
If the discount rate increases by 2% in the categories where the discount rate used in the valuation is 15% and
increases by 1% in all other loan categories relative to the discount rate used in the valuation then the bond
price will be higher by EUR 600 thousand.
93
Notes to the Financial Statements dated December 31, 2024
Group and Bank
If the discount rate is reduced by 2% in the categories where the discount rate used in the valuation is 15%
and is reduced by 1% in all other loan categories relative to the discount rate used in the valuation then the
price of the bond will be smaller by EUR 600 thousand.
Amounts in Eur ‘000 31/12/2024 Total Total fair Financial liabilities measured at fair value Level 1 Level 2 Level 3 accounting value value Derivative financial instruments 37 5,281 0 5,318 5,318 Total 37 5,281 0 5,318 5,318
There was no transfer of financial assets and financial liabilities between Levels 1 and 2 during the periods
ended 31 December 2024 and 31 December 2023. During the periods ended December 31, 2024 and December
31, 2023, there was no transfer to and from Level 3.
Transfers between levels are considered to have occurred at the end of the reporting periods in which the
financial instruments were transferred.
Financial items not measured at fair value
Amounts in Eur ‘000 31/12/2024 Total Level Level Level Total fair Financial assets accounting 1 2 3 value value Due from banks 151,204 0 9,332 160,536 160,157 Loans and advances to customers 0 0 3,814,213 3,814,213 3,596,600 Debt securities at amortised cost 406,829 0 0 406,829 413,844 Total 558,033 0 3,823,545 4,381,578 4,170,601
Fair value hierarchy as of December 31, 2023:
Financial assets measured at fair value
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial assets measured at fair value accounting 1 2 3 value value Financial assets measured at fair value through profit and loss 306,298 0 30,696 336,994 336,994 Derivative financial instruments 131 902 0 1,033 1,033 Financial assets measured at fair value through other comprehensive income 86,488 0 0 86,488 86,488 Total 392,917 902 30,696 424,515 424,515
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial liabilities measured at fair value accounting 1 2 3 value value Derivative financial instruments 97 8,400 0 8,497 8,497 Financial liabilities measured at fair value through profit and loss 39 0 0 39 39 Total 136 8,400 0 8,536 8,536
94
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Financial items not measured at fair value
Amounts in Eur ‘000 31/12/2023 Total Level Level Level Total fair Financial assets accounting 1 2 3 value value Loans and advances to customers 0 0 2,606,901 2,606,901 2,416,072 Debt securities at amortised cost 246,881 0 0 246,881 251,388 Total 246,881 0 2,606,901 2,853,782 2,667,460
Movement of financial instruments at Level 3 Financial instruments measured at fair value through profit or loss Balance as at 1/1/2023 36,242 Gain/ (loss) recognised at profit or loss 1,404 Repayments (6,950) Balance as at 31/12/2023 30,696 Gain/ (loss) recognised at profit or loss 2,043 Repayments (6,659) Balance as at 31/12/2024 26,080
6. Net interest income
The breakdown of net interest income is as follows:
Group
1/1/2024 – 1/1/2023 – Amounts in Eur ‘000 31/12/2024 31/12/2023 Interest and similar income Interest on debt securities at amortised cost 16,614 8,476 Interest on loans at amortised cost 207,230 141,533 Interest on interbank transactions 18,618 12,427 Other interest income 785 734 Interest on debt securities measured at fair value through other comprehensive income 1,221 1,330 Total interest and similar income for financial instrument not measured at FVTPL 244,468 164,500 Debt securities at fair value through profit and loss 6,994 8,485 Interest derivatives 2,185 112 Total interest and similar income from financial instruments 253,647 173,097
Interest expense and similar charges Interest on deposits (56,577) (25,756) Interbank transactions (3,477) (3,596) Interest on convertible bond loan 0 (366) Interest on rights of use assets (732)(762)Other interest expenses (649)(301)Total interest expense and similar charges on financial instruments not measured at FVTPL (61,435) (30,781) Interest on derivatives (2,355) (104) Total interest expense and similar charges (63,790) (30,885)
Net interest income 189,857 142,212
95
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
1/1/2024 – 1/1/2023 – Amounts in Eur ‘000 31/12/2024 31/12/2023 Interest and similar income Interest on debt securities at amortised cost 16,614 8,476 Interest on loans at amortised cost 204,400 139,233 Interest on due from banks 18,591 12,427 Other interest income 788 751 Interest on debt securities measured at fair value through other comprehensive income 1,221 1,330 Total interest and similar income for financial instrument not measured at FVTPL 241,614 162,217 Debt securities at fair value through profit and loss 6,994 8,485 Interest on derivatives 2,185 112 Total interest and similar income from financial instruments 250,793 170,814
Interest expense and similar charges Interest on deposits (56,602) (25,760) Interest on due to banks (3,477) (3,596) Interest on convertible bond loan 0 (366) Interest on rights of use assets (730) (762) Other interest expenses (619) (44) Total interest expense and similar charges on financial instruments not measured at FVTPL (61,428) (30,528) Interest on derivatives (2,355) (105) Total interest expense and similar charges (63,783) (30,633)
Net interest income 187,010 140,181
The increase in interest from bonds, loans and deposits is due to the evolution of the balances of the respective
portfolios.
7. Net fee and commission income
The breakdown of net fee and commission income is as follows:
Group
1/1/2024 – 1/1/2023 – Amounts in Eur ‘000 31/12/2024 31/12/2023 Fee and commission income Commission income from commercial transactions 4,478 3,443 Commission income from loans and letters of guarantee 20,660 16,187 Commission income from investment banking 6,590 5,336 Commission income from brokerage services 16,015 13,614 Total fee and commission income 47,743 38,580
Fee and commission expense Commission expense from commercial transactions (908) (665) Commission expense from brokerage services (5,503) (5,796) Total fee and commission expense (6,411) (6,461)
Net fee and commission income 41,332 32,119
96
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank 1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Fee and commission income Commission income from commercial transactions 4,494 3,444 Commission income from loans and letters of guarantee 20,697 16,262 Commission income from investment banking 490 924 Commission income from brokerage services 17,323 14,356 Total fee and commission income 43,004 34,986
Fee and commission expense Commission expense from commercial transactions (809) (659) Commission expense from brokerage services (5,503) (5,796) Total fee and commission expense (6,312) (6,455)
Net fee and commission income 36,692 28,531
The increase in loans, as well as the general development of banking and stock exchange transactions resulted
in the growth of the corresponding commissions.
8. Gains/ (losses) from financial transactions
The gains/(losses) from financial transactions are analysed as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Gains/(losses) from foreign exchange differences 5,861 8,572 Gains/(losses) from derivatives held for trading 3,538 (3,187) Gains/(losses) from carbon emission rights 1,050 913 Gains/(losses) from investments in shares and mutual funds 1,858 4,426 Gains/(losses) from bonds 7,488 5,833 Total 19,795 16,557
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Gains/(losses) from foreign exchange differences 5,857 8,575 Gains/(losses) from derivatives held for trading 3,539 (3,187) Gains/(losses) from carbon emission rights 1,050 913 Gains/(losses) from investments in shares and mutual funds 1,726 4,601 Gains/(losses) from bonds 7,497 5,833 Total 19,669 16,735
The gains/(losses) from financial transactions of the Bank have been mainly affected by the following:
• Gain of EUR 5,857 thousand included in line “Gains/(losses) from foreign exchange differences” concerns
management of foreign exchange position and client transactions on commodities and foreign exchange
derivatives.
97
Notes to the Financial Statements dated December 31, 2024
Group and Bank
• Gain of EUR 3,539 thousand in line "Gains/(losses) of financial transactions from derivatives held for
trading" mainly concerns gain of EUR 1,999 thousand from foreign exchange derivatives, gain of EUR
1,889 from settlement and valuation of interest rate derivatives (Interest Rate Swaps & Options) and
loss of EUR 335 thousand from derivatives on shares and indices of the Athens Stock Exchange which
are offset by profits from investments in shares and mutual funds.
• Gain of EUR 1,050 thousand included in line “Gains/(losses) from carbon emission rights” includes the
result from purchase and sale of carbon emission rights, in the context of the promotion of the product
to the Bank's customers, valuation of carbon emission inventory and carbon emission derivatives for
hedging purposes.
• Gain of EUR 1,726 thousand included in line "Gains/(losses) from investments in shares and mutual
funds" relates to management and revaluation of shares position.
• Gain of EUR 7,497 thousand included in line "Gains/(losses) from bonds" arises from gain of EUR 5,454
thousand from liquidations and valuation of bonds measured at fair value through profit and loss, as
well as gain of EUR 2,043 thousand relating to the valuation of a bond of securitised loans.
9. Other operating income
The other operating income is analysed as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Rental income 5 6 Other income 574 1,006 Total 579 1,012
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Rental income 38 38 Other income 657 1,116 Total 695 1,154
The variance of other income in Bank is due to the profit from the sale of property (EUR 0.5 million) on
31/12/2023.
10. Staff costs
The total charge on the results of the year for staff benefits is broken down as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Salaries and wages (26,164) (24,494) Social security contributions (4,693) (4,337) Pension costs - employee defined benefit plan 31 (184) (225) Other staff costs (1,597) (1,327) Total (32,638) (30,383)
98
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Salaries and wages (25,053) (23,714) Social security contributions (4,502) (4,150) Pension costs - employee defined benefit plan 31 (173) (207) Other staff costs (1,553) (1,290) Total (31,281) (29,361)
The increase in staff costs mainly results from the increase in the Bank's staff. The total number of Group’s staff
on 31/12/2024 amounted to 575 people and of Bank’s staff to 550 people (31/12/2023: Group 500 people and
Bank 478 people).
