Athens, March 6, 2024
ANNUAL REPORT
For the period from 1 January to 31 December 2023
(In accordance with Law 3556/2007)
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
5 | ANNUAL FINANCIAL REPORT
Contents
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS ................................................. 11
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023 ....................... 6
NON-FINANCIAL REPORT ........................................................................................................... 35
EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF ALPHA SERVICES AND
HOLDINGS S.A. FOR THE YEAR 2023 ........................................................................................ 75
CORPORATE GOVERNANCE STATEMENT ............................................................................... 78
INDEPENDENT AUDITOR’S REPORT ....................................................................................... 135
Group Financial Statements as at 31.12.2023 ............................................................................. 146
Consolidated Income Statement .................................................................................................. 147
Consolidated Statement of Comprehensive Income .................................................................... 148
Consolidated Balance Sheet ........................................................................................................ 149
Consolidated Statement of Changes in Equity ............................................................................. 150
Consolidated Statement of Cash Flows ....................................................................................... 152
Notes to the Consolidated Financial Statements ......................................................................... 153
GENERAL INFORMATION.................................................................................................................................... 153
ACCOUNTING POLICIES APPLIED ..................................................................................................................... 156
1. Accounting policies applied ........................................................................................................................... 156
1.1 Basis of presentation ....................................................................................................................................... 156
1.2 Material accounting policies ............................................................................................................................. 164
1.3 Significant accounting judgments and key sources of estimation uncertainty ................................................. 194
INCOME STATEMENT .......................................................................................................................................... 199
2. Net interest income ....................................................................................................................................... 199
3. Net fee and commission income ................................................................................................................... 200
4. Dividend income ............................................................................................................................................ 201
5. Gains less losses on derecognition of financial assets measured at amortised cost ................................... 201
6. Gains less losses on financial transactions .................................................................................................. 202
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6 | ANNUAL FINANCIAL REPORT
7. Other Income ................................................................................................................................................. 203
8. Staff costs ...................................................................................................................................................... 203
9. General Administrative expenses ................................................................................................................. 207
10. Impairment losses and provisions to cover credit risk .................................................................................. 208
11. Expenses relating to credit risk management ............................................................................................... 209
12. Impairment losses on fixed assets and equity investments .......................................................................... 209
13. Gains/(Losses) on disposal of fixed assets and equity investments ............................................................. 210
14. Provisions ...................................................................................................................................................... 210
15. Transformation costs ..................................................................................................................................... 210
16. Income tax ..................................................................................................................................................... 211
17. Earnings/(losses) per share .......................................................................................................................... 213
ASSETS ................................................................................................................................................................. 215
18. Cash and balances with Central Banks ........................................................................................................ 215
19. Due from banks ............................................................................................................................................. 215
20. Trading securities .......................................................................................................................................... 216
21. Derivative financial instruments (assets and liabilities) ................................................................................. 216
22. Loans and advances to customers ............................................................................................................... 225
23. Investment securities .................................................................................................................................... 228
24. Investments in associates and joint ventures ............................................................................................... 230
25. Investment property ...................................................................................................................................... 235
26. Property plant and equipment ....................................................................................................................... 236
27. Goodwill and other intangible assets ............................................................................................................ 237
28. Deferred tax assets and liabilities ................................................................................................................. 238
29. Other assets .................................................................................................................................................. 240
LIABILITIES ........................................................................................................................................................... 241
30. Due to Banks ................................................................................................................................................. 241
31. Due to customers .......................................................................................................................................... 241
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
7 | ANNUAL FINANCIAL REPORT
32. Insurance Contract Liabilities ........................................................................................................................ 241
33. Debt securities in issue and other borrowed funds ....................................................................................... 245
34. Liabilities for current income tax and other taxes .......................................................................................... 248
35. Employee defined benefit obligations ........................................................................................................... 248
36. Other Liabilities .............................................................................................................................................. 254
37. Provisions ...................................................................................................................................................... 255
EQUITY .................................................................................................................................................................. 256
38. Share Capital ................................................................................................................................................. 256
39. Share premium, Special Reserve from Share Capital Decrease .................................................................. 257
40. Other Equity Instruments .............................................................................................................................. 257
41. Reserves ....................................................................................................................................................... 258
42. Retained Earnings ......................................................................................................................................... 260
ADDITIONAL INFORMATION ............................................................................................................................... 261
43. Contingent liabilities and commitments ......................................................................................................... 261
44. Group Consolidated Companies ................................................................................................................... 268
45. Disclosures Law 4261/5.5.2014 .................................................................................................................... 280
46. Segment Reporting ....................................................................................................................................... 286
47. Risk Management ......................................................................................................................................... 289
47.1 Credit Risk ..................................................................................................................................................... 290
47.2 Market Risk ................................................................................................................................................... 370
47.3 Liquidity risk ................................................................................................................................................... 377
47.4 Fair value of financial assets and liabilities ................................................................................................... 383
47.5 Transfers of financial assets ......................................................................................................................... 390
47.6 Offsetting financial assets - liabilities ............................................................................................................ 391
47.7 Disclosures on interest rate reform ............................................................................................................... 393
48. Capital Adequacy .......................................................................................................................................... 394
49. Related party transactions ............................................................................................................................ 396
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
8 | ANNUAL FINANCIAL REPORT
50. Auditor’s fees ................................................................................................................................................. 398
51. Disclosure of Law 4151/2013 ........................................................................................................................ 398
52. Assets held for sale ....................................................................................................................................... 399
53. Corporate events relating to the Group structure .......................................................................................... 404
54. IFRS 17 adoption and restatement of Financial Statements ........................................................................ 407
55. Discontinued Operations ............................................................................................................................... 413
56. Strategic Plan ................................................................................................................................................ 415
57. Events after the balance sheet date.............................................................................................................. 415
Financial Statements of Alpha Services and Holdings S.A. as at 31.12.2023 ............................. 417
Income Statement ........................................................................................................................ 418
Statement of Comprehensive Income .......................................................................................... 419
Balance Sheet .............................................................................................................................. 420
Statement of Changes in Equity ................................................................................................... 421
Statement of Cash Flows ............................................................................................................. 423
Notes to the Financial Statements ............................................................................................... 424
GENERAL INFORMATION.................................................................................................................................... 424
1. Accounting policies applied ............................................................................................................................... 427
1.1 Basis of presentation ....................................................................................................................................... 427
1.2 Material accounting policies ............................................................................................................................. 435
1.3 Significant accounting judgments and key sources of estimation uncertainty ................................................. 454
INCOME STATEMENT .......................................................................................................................................... 455
2. Net interest income ............................................................................................................................................ 455
3. Net fee and commission income ........................................................................................................................ 455
4. Dividend income ................................................................................................................................................ 456
5. Gains less losses on financial transactions ....................................................................................................... 456
6. Other Income ..................................................................................................................................................... 456
7. Staff costs and expenses ................................................................................................................................... 456
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
9 | ANNUAL FINANCIAL REPORT
8. General administrative expenses ...................................................................................................................... 457
9. Impairment losses, provisions to cover credit risk ............................................................................................. 457
10. Expenses relating to credit risk management .................................................................................................. 457
11. Income Tax ...................................................................................................................................................... 458
12. Earnings/(losses) per share ............................................................................................................................. 459
ASSETS ................................................................................................................................................................. 460
13. Due from banks ................................................................................................................................................ 460
14. Due from customers ......................................................................................................................................... 460
15. Investment securities ....................................................................................................................................... 460
16. Investments in subsidiaries .............................................................................................................................. 461
17. Property plant and equipment .......................................................................................................................... 462
18. Goodwill and other intangible assets ............................................................................................................... 462
19. Other assets ..................................................................................................................................................... 463
LIABILITIES ........................................................................................................................................................... 464
20. Due to Banks ................................................................................................................................................... 464
21. Debt securities in issue and other borrowed funds .......................................................................................... 464
22. Liabilities for current income tax and other taxes ............................................................................................ 465
23. Employee defined benefit obligations .............................................................................................................. 465
24. Deferred tax liabilities....................................................................................................................................... 467
25. Other liabilities ................................................................................................................................................. 467
EQUITY .................................................................................................................................................................. 468
26. Share Capital ................................................................................................................................................... 468
27. Share premium ................................................................................................................................................ 468
28. Special Reserve from Share Capital Decrease ............................................................................................... 469
29. Other equity instruments .................................................................................................................................. 469
30. Reserves .......................................................................................................................................................... 469
31. Retained earnings ............................................................................................................................................ 470
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10 | ANNUAL FINANCIAL REPORT
ADDITIONAL INFORMATION ............................................................................................................................... 471
32. Contingent liabilities and commitments ........................................................................................................... 471
33. Risk Management ............................................................................................................................................ 472
34. Related party transactions ............................................................................................................................... 484
35. Auditors’ fees ................................................................................................................................................... 486
36. Assets held for sale .......................................................................................................................................... 487
37. Awarding of stock options to employees ......................................................................................................... 487
38. Stock awards to employees ............................................................................................................................. 489
39. Corporate events ............................................................................................................................................. 489
40. Restatement of financial statements ................................................................................................................ 490
41. Strategic Plan ................................................................................................................................................... 491
42. Events after the balance sheet date ................................................................................................................ 491
Appendix of the Board of Directors’ Annual Management Report ................................................ 493
Appendix for Non-Financial Report .............................................................................................. 499
Disclosures of Law 4374/2016 ..................................................................................................... 543
Availability of Annual Financial Report ......................................................................................... 553
STATEMENT BY THE MEMBERS OF BOARD OF DIRECTORS
11 | ANNUAL FINANCIAL REPORT
STATEMENT BY THE MEMBERS OF BOARD OF
DIRECTORS
(in accordance with article 4 paragraph 2 of Law 3556/2007)
To the best of our knowledge, the annual financial statements that have been prepared in accordance with the applicable
accounting standards, give a true view of the assets, liabilities, equity and financial performance of Alpha Services and Holdings
S.A. and of the group of companies included in the consolidated financial statements taken as a whole, as provided in article 4
paragraph 2 of Law 3556/2007, and the Board of Directors’ Annual Management Report presents fairly the evolution, performance
and financial position of Company, and group of companies included in the consolidated financial statements taken as a whole,
including the analysis of the main risks and uncertainties that they face.
Athens, March 6, 2024
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
EXECUTIVE MEMBER
OF THE BOARD OF DIRECTORS
VASILEIOS T. RAPANOS
ID. No ΑΙ 666242
VASSILIOS E. PSALTIS
ID No ΑΙ 666591
SPIROS N. FILARETOS
ID. No AK022255
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
6 | ANNUAL FINANCIAL REPORT
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT
REPORT AS AT 31.12.2023
MACROECONOMIC ENVIRONMENT
GREEK ECONOMY
Real GDP expanded by 2.2% on an annual basis in the first nine months of 2023, compared to 6.2% in the same period of 2022,
according to the Hellenic Statistical Authority (ELSTAT). Economic activity in Q3 2023 experienced significant growth on an annual
basis, by 2.1% and a marginal increase on a quarterly basis, by 0.02%. GDP growth during the first nine months of 2023 was
supported by the increase in investment, private and public consumption, as well as exports. The Economic Sentiment Indicator
(ESI) signals that economic activity in Greece continues to strengthen, remaining consistently above the euro area average since
May 2022. In December 2023, the difference between the ESI in Greece and the Euro Area stood at 9.4 points (105.8 in Greece vs
96.4 in the Εuro area).
Additionally, inflationary pressures are gradually receding. In 2023, inflation based on the Harmonized Index of Consumer Prices
(HICP) averaged to 4.2% compared to 9.3% in 2022. This was the result of two opposing forces: the decline of energy prices and
the upward pressures on food and services prices. Energy prices decreased by an average of 13.4% during the year, while food
(including alcohol and tobacco) and services’ prices rose by 10% and 4.5%, respectively.
The general government primary balance returned to positive territory in 2022, for the first time since the outbreak of the COVID-19
pandemic, standing at 0.1% of GDP. According to the 2024 State Budget by the Ministry of Economy and Finance the general
government primary balance is expected to further increase to 1.1% of GDP in 2023 and subsequently to 2.1% of GDP in 2024, .
The better-than-initially-expected performance of public finances in 2022 is mainly attributed to the overperformance of tax
revenues, combined with the strong economic recovery (8.4% in 2021; 5.6% in 2022). According to the latest available data
published by ELSTAT (Quarterly Non-Financial Accounts of General Government, January 2024) in the third quarter of 2023 the
primary surplus was equal to Euro 3.3 billion, compared to Euro 0.1 billion in the respective period of 2022. Furthermore, in 2022,
Greece recorded the largest annual reduction in public debt as a percentage of GDP among the European Union (EU-27)
countries, by 22.4 percentage points, reaching 172.6% of GDP, while the debt-to-GDP ratio it is expected to further decrease to
160.3% of GDP in 2023 and 152.3% in 2024 (Ministry of Economy and Finance, 2024 State Budget).
Since the start of 2023, Greece has raised a total of Euro 11.5 billion by issuing three new bonds : a ten-year in January, a five-
year in March and a fifteen-year in July, amounting to Euro 3.5 billion, Euro 2.5 billion and Euro 3.5 billion respectively. In addition,
nine existing bonds were reopened, raising a total of Euro 2 billion . The borrowing cost — which increased globally in 2022 due to
heightened uncertainty and the adverse effects of inflation — decreased in 2023. The decline accelerated after the national
elections held in May. As a result, the spread of the 10-year Greek Government Bond (GB) against the respective German GB
narrowed to 104 basis points (bps) on 29.12.2023, from 205 bps on 31.12.2022, remaining below Italy’s corresponding spread
since May 2023 and approaching the Spanish spread. In 2023, Greece achieved a significant milestone by regaining investment
grade status after 13 years. Several rating agencies upgraded the Greek sovereign above the particular threshold, due to the
ongoing improvement in macroeconomic and fiscal figures. DBRS upgraded Greece to BBB (low) in September, whereas S&P in
October and Fitch in December both affirmed a BBB- rating, with a stable outlook.
The unemployment rate stood at an average of 11% in 2023, from 12.4% in 2022. Employment continued to grow in 2023, although
at a slower pace than the previous year (1.3% in 2023, compared to 5.4% in 2022).
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The domestic real estate market continued to recover at a strong pace in 2023. According to the latest (provisional) data by the
Bank of Greece, in the first nine months of the year, nominal house prices rose by 13.9% on an annual basis, compared to 11.9%
in 2022. Similarly, commercial real estate prices (offices and shops) remained on an upward trajectory in the first half of 2023, rising
on an annual basis by 6.6% and 6.9%, respectively.
In the first nine months of 2023, the profitability of Greek banks increased by 4.6% compared to the corresponding period in 2022.
This upturn can be attributed to a rise in the net interest income and a reduction in credit risk provisions (Bank of Greece, Interim
Monetary Policy Report, December 2023). The Total Capital Ratio (TCR) for the Greek banks, on a consolidated basis, stood at
17.6% in September 2023 from 17.5% in December 2022, whereas the Common Equity Tier 1 (CET 1) ratio reached 14.3%
respectively, from 14.5% in December 2022.
In 2023, the sum of the private sector’s net deposit flows in the domestic banking system was positive (Euro 5.8 billion), following a
total increase of Euro 8 billion in 2022. Net credit expansion continued to rise in 2023, although at a slower pace compared to the
previous year. The annual rate of change of total credit to the private sector stood at 3.6% in December 2023, against 6.3% in
December 2022. Specifically, the annual rate of change of credit to non-financial corporations stood at 5.9% in December 2023,
whereas credit to households remains in negative territory.
THE PROSPECTS OF THE GREEK ECONOMY
According to the latest forecasts (Ministry of Economy and Finance, European Commission, International Monetary Fund,
Organisation for Economic Co-operation and Development), real GDP growth is estimated to slightly exceed 2% in 2023 and range
between 2% and 2.9% in 2024, significantly above the Euro area average (0.6% and 1.2% respectively according to the European
Commission). Economic growth is expected to be driven by three main factors: (i) increased investment due to absorption of the
Recovery and Resilience Facility (RRF) implementation of the Public Investment Budget (PIB) and increased Foreign Direct
Investment (FDI) flows, (ii) enhanced extroversion of the Greek firms, and (iii) strong private consumption, because of gradually
receding inflationary pressures.
Downside risks to the growth prospects in 2024 are mainly related to: (i) the adverse effects of persisting inflation on households’
real disposable income, which however is expected to further de-escalate to 2.6% this year (2024 State Budget), (ii) the monetary
policy tightening and the increased borrowing cost, (iii) any delays in the absorption rate of RRF funds and the implementation of
the plan, (iv) delays in the implementation of structural reforms (v) geopolitical risks associated with the ongoing conflicts in Ukraine
and the Middle East, (vi) the implications of climate change — such as the extreme weather conditions that led to natural disasters
in Greece during the third quarter of 2023, especially the devastating floods in the Thessaly region — and (vii) the slowdown in the
European economy, given that European Union countries are Greece’s main trading partners.
As far as point (vi) is concerned, it is noted that the periphery of Thessaly represents 5.2% of Greece’s GDP (2020 data in current
prices) and 14% of the economy’s total agricultural production (in terms of Gross Value Added). In the short- and medium-term
horizon, the impact on disposable income may be partly counterbalanced by the sizeable policy responses of the Hellenic
Government, European Commission and Hellenic Bank Association (HBA). However, there may be further inflationary pressures
on food prices. Furthermore, the decline in exports and the corresponding increase in imports to compensate for the decrease in
agricultural and livestock production for domestic consumption, may worsen the trade deficit.
GLOBAL ECONOMY
In 2023, the global economy faced several challenges. Persistent inflationary pressures — despite the declining trend of the last
months —, the banking sector turmoil and the tightening of monetary policies were some of the major issues. The consequences of
climate change and the rising risk of geo-economic fragmentation also added to the challenges. Furthermore, geopolitical
uncertainties, mainly provoked by the Russian invasion of Ukraine and the conflict in the Middle East, further complicated the
situation.
Despite the significant tightening of monetary policy, the United States (USA) economy recorded a better-than-expected
performance in 2023. Growth has been revised upwards, while the inflationary pressures have eased, however, remaining at a
relatively high level. In parallel, in China, after the pandemic measures were lifted, the economy struggled to rebound. It faced
problems in the real estate sector, but a broader recovery in consumption was achieved. According to the latest available data,
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
8 | ANNUAL FINANCIAL REPORT
global growth was modest in 2023 varying widely between countries, as it depends on (i) exposure to geopolitical tensions, ii)
disruption in supply chains and the volatility in energy prices, iii) the impact of fiscal policies to tackle the consequences of climate
change and iv) monetary policy. The combination of higher inflation versus the pre-pandemic period — especially core inflation —
with slow growth and excessive debt levels- could pose significant risks to the global economy.
According to the International Monetary Fund (IMF, World Economic Outlook Update, January 2024), global GDP growth
decelerated to 3.1% in 2023 from 3.5% in 2022, while it is expected to remain at 3.1% in 2024, before increasing again to 3.2% in
2025. Global inflation pressures have been declining since mid-2022, mainly as a result of the fall in fuel and energy commodity
prices and central banks’ monetary policies. According to the IMF (World Economic Outlook Update, January 2024), global inflation
is estimated to fall from 8.7% in 2022 to 6.8% in 2023 and 5.8% in 2024, remaining above the pre-pandemic level.
In 2024, the tightening of the monetary policy, which is necessary to tame persistent inflation, is expected to continue, despite the
expected cut rates, potentially after mid-2024. The Federal Reserve (FED) has raised interest rates 11 times since March 2022, at
a level ranging from 5.25% to 5.50%. However, FED has kept the policy rate unchanged since its meeting in September 2023. The
Bank of England (BoE) was one of the first central banks to begin the interest rates hikes. Ιn December 2023, the BoE left policy
rates unchanged to 5.25%, for the third meeting in a row, which is the highest level since 2008. The European Central Bank (ECB)
proceeded with consecutive interest rate increases in 2022 and 2023. At the last meeting of 2023, the ECB left its main interest
rates unchanged, including the main refinancing rate at 4.50%.
The main uncertainties that could affect the global economy are the following:
First, the geopolitical tensions in Ukraine and the Middle East. The duration of the Russian invasion of Ukraine and the possibility of
a wider tension in the Middle East, could disrupt global trade and gas and oil exports, potential leading to a renewed inflation shock.
Second, there is a risk of global geo-economic fragmentation. The pandemic and energy crisis have affected international relations
and the rivalry between the US and China. Furthermore, governments have reinforced initiatives, such as the Inflation Reduction
Act (IRA) and Chips Act in the US, as well as the European response, the EU Green Deal Industrial Plan.
Third, China’s economic growth. China’s economy has rebounded moderately in 2023, as uncertainties remain due to real estate
pressures and declining private investment. Monetary and fiscal policy should continue to support growth in the near term, as
structural reforms need to be implemented in China.
Fourth, governments will start to withdraw, gradually, the energy support measures from the beginning of 2024. Central banks may
need to hold their monetary policy tight, in order to curb inflationary pressures.
Fifth, the impact of climate change on public finances should be considered. Climate disasters and the warming of global
temperature are causing increasingly frequent and intense public economic damage, disproportionally affecting emerging markets
and developing economies, relative to advanced economies. Also, the green transition and digital transformation require significant
structural investments soon.
Sixth, upcoming elections. 2024, will be a crucial election year, as more than half of the world’s population is expected to go to the
polls. Τhe uncertain outcomes of elections in the U.S., India, Russia and the EU, are a major source of risk and could reshape the
global political landscape.
EUROZONE
According to the European Central Bank's December 2023 macroeconomic projections, the main factors that played an important
role in the euro area's anemic economic growth last year were high interest rates, tighter financing conditions, the recession in
Germany and the mild loss of competitiveness of European exports, primarily due to energy prices and the euro exchange rate
development. The geopolitical unrest in the Middle East remains an unpredictable element. Real GDP growth is estimated at 0.5%
in 2023, from 3.4% in 2022, and is projected to rebound marginally to 0.9% in 2024 and 1.7% in 2025 (IMF, World Economic
Outlook Update, January 2024). The mild recovery next year is expected to be supported by the strengthening of real disposable
income and foreign demand, and thus by higher private consumption and exports.
Regarding inflation based on the Harmonised Index of Consumer Prices, it is forecast to stand at 5.4% in 2023 from 8.4% in 2022
and to decline further to 2.7% in 2024 and 2.1% in 2025, very close to the ECB's target (ECB Macroeconomic Projections,
December 2023). Energy inflation is expected to rise in 2024, offsetting, to some extent, the decline in food inflation.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
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Although, employment growth decelerated in 2023 to 1.4% from 2.3% in 2022, reflecting the current climate of sluggish economic
development, the labor market is still predicted to be resilient. However, employment growth will stabilize at 0.4% in 2024-2026
(ECB Macroeconomic Projections, December 2023).
COUNTRIES WHERE THE GROUP OPERATES
Cyprus
Economic activity in Cyprus has fully rebounded following the pandemic crisis; nevertheless real GDP growth is anticipated to be
milder in 2023 (2.2%, based on the European Commission’s Autumn Forecast) compared to 2021-2022. The slowdown in
economic activity is attributed to inflationary pressures, higher interest rates and the weakening growth prospects of the country’s
trading partners. The national Recovery and Resilience Plan is expected to support economic activity, particularly investments. In
addition, the governmental measures to address inflation and the implementation of the automatic wage indexation will remain in
effect, supporting consumption. According to European Commission forecasts (European Economic Forecast Autumn 2023) real
GDP growth to expected to be around 2.6% in 2024.
Annual harmonised inflation decelerated from 8.1% in 2022, to 3.9% in 2023. According to the European Commission (European
Economic Forecast Autumn 2023), it is expected to further decelerate to 3% in 2024, fueled by decreasing energy costs and
governmental support measures.
Public debt is set to decline significantly from 85.6% of GDP in 2022, to 78.4% in 2023 and 71.5% in 2024, due to high nominal
GDP growth and significant primary surpluses (European Commission, European Economic Forecast Autumn 2023).
Romania
According to the European Commission (European Economic Forecast Autumn 2023), Romania’s real GDP is expected to increase
by 2.2% in 2023 from 4.6% in 2022, as a result of elevated inflation and its impact on real disposable income, as well as lower
external demand. Nevertheless, implementation of the national Resilience and Recovery Plan and other European programmes is
expected to support investment, mainly in public infrastructure, which alongside the anticipated improvement in terms of trade, will
provide a strong stimulus to economic activity in 2024 (3.1%). Gross fixed capital formation is projected to advance by more than
8% in 2023 and by 7% in 2024.
Annual harmonised inflation stood at 12% in 2022 and decelerated to 9.7% in 2023, with the surge in energy prices that was
recorded in the past year, having passed through to core inflation components, such as processed food and services. The
European Commission (Autumn 2023, Economic Forecast) predicts that HICP inflation will decelerate further in 2024 and 2025 to
5.9% and 3.4%, respectively.
Finally, the public debt-to-GDP ratio is forecasted to increase from 47.2% of GDP in 2022, to 47.9% in 2023 and to 48.9% in 2024
(European Commission, European Economic Forecast Autumn 2023) on the back of expected primary deficits (6.3% in 2023 and
5.3% in 2024) and decelerating nominal GDP growth.
United Kingdom
According to the International Monetary Fund (World Economic Outlook Update, January 2024), the UK’s real GDP is anticipated to
have demonstrated a modest uptick of 0.5% in 2023, followed by a marginally higher growth rate of 0.6% in 2024. Real GDP
growth is estimated to be primarily driven by private consumption, which in turn will be facilitated by alleviating price pressures. The
Bank of England raised its policy rate fourteen times in 2023, reaching 5.25% due to high inflation. Inflation based on the Consumer
Price Index (including owner occupiers’ housing costs-CPIH), averaged 6.8% in 2023, from 7.9% in 2022, whereas, according to
the European Commission (European Economic Forecast, Autumn 2023), it is expected to decelerate further to 3.6% in 2024.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
10 | ANNUAL FINANCIAL REPORT
STRATEGIC PLAN
The Group, during an Investors’ Day event held in June 7
th
2023, unveiled its 2023-2025 strategy, laying the foundations for
creating value and empowering growth, by leveraging on the identity of its franchise, its distinctive positioning in highly specialized
and profitable segments, its long-standing commitment to create shareholder value and its track record in delivering on its
promises.
The Strategic Plan is focused on priority areas of enhancing profits, maintaining balance sheet resilience and capital generation
and distribution, It builds upon successful implementation of transformation plan and plays to the unique strengths of the Group.
A resolute focus on improving profitability across all business units will elevate profits at the Group level, by growing earnings at an
average annualized pace above 20% for the period up to 2025. Favorable dynamics around net interest income, further supported
by macro tailwinds, will continue to drive revenues, while meticulous cost management will provide a buffer against inflationary
pressures.
Clearly defined strategic pillars will drive profitability across the Group’s business units:
a) Increase core revenues in retail banking, enhance productivity through automation and migrate core offering to digital
channels, reducing Cost to Income ratio
b) Adapt offering to attract a wider customer base across private banking and other selected clients while investing in technology
to modernize service model,
c) Reinforce position in wholesale lending and ensure adequate returns for capital while growing fees and continuing to refine
operating model.
d) Improve profitability in International by accelerating lending momentum through digital channels, capitalizing on strengths in
payments and wealth to grow fees, transform operations and increase productivity,
e) Continue to selectively grow lending book while maintaining strong levels of liquidity. The Group intends to further reduce its
Group NPE ratio while improving the coverage ratio (within a condensed Cost of Risk ratio) and to maintain a Loan-to-Deposit
ratio below 80% across the duration of the plan,
f) Scale-up sustainable finance strategy to meet full market potential and deliver on firm ESG commitments. Incorporate ESG
criteria in remuneration and risk-management framework and fully integrate sustainable finance strategy across business and
operating model.
During the period of it’s 2023-2025 Strategic Plan , the Group will focus on the following three financial priorities:
Profitability
o
Significant business profitability improvement across Business units, and re-allocation of capital from NPA unit
o
Revenues increase on the back of strong NII performance, largely attributed to NII growth driven by volume expansion and
favorable rates.
o
Cost management limiting inflation impact, and OpEx reduction through specific levers
Balance sheet
o
Liquid (<80% LDR), diversified and resilient balance sheet
o
Structural NPE reduction through organic and inorganic levers, lowering NPE ratio and improving coverage while further de-
escalating cost of risk
o
Diversified, granular and sticky deposit base (c.70% of insured deposits)
Capital generation and distribution
o
Healthy capital generation on the back of strong returns
o
Resulting fully loaded capital ratios significantly higher than management target of 13%
o
Restarting dividend distribution from 2023 profits, subject to regulatory approval
In late 2023, a landmark strategic partnership project Unicorn) with a global systemically important financial institution (UniCredit
S.p.A.) was announced, introducing a unique cooperation across geographies and products.
The agreement comprised 3 main pillars:
1. Strategic investment of UniCredit S.p.A in the Group
2. Merger of Alpha Bank and UniCredit Romanian subsisidiaries with Alpha Bank maintaining a 9.9% equity stake in the
combined entity
3. Commercial agreement in Bancassurance through the majority acquisition of Alpha Life by UniCredit S.p.A and in Asset
management through the distribution of UniCredit mutual funds through the the Group’s network
This development will allow the Group to deliver on its strategic priorities and accelerate business plan execution through:
o
Establishment of a strong partnership with reputable international player
o
Gain a stake in #3 largest bank in Romania
o
Potentially enhance domestic profitability on the back of the strategic partnership and know how sharing
o
Allow Alpha Bank to focus investors’ attention on profitable Greek and Cypriot businesses
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11 | ANNUAL FINANCIAL REPORT
ANALYSIS OF GROUP FINANCIAL INFORMATION
On 23.10.2023 the Group announced its strategic partnership with UniCredit S.p.A. which would result to the deconsolidation of the
subsidiaries Alpha Life, Alpha Bank Romania S.A, Alpha Leasing Romania INF S.A. and Alpha Insurance Brokers Srl. As a result of
the announcement, the assets and liabilities of these subsidiaries were classified as assets held for sale as at 31.12.2023, affecting
the line-by-line comparative analysis of the balance sheet.
As at 31.12.2023, the Group’s Total Assets decreased by Euro 4.3 billion or 5.6% compared to 31.12.2022, amounting to Euro 73.7
billion. The main driver of the decrease was the repayment of Euro 8 billion TLTRO funding in the first half of 2023, because of the
interest rate increases by the ECB since the third quarter of 2022, which resulted to changes in the funding mix strategy of the
Group. The Group has focused on the acquisition of higher yielding HQLA (High Quality Liquid Assets) securities to support its
profitability and liquidity metrics.
During the year, the Group managed to increase its deposit base following the increase in interest rates offered. In terms of debt
issued, the Group repaid Euro 500 million of Covered bonds and Euro 31.2 million of preferred Senior Notes, whilst it issued two
new preferred Senior Notes under the EMTN programme of nominal value Euro 620 million.
The Group’s Total Equity amounted to Euro 7.3 billion as at 31.12.2023, increased by Euro 1.1 billion compared to 31.12.2022,
mainly following the Additional Tier 1 Capital issuance of Euro 400 million nominal value (with callable maturity of 5.5 years and
yield of 11.875%) and Net profit for the year after tax of Euro 611 million.
The Total Capital Adequacy Ratio of the Group stands at 18.8% (31.12.2022: 16.1%), allowing the Bank to operate well above its
capital requirements by 31.12.2023. It is noted that Group’s capital ratios already include a provision of dividend according to its
policy.Excluding the provision for dividend at FY 2023, capital ratios further increase by c. 40bps and the Total Capital ratio would
stand at 19.2%
Regarding the results of the period to 31.12.2023, the Group’s net profits after income tax amounted to Euro 611 million
(31.12.2022: Euro 368 million as restated due to the first-year adoption of IFRS 17), mainly affected by the growth in net interest
income for Euro 480 million compared to last year. Below are the main drivers for the results of 2023:
•
Net interest income stood at Euro 1,653 million (31.12.2022: Euro 1,174 million), presenting an increase of 41% versus the
comparative period. The increase is mainly attributed to the increase in interest rates since the third quarter of 2022 that has
strengthened the net interest margin of the banking book.
•
Net fee and commission income for the year was Euro 372 million (31.12.2022: Euro 367 million) showing a slight increase of
1.4%, attributed mainly due to increased commission income on financial guarantees, mutual funds, foreign currency
exchange and transfers of capital less lost income following the sale of the merchant acquiring business on 30.6.2022.
•
Gains less losses on derecognition of financial assets measured at amortised cost for 2023 amounted to losses of Euro 17.2
million, mainly due to the exchange of government bonds measured at amortised cost at their fair value, with higher yield
government bonds of longer maturity. The corresponding losses for 2022 were Euro 4.3 million mainly due to the disposal of
loans following the conclusion of project Orbit.
•
Gains less losses on financial transactions amounted to a profit of Euro 71 million (31.12.2022: gains of Euro 181 million),
representing a decrease of 61%. Gains in the year are mainly due to foreign exchange differences and valuation of securities
at fair value through profit and loss. Last year, the relevant profit was affected mainly by gains of Euro 159 million from the
trading profit of derivatives.
•
Other income for the year ended 31.12.2023 was Euro 39 million (31.12.2022: Euro 31 million) driven mainly by higher rental
income.
•
Operating expenses for the year amounted to Euro 817 million (31.12.2022: Euro 856 million) and are analyzed as follows:
➢ staff costs of Euro 332 million (31.12.2022: Euro 327 million), increase mainly driven higher salaries and wages following
the implementation of the Bank’s Collective Labor Agreement from 1.12.2022 and the cost of the new stock awards.
➢ general and administrative expenses of Euro 326 million (31.12.2022: Euro 386 million), the decrease is mainly due the
disposal of the merchant acquiring business in the second quarter of 2022 and decrease in Contributions to the local
Resolution Scheme attributable to the cash received following the conclusion of the liquidation of a credit institution under
resolution in the year 2023 that covered the entire annual contribution of 2023.
➢ depreciation and amortization of Property, Plant and Equipment (PPE) and intangible assets of Euro 157million
(31.12.2022: Euro 142 million), the increase driven by higher capitalization of software at the beginning of the year and
new leases recognized as right of use assets.
•
Impairment losses and provisions to cover credit risk and related expenses amounted to Euro 467 million (31.12.2022: Euro
562 million), representing a 17% decrease compared to 2022, and includes impairment losses of Euro 162 million for the
NPEs transactions for Projects Gaia, Solar, Leasing, and Sky, as well as credit related expenses for credit protection and
servicing fees of Euro 86 million (31.12.2022: Euro 84 million) which are presented as a separate financial line item. The
underlying cost of risk stood at Euro 218 million. By contrast, the impairment losses and provisions to cover credit risk for
2022 stood at Euro 562 million due to the initiation of the NPEs de-leveraging plan for Projects Hermes, Solar and Leasing,
Light, Sky and Shipping, the impact of which amounted to Euro 272 million for 2022.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
12 | ANNUAL FINANCIAL REPORT
•
Impairment losses on fixed assets and equity instruments for 2023 amounted to Euro 19 million and include mainly Euro 8
million impairments relating to real estate assets that were included in the transactions of projects Sky and Skyline and Euro7
million impairment of other real estate assets of the Group that are not part of a transaction process. The respective figures for
2022 amounted to Euro 68 million of which Euro 66 million related to the initiation of the same transactions (Sky, Skyline and
Startek).
•
Gains/ (Losses) on disposal of fixed assets and equity instruments for 2023 amounted to Euro 3 million mainly due to the
conclusion of the Startrek and Sky transactions, against gains of Euro 317 million for 2022, which included a gain of Euro 297
million due to the disposal of the merchant acquiring business on 30.06.2022.
•
Provisions and transformation costs amounted to Euro 49 million in 2023 (31.12.2022: Euro 41 million) and include expenses
of Euro 39 million in relation to a new Voluntary Separation Scheme (VSS) and a Targeted Separation Scheme, as well as
Euro 12.5 million contribution for financial support of areas affected by the flooding in Thessaly in 2023.
•
Income tax for year 2023 amounted to Euro 233 million against an amount of Euro 238 million in year 2022.
•
Net profit/(loss) after income tax from discontinued operations for the years 2023 and 2022 include the subsidiaries' operations
that are part of the transcaction with UniCredit S.p.A .Additionally, in the year 2022, the discontinued operations also include
the subsidiary of the Alpha Bank Albania.
Since the Group has committed to specific targets through the announcements of the updated Strategic Plan, the Bank’s
management monitors the normalized gains/losses of the Group against the targets it has set, in order to monitor the
implementation of the business plan. Following a revised methodology as of 1
st
January, 2022, the Group monitors the Normalized
Results.
The Normalized Results do not include results that are not related to the normal course of business activities or that are not
repetitive in nature and therefore affect the results of the Group. Indicatively, the main income and expense items that are excluded
for purposes of the normalized profit calculation are listed below:
• NPE /NPA transactions costs and transformation costs;
• Results due to divestment of non-core assets and results of transactions of Non-Performing Exposures;
• Results with a short-term impact or arising from unexpected or exceptional events with a significant economic impact;
• Initial (one-off) impact from the adoption of new or amended International Financial Reporting Standards (IFRS);
• Tax-related one-off expenses and gains/losses.
The normalized profits of 2023 reached Euro 780 million against Euro 399 million in the comparative period of 2022. An analysis of
the normalized profits is presented in the Appendix of the Βoard οf Directors’ Management Report.
SIGNIFICANT EVENTS
•
On 06.02.2023, Alpha Services and Holdings S.A. announced the definitive agreement with the consortium comprised of Dimand
S.A. and Premia Properties REIC for the formation of an equity partnership in real estate investment through the sale of a Euro
438 million real estate portfolio (Project Skyline). The transaction, which is the largest real estate portfolio transaction in Greece
in recent years, comprises of more than 550" assets of multiple types, including offices, commercial real estate, residential and
industrial/logistics assets, with a gross area of approximately 500,000 sq.m. and is estimated to be completed in the first half of
2024. Alpha Astika Akinita S.A., the listed real estate company of the Group, through an exclusive agreement, will provide
property and facility management of the Skyline portfolio and the Alpha Bank Group will remain as a tenant for certain assets,
while the rest of the portfolio will either be redeveloped and repositioned for rental use or sold directly to the market. Through the
Skyline transaction, the Group will accomplish the liquidation of circa 475 repossessed assets. The size of the transaction and
the quality of its participants confirm the positive prospects of the Greek real estate market and the quality of the Group’s real
estate portfolio.