11. Other operating expenses
The breakdown of the "Other operating expenses" is as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 BoD, legal, consulting, audit fees etc. (2,964) (4,363) Computerization cost (4,459) (3,822) Subscription fees (734) (557) Building expenses (1,446) (1,270) Promotion, advertising expenses ana sponsorships (955) (859) Taxes and duties (2,810) (2,490) Office supplies (114) (108) Other expenses (3,430) (5,775) Total (16,912) (19,244)
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 BoD, legal, consulting, audit fees etc. (2,778) (4,216) Computerization cost (4,370) (3,767) Subscription fees (571) (410) Building expenses (1,416) (1,246) Promotion, advertising expenses ana sponsorships (924) (833) Taxes and duties (2,727) (2,426) Office supplies (110) (103) Other expenses (2,883) (5,575) Total (15,779) (18,576)
99
Notes to the Financial Statements dated December 31, 2024
Group and Bank
12. Provision for expected credit losses
The impairment provisions are broken down as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Provisions for loan impairment (17,353) (9,444) Provision for letters of guarantee (1,869) 191 Provisions for impairment of debt securities at amortised cost (423) 137 Provisions for impairment of other receivables 45 (141) Provisions for impairment of financial assets at fair value through the statement of other income 19 127 Gain/(loss) from modification of loans contractual terms (972) (783) Total (20,553) (9,913)
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Provisions for loan impairment (16,972) (9,242) Provision for letters of guarantee (1,869) 191 Provisions for impairment of debt securities at amortised cost (423) 137 Provisions for impairment of other receivables 45 (141) Provisions for impairment of financial assets at fair value through the statement of other income 19 127 Gain/(loss) from modification of loans contractual terms (972) (783) Total (20,172) (9,711)
The increase results mainly from the corresponding increase in the loan portfolio and the change in
macroeconomic parameters.
The Group on 31 December 2024, taking into account the internal risk tolerance limits as well as the supervisory
requirements (EDEA, CRR framework supervisory provisions) recognise an additional ECL amounted to EUR
6,412 thousand to form a minimum coverage ratio of Non-Performing Exposures at a rate of 33%. For the year
2023, the Group recognised additional impairment provisions of EUR 1,070 thousand for customers whose
businesses were affected by the natural disasters in the Thessaly region in September 2023.
The following table presents the net carrying amount of the loans of the Group and the Bank, before the
modification of contractual terms.
Amounts in Eur ‘000 31/12/2024 31/12/2023 Net carrying amount before the modification 235,671 112,640 Net gain/(loss) due to the modification (972) (783) Total 234,699 111,857
13. Other provisions
The analysis of “Other provisions” is as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Provision for legal cases 0 29 Total 0 29
100
Notes to the Financial Statements dated December 31, 2024
Group and Bank
For the Bank the balance of other provisions is zero for the years ended 31/12/2024 and 31/12/2023.
14. Income Tax
The charge for income tax for the year is broken down as follows:
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Deferred tax 1,992 2,829 Current tax (38,406) (25,750) Total (36,414) (22,921)
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Profit before tax 176,640 125,944 Tax calculated based on the current tax rate of 22% (2023: 22%) (38,861) (27,708) Adjustments to income tax for: Income not subject to taxation 10 206 Previous year tax (1,677) (8) Expenses not deductible for tax purposes (1,446) (462) Temporary differences income tax 0 10 Previous year defered tax recognition (921) 594 Tax effect of utilization of deductible temporary differences not previously recognised 6,412 4,323 Other tax adjustments 69 124 Income tax expense (36,414) (22,921) Effective tax rate 20.61% 18.20%
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Deferred tax 2,053 2,632 Current tax (37,471) (25,066) Total (35,418) (22,434)
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Profit before tax 172,130 123,154 Tax calculated based on the current tax rate of 22% (2023: 22%) (37,869) (27,094) Adjustments to income tax for: Income not subject to taxation 0 203 Previous year tax (1,677) (8) Expenses not deductible for tax purposes (1,373) (452) Previous year defered tax recognition (911) 594 Tax effect of utilization of deductible temporary differences not previously recognised 6,412 4,323 Income tax expense (35,418) (22,434) Effective tax rate 20.58% 18.22%
101
Notes to the Financial Statements dated December 31, 2024
Group and Bank
According to Law 4172/2013, the tax rate applicable in Greece for the reporting periods from 2021 onwards is
22%. Unaudited fiscal years for the Group’s companies, are presented in note 38(b).
For the financial year 2024, the audit is in progress and the relevant tax certificate is expected to be issued
after the publication of the financial statements for the year 2024. Upon completion of the tax audit the Group's
Management does not expect any significant tax liabilities beyond those already reported and presented in the
financial statements.
15. Earnings per share
The earnings per share are analysed as follows:
Basic and adjusted earnings per share
Group
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Profits attributable to the shareholders of the parent company 140,224 103,021 Weighted average number of common shares (in thousands) 73,765 53,327 Earnings after tax per share - basic (in Eur) 1.90 1.93
Bank
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Profits attributable to the shareholders of the parent company 136,712 100,720 Weighted average number of common shares (in thousands) 73,765 53,327 Earnings after tax per share - basic (in Eur) 1.85 1.89
With the decision of the Extraordinary General Assembly dated 22/3/2023, a share-split took place in the
nominal value of each common share of the Bank with a simultaneous increase in the total number of common
registered shares from 7,524,840 common registered shares to 37,624,200 common registered shares.
According to par. 64 of the IAS 33, the weighted average number of common shares has been adjusted for the
comparative period with the number of shares after the above decision of the Extraordinary General Assembly.
With the decision of the Board of Directors dated 21/4/2023 following the decision of the Extraordinary General
Assembly dated 22/3/2023, an increase of the Bank's share capital was carried out due to the conversion of the
bond loan and 14,084,435 new common nominal shares with voting right were issued.
With the decision of the Ordinary General Assembly dated 7/6/2023, an increase of the Bank's share capital
was carried out on 26/7/2023, through capitalization of part of the profits of the fiscal year 2022, amounting to
EUR 3,399,999.15 with the issuance of 985,507 new registered, ordinary, with voting rights, shares. According
to par. 64 of the IAS 33, the weighted average number of common shares has been retrospectively adjusted
for the comparative period after the above increase in the Bank's share capital.
102
Notes to the Financial Statements dated December 31, 2024
Group and Bank
On 4/10/2023, the increase of the share capital was completed with the issuance of 21,000,0000 new registered,
common with voting rights shares.
With the decision of the Ordinary General Meeting of Shareholders dated 23/5/2024, an increase of the Bank's
share capital was carried out by capitalizing part of undistributed profits of the financial year 2023 in the amount
of EUR 276,000, with the issuance of 80,000 new common, registered shares. According to par. 64 of the IAS
33, the weighted average number of common shares has been retrospectively adjusted for the comparative
period after the above Bank’s share capital increase.
16. Cash and balances with the central bank
The balance of cash and cash equivalents available for use, as well as central bank balances is broken down as
follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Cash 16,268 11,644 Deposits with central bank 781,378 467,679 Total 797,646 479,323
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Cash 16,267 11,643 Deposits with central bank 781,378 467,679 Total 797,645 479,322
The fair value of cash and balances with the central bank closely approximates their carrying amount.
Cash and cash equivalents (as reported in the Cash Flow Statement)
Group Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Cash and deposits with central bank 797,646 479,323 Due from banks 17 143,424 98,290 Total 941,070 577,613
Bank
Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Cash and deposits with central bank 797,645 479,322 Due from banks 17 132,272 95,825 Total 929,917 575,147
According to requirements from the Bank of Greece and the, the Group and the Bank should maintain deposits
with the Bank of Greece with an average balance of 1.00% of total customers deposits, as defined by the
European Central Bank.
Mandatory deposits at the Central Bank amount to EUR 39,718 thousand (EUR 29,955 thousand in 2023).
103
Notes to the Financial Statements dated December 31, 2024
Group and Bank
17. Due from banks
The claims from deposits and transactions with other financial institutions are analysed as follows:
Group Amounts in Eur ‘000 31/12/2024 31/12/2023 Due from banks - time deposits 10,016 0 Due from banks - sight deposits 133,408 98,290 Loans to financial institutions 8,953 8,919 Blocked deposits 3,485 10,248 Derivatives margin account 15,447 8,633 Total 171,309 126,090
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Due from banks - sight deposits 132,272 95,825 Loans to financial institutions 8,953 8,919 Blocked deposits 3,485 10,248 Derivatives margin account 15,447 8,633 Total 160,157 123,625
18. Financial assets at fair value through profit and loss
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Shares and variable securities measured at fair value Equity securities listed in Athens Stock Exchange 9,308 9,703 Mutual funds 2,816 634 Treasury bills 186,918 228,849 Government bonds 0 768 Corporate bonds 39,320 50,335 Bank bonds 0 16,643 Bond from loan securitisation 26,080 30,696 Total 264,442 337,628
The "loan securitisation bond" refers to the Bank's purchase of a bond (whose income comes from a securitised
mortgage portfolio) with terms of participation in its profits ("Profit Participating Security"), in May 2022
and is mandatorily measured at fair value.
The basic valuation assumptions of the financial assets are presented in note 2.4.
104
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Shares and other variable income securities Equity securities listed in Athens Stock Exchange 9,308 9,703 Treasury bills 186,918 228,849 Government bonds 0 768 Corporate bonds 39,320 50,335 Bank bonds 0 16,643 Bond from loan securitisation 26,080 30,696 Total 261,626 336,994
The movement of financial assets measured at fair value through profit and loss is analysed as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 337,628 211,653 Purchases 3,428,027 3,306,682 Sales / maturities / other movements (3,503,724) (3,184,214) Fair value adjustments 2,511 3,507 Balance at the end of year 264,442 337,628
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 336,994 210,114 Purchases 3,424,827 3,306,048 Sales / maturities / other movements (3,502,624) (3,184,214) Fair value adjustments 2,429 5,046 Balance at the end of year 261,626 336,994
19. Derivative financial instruments
Group
31/12/2024 Notional Estimated fair value Amounts in Eur ‘000 amount Assets Liabilities Bond / Stock /Index futures 9,311 0 0 Stock /Index οptions 53 23 29 Foreign exchange derivatives 294,548 1,571 766 Commodity derivatives 39,302 33 4,400 Interest rate derivatives (IRS- IRCAP) 80,360 583 123 Total derivative financial instruments 2,210 5,318
105
Notes to the Financial Statements dated December 31, 2024
Group and Bank
31/12/2023 Nominal Estimated fair value Amounts in Eur ‘000 value Assets Liabilities Bond / Stock / Index futures 13,332 0 0 Stock /Index οptions 138 41 97 Foreign exchange derivatives 363,989 598 2,913 Commodity derivatives 53,148 340 5,442 Interest rate derivatives (IRS- IRCAP) 37,174 54 45 Total derivative financial instruments 1,033 8,497
Bank
31st December 2024 Notional Estimated fair value Amounts in Eur ‘000 amount Assets Liabilities Bond / Stock /Index futures 9,311 0 0 Stock /Index οptions 53 23 29 Foreign exchange derivatives 294,548 1,571 766 Commodity derivatives 39,302 33 4,400 Interest rate derivatives (IRS- IRCAP) 80,360 583 123 Total derivative financial instruments 2,210 5,318
31st December 2023 Nominal Amounts in Eur ‘000 value Estimated fair value Assets Liabilities Bond / Stock / Index futures 13,332 0 0 Stock /Index οptions 138 41 97 Foreign exchange derivatives 363,989 598 2,913 Commodity derivatives 53,148 340 5,442 Interest rate derivatives (IRS- IRCAP) 37,174 54 45 Total derivative financial instruments 1,033 8,497
The valuation of the futures contracts up to December 31, 2023 amounted to EUR 34.7 thousand. was included
in the margin and clearing accounts.
20. Loans and advances to customers
Loans portfolio is broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Loans and advances to customers measured at amortised cost Consumer, personal & other 35,013 32,753 Mortgages 132,641 98,199 Large Corporate 1,717,713 1,054,855 SMEs 1,772,132 1,272,702 3,657,499 2,458,509 Less: Provisions for impairment of loans and advances to customers (44,901) (27,595) Book value of loans and advances to customers measured at amortised cost after provisions 3,612,598 2,430,914
106
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Loans and advances to customers measured at amortised cost Consumer, personal & other 35,013 32,753 Mortgages 132,641 98,199 Large Corporate 1,789,324 1,116,479 SMEs 1,684,007 1,196,101 3,640,985 2,443,532 Less: Provisions for impairment of loans and advances to customers (44,385) (27,460) Book value of loans and advances to customers measured at amortised cost after provisions 3,596,600 2,416,072
The movement on expected credit losses are broken down as follows:
Group
Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Balance at the beginning of the year (27,595) (18,907) Provisions for the year 12 (17,353) (9,444) Loans written-off 47 756 Balance at the end of year (44,901) (27,595)
Bank
Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Balance at the beginning of the year (27,460) (18,974) Provisions for the year 12 (16,972) (9,242) Loans written-off 47 756 Balance at the end of year (44,385) (27,460)
21. Financial assets at fair value through other comprehensive income
The investment portfolio includes shares and bonds.
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Fixed income securities Government bonds 17,432 52,996 Corporate bonds 10,877 6,050 Bank bonds 18,815 27,172 Total fixed income securities 47,124 86,218 Variable yield securities Equity securities listed in Athens Stock Exchange 260 264 Non-listed securities 6 6 Total equity variable yield securities 266 270 Total 47,390 86,488
107
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Fixed income securities Government bonds 17,432 52,996 Corporate bonds 10,877 6,050 Bank bonds 18,815 27,172 Total fixed income securities 47,124 86,218 Variable yield securities Equity securities listed in Athens Stock Exchange 260 264 Non-listed securities 6 6 Total equity variable yield securities 266 270 Total 47,390 86,488
The Bank has classified to financial assets at fair value through other comprehensive income shares which are
strategic and operational investments with a long-term horizon.
The movement in the portfolio of securities measured at fair value through other comprehensive income is as
follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 86,488 93,256 Purchases 189,178 28,318 Sales / maturities / other movements (230,186) (40,111) Fair value adjustments 1,910 5,025 Balance at the end of year 47,390 86,488
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 86,488 93,256 Purchases 189,178 28,318 Sales / maturities / other movements (230,186) (40,111) Fair value adjustments 1,910 5,025 Balance at the end of year 47,390 86,488
108
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The movement in the impairment provision of the securities portfolio measured at fair value through other
comprehensive income for the period 1/1/2023 – 31/12/2024 is as follows:
Group
Amounts in Eur ‘000 Balance as at 1st January 2023 (208) Government bonds 106 Corporate bonds 53 Bank bonds (32) Impairment provisions 1/1/2023 - 31/12/2023 127 Balance as at 1st January 2024 (81) Government Bonds 13 Corporate bonds (15) Bank bonds 21 Impairment provisions 1/1/2024 - 31/12/2024 19 Balance as at 31st December 2024 (62)
Bank
Amounts in Eur ‘000 Balance as at 1st January 2023 (208) Government bonds 106 Corporate bonds 53 Bank bonds (32) Impairment provisions 1/1/2023 - 31/12/2023 127 Balance as at 1st January 2024 (81) Government bonds 13 Corporate bonds (15) Bank bonds 21 Impairment provisions 1/1/2024 - 31/12/2024 19 Balance as at 31st December 2024 (62)
22. Debt securities at amortised cost
The debt securities at amortised cost are analysed as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Debt securities at amortised cost Government Bonds 161,834 93,792 Corporate bonds 102,371 63,252 Bank bonds 150,442 94,724 Expected credit losses (803) (380) Total 413,844 251,388
109
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Debt securities at amortised cost Greek Government Bonds 161,834 93,792 Corporate bonds 102,371 63,252 Bank bonds 150,442 94,724 Expected credit losses (803) (380) Total 413,844 251,388
The increase in the portfolio is due to the Bank's further investment in fixed interest rate bonds, as hedging,
with the aim of reducing the sensitivity of net interest income to changes in interest rates.
The movement in the portfolio of debt securities at amortised cost for the Group and the Bank is as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 251,388 174,464 Purchases 200,552 76,443 Sales / maturities / other movements (37,673) 861 Expected credit losses (423) (380) Balance at the end of year 413,844 251,388
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 251,388 174,464 Purchases 200,552 76,443 Sales / maturities / other movements (37,673) 861 Expected credit losses (423) (380) Balance at the end of year 413,844 251,388
The movement of portfolio impairment provisions at amortised cost, for the years 1/1/2023-31/12/2024 is as
follows:
Group
Amounts in Eur ‘000 Balance 1st January 2023 (517) Government Bonds 8 Corporate bonds 223 Bank bonds (94) Expected credit losses 1/1/2023 - 31/12/2023 137 Balance 1st January 2024 (380) Government Bonds (113) Corporate bonds (280) Bank bonds (30) Expected credit losses 1/1/2024 - 31/12/2024 (423) Balance 31st December 2024 (803)
110
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 Balance 1st January 2023 (517) Government Bonds 8 Corporate bonds 223 Bank bonds (94) Expected credit losses 1/1/2023 - 31/12/2023 137 Balance 1st January 2024 (380) Government Bonds (113) Corporate bonds (280) Bank bonds (30) Expected credit losses 1/1/2024 - 31/12/2024 (423) Balance 31st December 2024 (803)
23. Investments in subsidiaries and associates
Subsidiaries % Direct % Indirect investment investment 31/12/2024 31/12/2024 Corporate Name Country Business activity IBG CAPITAL S.A. Greece Capital & Holdings Company 100.00% 0.00% British ΙΒG INVESTMENTS S.A. Virgin Investment Company 79.04% 20.96% Islands OPTIMA FACTORS S.A. Greece Factoring Company 100.00% 0.00% OPTIMA ASSET MANAGEMENT Greece Asset Management Company 99.44% 0.00% Α.Ε.D.Α.Κ. OPTIMA LEASING S.A. Greece Leasing Company 100.00% 0.00%
% Direct % Indirect investment investment Corporate Name Country Business activity 31/12/2023 31/12/2023 IBG CAPITAL S.A. Greece Capital & Holdings Company 100.00% 0.00% British ΙΒG INVESTMENTS S.A. Virgin Investment Company 81.45% 18.55% Islands OPTIMA FACTORS S.A. Greece Factoring Company 100.00% 0.00% OPTIMA ASSET MANAGEMENT Greece Asset Management Company 99.44% 0.00% Α.Ε.D.Α.Κ.
In November 2024, Optima Leasing S.A. was incorporated, which is a 100% subsidiary Company of the
Optima Bank Group.
111
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The Group holds a total participation of 100% in IBG INVESTMENTS S.A. during both financial years.
Associates % investment % investment Corporate Name Country Business activity 31/12/2024 31/12/2023 Commercial representative, exclusive import and trading of NOTOS COM HOLDINGS S.A. Greece cosmetics, personal care 25.00% 25.00% products, clothing, footwear and stationery.
In October 2022, the Bank acquired 25% of NOTOS COM HOLDINGS S.A. as part of its restructuring.