•
Οn 20.03.2023 the establishment of Alpha Services and Holdings Group Employees Institution for Occupational Retirement
Provision (Alpha Services and Holdings IORP) was approved by Ministerial Decree 1760. The purpose was to unify all existing
plans by creating one scheme and adopt a common approach at Group level in Greece. The previous savings schemes have
been terminated in May 2023. The scheme provides an employer contribution of 2%, regardless of the employee participation
and in case the employee participation is equal to or exceeds 3% and up to max 25%, there is an increased employer
contribution depending on salary thresholds and the employee contribution.
•
On 25.05.2023, the Bank completed the disposal of a mixed pool of secured Non-Performing Loans to Greek Large Corporate
Entities and Small-Medium Sized Enterprises with a total gross book value as at the cut off dates of approximately Euro 0.65
billion (Project Hermes).
•
On 16.06.2023, the sale of a Cypriot NPEs portfolio of a total Gross Book Value and Real Estate properties of Euro 2.3 billion
to an affiliate of Cerberus Capital was completed, through the sale of Sky CAC Ltd, a subsidiary of Alpha International Holdings
S.A. (Project Sky). Apart from the loan perimeter, the transaction comprises c. 1,300 real estate assets with a value of Euro
110 million. The REs were mainly residential assets located in the districts of Paphos, Limassol and Larnaca with a covered
area of approximately 93,000 sq.m.
•
On 28.07.2023 Alpha Services and Holding S.A. successfully conluded the EU – wide 2023 Stress Test. The Stress Test is
conducted on static balance sheet approach under a baseline and an adverse macro scenario with a 3-year forecasting
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
13 | ANNUAL FINANCIAL REPORT
horizon (2023-2025). No hurdle rate or capital thesholds are applied for this exercise, but it is designed to be due as an
important input in the Supervisory Evaluation Process (SREP).
•
On 20.10.2023 the disposal of a Portfolio of Retail Unsecured Non-Performing Loans, of a total outstanding balance of Euro
1.5 billion as of 30.9.2022, to Hoist Finance AB was completed (the "Cell Transaction").
• On 23.10.2023 the Group and Unicredit S.p.A announced their agreement on a strategic partnership through the completion of
the following individual transactions:
o The merger of their subsidiary banks in Romania. Upon completion of the above transaction, which is expected within
2024 and is subject to the prior completion of the due diligence process, the receipt of the relevant corporate approvals
and the required regulatory approvals and consents, the Group will retain a 9.9% stake in the new entity.
o The acquisition by Unicredit S.p.A of 51% of the subsidiary Alpha Life and the distribution of Unicredit S.p.A onemarkets
mutual funds through the Bank's network. The completion of the transaction, which is expected within 2024, is subject to
the prior completion of the due diligence process, the receipt of the relevant corporate approvals and the required
regulatory approvals and consents.
The completion of the above transactions is expected to strengthen the Group's capital reserves by more than 100 basis
points, while the exact impact on the results and capital adequacy ratios will be determined upon completion of the due
diligence process and the finalization of the contractual texts.
On 13.11.2023 Unicredit S.p.A. acquired all shares held by the Hellenic Financial Stability Fund in Alpha Services and
Holdings.Following a notification received by UniCredit S.p.A on 14.11.2023, the latter, as of 13.11.2023, directly holds
9.6159% of the total voting rights of Alpha Services and Holdings, a percentage that includes the stake previously owned by
the Hellenic Financial Stability Fund and an additional on-market shares’ acquisition.
• On 19.12.2023, the Bank completed the disposal of all outstanding shares of Startrek Real Estate Single Member S.A., which
held a real estate portfolio of value of Euro 5.9 mln, to the investor “Zelos Raif V.C.L.C. Plc
• Following the successful implementation of the new Career Development Framework in July 2023, a new organizational
structure was approved in December with effect as of 1
st
January,2024. Some of the key components of this new structure
allow for:
o A more sector based segmentation of our Wholesale customers ensuring provision of targeted, specialized and high
quality services according to our customer’s needs
o Optimizing the use of multiple channels over and above the traditional physical network including remote branch, call
centre and digital for servicing our retail customers both in terms of mass offerings as well as high-value segments
o Strengthening of the operating model of risk management, focusing on operational and strategic risk management and
maintaining a robust second line of defence
o Further integration of sustainability principles into our operating model, with emphasis on corporate governance
o Leveraging the new design principles of the new career development framework to achieve a leaner structure with clearer
lines of responsibility while providing the opportunity for employee development through multiple career advancement
paths
RISK MANAGEMENT
The Group has established a framework of thorough management of risks, based on best practices and regulatory requirements.
This framework, based on the common European legislation and the current system of common banking rules, principles and
standards, is improving continuously over time and is applied in the daily conduct of the Group’s activities within and across
borders, making the corporate governance of the Group effective.
Since November 2014, the Group falls under the responsibility of the Single Supervisory Mechanism (SSM) – the financial
supervision system which involves the European Central Bank (ECB) and the Bank of Greece – and as a significant banking
institution is directly supervised by the ECB. The SSM operates jointly with the European Banking Authority (EBA), the European
Parliament, the Eurogroup, the European Commission and the European Systemic Risk Board (ESRB), within the scope of their
respective competences.
The applicable banking regulatory framework in the European Union (EU), i.e., the Basel III capital framework, is effective as of 1
st
January, 2014. The said framework entered into force through Regulation (EU) No 575/2013 on “prudential requirements for credit
institutions and investment firms” (the “Capital Requirements Regulation” or the “CRR”) published on 27 June, 2013, in conjunction
with Directive 2013/36/EU on “access to the activity of credit institutions and the prudential supervision of credit institutions and
investment firms” (the “Capital Requirements Directive IV” or the “CRD IV”) published on 27 June, 2013 that has been transposed
into the Greek legislative framework by Law 4261/2014. The framework was amended by Regulation (EU) No 2019/876 (CRR II) of
20 May, 2019 and Directive (EU) 2019/878 (CRD V) of 20 May, 2019. The latter has been transposed into the Greek legislative
framework by Law 4799/2021.
The Group’s approach constitutes a solid foundation for the continuous redefinition of the Risk Management Strategy through (a)
the determination of the extent to which the Bank is willing to undertake risks (risk appetite), (b) the assessment of potential impacts
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14 | ANNUAL FINANCIAL REPORT
of the development strategy activities on the definition of the risk appetite limits, so that the relevant decisions combine the
anticipated profitability with the potential losses and (c) the development of appropriate procedures for the implementation of this
strategy through a mechanism which allocates risk appetite responsibilities among the Group Units.
Specifically, the Group, taking into account the nature, the scale and the complexity of its activities, as well as the risk profile,
develops a risk management strategy based on the following three lines of defense, which are the key factors for its efficient
operation:
• 1
st
line of defense Units (process owners) have the primary responsibility to own and manage risks associated with day-to-day
operational activities.
• 2
nd
line of defense Units, comprising the areas of Chief Risk Control Officer, the Chief Compliance Officer, the Chief Credit
Officer, as well as the Risk Models & Data Validation functional area. These are independent from each other and from the other
lines of defense. These areas report to the Chief Risk Officer, which reports to the Risk Management Committee of the Group.
Their function is complementary to conducting banking business of the first line of defense in order to ensure the objectivity in
the decision-making process, to measure the effectiveness of these decisions in terms of risk undertaking,to design and execute
on the risk control strategy and to comply with the applicable legislative and institutional framework, by monitoring the internal
regulations and ethical standards as well as to display and evaluate the total exposure of the Bank and the Group to risk, based
on the established guidelines.
• The Internal Audit constitutes the third line of defense. The Internal Audit is an independent function, reporting to the Audit
Committee of the Board of Directors, and audits the activities of the Bank and the Group, including the activities of the Risk
Management Unit.
CREDIT RISK
Credit Risk arises from the potential failure of debtors’ or counterparties to meet all or part of their payment obligations to the
Group.
The primary objective of the Group’s strategy for credit risk management, in order to maximize the risk-adjusted return, is the
continuous, timely and systematic monitoring of the loan portfolio and the maintenance of credit exposures within the framework of
acceptable overall risk undertaking limits. At the same time, the conduct of daily business within a clearly defined framework of
granting credit, supported by specific credit criteria, is ensured.
Τhe Group’s credit risk management framework is being developed based on a series of credit policy procedures as well as
systems and models for measuring, monitoring and controlling credit risk. These models are subject to an ongoing review process
in order to ensure full compliance with the current institutional and regulatory framework and their adaptation to the respective
economic conditions and to the nature and extent of the Group’s business.
Under this perspective and in order to further strengthen and improve the credit risk management framework during 2023, the
following actions were implemented:
• Incorporation of the Environmental, Social and Governance (ESG) risk assessment in the credit approval process, at obligor,
transaction and overall level.
• Incorporation of the controversial activities assessment in the credit approval process.
• Update of the Credit Policy Manuals for Wholesale Banking and Retail Banking, taking into account the regulatory guidelines on
credit risk management issues and the Group’s business strategy.
• Update of the Group Credit Control Framework in order to ensure compliance with Credit Risk Policies at Bank and Group level.
• Ongoing validation of the Risk Models in order to ensure their accuracy, reliability, stability and predictive power.
• Development of a framework to validate the criteria and thresholds of significant increase in credit risk (SICR) after initial
recognition.
• Initial Validation of the model that evaluates the client in terms of environmental, social and corporate governance. (ESG Obligor
assessment model).
• Initial Validation of the models used for the approval of new financings in the automatic decision-making mechanism for Retail
Banking (THALIS).
• Benchmarking analysis using external sources to confirm the reliability of the internal models.
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15 | ANNUAL FINANCIAL REPORT
• Update of the Retail Banking, Wholesale Banking and International Network Arrears and Forbearance Policies in order to
incorporate the current business practice.
• Update of the "Concentration Risk and Credit Threshold Policy" regarding the maximum acceptable credit limits for large
business groups.
• Update of the Group’s Loan Collateral Policy regarding the process of annual revaluations of collaterals covering loan exposures
and the identification and consideration of climate related information in the collateral valuation.
• Update of the Credit Risk Early Warning Policy regarding the procedure to be followed when specific early warning triggers are
activated as well as the enrichment of the early warning triggers for the Commercial Real Estate financing portfolio.
• Update of the Credit Risk Model Management Policy in order to incorporate the latest Regulatory Guidelines and to be aligned
with the amendments included in the Group’s Model Risk Management Framework.
• Periodic conduct of stress test exercises as a tool for assessing the impact of various macroeconomic scenarios on the business
strategy formulation, the business decision-taking and the Group’s capital position. The stress tests are conducted in
accordance with the requirements of the regulatory framework and constitute a key component of the Group’s credit risk
management strategy.
ENVIRONMENT, SOCIAL AND GOVERNANCE (ESG) RISKS
The Group adopts a proactive approach to the management of Environmental, Social and Governance (ESG) risks, with particular
emphasis on risks arising from climate and environmental change, which is a key component of its Risk Management Strategy. The
Non Financial Report included in the annual report provides full information including the Business model, the risks addressed, the
management and monitoring of those risks.
Following the recommendations of the Task Force on Climate-related Financial Disclosures (“TCFD”), the Bank assesses current
and upcoming environmental policies, legal requirements and regulatory guidelines relating to climate and the environment, in order
to record and efficiently manage any transitional and physical risks related to its activities. In this context, the Group has developed
a comprehensive action plan, submitted to the European Central Bank (ECB) in May 2021, in which it presented how the climate
risk assessment would be incorporated in its operations and in the risk management process. The implementation of the plan
began in June 2021, continued throughout 2022 and was enhanced, taking into consideration the feedback provided by the Single
Supervisory Mechanism (SSM) in the context of the Climate Stress Test, conducted in January 2022, and the Thematic Review of
Climate-related and Environmental Risk Strategies, Governance and Risk Management Frameworks, conducted in June 2022.
Leveraging on the work already performed in 2022 the Bank has proceeded with targeted implementations during 2023 in
accordance Group’s ESG plan commitments.
The Group, acknowledging the relevance and potential impact of the risks stemming from climate, environmental and social related
factors, and especially climate change, and as part of its plan and in alignment with the respective external guidelines, has
elaborated further on the ESG incorporation into the risk identification and materiality assessment processes and in the overall risk
management framework, and is committed to monitoring, assessing, and managing these risks going forward. More specifically, in
2023 the following activities have been performed:
•
The Group has enhanced its credit policy to incorporate the ESG obligor, transaction and overall per transaction (combination
of obligor and transaction) assessment, into its credit approval process.
•
The Group has developed a Reputational Risk Policy which defines the main principles, processes and governance structure
for effectively managing the reputational risk exposures. The Policy also addresses reputational risk stemming from ESG
factors.
•
The Grouphas updated its Risk Inventory in order to include the dimension of climate-related risks in its Risk Registry. The
main climate-risk transmission channels in the area of risk management include a) the transition risk b) the physical risk and c)
the environmental risk.
•
The Group conducted a materiality assessment analysis to identify the sectors that are most vulnerable to climate and
environmental related risks. In alignment with the guidance across different sources [e.g. ECB, European Banking Authority
(EBA), European Commission], the Bank considers Climate and Environmental risks as a theme, i.e. as a transversal risk,
incorporating such factors as drivers of existing financial and non-financial risk categories in its risk management framework.
The Bank is currently actively working towards enhancing this materiality assessment by incorporating additional dimensions.
More specifically, the outcome of the materiality assessment for each risk category is outlined as follows:
•
Credit risk: significantly impacted by transition risks, both in the Non-Financial Corporate (NFC) portfolio and the Retail
portfolio secured by Real Estate. It is, also, considered to be materially affected by some individual physical risk factors.
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16 | ANNUAL FINANCIAL REPORT
•
Operational risk: based on historical data, operational risk is immaterial to ESG-related events. The Bank will closely monitor
ESG-related risks (i.e new regulatory requirements regarding greenwashing, increased physical risk due to extreme climate
conditions), as there are potentially material ESG factors that can lead to operational risk in the future.
•
Market risk: currently assessed as immaterial to both transition and physical risks.
•
Liquidity risk: there is no material effect from climate related and other ESG factors.
•
Reputational risk: a separate evaluation is not required as it arises because of other risk types (i.e., a second-order impact).
The materiality assessment of these types is sufficient to cover one-off (acute) events with reputational repercussions and
longer-term brand value impacts in the context of Strategic risk. Therefore, reputational risk is considered to be materially
affected by ESG factors. Especially regarding legal risk, the Bank has introduced enhancements to better identify, manage,
mitigate and monitor legal risk driven by ESG-related factors.
•
Business & Strategic risk: currently assessed as materially affected by ESG factors, with manifestations through several
drivers (e.g., the Bank's inability to properly execute its strategy, changes in the customers' demand of various Bank's
products, etc.).
•
Other environmental factors: The residual risks associated with those environmental and social risk factors are considered
immaterial on a portfolio basis.
To address the aforementioned risks, the Bank has deployed a comprehensive strategic plan by carrying out the following key
actions:
a) Performed an impact analysis of its loan portfolio by utilizing the UNEP FI Principles for Responsible Banking (PRB) Tool and
by conducting a Global Reporting Initiative (GRI) materiality analysis, in order to understand the positive and the negative
socioeconomic, environmental and social impacts of its portfolio.
b) Implemented regular monitoring of ESG Key Performance Indicators (KPIs) (such as % of disbursements to RES over total
disbursements to the energy sector, the gross disbursements aligned with the Sustainable Finance Framework etc.), in order
to take corrective action, when needed. Furthermore, the Bank in 2023 has enhanced its Risk and Capital Strategy (RCS)
document by incorporating additional quantitative monitoring ESG indicators.
c) Is in the process of developing science-based, sector-specific targets around its financed emissions, in alignment with the
Paris Agreement on climate change and the net zero emissions target for 2050.
d) Is in the process of developing short-, medium- and long-term targets until 2050, to incorporate the short-term transition
pathway into its three-year Business Plan.
Moreover, the Group has already incorporated in its Risk Appetite Framework (RAF) a set of qualitative commitments regarding
ESG risks.
Specifically:
•
The Group is committed to integrating climate risks into its overall risk management framework. In this context, the Bank
regularly monitors its exposure concentration in climate-sensitive sectors in its loan portfolio, also introducing a credit
concentration risk indicator within the Risk Appetite Framework, which monitors the level of concentration of the Bank’s
exposures within the loan portfolio in sectors that are more sensitive to climate transition risks, with the exception of exposures
that are aimed at financing or enabling the transition of such obligors to more sustainable activities and business models.
Furthermore, the Bank in 2023 has enhanced its Risk and Capital Strategy (RCS) document by incorporating additional
quantitative monitoring ESG indicators covering business planning and green financing, collateral vulnerability to physical and
transition risk, financial activity vulnerability to physical risk, sustainable investing and social related risk (HR).
•
The Group has enhanced its due diligence process with respect to the assessment of its Customers’ ESG/climate risk profile,
through the collection of relevant information. For High-Risk Obligors according ESG Obligor assessment outcome, the Bank
collaborates with Obligors to develop an action plan, outlining a timeframe and appropriate mitigation measures. This
collaborative effort aims to ensure obligors' compliance with the Bank's Environmental and Social (E&S) requirements. The
Group aims to finance its counterparties’ green/sustainable transition both in the short-and in the long-term.
•
The Group already applies an exclusion list, in line with the Environmental and Social Exclusion List developed by the
European Bank for Reconstruction and Development (EBRD), for the avoidance of the financing , directly or indirectly, of
specific activities considered as harmful to the environment and society. As of 1 January, 2024, the Group has expanded its
Exclusion List to encompass additional activities with environmental and social impact, such as the conversion of natural
forests into plantation, the wholesale and retail trade of thermal coal, the construction of new nuclear power plants, the
financing of clients who are involved in violations of human rights, according to the United Nations “Universal Declaration of
Human Rights”.
•
The Group has integrated information on the Energy Performance Certificate (EPC) of relevant real estate properties within its
credit decision making process as well as each collateral valuation subject to EPC eligibility.
•
To mitigate reputational risk, the Group has designed a robust process that involves identifying and assessing the potential
participation of its Obligors in controversial activities.
In order to assess the impact of climate risk on the calculation of Expected Credit Loss (ECL), detailed information on the location
of collateral as well as information on EPCs is being collected. The information will be incorporated into the respective data systems
and methodological approaches will be developed in order to adapt the models for calculating the ECL. More specifically, the
following are in progress:
• Development of a validation methodology for the new models that assess environmental, governance and social risks and
integration of the former into the Credit Risk Models Validation Framework.
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17 | ANNUAL FINANCIAL REPORT
• Performing enhancements or additions to the current set of models used for risk parameter estimation and prediction, in order to
integrate ESG risks.
• Identifying ESG-related data needs, leveraging the data that will be collected for the borrower’s assessment and supplementing
it with additional information, where needed.
• Examining alternative methodological approaches for the quantification and the integration of ESG risks into the credit risk
parameters.
Additionally, the Bank has developed innovative scorecards, simplified and advanced (cross sector and sectorial), for
environmental risks, providing differentiation by industry and depending on the size of the company (e.g. turnover) as well as
scorecards for governance and social risks. These scorecards have been developed and calibrated during 2023.
The Group continues to develop and implement its ambitious ESG Workplan, aiming to enhance the sustainability of its business
model and to ensure long-term value creation for its Shareholders.
LIQUIDITY RISK
Liquidity risk derives from the possibility of cash outflows not being fully covered by cash inflows (funding liquidity risk) as well as
from the possibility of failure to timely address changes in market conditions that affect the ability to liquidate assets quickly and
with minimal loss in value (market liquidity risk).
During 2023, customer deposits, including balances of Alpha Bank Romania and Alpha Life classified as Held for Sale as at
31.12.2023, increased by Euro 1.7 billion, representing an increase of 3% compared to 31.12.2022.
During 2023, the subsidiaries continued to have increased liquidity. Their liquidity buffer, comprising Cash and Deposits on Central
Banks, government bonds both eligible and non-eligible as collateral by the Central Bank, bonds issued by financial institutions,
subordinated notes both eligible and non-eligible as collateral by the Central Bank etc., on 31.12.2023 stood at the level of Euro 2.2
billion for Cyprus and of Euro 0.8 billion for Romania.
The Bank’s financing from the Euro system stood at Euro 5 billion on 31.12.2023.
Alpha Bank successfully placed at 01.02.2023 a Euro 0.4 bn, Additional Tier 1 bond with a coupon of 11.875%. The Additional Tier
1 bond has a perpetual maturity and is callable at 5.5 years. In February 2023, an additional Εuro Medium Term Note of 70millions
was issued. Additionally, on 21.06.2023 Alpha Bank has concluded a Euro 500 million Senior Preferred Bond issuance. The Senior
Preferred Bond has a 6-year maturity and is callable in year 5, with a coupon of 6.875% and a yield of 7%. In November 2023, an
issuance of Εuro 50 million was concluded. Additionally,on 5.2.2024, the Bank completed the issuance of a senior preferred bond
with a nominal value of €400m., maturity of 6.5 years, with the option to call at 5.25 years, with a nominal interest rate of 5% and a
yield of 5.125%.
In 2023 S&P, Fitch, and DBRS rating agencies upgraded Greece's credit rating to investment grade, citing the country's steady
progress on reforms and improvement in its fiscal position. Taking into consideration the Greek economy and the new economic
environment, liquidity stress tests are conducted on a regular basis in order to assess potential outflows (contractual or contingent).
The purpose of this process is to confirm whether the existing liquidity buffer is adequate to cover the Bank’s needs. These stress
tests are carried out in accordance with the approved Liquidity Risk Policy of the Group. It is noted that according to these stress
tests the Group remains solvent across all scenarios.
In 2023, the Contingency Funding Plan was updated to incorporate an increased liquidity buffer. The Contingency Funding Plan is
complementary to the Recovery Plan. Its purpose is to facilitate efficient management in the beginning of a possible liquidity crisis
in order to take remedial actions, in a timely manner, to mitigate a reduction in the liquidity buffer.
Finally, in the context of the review of the Internal Liquidity Adequacy Assessment Process, the Bank updated the liquidity stress
test scenarios.
INTEREST RATE RISK IN THE BANKING BOOK
Interest Rate Risk in the Banking Book (IRRBB) is the risk that relates to how a change in base interest rates, such as the Euro
swap curve, will affect the Net Interest Income of the Bank and the Fair Value of Assets and Liabilities (Economic Value of Equity).
The change in the Net Interest Income and the change in the Economic Value of Equity, which results from a change in base
interest rates, are calculated for internal and prudential stress scenarios on a regular basis. The relevant IRRBB stress tests
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
18 | ANNUAL FINANCIAL REPORT
scenarios results are presented to the Assets-Liabilities Management Committee and to the Risk Management Committee of the
Board of Directors.
The Group closely monitors the interest rate risk of the banking book and has adopted a strategic and holistic approach to manage
the overall IR gap risk. The Bank is well within the ΔEVE (Economic Value of Equity) to Tier 1 limits across all different interest rate
stress scenarios. With a floating rate performing loan portfolio (c. 90%) and a low concentration and well diversified deposit base,
interest rate increases have significantly benefited the balance sheet’s profitability.
During 2023, uncertainty and adverse geopolitical developments in the international environment, including the persistence of the
war in Ukraine and the geopolitical turbulence in the Middle East, weighed on economic growth. Interest rate hikes by central banks
have continued throughout the year.The European Central Bank raised its key interest rates by 200 basis points, bringing the
deposit rate facility to 4% and the main refinancing rate to 4.5%, while the Fed raised its key interest rate to 5.50%.
The higher interest rates led to an increase in interest income resulting in an improvement in the Net Interest Margin considering
the degree of repricing of the cost of customer deposits.
The existing IRRBB Key Risk Indicators were reviewed and a new regulatory ΔNII limit as a percentage of Tier I equity replaced the
existing one, aligning with the new supervisory guidelines that were issued in the end of 2022. Additionally, Credit Spread Risk of
the Banking Book (CSRBB), which captures the risk of an instrument’s changing spread while assuming the same level of
creditworthiness, was introduced as of 31.12.2023.
MARKET, FOREIGN CURRENCY AND COUNTERPARTY RISK
The Group has developed a control environment, applying policies and procedures, in accordance with the regulatory framework
and international best practices,
Market risk is the risk of losses arising from unfavorable changes in the price or volatility of products with underlying interest rates,
foreign exchange rates, stock exchange indices, equity prices and commodities. The valuations of bond and derivative positions
are monitored on an ongoing basis. Stress tests are conducted on a regular basis in order to assess the impact for each scenario
on profit and loss and capital adequacy, in the markets where the Group operates.
A detailed policy for trading limits, investment limits and counterparty limits has been designed and implemented. This policy
involves regularly monitoring trigger events that could signal increased volatility in certain markets.
For the mitigation of the interest rate and foreign currency risk of the banking portfolio, hedging strategies are applied using
derivatives.
During the year, the trading book market risk, as measured by Value at Risk, fluctuated between Euro 0.5 million and Euro 1.2
million. Value at Risk is the maximum loss that could take place in one day with 99% Confidence level. Value at Risk captures
foreign currency risk, interest rate risk, price risk and commodity risk in the trading book.
The Sovereign yields decreased: the 10-year German Government Bond yield by 42 basis points (bps), the 10-year Greek
Government Bond yield by 155 bps, and the 10-year Italian Government Bond yield by 85 bps.
During the year there was an increase in Investment securities measured at amortized cost (notional value) of approximately Euro
3.5 billion. The key driver was the increase in sovereign bonds by Euro 2.5 billion, out of which Greek Government Bonds
increased by approximately Euro 1.5 billion.
OPERATIONAL RISK
Operational Risk is defined as the risk of financial or qualitative negative effects resulting from inadequate or failed internal
processes, IT systems, people (intentionally or unintentionally) and external events. Operational Risk includes legal risk.
The Group has developed the Operational Risk Management Framework which is compliant with the qualitative and quantitative
regulatory requirements of the Standardized Approach as defined by the Capital Requirement Directive (CRD).The effective
implementation of the Operational Risk Management Framework is monitored by the Group’s competent Operational Risk and
Internal Control Committees.
The Group Operational Risk Management Framework’s main components aim to manage the operational risk exposures effectively
and proactively. In particular:
•
Operational Risk Events: management of operational risk events occurring across the Group
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
19 | ANNUAL FINANCIAL REPORT
•
Risk Assessments and Scenario Analysis: various operational risk assessments are performed (e.g. Risk & Control Self-
Assessment, Outsourcing Risk Assessment) and Scenarios are developed to proactively identify and mitigate potential
operational risk exposures.
•
Indicators: Key Risk Indicators have been developed to Group Entities (both at Risk Appetite Framework and operational level)
to monitor the operational risk exposures
•
Mitigating Actions: Corrective actions are developed and monitored to mitigate the operational risk exposures
•
Reporting: Internal and regulatory reports are generated and disseminated to various stakeholders across the Group
In the last quarter of 2023, the following developments occurred:
•
Reputational Risk: The Reputational Risk Policy was developed and issued. The Policy defines the governance structure and
the risk management practices adopted by the Group for effectively managing its Reputational Risk exposure.
•
Operational Risk Management - New Target Operating Model: The Group is in the process of introducing a new Operating
Model regarding operational risk management. The new Operating Model aims to further strengthen the existing governance
structure, to promote further risk control culture and awareness as well as to increase the effectiveness of the operational risk
management procedures. The new Operating Model introduces the role of Operational Risk Partner across the first Line of
Defense Units, who will have an enhanced role in managing the Operational Risk within his/ her Unit. The expected benefits of
the new model are the following: minimize of operational risk losses, proactive risk management, effective control performance,
enhanced risk culture, facilitation of decision making.
•
2024 ECB Cyber Resilience Stress Test: The Bank participates in the ECB’s annual supervisory stress test, which consists of
a thematic exercise assessing the digital operational resilience of Supervised Institutions to withstand a severe but plausible
cybersecurity event. The 2024 SSM cyber resilience stress test is not intended to be a financial stress test of the capital and
liquidity buffers of institutions in the event of an adverse economic scenario. Instead, it is intended as an additional tool in the
supervisory toolkit to assess the ability of institutions to withstand a severe but plausible operational disruption caused by a
cybersecurity event.
LIBOR REFORM
The London Interbank Offered Rate (LIBOR), one of the main and most important interest rate benchmarks used in global financial
markets ceased to exist or lost its representativeness since 1
st
January, 2022. In line with the announcements of the Financial Conduct
Authority (FCA), the end of 2021 brought to a close the first major phase of LIBOR cessation with 24 of the 35 LIBOR settings ceasing.
The continuation of some USD LIBOR settings through 30
th
June, 2023, intended only to support the transition of legacy products.
The Group took all the necessary steps in order to comply with the above regulations. A detailed action plan was drafted and the
internal Working Group, representing several workstreams, identified dependencies on LIBORs and implemented the necessary
amendments.
The Group informed its Customers of the LIBOR transition well in advance by uploading on its website all the relevant information.
Furthermore, dedicated correspondence was sent to Customers with direct exposure to the new alternative interest rates.
Furthermore, the Group concluded the transition of the remaining USD LIBOR settings which continued to exist up to 30
th
June, 2023.
Regarding new industry developments, on 3 April, 2023, the FCA announced its decision to require LIBOR’s administrator, IBA, to
continue to publish the 1-, 3- and 6-month US dollar LIBOR settings under a ‘synthetic’ methodology until end-September 2024 for
use in legacy contracts only. For sterling LIBOR, FCA intends to continue to require IBA to publish the 3-month synthetic sterling
LIBOR setting until end-March 2024, after which it will cease permanently.
Furthermore, the Euro Risk Free Rates Working Group in order to facilitate the establishment of a fallback rate in an event that a
benchmark materially changes or ceases to exist, has recommended as a fallback rate for EURIBOR a forward-looking term rate for
a variety of asset classes. In particular, on November 2022 EMMI launched EFTERM, a forward looking EuroSTR-based term
benchmark calculated for five settings, known as “tenors”: one week, and one, three, six and twelve months.
The Group continues to monitor all relevant market developments, taking all necessary actions to ensure compliance where required
and to support its Customers.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
20 | ANNUAL FINANCIAL REPORT
MANAGEMENT OF NON-PERFORMING EXPOSURES (NPEs) AND REAL ESTATE
OWNED ASSETS (REOs)
NPES MANAGEMENT
The Group has set as a key priority the effective management of NPEs, as this will lead not only to the improvement of the Group’s
financial strength but also to the restoration of liquidity in the real economy, households and productive business sectors,
contributing to the development of the Greek economy in general.
oring unit (the "NSRM") is responsible for the remedial managementPerforming Exposures Strategy, REcovery and Monit-The Non
ion planof the NPE portfolio of the Group, setting the strategic principles and actively monitoring the performance of the NPE reduct
The NSRM unit acts as a single point of reference between the Bank and cooperating Servicers, and, among other, is responsible
for:
- Formulating the NPE recovery strategies
- Monitoring the execution of NPE remedial strategies in accordance with the Bank’s policies
- Managing the relationship with external Servicers and monitors their performance
- Developing business analytics tools and overseeing the NPE performance evolution
- Ensuring compliance with regulatory requirements and relevant Service Level Agreements (SLAs)
As a result of the dedicated effort towards achieving the NPE target, total NPEs in 2023 decreased by 0.9 billion compared to prior
year and therefore NPE ratio reduced to 6% as at 31.12.2023
The organic reduction effort focused on long-term restructuring solutions, while the devise and use of business analytics tools has
contributed to a decelerating trend in loan defaults throughout the year, thus reaching the 2023 target. Targeted campaigns and
new product offerings also contributed to the positive results of the organic deleveraging in 2023, an effort that will continue in
2024. Furthermore, portfolio sales remain pivotal in accelerating the implementation of the submitted plan. In the first half of 2023
the Bank completed the disposal of a mixed pool of secured Non-Performing Loans to Greek Large Corporate Entities and Small-
Medium Sized Enterprises with a total Gross Book Value of approximately Euro0.65 billion (Project Hermes) as also the sale of a
Cypriot NPEs portfolio of a total Gross Book Value and Real Estate properties of Euro 2.3 billion (Project Sky) and finally, during
the last quarter of 2023, the sale of a Retail NPEs portfolio of a total Gross Book Value of approximately Euro0.09 billion (Project
Cell). Also, the Bank will finalize, by the end of the year 2024, the sale of a Retail NPEs portfolio of a total Gross Book Value of
approximately Euro0.37 billion (Project GAIA).
In 2023, the macro headwinds – mainly reflected through energy inflation and ascending interest rates – reduced the real income
and increased loan installments, both developments putting significant stress on the financially-vulnerable segments of the
population. The Group, managed to address these challenges successfully through:
•
the launch of new targeted campaigns;
•
the rollout of the interest rate cap on performing retail debtors
•
the introduction of new long-term restructuring solutions.
These actions led to:
•
a significant number of Retail (RTL) viable NPEs modifications during 2023;
•
the reduction of RTL NPE inflows, across the year improving both default and cure rates, maintaining a robust performance on
its entire loan book.
In 2024, the macro challenges are expected to continue – albeit less intense – so the Bank intends to capitalize on the
management proactive actions framework, leveraging our knowledge and experience, upon the most sensitive parts of our loan
portfolio. This, along with the improved internal data analysis and the enhanced servicing practices (through CEPAL), will allow us:
• to successfully defend the strong credit standing of our loan book;
• to achieve our ambitious NPEs deleveraging targets
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
21 | ANNUAL FINANCIAL REPORT
REOS MANAGEMENT
In addition to the efficient and effective management of its NPEs, during the last few years the Group has captured within its strategic
priorities the successful management of REOs as well. In this context, the Group during 2023 continued its strategy as follows:
Ongoing implementation of a management strategy for REOs through the Subsidiary Αlpha Astika Akinita S.A. (renamed to Alpha
Real Estate Services S.A. on 19.01.2024) with the aim to:
• Monitor the repossession procedure (asset onboarding).
• Coordinate the asset management operations through the Group’s Special Purpose Vehicles (SPVs).
• Supervise and coordinate asset management and development.
• Supervise and coordinate repossessed asset commercialization, in accordance with the applicable Group policy.
• Set and monitor the Key Performance Indicators (KPIs) for the collaborating asset management agencies (internal units and
external collaborators).
In early 2024, an update of the existing Bank's and Group's Asset Management and Valuation Accounting Policy was carried out,
aiming to outline guidelines and procedures for a more effective administration, operation and maintenance of real estate assets.
Real Estate Management and Appraisal Policy addresses acquisition, leasing, valuation and overall strategies and assigns
responsibilities to the related units.
Additionally, a website has been created to facilitate the more effective promotion of non own-used and recovered properties. Through
the website as a main point of first contact with interested parties, Alpha Astika Akinita S.A. has managed to dispose assets
representing a book value of approximately Euro 36 million in Greece and Euro 15 million in Cyprus (excluding Projects Sky and
Skyline), achieving the targeted sale prices. This demand has been driven mainly by inflation which traditionally favor less liquid
assets. As at 31.12.2023 the Group’s balance of repossessed assets (exc. Own used) amounted to ca. Euro 639 million (4,633
properties). Our forecasts indicate that the strong interest in real estate market will continue in 2024.
During the year significant transactions have been either initiated or completed such as Projects Skyline, Sky and Startreck. Analysis
of the above transcactions is presented in the section “Significant Events”.
CAPITAL ADEQUACY
The scope of the Group’s Capital Strategy pertains to maintaining a strong capital adequacy both from an economic and from a
regulatory perspective. It aims at monitoring and adjusting the Group’s capital levels, taking into consideration the capital markets’
demand and supply, in an effort to achieve the optimal balance between economic and regulatory considerations.
The Group’s Risk and Capital Strategy sets specific risk limits, based on the risk appetite, and monitors deviations therefrom.
The objectives of the Group’s capital management policy are to ensure that the Group has sufficient capital to cover the risks of its
business, to support its strategy and to comply with the regulatory framework at all times.
1. SUPERVISORY REVIEW AND EVALUATION PROCESS (SREP)
According to the Supervisory Review and Evaluation Process (SREP) 2022 decision, communicated by the European Central Bank
(ECB), for 2023 Alpha Services and Holdings S.A. is required to meet on a consolidated basis an Overall Capital Requirement
(OCR) on the Total Capital ratio of at least 14.69% [the OCR includes the Capital Conservation Buffer (CCB) of 2.50%, the Other
Systemically Important Institutions (O-SII) buffer of 1% and the applicable Countercyclical Capital Buffer (CCyB) of 0.19%, mainly
stemming from the contribution of the subsidiaries,for which further information can be found in Note 48 for Capital Adequacy].
The OCR consists of the minimum threshold of the Total Equity Ratio (8%), in accordance with Article 92 (1) of the CRR, and the
additional supervisory requirements for Pillar II (P2R), in accordance with Article 16 (2) (a) of Regulation 1024/2013/EU, which
amount to 3.0%, as well as the combined security requirements (i.e., CCB, O-SII, CCyB), in accordance with Article 128 (6) of
Directive 2013/36/EU. The minimum ratio should be kept on an ongoing basis, considering the CRR/CRD IV Transitional
Provisions.
The Bank of Greece has set the O-SII buffer at 1 % for 2023, increased by 0.25% compared to 2022 and the Countercyclical
Capital Buffer at 0% for Greece, for the year 2023.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
22 | ANNUAL FINANCIAL REPORT
The capital adequacy requirements set by the SSM/ECB are used by the Group as the basis for its capital management. The
Group seeks to maintain sufficient capital to ensure that these requirements are met.
In response to COVID-19 pandemic and to encourage banks to grant new loans, the European Commission decided to revise the
existing regulatory framework by bringing forward regulations that would normally come into effect with the CRR 2/CRD V
framework.