Bank
Financial data 31/12/2024 Profit / (loss) Amounts in Eur ‘000 Assets Liabilities Revenues before tax IBG CAPITAL S.A. 1,171 13 0 (13) ΙΒG INVESTMENTS S.A. 2,228 2 7 0 OPTIMA FACTORS S.A. 164,592 145,873 13,266 4,195 OPTIMA ASSET MANAGEMENT Α.Ε.D.Α.Κ. 5,696 1,740 3,137 588 OPTIMA LEASING S.A. 15,189 493 28 (304) 188,876 148,121 16,438 4,466
Financial data 31/12/2023 Profit / (loss) Amounts in Eur ‘000 Assets Liabilities Revenues before tax IBG CAPITAL S.A. 1,182 11 0 (6) ΙΒG INVESTMENTS S.A. 2,390 2 (210) (217) OPTIMA FACTORS S.A. 124,618 109,114 8,792 2,757 OPTIMA ASSET MANAGEMENT Α.Ε.D.Α.Κ. 5,206 1,685 2,155 387 133,395 110,813 10,737 2,920
The above tables present the shareholding percentages held by the Bank.
The “Investments in subsidiaries and associates” is broken down as follows:
Group - Investments in associates Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 260 448 - New investments 0 1 - Share of profit/(loss) of associates 349 (189) Balance at the end of year 609 260
Bank- Investments in subsidiaries and associates
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance at the beginning of the year 9,134 9,133 - New investments 15,000 1 - Disposal of shares in investments in subsidiaries and associates (162) 0 Balance at the end of year 23,972 9,134
112
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The cost of investment in the Bank’s subsidiaries is broken down as follows:
Amounts in Eur ‘000 Investment Investment amount amount Subsidiaries 31/12/2024 31/12/2023 IBG CAPITAL S.A. 778 778 ΙΒG INVESTMENTS S.A. 984 1,146 OPTIMA FACTORS 6,307 6,307 OPTIMA ASSET MANAGEMENT AEDΑΚ 892 892 OPTIMA LEASING S.A. 15,000 0 Total investments in subsidiaries 23,961 9,123
Amounts in Eur ‘000 Investment Investment amount amount Associated Companies 31/12/2024 31/12/2023 NOTOS COM HOLDINGS S.A. 11 11 Total investments in associates 11 11
24. Property, plant and equipment
The changes in tangible fixed assets during the years 2024 and 2023 are as follows:
Group
Furniture Land and Vehicles & and other Amounts in Eur ‘000 buildings machinery equipment Total Acquisition cost on 1 January 2024 12,787 3,277 4,073 20,137 Accumulated depreciation on 1 January 2024 (4,787) (2,374) (2,073) (9,234) Carrying amount at 1 January 2024 8,000 903 2,000 10,903 Additions 987 477 302 1,766 Disposals/write-offs 0 (43) 0 (43) Depreciation for the year (1,251) (388) (309) (1,948) Depreciation of disposals/write offs 0 39 0 39 Acquisition cost at 31 December 2024 13,774 3,711 4,375 21,860 Accumulated depreciation at 31 December 2024 (6,038) (2,723) (2,382) (11,143) Carrying amount at 31 December 2024 7,736 988 1,993 10,717
Furniture Land and Vehicles & and other Amounts in Eur ‘000 buildings machinery equipment Total Acquisition cost on 1 January 2023 12,664 2,751 3,916 19,331 Accumulated depreciation on 1 January 2023 (3,686) (2,020) (1,786) (7,492) Carrying amount at 1 January 2023 8,979 732 2,131 11,841 Additions 798 528 160 1,486 Disposals/write-offs (675) (2) (3) (680) Depreciation for the year (1,120) (356) (290) (1,766) Depreciation of disposals/write offs 19 2 3 24 Acquisition cost at 31 December 2023 12,787 3,277 4,073 20,137 Accumulated depreciation at 31 December 2023 (4,787) (2,374) (2,073) (9,234) Carrying amount at 31 December 2023 8,000 903 2,000 10,903
113
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Furniture Land and Vehicles & and other Amounts in Eur ‘000 buildings machinery equipment Total Acquisition cost on 1 January 2024 12,652 3,277 3,952 19,881 Accumulated depreciation on 1 January 2024 (4,773) (2,374) (1,996) (9,143) Carrying amount at 1 January 2024 7,879 903 1,956 10,738 Additions 969 476 294 1,739 Disposals/write-offs 0 (43) 0 (43) Depreciation for the year (1,203) (388) (294) (1,885) Depreciation of disposals/write offs 0 39 0 39 Acquisition cost at 31 December 2024 13,621 3,710 4,246 21,577 Accumulated depreciation at 31 December 2024 (5,976) (2,723) (2,290) (10,989) Carrying amount at 31 December 2024 7,645 987 1,956 10,588
Furniture Land and Vehicles & and other Amounts in Eur ‘000 buildings machinery equipment Total Acquisition cost on 1 January 2023 12,533 2,751 3,800 19,084 Accumulated depreciation on 1 January 2023 (3,678) (2,020) (1,722) (7,420) Carrying amount at 1 January 2023 8,855 731 2,078 11,664 Additions 797 528 153 1,478 Disposals/write-offs (678) (2) (1) (681) Depreciation for the year (1,114) (356) (276) (1,746) Depreciation of disposals/write offs 19 2 2 23 Acquisition cost at 31 December 2023 12,652 3,277 3,952 19,881 Accumulated depreciation at 31 December 2023 (4,773) (2,374) (1,996) (9,143) Carrying amount at 31 December 2023 7,879 903 1,956 10,738
25. Intangible assets
The movement of the intangible assets the years 2024 and 2023 are as follows:
Group
Other Amounts in Eur ‘000 Software Intangible Total Acquisition cost on 1 January 2024 14,849 4,055 18,904 Accumulated depreciation on 1 January 2024 (7,174) (925) (8,099) Carrying amount at 1 January 2024 7,675 3,130 10,805 Additions 3,723 0 3,723 Depreciation for the year (2,824) (308) (3,132) Acquisition cost at 31 December 2024 18,572 4,055 22,627 Accumulated depreciation at 31 December 2024 (9,998) (1,233) (11,231) Carrying amount at 31 December 2024 8,574 2,822 11,396
114
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Other Amounts in Eur ‘000 Software Intangible Total Acquisition cost on 1 January 2023 11,848 4,055 15,903 Accumulated depreciation on 1 January 2023 (4,962) (617) (5,579) Carrying amount at 1 January 2023 6,886 3,438 10,324 Additions 3,001 0 3,001 Depreciation for the year (2,212) (308) (2,520) Acquisition cost at 31 December 2023 14,849 4,055 18,904 Accumulated depreciation at 31 December 2023 (7,174) (925) (8,099)Carrying amount at 31 December 2023 7,675 3,130 10,805
The line “Other Intangible” includes intangible assets attributable to customer relationships and trademarks
recognised at the time of acquisition of the Bank’s subsidiaries Optima Factors and Optima Asset Management
AEDAK.
Bank
Amounts in Eur ‘000 Software Total Acquisition cost on 1 January 2024 13,872 13,872 Accumulated depreciation on 1 January 2024 (6,451) (6,451) Carrying amount at 1 January 2024 7,421 7,421 Additions 3,508 3,508 Depreciation for the year (2,736) (2,736) Acquisition cost at 31 December 2024 17,380 17,380 Accumulated depreciation at 31 December 2024 (9,187) (9,187) Carrying amount at 31 December 2024 8,193 8,193
Amounts in Eur ‘000 Software Total Acquisition cost on 1 January 2023 11,040 11,040 Accumulated depreciation on 1 January 2023 (4,307) (4,307) Carrying amount at 1 January 2023 6,733 6,733 Additions 2,832 2,832 Depreciation for the year (2,144) (2,144) Acquisition cost at 31 December 2023 13,872 13,872 Accumulated depreciation at 31 December 2023 (6,451) (6,451) Carrying amount at 31 December 2023 7,421 7,421
26. Right of use assets and Lease liabilities
Group
(i) Amounts recognised in statement of financial position
Amounts in Eur ‘000 31/12/2024 31/12/2023 Rights of use assets Buildings 18,288 18,546 Vehicles 1,307 962 Balance at the end of year 19,595 19,508 Lease liabilities Short-term liabilities 3,265 2,696 Long-term liabilities 17,955 18,165 Balance at the end of year 21,220 20,861
115
Notes to the Financial Statements dated December 31, 2024
Group and Bank
(ii) Amounts recognised in statement of profit or loss
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Depreciation of rights-of-use on assets Buildings 2,817 2,693 Vehicles 431 331 Total 3,248 3,024 Interest expense 739 769
Amounts in Eur ‘000 Buildings Vehicles Total Acquisition cost on 1 January 2024 27,200 1,512 28,712 Accumulated depreciation on 1 January 2024 (8,654) (550) (9,204) Carrying amount at 1 January 2024 18,546 962 19,508 Additions 2,559 775 3,334 Disposals/write-offs 0 (300) (300) Depreciation for the year (2,817) (431) (3,248) Depreciation of disposals/write offs 1 300 301 Acquisition cost at 31 December 2024 29,759 1,987 31,746 Accumulated depreciation at 31 December 2024 (11,470) (681) (12,151) Carrying amount at 31 December 2024 18,289 1,306 19,595
Amounts in Eur ‘000 Buildings Vehicles Total Acquisition cost on 1 January 2023 25,028 1,244 26,272 Accumulated depreciation on 1 January 2023 (6,136) (700) (6,836) Carrying amount at 1 January 2023 18,892 544 19,436 Additions 2,347 822 3,169 Disposals/write-offs (175) (554) (729) Depreciation for the year (2,693) (333) (3,026) Depreciation of disposals/write offs 175 483 658 Acquisition cost at 31 December 2023 27,200 1,512 28,712 Accumulated depreciation at 31 December 2023 (8,654) (550) (9,204) Carrying amount at 31 December 2023 18,546 962 19,508
Bank
(i) Amounts recognised in statement of financial position
Amounts in Eur ‘000 31/12/2024 31/12/2023 Rights of use assets Buildings 18,289 18,545 Vehicles 1,272 933 Balance at the end of year 19,561 19,478 Lease liabilities Short-term liabilities 3,258 2,688 Long-term liabilities 17,930 18,146 Balance at the end of year 21,188 20,834
116
Notes to the Financial Statements dated December 31, 2024
Group and Bank
(ii) Amounts recognised in statement of profit or loss
1/1/2024 - 1/1/2023 - Amounts in Eur ‘000 31/12/2024 31/12/2023 Depreciation of rights-of-use on assets Buildings 2,817 2,693 Vehicles 414 324 Total 3,231 3,017 Interest expense 730 762
Amounts in Eur ‘000 Buildings Vehicles Total Acquisition cost on 1 January 2024 27,200 1,468 28,668 Accumulated depreciation on 1 January 2024 (8,654) (536) (9,190) Carrying amount at 1 January 2024 18,546 932 19,478 Additions 2,559 754 3,313 Disposals/write-offs 0 (300) (300) Depreciation for the year (2,817) (414) (3,231) Depreciation of disposals/write offs 1 300 301 Acquisition cost at 31 December 2024 29,759 1,922 31,681 Accumulated depreciation at 31 December 2024 (11,470) (650) (12,120) Carrying amount at 31 December 2024 18,289 1,272 19,561
Amounts in Eur ‘000 Buildings Vehicles Total Acquisition cost on 1 January 2023 25,028 1,214 26,242 Accumulated depreciation on 1 January 2023 (6,136) (695) (6,831) Carrying amount at 1 January 2023 18,892 519 19,411 Additions 2,347 807 3,154 Disposals/write-offs (175) (553) (728) Depreciation for the year (2,693) (324) (3,017) Depreciation of disposals/write offs 175 483 658 Acquisition cost at 31 December 2023 27,200 1,468 28,668 Accumulated depreciation at 31 December 2023 (8,654) (536) (9,190) Carrying amount at 31 December 2023 18,546 932 19,478
117
Notes to the Financial Statements dated December 31, 2024
Group and Bank
27. Deferred tax assets
The change in the deferred tax assets by category of temporary differences in the year 2024 is analysed as
follows:
Group
Credit / (debit) Balance as at Credit / to other Balance as at 1 January (debit) to comprehensive 31 December Amounts in Eur ‘000 2024 results income 2024 Property, plant & equipment and Intangible assets 54 1 0 55 Intangible assets from the acquisition of subsidiaries (688) 68 0 (620) Provisions for impairment on loans and advances to customers 5,945 3,551 0 9,496 Other provisions 485 537 0 1,022 Retirement benefit obligations 153 40 34 227 Financial assets measured at fair value through other comprehensive income 851 0 (420) 431 Financial assets measured at fair value through profit and loss (954) (549) 0 (1,503) Valuation of carbon emissions (1,164) 225 0 (939) Valuation of derivatives 1,698 (985) 0 713 Leases 298 83 0 381 Other 1,401 (979) 0 422 Total 8,079 1,992 (386) 9,685
Credit / (debit) Balance as at Balance as at Credit / to other 31st 1st January (debit) to comprehensive December Amounts in Eur ‘000 2023 results income 2023 Property, Plant & Equipment and Intangible assets 97 (43) 0 54 Intangible assets from the acquisition of subsidiaries at fair value (756) 68 0 (688) Provisions for impairment on loans and advances to customers 3,994 1,951 0 5,945 Other provisions 766 (281) 0 485 Retirement benefit obligations 121 29 3 153 Financial assets at fair value through other comprehensive income 1,957 0 (1,106) 851 Financial assets at fair value through profit and loss 163 (1,117) 0 (954) Valuation of carbon emissions 0 (1,164) 0 (1,164) Valuation of derivatives (248) 1,946 0 1,698 Leases 181 117 0 298 Other 78 1,323 0 1,401 Total 6,353 2,829 (1,103) 8,079
118
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Credit / (debit) Balance as at Credit / to other Balance as at 1 January (debit) to comprehensive 31 December Amounts in Eur ‘000 2024 results income 2024 Property, plant & equipment and Intangible assets 49 0 0 49 Provisions for impairment on loans and advances to customers 6,078 3,714 0 9,792 Other provisions 532 489 0 1,021 Retirement benefit obligations 143 38 31 212 Financial assets measured at fair value through other comprehensive income 849 0 (420) 429 Financial assets measured at fair value through profit and loss (946) (531) 0 (1,477) Valuation of carbon emissions (1,164) 225 0 (939) Valuation of derivatives 1,698 (985) 0 713 Leases 298 83 0 381 Other 1,401 (980) 0 421 Total 8,938 2,053 (389) 10,603
Credit / (debit) Balance as at Credit / to other Balance as at 1 January (debit) to comprehensive 31 December Amounts in Eur ‘000 2023 results income 2023 Property, plant & equipment and Intangible assets 93 (44) 0 49 Provisions for impairment on loans and advances to customers 4,048 2,030 0 6,078 Other provisions 1,026 (494) 0 532 Retirement benefit obligations 113 27 3 143 Financial assets measured at fair value through other comprehensive income 1,955 0 (1,106) 849 Financial assets measured at fair value through profit and loss 163 (1,109) 0 (946) Valuation of carbon emissions 0 (1,164) 0 (1,164) Valuation of derivatives (248) 1,946 0 1,698 Leases 181 117 0 298 Other 78 1,323 0 1,401 Total 7,409 2,632 (1,103) 8,938
119
Notes to the Financial Statements dated December 31, 2024
Group and Bank
28. Other assets
The other assets are broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Derivatives and securities margin accounts 31,279 23,719 Clearing accounts for securities transactions in Athens Stock Exchange, Greek derivatives market and foreign stock exchanges 66,683 5,656 Hellenic Deposit and Investment Guarantee Fund 0 1,595 Guarantee fund 7,404 6,397 Auxiliary fund 3,606 4,096 Energy Stock Exchange 1,250 1,250 Debtors 2,610 2,390 Guarantees 1,796 1,140 Carbon emissions inventory 38,348 40,479 Advances and other receivables accounts 15,395 5,989 Prepaid expenses and accrued revenue 2,006 2,702 Advance on Income tax 0 415 Other receivables from the Greek State 84 268 Due from brokerage companies 9,147 9,856 179,608 105,952 Less: Impairment Provisions (102) (102) Total 179,506 105,850
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Derivatives and securities margin accounts 31,279 23,719 Clearing accounts for securities transactions in Athens Stock Exchange, Greek derivatives market and foreign stock exchanges 66,683 5,656 Hellenic Deposit and Investment Guarantee Fund 0 1,595 Guarantee fund 7,154 6,147 Auxiliary fund 3,606 4,096 Energy Stock Exchange 1,250 1,250 Debtors 3,479 2,575 Guarantees 1,796 1,140 Carbon emissions inventory 38,348 40,479 Advances and other receivables accounts 15,137 5,527 Prepaid expenses and accrued revenue 1,948 2,555 Other receivables from the Greek State 79 82 Due from brokerage companies 9,147 9,856 179,906 104,677 Less: Impairment Provisions (102) (102) Total 179,804 104,575
The changes in the balances are mainly due to the account "Clearing accounts and receivables from customers
from stock exchange transactions in AXA, CFA & foreign stock exchanges" which concerns sales of the Bank's
bonds that have not been cleared.
120
Notes to the Financial Statements dated December 31, 2024
Group and Bank
29. Due to banks
The due to other credit institutions are broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Due to banks - sight deposits 421 612 81,079Due to banks - time deposits 71,035 78,443 Bond loan 0 2,024 Listed derivatives margin account 850 0 Other deposits 43,257 0 Total 115,563
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Due to banks - sight deposits 421 612 Due to banks - time deposits 71,035 78,443 Listed derivatives margin account 850 0 Other deposits 43,257 0 Total 115,563 79,055
The "Other Deposits" line includes the balances of agreements to grant government bonds to credit institutions
with parallel repurchase agreements (repo transactions) for the purposes of raising liquidity.
The fair value of liabilities to financial institutions approximates their carrying amount.
30. Due to customers
The deposits and other customers’ accounts are broken down as follows:
Group Amounts in Eur ‘000 31/12/2024 31/12/2023 Sight deposits 1,617,438 1,337,170 Savings accounts 1,494 3,963 Time deposits 2,701,079 1,579,364 Blocked deposits 218,071 172,614 Other deposits 83,261 85,944 Cheques payable 22,069 12,749 Total 4,643,412 3,191,804
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Sight deposits 1,623,090 1,342,277 Savings accounts 1,494 3,963 Time deposits 2,706,079 1,579,364 Blocked deposits 218,071 172,614 Other deposits 83,261 85,944 Cheques payable 22,069 12,749 Total 4,654,064 3,196,911
The item “Other Deposits” includes the balances of the brokerage accounts of the Bank's customers.
The fair value of “due to customers” approximates their carrying amount.