As a result, on 22
nd
June, 2020 the EU published Regulation (EU) No 2020/873 in its Official Journal, which included amendments
in relation to the capital requirements set by Regulations (EU) No 575/2013 and 876/2019. The revised Regulation includes,
inter
alia
, article 473a which introduces provisions aiming to mitigate the negative impact on the regulatory capital of the banks from the
increase in the expected credit loss resulting from the Covid-19 pandemic. This article extends to another two years the ability to
add back to the regulatory capital the expected credit losses recognized in 2020 and afterwards relating to performing financial
instruments. This transition period is effective until the end of 2024.
2. IFRS 9 CAPITAL IMPACT
Regarding the International Financial Reporting Standard (IFRS) 9, the Group makes use of Article 473a of Regulation (EU) No
2395/2017 of the European Parliament and of the Council, amended by Regulation (EU) No 873/2020, and applies the transitional
provisions for the calculation of Capital Adequacy on both solo and consolidated basis. The Group is adequately capitalized to
meet the needs arising from the application of the Standard, and the impact from the initial implementation of the Standard has
been fully incorporated in the ratios since January 2023.
3. CAPITAL ADEQUACY RATIOS
On 31.12.2023, the consolidated Common Equity Tier (CET) 1 capital stood at Euro 4.6 billion, while the Risk Weighted Assets
(RWAs) amounted to Euro 32.2 billion, resulting in a CET 1 ratio of 14.4%, up by 1.18% versus 31.12.2022.
During 2023, in line with the Strategic Plan, Alpha Services and Holdings proceed to the following actions:
o
On 08.02.2023, the completion of the issuance of its Euro 400 million Perpetual Fixed Rate Reset Additional Tier 1 Notes
(the “AT1 Notes”). The AT1 Notes, which are non-call 5.5 years’ notes, are issued with a yield of 11.875%. Dividend
payment is on a semi-annual basis and is subject to the approval of The Board of Directors (BoD).
o
The completion of the Hermes and Sky transactions and the reclassification of NPE portfolio for the perimeter of Gaia to
Held for Sale.
o
The Shipping Synthetic Securitization (Project “Compass”) and the Synthetic Securitization (Project “Blue”/Wholesale
Portfolio) were successfully completed.
o
On 23.10.2023, the announcement of an agreement with Unicredit S.p.A as described in the section of “Strategic Plan”
and of the “Significant Events".
Following the above, the capital adequacy ratios are well and above all the regulatory capital requirements and are expected to be
further enhanced due to the completion of the rest scheduled transactions (e.g., Skyline) as well as the completion of a new
synthetic Securitization (Project “Mortgage”/Housing Portfolio”) scheduled at H2 2024.
4. DIVIDEND POLICY
Alpha Services and Holdings has updated its dividend distribution policy following the restoration of profitability and in view of the
capital accretive Business Plan that may allow to proceed with distribution. Alpha Services and Holdings envisages to proceed to a
dividend distribution in 2024 based on 2023 profitability subject to regulatory approvals.
The policy document has been approved by the Board of Directors (BoD) on the Meeting of 8.5.2023. The Policy sets the
framework (legal, accounting, regulatory) under which the Bank may proceed to a dividend distribution and is reviewed at least
annually in the context of ICAAP and/or as often as necessary in order to reflect amendments in all applicable laws and regulations.
As of 31.12.2023, the Alpha Services and Holdings capital ratios (on an individual and consolidated basis) meet all regulatory
requirements and the management targets as defined in its Dividend Policy .Following the above and based on FY2023 profitability,
the Alpha Services and Holdings has the ambition for a dividend distribution of a total amount of Euro c.122 millions to
shareholders.
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23 | ANNUAL FINANCIAL REPORT
5. EU-WIDE STRESS TEST 2023
The EU-wide Stress Test is a biannual exercise and is conducted by EBA for the largest European banks and by ECB for the banks
which are not included in the first group. The EU-wide Stress Test 2023 includes additional 26 banks that have been added to the
stress test sample compared to the 2021 exercise and further proportionality has been introduced into the methodology. Alpha
Bank was part of the EBA sample for the 2023 Stress Test exercise.
The 2023 EU-wide stress test used a constrained bottom-up approach with some top-down elements. Focus was on the
assessment of the impact of adverse shocks on banks’ solvency. Banks were required to estimate the evolution of a common set of
risks (credit, market, counterparty, and operational risk) under a baseline and an adverse scenario.
The Stress Test was conducted based on a static balance sheet approach under a baseline and an adverse macro scenario with a
3-year forecasting horizon (2023-2025).
Alpha Services and Holdings successfully concluded the 2023 EU-wide Stress Test and the results were published by EBA on
28.7.2023.
The results of Alpha Services and Holdings (IFRS 9 - fully loaded basis) are presented in the following table:
It is noted that the Stress Test methodology did not incorporate the Bank’s H1 2023 capital strengthening actions. These include,
among others, NPE deleveraging through the “Sky” and “Hermes” transactions, the shipping synthetic securitization, additional Τier
1 issuance and organic capital accretion. The CET 1, Tier I and Total capital ratios of December 2022 pro-forma for the above
actions are enhanced by c. 1.3%, 2.5% and 2.6% respectively.
In the base scenario there is a capital accretion with an increase in the Common Equity Tier I (FL) by 2.2 pp in the 3 years horizon
including also a dividend pay-out of 30 %.
Since the previous EU ST 2021, Alpha Services and Holdings has transformed itself, significantly strengthening its balance sheet,
decisively reducing its NPEs, restoring its organic profitability and successfully building a track record in the capital markets through
the issuance of capital and MREL instruments while also further enhancing capital and liquidity buffers. The capital depletion in the
Common Equity Tier I (IFRS9-fully loaded basis) over the three years horizon in the adverse scenario (ignoring any post year-end
events) was 3.1 pp compared to 4.6 pp for the EU Average.
6. DEFERRED TAX ASSETS (DTAS)
The Deferred Tax Assets (DTAs) which are included in the Group’s capital base as at 31.12.2023 stand at Euro 5.0 billion.
According to article 5 of Law 4303/17.10.2014, as amended by article 4 of Law 4340/1.11.2015, on the “Recapitalization of financial
institutions and other provisions of the Ministry of Finance” and Laws 4549/2018 and 4722/2020 and, most recently, by
Law 4831/2021, DTAs that have been recognized and are due to the debit difference arising from the Private Sector Involvement
(PSI) and the accumulated provisions and other general losses due to credit risk, which were accounted until 30.06.2015, are
converted into final and settled claims against the Greek State. The above mentioned are set into force in case the accounting
result for the period after taxes is a loss, according to the audited and approved by the Ordinary General Meeting of Shareholders
financial statements.
In accordance with article 39 of Regulation (EU) No 575/2013 of the European Parliament and of the Council on “prudential
requirements for credit institutions and investment firms” (the “Capital Requirements Regulation – CRR”), which amended
Regulation (EU) No 648/2012, a risk weight of 100% will be applied to the abovementioned DTAs that may be converted into tax
credit, instead of being deducted from the Regulatory Equity Capital.
Table 1 – Stress test results (Actual)
Stress Test Results
31.12.2022
31.12.2025
31.12.2025
Starting
Point
Baseline
Adverse
CET1 fully loaded (%)
11.9%
14.1%
8.9%
Tier I fully loaded (%)
11.9%
14.1%
8.9%
Total Capital fully loaded (%)
14.9%
16.9%
11.7%
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
24 | ANNUAL FINANCIAL REPORT
On 31.12.2023, the amount of DTAs, which is eligible for the scope of the aforementioned Law, is the same for the Bank and the
Group and is included in the Common Equity Tier 1, stands at Euro 2.6 billion and constitutes 55.5% of the Group’s Common
Equity Tier 1 and 8% of the respective Weighted Assets.
Any change in the above framework that will result in the non-recognition of DTAs as a tax credit will have an adverse effect on the
Bank’s and the Group’s capital adequacy.
7. CAPITAL REQUIREMENTS UNDER PILLAR I
The approaches adopted for the calculation of the capital requirements under Pillar I are determined by the policy of the Group in
conjunction with factors such as the nature and type of risks the Group undertakes, the level and complexity of the Group’s
business and other factors such as the degree of readiness of the information and software systems.
Capital Requirements for Credit Risk are calculated using the Standardized Approach (STA). The advanced method is used for the
valuation of financial collaterals. For the Operational Risk capital requirements, the Group follows the STA. As regards Market Risk,
the Bank uses for the significant exposures a Value at Risk (VaR) model developed at Bank level and approved by the Bank of
Greece. Additionally, STA is used to calculate Market Risk for the remaining non-significant exposures by the financial institutions
of the Group at solo level as also on Group level.
8. INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS (ICAAP) AND INTERNAL LIQUIDITY
ADEQUACY ASSESSMENT PROCESS (ILAAP)
The ICAAP and ILAAP are an integral part of the Internal Control System (ICS) of the Group. They are aligned with best practices
and the general principles and requirements set by the regulatory framework, including the guidelines provided by the Single
Supervisory Mechanism (SSM) and/or the European Banking Authority (EBA). These guidelines allow for:
• The identification, analysis, monitoring and the overall assessment of risks to capital and liquidity.
• The improvement of various systems/procedures/policies related to the assessment and management of risks.
• The estimation of the Internal Capital required for the coverage of all risks and the determination, the management and the
monitoring of the liquidity buffer.
• Capital and liquidity planning, taking also into consideration the Group’s risk appetite and the approved business plan.
ICAAP and ILAAP are integrated into the business decision-making and risk management processes of the Group, contributing to
its continuity by ensuring its capital and liquidity adequacy from different but complementary perspectives (e.g. the economic
perspective and the normative perspective), while both perspectives mutually inform each other and are integrated into all material
business activities and decisions.
The Board of Directors has the overall responsibility of the ICAAP/ILAAP implementation with a clear and transparent assignment
of responsibilities to the Risk Management Committee and to Senior Management Members. The Board of Directors, following the
Risk Management Committee endorsement, approves the results of the ICAAP and the ILAAP and signs the Group’s Capital
Adequacy Statement (CAS) and the Liquidity Adequacy Statement (LAS).
The related reports are updated at least annually or on a more frequent basis if material changes occur and are submitted to the
SSM of the European Central Bank (ECB). The ICAAP and ILAAP Reports are assessed yearly by the ECB as part of the
Supervisory Review and Evaluation Process (SREP).
9. REGULATORY LIQUIDITY
The Group’s NPE deleveraging, coupled with the customer deposits increase, the restored market access and the issuances of
Euro 2.9 billion, improved the Group’s funding mix. As of December 31, 2023, the Group’s Liquidity Coverage Ratio (LCR)
stands at 191.0% and Group Net Stable Funding ratio (NSFR) stood at 130.08% % respectively. It is also noticed that HQLA (High
Quality Liquid Assets) to total Deposits ratio was further improved compared to previous quarter and stands at 31% while Loans to
Deposits stands at 75%.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
25 | ANNUAL FINANCIAL REPORT
10. MREL
The Minimum Requirement for own funds and Eligible Liabilities (MREL) constitutes a buffer that the Bank has to maintain in order
to absorb losses in the event of resolution. The minimum levels of MREL are determined by the Single Resolution Board (SRB) on
an annual basis.
As per the latest official SRB decision on 21 March 2023, as of January 1, 2023, the Bank shall comply, on a consolidated basis,
with an intermediate MREL target equal to 16.36% of the Total Risk Exposure Amount (TREA) and 5.91% of the Leverage
Exposure (LRE).
As of January 1, 2026, the consolidated MREL will become “fully loaded” and will be set at 23.60% of the TREA and 5.91% of the
LRE. The final MREL ratio expressed as a percentage of TREA does not include the Combined Buffer Requirement (CBR), which
stands at 3.69% effective 01 January 2024.
Following four Senior Preferred Bond issuances in 2021 and 2022 amounting to EUR 1.7 billion in total, Alpha Bank further placed
one Minimum Requirement for own funds and Eligible Liabilities (MREL) Senior preferred bond issuance during 2023. In June 2023
a Euro 0.5 billion senior preferred bond was issued, with a 6.875% coupon rate, a yield of 7% and a six-year maturity, while it is
callable in the fifth year.
On December 31, 2023, the Bank’s MREL ratio stood at 25.40%, which is well above the interim non-binding target of 22.50% of
the Total Risk Exposure Amount (TREA) (effective 01.01.2024). The said ratio includes the profit of the financial reporting period
that ended on December 31, 2023 post a provision for dividend payout.
TRANSFORMATION
TRANSFORMATION PLAN
The year 2023 marks the successful completion of the first phase of the Group’s Transformation plan (“Transformation 1.0”), and the
transition to the next phase (“Transformation 2.0”) which has already started with a clear set of priorities across the organization.
The Group has already capitalized significant benefits from “Transformation 1.0” in the areas of Retail, Wholesale and Operations.
Some of the most prominent transformations initiatives achieved include the establishment of a segment-based operating model in
Retail (evidenced through the delivery of a personalized service for more than 280.000 priority customers), the significant release of
commercial time from front line teams (Retail and Wholesale), the delivery of over 18 new digital products and services that reinforced
the Group’s digital footprint in Wholesale, the significant productivity improvement reaching more than 20% in central functions, the
automation of credit decisioning, the saving of over Euro 23million on a yearly basis in G&A expenses, and the shift of our IT teams
into a DevOps model of working.
Aside from the benefits in the businesses, the Transformation effort has enabled the Bank to re-define the way it operates and delivers
change, to raise the level of ambition focusing on “what matters”, to remove legacy silos between different functional areas and to go
beyond its normal delivery capacity with targeted and prioritized initiatives.
In 2024, the Group will shift its effort towards Transformation 2.0, a more focused program aiming to deliver further structural changes
in the areas of Retail, Wholesale, Wealth management & International.
Through Transformation 2.0, the Wholesale area will reshuffle its Operating Model and apply targeted improvements in the Servicing
Model. More specifically, the Bank is in the process of reallocating activities among Wholesale stakeholders with primary focus on
Relationship Manager’s (RM) efficiency and customer experience. At the same time, the Bank revisits its servicing model by
optimizing Wholesale customers’ service touchpoints and creating dedicated after-sales support capabilities. Wholesale will also
leverage the recently developed Retail tools to offer Wholesale Clients remote/centralized services through a hybrid “phygital”
servicing model. Finally, Wholesale digital product offering will be further expanded through the roll-out of additional digital product
and services including but not limited to the implementation of digital signatures, e-LGs, e-factoring etc. which will drive further
improvement in customer experience.
The second phase of the Transformation program also aims to deliver further improvements in RM productivity. In this context, the
Bank is working on further enhancements on the credit workflow tools which will bring more automations and interlinks with various
Bank systems leading to release of RM commercial time. The usage of these tools will also be expanded to other areas of Wholesale
in order to benefit a larger population of RMs and clients. In addition, the Bank has already put in place a “swimlane approach” in the
SME portfolio, which introduces a simplified process for non complex credit cases. Coupled with further improvements in the digital
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
26 | ANNUAL FINANCIAL REPORT
credit paper, this is expected to accelerate the decision process (time-to-yes) by c. 40% and create further efficiencies in RMs and
credit officers in the area of 10%.
Transformation 2.0 will also bring into the spotlight the reinforcement of Transaction Banking. The Bank has already deployed a new
collaboration framework between RMs and Product Expects with emphasis on cross-selling of non-lending products. Additionally, the
Bank is in the process of rolling-out a new incentive framework for Transaction Banking products. Together with other initiatives that
impact the pricing structure of transaction banking products, this umbrella of initiatives will boost revenues and profitability across
Transaction Banking.
In the area of Wealth, the Bank has identified as a key priority the enhancement of the technology infrastructure and business
architecture for its wealth management platform, coupled with the development of a new offshore wealth management offering
covering the Group’s operations abroad. More specifically, the Bank aims to revamp its system infrastructure and key processes
building a more scalable and customer friendly infrastructure which will boost client experience and simplify existing processes. This
key initiative underpins the ambitious growth plans of the bank in the Wealth space.
In International business, Transformation 2.0 will support the evolution of Alpha Bank London business model into a digitally enabled
bank that serves Greek, Cypriot and Romanian communities in the UK.
Enhancing the efficiency of the Bank’s operating platform will remain a key priority for the Bank. To this end, Transformation 2.0 has
already prioritized a number of key journeys and processes that have significant potential for productivity improvement through the
levers of centralization, automations and system integrations. This includes automations in the disbursement processes, further
connectivity and system integrations in the credit application processes, smarter management of client documents enabling future
re-use, further expansion of our RPA capabilities to name just a few.
The transition from Transformation 1.0 to Transformation 2.0 signals the strong commitment of the Group to continue delivering
structural change, leveraging the proven change management methodology adopted in the first phase of the program. This is coupled
with further initiatives that influence and gradually transform the organizational culture of the bank contributing to a holistic
transformation that cuts across, clients, colleagues, processes and technology.
DIGITAL TRANSFORMATION AND INNOVATION ACTIVITIES
The Group continues addressing the evolving banking needs of its customers during the execution of its Strategic Plan 2023-2025.
This plan emphasizes on the design and implementation of digital solutions aiming to upgrade the customer banking experience.
In 2023, the Group marked substantial progress in its digital transformation journey, highlighted by the growth and integration of its
Digital Factory.
The agile Digital Factory has seen a significant expansion, now featuring 14 agile delivery teams (“squads”) that are efficiently
organized into chapters and tribes. This organizational refinement enables swift and adaptive project execution, ensuring the
delivery of timely and impactful outcomes.
The introduction of User Experience (UX) and Advanced Analytics Centers of Excellence has further bolstered the Digital Factory's
capabilities, enabling the Bank to create more intuitive digital experiences and leverage data-driven insights for informed decision-
making. Additionally, the formation of the Digital Sales teams, consisting of over 40 professionals from various divisions has
successfully met or surpassed, digital penetration goals, particularly in the consumer lending segment.
Daily Banking
In 2023, the AlphaBank made notable advancements in accelerating the digitalization of daily banking. Through the establishment
of a comprehensive delivery mechanism, the Alpha Bank achieved a significant increase of banking transactions in digital channels,
ensuring seamless customer experiences.
A suite of new digital banking offerings was introduced, enhancing its services to both individuals and businesses. These
implementations included the launch of the digital credit cards issuing along with the special digital loan for payroll clients,
equipping individuals with additional digital product offerings for effective financial management. Moreover, the introduction of Alpha
Payroll account opening offered tailored solutions for salary and pension accounts, readily accessible through myAlpha Web and
myAlpha Mobile.
The year also marked the AlphaBank’s first significant step in introducing subscription-based banking through digital channels.
myAlpha Benefit transactions bundles were introduced to the market, featuring one standard and two value-adding packages,
designed to meet the diverse individual clients needs comprehensively.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
27 | ANNUAL FINANCIAL REPORT
In alignment with the AlphaBank’s strategic commitment to family-centric services, the launch of myAlpha Vibe represented a
significant innovation. MyAlpha Vibe offers a distinctive pocket money management solution for teenagers aged 15-18, marking
Alpha Bank as the first and only Greek systemic bank to provide such a unique service. The product stands out by offering a
modern and convenient digital service to teenagers, while simultaneously ensuring parents have sufficient oversight to promote
responsible usage.
In response to the growing demand for remote banking services, Alpha Bank has unveiled its remote collaboration platform. The
platform leverages a wide range of digital services such as appointment booking, video banking, electronic document exchange
and signing through a unified digital service cockpit in both myAlpha Web and mobile application.
In order to address the needs of business clients the Alpha Bank enhanced its digital service offerings by introducing non-EU
Simple Imports, Certificate Issuance, and myAlpha Documents for Business. These services facilitate the digital exchange of
documents, incorporate tap-to-accept digital signatures and real-time notifications, thereby providing businesses with efficient and
secure digital solutions that adapt to their dynamic requirements. Additionally, Alpha Bank has distinguished itself as the first and
only Greek bank to launch a mobile-based business expenses management solution, bizpay, as part of its digital strategy to
enhance customer service quality and pioneer a multi-channel banking experience.
Customers continued to overwhelmingly favor the Bank's digital channels for their transactions, with 97% of transactions being
conducted digitally, leaving only 3% to be completed within the bank's branch network. Notably, both the number and value of
transactions via digital channels presented significant increases of 11% and 10%, respectively, compared to 2022. The trend of
new customers registration for e-Banking remained robust, with one in three new customers opting to complete their registration
exclusively online via the myAlpha Mobile app. This trend outlines the Bank's successful transition towards digital banking.
The Bank’s ATM network maintained a stable transaction volume, including withdrawals, deposits, and cash payments.. Alpha
Bank achieved a significant milestone with the completion of its ATM replacement program, replacing the remaining 25% of the
ATM share with newer technology machines. Concurrently, the utilization of the voice guidance service experienced a 6% uptick
compared to 2022, facilitating easier cash withdrawals and balance inquiries for more citizens using Alpha Bank cards or cards
from other Greek banks. This service allows users to connect their headsets to the corresponding Alpha Bank ATMs' reception.
Additionally, by the end of 2023, 98% of the Branch Network had installed at least one Automated Payment System (APS),
enabling deposit and payment transactions, both in cash and by debiting an Alpha Bank card.
Digital Experience
In 2023, Alpha Bank's commitment to providing exceptional digital experiences for both employees and customers was reinforced
through the establishment of a Customer Experience (CX) & User Experience (UX) Center of Excellence. This initiative was geared
towards the creation of streamlined, human-centric digital journeys, ensuring ease of use and satisfaction across all digital
touchpoints. Under this framework, the bank developed over 200 digital journeys, covering a wide range of banking activities.
Customer journey mapping and employee systems flows were streamlined to optimize user experiences.
Additionally, wireframes and designs were developed, alongside the establishment of a new digital voice through engaging and
compelling copywriting. Prototyping was integral to the process, enabling the validation of concepts and refinement of designs,
while cross-component guidelines ensured consistency and coherence across all digital assets.
Advanced Analytics
Advanced analytics and campaign management have been substantial improved in terms of both capacity and expertise. The Bank
has defined and segregated new expert roles as also increased delivery capacity through additions in data management and data
science. Over 20 new governance processes were designed and put in force to help prioritize projects and manage analytics
models’ lifecycle effectively. Under this context, governance bodies have been constituted, and performance KPIs have been
defined to monitor and assess progress effectively. A new cloud-ready Advanced Analytics platform has been deployed, and the
campaign management system has been integrated with mobile apps and web banking.
Furthermore, the Bank invested in new technologies like Natural Language Processing (NLP) and Generative AI, extending their
application beyond Retail banking to the Wholesale banking and the HR domains. These enhancements outline the commitment to
advanced analytics with a view to enhance strategic decision-making and enrich customer experiences.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
28 | ANNUAL FINANCIAL REPORT
OTHER
ALPHA SERVICES AND HOLDING’S SHARE AND SHAREHOLDER STRUCTURE
Share
The Alpha Services and Holdings S.A. is listed on the Athens Exchange since 1925 and is consistently one of the largest
companies in terms of market capitalization. At the end of December 2023, the capitalization of the Alpha Services and Holdings
S.A. stood at Euro 3,619 million and represented 5.09% and 22.89% of the capitalization of the Athens Exchange’s General and
Banking Indexes respectively, while the participation of its share in the FTSE/Athex Large Cap Index was 8.21%.
In addition to the Greek stock exchange, the share is also traded over-the-counter on the New York exchange in the form of
American Depository Receipts (ADRs). The share is included in international indeces such as the FTSE All-World Index, the FTSE
Med 100 Index, the FTSE4Good Emerging Index and the MSCI Global Standard.
The share’s daily trading volume for 2023 amounted to an average of 8,504,513 shares per session, increased by 2% versus
previous year, with an average daily value of transactions of Euro 11,632,472.
Share information for the Alpha Services and Holdings S.A
2023
2022
Closing Price (period end, in Euro)
1.54
1.00
Highest Price (period, in Euro)
1.68
1.43
Lowest price (period, in Euro)
1.03
0.73
Market Cap (period end, in billion Euro)
3.6
2.3
Share’s daily trading volume
8,504,513
8,341,881
Average daily value of transactions (in Euro)
11,632,472
8,684,108
Shareholder Structure
On 31.12.2023, the Alpha Services and Holdings S.A share capital stood at Euro 681,992,324.6 divided into 2,351,697,671
common, nominal, paperless shares with voting rights, of a nominal value of Euro 0.29 each, which are listed for trading on the
Securities Market of the Athens Stock Exchange ("ATHEX").
The shares in circulation on 31.12.2023 were held by approximately 108,000 Individual and Institutional Investors.
The breakdown of the Alpha Services and Holdings shareholders on 31.12.2023 is presented in the section of “Company’s Share
Capital Structure” of the Explanatory Report of the Board of Directors.
ORDINARY GENERAL MEETING OF SHAREHOLDERS OF THE YEAR 2023
On 27.07.2023 the Ordinary General Meeting of the year 2023 was held and resolved,
inter alia
, as follows:
•
Approval of the Annual Separate and Consolidated Financial Statements of the financial year 2022 (1.1.2022 - 31.12.2022),
together with the relevant reports of the Board of Directors which are accompanied by the Statutory Certified Auditors’ Report.
•
Approval of (a) the netting-off of the Retained Earnings/(Losses) against the Statutory Reserve, the Special Reserve of article
31 of law 4548/2018 and the Share Premium and (b) the potential distribution of the intragroup dividend reserve.
•
Announcement on the election by the Board of Directors of two new Members of the Board of Directors in replacement of
Members who have tendered their resignation. Decision on the appointment of Independent Non-Executive Members of the
Board of Directors.
•
Establishment of a Share Buyback Program in accordance with article 49 of law 4548/2018 and authorization to the Board of
Directors for its implementation.
•
Establishment, in accordance with article 114 of law 4548/2018, of a program for free distribution of shares of the Company for
Members of the Management and Employees of the Company and its affiliates and granting of authorization to the Board of
Directors in relation to the program.
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
29 | ANNUAL FINANCIAL REPORT
All items of the Ordinary General Meeting of Shareholders are presented to the Corporate Governance Statement for the year 2023
(section D. “Shareholders-General Meetings of Shareholders”).
TREASURY SHARES
Αlpha Services and Holdings decided at its shareholders Ordinary General Meeting dated 27.07.2023, the establishment of a
Share Buyback Program for acquisition of own existing shares for the purpose of their free distribution to Members of the
Management and employees of the Company and its Affiliated Companies, in the sense of article 32 of Law 4308/2014. Subsidiary
company Alpha Finance performs transactions with the shares of the company Alpha Services and Holdings in the context of
market making. As at 31.12.2023 the carrying amount of the treasury shares was € 10,631. Below are described the transactions of
treasury shares of the Group.
Number of shares
Value
Balance 1.1.2022
-
-
Purchases
3,604,557
3,709
Sales
(2,261,222)
(2,185)
Losses from sales
(228)
Balance 31.12.2022
1,343,335
1,296
Purchases
21,833,960
30,701
Sales
(15,935,826)
(22,689)
Gains from sales
1,323
Balance 31.12.2023
7,241,469
10,631
NUMBER OF BRANCHES
As at 31.12.2023 the Group was operating with 396 Branches, out of which 251 were established in Greece and 145 were
established abroad.
EVENTS AFTER THE BALANCE SHEET DATE
• On 11.01.2024, the Company distributed to 56 beneficiaries of (i) the Performance Incentive Program and (ii) the Retention
Plan for 2023, 1,890,504 own, common registered with voting rights shares of the Company. The shares were distributed to the
beneficiaries free of charge and through over-the-counter transactions. Following the above distribution, the Company holds
directly, 3,965,290 own shares.
• On 12.1.2024 , Alpha Bank Romania acquired through a business transfer the consumer ecosystem built by Orange Money
Romania (comprised of a customer portfolio, top of the market digital asset, credit card portfolio). The transaction allows Alpha
Bank Romania to strengthen its market position on the retail segment and significantly enhance its digital proposition for the
respective segment.
According to IFRS 3, the acquisition method was applied by Alpha Bank Romania as accounting treatment for this business
transfer. The identifiable assets acquired and liabilities assumed were initially recognized on acquisition date at their fair value,
while the purchase price consideration amounting to € 11,896 was paid in cash.
The fair value of assets acquired and liabilities assumed is presented in the table below:
Fair Value
12.01.2024
Cash and balances with central banks
2,027
Loans and advances to customers
11,070
Goodwill and other intangible assets
7,433
Total assets
20,530
Due to customers
(2,027)
Total assets & liabilities
18,503
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
30 | ANNUAL FINANCIAL REPORT
For the credit cards acquired the gross contractual amounts receivable is in amount of € 12,345, while the best estimate at the
acquisition date of the contractual cash flows not expected to be collected is in amount of € 1,276.
The difference between:
a) the sum of the consideration transferred, and
b) the net of the acquisition date amounts of the identifiable assets acquired and the liabilities assumed,
was recognized as a gain in profit or loss account for an amount of € 6,607.
• In the context of the stock option plan for the years 2019 and 2020, during the exercising period of the stock options and in
specific during the period 2.1.2024 until 15.1.2024, 1,142,026 stock options were exercised by the holders for the acquisition of
common, nominal shares of the Company of the same number with a nominal value of € 0.29 each and an exercise price of
€ 0.29 corresponding to 660,418 stοck options and an exercise price of € 0.30 corresponding to 481,608 stock options . The
purchase amount of the above shares was paid in cash and amounted to a total of € 336. On 7.2.2024 the share capital
increase was registered in General Electronic Commercial Registry’s (GEMI) while on 13.2.2023 the above 1,142,026 new
common, registered shares of the Company) started trading on the Stock Exchange (ASE). It is noted that, following the above
increase, the share capital of the Company amounts to € 682,324, divided into 2,352,839,697 common, nominal, voting shares
with a nominal value of € 0.29 each.
• On 5.2.2024, the Bank completed the issuance of a senior preferred bond with a nominal value of €400m., maturity of 6.5 years,
with the option to call at 5.25 years, with a nominal interest rate of 5% and a yield of 5.125
APPLICATION OF PAR. 3 ARTICLE 97 AND ARTICLE 99 OF LAW 4548/2018
Αpplication of par. 3, article 97 of Law 4548/2018:
a) Messrs. V.E. Psaltis, CΕΟ, and S.N. Filaretos, Executive Member of the Board of Directors, did not participate in a meeting of
the Board of Directors of Alpha Services and Holdings S.A. regarding the approval of the Material Risk Takers (MRTs) list for
the year 2022 at Group level.
b) Messrs. V.E. Psaltis, CΕΟ, and S.N. Filaretos, Executive Member of the Board of Directors, did not participate in a meeting of
the Board of Directors of Alpha Services and Holdings S.A. regarding the update and reinstatement of the Senior Executives
Severance Payment Policy (intended to replace the current Policy) of Alpha Bank S.A., as they are included among the Senior
Executives the Policy applies to, to avoid conflict of interest.
c) Mr. R.R. Gildea, Independent Non-Executive Member of the Board of Directors, did not participate in a meeting of the Board of
Directors of Alpha Services and Holdings S.A. regarding his appointment as Advisor to the Chair of the Board of Directors, to
avoid conflict of interest.
d) Messrs. Mr. Vassilios Psaltis, CEO, and Spyridon Filaretos, Executive Member of the Board of Directors, did not participate in a
meeting of the Board of Directors of Alpha Services and Holdings S.A. regarding the amendments of the Executive Committee
Members contracts, as they are Members of the Executive Committee whose contracts were amended, to avoid conflict of
interest.
e) Messrs. Mr. Vassilios Psaltis, CEO, and Spyridon Filaretos, Executive Member of the Board of Directors, abstained from voting
on the approval by the Board of Directors of Alpha Services and Holdings S.A. of the Stock Award Plan Regulation and the
Regulation of the 2023 Retention Plan, as they are included in the Beneficiaries of the aforementioned Regulations, to avoid
conflict of interest.
f) Messrs. Mr. Vassilios Psaltis, CEO, and Spyridon Filaretos, Executive Member of the Board of Directors, abstained from voting
on the approval by the Board of Directors of Alpha Services and Holdings S.A. of the allocation, in the context of the Regulation
for the Stock Award Plan, of Shares to MRTs of the Company and its Affiliates and to the Eligible for the 2023 Retention Plan
perimeter, as they are included in the Beneficiaries of the allocation of the award under the Stock Award Plan in 2023, to avoid
conflict of interest.
g) Mr. J.-H.-F.G. Umbgrove, as representative of the Hellenic Financial Stability Fund (the “HFSF”), abstained from voting on the
approval by the Board of Directors of Alpha Services and Holdings S.A. of the General Terms and Conditions for a Strategic
Partnership with UniCredit S.p.A. in Greece and in International Operations, as, with regard to the issue under consideration,
the interests of the HFSF may not be aligned and, thus, may be in material conflict with those of Alpha Services and Holdings
S.A. and his duty of loyalty and his duty of care owed towards the HFSF are in material conflict with the duty of loyalty and the
duty of care he owes towards Alpha Services and Holdings S.A., to avoid conflict of interest.
h) Messrs. Mr. Vassilios Psaltis, CEO, and Spyridon Filaretos, Executive Member of the Board of Directors, did not participate in a
meeting of the Board of Directors of Alpha Services and Holdings S.A. regarding the approval of a Savings Plan for the Senior
Executives and of the conclusion of a relevant contract with the company under the name “Generali Hellas Insurance Company
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
31 | ANNUAL FINANCIAL REPORT
S.A.” for the establishment and implementation of the said Savings Plan, as they are included in the Beneficiaries/Insured
Members, to avoid conflict of interests.
In application of article 99 of Law 4548/2018:
a) The Board of Directors of Alpha Services and Holdings S.A. (“the Company”) endorsed on 25.05.2023 the update and
reinstatement of the Senior Executives Severance Payment Policy (intended to replace the current Policy) of Alpha Bank
S.A. (the “Bank”), as Senior Executives are related parties with both the Bank and the Company, in accordance with
articles 99-101 of law 4548/2018, after having taken into account the granting of the special permission by the Board of
Directors of the Bank with respect to the update and reinstatement of the Policy as well as the Fairness Opinion dated
25.05.2023, issued by the Independent Advisor “KPMG Advisors Single Member S.A.”, through which it was assessed that
the abovementioned transactions were fair and reasonable for the Bank and its Shareholders. The above-mentioned
decision along with the above Fairness Opinion issued by the Independent Advisor “KPMG Advisors Single Member S.A.”
were announced to the General Commercial Registry (G.E.MI.) on 21.06.2023. On 06.07.2023 the Board of Directors
announced to G.E.MI. its confirmation, pursuant to article 101 par. 2 of law 4548/2018, for the inactive lapse of the 10-day
period deadline, which is provided for in article 100 par. 3 of the said law for the exercise by the Shareholders of the right
to convene a General Meeting for this issue.
b) The Board of Directors of Alpha Services and Holdings S.A. endorsed on 31.08.2023 the amendments of the Executive
Committee Members contracts, as Members of the Executive Committee are related parties with both the Bank and the
Company, in accordance with articles 99-101 of law 4548/2018, after having taken into account the granting of the special
permission by the Board of Directors of the Bank with respect to the amendments of the Executive Committee Members
contracts as well as the Fairness Opinion dated 31.08.2023, issued by the Independent Advisor “RSM Greece Certified
Auditors and Management Consultants S.A.” through which it was assessed that the abovementioned transactions were
fair and reasonable for the Company and its Shareholders. The above-mentioned decision along with the above Fairness
Opinion issued by the Independent Advisor “RSM Greece Certified Auditors and Management Consultants S.A.” were
announced to the General Commercial Registry (G.E.MI.) on 6.9.2023. On 26.09.2023 the Board of Directors announced
to G.E.MI. its confirmation, pursuant to article 101 par. 2 of law 4548/2018, for the inactive lapse of the 10-day period
deadline, which is provided for in article 100 par. 3 of the said law for the exercise by the Shareholders of the right to
convene a General Meeting for this issue.
c) The Board of Directors of Alpha Services and Holdings S.A. (“the Company”) endorsed on 14.12.2023 the approval of a
Savings Plan for the Senior Executives and of the conclusion of a relevant contract with the company under the name
“Generali Hellas Insurance Company S.A.” for the establishment and implementation of the said Savings Plan, as Senior
Executives are related parties with both the Bank and the Company, in accordance with articles 99-101 of law 4548/2018,
after having taken into account the granting of the special permission by the Board of Directors of the Bank with respect to
the approval of a Savings Plan for the Senior Executives and of the conclusion of a relevant contract with the company
under the name “Generali Hellas Insurance Company S.A.” for the establishment and implementation of the said Savings
Plan as well as the Fairness Opinion dated 8.12.2023, issued by the Independent Advisor “RSM Greece Certified Auditors
and Management Consultants S.A.”, through which it was assessed that the abovementioned transactions were fair and
reasonable for the Bank, the Company and their Shareholders. The above-mentioned decision along with the above
Fairness Opinion issued by the Independent «RSM Greece ΑΕ» were announced to the General Commercial Registry
(G.E.MI.) on 15.12.2023. On 16.01.2024 the Board of Directors announced to G.E.MI. its confirmation, pursuant to article
101 par. 2 of law 4548/2018, for the inactive lapse of the 10-day period deadline, which is provided for in article 100 par. 3
of the said law for the exercise by the Shareholders of the right to convene a General Meeting for this issue.
TRANSACTIONS WITH RELATED PARTIES
According to the corresponding regulatory framework, this report must include the main transactions with related parties. All the
transactions between related parties are performed in the ordinary course of business, conducted according to market conditions
and are authorized by corresponding management personnel.
A. The outstanding balances of the Group transactions with key management personnel which is composed by members of the
Board of Directors and the Executive Committee of the Alpha Services and Holdings S.A., as well as their close family members
and the companies relating to them, as well as the corresponding results from those transactions are as follows:
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
32 | ANNUAL FINANCIAL REPORT
31.12.2023
31.12.2022
Assets
Loans and advances to customers
3,633
3,911
Liabilities
Due to customers
7,346
5,058
Employee defined benefit obligations
253
213
Debt securities in issue and other borrowed funds
4,765
3,622
Total
12,364
8,893
Letters of guarantee and approved limits
308
382
From 1 January to
31.12.2023
31.12.2022
Income
Interest and similar income
174
68
Fee and commission income
5
6
Gains less losses on financial transactions
2
1
Other income
124
Total
180
199
Expenses
Interest expense and similar charges
106
61
Commission expenses
General administrative expenses
Remuneration of Board members, salaries and wages
9,922
7,387
Total
10,028
7,448
Remuneration of key executives and their close relatives is analyzed as follows:
From 1 January to
31.12.2023
31.12.2022
Remuneration of Board members, salaries and wages
6,451
5,685
Benefits fees
21
116
Bonus Incentive program expenses
2,511
708
Employer contributions
728
446
Other
216
432
Total
9,927
7,387
B. Τhe outstanding balances of Alpha Services and Holdings S.A. with the Group companies and the corresponding results are as
follows:
a.