121
Notes to the Financial Statements dated December 31, 2024
Group and Bank
31. Retirement benefit obligations
Group The amounts recorded in the statement of financial position are the following: Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance sheet liabilities for: Lump-sum payments upon retirement - Non funded 1,027 692 1,027 692
The amounts recorded in the income statement are the following:
Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Current service cost 160 137 Finance cost 24 10 Settlement cost 0 78 Total included in employee benefits 10 184 225
The movement in the liability recognised in the statement of financial position is as follows:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Net obligation recognised in the balance sheet at the beginning of the year 692 550 Expenditure to be recorded in the income statement 184 226 Employer contributions paid 0 (96) Amount recorded in other comprehensive income 152 12 Net obligation recognised in the balance sheet at the end of the year 1,027 692
The amount recorded in other comprehensive income is as follows:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Amount recognised in other comprehensive income 152 12 Actuarial (gain) / loss on obligation due to: - financial assumptions 43 (36) - demographic assumptions 3 0 - experience 106 48
Bank
The amounts recorded on the statement of financial position are the following:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Balance sheet liabilities for: Lump-sum payments upon retirement - Non funded 964 650 964 650
The amounts recorded in the income statement are the following:
Amounts in Eur ‘000 Note 31/12/2024 31/12/2023 Current service cost 151 130 Finance cost 22 9 Settlement cost 0 68 Total included in employee benefits 10 173 207
122
Notes to the Financial Statements dated December 31, 2024
Group and Bank
The movement in the liability recognised in the statement of financial position is as follows:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Net obligation recognised in the balance sheet at the beginning of the year 650 514 Expenditure to be recorded in the income statement 173 208 Employer contributions paid 0 (84) Amount recorded in other comprehensive income 141 12 Net obligation recognised in the balance sheet at the end of the year 964 650
The amount recorded in other comprehensive income is as follows:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Amount recognised in other comprehensive income 141 12 Actuarial (gain) / loss on obligation due to: - financial assumptions 41 (34) - demographic assumptions 2 0 - experience 98 46
The main actuarial assumptions used for accounting purposes are as follows:
31/12/2024 31/12/2023 Discount rate 2.76% 3.45% Future salary increases 2.10% 2.10% Inflation 2.00% 2.10%
Sensitivity analysis
The sensitivity analysis of the defined employee retirement benefit liability is as follows:
Effect on the defined benefit liability OPTIMA BANK OPTIMA FACTORS OPTIMA AEDAK Increase Decrease Increase Decrease Increase Decrease Discount rate (change in assumption by 0.5%) -3% 3% -6% 6% -3% 3% Salary increase (change in assumption by 0.5%) 3% -3% 4% -4% 3% -3%
32. Other liabilities
Other liabilities are broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Clearing accounts for securities transactions in Athens Stock Exchange, Greek derivatives market and foreign stock exchanges 90,971 6,215 Taxes and duties payables 2,924 2,394 Accrued interest and other deferred revenue 1,857 1,991 Other payables 27,419 28,887 Social security payable 1,193 999 Due to brokerage companies 4 181 Total 124,368 40,667
123
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Clearing accounts for securities transactions in Athens Stock Exchange, Greek derivatives market and foreign stock exchanges 90,971 6,215 Taxes and duties payables 2,396 1,775 Accrued interest and other deferred revenue 1,857 1,991 Other payables 26,559 27,966 Social security payable 1,146 954 Due to brokerage companies 4 181 Total 122,933 39,082
The variance in the balances is mainly due to the item " Clearing accounts for securities transactions in Athens
Stock Exchange, Greek derivatives market and foreign stock exchanges " which concerns purchases of the
Bank's bonds that have not been cleared.
33. Provisions
The provisions are broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Provisions for legal cases 189 257 Provisions for unaudited fiscal years 331 331 Provisions of guarantee letters 3,647 1,778 Total 4,167 2,366
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Provisions for legal cases 188 257 Provisions for unaudited fiscal years 321 321 Provisions of guarantee letters 3,648 1,778 Total 4,157 2,356
124
Notes to the Financial Statements dated December 31, 2024
Group and Bank
34. Share capital
On 31/12/2024, the share capital amounts to EUR 254,521 thousand (EUR 254,245 thousand as of 31/12/2023)
divided into 73,774,142 shares with voting rights and a nominal value of EUR 3.45 per share. The Bank has
9,193 own shares.
Number of Shares Bank Group No. of ordinary Total no. of shares Own shares ordinary shares Balance as at 1st January 2023 7,524,840 7,524,840 Share capital decrease with losses net off (7,524,840) (7,524,840) Share capital decrease with split (1 old for 5 new shares) 37,624,200 37,624,200 Share capital increase with bond loan conversion 14,084,435 14,084,435 Capitalization of earnings 985,507 985,507 Share capital increase 21,000,000 21,000,000 Purchases of own shares (107,972) (107,972) Sales of own shares 84,674 84,674 Balance as at 31st December 2023 73,694,142 (23,298) 73,670,844 Balance as at 1st January 2024 73,694,142 (23,298) 73,670,844 Capitalization of earnings 80,000 80,000 Purchases of own shares (302,174) (302,174) Sales of own shares 316,279 316,279 Balance as at 31st December 2024 73,774,142 (9,193) 73,764,949
35. Other reserves
The breakdown of other reserves is as follows:
Group Amounts in Eur ‘000 31/12/2024 31/12/2023 Statutory reserve 24,123 17,204 Special reserves 7,183 7,183 Actuarial gain/(loss) reserve 314 433 Reserve for stock awards to personnel 0 5,326 Total 31,620 30,146
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Statutory reserve 23,746 17,008 Special reserves 6,483 6,483 Actuarial gain/(loss) reserve 322 432 Reserve for stock awards to personnel 0 5,326 Total 30,551 29,249
125
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Statutory Reserve: According to the Greek Trade Law, the Group is required to withhold from its net
accounting profits a minimum of 5% per year as legal reserve. Such withholding ceases to be compulsory when
the total legal reserve exceeds 1/3 of the paid-up share capital. This taxed reserve is non-distributable
throughout the Group’s lifetime and is intended to cover any debit balances of the profit and loss carried forward
item.
Extraordinary Reserves: The extraordinary reserves have been formed from taxed profits, and therefore no
additional tax liability will be imposed in case of their distribution.
36. Balance sheet items broken down by expected due date
The classification of balance sheet items by expected due date is analyzed as follows:
Group
Amounts in Eur ‘000 Within 1 year After 1 year As at 31st December 2024 ASSETS Cash and balances with central bank 797,646 0 Due from banks 162,356 8,953 Financial assets measured at fair value through profit or loss 238,362 26,080 Derivative financial instruments 2,210 0 Loans and advances to customers 1,627,261 1,985,337 Financial assets measured at fair value through other comprehensive income 29,693 17,697 Debt securities at amortised cost 30 413,814 Investment in subsidiaries and associates 0 609 Property, plant and equipment 0 10,717 Intangible assets 0 11,396 Right of use assets 0 19,595 Deferred tax assets 0 9,685 Other assets 97,620 81,886 Total assets 2,955,178 2,585,769 LIABILITIES Due to banks 115,563 0 Due to customers 4,639,606 3,806 Derivative financial instruments 5,318 0 Lease liabilities 3,265 17,955 Retirement benefit obligations 0 1,027 Income tax liability 5,573 0 Other liabilities 124,368 0 Provisions 0 4,167 Total liabilities 4,893,693 26,955
126
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Amounts in Eur ‘000 Within 1 year After 1 year As at 31st December 2023 ASSETS Cash and balances with central bank 479,323 0 Due from banks 117,171 8,919 Financial assets measured at fair value through profit or loss 306,932 30,696 Derivative financial instruments 1,033 0 Loans and advances to customers 1,062,695 1,368,219 Financial assets measured at fair value through other comprehensive income 50,183 36,305 Debt securities at amortised cost 22,702 228,686 Investment in subsidiaries and associates 0 260 Property, plant and equipment 0 10,903 Intangible assets 0 10,805 Right of use assets 0 19,508 Deferred tax assets 0 8,079 Other assets 30,603 75,247 Total assets 2,070,643 1,797,626 LIABILITIES Due to banks 81,079 0 Due to customers 3,177,580 14,224 Derivative financial instruments 8,497 0 Lease liabilities 2,696 18,165 Retirement benefit obligations 0 692 Income tax liability 12,226 0 Other liabilities 40,667 0 Provisions 0 2,366 Total liabilities 3,322,745 35,447
Bank
Amounts in Eur ‘000 Within 1 year After 1 year As at 31st December 2024 ASSETS Cash and balances with central bank 797,645 0 Due from banks 151,204 8,953 Financial assets measured at fair value through profit or loss 235,546 26,080 Derivative financial instruments 2,210 0 Loans and advances to customers 1,493,400 2,103,200 Financial assets measured at fair value through other comprehensive income 29,693 17,697 Debt securities at amortised cost 30 413,814 Investment in subsidiaries and associates 0 23,972 Property, plant and equipment 0 10,588 Intangible assets 0 8,193 Right of use assets 0 19,561 Deferred tax assets 0 10,603 Other assets 98,168 81,636 Total assets 2,807,896 2,724,297 LIABILITIES Due to banks 115,563 0 Due to customers 4,650,258 3,806 Derivative financial instruments 5,318 0 Lease liabilities 3,258 17,930 Retirement benefit obligations 0 964 Income tax liability 4,961 0 Other liabilities 122,933 0 Provisions 0 4,157 Total liabilities 4,902,291 26,857
127
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Amounts in Eur ‘000 Within 1 year After 1 year As at 31st December 2023 ASSETS Cash and balances with central bank 479,322 0 Due from banks 114,706 8,919 Financial assets measured at fair value through profit or loss 306,302 30,692 Derivative financial instruments 1,033 0 Loans and advances to customers 943,986 1,472,086 Financial assets measured at fair value through other comprehensive income 50,183 36,305 Debt securities at amortised cost 22,702 228,686 Investment in subsidiaries and associates 0 9,134 Property, plant and equipment 0 10,738 Intangible assets 0 7,421 Right of use assets 0 19,478 Deferred tax assets 0 8,938 Other assets 30,086 74,489 Total assets 1,948,320 1,906,886 LIABILITIES Due to banks 79,055 0 Due to customers 3,182,687 14,224 Derivative financial instruments 8,497 0 Lease liabilities 2,689 18,145 Retirement benefit obligations 0 650 Income tax liability 11,491 0 Other liabilities 39,082 0 Provisions 0 2,356 Total liabilities 3,323,501 35,375
37. Share based payments
With the decision of the Ordinary General Assesmbly dated 23/5/2024, an increase of the Bank's share capital
was carried out, through the capitalization of part of the profits of the fiscal year 2023, amounting to €276,000
with the issuance of 80,000 new registered, common, with voting rights, shares with a nominal value of €3.45
each.
At the same time, in the framework of the establishment of a share distribution program, the new shares were
made available free of charge to Members of the Board of Directors as well as to top management executives
of the Bank at a distribution price of €12.10.
During the comparative year, with the decision of the Ordinary General Meeting dated 7/6/2023, an increase of
the Bank's share capital was carried out on 26/7/2023, through the capitalization of part of the profits of the
year 2022, amounting to €3,399,999.15 with the issuance of 985,507 new registered, common, voting shares,
which were made available free of charge to members of the Board of Directors and staff.
In addition, with the decision of 26/9/2023 of the Board of Directors of the Bank, a parallel sale of 471,327
common, with voting rights, shares was carried out for the members of the Board of Directors of the Bank and
the staff with a sale price of €6.48 (reduced by 10% from the final sale price which amounted to €7.20).
The total of the aforementioned benefits amounts to €968 thousand for the year 2024, while the corresponding
benefits in the comparative year 2023 amounted to €5,326 thousand.
128
Notes to the Financial Statements dated December 31, 2024
Group and Bank
38. Commitments, contingent liabilities and assets
a) Contingent liabilities from guarantees
The nominal values of the contingent and undertaken liabilities are broken down as follows:
Group
Amounts in Eur ‘000 31/12/2024 31/12/2023 Letters of guarantee issued 855,132 616,459 855,132 616,459
Bank
Amounts in Eur ‘000 31/12/2024 31/12/2023 Letters of guarantee issued 855,132 616,459 855,132 616,459
In addition to the above, on December 31, 2024 the credit commitments include approved loan agreements
and credit limits of EUR 1,317,046 thousand for the Group (December 31, 2023: EUR 910,560 thousand) and
EUR 1,158,890 thousand for the Bank (December 31, 2022: EUR 799,927 thousand).
Approved undisbursed loan agreements and approved credit lines are revocable commitments as they include
amounts that can be unconditionally canceled at any time without notice and require the bank's prior approval.
b) Contingent tax liabilities
According to Law 4174/2013 (Article 65A as in force and as defined by article 82 of Law 2238/1994), Greek
companies whose financial statements are mandatorily audited are obliged to receive an “Annual Tax Certificate”
up to the fiscal year 2015, the issuance of which requires the conduct of a tax audit by its statutory auditors.
For fiscal years from 01/1/2016 onwards, the Annual Tax Certificate is optional, however the Bank continues to
receive it.
The Group has been audited by the tax authorities up to the financial year 2009. It has not been audited by
the tax authorities for the year 2010 when the Annual Tax Certificate was not compulsory.
The Bank has obtained a tax certificate from its Auditors without qualifications for the years 2011, 2012, 2015,
2016, 2017, 2018, 2019, 2020, 2021, 2022 and 2023. For the years 2013 and 2014, it has obtained a tax
certificate from its Auditors without qualifications, but with an emphasis of matter based on the inquiry
submitted by the Bank to the Ministry of Finance regarding the tax treatment of loss from the transfer of assets
and liabilities to Piraeus Bank.
For the financial year 2024, the Bank is audited by its Auditors. Said audit is in progress and the relevant tax
certificate is expected to be issued after the publication of the financial statements for the year 2024. We
consider that until the completion of the tax audit, no additional tax liabilities will arise that will have a significant
impact on the financial statements.
Within the fiscal year 2024, a tax audit was carried out from the tax authorities for the fiscal years 2019 and
2020 which gave resulted in a decrease of tax losses carried forward by the amount of EUR 405 thousand.
129
Notes to the Financial Statements dated December 31, 2024
Group and Bank
OPTIMA FACTORS S.A. has been tax audited for the years up to and including 2008 and has closed, in terms
of taxation the year 2009 in accordance with the provisions of Law 3888/2012. For the year 2010, the limitation
provisions of article 72 par. 11 Law 4174/2013 are applicable. For the years 2011, 2012 and 2013 the Company
has been audited by its statutory auditors and has received the annual tax certificate of paragraph 5, Article 82
of the Income Tax Code (Law 2238/1994), while for the years 2014 to 2023 a tax certificate has been issued
in accordance with Article 65A of Law 4174/2013. For the year 2024, the audit for the issuance of the annual
tax certificate is in progress. We consider that until the completion of the audit, no additional tax liabilities would
arise that would have a significant impact on the financial statements.
Moreover, OPTIMA ASSET MANAGEMENT S.A. has been tax audited for the years 2011 to and including 2013
and the said tax audit is conducted in accordance with Article 82, para. 5 of Law 2238/1994 and the Decision
ref. POL 1159/22.7.2011 of the Minister of Finance. The years 2014 to and including 2023 have been audited
in accordance with Article 65 A of Law 4174/2013. For the year 2024, the tax audit is in progress and is expected
to be completed within the time limits provided for. We consider that until the completion of the audit, no
additional tax liabilities would arise that would have a significant impact on the financial statements.
IBG CAPITAL SA has obtained a tax certificate without qualifications from its Auditors for the financial years
2011 to and including 2013, while for the years 2014 to and including 2018 it has not obtained any tax certificate
in accordance with Law 4174/2013, Article 65. For the years 2019 to 2023, the company has obtained a tax
certificate without qualifications, while for the year 2024 the audit in the process of the tax certificate is in
progress. We consider that until the completion of the audit, no additional tax liabilities would arise that would
have a significant impact on the financial statements.
IBG INVESTMENTS S.A. has no tax liabilities in accordance with the tax framework of its country of
establishment.
According to the Greek tax legislation and the relevant ministerial decisions, the companies for which a tax
certificate without qualification is issued, are not exempted from the imposition of additional taxes and fines by
the tax authorities within the framework of the legislative restrictions (five years from the end of the fiscal year
in which the relevant tax return should have been submitted). In light of the above, as a general rule, the right
of the Greek State to impose taxes until the 2018 financial year is considered to have passed for the Group.
c) Contingent legal obligations
There are no pending legal claims or liabilities that could materially affect the financial position of the Group on
December 31, 2024, except for the cases for which a relevant provision has already been formed (note 33).
d) Asset commitments
Due from banks:
• Placements of EUR 25,622 thousand relate to derivative instruments transaction guarantees as of
31/12/2024 (EUR 19,565 thousand as of 31/12/2023).
130
Notes to the Financial Statements dated December 31, 2024
Group and Bank
• Amount of a book value of EUR 3,485 thousand (EUR 10,248 thousand on 31/12/2023) relates to
counter-guarantees for letters of guarantee issued by cooperating banks. These are cases where
we do not have a correspondence relation with the beneficiary’s Bank.
Investment and trading portfolio securities:
• Amount of a book value of EUR 3,326 thousand on 31/12/2024 (EUR 63,882 thousand 31/12/2023)
relates to securities lending to cooperating banking institutions, in the framework of the utilization
of the Bank's assets with the parallel receipt of interest income on 31/12/2024.
Loans and advances to customers:
The nominal value of EUR 44,438 thousand corresponds to a portfolio of loan receivables from businesses (pool
of credit claims) on 31/12/2024, which is pledged in the Bank of Greece as collateral for Eurosystem monetary
policy practices.
The upper amount is subject to a 60% cut (haircut) and is ultimately set to EUR 17,775 thousand which is also
the maximum potential amount of funding from the Eurosystem against the portfolio of loan claims. As of
12/31/2024, the Bank had not made use of the specific pledge for the purposes of raising liquidity.
39. Related party transactions
All transactions are conducted at arm’s length and fall within the scope of the normal activities of the Group.
The volume of transactions per category is presented here below.
39.1 Transactions with subsidiaries and associates of Optima Bank
Amounts in Eur '000GROUP BANK a) Accounts Receivable Receivables from subsidiaries 31/12/2024 31/12/2024 Loans net of provisions 0 136,877 Other receivables 0 869 Total 0 137,746 Receivables from associates 31/12/2024 31/12/2024 Loans net of provisions 16,343 10,502 Total 16,343 10,502
Loans net of provisions include an impairment provision of EUR 39 thousand for loans to subsidiaries (EUR 453
thousand 31/12/2023).