Subsidiaries
Name
Receivables
Liabilities
Income
Expenses
Banks
1
Alpha Bank S.A.
1.030.437
28.313
77.817
18.690
Leasing
1
Alpha Leasing S.A.
0
0
0
Asset Management
1
Alpha Asset Management Α.Ε.Δ.Α.Κ.
0
0
0
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
33 | ANNUAL FINANCIAL REPORT
a.
Subsidiaries
Name
Receivables
Liabilities
Income
Expenses
Insurance
1
Alpha Insurance Agents S.A.
0
0
0
2
Alphalife A.A.E.Z.
2.424
0
9.173
0
Investment Banking
1
Alpha Finance A.E.P.Ε.Υ.
0
0
0
Real Estate and hotel
1
Alpha Real Estate Management and Investments S.A.
0
0
25
0
2
Alpha Investment Property Attikis S.A.
2
0
7
0
3
APE Fixed Assets S.A.
6
0
21
0
4
Alpha Investment Property Neas Kifissias S.A.
4
0
12
0
5
Alpha Investment Property Kallirois S.A
3
0
8
0
6
Alpha Investment Property Levadias S.A.
5
0
12
0
7
Alpha Investment Property Neas Erythraias S.A
3
0
7
0
8
Alpha Investments Property Spaton S.A
0
0
8
0
9
Alpha Investments Property Kallitheas S.A
0
0
19
0
10
Alpha Investment Property Irakleiou S.A.
2
0
5
0
11
AEP Industrial Property S.M.S.A.
5
0
21
0
12
AIP Attica Residential Assets I S.M.S.A.
3
0
10
0
13
AIP Rog Residential Assets S.M.S.A.
0
0
11
0
14
AIP Thessaloniki Residential Assets S.M.S.A.
5
0
7
0
15
AIP Cretan Residential Assets S.M.S.A
2
0
5
0
16
AIP Aegean Residential Assets S.M.S.A.
0
0
6
0
17
AIP Ionion Residential Assets S.M.S.A.
0
0
6
0
18
AIP Commercial Assets City Centres S.M.S.A.
8
0
9
0
19
AIP Thessaloniki Commercial Assets S.M.S.A.
0
0
5
0
20
AIP Commercial Assets Rog S.M.S.A.
0
0
6
0
21
AIP Attica Retail Assets I S.M.S.A.
0
0
7
0
22
AIP Attica Retail Assets II S.M.S.A.
0
0
6
0
23
AIP Attica Residential Assets II S.M.S.A.
5
0
8
0
24
AIP Retail Assets Rog S.M.S.A.
0
0
6
0
25
AIP Gis ΙΙ S.M.S.A
0
0
7
0
26
AIP Commercial Assets ΙΙ S.M.S.A
2
0
6
0
27
AIP Attica Resedential Assets IV S.M.S.A.
2
0
5
0
28
Startrek S.M.S.A.
0
0
0
29
Skyline Assets Single Member S.A.
9
0
14
0
30
Athens Commercial Assets I
2
0
5
0
31
Athens Commercial Assets II
2
0
5
0
32
AIP Commercial Assets ΙΙI S.M.S.A
2
0
4
0
SPEs and Holding
1
Alpha Holdings Single Member S.A.
0
0
37
0
Other companies
1
Kafe Alpha S.A.
10
0
5
0
2
Alpha Supporting Services S.A.
23
0
0
3
Emporiki Management S.A
6
0
6
0
4
Alpha Bank Notification Services S.A
(0)
0
5
0
b.
Associate
1
Nexi Payments Hellas S.A.
0
0
0
2
Alpha Investment Property Eleona S.A.
28
0
45
0
BOARD OF DIRECTORS’ ANNUAL MANAGEMENT REPORT AS AT 31.12.2023
34 | ANNUAL FINANCIAL REPORT
a.
Subsidiaries
Name
Receivables
Liabilities
Income
Expenses
c. Κοινοπραξίες (Joint ventures)
1
APE Commercial Property S.A.
0
0
5
0
2
APE Investment Property S.A.
35
0
86
0
3
Alpha Investment Property Commercial Stores S.A
5
0
8
0
Τotal (a)
1.032.971
28.313
87.328
18.690
Τotal (b)
28
0
45
0
Τotal (c)
40
0
98
0
C. The Hellenic Financial Stability Fund (HFSF) exerts significant influence on the Bank. In particular, in the context of Law
3864/2010 and based to Relationship Framework Agreement (“RFA”) signed on 23.11.2015, which replaced the previous one
signed in 2013, HFSF has participation in the Board of Directors and other significant Committees of the Bank. Therefore,
according to IAS 24, HFSF and its related entities are considered related parties for the Bank.
The outstanding balances and the results related to these transactions are analyzed as follows:
From 1 January to
31.12.2023
31.12.2022
Income
Fee and commission income
7
6
D. TEA Group Alpha Services and Holdings, founded in March 2023, is a post-employment benefit plan for the benefit of the
employees of the Group of Alpha Services and Holdings, with a salaried mandate relationship or with a dependent work relationship
of indefinite duration. More specifically the subsidiary companies participating are ABC Factors S.A., Alpha Asset Management
A.E.D.A.K, Alpha Bank S.A., Alpha Finance A.E.P.E.Y., Alpha Leasing S.A., Alpha Astika Akinita S.A., Alpha Services and Holdings
S.A., Alpha Supporting Services S.A., Alphalife A.A.E.Z.
From 1 January to
31.12.2023
31.12.2022
Expenses
Staff costs and expenses
9,403
Total
9,403
-
TEA Group Alpha Services and Holdings keeps a deposit with Alpha Bank amounting to € 61 as at 31.12.2023
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35 | ANNUAL FINANCIAL REPORT
NON-FINANCIAL REPORT
The Non-Financial Report (NFR or Report) has been prepared in accordance with Law 4548/2018 and the General Electronic
Commercial Registry’s (GEMI) Circular 62784/2017. In addition, best international practices in the issuance of non-financial
information have been applied, using recognized guidelines and frameworks (such as the Global Reporting Initiative (GRI)
Standards) and the “Public Statement - European common enforcement priorities for 2023 annual financial reports” of the
European Securities and Market Authorities (ESMA).
The Report includes the following sections:
- Sustainable Business
• Business Model
• Codes and Policies
• Stakeholder Engagement- Identification of Material Impact Areas
• ESG Risk considerations
• Operational Risk Materiality Assessment
• Sustainability strategy
- Environment
- Social and Employee Matters
- Human Rights
- Anti-Corruption and Bribery
- Supply Chain
- Governance
- Responsible Investment and Financing
- ESG Performance Ratings
- EU Taxonomy Disclosure Data Collection Process
Data have been collected by the Alpha Services and Holdings Group (Group). Detailed information and additional performance
indicators for Alpha Services and Holdings S.A. and its Group, are presented in the Alpha Services and Holdings S.A. Sustainability
Report 2023. It should be noted that Alpha Bank S.A. (“Bank’) is the largest subsidiary of the Group and, as such, all data
presented in for Alpha Services and Holdings S.A. refer to Alpha Bank’s S.A. performance.
The process of corporate reporting is an integral part of the Internal Control System (ICS) of the Group which is described in detail
in the Corporate Governance Statement.
More specifically, the data collection process for the reporting of non-financial information follows the basic principles of the
corporate reporting process featuring standard controls such as the identification of roles and responsibilities, information
systems, management review and approvals. The procedure along with detailed description about specific data points and owners,
are formally stated in the “Manual for the development of Non- Financial Reports” that has been approved by the General
Management. Finally, in the context of increasing the reliability of the data of the NFR, Alpha Services and Holdings S.A. subjects
selected data of its NFR to external independent assurance.
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36 | ANNUAL FINANCIAL REPORT
SUSTAINABLE BUSINESS
BUSINESS MODEL
The Business Model of Alpha Bank S.A. aims to create value for its stakeholders. Alpha Bank S.A. supports the Greek economy,
by amplifying its electronic services to improve clients’ access to finance. It also offers products and services that enable its clients’
transition to more sustainable business models. Alpha Bank S.A. invests in its Employees, its network, and infrastructures to bring
high-quality services and products to Market. It also works with its Stakeholders to identify their requirements in a timely manner, to
ensure its responsible operations and to support society. Alpha Bank S.A. provides a healthy work environment, in which
Employees enhance their knowledge and skills and contribute to the development of new products and services.
The organization and operation of Alpha Services and Holdings Group is governed by best banking and business practices, which
are supported by certifications with recognized international standards:
• ISO 9001 Quality Management System,
• ISO 20000 Information Technology Services Management System,
• ISO 22301 Business Continuity Management System,
• ISO 27001 Information Security Management System, integrated with ISO27701 (Privacy Information management),
• ISO27017 (Information Security controls for cloud services System)
• ISO27018 (Protection of personally identifiable information in public clouds System)
• ISO 14001 Environmental Management System
• ISO 14064 Greenhouse Gas Emissions Management System).
The certified management systems (ISO) implemented by the Group aim to enable it to better respond to the ever-changing
business environment and to the Customer needs, in alignment with current legislative and regulatory requirements. In that context,
Alpha Bank S.A., commencing 2022 is developing, an Environmental Statement in accordance with the EU Eco-Management and
Audit Scheme (EMAS) which has been submitted to the Ministry of Environment and Energy.
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37 | ANNUAL FINANCIAL REPORT
Additionally, it should be noted that, Alpha Bank S.A. was the first bank in Greece to verify its Organizational Resilience framework
with the international standard ISO 22316 (Organizational Resilience). The Bank has also obtained ISO 45001 (Occupational
Health and Safety) certification, further enhancing the Group’s alignment with international standards and best practices.
Finally, it should be noted that Alpha Bank S.A. initiated in 2023 the implementation of Energy Management System (ISO 50001)
and Sustainable Procurement Management System (ISO 20400) aiming to obtain certification within 2024.
CODES AND POLICIES
Alpha Bank S.A.’ s fundamental policies in relation to Environmental, Social and Governance (ESG) issues are presented in the
following table. Further details regarding Alpha Bank S.A. or Alpha Services and Holdings Group policies and corporate
governance are included in the Corporate Governance Statement and the Annual Sustainability Report 2022. It should be noted
that the policies are available in a dedicated section of the Group’s Intranet and website. Once a new policy or an updated policy is
published, a corresponding circular is also uploaded on the Group’s intranet.
Fundamental Codes, Policies and Compliance Regulations
applied by Alpha Bank S.A. and Alpha Services and Holdings Group Companies
Active Ownership & Voting Policy
Alpha Services and Holdings S.A.-Suitability and Nomination Policy for the Members of the Board of Directors
Alpha Bank S.A.-Suitability and Nomination Policy for the Members of the Board of Directors and Key Function
Holders
Alpha Bank S.A.-Policy for the Evaluation of Senior Executives and Key Function Holders
Anti-Bribery and Corruption Policy
Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy
Bank Secrecy Procedure
Climate Related, Environmental, Social and Governance Risk Management Policy on Group’s Business lending
Code of Ethics
Compliance Policy
Concentration Risk and Credit Threshold Policy
Corporate Responsibility Policy
Credit Risk Early Warning Policy
Diversity Policy
Expenses Policy for the Non-Executive Members of the Board of Directors
Fraud Risk Management Policy
Group Business Continuity Management Policy
Group Credit Risk Management Policy
Group ISO Certification Management Policy
Group Personal Data Protection Policy
Group Market Risk Management Policy
Group Procurement Policy
Group Recovery Plan Framework and Manual
Induction and Training Policy and Procedure for the Members of the Board of Directors
Information and Communication Technologies (ICT) and Security Risk Management Policy
Internal Governance Regulation
Liquidity Risk Policy
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38 | ANNUAL FINANCIAL REPORT
Pricing Framework within Loan Origination
Main Principles on Sanctions or Restrictive Measures for Group Companies against Countries, Individuals or
Legal Entities
Market Abuse Prevention Policy and Procedures
Occupational Health and Safety Policy
Operational Risk Management Policy
Outsourcing Policy
Policy for the Succession Planning of Senior Executives and Key Function Holders
Policy and Procedure for the Provision of Financial Assistance (sponsorships)
Policy and Process for the Succession Planning of Non-Executive and Independent Non-Executive Members of
the Board of Directors
Policy on the Prevention of Conflict of Interests
Policy on “Related Parties” Transactions
Remuneration Policy of the Members of the Board of Directors as per the provisions of Law 4548/2018
Remuneration Policy for Alpha Services and Holdings. and its Group
Remuneration Policy for Alpha Bank S.A. and the other Companies of the Banking Group
Reputational Risk Management Policy
Senior Executives Severance Payment Policy
Suitability and Nomination Process for the Members of the Board of Directors
Sustainable Finance Framework
Tax Risk Management Group Policy
Whistleblowing Policy and Procedures
STAKEHOLDER ENGAGEMENT- IDENTIFICATION OF MATERIAL IMPACT AREAS
Alpha Bank S.A. has recognized as its Stakeholders the natural persons and/or legal entities that, either directly or indirectly, are
connected to and affect or are affected by the Bank’s decisions and operations. Following a series of management meetings and
based on the relevant laws and international guidelines, the existing policies and procedures, the Group’s sustainability strategy
and its daily operations the Bank has identified four different Stakeholder groups: (i) Investors (as well as investment analysts and
advisors), (ii) Customers (iii) Employees and Society and (iv) Official and Regulatory Authorities. Alpha Bank S.A. upholds its
commitment to active stakeholder engagement throughout the year, recognizing the importance of open communication in
understanding better and responding to the Stakeholders’ needs and expectations.
Investors and Analysts are provided with full and prompt information via specific sections on the website, together with the
Financial Statements, the Business Review, the Sustainability Report as well as direct meetings. Alpha Bank S.A. conducts regular
and structured engagements, including quarterly briefings and dedicated meetings, ensuring a consistent and transparent
communication channel. These engagements are important in aligning its strategic objectives with the expectations of the Investor
and Analyst community , thereby fostering a robust investment relationship. It is noted that in 2023, the Bank conducted one
Corporate Governance & Sustainability Roadshow with the participation of Board Directors, and numerous physical and virtual
engagements with Investors and Analysts, and thereafter accessed and incorporated in the Bank's strategic plans.
Furthermore, Alpha Bank S.A. pays great attention to ensuring its Customers’ satisfaction and to providing high-quality products
and services. The Customer Service Division is in charge of delivering the Quality Assurance and is committed to fulfilling these
objectives. Alpha Bank S.A. conducts surveys and focus groups to gather Customer feedback and leverage this for improving
customer satisfaction and product innovation.
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39 | ANNUAL FINANCIAL REPORT
Alpha Bank S.A. ensures effective communication with Employees, by establishing the role of Human Resources Business
Partners that serve as a first point of contact for employees and Visits by Human Resources Unit Executives to Bank Units and
Branches. Alpha Bank S.A. also conducts regular townhall meetings, employee satisfaction surveys, and has set up mechanisms
for anonymous feedback to ensure that Employees share their ideas, concerns, and aspirations.
Finally, the Bank is often involved in the stakeholder dialogue with consultations with Official sector authorities, both locally and at
European level. The Bank supports public administration services, local organizations, foundations and engages with
representatives of local communities on a regular basis. Through regular reporting, meetings, and participation in industry forums,
Alpha Bank S.A. ensures that its practices align with regulatory and market standards and frameworks and contribute positively to
the broader financial landscape.
Alpha Services and Holdings S.A., periodically, tries to identify, assess and prioritize the ESG issues which are related to its
activities and value chain, material impact or potential impact on people and the natural environment, through a materiality analysis
process, in accordance with the “GRI 3: Material Topics 2021”. This year, the Group revisited the Materiality Analysis performed in
the previous financial year, re-identified and re-assessed the topics, in consultation with internal stakeholders and experts, through
the following process:
Understand the organization’s context
• Review of the 2022 list of identified impacts to people/stakeholders and to the natural environment through its own
operations, supply chain and financial products and services.
• Media, Peer & Standards review in order to identify any additional impacts to people/stakeholders and to the natural
environment related to its business model and value chain.
Actual and potential impacts re-identification
• Actual impacts, either positive or negative, to the natural environment and people, including impacts on human rights,
across the organization’s activities and business relationships were re-validated taking into consideration new impacts
identified through peer and reporting Standards’ review. Potential impacts were re-identified with the consultation of
internal stakeholders. The new list of identified impacts included in-house impacts across the Bank’s operations and
its supply chain, and financed impacts (i.e., impacts associated with Bank’s financial products and services).
Re-assessment of the significance of the impacts
• The re-assessment of impacts was based on a qualitative analysis by the Bank’s ESG Working Group, through a
dedicated electronic survey (e-survey) tool. Impacts were assessed in accordance to their severity/significance for the
short-term, mid-term and long-term time horizon and, in case of any additional potential impacts, their probability of
occurrence was taken into account considering how likely is the impact to be realized in the defined time horizon.
Prioritize the most significant impacts
• The prioritization was based on the results of the e-survey assessment, via which the significance of the impacts was
determined, and thresholds set to determine which positive and negative impacts will be material to the organization’s
operations, strategy and disclosures. The final list of material impact areas was debated by a dedicated working
group, comprised of executives from Governance & Sustainability Division, Strategy & Investments, Digital,
Transformation Office, Compliance, Wholesale and Retail Banking, Climate & ESG Risk and HR.
The material impact areas, identified, prioritized and validated are the following
1
:
• Climate Stability (Impact on climate mitigation, through financial products/services, Impact on climate mitigation, through
own operations (including CSR) and supply chain activities (GHG emissions from own operations and supply chain),
Impact on climate adaptation, through own operations (including CSR) and supply chain activities, Impact on climate
adaptation, through financial products/services
2
).
• Data privacy, Connectivity, Information (Impact on customers, through information-related topics (data privacy, freedom
of expression, access to (quality) information, connectivity)).
• Employment (Impact to employees, through employment practices for own workforce and supply chain (secure
employment, working time, adequate wages, social dialogue, freedom of association, collective bargaining, work-life
balance, health and safety)).
1
Impact areas are presented in prioritization order, considering the maximum score of impacts included in the specific impact area
2
The underlined text refers to potential impact
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40 | ANNUAL FINANCIAL REPORT
• Access to Finance (Impact on customers, through financial access and inclusion (i.e., remote locations, elderly, youth,
women, physical accessibility))
• Biodiversity (Impact on water and marine resources, through financial products/services, Impact on biodiversity and
ecosystems, through financial products/services).
• Socio-economic value creation through financial products/services (Impact on customers and broader
society/economy, through financial products/services for socioeconomic value (i.e., induced employment, access to
housing, education, mobility, energy, healthcare, diversity & inclusion, innovation, culture and heritage, infrastructure,
food, water)).
• Equal treatment and opportunities for all (own workforce & workers in the value chain) (Impact on employees,
through equal treatment and opportunities for workers at own operations and supply chain (gender equality and equal pay
for work of equal value, training and skills development, employment and inclusion of persons with disabilities measures
against violence and harassment in the workplace, diversity)).
• Pollution prevention and control (Impact on pollution prevention and control, through financial products/services).
• Circularity (Impact on circularity (resources & waste), through financial products/services).
• Cultural Heritage (Impact on local and broader community, through CSR programs for social value (i.e., education,
culture and heritage)).
ESG RISK CONSIDERATIONS
In light of the double materiality concept, derived from the latest version of the European Sustainability Reporting Standards (ESRS)
adopted by the European Commission (C(2023) 5303 final/31.07.2023), the Bank has already adopted a proactive approach to
managing ESG risks, with particular emphasis on risks arising from climate change as a key component of its Risk Management
Strategy. In this direction, the Bank has implemented a Risk materiality assessment and an internal operational risk assessment,
which will enable further the identification and integration of ESG-related risks and opportunities which arise from its external
environment causing process disruptions, litigation/liability issues and reputational damage which relate to material financial
implications into its comprehensive Risk Management Framework. The materiality risk assessment incorporated also the Bank’s
exposures which are sensitive to ESG factors as a percentage (%) of total assets per total loan portfolio, as described in the respective
section of this report.
More specifically, the Bank’s activities related to ESG risk considerations are outlined in the Environment section and specifically
“Climate Related Risks Materiality assessment” section of this report.
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41 | ANNUAL FINANCIAL REPORT
OPERATIONAL RISK MATERIALITY ASSESSMENT
The Bank has enhanced, in 2023, its Operational Risk Management Framework components to incorporate and manage ESG
factors in Operational Risk:
1. Risk Taxonomy: The Bank has updated its Risk Taxonomy to include the E, S and G flags which will be used to
capture and monitor environmental, social and governance factors.
2. Loss Events Management: ESG related Loss Events are identified and managed as required.
3. Risk and Control Self-Assessment (RCSA): Potential risks and controls related to environmental, social and
governance risks are identified and assessed in the context of the RCSA Process.
4. Scenario analysis: ESG related scenarios are identified and assessed annually.
5. Key Risk Indicators (KRIs): KRIs have been set for monitoring ESG risk exposures.
6. Outsourcing Risk Assessment: The Bank’s Vendor Risk Assessment Questionnaire has been enhanced to
incorporate questions regarding ESG Risk factors that might affect vendors' operations and consequently the services
offered to the Bank.
7. Lawsuits Management: In particular for legal risk, the Bank has introduced enhancements to better identify, manage,
mitigate and monitor legal risk driven from ESG-related factors.
8. Reputational Risk: The Bank has developed the Reputational Risk Policy which sets the principles, processes and
structures for managing risk exposures that may have impact on its reputation, including ESG related factors.
Although historical data do not reflect material losses from ESG-related events, the Bank introduced the aforementioned
enhancements to better manage, monitor and mitigate ESG-related risks effectively, acknowledging that there are potentially
material ESG factors that could drive operational risk in the future. This is mostly based on a conservative forward-looking view (i.e
future ESG-related losses may be greater compared to historical ones), as well as the fact that such events may have material
reputational impact in the future, due to the shifting expectations of customers and the broader society around ESG matters.
The ESG factors may have impact to the following Operational Risk Categories:
• Physical damage and disruption
• Conduct Risk
• Compliance Risk
• Financial Crime risk
• Fraud Risk
• Outsourcing Risk
• Legal Risk
• Reputational Risk
The Bank is in the process of setting its targets related to climate and the environment. In this direction, it prioritizes the financing of
sustainable activities, exploring the physical or transition risks deriving from climate change and the environment and focusing on
specific sectors that may impact financially its own activities. By prioritizing the financing of green activities, the Bank aims to constitute
an enabler for the transition of the country to a more sustainable economy.
SUSTAINABILITY STRATEGY
The Group is committed to operating responsibly and creating long- term value for its Stakeholders by taking into account the
economic, social and environmental parameters of its operations in Greece and in the other countries where it has presence. In the
global effort to build a sustainable future for the economy and the planet, the Bank signed the six Principles for Responsible
Banking in 2019, which were developed as an international initiative of the United Nations – Environment Programme Finance
Initiative (UNEP FI). A year earlier, in 2018, and Alpha Asset Management M.F.M.C. became a signatory of the Principles for
Responsible Investment (PRI) Initiative. For the purpose of implementing the Principles, Alpha Services and Holdings S.A. has
already submitted three self- assessment reports, while in 2022, a new dedicated portfolio alignment analysis has been conducted,
in accordance with the UNEP FI Principles for Responsible Banking (PRB) Impact Analysis, using the Portfolio Impact Analysis
Tool for Banks (version 3). Positive and negative impacts that the Bank generates through its institutional and consumer banking
portfolios, were assessed and mapped against the impact areas and topics of the revised Impact Radar (June 2022). The Bank
identified positive and negative associations between its portfolio and the 23 environmental, economic and social areas defined by
the UNEP FI Principles for Responsible Banking (PRB). The Bank is in progress of enhancing its impact analysis to include data
from the Group’s key subsidiaries. In this direction, the Bank implemented in 2023 an Impact Analysis for its institutional and
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42 | ANNUAL FINANCIAL REPORT
consumer banking portfolios in Cyprus. Based on the results of the PRB impact analysis, during 2023, the Group redefined its
Sustainability Strategy and set ambitious targets, in order to be able to support the change towards a sustainable economy. The
Strategy is defined around the three ESG pillars:
Support an environmentally sustainable economy:
In order to support an environmentally sustainable economy and mitigate climate change, the Group’s main objective is the
increase in Sustainable Financings and the reduction of financings that may have a negative impact on the environment. The
biggest challenge, towards this direction, however, is our ambition to achieve Net Zero greenhouse gas emissions by 2050.
In order to define the medium to long-term part of its Sustainability Strategy, the Bank completed an initial measurement of
financed emissions, with FY 2021 client data (the latest available at the time), which was disclosed in its 2022 TCFD report. It
has also begun to analyze its major clients in key sectors such as energy, reviewing their emissions, sustainability
performance, targets and commitments, in order to consider their likely trajectories and potential climate risk.
The Bank has also completed a 2nd measurement of Financed Emissions with FY 2022 client data. This is intended to serve
as a baseline for the next step in the Bank's strategy which is to set Science Based Targets to align its portfolio with the Paris
Objectives and to define a set of Business Plan targets to underpin those. This work will take place during 2024, with SBT's to be
disclosed by the end of the year, as part of the commitment to NZBA, while associated lending volume targets will be
incorporated in the next review of the Business Plan.
These targets will be monitored, reviewed and assessed regularly along with the progress against them, to ensure consistency with
the Bank's strategy and relevant policies.
Currently, Alpha Services and Holdings S.A.’ ambition to support a net zero carbon and nature positive economy, is reflected by the
following targets:
Matters
according to Law
4548/2018 and
GEMI Circular
62784/2017
Commitments
Targets
Target Year
Environment
Support our customers’
decarbonization and align our
portfolio emissions with the
objectives set in the Paris
Agreement
Targets supporting transition Trajectories
Allocate Euro 3 billion to new Sustainable
Financings by 2025
3
2025
Within the total Sustainable Financings,
achieve at least Euro 1 billion to Renewable
Energy Systems by 2025
4
2025
Within the total Sustainable Financings,
achieve at least Euro 300 million of Retail
green loans, including loans to small
businesses
4
2025
Launch new sustainability-based mortgage and
consumer loan products and credit cards
4
2025
GHG Emission Reduction Targets
Zero financing to new investments in thermal
coal mining, upstream oil exploration or coal-
fired electricity generation
4
Ongoing as of
2023
3
Targets related to scope 3 financed emissions.
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43 | ANNUAL FINANCIAL REPORT
Support the transition to a circular
economy
Reduction of annual internal paper usage rate
by 50% by the end of 2025 (compared to
2019)
4
2025
Achieve Net Zero emissions in our
own operations
Reduction of our operating footprint and setting
Net-Zero targets within 2023
5
2023 (on track)
Reduction of scope 1 and 2 GHG emissions by
20% until 2025
5
(compared to 2019)
2025
Upgrading lighting to LED lighting throughout
the network
5
2028
Continue to procure 100% renewable electricity
for all our buildings and Branches
5
2023 (on track)
Replacement of 70 % of the Bank’s fleet with
electric and/or plug-in and hybrid vehicles.
5
2025
Mitigate Key drivers of biodiversity
loss
Zero financing to targeted activities harming
species diversity, habitats and waterbodies
Ongoing as of
2023
Foster Healthy economies and societal progress:
In order to foster healthy economies and societal progress, the Group is committed to provide a safe and inclusive work
environment for all Employees, while safeguarding society’s access to finance as well as to healthcare services and cultural
heritage.
Matters
according to Law 4548/2018
and GEMI Circular
62784/2017
Commitments
Targets
Target Date
Enhance people’s
financial health
through inclusive
access to financing
Increase employment of young
people (18-25 years old) by 20% by
2025 (compared to 2019)
2025
Social and Employee
Matters
Support financial inclusion through
educational programs addressed to
teachers, students and people over
55
Ongoing as of 2023
Increase access to people with
mobility limitations to 85% of our
Branches by 2025
2025
Provide an inclusive
and safe work
environment
Provide a safe and inclusive work
environment
Annual
4
Targets related to Scope 1&2 emissions
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Maintain >40% women
representation in Managerial
positions
Annual
Support inclusivity
and access to
Healthcare,
Education, Culture
and Heritage
Support equal access to culture for
people with disabilities, cognitive
impairment, the elderly and children
in remote areas
Ongoing as of 2023
Limited financing to activities that can
affect health and well-being, including
gambling, tobacco and alcohol
Ongoing as of 2023
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Ensure robust and transparent governance:
In order to ensure robust and transparent governance, the Group engages on a regular basis with its Stakeholders and is
committed to providing them with transparent and material information, while also safeguarding any internal risk controls and
business ethics, all supported by a diverse Board of Directors with a majority of Independent Non- Executive Members.
Matters
according to Law
4548/2018 and
GEMI Circular
62784/2017
Commitments
Targets
Target Date
Respect of Human
Rights
Enhance transparency
and safeguard
business ethics
• Safeguard internal risk
controls that protect the
Customers’ data
• A majority of Independent
Members in the Board of
Directors and its
Committees
• Increase material
information disclosure to all
Stakeholders
• Proactive engagement with
Investors and Stakeholders
to align priorities
• Incorporate ESG criteria in
our Remuneration and Risk
Management frameworks
2023
Anti-Corruption
and Bribery
Supply Chain
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In the following pages the primary potential risks for the five areas (environment, social and employee matters, human rights, anti-
corruption and bribery and supply chain) specified by the Greek Law 4548/2018 and the General Electronic Commercial Registry’s
Circular 62784/2017 are presented along with an outline of Alpha Services and Holdings S.A.’ s management approach.
ENVIRONMENT
Theoretically Potential Risks*
Alpha Services and Holdings S.A.’ s identified environmental risks include:
• Inability to integrate environmental criteria into the design of new products and services (e.g. products with positive
environmental impacts), to offer environmentally responsible investments, and to participate in the financing of projects
with positive effects on the environment.
• Failure to assess environmental risks in customer and project finance, including inadequate monitoring of risk
management during the implementation of the financed projects. Refraining from addressing risks presented by climate
change to businesses, such as the impact of more extreme weather events. Increased costs from additional due diligence
required, when applying minimum ESG standards.
• Failure to meet new requirements (e.g. TCFD, MiFID II, guidelines on non-financial reporting, European Banking Authority
(EBA) guidelines on green lending, European Central Bank (ECB) guidelines on climate-related and environmental risks,
EU Taxonomy, UNEP FI Principles for Responsible Banking, UN PRI Principles for Responsible Investment etc.).
• Inability to offer environmentally responsible investments. Miss the opportunity to offer new investment opportunities with
better performance.
• Increased risk of damage to the Bank's infrastructure due to increased frequency and intensity of extreme weather events.
• Increased energy use (e.g. from Βank branches, buildings and data centers and consumption during transport and
distribution of mail, information material, employee transportation etc.).
• Increased environmental footprint from operations (e.g. paper consumption, water consumption, insufficient management
of hazardous waste, failure to adopt circular economy principles).
• Increased reputational risk exposure for the Bank due to financing customers that do not meet certain environmental
standards and their activities have negative effects on the environment.
* The Theoretically Potential Risks have been evaluated in the context of the Materiality Assessment and those deemed relevant
have been incorporated in the Materiality Matrix.
Alpha Services and Holdings S.A.’ Management
Operational Activities targeting Climate Change:
The Group has developed policies and procedures in order to reduce the operational environmental footprint with the overarching
aim of Net Zero and to strengthen its commitments associated with this objective.
The Bank monitors its environmental impacts related to its operation and aims to reduce its environmental footprint by promoting
the rational use of lighting, heating and cooling installations in its buildings, the use of environment-friendly class A++ or higher
energy efficiency equipment as well as distance training, by implementing initiatives for the efficient use of raw and other materials
and by applying the “reduce, reuse, recycle” principles of circular economy in the waste management. Indicatively, the Bank
recycles paper, batteries, light bulbs, printer consumables, electric and electronic equipment, and donates old office equipment. It
should also be noted, that Alpha Bank S.A. (and any co-located subsidiaries) maintains an 100% supply of electricity from
renewable sources, with certificate of origin The Bank’s Environmental Policy and procedures according to the requirements of ISO
14001 Environmental Management System, improve the management of these issues. Through these procedures, the Bank
identifies and assesses known and potential environmental risks and opportunities in a more formal and detailed way. Furthermore,
the Bank organizes, supports and participates in environmental actions to cultivate the ecological conscience of its Employees and
their families and to improve the quality of the environment. More information on the Bank’s operational environmental footprint and
certifications, can be found in Alpha Services and Holdings S.A. Sustainability Report 2022.
Sustainable Finance:
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Raising awareness on environmental issues and protecting the environment are at the core of our sustainability approach. To
support an environmentally sustainable economy and mitigate climate change, the Group’s actions focus on the increase in
Sustainable Financings and the reduction of financings that may have a negative impact on the environment.
In this context, the Bank is implementing commercial initiatives to identify sustainable financing opportunities and establish the
Bank’s position in both the Wholesale and Retail banking markets. These initiatives aim to assess customers’ level of ESG maturity
and potential transition pathways, in order to help develop financing solutions to serve their sustainability needs. To achieve this,
the Bank has developed the Sustainable Finance Framework (SFF) in accordance with market best practices requirements
reflected in the principles established by the International Capital Market Association and the Loan Market Association. The
Framework also incorporates the EU Taxonomy Regulation on economic activities that significantly contribute to climate mitigation
or climate adaptation. The Framework defines in detail the criteria and process to classify financial products and services as
sustainable covering both dedicated and general-purpose financing.
The Framework identifies green eligible activities grouped into the themes of Energy Efficiency, Renewable Energy, Sustainable
Transport, Resource Efficiency & Pollution Control and Green Buildings for sustainable financing. In addition, social eligible
activities are grouped into the themes of Economic Inclusion, Access to Essential Services, Affordable Basic Infrastructure and
Affordable Housing.
In 2023, the Bank prioritised the operationalisation of the Sustainable Finance Framework to support its commitment to sustainable
lending activities. The Bank follows a multi-step assessment process at the client and transaction level. The ESG performance of
the client is first assessed against qualitative and quantitative factors and the transaction or potential projects are screened against
the Framework’s eligible theme categories and criteria. The transactions that are identified to meet the relevant sustainability
criteria outlined in the Framework are classified as sustainable financing. The Bank has put in place the SFF governance model to
ensure a robust decision process encompassing all relevant divisions and lines of defence.
An external review of the Framework was conducted by an independent third party to validate the environmental and social
credentials for positive contribution to the UN Sustainable Development Goals (SDGs) and to demonstrate its credibility as a tool
for capital allocation decisions.
To build ESG awareness and build internal capacity to address ESG business challenges, an ESG Academy has been launched
that provides a multi-year dedicated training plan for all employees. This enables the Bank’s employees to understand the evolving
sustainability landscape and stakeholder expectations, which is key requirement for the Bank’s sustainability journey. In 2023 more
than 4.500 enrollments in courses relating to ESG were completed. Also more than 80% of the Bank’s employees in Wholesale
Banking Business completed tailored training programs which focused on embedding the ESG principles in the way work is
completed while adapting to a sustainable finance mindset. Additionally. More than 90% of the Bank’s Risk Control Areas,
completed a dedicated course on ESG Risk Management.
It should be noted that the Bank’s Project Finance Unit works on securing financing for investments in projects aiming at benefiting
environment while undergoing a due diligence process to safeguard against possible negative impacts. In 2023, the Project
Finance Unit continued its successful activity, providing financing for new investments in wind farms, solar parks and green-certified
buildings, while it also undertook or participated in new financing arrangements. Τhe Bank is also monitoring opportunities related
to climate change and energy transition that may arise from its external environment, which include investments in RES Projects
through the Project Finance Unit, as well.”
Climate Related Risks Materiality assessment
The Group adopts a proactive approach to the management of Environmental, Social and Governance (ESG) risks, with particular
emphasis on risks arising from climate and environmental change, which is already a key component of its Risk Management
Strategy.
Following the recommendations of the Task Force on Climate-related Financial Disclosures (“TCFD”), the Bank assesses current
and upcoming environmental policies, legal requirements and regulatory guidelines relating to climate and the environment, in
order to record and efficiently manage any transitional and physical risks related to its activities. In this context, the Group has
developed a comprehensive action plan, submitted to the European Central Bank (ECB) in May 2021, in which it presented how
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the climate risk assessment would be incorporated in its operations and in the risk management process. The implementation of
the plan began in June 2021, continued throughout 2022 and was further enhanced, taking into consideration the feedback
provided by the Single Supervisory Mechanism (SSM) in the context of the Climate Stress Test, conducted in January 2022, and
the Thematic Review of Climate-related and Environmental Risk Strategies, Governance and Risk Management Frameworks,
conducted in June 2022. Leveraging on the work already performed in 2022 the Bank has proceeded with targeted enhancements
during 2023 in accordance with the Group’s plan commitments The plan aims not only to align with Stakeholders’ expectations and
ensure the Bank’s long- term sustainability, but also to manage any potential ESG risks.
Acknowledging the relevance and potential impact of the risks stemming from climate and environmental related factors, and
especially climate change, and as part of its plan and in alignment with the respective external guidelines, the Bank has elaborated
further on the ESG incorporation into the risk identification and materiality assessment processes and in the overall risk
management framework, and is committed to monitoring, assessing and managing these risks going forward. More specifically, in
2023 the following activities have been performed:
•
The Bank updated its Risk Inventory in order to include the dimension of climate-related risks in the Bank’s Risk Registry.
The main climate-risk transmission channels in the area of risk management include transition risk (e.g. the risk of any
negative financial impact on the institution, stemming from the current or from prospective impacts of the transition to an
environmentally-sustainable economy on its counterparties or its invested assets) physical risk (e.g. the risk of any
negative financial impact on the institution, stemming from the current or prospective impacts of the physical effects of
environmental factors on its counterparties or its invested assets) and other social and environmental risk aspects.
•
The Bank has enhanced its credit policy to incorporate the ESG obligor, transaction and overall (combination of obligor
and transaction) assessment, into its credit approval process. The Bank conducted a materiality assessment analysis to
identify the risk categories that are most vulnerable to climate and other environmental risks. In alignment with the
guidance across different sources [e.g. ECB, European Banking Authority (EBA), European Commission], the Bank
considers Climate and Environmental risks as a theme, i.e. as a transversal risk, incorporating such factors as drivers of
existing financial and non-financial risk categories in its risk management framework. Consequently, the materiality
assessment covered all key risk aspects (i.e. Credit Risk/Operational Risk/Market Risk/Liquidity Risk/Reputational Risk
and Business/Strategic Risk). The Bank is currently working towards enhancing this materiality assessment by
incorporating additional dimensions.
More specifically, the outcome of the materiality assessment for each risk category is outlined as follows:
•
The credit risk is perceived to be materially affected by ESG factors, given the Bank’s sizeable loan portfolio and
exposures to sectors commonly perceived as sensitive to climate-related risks. More specifically,
•
The Bank regularly conducts a transition risk materiality assessment in its Non-Financial Corporations (NFC) portfolio
based on the Climate Policy Relevant Sectors (CPRS) perimeter, to identify its exposure per sector and the allocation
of the portfolio to potentially high transition risk categories. The Bank is working towards incorporating additional
dimensions in the materiality assessment, such as GHG absolute emissions, emissions’ intensity and the level of
maturity of sectoral transition pathways. In this context, the Bank is planning to update in the first quarter of 2024 the
transition risk materiality assessment, including different time horizons in alignment with European Sustainability
Reporting Standards (ESRS). Beyond the materiality assessment conducted in its NFC portfolio, the Bank recognizes
the materiality of Climate and Environmental (C&E) risks in its retail portfolio, in terms of the energy efficiency of real
estate collateral held by the Bank. In this context, the Bank has incorporated in its credit decision making process the
Energy Performance Certificate (EPC). In parallel, the Bank has developed a model in order to evaluate proxies for
the energy efficiency score and the EPC label, that enabled the distribution of energy efficiency score bands and EPC
label of the real estate properties included in the Bank’s portfolio (as real estate owned assets) or used as collateral
on existing assets. Using this model, the Bank was able to derive an estimate of its EPC distribution across the above
/perimeter of real estate properties.
•
Regarding physical risk, the Bank regularly conducts a materiality assessment for physical risks in its loan portfolio.
The Bank has laid down a methodology based on sensitivity and exposure analysis to derive vulnerability to physical
risk factors. The vulnerability assessment aims to identify potential significant hazards and related risks and forms the
basis for the decision to continue the risk assessment, while it is aligned with the Invest EU methodology “Technical
guidance on the climate proofing of infrastructure in the period 2021-2027” and with the “ECB: Good practices for
climate related and environmental risk management: Observations from the 2022 thematic review”. The analysis is
applied to the Corporate portfolio per NACE sector (22 NACE codes) at a country level, while for exposures covered
by real estate collateral the analysis is applied per climate zone at a regional level, based on the location of the real
estate property. The vulnerability analysis combines the outcome of the sensitivity analysis and the exposure
analysis, categorizing physical climate risk as High, Medium or Low Risk. The Bank is working towards performing a
more granular sensitivity analysis, focusing on selected key subsectors. This analysis will examine various operation
components within each subsector and their susceptibility to selected climate physical events, considering their
broader impact on the network or system. The Bank also plans to analyze further climate hazards that buildings are
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sensitive to (e.g., sea level rise, soil & coastal erosion, wildfires, storms and floods as identified in the existing Bank’s
ESG materiality assessment) and provide NUTS3-level outcomes in terms of High / Medium / Low exposure levels,
leveraging relevant hazard maps for Greece. In line with transition risk, the Bank is working on updating the physical
risk materiality assessment (in both analyses presented above) by the end of the first quarter of 2024, incorporating
different time horizons in alignment with European Sustainability Reporting Standards (ESRS).
•
Regarding Operational Risk, although historical data do not reflect material losses from ESG-related events, the Bank
introduced several enhancements to better manage, monitor and mitigate ESG-related risks, effectively acknowledging
that there are potentially material ESG factors that could drive operational risk in the future. This is mostly based on a
conservative forward-looking view (i.e. future ESG-related losses may be greater compared to historical ones) as well as
on the fact that such events may have material reputational impact in the future, due to the shifting expectations of the
Customers and the society as a whole regarding ESG issues. Especially regarding legal risk, the Bank has introduced
enhancements to better identify, manage, mitigate and monitor legal risk driven by ESG-related factors. Emphasis is
placed on ESG-related legal risk due to customer and third-party controversial activities (through enhancements on the
obligor assessment process) as well as due to internal processes that are being established to prevent greenwashing
going forward (through the introduction of internal controls regarding the identification and the tagging of sustainable
finance exposures). More specifically, the Operational Risk Platform (Archer) has been enhanced incorporating a flag for
the classification of ESG Risk lawsuits and all labor lawsuits that have already been classified as “Social Risk related”. As
far as the commercial lawsuits are concerned, a mechanism will be initiated from 1/1/2024 in cooperation with the Civil,
Administrative, Criminal Law Disputes and NPEs’ Legal Support”/, identify, flag and report accordingly, relevant cases.
•
With respect to market risk, based on the materiality assessment of the Bank’s bond portfolio following the Climate Policy
Relevant Sectors (CPRS) methodology, taking also into consideration the average residual maturity of the ESG-sensitive
perimeter in order to identify the portfolio’s sensitivity to environmental risks that are expected to materialize in long-term
horizons, there is limited potential effect from climate-related and other ESG factors. The Bank has also proceeded to a
materiality assessment of Physical Risk for the Corporate Portfolio. The Bank’s exposure to physical risk can be
considered minimal or immaterial due to its minor size. The Bank is working to update the materiality assessment.
•
In terms of liquidity risk materiality, there seems to be no material effect from climate-related and other ESG factors. On
the asset liquidity side, this is driven by the composition of the buffer, mainly consisting of sovereign rather than corporate
bonds, which are considered to be immaterially impacted by ESG factors, as described in the market risk above. On the
funding side, deposits constitute the main funding source, mostly consisting of retail Customers, thus corporate Customers
constitute a relatively smaller part of the Bank’s funding position, limiting the exposure to ESG risks. The Bank aims to
incorporate a physical risk assessment in its liquidity risk materiality assessment by the end of the first quarter of 2024.
This entails evaluating the vulnerability of deposits (stemming from NFC and Individual portfolios) to acute climate risk
events based on NACE Sectors and the locations of the Obligors locations, respectively.
•
Reputational risk is generally considered to arise as a result of the manifestation of other risk types (i.e. a second-order
impact), while it could also give rise to other risk types subsequently (e.g. liquidity outflows, following a reputational
impact). In that sense, a separate evaluation of the materiality of ESG-related drivers is not required. To mitigate
reputational risk, the Bank has designed a robust process that involves identifying and assessing the potential participation
of its Obligors in controversial activities. The materiality assessment for other risk types suffices to cover potential one-off
(acute) events with reputational repercussions (e.g. within operational risk) as well as longer-term brand value impacts that
could arise in the context of Strategic Risk.
•
Business and Strategic Risk includes the risk of potential (internal or external) adverse events that negatively affect an
institution’s ability to achieve its objectives and, consequently, it has a negative effect on earnings (profit and loss account)
and, through the latter, on solvency. Strategic risk can be defined as the impact on capital, arising from adverse business
decisions, improper implementation of those decisions or lack of responsiveness to political, fiscal, regulatory, economic,
cultural, market or industry changes. The relevance of ESG factors in Business and Strategic Risk is reflected through the
failure to account for rising ESG factors, considering both idiosyncratic (strategic) and systemic (business) components .In
this context, the Bank acknowledges that ESG factors could have a significant impact from a Business and Strategic Risk
perspective, recognizing as key drivers the potential shift in consumer preferences, behavioral/demand patterns, the
market sentiment and the potential change in the competitive landscape, which could result to loss of the Bank’s market
share and affect its revenue and profitability, due to ESG considerations. The impact that ESG factors can have on
Business and Strategic Risk is also highlighted by the fact that they can lead to significant reputational risk, as a second-
order effect, in terms of a long-term impact on the Bank’s brand and reputation (e.g. the Bank gradually lagging in terms of
strategy and brand in ESG-related issues, compared to its peers). The impact of the Bank’s financing activity and overall
strategic direction on the environment is often subject to public scrutiny and, hence, associated with reputational
considerations. With respect to other environmental factors, from an inherent risk perspective, the Bank considers these
to be material, due to the size and sectoral allocation of its Non-Financial Corporate Loan portfolio. The Bank has
established the following dedicated processes to identify and mitigate risks associated with other environmental factors
during credit origination: a) Exclusion List, b) ESG Obligor Assessment Questionnaires and c) Transaction Assessment
and Due Diligence process. The aforementioned processes have been developed in alignment with international
standards and enable the Bank to mitigate ex ante environmental and/or social risks within its portfolio. Considering the
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effect of those processes, the residual risks associated with those environmental and social risk factors are considered
immaterial on a portfolio basis.
• Exclusion List: The Bank applies, maintains and updates an exclusion list that determines specific activities
which are not allowed to be financed. The criteria for exclusion span across various environmental and social
matters. Some indicative examples which include enhancements performed by the Bank by the end of 2023,
involve:
•
The keeping of animals for the primary purpose of fur production or any activities involving fur
production. (relates to biodiversity).
•
The export of mercury and mercury compounds, and the manufacture, export and import of a large
range of mercury added products. (relates to pollution)
•
Activities prohibited by host country legislation or international conventions relating to the protection of
biodiversity resources or cultural heritage. (relates to biodiversity)
•
Any activity involving degradation, conversion or destruction of the UNESCO World Heritage Sites.
(relates to biodiversity)
•
Any activity involving significant degradation, conversion or destruction of the sites included in the
Natura map. (relates to biodiversity)
•
Shipping oil or other hazardous substances in single hull tankers or tankers not compliant with IMO
requirements.( relates to pollution / water & effluents)
•
Production of or trade in persistent organic pollutants. (relates to pollution)
•
Production of or trade in wildlife products regulated under CITES. (relates to biodiversity)
In 2023, there were no cases of non-approval of credits due to issues arising during the assessment of environmental and
social risks. From 1.1.2024 the Bank implemented an enhanced Exclusion List. Among the new activities added to it are
the following: "Any activity involving significant degradation, conversion or destruction of the areas included in the Natura
map", "Wholesale and retail trade of thermal coal" and "Conversion of natural forests to plantations".
It should be noted that the Group also considers climate risks related information in the collateral valuation, i.e. the
outcome of the Energy Performance Certificate. Climate-related risks are also considered in the Market Value
determination of the understudy properties by establishing adjustments on the unit values provided by the appraisers.
For new collaterals eligible for EPC has been collected during the valuation process, it is taken into consideration. Regarding
transition risk, the market value of the collaterals is going to be furtherly enhanced through the EPC model output as well as
through the collection of the EPC assessments. With regards to the physical risk, the institution identifies and therefore considers
climate-risk related information on the physical risks in the process of the collateral valuation, and explicitly mentions the existence
of a potential risk. It is expected that during 2025 the International Valuation standards will be updated providing guiding notes on
the assessment of C&E risks and, subsequently, the institution will incorporate the guidance - to a certain extent - in its valuation
manual.
•
ESG Assessment: The ESG assessment is carried out at obligor, transaction and overall assessment level
(combination of obligor and transaction). In particular:
•
ESG Obligor Assessment: Taking into account that environmental and social risk factors may be, to a
significant extent, company-specific and also the fact that not all companies are equally successful in
managing environmental, social and governance-related topics that are relevant to their business
models, the Bank is currently rolling out a bottom-up process, at obligor level, which is used to evaluate
the performance of each obligor around such topics and better inform the credit origination processes in
place. This ESG Obligor Assessment process embeds a materiality assessment, through which the
Bank concluded into the environmental and social topics for several economic sectors in its portfolio.
More specifically, for obligors falling within the ESG-sensitive perimeter, obligor-level assessment
questionnaires have been developed, aiming at collecting data and assessing the borrowers in terms of
ESG criteria. Regarding the non-ESG-sensitive perimeter, a sector-agnostic assessment is applied,
considering fundamental aspects of ESG criteria that are common across all sectors. The set of these
questionnaires is available for completion on the "esgr" platform of Tiresias. Through the questionnaires
climate-related information is captured (e.g. emissions data, energy consumption data etc.). The
interbank ESG obligor questionnaires are integrated in client onboarding and due diligence process
during loan origination and ESG aspects of obligors are assessed through the internal scorecards.
Taking into consideration the scoring (High, Medium, Low), which is obtained from the ESG Obligor
Assessment questionnaire, the Bank sets mitigation actions in several processes, e.g., a corrective
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action plan with a specific implementation schedule is jointly agreed with the customer in case of High-
risk outcome.
•
ESG Transaction Assessment and Due diligence process: The ESG assessment at transaction level
concerns the activity for which the client is applying or has received financing based on the information
provided during the preparation of the credit request. The outcome of this assessment may be
"sustainable" or "non-sustainable” financing. Sustainable financings are further divided into aligned or
not aligned with the EU Taxonomy. Νon-sustainable financings are classified as Low, Medium, or High
ESG risk. To evaluate each requested transaction, specific criteria have been developed, on top of the
assessment at obligor level, including the alignment with specific criteria, as defined on the Group’s
Sustainable Finance Framework, in order to identify and capture sustainable activities, as well as
transaction-specific characteristics. In case the transaction is non-sustainable Medium or High Risk and
the request under consideration concerns new specific purpose financing of an investment nature (e.g.
project financing), an ESG due diligence (i.e. on site visit by specialized technical advisors) is carried out
and a respective plan of corrective actions is drawn up with a specific implementation schedule on
behalf of the customer if needed. Following the disbursement of credit, adherence to environmental
terms and commitments is obligatory, throughout the long duration of the said financing. The overall
ESG assessment is a combination of the ESG assessment at obligor and transaction level and is
captured per transaction. The outcome of this assessment may be Low, Medium or Increased ESG
Impact.
In addition, regarding other environmental and social related risks, the Bank will take into consideration additional information from
various commonly used benchmarks, e.g., the UNEP FI Portfolio Impact Analysis Tool, in order to enhance the relationship
between specific activities/ NACE codes with negative impact on the other environmental factors (covering factors such as
management of water resources, Impact on Biodiversity, Soil degradation, Air quality, and management of resources and waste).
To address the aforementioned risks, the Bank has deployed a comprehensive strategic plan by carrying out the following
actions:
a) Performing an impact analysis of its loan portfolio by utilizing the UNEP FI Principles for Responsible
Banking (PRB) Tool and by conducting a Global Reporting Initiative (GRI) materiality analysis, in order to
understand the positive and the negative socioeconomic, environmental and social impacts of its portfolio.
b) Regularly monitoring of ESG Key Performance Indicators (KPIs),such as % of disbursements to RES over
total disbursements to the energy sector, the gross disbursements aligned with the Sustainable Finance
Framework etc., in order to take corrective action, when needed.
c) Furthermore, the Bank has enhanced its Risk and Capital Strategy (RCS) document by incorporating
additional quantitative monitoring ESG indicators covering business planning and green financing,
collateral vulnerability to physical & transition risk, financial activity vulnerability to physical risk, sustainable
investing and social related risk (HR).
d) Is in the process of developing science-based, sector-specific targets around its financed emissions, in
alignment with the Paris Agreement on climate change and the net zero emissions target for 2050.
e) Is in the process of developing short-, medium- and long-term targets until 2050, to incorporate the short-
term transition pathway into its three-year Business Plan.
In addition, the Group has already enhanced its Risk Appetite Framework (RAF) with additional qualitative commitments as well as
quantitative indicators regarding ESG risks.
Specifically:
▪ The Bank regularly monitors its exposure concentration in climate-sensitive sectors in its loan portfolio, also
introducing a credit concentration risk indicator within the Risk Appetite Framework.
▪ The Group has enhanced its due diligence process with respect to the assessment of its Customers’ ESG/climate
risk profile, through the collection of relevant information.
▪ As of January 1, 2024, the Group has expanded its Exclusion List to encompass additional activities with
environmental and social impact.
▪ The Group has integrated information on the Energy Performance Certificate (EPC) of relevant real estate
properties within its credit decision making process as well as each collateral valuation subject to EPC eligibility.
ESG indicators covering business planning and green financing, collateral vulnerability to physical and transition
risk, financial activity vulnerability to physical risk, sustainable investing.
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Finally, the Loan Pricing Framework was updated in order to take into consideration the overall ESG assessment in the pricing of
new loan facilities. The overall ESG assessment is derived by combining the outcomes from ESG Obligor assessment that
examines quantitatively and qualitatively ESG aspects of obligors, as well through transaction assessment that examines the
characteristics of the loan to define whether it is sustainable or not (i.e., low, medium, or high risk).
Performance in 2022 and 2023
Indicators
Alpha Services and Holdings S.A.
Alpha Services and Holdings Group
Year
2022
2023
2022
2023
New Sustainable financing
volumes (disbursements)
throughout the year (total
amount in Euro)
-
800,191,309
8
-
843,194,101
8
Of which: New
financing volumes
(disbursements) to
renewable energy projects
throughout the year (total
amount in Euro)
-
431,838,942
•
433,610,776
New financing volumes to
Retails Green Loans,
including loans to small
Businesses
34.9
45.8
154.67
88.86
5
Amount of paper recycled
throughout the year
1
(total
amount in tons)
803
449
1,066
6
1,015
6
Number of Branches with
upgraded LED lighting
127
153
147
178
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53 | ANNUAL FINANCIAL REPORT
Electricity consumption
throughout the year (in
kWh)
2
39,260,930
7
34,485,732
52,741,574
7
,
39,266,382
Scope 1
2,665 21tn CO
2
e
1,166.37tn CO
2
e
2,786 tnCO
2
e
1,290.19 tnCO
2
e
Scope 2
21,849.942tnCO
2
e
3
18,418.7
3
tn CO
2
e
19,318 tnCO
2
e
21,346.5 tnCO
2
e
Scope 3-(excl, Cat15)
4
12,055 tnCO
2
e
To be reported in
the Sustainability
report 2023
92,625 tnCO
2
e
To be reported in the
Sustainability report 2023
Scope 3 (incl. Cat15)
4
44,971,606
tnCO
2
e
53,422,526 tnCO
2
e
With regards to Scope 3 emissions, it should be noted that:
1. 81.6% (26,826,318 tons) of financed emissions are due to a specific customer, with a significantly large carbon footprint, due to
the methodological peculiarities of measuring GHG emissions along its value chain, for its own business activity.
2. The Bank acknowledges that with the increase in demands for full carbon footprint measurements from its customers in the
coming years, the absolute values (absolute values in tnCO2e) of financed emissions for itself may be materially affected.
The Bank monitors performance separately at sector level and is in the process of climate targeting for important sectors in line with
the NZBA.
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54 | ANNUAL FINANCIAL REPORT
1
Amount of paper recycled (total amount in tons) as verified by the logistic partner. Recycled paper includes cut and uncut - mashed paper bank
documents. The amount of paper recycled is decreased compared to 2022, due to clearance that took place in 2022, in the context of the Bank’s
strategy for reduced paper use.
2
Alpha Services and Holdings S.A. Group calculates electricity consumption in all buildings, offices & branches. The total amount of electricity
consumption for 2023 is based on measurements taken at buildings, branches (network), empty properties & other facilities of the Bank as well as
the Group Companies that are co-located in these buildings in Greece’’. In order to calculate the electricity consumption, the following principles
were applied (where applicable & feasible):
- The Group Companies are included (e.g. co-housing in the same Buildings), as well as common areas, empty spaces, parking spaces and
secondary areas (e.g., due to building ownership or contractual agreements, etc.).
- Cases where the Bank is charged with its share of consumption, through the bills for shared consumption and maintenance expenses for the
respective buildings are included.
- Empty properties that the Bank owns or is responsible for the premises, are included.
- An estimate of the annual consumption of about 3%-5% of the total surface occupied by the Bank and the Group Companies included in the KPI,
for which data were not recorded, has also been included.
- For those areas for which no electricity bills have been received from the supplier, the consumption has been projected to cover the whole year.
- The electricity consumption of the Bank’s electric vehicles is not taken into account in the calculation of the consumption. This is applicable to the
following Group Companies: Alpha Bank S.A. S.A (main subsidiary Bank), Alpha Bank London, Alpha Bank Cyprus, Alpha Finance Investment
Services, Alpha Leasing, Alpha Asset Management, Alpha Astika Akinita, Alpha Supporting Services, Alpha Life Insurance Company, ABC Factors.
The year 2022, includes additionally the Alpha Bank Luxemburg, ARES Romania, ACAC, Leasing Romania and Alpha Bank Romania.
3
Scope 2 emissions for 2022 have been restated due to a change in the calculation methodology. Specifically, for the calculation of Scope 2 emissions,
the Ministry's proposal for the climate law has been used and instead of the NIR used in 2022, the DAPEEP 2022, was used. Following the previous
methodology for 2022, the emissions disclosed in NFR 2022 were 17,221.48.
4
According to the GHG Protocol Standard, Scope 3 emissions represent all indirect GHG emissions that occur in the value chain of a company. Scope
3 emissions are divided into upstream (related to purchased or acquired goods and services) and downstream emissions (related to sold goods and
services, with the latter being associated with the provision of capital or financing) and categorized into 15 distinct categories. Category 15 –
Investments accounts for equity investments, corporate debt holdings (such as bonds or loans), project finance and investments managed on behalf
of clients or services provided to clients. The calculation of indirect emissions was carried out on the basis of the methodologies described in the GHG
Protocol, which was developed in 2001 by the World Resources Institute and the World Business Council for Sustainable Development, but also in
the technical reports of the Partnership Carbon Accounting Financials (PCAF, hereafter) body (for the cases where the GHG Protocol in its existing
form was not sufficiently specialized or did not cover all cases). In addition, the quantification was based on appropriate physical and economic activity
data (primary by business or supply costs), carbon footprint factors for products and services from reliable databases (e.g. DEFRA- Department for
Environment, Food and Rural Affairs- , NIR- National Inventory Report (2022)- , European Printing Ink Association), I-O factors in level of 2-digit sector
of economic activity calculated in the framework of the environmental input-output analysis (see approach 2), as well as national carbon footprint
coefficients (e.g. OASA and STASY in the case of public transport). Specifically, for the calculation of direct and indirect emissions, the following three
approaches were followed: 1) Activity data-based approach 2) Spend based approach 3) share of attribution based approach).
5
2022 Group level data is significantly decreased because of the fact that. 2023 was a year with low demand in the mortgage segment in Romania,
that in 2022, disbursed 106.54 mil Euro, in Green Loans and Hybrid Cars Loans for Retail Banking Individuals, versus 56.71 mil EUR, in 2023.
6
This KPI is applicable to the following Group companies: Alpha Bank S.A., Alpha Real Estate Bulgaria, Alpha Real Estate Romania, ABC Factors,
Alpha Finance, Alpha Supporting, Alpha Leasing, Alpha Leasing Romania, Alpha Bank Romania, Alpha Bank Cyprus, ABR Insurance Brokers,
Alpha Asset, Alpha Life, Alpha Astika Akinita..
7
The data disclosed for 2022 and included in the NFR 2023, have been restated compared to the relevant disclosure for 2022 and included in the
NFR 2022, in order to be consistent with the electricity consumption calculation followed in 2023
8
There are no data available for 2022, since the Bank and the Group, proceeded in 2023 to sustainable loan’s categorization, based on its
Sustainable Finance Framework
SOCIAL AND EMPLOYEE MATTERS
Theoretically Potential Risks*
Alpha Services and Holdings S.A.’ identified social and employee risks including:
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55 | ANNUAL FINANCIAL REPORT
Insufficient human resources management (e.g. resulting in high Employee turnover, insufficient incentives for new Employees,
unsatisfied and insecure Employees / trade unions, Employees without a common vision / culture, limited cooperation between
Employees etc.).
Existence of unfair or discriminatory labor practices (e.g. resulting in incidents of racial, religious and political racism in the
workplace, unequal treatment of men and women, lack of job opportunities for people with disabilities, inefficient complaint handling
mechanisms for labor practices etc.).
Insufficient health and safety management at the workplace (e.g. resulting in injuries of Employees / contractors at work, lost days
of work, breaches of regulations governing workplace health and safety, lack of Emergency Plans in the Bank's buildings and
branches etc.).
Unable to serve Customers through digital networks. Physical presence in Branches is required. Failure to foster financial inclusion.
Failure to manage impacts on society and local communities (e.g. failure to support local economy, reduce awareness of local
communities' needs and dynamics, failure to monitor and report Bank's indirect impacts to society etc.).
Unable to provide social contribution, promote and support Employee efforts to improve environmental and social practices.
Inability to integrate social criteria into the design of new products and services, to offer socially responsible investments, to
participate in the financing of projects with positive impacts on society.
Failure to assess social risks in customer and project finance.
Violation of social and employee standards by the Bank leading to increased reputational risk exposure
* The Theoretically Potential Risks have been evaluated in the context of the Materiality Assessment and those deemed relevant
have been incorporated in the Materiality Matrix
Alpha Services and Holdings S.A.’ Management
Employee Matters:
Alpha Bank S.A.’s Employees play a pivotal role to the Group’s growth and the achievement of its business targets as they depend
on their performance and competence. Alpha Bank S.A. implements fair labor practices and policies with regards to its Employees,
following well established international guidelines. It ensures high-quality work conditions and opportunities for professional
development based on merit and equitable treatment, offers fair remuneration and provides Employees with professional
development opportunities.
Building a diverse, equitable and inclusive work culture is fundamental for the Bank’s strategic priorities. Diversity, equity and
inclusion are applied throughout the organization, involving all stakeholders (Employees, Customers, communities and
shareholders), and focusing on the different needs of each stakeholder group. Within 2023, the Bank developed its new Diversity,
Equity & Inclusion Strategy, consisting of five DE&I focus pillars: Gender Diversity, Generational Diversity, Health Equity, Financial
Inclusion and LGBTQ+ inclusion.
In terms of Gender Diversity, Alpha Bank S.A. is the first Greek bank to be included in the Bloomberg Gender Equality Index (GEI)
and to firmly remain there for 5 consecutive years, while within 2022, was the first Bank in Greece to adopt the most modern
framework against bullying and harassment at the workplace.
In this context, a framework of interventions has been developed in the past three years, not only with respect to providing equal
opportunities for professional development, equal performance evaluation and rewards, but most importantly, a framework for
personal development for women throughout their life cycle. A key part of these interventions has been the practice of mentoring,
placing women in the driver’s seat, through the role of mentor for new joiners and young colleagues, both male and female.
Examples of empowerment initiatives are three mentoring programs that evolved during 2021-23, namely “Trading Alpha Brains”
(TAB), “SheForHe”, “Bankers and Daughters”, as well as the “Grow Aware Academy”. These actions are addressed not only to
Alpha Bank S.A. employees and their families, but also to alumni women who have left the Bank.
In terms of Generational Diversity, among the indicative initiatives have been the opportunity to students to obtain experience
through short or long-term internship programs and young professionals to work full-time in various functional areas through fixed-
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term contracts. In 2023 we held close to 120 such contracts, 100 of which were for employees below the age of 30 years old. An
example of young employment programs are the two Accelerators that we completed in 2023 to cover 120 positions in the Retail
and Wholesale areas.
Health Equity is supported through the provision of disability-related extra days of leave, reduced working time and financial
assistance as well as the extension of financial support for child health issues/disabilities. Psychological support sessions and
annual health check-ups were also provided. All employees and their family members are entitled to health and life insurance
plans, outpatient insurance plans and group personnel savings plans. Multiple benefits are also offered to parents, such as
childbirth allowance, reduced working hours, day-care benefit, etc. Finally, all employees are supported by two physicians with fully
equipped dispensaries.
To activate the Financial inclusion pillar in relation to our Employees, Alpha Bank S.A. has designed a Financial Literacy program
for 100 female participants, aiming to help them strengthen their financial resilience, become familiar with the basic principles of
financial literacy and develop the skills that will allow them manage their financial future with greater confidence. The program is
scheduled to be implemented in 2024.
In terms of LGBTQ+ inclusion, embracing the values of Diversity, Equity, and Inclusion, Alpha Bank S.A. is proud to underline its
commitment to creating a welcoming and supportive environment for all employees. Recognizing the importance of LGBTQ+
inclusion, Alpha Bank S.A. fosters a culture where all individuals, regardless of their sexual orientation or gender identity, are
treated with respect, fairness, and dignity. To this end, a large scale program has been designed to help highlight and prevent all
forms of Unconscious Bias.
CSR and Employee collaboration Initiatives
In order to increase the engagement, productivity and commitment of employees, multiple initiatives have been launched over the
past few years. First priority has been to safeguard that employee issues and concerns will be timely communicated and
addressed.
As a vehicle in promoting collaboration and networking, employee groups with common interests or characteristics, the
“Communities of Change”, were inaugurated in 2021 and further developed within 2022-2023 to facilitate:
✓ Learning from the unique experiences of employees capitalizing on their diverse professional backgrounds;
✓ distributing best practices among Units in order to achieve the goal of shaping the next day for Alpha Bank S.A.;
✓ nurturing cross-functional alliances for employees from different areas and promote collaboration;
✓ establishing Alpha Bank S.A. as an employer of choice and introducing practices that enhance our employee value
proposition.
Alpha Ithacans Community of Change
The Community was formed in July 2021 and currently counts approximately 80 members, Alpha Bank S.A. employees, repatriated
from abroad, since 2019 onwards.
The primary objective of this community is to facilitate the exchange of knowledge, best practices, and diverse experiences among
its members who bring insights from different regions and environments, to accelerate change, improve results and boost
effectiveness within the Bank; and to encourage more Greeks from abroad to consider Alpha Bank S.A. as an employer of choice
for their repatriation.
As part of Alpha Bank S.A.’s “Future Ithacans” initiative, following the successful networking event in 2022 in London, we organized
a second special event the following year in New York, which targeted Greeks who work in the US. Theaim was to raise their
awareness around the new developments in the Greek economy and state and of the reasons why they would consider Alpha Bank
S.A. as their employer of choice.
Agile Bankers Community of Change
The Community was formed in February 2021 and currently has approximately 170 members. The community’s purpose is to build
an Agile mindset within Alpha Bank S.A.: ensure top management engagement, build the Agile Academy, grow the Community and
expand agile squads. The Community’s core team members meet on a weekly basis and all members participate in monthly meet-
ups and workshops. All members also participate in the webinars and e-learnings of the Agile Academy (ACE).
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Diversity, Equity & Inclusion Community of Change
The Community was formed in September 2023 and currently counts around 280 members, from various Divisions of Alpha Bank
S.A. Its purpose is to grow a DE&I mindset in the organization by proposing, designing and implementing DE&I programs as well as
supporting and participating in DE&I actions and initiatives.
The community is organized under the DE&I Strategy five pillars: gender diversity, generational diversity, health equity, financial
inclusion and LGBTQ+ inclusion. The Community’s core team members meet on a regular basis and all community members
participate in meet-ups and workshops.
Additional Communities have been designed and will be launched in 2024, centered around the key strategic priorities of the Bank,
such as analytics and generational diversity.
Employee Learning and Development:
In 2023, our strategic commitment to sustainable growth was fostered, focusing strongly on empowering our People to unleash
their potential. Central to our Learning and Development portfolio is the learning ecosystem of Alpha Bank S.A.. The ‘Alpha
Creating Excellence- ACE #together we grow’ which was further enriched with the design and launch of specialized academies,
including those dedicated to ESG principles and Digital advancements. These academies not only underscore our dedication to
staying at the forefront of industry trends but also emphasize our commitment to fostering a workforce equipped with skills relevant
to our swiftly evolving landscape.
Additionally, we reinforced and expanded our existing learning academies (Agile, Customer Experience, Retail) with new and role-
based learning activities, while we continued our partnership with esteemed learning platforms offering professional and personal
development opportunities to all. As youth hires are pivotal in shaping our organization, in 2023 we launched an effective
onboarding program for our new Retail Bankers and set foundation for such onboarding programs for 2024.
True to our people-centric mentality, we designed initiatives aligned with our renewed Purpose and Values- Leadership programs
emphasizing the cultivation of empowered hybrid teams, Team-building activities, initially piloted within different areas of our
organization, proved so impactful that they seamlessly integrated into our organizational culture, becoming a mainstay throughout
2024. Concurrently, we designed tools for our leaders to form strong team bonds, alongside tailored training sessions addressing
unconscious bias which will launch officially in 2024, marking our clear commitment to fostering an inclusive and diverse workplace.
Health and Safety
Health and safety at the workplace are significant for the Group and its Human Resources, as any illnesses, injuries or other health
issues may affect the work environment and the Employees’ performance. The Group complies with the laws in force and ensures
the provision of additional benefits and programs such as training programs related to robbery incidents, hostage-taking, fire safety,
earthquake and building evacuation etc. The development of a comprehensive and effective Business Continuity Management
Framework and the Emergency Response and Evacuation Plan training ensure, to the maximum extent possible, the protection of
the health and safety of Employees, the uninterrupted provision of services to Customers and other Stakeholders (Shareholders,
business partners, suppliers, Regulatory and State Authorities etc.) and the minimization of the consequences (in terms of
operation, finances, legal issues and reputation) in case of an unforeseen event which can affect its operation. Alpha Bank S.A.
applies and maintains an Occupational Health and Safety Management System in accordance with ISO 45001:2018. In addition,
there is a permanent presence of Occupational Physicians in work premises with large number of Personnel, while the Bank
engages with experts (ie. psychologists) and offers Employees the opportunity for consultation and support services.
Social Matters
Financial Inclusion
Alpha Bank S.A. offers access to financial services through a wide range of financial products and services, including retail
banking, banking for medium-sized and large enterprises, asset management and private banking, insurance products, investment
banking, brokerage and real estate management.
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Having identified the opportunities and challenges of the new digital era from an early stage, Alpha Bank S.A. has established the
Digital Transformation and Innovation Division to coordinate and implement actions and activities that promote the Bank's digital
transformation. The Bank is actively promoting financial inclusion through an extensive network of Branches and off-site ATMs
across Greece. Indicatively, the Bank operates 10 Branches and 35 ATMs in sparsely populated areas in Greece with fewer than
2,000 inhabitants.
Alpha Services and Holdings S.A. invests in activities and initiatives that support financial literacy, equal access to, healthcare and
culture and environmental awareness. Moreover, the Bank promotes the concept of voluntarism by raising awareness on crucial
social and environmental issues and by engaging Employees in relevant initiatives.
In 2023, Alpha Bank S.A. launched the program ‘’IQonomy’’. The goal of this initiative is to promote the development of knowledge
and skills that will help citizens and businesses to make responsible and sustainable decisions that improve their financial well-
being, as well as to strengthen their environmental awareness. The target audience, as identified by the OECD, includes students
of all educational levels, women, and the general population over 55. IQonomy consists of 4 programs, designed and implemented
in collaboration with Non-Profit Organizations (ActionAid, SciCo, Women on Top, People Behind). These programs cover topics
such as drawing up an individual or family budget, saving, timely planning of obligations and familiarity with digital tools.
Additionally, the programs aim to educate participants on the principles of the circular economy, contributing to economic stability,
sustainable development and environmental protection.
Social Impact Investments
Finally, the Bank manages the social dimension of financing through its responsible financing approach in order to increase its
positive effect on society and the environment, utilising new business opportunities and generating value for all stakeholders.
Towards this direction, the Bank offers thematic investments with a positive direct or indirect impact on humanity and the
environment (Socially Responsible Investing - SRI) as well as on mutual fund choices that also consider social responsibility and
corporate governance regarding the underlying Assets under Management (Environmental, Social and Governance - ESG criteria).
Aiming at raise awareness regarding ESG and sustainable investments, Alpha Bank S.A. organizes informative events and on a
regular basis publishes relevant informative material in reports. It supports households and business responsible investment
choices and invests in large infrastructure projects and projects that have a positive environmental and social impact. On this basis,
Alpha Bank S.A. regularly coordinates internal and external (Customer) events focused on the merits of ESG investing.
Performance in 2022 and 2023
Indicators
Alpha Services and Holdings S.A.
Alpha Services and Holdings Group
Year
2022
2023
2022
2023
Women Employees
1
as of 31
December (%)
56%
57%
61%
6
62%
6
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Percentage of women
employees in managerial
positions
1,4
as of 31 December
(%)
40%
41%
45%
6
45%
6
Percentage of women
1
in the
Board of Directors as of 31
December (%)
31%
38.5%
22%
6
28%
8
Percentage of hirings
7
in the
age group 18-25 throughout
the year
3%
12%
21%
6
23%
6
Total training hours of
employees included in the top
10% of employees by total
compensation
5
12,804
13,979
13,670
6
22,626
6
Total training hours of
employees included in the
bottom 90% of employees by
total compensation
5
131,505
211,606
138,336
6
317,307
6
Number of injuries in the
workplace throughout the year
2
4
5
4
6
7
6
Percentage of branches
accessible (ramp or easily
accessible) by people with
disabilities (PwD) as of 31
December
3
(%)
74%
80%
81%
86%
Financing provided to
gambling, tobacco and
alcoholic beverages as % of
total loan portfolio (cap of 5%)
1.12%
0.84%
1.065%
0.89%
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1
This KPI applies to all the regular (full-time indeterminant term contracts) employees.
2
This KPI includes injuries and accidents that took place while arriving to/leaving from work. Incidents from strictly natural causes are excluded (e.g
heart attack, epilepsy)
3
This KPI is applicable only to Alpha Bank S.A. (main subsidiary Bank), Alpha Bank Romania, Alpha Bank Cyprus and Alpha Bank London.