131
Notes to the Financial Statements dated December 31, 2024
Group and Bank
Amounts in Eur '000 GROUP BANK b) Accounts payable Payables to subsidiaries 31/12/2024 31/12/2024 Due to clients 0 17,575 Other liabilities 0 153 Total 0 17,728 Amounts in Eur '000 GROUP BANK c) Income 1/1/2024 - 1/1/2024 - Income from subsidiaries 31/12/2024 31/12/2024 Interest and similar income 0 7,242 Fee and commission income 0 1,362 Total 0 8,800 1/1/2024 - 1/1/2024 - Income from associates 31/12/2024 31/12/2024 Interest and similar income 935 761 Fee and commission income 173 51 Total 1,108 812 Amounts in Eur '000 GROUP BANK d) Expenses 1/1/2024 - 1/1/2024 - Expenses from subsidiaries 31/12/2024 31/12/2024 Interest expense and similar charges 0 (24) Total 0 (24) 1/1/2024 - 1/1/2024 - Expenses from associates 31/12/2024 31/12/2024 Interest expense and similar charges (1) (1) Total (1) (1) Amounts in Eur '000GROUP BANK a) Accounts Receivable Receivables from subsidiaries 31/12/2023 31/12/2023 Loans net of provisions 0 103,405 Other receivables 0 13 Total 0 103,418 Receivables from associates 31/12/2023 31/12/2023 Loans net of provisions 11,219 9,723 Other receivables 29 29 Total 11,248 9,752 Amounts in Eur '000 GROUP BANK b) Accounts payable Payables to subsidiaries 31/12/2023 31/12/2023 Due to clients 0 6,566 Total 0 6,566
132
Notes to the Financial Statements dated December 31, 2024
Group and Bank
It is noted that the above transactions are carried out within the framework of business as usual, based on
the arm’s length principle and the usual commercial terms for relevant transactions with third parties (market
terms).
39.2 Related party transactions with managers, directors and immediate family members
Amounts in Eur '000 GROUP BANK a) Accounts receivable 31/12/2024 31/12/2024 Loans 1,848 1,848 Total 1,848 1,848 b) Accounts payable 31/12/2024 31/12/2024 Deposits 5,413 5,413 Total 5,413 5,413 1/1/2024 - 1/1/2024 - c) Income 31/12/2024 31/12/2024 Interest and similar income 82 82 Fee and commission income 18 18 Other income 1 1 Total 101 101 Amounts in Eur '000 GROUP BANK a) Accounts receivable 31/12/2023 31/12/2023 Loans 5,572 5,572 Total 5,572 5,572 b) Accounts payable 31/12/2023 31/12/2023 Deposits 3,401 3,042 Total 3,401 3,042
Amounts in Eur '000 GROUP BANK c) Income 1/1/2023 - 1/1/2023 - Income from subsidiaries 31/12/2023 31/12/2023 Interest and similar income 0 4,159 Fee and commission income 0 888 Other income 0 176 Total 0 5,223 1/1/2023 - 1/1/2023 - Income from associates 31/12/2023 31/12/2023 Interest and similar income 787 745 Fee and commission income 34 2 Total 821 747 d) Expenses 1/1/2023 - 1/1/2023 - Expenses from subsidiaries 31/12/2023 31/12/2023 Interest expense and similar charges 0 (7) Total 0 (7)
133
Notes to the Financial Statements dated December 31, 2024
Group and Bank
1/1/2023 - 1/1/2023 - c) Income 31/12/2023 31/12/2023 Interest and similar income 105 103 Total 105 103 1/1/2023 - 1/1/2023 - d) Expenses 31/12/2023 31/12/2023 Interest expense and similar charges (7) (6) Total (7) (6)
It is noted that the above transactions are carried out within the framework of business as usual, based on
the arm’s length principle and the usual commercial terms for relevant transactions with third parties (market
terms).
39.3 Remuneration of Management and members of the Board of Directors
GROUP BANK 1/1/2024 - 1/1/2024 - Amounts in Eur '00031/12/2024 31/12/2024 Salaries, social insurance contributions and other expenses 4,165 3,716 Compensation & other benefits 150 127 Stock awards 968 968 Total 5,283 4,811 GROUP BANK 1/1/2023 - 1/1/2023 - Amounts in Eur '000 31/12/2023 31/12/2023 Salaries, social insurance contributions and other expenses 2,937 2,548 Compensation & other benefits 143 110 Stock awards 3,698 3,698 Total 6.778 6.356
40. Auditor’s fees
The total fees paid by the Bank to the statutory auditor “Deloitte Certified Public Accountants S.A.” for the audit
and other services they provided are broken down as follows:
Amounts in Eur ‘000 31/12/2024 31/12/2023 Statutory Audit 332 300 Tax Certificate 87 87 Non audit services 155 280 Total 574 667
41. Segment Reporting
Bank's management monitors returns from banking, treasury, and capital market activities on an aggregated
basis. The amounts related to the net revenues of the business sectors derive from direct net revenues and do
not include internal allocations and financing between sectors.
As regards the costs, they are reported in total, since they are monitored at the level of the business owner by
the Bank’s management.
134
Notes to the Financial Statements dated December 31, 2024
Group and Bank
At the same time, the Bank's Management monitors separately the results of the Group's subsidiaries.
Amounts in Eur '000 1/1/2024 - 31/12/2024 Total Total Banking Brokerage Treasury Other Bank Subsidiaries Eliminations Group Income from operating activities Net interest income 145,727 2,738 39,275 (730) 187,010 2,776 71 189,857 Net fee and commission income 27,584 9,074 0 34 36,692 4,640 0 41,332 Gains/losses from financial transactions 0 0 18,126 2,043 20,169 138 0 20,307 Other operating income 0 0 496 2,847 3,343 80 (196) 3,227 Total operating income 173,311 11,812 57,897 4,194 247,214 7,634 (125) 254,723 Other non allocated amounts (75,084) (2,858) (139) (78,081) Profit before tax 172,130 176,640 Profit after tax 136,712 140,226 Assets 31/12/2024 3,588,389 90,987 1,707,272 145,545 5,532,193 186,053 (177,299) 5,540,947 Liabilities 31/12/2024 4,906,620 50,978 212,484 56,066 4,929,148 147,499 (155,999) 4,920,648 Amounts in Eur '000 1/1/2023 - 31/12/2023 Total Total Banking Brokerage Treasury Other Bank Subsidiaries Eliminations Group Income from operating activities Net interest income 111,666 1,694 27,949 (1,128) 140,181 2,044 (12) 142,212 Net fee and commission income 21,301 7,187 0 44 28,531 3,518 70 32,119 Gains/losses from financial transactions 0 0 16,439 1,404 17,843 (179) (51) 17,614 Other operating income 0 0 400 754 1,154 39 (182) 1,012 Total operating income 132,967 8,881 44,789 1,074 187,710 5,422 (176) 192,957 Other non allocated amounts (64,555) (2,194) (263) (67,013) Profit before tax 123,155 125,944 Profit after tax 100,721 103,023 Assets 31/12/2023 2,401,273 82,987 1,279,444 91,503 3,855,207 130,266 (117,204) 3,868,269 Liabilities 31/12/2023 3,137,062 57,659 88,169 75,987 3,358,877 110,124 (110,809) 3,358,192
42. Irrevocable payment commitments to the Single Resolution Board (SRB)
The Bank does not make use of the irrevocable payment commitments to the Single Resolution Board. During
the financial year 2024 there was no obligation for a payment contribution. The contribution for the financial
year 2023 amounted to EUR 737 thousand and burdened the profit before tax.
43. Distribution of dividend
Following the decision of the Annual General Meeting of Shareholders dated 23/5/2024, the Bank proceeded to
the distribution of gross dividend amounting to EUR 0.44 per share, from the profits of the financial year 2023
for a total amount of EUR 32,461 thousand.
The dividend was paid on 1/7/2024.
135
Notes to the Financial Statements dated December 31, 2024
Group and Bank
44. Disclosures of Law 4261/5.5.2014
In accordance with article 81 of Law 4261/2014, which incorporates into Greek legislation article 89 of Directive
2013/36/EU of the European Parliament and of the Council of June 26, 2013, it is enacted for the first time, the
obligation for the Group to disclose information on a consolidated basis for each country in which it operates.
The disclosed information includes: the name of the subsidiary company/ companies, the nature of activities,
the geographical location, the turnover, the number of full-time employees, results before tax, income tax, as
well public subsidies received.
The required information is presented below:
Greece
On 31/12/2024 the turnover amounted to EUR 254,715 thousand (EUR 193,167 thousand on 31/12/2023),
profits before tax amounted to EUR 176,641 thousand (EUR 126,161 thousand on 31/12/2023), income tax
amounted to EUR 36,414 thousand (EUR 22,921 thousand on 31/12/2023) and the number of employees was
575 (500 employees on 31/12/2023).
The following companies are active in the country:
Company Activity OPTIMA BANK S.A. Bank IBG CAPITAL S.A. Capital & Holdings Company OPTIMA FACTORS S.A. Factoring Company OPTIMA ASSET MANAGEMENT Α.Ε.D.Α.Κ. Asset Management Company OPTIMA LEASING S.A. Leasing Company
British Virgin Islands
On 31/12/2024 the turnover amounted to EUR 7 thousand (EUR 210 thousand on 31/12/2023) and the loss to
EUR 0.1 thousand (profit before tax EUR 217 thousand on 31/12/2023). There is no staff and no tax liability.
The company operating in the country is as follows:
Company Activity ΙΒG INVESTMENTS S.A. Investment services
Within 2023, the last investment of AKES (Closed-end Mutual Fund), of which IBG Investments is a shareholder,
was liquidated.
The Bank estimates that within 2025, the dissolution of IBG Investments will take place.
It is noted that neither the Bank nor any of the Group's companies have received public subsidies.
45. Disclosures of Law 4151/2013
According to the provisions of article 8 par. 3 of L. 4151/2013, any active credit institution established in Greece,
is obliged, immediately after the expiry of the twenty-year time limit, to remit to the Greek State collectively,
by the end of April of each year, the balances of dormant deposits, plus accrued interest. The Bank has no
dormant balances that have reached the twenty-year time limit.
136
Notes to the Financial Statements dated December 31, 2024
Group and Bank
46. Events after the reporting period date
There are no events subsequent to the financial statements issue.
Maroussi, March 20, 2025
The Chairman of the Board
of Directors
The Chief Executive Officer
Georgios Taniskidis
Dimitrios Kyparissis
The Head of Finance
The Head of Accounting and Tax
Services
Angelos Sapranidis
Eleni Peristera
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