4
Management positions include Branch Managers, Managers of Divisions and Senior Management Members (Chiefs and Chief Executive Officer).
5
The top 10% and bottom 90% is defined according to the total annual earnings, for all payments made within the year, sorted from highest to
lowest earnings.
6
This KPI is applicable to Alpha Bank S.A. (main subsidiary Bank), Alpha Bank Romania, Alpha Bank Cyprus, Alpha Real Estate Bulgaria, Alpha
Real Estate Services SRL, Alpha Credit Acquisition Company Ltd (ACAC), Alpha Leasing Romania, Alpha Real Estate Services LLC, ABC Factors,
Alpha Finance Investment Services, Alpha Leasing, Alpha Insurance Brokers SRL, Alpha Asset Management, Alpha Astika Akinita, Alpha Life,
Alpha Supporting Services, Alpha Services and Holdings S.A., Alpha Bank London. The year 2022 includes “Alpha Ventures” too. In 2023, “Alpha
Ventures” ceased its activities, thus it is not included in 2023 metrics.
7
This KPI applies to full time employees with fixed term and indeterminant term contracts.
8
This KPI applies to Alpha Bank S.A., Alpha Bank London, ABC Factors, Alpha Finance, Alpha Supporting, Alpha Leasing, Alpha Bank Romania,
Alpha Bank Cyprus, Alpha Asset, Alpha Life and Alpha Astika Akinita.
9
This KPI is applicable only to Alpha Bank S.A., Alpha Bank Cyprus and Alpha Bank Romania
10
The term equal access to cultural activities and events refers to programs and actions that aim to remove the limitations experienced by our fellow
human beings due to: 1) Lack of accessibility to the content and/or facilities (disabled and disabled people) 2) Vulnerability (individuals 3rd age) 3)
Geographical restrictions (children/residents of remote areas).
Number of CSR initiatives
targeted to the provision of
equal access
10
to cultural
Programs
8
13
16
9
21
9
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HUMAN RIGHTS
Theoretically Potential Risks*
Alpha Services and Holdings S.A.’ identified human rights risks include:
Violations of human rights (e.g. freedom of association, collective bargaining, forced or compulsory labor, child labor etc.).
Inefficient complaint handling mechanisms for human rights issues.
Incidents of discrimination against Customers.
Violation of human rights by the Bank leading to increased reputational risk exposure.
* The Theoretically Potential Risks have been evaluated in the context of the Materiality Assessment and those deemed relevant
have been incorporated in the Materiality Matrix
Alpha Services and Holdings S.A.’ s Management
Protection of Human Rights
Alpha Services and Holdings Group respects and promotes human rights through the business policies it applies, its responsible
supply chain operation and the relations it develops with its Customers. The Bank’s Corporate Responsibility Policy and the
Group’s Code of Ethics describe its approach and commitment to the management of human rights. At the same time, it applies the
laws and follows internationally acclaimed directives, principles and initiatives to protect human rights, such as the Core Labour
Conventions of the International Labour Organisation (ILO) and the Universal Declaration of Human Rights (UDHR). The Group
respects human rights and renounces any form of child, forced or compulsory labor. At the same time, the Group recognizes the
right to form trade unions and the right of collective bargaining. Collective bargaining and trade union rights are established under
national and international regulations. The Alpha Bank S.A. Group, fully respecting the rights of Employees, is committed to fully
safeguarding these rights, as established under the national and the EU Law and the conventions of the ILO. The validity of
sectoral Collective Labor Agreements (CLA) covers the entire banking sector, while the validity of Corporate Collective Labor
Agreements (CCLA) covers all regular Employees of the Bank. The validity of both sectoral and Corporate Collective Labor
Agreements is irrespective of the capacity of the trade union member of any level.
Additionally, the Bank and the Group Companies take all suitable measures to ensure that the Suppliers act in a manner consistent
with the values, principles, commitments and obligations of the Code of Ethics set out in the Bank’s Corporate Responsibility Policy.
In particular, the Suppliers established in third countries and their subcontractors are required to assure that they are acting in a
socially responsible manner and respect international standards on human rights and apply appropriate working conditions,
including the prohibition of child labor. It should be noted that the Suppliers’ Code, issued in 2022, should be accepted by every
new onboarding Supplier, since this constitutes an Annex to each new Contract signed. In the Suppliers’ Code there is specific
reference to issues related to: 1. Work – human rights 2. Health and safety 3. Environmental responsibility 4. Integrity, Ethics and
Business Conduct.
Human rights issues are addressed through the Human Resources Business Partners, as explained above. Similarly, employees
may report through the Bank’s whistleblowing mechanism any irregularities, omissions or offences that came to their attention, such
as serious violation of policies and procedures, acts that arguably offend the code of ethical practice of the Bank and the Group
Companies, acts that endanger the safety of an Employee etc. Disputes of a labor relations nature are addressed in accordance
with the provisions of the Personnel Regulation of the Bank.
The Group is committed to creating an environment which values the diversity and treats Colleagues with respect, deprived of
discrimination on the grounds of age, gender, race, nationality, religion, family status, physical or mobility impairments or any other
characteristics. The Group condemns any discrimination, harassment, or any form of misconduct against Colleagues, Customers,
Suppliers, Contractors, or any individual who intends to do business with the Group. The Group grants priority to the satisfaction of
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their individual and business needs by providing high quality services to all of its customers without any discriminations, protecting
the Customers’ legitimate interests and human rights.
Cybersecurity and Protection of Personal Data
Corporate information is classified according to the Group Cybersecurity and Information Security Framework, which sets out the
information security principles, rules and procedures for protecting sensitive information and personal data accordingly. The
Framework is regularly updated to meet the increased requirements arising from the regulatory framework, the operational and
technological environment.
The Cybersecurity and Information Security Division, under the supervision of the Group Information Security Officer, manages all
Cybersecurity issues at Group level. In 2023, the Cybersecurity and Information Security Division of the Bank completed the final
stage of its Strategic Plan (2021-2023), based on the new model for Cyber Maturity Assessment. This was the final cycle using the
Capability Maturity approach, following the successful first and second cycles and the completion of the corresponding Strategic
Plan for 2018 - 2020. The final cycle/model evaluated the Cybersecurity posture based on the assessment of Cyber capabilities for
32 Technical and Organizational domains/areas including Data Privacy domain, and more than 2,400 control objectives (criteria).
The same methodology has also been extended to foreign Subsidiaries, to implement a unified approach for the evaluation of
Cyber Maturity and provide an individual as well as a Group Cyber view. Strategic Plans and performance monitoring for all entities
have also been based on the maturity scores and targets set by each entity.
Furthermore, the Bank is currently in the process of establishing the new Group three-year Strategic Plan.
Alpha Bank S.A. applies the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the
Council), which concerns the protection of Individuals with regard to the processing of Personal Data.
The Bank has set Data Protection as a priority and recognizes that protecting Customer’s data apart from obligation is also a great
responsibility. In light of this the Group has developed a robust framework consisting of Personal Data Policies, Procedures as well
as Organizational and Technical Measures that is strong evidence of accountability and full compliance with the Data Protection
legislation and at the same time ensure protection of customers’ data and their rights. Data Protection is a task that involves almost
every Group employee and not just a single person (the Data Protection Officer) therefore training, awareness and creating a data
protection culture is of great significance to the Group.
Aiming at achieving a high level of awareness, after two massive e-learning sessions (conducted in the years 2018-2019 and 2020-
2021) for all of the employees, the Bank has focused on raising awareness with specialized training sessions for different groups of
people depending on their participation in the data processing. The first group is Branch Network Managers and employees, and
the second group is employees across 53 Central Units where they have been scheduled and performed seventeen (17)
workshops with dual objectives: training and reviewing all the Data Processing Activities.
To inform Individuals about the processing of Personal Data carried out in each case by the competent Units of the Bank or by
external third parties processing data on its behalf, the Bank maintains the document entitled “Notification on the Processing of
Personal Data”, which is provided upon collection of their personal data. This document remains always available at a central point
on the Bank’s website and serves as a set of information for all relevant details that Individuals need to know regarding personal
data processing, such as the purpose of processing, the sources and recipients of data, the storage period, their rights and how to
exercise them and the contact persons at the Bank’s Competent Services.
In addition to the above general information, Natural Persons are also provided with specific information on personal data
processing, also for products and services provided via alternative Digital Networks in the context of the Bank’s digital
transformation.
Furthermore, the Bank applies a set of coordinated actions in order to further establish and enhance personal data protection.
These include, but are not limited to:
• Review of the Register of Processing Activities (RoPA), kept by the Bank and Group Entities.This includes all operations
that involve personal data processing and update of the Record of Processing Activities with the addition of the new
processing flows and the update or modification of the existing ones available in the relative GRC Platform – (Operational
Risk, Cyber Security) RoPA module in accordance with the instructions of the Group Data Protection Officer. Ongoing
Process for Group Entities.
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• Enhancement of the RoPA update mechanism in the relative Archer GRC Platform.
• Assessing the impact on Personal Data processing flows of potentially high risk for the freedoms and rights of Natural
Persons and development of action plans for applying technical and organizational measures in order to mitigate risks.
• Developing the appropriate infrastructure for collecting and efficiently managing consent to data processing, as well as for
withdrawing consent, if applicable.
• Update of the Employees' Privacy Notice for Domestic Group entities to incorporate the Centralization of HR
• Adoption of Key Risk Indicators (KRIs) for monitoring the Organization’s level of compliance with the GDPR and definition
of Key Performance Indicators (KPIs) for assessing the effectiveness of the Personal Data Protection
Framework.Development of a Privacy Notice for the Bank’s Vendors, since their data is being processed by the Bank.
At Group level, three (3) incidents have been notified to the Local Data Protection Authorities. For these incidents corrective actions
have been immediately taken in order to mitigate potential risks for the affected data subjects.
Moreover, the Group Entities proceeded to actions to further improve and strengthen the existing technical and organizational
measures in order to avoid the recurrence of such incidents.
Performance in 2022 and 2023
Indicators
Alpha Services and Holdings
S.A.
Alpha Services and Holdings
Group
Year
2022
2023
2022
2023
Convictions against the Senior
Management
1
for any incidents
of human rights violations
throughout the year (numbers of
incidents)
0
0
0
2
0
2
Personal Data
breach incidents
3
(number of
incidents) notified
to the Personal
Data Protection
Authorities
1
1
2
2
3
2
1
As Senior Management are defined the members of the Board of Directors and the Chiefs.
2
This KPI is applicable to Alpha Bank S.A. (main subsidiary Bank), Alpha Bank Romania, Alpha Bank Cyprus, Alpha Real Estate Bulgaria, Alpha
Real Estate Services SRL, Alpha Credit Acquisition Company Ltd (ACAC), Alpha Leasing Romania, Alpha Real Estate Services LLC, ABC Factors,
Alpha Finance Investment Services, Alpha Leasing, Alpha Insurance Brokers SRL, Alpha Asset Management, Alpha Astika Akinita, Alpha Life,
Alpha Supporting Services, Alpha Services and Holdings S.A., Alpha Bank London. The year 2022 also includes “Alpha Ventures”. In 2023, “Alpha
Ventures” ceased its activities.”
3
The breach incidents include leaks, thefts or losses of personal data.
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ANTI-CORRUPTION AND BRIBERY*
Theoretically Potential Risks
Alpha Services and Holdings S.A.’ identified anti-corruption and bribery risks including:
• Corruption / bribery incidents within the Company or involving other entities (e.g. suppliers, customers, distributors etc.)
that are doing business with the Company.
• Legal actions / fines against the Company.
• Lack of or ineffective operation of anonymous reporting mechanisms (whistleblowing).
• Lack of or ineffective operation of grievance mechanisms regarding incidents of bribery, corruption and fraud etc.
• Increased reputational risk exposure due to corruption and bribery incidents occurring within the Bank.
* The Theoretically Potential Risks have been evaluated in the context of the Materiality Assessment and those deemed relevant
have been incorporated in the Materiality Matrix.
Alpha Services and Holdings S.A.’ Management
In line with its firm and unwavering position against corruption, bribery and fraud, Alpha Bank S.A. has issued a Group Anti Bribery
and Corruption Policy and established relevant control mechanisms in order to mitigate the relevant risks. Those issues were included
in the 2023 Compliance Training Program, in Alpha Services and Holdings S.A. Group Employees. The Bank conducts internal audits
for compliance with the regulatory framework and has put in place specialized control and reporting systems and works closely with
the competent Regulatory Authorities to combat money laundering and financial crime. Additionally, Bank employees follow annual
training programs on money laundering, bank secrecy and anti-corruption policies and procedures, in order to ensure their knowledge
remains current.
Compliance Division Officers conducted 7 training programs for the Bank Officers (total 63 sessions), attended by 2.940 Officers.
Specifically, (i) 1.816 Bank Officers attended 30 physical and web-based training sessions of the program “Control and Risk Culture
across Branch Network” a program that covers topics on the field of regulatory framework, AML/CFT and Bank Secrecy, (ii) 244 Bank
Officers attended the 5 web-based sessions on ”AML Officer” program, (iii) 498 Bank Officers attended 9 training sessions related
to “Customers periodic reviews process”, (iv) 299 Bank Officers attended 7 web-based sessions on “Transaction Monitoring” program
and (v) 83 new Bank employees attended 12 training sessions related to “Retail Acceleration on boarding” program.
In addition, in December 2023, a 2-hour AML Awareness e-learning session was assigned to all Bank Officers as well as to Officers
from Group Subsidiaries in Greece. To further elaborate on the importance of AML, we deployed a 5 hours webinar for all Branch
Managers/ Money Laundering Responsible Offices of the Network. Such training programs were performed across the Group
Subsidiaries, abroad and in Greece, i.e. Alpha Bank S.A. Romania, Alpha Bank S.A. Cyprus, Alpha Astika Akinita.
“Whistleblowing Framework”
A robust Whistleblowing Framework is in place for several years, enabling Employees, customers and suppliers who become
aware of serious irregularities, omissions or offences, to report them in accordance with the Bank’s Whistleblowing Policy and
Procedures. In 2023, thirteen (13) reports were submitted via the whistleblowing channels. The Whistleblowing Committee has
convened several times in 2023 and has thoroughly examined each cases, taking all necessary actions per case.
Performance in 2022 and 2023
Indicators
Alpha Services and
Holdings S.A.
Alpha Services and
Holdings Group
Year
2022
2023
2022
2023
Convictions against the Senior Management
1
for any corruption
2
offences throughout the year (numbers of incidents)
0
0
0
3
0
3
1
As Senior Management are defined the members of the Board of Directors and the Chiefs.
2
Corruption is defined as the misuse of entrusted power for private gain.
3
This KPI is applicable to Alpha Bank S.A. (main subsidiary Bank), Alpha Bank Romania, Alpha Bank Cyprus, Alpha Real Estate Bulgaria, Alpha
Real Estate Services SRL, Alpha Credit Acquisition Company Ltd (ACAC), Alpha Leasing Romania, Alpha Real Estate Services LLC, ABC Factors,
Alpha Finance Investment Services, Alpha Leasing, Alpha Insurance Brokers SRL, Alpha Asset Management, Alpha Astika Akinita, Alpha Life,
Alpha Supporting Services, Alpha Services and Holdings S.A., Alpha Bank London. The year 2022 also includes “Alpha Ventures”. In 2023, “Alpha
Ventures” ceased its activities.
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SUPPLY CHAIN
Theoretically Potential Risks*
Alpha Services and Holdings S.A.’ identified supply chain risks including:
• Conducting business with suppliers that fail to address business ethics (e.g. corruption and bribery issues), fair labor
practices, human rights as well as having negative impacts on society and/or the environment.
• Low expenditure spent to local/domestic suppliers.
• Outsourcing agreements with companies that do not comply with regulations, Alpha Bank S.A.'s values and business
principles or the current market practices (e.g. business continuity plans etc.).Increased reputational risk exposure due to
supply chain issues occurring within the Bank or its associated third parties.
* The Theoretically Potential Risks have been evaluated in the context of the Materiality Assessment and those deemed relevant
have been incorporated in the Materiality Matrix.
Alpha Services and Holdings S.A.’ Management
Alpha Services and Holdings S.A. maintains a register of third-party suppliers.
The Bank has identified the Corporate Social Responsibility principles that should be applied by the Bank, its suppliers and
partners in its Corporate Responsibility Policy. All suppliers are expected to comply with this Policy and operate responsibly. When
evaluating suppliers’ performance, the Bank assesses whether they have had their management systems certified according to
international standards such as ISO 9001, ISO 45001 and ISO 14001.
Furthermore, the cooperation and service agreement contracts contain contractual terms for compliance with labor and insurance
legalization and for taking the necessary measures to ensure the health and safety of Employees.
The Bank has also established a Group Outsourcing Policy, which sets specific evaluation criteria for third party service providers
aiming to minimize potential risks for the Bank and its Customers. According to the Policy, every third party and service provider is
periodically evaluated by the relevant Divisions of the Bank, coordinated by Alpha Bank S.A. Outsourcing Functional Area. The
initial or/and periodic assessment of suppliers of Outsourcing services (critical - noncritical) is carried out with specifically designed
questionnaires containing many questions and information. Through these questionnaires, based on their competencies and scope,
the specific jointly-competent Divisions assess any risks for the quality of services, counterparty risk (financial status, long-term
sustainability), information security risk, confidentiality risk, personal data management risk, business continuity risk,
regulatory/legal and tax compliance risk.
As of 2021 the Bank began a transformation project concerning the outsourcing providers’ scorecards, in order to align the Bank’s
demands of its vendors with the appropriate guidelines. The updated scorecards have been presented and approved by the
Competent Structures of the Bank during 2022 (including ESG criteria).
In addition, it should be mentioned that the Group Procurement Policy was revised (Dec’22), incorporating guidelines on
sustainable procurement and ESG practices.
During the same period, the Supplier Management Policy was adopted, which defines among others the evaluation method and
measurement of the vendors performance.
In parallel, the Supplier Code of Conduct (Labor-Human Rights, Health & Safety, Environmental Responsibility, Integrity-Business
Ethics) was issued. Its acceptance and compliance with its principles and values is a prerequisite for signing contracts and
assignments (if the vendor doesn’t apply a similar code).
Alpha Bank S.A. introduces a Digital Procurement Platform aiming to simplify and streamline procurement management processes,
ensuring transparency and audit trail. The platform entered in production in late 2023 and will roll-out to cover all Procurement
activities within Q1-2024. Supplier onboarding procedure performed through the new platform will be enhanced with an additional
environmental, social and governance (ESG) questionnaire, designed and integrated in the Procurement Platform.
Finally, Alpha Services and Holdings S.A. seeks to support local communities and create added value for the local economies. In
2023, Alpha Services and Holdings S.A. Group cooperated primarily with local suppliers, whenever possible.
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Performance in 2022 and 2023
Indicators
Alpha Services and Holdings
S.A.
Alpha Services and Holdings
Group
Year
2022
2023
2022
2023
Percentage of payments to domestic
suppliers
1
(%) in support of local economy
87%
90 %
85%
88%
1
Total amount paid of procurement (in Euro- including VAT) from domestic suppliers (defined as domestic suppliers for each
country according to the VAT number) divided by total amount paid of procurement (in Euro- including VAT) from all suppliers
(domestic and international).
This indicator is applicable to the following Group Companies: Alpha Bank S.A. (main subsidiary Bank), Alpha Asset Management,
Alpha Finance Investment Services, Alpha Supporting Services, Alpha Real Estate Bulgaria, Alpha Bank Cyprus, Alpha Bank
Romania S.A., Alpha Bank London, Alpha Leasing Romania, Alpha Astika Akinita, Alpha Real Estate Services SRL. The year
2022, also, includes ABC Factors, Alpha Leasing, Alpha Life, Alpha Ventures, Alpha Credit Acquisition Company Ltd (ACAC) and
Alpha Insurance Brokers SRL.
GOVERNANCE
General Information
The Group’s ambition is to safeguard robust and transparent governance. Towards this direction, is committed to:
- Ensure the Diversity and Independence of the Board of Directors.
- Embed Sustainability in Governance practices and strategy.
- Enhance transparency and safeguard business ethics.
In alignment with the aforementioned commitments, the Board of Directors with the support of the Corporate Governance,
Sustainability and Nominations Committee of Alpha Services and Holdings S.A. assesses on an annual basis its effectiveness as
well as that of its Committees. During 2023, the collective evaluation of the Members of the Board of Directors and its Committees,
for the 2022, was conducted by Morrow Sodali, with the assistance of the Corporate Governance, Sustainability and Nominations
Committee. The Individual Evaluation of the Members of the Board of Directors for the year 2022 was conducted, in 2023, by the
Chair of the Board of Directors.
Further to the aforementioned evaluation of the Board of Directors, an assessment of the Board Members’ collective suitability in
terms of knowledge, skills and experience was conducted, based on the ESMA/ EBA “Guidelines on the Assessment of the
Suitability of Members of the Management Body and Key Function Holders” with the support of the Corporate Governance,
Sustainability and Nominations Committee.
Sustainability Oversight
The Corporate Governance, Sustainability and Nominations Committee acts as the ultimate liaison/ responsible Board Committee
with respect to all sustainability/ESG issues and promotes respective communications and feedback from all the Board of Directors
Committees.
The Risk Management Committee, the Corporate Governance, Sustainability and Nominations Committee and the Audit
Committee are informed, on regularly by the Group ESG Coordinator, the Chief Risk Officer, the Chief of Wholesale Banking and
the Chief of Corporate Center on issues related to Sustainability and Climate Risk. Consequently, the Chair of each Committee
endorsed for approval by the BoD, specific items that are being discussed and the BoD proceeds to the final approval.
In 2023, the Corporate Governance, Sustainability & Nominations Committee was informed about the ESG Project, 7 times. In
addition, the CGSNC provided feedback on the Group’s Sustainability Disclosures.
Additionally, in 2023, the Corporate Governance, Sustainability and Nominations Committee agenda included the following:
✓ ECB Climate-related and Environmental Risk Disclosures.
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✓ Sustainability Report 2022.
✓ Task Force on Climate-related Financial Disclosures (TCFD) Report.
✓ Sustainability Strategy & KPIs.
✓ ESG Report including ESG Workplan as well as Key recent developments in the market and Regulatory areas.
✓ ESG KPI monitoring Dashboard.
Concurrently, the Risk Management Committee was informed of the ESG Report, of the feedback letter on Climate-Related and
Environmental Risk Disclosures as well as it was updated on the process and methodology behind the Financed Emissions
Assessment and the Forward-Looking Assessment and on the Climate risk supervisory action plan.
At the Executive Management level, a key part of the ESG Governance structure is the Group Sustainability Committee, which
oversees ESG topics, steers the Group’s ESG strategy and oversees its implementation, as well as supporting the Board of
Directors in their oversight of Climate & ESG Risks and Sustainability in general.
The committee membership includes six Chiefs as permanent members and 8 additional members who are Chiefs or at the senior
executive level. In 2023, the Group Sustainability Committee met nine (9) times to discuss, among others, the progress on ESG
integration and corresponding action plan to meet the supervisory expectations. The Committee members examined the Bank’s
ESG strategy and commercial implications as well as the Sustainable Finance Framework operationalization and developments on
IT systems’ integration. The Committee was also informed about the materiality assessment of climate risk, the ESG training
provided to the Bank’s employees and the progress of international subsidiaries in integrating ESG. The members, also exchanged
views on the measurement of financed emissions and climate strategy target setting and reviewed the Bank’s disclosures. The
Committee approved the ESG Operating Model, the risk identification & materiality assessment of Climate Risk, and the updated
policies and sustainability-related disclosures. Finally, the 2024 ESG Workplan was presented to the Committee
members with priority initiatives to ensure the continuation of the Bank’s action plan, to support its clients’ decarbonization efforts
and the successful implementation of business strategy.
The Group ESG governance model was established in 2021 and enhanced within 2022 with the establishment of expert teams with
advanced skills in the Climate, ESG and Enterprise Risk Management, and the M&A International Business Strategy Divisions,
ensuring the effective management of Sustainability issues. The oversight and steering provided by the Board of Directors and its
Committees ensures that the Bank has accelerated the development and implementation of its Sustainability strategy.
At operational level, an ESG Working Group has been established in order to implement key initiatives, led by the Group ESG
Coordinator, who is also responsible for providing direction to subsidiaries and other units. The Bank’s Governance and
Sustainability Division drives the ESG agenda and ensures internal adoption of best practice across the Group.
The Climate & ESG risk coordinates closely with the Governance & Sustainability Division for ESG and climate related issues, as
well as with Supervisory Issues Management Division, for the risk-related input to supervisory processes and submissions. Among
others, the Climate, ESG and Enterprise Risk Management Division provides expert guidance for ESG integration in the risk
management framework, supports consistency and adequacy of risk input across risk types, reviews questionnaires in the borrower
assessment process, designs assessment methodologies (e.g. for physical climate risk) and is responsible for risk- related aspects
of strategy-setting and business planning.
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RESPONSIBLE INVESTMENT AND FINANCING
Alpha Asset Management
The Group’s asset management subsidiary, Alpha Asset Management M.F.M.C. (Alpha Asset Management), acknowledges ESG
issues as key non-financial parameters that may affect long-term returns of investments and investment portfolios. Along with
traditional financials, the company takes ESG factors into consideration in the investment process.
Alpha Asset Management has developed a credible methodology to incorporate sustainability perspectives into investment decisions,
active ownership and business culture for long-term value creation and positive contribution to society. The company’s Environmental,
Social and Governance (ESG) Policy represents the guiding principles that the company applies to ensure that information on ESG
risks and opportunities is appropriately incorporated into the investment management process. Alpha Asset Management
acknowledges the responsibility it has as an asset management company to address ESG considerations. It also recognizes that
ESG risks and opportunities can have material effects on the financial performance of the securities and assets in which it invests.
The company’s commitment towards enhancing its ESG product offering is demonstrated by the fact that, in order to respond to the
growing investor demand for ESG products, it converted (in May 2023) two additional UCITS funds from Article 6 to Article 8 under
Sustainable Finance Disclosure Regulation (SFDR). This action increased the company’s assets under management promoting
sustainability characteristics by 21%. Furthermore, over the next couple of years the company will be examining the conversion of
some of its existing financial products from Article 6 to Article 8 under SFDR as well as the launch of new products that fall under
Article 8. The Company’s financial products falling under Article 8 of SFDR apply additional ESG criteria in their investment strategy,
primarily a combination of exclusion, negative screening and positive,best-in-class screening at the “asset manager” and “underlying
fund” level.
Alpha Asset Management has also established an ESG Investment Committee which is the body for implementing the responsible
investment policy. More specifically, the Committee ensures that:
• ESG criteria are integrated into the Company’s investment policy;
• the Company meets its commitments as a signatory to the Principles for Responsible Investment (PRI);
• the Company meets its regulatory requirements.
The Risk Management unit of Alpha Asset Management monitors compliance with the internal thresholds that Alpha Asset
Management has set as part of the company’s ESG Policy implementation.
Furthermore, Alpha Asset Management developed and distributed an ESG Questionnaire to Greek issuers and uses the data
collected from the questionnaire as the basis to form a proprietary ESG Assessment and Scoring Framework. In addition, based on
issuers’ responses to the Questionnaire, the company has initiated engagement with investee companies in order to encourage
sound corporate governance practices.
Alpha Asset Management incorporated additional ESG filters, factors and criteria into the portfolio construction process, which were
implemented at the beginning of 2023. These enhancements aim at further strengthening the sustainability profile of Alpha Asset
Management’s funds. An additional step that the company has outlined to advance its commitment to responsible investment is the
increased focus on the integration of climate-related risks and opportunities into the company’s investment strategies. Alpha Asset
Management considers climate change to be one of the most significant economic and political challenges of our century.
Alpha Asset Management demonstrates responsible ownership by exercising voting rights at annual general meetings and
extraordinary general meetings for its funds’ equity holdings, with a primary focus on domestic market investments. Throughout the
year, the company actively exercised voting rights in 55 shareholder meetings, marking a substantial increase compared to its
participation in such meetings in previous years. Since 2022, Alpha Asset Management has started cooperating with a leading
Advisor, specializing in corporate governance and proxy voting solutions. The Advisor provides research and voting
recommendations at the general meetings, based on internationally recognized best practice guidelines. In cases where the Advisor
recommended voting against specific general meeting agenda items, Alpha Asset Management engaged in constructive dialogue
with the investee companies in order to source additional information about those controversial topics and any potential improvement
action plans that the investee companies’ management has established.
As part of the company’s commitment to incorporate ESG criteria into its investment process, Alpha Asset Management has been a
signatory of the United Nations-backed Principles for Responsible Investment (PRI) since December 2018. In August 2023, the
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company submitted its 2022 PRI Assessment report in which it reported on its responsible investment activities throughout the year
2022.
Alpha Asset Management will continue to act as sustainability advocate, strengthen its product offering of ESG-related strategies and
collaborate with stakeholders and market participants to raise awareness and promote responsible investment practices. The
company’s approach to responsible investment will continue to reflect the best interest of its stakeholders in delivering enhanced risk-
adjusted returns over the long term while contributing to a sustainable world.
Impact Investment Products
The Bank is dedicated not only to not financing polluting projects but also to actively fight climate change by its activities and
operations. In 2023, Alpha Bank S.A. introduced for the second time, impact investment products. Through the “Reforest Action”,
which is highly relevant for Greece due to the wildfire outbreaks for consecutive years, more than 56 thousand trees have been
financed to be planted, which translates to 8,42 thousand tons of CO2 stored and the creation of 168 thousand natural shelters for
wild animals. Additionally, the above-mentioned action created the need to cover about 56 thousand hours of work. The Reforest
Action is particularly important for Greece not only for the environment but also for the residents of the affected areas by the wildfires,
since the reforestation prevents severe floods.
In addition, the Bank for the first time selected and promoted to the clientele two issues of Social Bonds within the year. Social Bonds
are defined bonds that have a social benefit, in the sense that the funds raised from their issuance, or equivalent amounts, are used
to finance or refinance, in whole or in part, new and/or existing projects with social sustainability characteristics (Social Projects).
The criteria for the selection of the issues were based on their ability to cover areas such as basic social infrastructure (transport,
drinking water and water supply, energy), access to basic social services (education, health, finance), housing, employment and
unemployment reduction, food safety, technology and sustainability, elimination of socio-economic inequalities and ensuring equal
opportunities for different social groups. Alpha Bank in its role as an Investment Products Distributor and within its Investment
Product Governance duties, has developed a robust process to receive or identify, assess, store, and display for utilization all
information of the Investment Products characteristics including those of sustainability. In this context, Alpha Bank receives by the
Investment Products Manufacturers, on a monthly basis, the sustainability characteristics of the respective Investment Products,
including the information on SFDR, Taxonomy, Principal Adverse Impacts and Negative Screening. This information is stored and
maintained in Alpha Bank’s IT systems in order to service front line requests on clients’ sustainability preferences.
ESG PERFORMANCE RATINGS
Alpha Services and Holdings S.A. is subject to assessments by international analysts and rating agencies and as shown in the
following table, it is constantly improving its ESG performance.
ESG Ratings
Year
2020
2021
2022
2023
MSCI ESG Rating
(scale CCC-AAA)
AA
AA
A
2
A
FTSE4Good Emerging Index
🗸
🗸
🗸
🗸
ISS ESG Quality Score
1
(score 1-10, 1 indicates lower risk and better
disclosure)
E 1
S: 2
G: 4
December
2020
E 1
S: 2
G: 6
December
2021
E 1
S: 3
G: 3
December
2022
E 2
S: 2
G: 3
December 2023
Climate Change CDP
C
B
-
B
C
Bloomberg Gender Equality Index
🗸
(Index 2021)
🗸
(Index 2022)
🗸
(Index 2023)
Not scored yet
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1
The ISS rating is a comparative rating, which fluctuates due to changes in the market, rather than the sustainability performance of the company.
2
The MSCI rating for 2022, has been downgraded due to methodological changes that resulted in the inclusion of the Corporate Behavior Theme in
Alpha Bank S.A.'s Governance assessment.
EU TAXONOMY DISCLOSURE REQUIREMENTS
Disclosure requirements in accordance with Article 8 of the EU Taxonomy Regulation
Regulation (EU) 2020/852 (EU Taxonomy) was created to meet the need for a common system for the classification of
environmentally sustainable economic activities. At the same time, it forms an integral part of the European Green Deal, as well
as of the EU Action Plan on Sustainable Finance.
The EU Taxonomy Regulation is effective since July 12th, 2020, and establishes the following six environmental objectives:
1. Climate change mitigation (CCM);
2. Climate change adaptation (CCA);
3. Sustainable use and protection of water and marine resources;
4. Transition to a circular economy;
5. Pollution prevention and control; and
6. Protection and restoration of biodiversity and ecosystems.
The 1st Delegated Act (commonly known as the "Climate Delegated Act") concerning the technical criteria for economic
activities with a significant contribution to the first two objectives, (i.e., the climate change mitigation and the climate change
adaptation), was adopted on July 4th, 2021, and is effective as from January 1st, 2022. Ιn 2023, two new Delegated acts issued
by the European Commission have been adopted :
1. The Delegated Act 2023/2485 which includes technical screening criteria of new activities for the substantial
contribution to the first two environmental objectives (CCM and CCA) and
2. The Delegated Act 2023/2486 which includes technical screening criteria of new activities for the substantial
contribution to the remaining four environmental objectives.
Furthermore, a reporting guidance has been published by the European Commission including relevant FAQs. This guidance
provides definitions as well as interpretation and clarifications of reporting requirements for financial undertakings.
According to the Regulation (EU) 2020/852 (EU Taxonomy), the term “eligible” is used for economic activities included in the
above mentioned Delegated Acts. However, it should be noted that even if an economic activity is eligible, it does not mean it is
also environmentally sustainable. The term "environmentally sustainable activity or investment" is associated with alignment,
which requires greater analysis compared to eligibility. To be taxonomy-aligned an economic activity should comply with all the
requirements listed in the respective technical criteria, should not do significant harm (DNSH) to other environmental objectives,
and should be exercised in accordance with the minimum social safeguards.
For the first time, in current year reporting, credit institutions shall disclose, according to the EU Taxonomy regulation,
taxonomy alignment information for the two climate environmental objectives and taxonomy eligibility information for the
remaining four environmental objectives. The ratio that indicates the alignment is the Green Asset Ratio (GAR) which shall be
disclosed along with a breakdown by environmental objective, type of counterparty and type of eligible asset.
Implementation in business strategy, product design processes and engagement with clients and counterparties
Alpha Bank seeks to increase its positive effect on society and the environment, utilizing new business opportunities and
generating value for all stakeholders. Through its Sustainable Finance Framework, Alpha Bank supports lending activities as well
as other funding instruments with clear environmental and social credentials in alignment with the EU Taxonomy regulation and
with the principles established by the International Capital Market Association.
For further information in relation to sustainable financing practices refer to the “Responsible Investments and Financing”
section of this Report.
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Approach for Taxonomy eligibility and alignment assessment
The information presented follows the requirements described in Article 7 and Article 10 of the Delegated Regulation (EU)
2021/2178. The information relating to Taxonomy is prepared following the prudential approach and consolidation of Alpha
Services and Holdings Group, in accordance with the applicable laws.
The taxonomy eligibility assessment shows the proportion of the Group’s assets financed and invested in taxonomy-eligible
economic activities as a proportion of total covered assets. The taxonomy alignment assessment, and specifically the GAR ratio,
shows the proportion of the Group’s assets financing and invested in taxonomy-aligned economic activities as a proportion of
total covered assets. The numerator covers the loans and advances, debt securities, equities and repossessed collaterals,
financing taxonomy-aligned economic activities based on the relevant turnover and CapEx KPIs. The following categories of
exposures have been excluded from the calculation of the GAR ratio as necessary:
• 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 that are not obliged to publish non-financial information pursuant to 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;
In addition, credit institutions shall disclose the percentage of their total assets that are excluded from the numerator and the
denominator of GAR.
Alpha Services and Holdings collected the reported information from the latest published taxonomy information and relevant
KPIs for the counterparties in scope of Non-Financial Reporting Directive (NFRD). The counterparties that are not in scope of
NFRD, and hence not required to report Taxonomy information, are not included in the assessment for taxonomy-eligibility and
alignment.
For specific purpose funding, which is defined as exposures that have the purpose of financing specific identified activities,
(‘known use of proceeds’), project-specific KPIs are used in the assessment for taxonomy-eligibility and alignment.
For retail exposures relevant to EU Taxonomy, only loans collateralised by residential real estate, loans granted for renovation
purposes and loans granted with purpose to finance the purchase of vehicles were analysed for taxonomy-alignment.
In accordance with the guidance published in December 2023 FAQs, no estimates were included in the calculation of eligibility
and alignment for mandatory disclosures presented.
KPIs for off-balance sheet exposures include financial guarantees granted by the credit institution and assets under management
for guarantee and investee non-financial undertakings. Other off-balance sheet exposures such as commitments are excluded
from that calculation.
According to Delegated Act (EU) 2022/1214, credit institutions disclose their exposure to economic activities related to fossil gas
and nuclear energy. Exposures relevant to taxonomy-aligned economic activities of nuclear energy and fossil fuel have been
included in the numerator and denominator of their KPIs, and exposures relevant to taxonomy-non-eligible nuclear energy and
fossil gas related activities are included in the denominator of their KPIs.
Limitations in data and information
The information for financial undertakings is limited as this is the first year of alignment reporting, and most of the financial
undertakings have not yet published their 2023 annual reports. Non-financial undertakings have not published yet taxonomy
information for 2023, thus the Taxonomy reporting of alignment for non-financial undertakings is based on data publicly
available from 2022.
Additionally, information on taxonomy-eligibility for the four environmental objectives implemented in 2023 is not possible due
to the lack of data as information collected from latest publicly available taxonomy information by counterparties may not
include the new economic activities incorporated in the Delegated Acts issued in 2023.
NON-FINANCIAL REPORT
73 | ANNUAL FINANCIAL REPORT
In relation to mortgage lending to households, the technical screening criteria is also constrained due to the lack of complete
datapoints for the Energy Performance Certificate (EPC) labels of collaterals. In addition, the assessment of DNSH was not
possible.
For lending with purpose of financing vehicles, the assessment of DNSH criteria was not possible due to unavailability of relevant
data, i.e. tires of the motor vehicle etc.
Reporting of taxonomy-eligibility and taxonomy-alignment for off-balance sheet exposures is not possible due to the lack of
complete datapoints. Additionally, reporting of flow for households is not possible due to the lack of complete datapoints.
In view of the upcoming CSRD requirements and the continuous amendments on Taxonomy regulation, Alpha Services and
Holdings Group closely monitors all relevant announcements to ensure transparency and completeness of the information
required to be disclosed, both for the current year as well as for the upcoming years. Moreover, the gradual implementation of
CSRD is expected to improve the reported Taxonomy KPIs, as it will increase the number of companies in scope of the new
directive.
Overview of results
The gross carrying amount of total covered assets amounted to EUR 57.655 m as of the year end 2023.
The eligibility ratio relevant to climate change mitigation and climate change adaptation is 18.1% based on turnover (20.6%
CapEx based).
The total GAR based on turnover is 2.1% of total covered assets while the total GAR based on CapEx is 3.5% of total covered
assets as at year end 2023. The GAR is predominantly influenced by exposures to NFRD counterparties and exposures where the
use of proceeds is known and finances taxonomy-aligned economic activities (i.e., for which the project specific KPIs were used).
Exposures relevant to nuclear energy and fossil gas economic activities are reported in tables below.
Taxonomy disclosures and reporting templates
The following table presents a summary of the KPIs that must be disclosed by Credit Institutions under Article 8 Taxonomy
Regulation.
The reporting forms in accordance with the Disclosures Delegated Act, Annex VI, and Annex XII related to nuclear and fossil gas
activities, can be found in the Appendix of the Non Financial Report. Comparative information for 2022 is not reported.
Columns from the reporting templates for the four environmental objectives have been omitted and not reported for 2023 as
publicly official data is not available by the counterparties.
NON-FINANCIAL REPORT
74 | ANNUAL FINANCIAL REPORT
Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation
Total environmentally sustainable assets (1)
KPI (3)
KPI (4)
% coverage (over total assets) (5)
% of assets excluded
from the numerator of the
GAR (Article 7(2) and (3)
and Section 1.1.2. of
Annex V)
% of assets excluded from
the denominator of the
GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Main KPI
Green asset ratio (GAR) stock
1.239
2,1
3,5
77,9
54,8
22,1
Total environmentally sustainable activities (2)
KPI (3)
KPI (4)
% 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)
463
6,4
9,1
27,6
N/A
N/A
Trading book(6)
Financial guarantees
0
0,0
0,0
Assets under management
0
0,0
0,0
Fees and commissions income(6)
(1) Total environmentally sustainable assets used for turnover KPI. Total environmentally sustainable assets used for Capex KPI amounts to EUR 2.001 million
(2) Total environmentally sustainable assets used for turnover KPI. Total environmentally sustainable assets used for Capex KPI amounts to EUR 659 million for GAR flow,
EUR 0 million for financial guarantees and EUR 0 million for assets
(3) Based on the Turnover KPI of the counterparty
(4) Based on the CapEx KPI of the counterparty
(5) % of assets covered by the KPI over Group´s total assets
(6) "Trading book" and "fees and commissions income" KPIs shall apply from FY2025 onwards
EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF ALPHA SERVICES
AND HOLDINGS S.A.
75 | ANNUAL FINANCIAL REPORT
EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF
ALPHA SERVICES AND HOLDINGS S.A. FOR THE YEAR 2023
The present Explanatory Report of the Board of Directors of Alpha Services and Holdings S.A. (hereinafter the “Company”) to the
Ordinary General Meeting of Shareholders of the Company for the Year 2023 contains detailed information, pursuant to the
provision of article 4 par. 7 of Law 3556/2007, with reference date 31.12.2023, in accordance with the order in which it appears in
the said provision.
In particular:
I. Company’s Share Capital Structure
On 31.12.2023 the share capital of the Company stood at the total amount of Euro 681,992,324.59, divided into
2,351,697,671 common, registered, dematerialized shares with voting rights, of a nominal value of Euro 0.29 each. All shares
are listed for trading on the Securities Market of the Athens Exchange.
Τhe share capital of the Company as of 31.12.2023 was formed following the share capital increase pursuant to the resolution
of 28.9.2023 of the Board of Directors of the Company, in accordance with article 113 par. 3 of Law 4548/2018, in the context
of the implementation of the resolution of the Ordinary General Meeting of Shareholders of July 31, 2020 on the approval of a
Stock Options Plan, for the years 2020-2024, by the amount of Euro 808,840.16, by issuing and granting to the
Beneficiaries/Employees of the Company and its Affiliated Companies 2,789,104 common, registered, dematerialized shares
of the Company with voting rights, of a nominal value of Euro 0.29 each, whereby the difference between the offer price and
the nominal value of 2,648,860 shares, amounting to a total of Euro 26,488.60, was credited to the special account (share
premium account) under the title “issuance of shares above par value”.
It is noted that on 13.11.2023 the Hellenic Financial Stability Fund (HFSF) announced the successful disposal of its entire stake in
the share capital of Alpha Services and Holdings S.A. to UniCredit S.p.A., pursuant to a share purchase agreement entered into
between the HFSF and UniCredit S.p.A. on 12.11.2023 and following the completion of a competitive process launched by the
HFSF on 30.10.2023, which was triggered by a binding offer from UniCredit S.p.A. received by the HFSF on 23.10.2023 for the
acquisition of the HFSF’s entire stake in the share capital of Alpha Services and Holdings S.A. Upon completion of the above sale,
the HFSF has no longer the special rights provided for in Law 3864/2010, as in force, including the right to appoint a
representative to the Board of Directors and its Committees.
EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF ALPHA SERVICES
AND HOLDINGS S.A.
76 | ANNUAL FINANCIAL REPORT
II. Restrictions on the transfer of the Company’s shares
The Articles of Incorporation of the Company contain no restrictions on the transfer of its shares, save as otherwise provided
for in the law.
III. Significant direct and indirect shareholdings as per Greek Law 3556/2007
According to the Company’s records, on 31.12.2023, “UniCredit S.p.A.” held common shares representing 9.616% of the total
paid-in share capital of the Company and “REGGEBORGH INVEST B.V.” held common shares representing 9.106% of the
total paid-in share capital of the Company.
Also according to the Company’s records, as at 31.12.2023 no other shareholder (individual or legal person) holds on an
individual basis (directly or indirectly) more than 5% of the total number of the ordinary shares of the Company.
IV. Shares with special rights of control
There are no shares issued by the Company granting special rights of control to their holders.
V. Restrictions on voting rights
The Articles of Incorporation contain no restrictions on voting rights and on the exercise periods of voting rights on shares
issued by the Company.
VI. Shareholder agreements
To the knowledge of the Company, there are no shareholder agreements providing for restrictions on share transfers or
restrictions on the exercise of voting rights on shares issued by the Company.
VII. Rules regarding the appointment and replacement of Members of the Board of Directors and amendments of the Articles
of Incorporation
There are no rules in the Articles of Incorporation for the appointment and replacement of Members of the Board of Directors
as well as for the amendment of the Articles of Incorporation of the Company, which are at variance with the stipulations of
Law 4548/2018, as in force.
VIII. Authority granted to the Board of Directors to issue new shares or to acquire own shares
The Company may increase its share capital by virtue of a resolution of the General Meeting of Shareholders or of the Board
of Directors, in accordance with the law and the Articles of Incorporation.
On 27.7.2023, the Ordinary General Meeting of Shareholders approved, pursuant to article 49 of Law 4548/2018, the
establishment of a Share Buyback Program (the “Share Buyback Program”) for the acquisition by the Company (or any of its
Subsidiaries) of own existing common, registered, dematerialized shares, with voting rights, in a price range between the current
nominal value of the share i.e. currently Euro 0.29 (minimum price) and Euro 3.00 (maximum price) per share, for a period of 24
months starting from the day immediately after the day of its approval by the Ordinary General Meeting, and authorized the Board
of Directors of the Company to determine at its discretion any other detail and to proceed with all necessary actions for the
implementation of the Share Buyback Program.
Following the above authorization, the Board of Directors by virtue of its resolution dated 8.11.2023 proceeded with the
commencement of the Share Buyback Program, as per the above terms and conditions set by the General Meeting, and
approved additional terms and details in respect of the Share Buyback Program, including the fact that the share buybacks
will be carried out in the stock market via a third party, namely an entity providing investment services, which does not belong
to the Company’s Group and will be appointed as lead manager of the Share Buyback Program, pursuant to Article 4 par. 2
(b) of the Commission Delegated Regulation (EU) 2016/1052, making its trading decisions concerning the purchases of the
Company shares under the Program independently of the Company.
EXPLANATORY REPORT OF THE BOARD OF DIRECTORS OF ALPHA SERVICES
AND HOLDINGS S.A.
77 | ANNUAL FINANCIAL REPORT
IX. Significant agreements put in force, amended or terminated in case of a change in the Company’s control following a
public tender offer
The Company has entered into no major agreement which comes into effect, is amended or expires upon a change of control
of the Company following a public tender offer.
X. Agreements with Members of the Board of Directors or with Employees
The Company has entered into no agreement with Members of the Board of Directors or with its Employees, providing for
compensation upon their resignation or dismissal without just cause or upon termination of tenure or employment owing to a
public tender offer, except in accordance with the provisions of the law.
Athens, March 6, 2024
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
VASILEIOS T. RAPANOS
ID. No ΑΙ 666242
VASSILIOS E. PSALTIS
ID. No ΑΙ 666591
CORPORATE GOVERNANCE STATEMENT
78 | ANNUAL FINANCIAL REPORT
CORPORATE GOVERNANCE STATEMENT
A. INTRODUCTION
Pursuant to article 152 par. 1 and article 153 par. 3 of Law 4548/2018, Law 4706/2020 and the Hellenic Corporate Governance
Code, the Board of Directors’ Annual Management Report of Alpha Services and Holdings S.A. (the “Company”) includes the
Corporate Governance Statement for the year 2023. The reference date of the Corporate Governance Statement is 31.12.2023.
Items c), d), f), h), i) of article 10 of Directive 2004/25/EC of the European Parliament and of the Council, as they are incorporated
in items c), d), e), g), h) of article 4 par. 7 of Law 3556/2007, are analyzed in the Explanatory Report of the Board of Directors,
which is included in the Board of Directors’ Annual Management Report.
B. CORPORATE GOVERNANCE CODE AND PRACTICES
1. Statement of Compliance with the Corporate Governance Code
The Company, following a resolution of the Board of Directors and with reference to article 17 of Law 4706/2020, adopted
the Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council (the “Code”).
The Company adheres to the Code which is posted on its website (https://www.alphaholdings.gr/en/esg-and-
sustainability/advocating-sound-governance-practices/management/codes-and-policies).
The Corporate Governance, Sustainability and Nominations Committee (the “CGSNC”) of the Company: i) monitors the compliance
of the Company and the Group with the pertinent Hellenic Corporate Governance Code, ensuring the appropriate application of the
“comply or explain” principle required, and ii) provides oversight that the implementation of this principle aligns with the legislation in
force, the regulatory expectations and the international corporate governance best practice.
2. Explanation on issues of non-compliance with the Hellenic Corporate Governance Code in the context of
the “comply or explain” principle
The Company complies with the Hellenic Corporate Governance Code, with the exception of the provision on the election of Vice-
Chair or Senior Independent Director (par. 2.2.21 “Special Practice” of the Code).
In this regard, the Chair of the Board of Directors has been designated, among the Non-Executive Members, to coordinate
Independent and Non-Executive Members’ meetings. Furthermore, the responsibilities of the Senior Independent Member are
covered by the Chair of the Board of Directors and the Chair of the CGSNC. Under the Company’s Board of Directors Charter, the
Non-Executive Members of the Board of Directors must meet at least annually, or more frequently if required, without the presence
of Executive Members.
In 2023, ten meetings of the Non-Executive Members of the Board of Directors were convened, well above the minimum
requirement. In addition, it should be noted that all four Committees of the Board of Directors are chaired by Independent Non-
Executive Members (and the majority of their Members are also Independent Non-Executive Members) and effectively support the
Chair in the execution of his duties and responsibilities.
The Company reconsiders on an annual basis the guidance of the Code in this regard.
3. Update of Corporate Governance Documents during 2023
During 2023, the Company revised/updated:
− the Articles of Incorporation,
− the Internal Governance Regulation,
− the Charter of the Executive Committee, as well as
− policies pertaining to corporate governance and in particular:
✓ the Suitability and Nomination Policy for the Members of the Board of Directors,
✓ the Induction and Training Policy and Procedure for the Members of the Board of Directors,
CORPORATE GOVERNANCE STATEMENT
79 | ANNUAL FINANCIAL REPORT
✓ the Policy and Process for the Succession Planning of Non-Executive and Independent Non-Executive Members of the
Board of Directors,
✓ the Policy for the Succession Planning of Senior Executives and Key Function Holders,
✓ the Remuneration Policy of the Members of the Board of Directors as per the provisions of Law 4548/2018,
✓ the Group Benefits and Corporate Expenses Policy,
✓ the Senior Executives Severance Payment Policy,
✓ the Expenses Policy for the Non-Executive Members of the Board of Directors,
in order for them to be fully aligned with the current regulatory framework and with the most recent best practices of corporate
governance.
Further to the above, the Company revised the Charters of the Board of Directors and its Committees (i.e. Audit Committee, Risk
Management Committee, Remuneration Committee and Corporate Governance, Sustainability and Nominations Committee) as
well as the Remuneration Policy for Alpha Services and Holdings and its Group which will be approved by the Board of Directors
within the first quarter of 2024. The Policy for the Evaluation of Senior Executives and Key Function Holders was discussed and
approved by the Board of Directors of the Company at the meeting of January 2024.
4. Corporate Governance at Group Level
During 2023, the Board Committees of the Company met with the Board Committees of the Subsidiaries. Further to the above, the
Board of Directors and its Committees reviewed the Subsidiaries’ Boards of Directors and Committees Annual and Semi-Annual
Activity Reports regarding the fulfillment of their responsibilities. Moreover, they discussed matters related to the Board structure
and practices on corporate governance. Further to the above, the Board of Directors through the Corporate Governance,
Sustainability and Nominations Committee was informed of changes in the Subsidiaries’ Boards of Directors and Committees.
5. 2023 Highlights
Landmark agreement between Alpha Services and Holdings S.A. and UniCredit
On October 23, 2023 the CEO of the Company announced a strategic partnership with UniCredit S.p.A., the largest Italian bank
and one of the major banking groups globally. It is a landmark agreement in line with the implementation of the Strategic Plan and
with the objective to create value for the Shareholders and for the economies where it operates.
The agreement concerned:
1. The submission by UniCredit of an offer to the Hellenic Financial Stability Fund (HFSF) for the total stake it held in Alpha
Services and Holdings S.A. This was a proposal of high strategic importance, supporting the strategic planning of the State with
regard to the HFSF divestment from the Greek banks, which, as it was accepted by the HFSF, allowed Alpha Bank to return to full
private ownership, while also becoming the only bank in Greece with a strategic investor participating in its capital.
2. The fact that Alpha Bank and UniCredit joined forces in Romania by merging the two subsidiaries in the country to create the top
3 player in the Romanian banking market. This decision was consistent with the objective to best leverage assets and maximize
value creation, by releasing capital, while also maintaining strong revenue streams through a 9.9% stake
in the new, larger bank and capitalizing on the positive prospects of the Romanian economy. As a result, the Alpha Bank Romania
Customers will gain access to a broader range of services and products, while the Employees will join the group of a strong
international player from Europe.
3. A commercial partnership with UniCredit in asset management, specifically through a joint venture in mutual fund
distribution and bancassurance, whereby UniCredit acquired a 51% equity interest in AlphaLife Insurance Company S.A.
This partnership was fully aligned with the objectives of the Company. In addition, the strategic partnership with UniCredit
allowed the Company to utilize the former’s strong expertise, products portfolio and extended network in Central and
Eastern Europe, in order to further develop the penetration capabilities of the customers to these markets.
4.
HFSF divestment from Alpha Services and Holdings S.A.
On 13.11.2023 the HFSF announced the successful disposal of its entire stake in the share capital of Alpha Services and Holdings
S.A. to UniCredit S.p.A., pursuant to a share purchase agreement entered into between the HFSF and UniCredit on 12.11.2023
and following the completion of a competitive process launched by the HFSF on 30.10.2023, which was triggered by the relevant
binding offer of UniCredit received by the HFSF on 23.10.2023 for the acquisition of HFSF’s entire stake in the share capital of
Alpha Services and Holdings. Upon completion of the abovementioned sale, the HFSF has no longer the special rights provided for
in Law 3864/2010, as in force, including the right to appoint a representative in the Board of Directors and Committees. Therefore,
as of 15.11.2023 Mr. Johannes Herman Frederik G. Umbgrove’s appointment by the HFSF as its representative in the Board of
CORPORATE GOVERNANCE STATEMENT
80 | ANNUAL FINANCIAL REPORT
Directors and its Committees has been revoked and his mandate with the HFSF has been terminated. The same applies for the
HFSF’s Observer. Mr. Johannes Herman Frederik G. Umbgrove remains a Non-Executive Member of the Board of Directors.
6. 2024 Priorities
The main Corporate Governance priorities for 2024 include but are not limited to those presented below:
− Further enhancement of diversification in the Board of Directors and in the Management.
− Review of the Company’s Corporate Governance documents taking into consideration the regulatory developments.
− Provision of further specialized training to the Members of the Board of Directors.
− Monitoring of the adoption of corporate governance practices by the Subsidiaries.
− Approval of new policies following the developments in the field of corporate governance.
− Monitoring of the implementation of the Succession Policy.
− Monitoring of the implementation of the Variable Remuneration Framework.
C. INTERNAL CONTROL SYSTEM (ICS)
The Internal Control System, on which the Company places great emphasis, comprises all mechanisms and procedures relating to
all the activities of the Company at an individual and a Group level and is designed to ensure:
−
the consistent implementation of the business strategy with an effective utilization of the available resources,
−
the identification and management of all risks undertaken to achieve business objectives,
−
the completeness and the reliability of the data and information required for the accurate and timely determination of the
financial situation of the Company and the generation of reliable Financial Statements,
−
the compliance with the current regulatory framework, the internal regulations, the rules of ethics,
−
the prevention and avoidance of erroneous actions that could jeopardize the reputation and interests of the Company, the
Shareholders and those transacting with it,
−
the effective operation of the IT systems in order to support the business strategy and the secure circulation, processing and
storage of critical business information.
The Internal Control System is structured along the three lines of defense model: the business and operational or support Units
(first line); the risk management and compliance functions (second line) and the internal audit function (third line).
The Audit Committee is responsible for the monitoring of financial reporting processes, the effective operation of the internal control
and risk management systems as well as for the supervision and monitoring of the performance and independence of the Statutory
Certified Auditors.
The Audit Committee cooperates with the Risk Management Committee regarding the oversight of certain key areas of risk and
capital management and their repercussions on the Internal Control System.
The evaluation of the adequacy and effectiveness of the Internal Control System of the Company is conducted:
a. On a continuous basis through the review of audits conducted by the Internal Audit Unit at a Group level, following a risk-
based audit plan, and the activity performed by the Compliance Unit as well as the Risk Management Unit.
b. Regularly, by the Audit Committee of the Board of Directors, on the basis of the relevant data and information received
through the year from the Internal Audit Unit, the Compliance Unit, the Risk Management Unit and the Management as
well as on the basis of the findings and observations from the External Auditors and the Regulatory Authorities.
c. Periodically by external auditors, other than the Statutory Certified Auditor, who are highly experienced individuals in the
field of internal control (external auditors or special advisors), who are independent of the Group.
With regard to the financial reporting and accounting processes in particular, the Company has in place policies and procedures
established in accordance with the current legislation and the accounting standards in force, as defined in the International
Financial Reporting Standards (IFRS), that have been adopted by the European Union, pursuant to Regulation (EC) No 1606/2002
of the European Parliament and of the Council of 19 July 2002. The primary procedures followed by the Company in order to
ensure control effectiveness and to prevent errors and fraud include the segregation of duties and the four-eyes principle, based on
shared responsibilities for key processes to more than one persons or Divisions and on the approval of certain activities by at least
two people.
CORPORATE GOVERNANCE STATEMENT
81 | ANNUAL FINANCIAL REPORT
The accounting system of the Company and the Group is supported by appropriate IT systems which have been adapted to the
business requirements of the Company and the requirements of the accounting standards.
Accounting and control procedures have been established in order to ensure the completeness, correctness and the accuracy of
the entries in the accounting books as well as the completeness and validity of the Financial Statements.
1. Internal Audit Function
The purpose of the Internal Audit Function is to provide independent, objective assurance and consulting services designed to add
value and improve the operations at Group level. The mission of the Internal Audit Function is to enhance and to protect the
organizational value by conducting risk-based audits and by reviewing the internal governance arrangements, processes and
mechanisms to ascertain that they are sound and effective, implemented and consistently applied as well as to provide objective
assurance, advice and insight.
The Internal Audit Function helps accomplish the Company’s objectives by providing a systematic and disciplined approach to
evaluate and improve the effectiveness of governance, risk management and control processes.
The Internal Audit Function conforms to the Institute of Internal Auditor’s International Professional Practices Framework (IPPF).
Furthermore, it applies the relevant regulatory framework, including Articles 15-16 of Law 4706/2020 and the European Banking
Authority (EBA) guidelines on internal governance under Directive 2013/36/EU section 22, on the Internal Audit Function.
The Head of the Internal Audit is appointed by the Board of Directors following a proposal by the Audit Committee and reports
functionally to the Board of Directors, through the Audit Committee. For solely administrative purposes the Head of the Internal
Audit reports to the Chief Executive Officer. He is in charge of managing the independent Internal Audit Function. The performance
of the Head of the Internal Audit is reviewed and evaluated by the Board of Directors through the Audit Committee. The Audit
Committee may consult with the CEO and others on this purpose.
The Head of the Internal Audit has unrestricted access to the Board of Directors and the Audit Committee, communicates and
interacts directly with them, including in private meetings without the Management being present, where necessary. This should not
prevent the Head of the Internal Audit from reporting within the regular reporting lines as well.
The Board of Directors authorizes and the Audit Committee supports the Internal Audit Function to:
−
Have unfettered institution-wide, full, free and unrestricted access to all functions, records, documents, information,
buildings, property and Personnel of the Group pertinent to carrying out any engagement, subject to accountability for
confidentiality and safeguarding of records and information. This should include access to the Management Information
Systems and the Minutes of the meetings of all Committees and decision-making bodies.
−
Have sufficient resources and ensure that the qualification of the Internal Audit Function’s staff members and resources, in
particular its auditing tools and risk analysis methods, are adequate for the Company’s size and locations, as well as for
the nature, scale and complexity of the risks associated with its business model, activities, risk culture and risk appetite.
The Internal Auditors maintain an unbiased mental attitude that allows them to perform engagements objectively and in such a
manner that they believe that no quality compromises are made in their work product and that they do not subordinate their
judgment on audit matters to others. The Internal Auditors have no operational responsibility for or authority over any of the
activities audited. Furthermore, they are not related with the activities they are assigned to audit from an organizational perspective.
The Head of the Internal Audit confirms to the Board of Directors and to the Audit Committee, at least annually, the organizational
independence of the Internal Audit Function.
The scope of internal audit activities encompasses, but is not limited to, objective examinations of evidence for the purpose of
providing independent assessments to the Audit Committee and to the Board of Directors on the adequacy and effectiveness of
governance, risk management and control processes for the Company.
The Head of the Internal Audit has the responsibility to:
− Submit, at least annually, a risk-based Internal Audit Plan on the basis of the annual risk assessment process for approval
to the Board of Directors following the endorsement thereof by the Audit Committee.
− Review and adjust the Internal Audit Plan, as necessary, in response to changes in the Alpha Services and Holdings S.A.
internal and external business risks, operations, programs, projects, systems and controls.
− Communicate to the Board of Directors and to the Audit Committee any significant changes to the Internal Audit Plan for
approval.
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82 | ANNUAL FINANCIAL REPORT
− Ensure execution of the Internal Audit Plan, including the establishment of objectives and scope, the assignment of
appropriate and adequately supervised resources, the documentation of work programs and testing results and the
communication of engagement results and recommendations to appropriate stakeholders.
− Follow up the engagement findings and corrective actions and submit regularly to the Board of Directors and to the Audit
Committee written reports on major identified deficiencies as well as any corrective actions not effectively implemented.
− Ensure that the Internal Audit Function applies and upholds the principles of integrity, objectivity, confidentiality and
competency and periodically report conformance with the IIA’s Code of Ethics to the Board of Directors and to the Audit
Committee.
− Ensure that the Internal Audit Function collectively possesses or obtains the knowledge, skills and other competencies
needed to meet the requirements set by the Internal Audit Charter.
− Communicate to the Board of Directors and to the Audit Committee the impact of resource limitations on the Internal Audit
Plan.
− Ensure that emerging trends and successful practices in internal auditing are considered.
− Establish and ensure adherence to policies and procedures designed to guide the Internal Audit Function.
− Ensure adherence to the Company’s relevant policies and procedures, unless such policies and procedures conflict with
the Internal Audit Charter. Any such conflicts will be resolved or otherwise communicated to Board of Directors and the
Audit Committee.
− Ensure conformance of the Internal Audit Function with the standards, with the following qualifications:
a. If the Internal Audit Function is prohibited by law or regulation from conformance with certain parts of the standards,
the Head of the Internal Audit will ensure appropriate disclosures and conformance with all other parts of the
standards.
b. If the standards are used in conjunction with requirements issued by other Supervisory Authorities, the Head of the
Internal Audit will ensure that the Internal Audit Function conforms with the standards, even if it also conforms with
the more restrictive requirements set by other Supervisory Authorities and local laws and regulations.
2. Compliance Function
The Compliance Function is responsible for the monitoring of the Compliance Risk at the level of the Company and the Group, as
per the duties and responsibilities included in its Charter.
Being part of the Second Line of Defense, the Compliance Function is responsible for identifying and assessing the compliance risk
and for informing the competent bodies accordingly as well as for proposing appropriate measures to address the identified
weaknesses and for monitoring their implementation.
Compliance Risk is the risk that affects the business model, the reputation and the financial status of the Company, due to the
failure to comply with the regulatory framework applicable to the Company, the regulatory Acts issued by the Authorities, the Code
of Conduct and Ethics as well as the internal procedures.
In terms of governance, the Compliance reports functionally through the Audit Committee to the Board of Directors and
administratively to the Chief Risk Officer. It constitutes an independent function and is empowered with unrestricted access to data
and information necessary to carry out its mission. The Management ensures the availability of the required resources which enable
the Compliance Function to perform its duties.
The Compliance Function is subject to audits or reviews carried out by the Competent Authorities and supervisors [Single
Supervisory Mechanism (SSM), Bank of Greece, Hellenic Capital Market Commission] and by the Internal Audit.
The Compliance Function is responsible for:
• Representing the Company to supervisory and other authorities;
• Reporting to the Management regarding the compliance level of the Company and proposing actions for enhancing
adherence of the Company to the regulatory framework requirements;
• Establishing and implementing appropriate and up-to-date policies and procedures, with a view to achieving the Company’s
compliance with the applicable regulatory framework;
• Assessing the complexity and nature of the Company's activities, including the development and promotion of new
products and business practices, when introducing relevant policies and procedures;
• Ensuring the timely, complete and continuously effective management of the relevant Compliance risks, by following a
systematic methodology and by introducing enhancements in case of discrepancies. To this end, it designs performance
and risk indicators, in order to measure the Compliance residual risk and to frame the Compliance Risk Appetite;
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• Monitoring the adherence to the contextually applicable regulatory framework and the adoption of the Group Policies from
the Subsidiaries in order to facilitate a harmonized Compliance approach among them.
• Ensuring the continuous update of the Officers regarding the applicable regulatory framework, through training based on
compliance-oriented programs.
The Compliance Function drafts the Annual Compliance Program which is reviewed by the Audit Committee for endorsement and
is subsequently submitted for approval to the Board of Directors.
It cooperates, inter alia, with the Internal Audit, the Legal, the Risk Management and Business area when appropriate, to deal with
compliance issues under a common approach.
The Head of Compliance is the Group Compliance Officer and is responsible for:
− assessing the Company’s level of compliance with the requirements of the legal and regulatory framework and with the
internal procedures as well as for providing the relevant information to the Management;
− supervising the Personnel that performs tasks involving Compliance matters and ensuring their adequate training and
continuous information on relevant developments;
− continuously monitoring trends, best practices, laws and regulations on Compliance matters;
− supervising the Subsidiaries’ Compliance functions;
− reporting to the Audit Committee and to the Board of Directors and informing the Competent Authorities on Compliance
matters;
− ensuring the proper organization and operation of the Compliance as well as the organization and coordination of the
Compliance Units and the Compliance Officers of the Subsidiaries, providing respective guidelines.
3. Risk Management Function
The Company commits to achieving a strong control environment and a distinctive risk management capability in order to meet its
performance objectives and to achieve continuous improvement in the area of risk management.
The Risk Management Function is independent from any executive activities and Units.
All Risk Management Policies and Frameworks are approved by the appropriate Committees and are based on the following
guiding principles:
• risk-appetite driven;
• an integral part of the business strategy and the decision-making;
• responsibility driven;
• transparent through clear communication lines;
• documented appropriately, ensuring that all risk identification, assessment, monitoring, reporting, control/mitigation,
activities and systems perform as required;
• structured appropriately, ensuring that adequate information and reporting mechanisms are provided to all levels of the
Management.
The Risk Management Framework, policies and procedures are reviewed annually. The Risk Management Framework is based on
an extensive set of risk policies. The main objective of the Risk Management Framework in place is to ensure that the outcomes of
risk-taking activities are consistent with the Group’s strategy and risk appetite and that there is an appropriate balance between risk
and reward in order to maximize shareholder returns. The Risk Appetite Framework, which constitutes a major component of the
Risk and Capital Strategy, allows the Company to combine the corporate and business strategy with the financial and capital
planning and with the Risk Management Framework.
The risk analysis is integrated into the Company’s annual strategic planning process and strategic plan goals are reviewed on the
basis of the risk policy.
The risk management is spread across three different levels, in order to create a Three Lines of Defense Model in which the
Company has integrated Climate and ESG Risk through the establishment of a dedicated horizontal function. The duties and
responsibilities of all lines of defense are clearly defined and separated and the relevant roles are sufficiently independent.
Τhe Chief Risk Officer reports to the Risk Management Committee and, through the latter, to the Board of Directors. Moreover, he
has the overall responsibility for all the risk issues outlined in the relevant risk policies and additionally supervises and coordinates
the risk management activities of the Company.
His main responsibilities are as follows:
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• Ensures that appropriate risk management policies are in place and in line with the Group’s risk management strategy, risk
appetite and business objectives and oversees the risk policies implementation;
• Ensures that there are appropriate risk management tools and methods in place, including the models for risk
identification, assessment, monitoring, controlling, reporting and stress testing;
• Ensures that the Company adequately embeds all risk types in the risk appetite statement and framework, business
strategy and risk management framework;
• Ensures compliance with all internal and regulatory risk limits as well as that any deviations from the risk appetite are
timely communicated to the Risk Management Committee;
• Ensures that the Company holds adequate economic and regulatory capital;
• Participates in the evaluation of the Company’s economic and regulatory capital by the regulatory authorities;
• Monitors the “troubled assets” portfolio and recommends impairment levels;
• Provides the Risk Management Committee, on a regular basis, with adequate reporting in order to enable the Committee
to properly advise the Board of Directors on the Group’s exposure, profile and strategy;
• Submits to the Board of Directors annually, through the Risk Management Committee, reports in relation to the Company’s
Risk Management activities across risk types.
The Audit Committee and the Risk Management Committee, in a joint session, provide oversight of certain key areas of risk and
capital management and their repercussions on the Internal Control System and they review issues relevant to the remediation
plans related to regulatory/supervisory assessments, operational risk and other issues of importance and common interest.
4. Periodical Assessment of Internal Control System
The Company has endorsed the Policy and Procedure for the External Periodical Assessment of the Internal Control System,
according to the respective legal and regulatory framework (Law 4706/2020, article 14).
The abovementioned Policy aims at setting the standards for the assessment perimeter, the external auditor assessment
procedure, the characteristics required from the auditors, the audits’ periodicity, the assessment report contents and recipients.
The Audit Committee is responsible for monitoring the Internal Control System Policy and Procedures.
The Internal Control System assessment is carried out every three years by independent external auditors and upon the
conclusion of the assessment a Report is being prepared where the auditors’ findings are outlined along with their analysis and
conclusions. The latest assessment report was issued by Mazars in June 2023, covering the period 2020-2022, and it was
submitted to the Board of Directors, through the Audit Committee, and then to the Bank of Greece. As a result of their
assessment nothing came to their attention that causes them to believe that there are material weaknesses affecting the
adequacy of Company’s Internal Control System.
D. SHAREHOLDERS
1. General Meeting of Shareholders
The General Meeting of Shareholders is the supreme governing body of the Company and resolves on all corporate affairs, in
accordance with the applicable legislation. The resolutions of the General Meeting, which are in accordance with the applicable
law, shall be binding upon absent and dissenting Shareholders as well.
The General Meeting of Shareholders shall be convened by the Board of Directors, or otherwise as stipulated by the applicable
legislation, at the Company’s registered office or in the district of another municipality within the prefecture of the registered office or
another contiguous municipality to the registered office or in the registered office of the Athens Exchange in which the Company’s
shares are listed for trading, at least once in the course of the fiscal year at the latest by the tenth calendar day of the ninth month
following the end of the fiscal year (Ordinary General Meeting) or on an ad hoc basis.
The General Meeting shall be presided over provisionally by the Chair of the Board of Directors and he/she shall name provisional
secretaries and ballot-collectors, until the list of Shareholders with a right to participate in the General Meeting has been ratified and
the regular Presidium, i.e. the permanent Chair as well as the permanent secretaries and the ballot-collectors, is elected by the
General Meeting.
Persons having the Shareholder capacity on the record date, as defined by the legislative framework, are entitled to participate in
the General Meeting. Shareholders must timely and properly abide by the provisions of the law and the relevant invitation to the
General Meeting. In any other case, their participation will be allowed only upon permission from the General Meeting.
Shareholders participate in the General Meeting either in person or by proxy. Minors, persons under judicial guardianship and legal
entities shall be represented in accordance with the applicable legislation. The appointment and revoking or replacement of
representatives is effected in writing (via private or public document) or, upon a resolution by the Board of Directors, via electronic
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mail and/or other electronic means of communication, in accordance with the instructions included in the Invitation to the General
Meeting.
Following a resolution of the Board of Directors and pursuant to the applicable legislation, the proceedings of the General Meeting
may take place via teleconference.
Following a resolution of the Board of Directors, it may be resolved that Shareholders may participate in the General Meeting via a
Mail Vote, i.e. by mail or by electronic means, prior to the General Meeting, in accordance with the applicable legislation and with
the instructions included in the invitation to the General Meeting.
The Members of the Board of Directors and the auditors of the Company may attend the General Meeting. Upon permission
granted by the Chair of the General Meeting, the presence of other persons not having the Shareholder capacity may be allowed.
During 2023 one General Meeting of Shareholders was held.
Ordinary General Meeting of Shareholders on 27.7.2023
1
out of a total of 2,348,908,567 common, registered, dematerialized shares with voting rights
Voting results and resolutions
All the items of the agenda were approved by the Ordinary General Meeting of Shareholders.
The resolutions approved and the valid votes are presented below:
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ITEM
AGENDA
% VALID VOTES
1
Approval of the Annual Separate and Consolidated Financial Statements of the
financial year 2022 (1.1.2022 - 31.12.2022), together with the relevant reports of
the Board of Directors which are accompanied by the Statutory Certified Auditors’
Report.
99.84%
2
Approval of (a) the netting-off of the Retained Earnings/(Losses) against the
Statutory Reserve, the Special Reserve of article 31 of law 4548/2018 and the
Share Premium and (b) the potential distribution of the intragroup dividend
reserve.
100.00%
3
Approval of the overall management for the financial year 2022 (1.1.2022 -
31.12.2022) as per article 108 of law 4548/2018 and discharge of the Statutory
Certified Auditors for the financial year 2022, in accordance with article 117(1)(c)
of law 4548/2018.
99.80%
4
Appointment of Statutory Certified Auditors for the financial year 2023 (1.1.2023 -
31.12.2023) and approval of their fee.
100.00%
5
Approval of the Members of the Board of Directors’ remuneration for the financial
year 2022 (1.1.2022 - 31.12.2022).
99.97%
6
Approval, in accordance with article 109 of law 4548/2018, of the advance
payment of remuneration to the Members of the Board of Directors for the
financial year 2023 (1.1.2023 - 31.12.2023).
99.96%
7
Deliberation and advisory vote on the Remuneration Report for the financial year
2022, in accordance with article 112 of law 4548/2018.
99.97%
8
Approval of the updated and amended Remuneration Policy of the Members of
the Board of Directors in accordance with articles 110 and 111 of law 4548/2018.
99.67%
9
Submission of the Activity Report of the Audit Committee for the year 2022, in
accordance with article 44 of law 4449/2017.
Non-Voting Item
10
Submission of the Report of the Independent Non-Executive Members, according
to article 9(5) of law 4706/2020.
Non-Voting Item
11
Approval of the updated and amended Suitability and Nomination Policy for the
Members of the Board of Directors.
100.00%
12.a
Announcement on the election by the Board of Directors of two new Members
of the Board of Directors in replacement of Members who have tendered their
resignation.
Non-Voting Item
12.b
Decision on the appointment of Independent Non-Executive Members of the
Board of Directors.
Itemized ballot
12.b.1
Diony C. Lebot
99.83%
12.b.2
Panagiotis I.-K. Papazoglou
99.83%
13
Determination of the type of the Audit Committee, its term of office, the number
and the qualifications of its Members as per article 44 par. 1 case b) of law
4449/2017.
99.83%
14
Publication to the Ordinary General Meeting of the Shareholders of the Company,
according to article 97 par. 1 (b) of law 4548/2018, of any cases of conflict of
interest and agreements of the financial year 2022 which fall under article 99 of
law 4548/2018.
Non-Voting Item
15
Establishment of a Share Buyback Program in accordance with article 49 of law
4548/2018 and authorization to the Board of Directors for its implementation.
100.00%
16
Establishment, in accordance with article 114 of law 4548/2018, of a program for
free distribution of shares of the Company for Members of the Management and
Employees of the Company and its affiliates and granting of authorization to the
Board of Directors in relation to the program.
99.67%
17
Granting of authority, in accordance with article 98 par. 1 of law 4548/2018, to the
Members of the Board of Directors and the General Management as well as to
Managers of the Company to participate in the boards of directors or in the
management of companies having purposes similar to those of the Company.
100.00%
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The Resolutions adopted at the Ordinary General Meeting of Shareholders held on 27.7.2023 have been posted on the Company’s
website (https://www.alphaholdings.gr/en/investor-relations/general-meetings).
2. Communication with Shareholders, Investor Roadshows and Corporate Governance Meetings
In order to enhance the active participation of the Shareholders in the General Meetings and the genuine interest in issues relating
to its operation, the Company applies procedures of active communication with them and establishes the appropriate conditions so
that the policies and strategies adopted are based on the constructive exchange of views with them.
The Company enhances its relations with proxy advisors and investors who focus on corporate governance, providing them, where
necessary, with further information so as to facilitate their decision-making process on corporate governance matters of the
Company in view of the General Meetings of Shareholders.
In particular, given the increasing interest of investors and proxy advisors in corporate governance issues, bilateral meetings were
held throughout the year with representatives from proxy advisors, analysts and investors. It is noted that, in 2023, (from December
2022 to February 2023), twelve roadshows with ten investors and two international proxy advisors took place with the participation
of the Chair of the Corporate Governance, Sustainability and Nominations Committee and of Executives of the Company.
The roadshows focused mainly on the below elements:
✓ Strategic Overview,
✓ Corporate Governance (Board Structure/Board Effectiveness and Remuneration),
✓ Sustainability.
Through this initiative, the Company aimed at increasing awareness and understanding among the key Stakeholders of the
Company’s Sustainability initiatives, engaging with key Stakeholders and sustaining dialogue on sustainability issues,
strengthening relationship with ESG-focused Shareholders, demonstrating the Company’s progress on and commitment to
sustainable practices, collecting stakeholder feedback and identifying key concerns to shape the Company’s future strategy and
demonstrating the Company’s commitment to open dialogue, transparency and accountability.
Furthermore, during 2023 (from November to December 2023), in view of the Annual General Meeting of Shareholders of 2024,
seven roadshows took place with the participation of Members of the Board of Directors (the Chairs of the Corporate Governance,
Sustainability and Nominations Committee and of the Remuneration Committee) and of Executives of the Company. These
roadshows mainly focused on the below elements:
✓ Strategic Overview,
✓ Corporate Governance (Board Structure/Board Effectiveness and Remuneration),
✓ Sustainable Banking (Environmental Strategy and Sustainable Finance),
✓ Social Impact Strategy (Our People and Our Communities).
Moreover, the Company enhanced relations with Stakeholders who focus on corporate governance, providing them, where
necessary, with further information so as to assist their decision-making process, leading to further improving the Company’s
corporate governance, while also facilitating their voting recommendations on governance matters in view of the upcoming General
Meetings of Shareholders.
Following these meetings, the Company enhanced the information provided to the Institutional Shareholder Services (ISS)
database. As a result, the Company’s ISS rating during 2023 regarding governance improved from 6 (December 2021) to 3
(December 2023) (1 being the best score).
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3. Shareholder Structure
The share capital of the Company amounts to the total amount of Euro 681,992,324.59, divided into 2,351,697,671 common,
registered, dematerialized shares with voting rights, of a nominal value of Euro 0.29 each.
The above-mentioned share capital of the Company has resulted,
inter alia,
from the share capital increase pursuant to the
resolution of the Board of Directors of the Company as of 28.9.2023, in accordance with article 113 par. 3 of Law 4548/2018, in the
context of the implementation of the resolution of the Ordinary General Meeting of Shareholders of July 31, 2020 on the approval of
a Stock Options Plan, for the years 2020-2024, by the amount of Euro 808,840.16, by issuing and granting to the
Beneficiaries/Employees of the Company and its Affiliated Companies 2,789,104 common, registered, dematerialized shares of the
Company with voting rights, of a nominal value of Euro 0.29 each, whereby the difference between the offer price and the nominal
value of 2,648,860 shares, amounting to a total of Euro 26,488.60, was credited to the special account (share premium account)
under the title “issuance of shares above par value”.
E. ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG)
Commitment to Sustainability
The Company is committed to operating responsibly and with a long-term view of sustainable value creation for its Shareholders
and other Stakeholders, taking due account of the economic, social and environmental parameters of its activities, both in Greece
and in the other countries where it operates. As part of its Sustainability Strategy and based on the relevant laws, on international
guidelines and best market practices as well as on the Group’s policies, the Company has identified four primary Stakeholder
groups, namely, (i) Investors (as well as investment analysts and advisors), (ii) Customers, (iii) Employees and Society and (iv)
Official and Regulatory Authorities. Accordingly, the Company engages in an ongoing dialogue and collaboration with these
Stakeholders, in order to understand and address their expectations, needs and concerns in the most appropriate way possible.
As a result, the Company balances its profitability goals with the needs of its Customers and the Environment and Society as a
whole by integrating Environmental, Social and Governance (ESG) principles into its corporate strategy and operations and invests
in its Employees, its Network and its infrastructures to develop and place high-quality services and products on the market.
In the context of the responsible operation, the Company developed, in 2023, a comprehensive Sustainability Strategy in order to
prioritize its resources appropriately and to be able to play a significant role in the journey towards sustainable development.
Therefore, the Company has committed to:
• Support an environmentally sustainable economy;
• Foster healthy economic and societal progress;
• Ensure robust and transparent governance.
These commitments are supported by concrete targets and KPIs, which are presented in the Non-Financial Report and the
Sustainability Report of Alpha Services and Holdings S.A.
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Environmental Stewardship
In 2023, the most notable manifestation of the commitment to a sustainable economy was the decision to become Alpha Bank, the
first Greek Bank to join the NetZero Banking Alliance and to achieve Net Zero greenhouse gas emissions by 2050.
At the same time, the Company continued to implement the ESG Workplan, which aims to integrate sustainability and climate risk
criteria into the decision-making processes, including strategy, risk management, lending and operations.
As a result, the portfolio of green loans and investments increased and supported projects that enable renewable energy
generation and contribute to a more sustainable economy.
Additionally, the Company continued its journey towards reducing its own carbon footprint. Significant investments were made in
green building technologies, resulting in lower energy consumption across Branches and Business Centres.
Finally, the Company focused on increasing the awareness on ESG and climate risks by providing Customer Relationship
Managers with training and support on sustainable finance. It is noted that, in 2023, 80% of the Company’s employees in
Wholesale Banking business were trained on ESG issues.
Social Responsibility
The Company has adopted and integrated the Corporate Responsibility Policy, as part of its strategy for sustainable development
and commitment to operating responsibly as well as meeting best practice standards in its activities. In order to enhance social
responsibility and integrate it into the Group’s Principles and Values, the Company implements internationally-recognized best
practice on sustainable development, including the Organization for Economic Co-operation and Development (OECD) Guidelines
for Multinational Enterprises on Responsible Business Conduct, the Core Conventions of the International Labour Organization
(ILO) and the Universal Declaration of Human Rights (UDHR), as well as complying with all legal and regulatory obligations.
The Company responsibly implements several policies with regard to the protection and promotion of its Human Resources, as
described in detail in the Non-Financial Report. The health and development of its Employees is a priority and the Company
provides a healthy work environment, in which its Employees broaden their knowledge and skills and contribute to the development
of new products and services in an environment of diversity and inclusion, where every individual feels valued and respected.
Moreover, the Company enhances financial inclusion and supports the Greek economy by providing access to financing, offering
products and services with specific social and environmental characteristics and supporting its Customers in their transition to more
sustainable business models.
Finally, the Company’s commitment to social welfare is reflected in its numerous community outreach programs.
Robust Governance
The Group ESG Governance model, which ensures the effective management of Sustainability issues, was further enhanced by
the establishment of expert teams with advanced skills in specific areas, such as the Climate and ESG Risk Team and the
Sustainability Strategy lead in the Strategy and Investments Business Area.
At the Board level, the Corporate Governance, Sustainability and Nominations Committee acts as the ultimate liaison and
responsible Board Committee for all sustainability/ESG issues. During 2023, the Corporate Governance, Sustainability and
Nominations Committee met 11 times.
At the Executive Management level, a key part of the ESG Governance structure is the Group Sustainability Committee, which
oversees ESG topics, steers the Group’s Sustainability Strategy, oversees its implementation and supports the Board of Directors
in their oversight of Climate & ESG Risks and Sustainability in general. The committee membership includes six Chiefs as
permanent members and eight additional members at senior executive level. The Group Sustainability Committee met nine times
during 2023 to discuss, among others, the progress in ESG integration and the corresponding action plan to meet the supervisory
expectations. The Committee Members examined the Company’s Sustainability Strategy and commercial implications as well as
the Sustainable Finance Framework operationalization and developments with regard to the IT systems’ integration. The Members
of the Committee were also informed about the materiality assessment of climate risk, the ESG training provided to the Company’s
Employees and the progress of international subsidiaries in integrating ESG criteria in their processes. They also exchanged views
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on the measurement of financed emissions and climate strategy target setting and reviewed the Company’s disclosures. The
Committee approved the ESG Operating Model, the risk identification and materiality assessment of Climate Risk, the updated
policies and the sustainability-related disclosures.
The 2024 ESG Workplan was presented to the Committee members with priority initiatives to further integrate ESG issues into
strategy and planning, to advance the Company’s climate risk management, to support its Customers’ decarbonization efforts and
to meet regulatory expectations.
At the Operational level, the ESG Working Group is responsible for implementing key initiatives, led by the Group ESG Coordinator,
who also provides direction to Subsidiaries and other Units. The Bank’s Governance and Sustainability Business Area drives the
ESG agenda and ensures internal adoption of best practice across the Group.
The Climate, ESG and Enterprise Risk Management coordinates closely with the Governance and Sustainability Business Area on
ESG and climate-related issues as well as with the Supervisory Issues Management Business Area on risk-related input to
supervisory processes/submissions. Among others, the Climate, ESG and Enterprise Risk Management Business Area provides
expert guidance for ESG integration in the Risk Management Framework, supports consistency and adequacy of risk input across
risk types, reviews questionnaires in the borrower assessment process, designs assessment methodologies (e.g. for physical
climate risk) and is responsible for the risk-related aspects of strategy-setting and business planning.
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The Company’s organization and operation follow the best banking and business practices and are governed by the principles of
integrity, honesty, impartiality and independence, confidentiality and discretion, as provided for in the Company’s Code of Conduct
and Ethics and in the principles of Corporate Governance. Particular significance is attached to the identification, measurement and
management of risks undertaken, to the compliance with the legal and regulatory framework as in force and to transparency with
the provision of full, accurate and truthful information to the Company’s Stakeholders.
Future Outlook
Looking ahead, the Company remains committed to further integrating ESG considerations in its business decisions, innovating
and investing in products and services that advance sustainability, and expanding its ESG engagement with the Stakeholders,
providing a comprehensive understanding of its sustainability initiatives and progress.
F. BOARD OF DIRECTORS AND COMMITTEES
1. Board of Directors
The Board of Directors is responsible for the management of the Company’s affairs and its representation vis-à-vis third parties.
Further, it has the ultimate and overall responsibility for the Company and defines, oversees and is accountable for the
implementation of the governance arrangements within the Company that ensure effective and prudent management of the
Company. Among others, the Board of Directors:
a. has the overall responsibility for the Company and approves and oversees the implementation of the Company’s strategic
objectives, risk strategy, ESG strategy and internal governance;
b. ensures the integrity of the accounting and financial reporting systems, including financial and operational controls and
compliance with the law and relevant standards;
c. oversees the process of disclosure and communications;
d. is responsible for providing effective oversight of the Senior Management.
The Board of Directors consists of no less than nine and no more than fifteen Members (only odd numbers are allowed, while an
even number can be accepted temporarily for a justified reason), including Executive and Non-Executive Members, in accordance
with the provisions of the applicable legislation. The Independent Non-Executive Members are not less than 50% of the total
number of its Members. A legal entity may also participate in the Board of Directors as a Member, pursuant to article 77 par. 4 of
Law 4548/2018.
The tenure of the Members of the Board of Directors is quadrennial. It may be extended until the termination of the deadline for the
convocation of the next Ordinary General Meeting and until the respective resolution has been adopted.
The Board of Directors meets whenever is required for the proper discharge of its responsibilities. At the beginning of each
calendar year, the Board of Directors adopts a calendar and an annual work plan. The work plan may be reviewed by the Board of
Directors on an ongoing basis, as needed.
The meetings of the Board of Directors are convened upon the invitation of the Chair of the Board of Directors or at the request of
at least two Members.
The Board of Directors may validly meet by videoconference or teleconference, in respect of some or all of its Members. In this
event, the invitation to the Members of the Board of Directors includes the necessary information and instructions for their
participation in the meeting.
The Board of Directors achieves a quorum and convenes validly when at least half of its Members plus one are present or
represented. In any case, the number of Members personally present either physically, by videoconference or by teleconference
may never be less than six.
At the Board of Directors’ meetings where the drafting of Financial Statements of the Company is discussed or the daily agenda of
which includes items, for the approval of which a decision by the General Meeting, by special quorum and a majority, is set forth, in
accordance with Law 4548/2018, a quorum of the Board of Directors is achieved if at least two Independent Non-Executive
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Members are present. In case of unjustified absence of an Independent Member at two, at least, consecutive meetings of the
Board of Directors, such Member is considered to have resigned. Such resignation is ascertained by a decision of the Board of
Directors, which proceeds with the replacement of the Member.
The resolutions of the Board of Directors shall be passed by absolute majority of the Members present or duly represented, unless
otherwise stipulated by the Company’s Articles of Incorporation or the law. In case there is no unanimous decision, the views of the
minority shall be recorded in the Minutes.
Subject to the respective provisions of the related legal and regulatory framework and the Company’s Articles of Incorporation, the
specific duties and responsibilities as well as the principles and the framework for the proper operation of the Board of Directors
are set out in its Charter, which is posted on the Company’s website (https://www.alphaholdings.gr/en/corporate-
governance/administrative-structure/board-of-directors).
During 2023, the following changes took place with regard to the composition of the Board of Directors and its
Committees:
The Board of Directors, following a relevant recommendation by the Corporate Governance, Sustainability and Nominations
Committee, at its meeting held on 29.6.2023 resolved on the election of Ms. Diony C. Lebot and Mr. Panagiotis I.-K. Papazoglou as
Independent Non-Executive Members of the Board of Directors of the Company with effect as of 27.7.2023, in replacement of the
Independent Non-Executive Members Messrs. Richard R. Gildea and Shahzad A. Shahbaz respectively.
The Ordinary General Meeting of 27.7.2023, following a relevant proposal by the Board of Directors, resolved on the appointment
of Ms. Diony C. Lebot and Mr. Panagiotis I.-K. Papazoglou, who fulfill the independence criteria according to article 9 of law
4706/2020, as Independent Non-Executive Members for the rest of the tenure of the Board of Directors of the Company,.
In particular, the individual as well as the collective suitability was assessed and reviewed, considering:
− the evaluation of the collective and individual capabilities of the Board of Directors,
− the skills, experience and knowledge, along with the qualifications of the Members of the Board of Directors as well as
their CVs,
− the other professional commitments of the Members of the Board of Directors,
− the provisions of the applicable regulatory and legislative framework, the approved Suitability and Nomination Policy for
the Members of the Board of Directors of the Company, the Diversity Policy of the Company, the Hellenic Corporate
Governance Code, determining that, following the election of the two new Board Members:
✓ the level of gender diversity shall be above the minimum legal requirements (i.e. 38.5%, exceeding the 25% legal
requirement, rounded to the previous integer, pursuant to article 3 of law 4706/2020),
✓ there is a significantly higher than set by applicable law number of proposed Independent Non-Executive
Members, ensuring a high level of independence on the Board and its Committees (8 out of 13, i.e. 62%), and
✓ the suitability criteria set out in the current regulatory framework and the Company’s Suitability and Nomination
Policy for the Members of the Board of Directors are met.
More specifically, it was determined that the new Members of the Board of Directors are adequately qualified, in terms of
knowledge and skills, including academic and professional qualifications, their experience and background, to perform the duties
assigned to them, as well as pursuant to the requirements of their position. Furthermore, for each proposed Board Member her/his
honesty and integrity, good reputation, sufficiency of time to be allocated in discharging her/his duties as well as the absence of any
conflict in relation to her/his election were ascertained.
It is noted that, in accordance with the provisions of the regulatory and legislative framework applying to the Company, the
appointment of new Board Members is subject to approval and constant review by the European Central Bank (ECB), in the
framework of the Single Supervisory Mechanism (SSM).
CORPORATE GOVERNANCE STATEMENT
93 | ANNUAL FINANCIAL REPORT
The Members of the Board of Directors comply with the stipulations of article 83 of Law 4261/2014 on the combination of
directorships, as they do not hold more than one of the following combinations of directorships at the same time: (a) One Executive
directorship and two Non-Executive directorships; (b) Four Non-Executive directorships, excluding directorships in organizations
which do not pursue predominantly commercial objectives (e.g. non-profit, charities). It is noted that directorships held within the
same group are regarded as one directorship (see table below in “3. Professional commitments of the Members of the Board of
Directors”).
The Corporate Secretariat and Governance Policies Business Area supports the functionality of the Board of Directors, its
Committees and its Members and, among others, coordinates the communications among the Members of the Board of Directors,
the Management and the Subsidiaries in order to achieve the effective flow of information to and from the Board.
2. CVs of the Members of the Board of Directors
The CVs of the Members of the Board of Directors are presented below and are also available on the Company’s website
(https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-practices/management/board-of-directors).
Chair
Vasileios T. Rapanos
Non-Executive Member
Chair of the Board of Directors since May 2014
Nationality: Greek
Born in Kos, Greece, in 1947.
Experience: He was Deputy Governor and Governor of the Mortgage Bank (1995-1998), Chairman of the Board of Directors of the
Hellenic Telecommunications Organization (1998-2000), Chairman of the Council of Economic Advisors at the Ministry of Economy
and Finance (2000-2004), member of the Board of Directors of the Public Debt Management Agency (PDMA) (2000-2004) as well
as Chairman of the Board of Directors of the National Bank of Greece and of the Hellenic Bank Association (2009-2012). In
October 2021 he was re-elected as Chairman of the Board of Directors of the Hellenic Bank Association, a position he retained until
November 2023.
Other positions of note: He is Professor Emeritus at the Faculty of Economics of the University of Athens and has been an
Ordinary Member of the Academy of Athens since 2016. Moreover, he is a member of the Board of Directors of the Foundation for
Economic & Industrial Research (IOBE), a member of the Board of Directors of the Biomedical Research Foundation Academy of
Athens (BRFAA) and Chair of the Board of Directors of the Alpha Bank Cultural Foundation.
Education: B.A., Athens School of Economics and Business (1975), Master’s in Economics, Lakehead University, Canada (1977),
PhD, Queen’s University, Canada
CORPORATE GOVERNANCE STATEMENT
94 | ANNUAL FINANCIAL REPORT
CEO
Vassilios E. Psaltis
Executive Member
Member of the Board of Directors since November 2018 and Chief Executive
Officer since January 2019
Nationality: Greek
Born in Athens, Greece, in 1968.
Experience: He held various senior management positions at ABN AMRO Bank’s Financial Institutions Group in London (1999-
2001) and at Emporiki Bank where he worked as Deputy (acting) Chief Financial Officer (2002-2006). He joined Alpha Bank in
2007. In 2010 he was appointed Group Chief Financial Officer (CFO) and in 2012 he was appointed General Manager. Through
these posts, he spearheaded capital raisings of several billions from foreign institutional shareholders, diversifying the Bank’s
shareholder base, as well as significant mergers and acquisitions that contributed to the consolidation of the Greek banking market,
reinforcing the position of the Bank.
Other positions of note: In 2019 he was elected member of the Institut International d' Études Bancaires (IIEB). He has been a
Member of the Board of Directors and of the Executive Committee of the Hellenic Federation of Enterprises (SEV) since July 2021
as well as Member of the Board of Directors of the Hellenic Bank Association (HBA) since October 2021.
Education: PhD in Banking, MA in Business and Banking, University of St. Gallen, Switzerland
Spyros N. Filaretos
Executive Member
Member of the Board of Directors since 2005
Nationality: Greek
Born in Athens, Greece, in 1958.
Experience: Ιn 1985, he joined Alpha Bank, where he held key positions at different branches and Divisions (Organization, Human
Resources and Treasury Management). He was appointed Executive General Manager in 1997 and General Manager in 2005.
From October 2009 to November 2020, he served as Chief Operating Officer (COO). In December 2020, he was appointed
General Manager - Growth and Innovation (new title as of 15.12.2023 Chief of Growth and Innovation).
Other positions of note: He is a Member of the Boards of Directors of Alpha Bank London Ltd and the Alpha Bank Cultural
Foundation as well as Chair of the Board of Directors of Efstathia J. Costopoulos Foundation. Moreover, he is a Member of the
Executive Committee.
Education: BA in Economics, University of Manchester, and MPhil in Development Economics and International Development,
University of Sussex
CORPORATE GOVERNANCE STATEMENT
95 | ANNUAL FINANCIAL REPORT
Efthimios O. Vidalis
Non-Executive Member
Member of the Board of Directors since May 2014
Membership of Board Committees: Member of the Remuneration Committee and of the Corporate Governance, Sustainability
and Nominations Committee
Nationality: Greek
Born in Washington, USA, in 1954.
Experience: He held several leadership positions for almost 20 years at Owens Corning, where he served as President of the
Global Composites and Insulation Business Units. He joined S&B Industrial Minerals S.A. in 1998 as Chief Operating Officer (1998-
2001), became the first non-family Chief Executive Officer (2001-2011) and served on the Board of Directors for 15 years. He was
a member of the Board of Directors of Future Pipe Industries (Dubai, U.A.E.) from 2008 to 2019 and of Fairfield-Maxwell Ltd (USA)
from 2018 to 2023. He was Chairman of the Board of Directors of the Greek Mining Enterprises Association (2005-2009) and
member of the Board of Directors of the Hellenic Federation of Enterprises (SEV) from 2006 to 2016, where he served as Vice
Chairman (2010-2014) and as Secretary General (2014-2016). Furthermore, he is the founder of the SEV Business Council for
Sustainable Development and was the Chairman thereof from 2008 to 2016.
Other positions of note: He was elected President of the Executive Committee of SEV during its Annual General Meeting held in
June 2020. He is a non-executive member of the Board of Directors of Titan Cement Company S.A. and an independent non-
executive member of Eurolife FFH Insurance Group Holdings S.A.
Education: BA in Government, Harvard University, MBA, Harvard Graduate School of Business Administration, USA
Elli M. Andriopoulou
Independent Non-Executive Member
Member of the Board of Directors since January 2022
Membership of Board Committees: Member of the Audit Committee and of the Corporate Governance, Sustainability and
Nominations Committee
Nationality: Greek
Born in Athens, Greece, in 1975.
Experience: She commenced her career at Citibank NA (Athens, Greece) (1996-1999) and then worked as a consultant (2000-
2003) at Mercer Management Consulting (currently Oliver Wyman), (USA). Afterwards, she re-joined Citibank International Plc
(Athens, Greece) (2004-2012), where she held various positions, including those of Sales Development Manager, Branch
Expansion Project Manager, Strategy and Development Manager, Customer Interaction Unit Head, Customer Advocacy and
Segment Management Head as well as Marketing Director. Subsequently, she served as Co-Chief Operating Officer (2013) at the
Stavros Niarchos Foundation, as Chief Operating Officer (2014-2015) of the Stavros Niarchos Foundation Cultural Center (SNFCC)
and as SNFCC Grant Manager (2016-2020).
Other positions of note: Since 2020, she has been Chairwoman and Managing Director of the SNFCC.
Education: BA in Psychology, American College of Greece (Deree College), MBA, Kellogg School of Management, Northwestern
University, USA
CORPORATE GOVERNANCE STATEMENT
96 | ANNUAL FINANCIAL REPORT
Aspasia F. Palimeri
Independent Non-Executive Member
Member of the Board of Directors since July 2022
Membership of Board Committees: Member of the Risk Management Committee and of the Remuneration Committee
Nationality: Greek
Born in Athens, Greece, in 1973.
Experience: She commenced her career at Citibank NA (Athens, Greece) (1995-1996) and Eurobank Cards S.A. (Athens, Greece)
(1996-1998). After acquiring her MBA, she joined McKinsey & Company (Athens, Greece), where she worked as an Associate
Consultant (2000-2001) and as a Junior Engagement Manager (2001-2002), supporting strategic projects for leading Greek banks
and corporates. Subsequently, she re-joined Eurobank Cards S.A. as the Group Product Manager for Loans (2002-2005) and as
the company’s Marketing Manager (2005-2010). She also served as the Cards Business Manager at Marfin Egnatia Bank (Athens,
Greece) (2010-2013) and as the Deposit and Investment Products Senior Director at Piraeus Bank (Athens, Greece) (2013-2016).
From 2016 to May 2022, she was the Country Manager for Greece, Cyprus and Malta at Mastercard, being responsible for the
market share growth and the strategic development of these markets.
Other positions of note: Since 2021, she has been a member of the Board of Directors of the Foundation for Economic &
Industrial Research (IOBE).
Education: BA in Accounting and Finance, American College of Greece (Deree College) (1995), MBA in Finance and Marketing,
Columbia Business School, New York, USA (2000)
Panagiotis I.-K. Papazoglou
Independent Non-Executive Member
Member of the Board of Directors since July 2023
Membership of Board Committees: Member of the Audit Committee and of the Remuneration Committee
Nationality: Greek
Born in Athens, Greece, in 1959.
Experience: He commenced his career in 1988 at Ernst & Whinney (which was renamed Ernst & Young in 1991), where he was a
Partner from 2000 to 2022. He acted as the Engagement (signing) Partner in a number of large Group audits, and the audit of a
number of large shipping groups, preparing them for listing on the US and the UK stock markets (2000-2005). He served as
Country Managing Partner, Head of Assurance at EY Bulgaria, Sofia (2005-2007) and as Head of Assurance at EY Romania,
Bucharest (2008-2010), where he led a number of major assurance and advisory audit projects for international clients.
Furthermore, he served as Managing Partner of EY (Ernst & Young) Greece and Southeastern Europe (Greece, Romania,
Bulgaria, Cyprus, Albania, Malta, Kosovo, FYROM, Moldova) from June 2010 to December 31, 2022 and from January 2015 to
December 2021, he was the Accounts Leader for Central, Eastern and Southeastern Europe and Central Asia. He was a Senior
Advisor to EY Greece, retiring from EY on June 22, 2023. He was a Certified Auditor in Greece and in Romania. He was a member
of the Supervisory Council of the Institute of Certified Public Accountants of Greece and a member of the Board of Directors of the
American-Hellenic Chamber of Commerce.
Other positions of note: He is a member of the Executive Committee of the Foundation for Economic and Industrial Research
(IOBE) as well as Vice-Chair of the Citizens’ Movement for an Open Society.
Education: BSc in Economics and MA in Economic Theory and Policy, Athens University of Economics and Business, Greece,
MBA in Finance and Management, University of Aston, Birmingham, UK, EY Journey to the Boardroom program, Harvard Business
Publishing (2022)
CORPORATE GOVERNANCE STATEMENT
97 | ANNUAL FINANCIAL REPORT
Dimitris C. Tsitsiragos
Independent Non-Executive Member
Member of the Board of Directors since July 2020
Membership of Board Committees: Chair of the Remuneration Committee and Member of the Risk Management Committee
Nationality: Greek
Born in Athens, Greece, in 1963.
Experience: He worked for 28 years at the International Finance Corporation (IFC) – World Bank Group. He held progressive
positions in the Oil, Gas and Mining and in the Central and Eastern Europe Departments, including the positions of Manager, Oil
and Gas and Manager, Manufacturing and Services, based in Washington, D.C., USA (1989-2002). Furthermore, he held director
positions for South Asia (New Delhi, India), Global Manufacturing and Services (Washington, D.C.) and Middle East, North Africa
(Cairo, Egypt) and Southern Europe, overseeing IFC’s global and regional investment operations (2002-2011). In 2011, he was
promoted to Vice President, EMENA region (Istanbul, Turkey) and in 2014 he was appointed Vice President
Investments/Operations (Istanbul/Washington). He served as a Senior Advisor, Emerging Markets at Pacific Investment
Management Company (PIMCO) in London, UK (2018-2022). He previously served as a non-executive independent Board
Member at the Infrastructure Development Finance Company (IDFC), India and at the Commercial Bank of Ceylon (CBC), Sri
Lanka.
Other positions of note: He is a member of the Board of Directors of Titan Cement International.
Education: BA in Economics, Rutgers University, USA, MBA, George Washington University, USA, World Bank Group Executive
Development Program, Harvard Business School, USA
Jean L. Cheval
Independent Non-Executive Member
Member of the Board of Directors since June 2018
Membership of Board Committees: Chair of the Risk Management Committee and Member of the Audit Committee
Nationality: French
Born in Vannes, France, in 1949.
Experience: After starting his career at BIPE (Bureau d’Information et de Prévisions Économiques), he served in the French public
sector (1978-1983) and then worked at Banque Indosuez-Crédit Agricole (1983-2001), wherein he held various senior
management positions, including the positions of Chief Economist, Head of Corporate Planning and Head of Asset-based Finance
and subsequently he became General Manager. He served as Chairman and CEO of the Banque Audi France (2002-2005) as well
as Chairman of the Banque Audi Suisse (2002-2004). Furthermore, he served as Head of France at the Bank of Scotland (2005-
2009). Between 2009 and 2017, he worked at Natixis in various senior management positions, such as Head of the Structured
Asset Finance Department and Head of Finance and Risk, second “Dirigeant effectif” of the company alongside the CEO (2012-
2017). As of 2017 and until April 2022, he served as Senior Advisor of Natixis’ CEO, while chairing the Credit Risk Committee and
supervising the main restructuring operations (impaired assets).
Other positions of note: He is currently a member of the Board of Directors and a member of the Audit and Risk Committee of
EFG-Hermes, Egypt, a member of the Board of Directors of Natixis Algérie and Chairman of the Natixis Foundation for Research
and Innovation.
Education: Engineering, École Centrale des Arts et Manufactures, DES (Diplôme d’Études Spécialisées) in Economics (1974),
University of Paris I, France, DEA (Diplôme d’ Études Approfondies) in Statistics and in Applied Mathematics, University of Paris VI,
France
CORPORATE GOVERNANCE STATEMENT
98 | ANNUAL FINANCIAL REPORT
Carolyn G. Dittmeier
Independent Non-Executive Member
Member of the Board of Directors since January 2017
Membership of Board Committees: Chair of the Audit Committee and Member of the Corporate Governance, Sustainability and
Nominations Committee, Member in charge of overseeing ESG issues
Nationality: Italian and American
Born in Salem, Massachusetts, USA, in 1956.
Experience: She commenced her career in the US at the auditing and consulting firm Peat Marwick & Mitchell (now KPMG), where
she reached the position of Audit Manager. Subsequently, following her transfer to Italy, she assumed managerial responsibilities in
the Montedison Group as Financial Controller and later as Head of Internal Audit. In 1999, as associate partner, she successfully,
launched the practice of corporate governance services in KPMG Italy. Subsequently, she took on the role of Chief Internal Audit
Executive of the Poste Italiane Group (2002-2014). She has carried out various professional and academic activities focusing on
risk and control governance and has written two books. She was Vice Chair (2013-2014) and Director of the Institute of Internal
Auditors (2007-2014), Chair of the European Confederation of Institutes of Internal Auditing (2011-2012) and Chair of the Italian
Association of Internal Auditors (2004-2010). Commencing in 2012, she assumed roles in boards of directors, serving as
Independent Director and Chair of the Risk and Control Committee of Autogrill SpA (2012-2017) as well as of Italmobiliare SpA
(2014-2017). She was also Chair of the Board of Statutory Auditors of Assicurazioni Generali SpA (2014 - April 2023).
Other positions of note: She is currently a member of the Boards and/or the Audit Committees of some non-financial companies
(Moncler, Illycaffè) and since May 2023 she is independent non-executive member of the Board of Directors, Chair of the
Nomination Committee as well as member of the Control and Risk Committee of ENI SpA, an energy company.
Education: BSc in Economics, Wharton School, University of Pennsylvania, USA. She is a Statutory Auditor, a Certified Public
Accountant (CPA), a Certified Internal Auditor (CIA) and a Certified Risk Management Assurance (CRMA) professional, focusing on
the audit and risk management sectors.
Elanor R. Hardwick
Independent Non-Executive Member
Member of the Board of Directors since July 2020
Membership of Board Committees: Chair of the Corporate Governance, Sustainability and Nominations Committee and Member
of the Risk Management Committee
Nationality: British
Born in the UK, in 1973.
Experience: She commenced her career in 1995 at the UK Government’s Department of Trade and Industry, focusing on the
Communications and Information Industries policy, and subsequently held roles as a strategy consultant with Booz Allen Hamilton’s
Tech, Media and Telco practice and with the Institutional Equity Division of Morgan Stanley. Since 2005, she has held various
roles, including Global Head of Professional Publishing and Global Head of Strategy, Investment Advisory at Thomson Reuters
(now London Stock Exchange Group). Afterwards, she joined the team founding FinTech startup Credit Benchmark, becoming its
CEO (2012-2016). Then, she served as Head of Innovation at Deutsche Bank (2016-2018) and as Chief Digital Officer at UBS
(2019-2020). She served as a non-executive member of the Board of Directors of Itiviti Group AB (July 2020 - May 2021) and as a
member of the Supervisory Council of Luminor Group (April 2022 - October 2023).
Other positions of note: Since 2018 she has served as a non-executive member of the Board of Directors of specialty (re)insurer
Axis Capital, while she is also a member of the Human Capital and Compensation Committee and of the Corporate Governance,
Nominating and Social Responsibility Committee. She is an external member of the Audit Committee of the University of
Cambridge as of January 2021.
Education: MA (Cantab), University of Cambridge, UK, MBA, Harvard Business School, USA
CORPORATE GOVERNANCE STATEMENT
99 | ANNUAL FINANCIAL REPORT
Diony C. Lebot
Independent Non-Executive Member
Member of the Board of Directors since July 2023
Membership of Board Committees: Member of the Risk Management Committee and Member of the Corporate Governance,
Sustainability and Nominations Committee, NPL Expert
Nationality: French and Greek
Born in Beyrouth, Lebanon, in 1962.
Experience: In 1986 she joined Société Générale, where she has held various senior management positions such as Vice
President and Director in Asset based and Project Finance (1987-1997), Head of Big Ticket leasing and Asset based Finance
(1997-1998), Deputy Global Head of SG Financial Engineering (1998-2001) as well as Global Head of Asset Finance (2001-2004).
She was Head of Coverage Europe (Large corporate and Institutional Clients of SGCIB) (2004-2007), before serving as CEO of SG
Americas (US, Canada, Latin America), CEO of SG American Securities (2007-2012) as well as Deputy Global Head of Coverage
and Investment Banking and CEO of SG Corporate and Investment Banking for Western Europe (2012-2015). Subsequently, she
was the Deputy Group Chief Risk Officer (2015-2016) and the Group Chief Risk Officer (2016-2018). Since 2018 and until the
23.5.2023 she has been the Deputy Group Chief Executive Officer at Société Générale. Furthermore, she has held main Board
positions over the last 10 years in Franfinance, Société Générale Bank and Trust (SGBT), Société Générale Factoring (previously
CGA) and TCW (Asset Management company based in LA – California), Chair of the Board of Directors of Sogecap and of Ayvens
(former ALD Automotive).
Other positions of note: Since 24.5.2023 she is senior advisor to the CEO of Société Générale. She is also a Non-Executive
Member of the Board of Directors of Ayvens (former ALD Automotive) and a Non-Executive Member of the Board of Directors and
Chair of the Audit Committee of EQT AB.
Education: MA in Management from Pantheon-Sorbonne University, France, MSc in Finance and Taxation from University of
Paris, France
Johannes Herman Frederik G. Umbgrove
Non-Executive Member
Member of the Board of Directors since April 2018 (representative of the
Hellenic Financial Stability Fund from April 2018 until November 2023)
Membership of Board Committees: Member of the Audit Committee, of the Risk Management
Committee, of the Remuneration Committee and of the Corporate Governance, Sustainability and Nominations Committee
Nationality: Dutch
Born in Vught, the Netherlands, in 1961.
Experience: He worked at ABN AMRO Bank N.V. (1986-2008), wherein he held various senior management positions throughout
his career. He served as Chief Credit Officer Central and Eastern Europe, Middle East and Africa (CEEMEA) of the Global Markets
Division at The Royal Bank of Scotland Group (2008-2010) and as Chief Risk Officer and member of the Management Board at
Amsterdam Trade Bank N.V. (2010-2013). From 2011 until 2013 he was Group Risk Officer at Alfa Bank Group Holding.
Other positions of note: As of 2014 he has been a Risk Advisor at Sparrenwoude B.V. He has been a member of the Supervisory
Board of DHB Bank N.V. [former Demir-Halk Bank (Nederland) N.V.] since 2016 and in 2018 he became the Chairman of the
Supervisory Board thereof. He is currently the Chair of the Supervisory Board, of the Nomination and Remuneration Committee as
well as a member of the Risk and Audit Committee, and of the Related Party Transactions Committee of DHB Bank N.V.
Furthermore, since December 2019 he has been an independent member of the Supervisory Board and as of 1.1.2022 he has
been the Chairman of the Risk Committee and the Audit Committee of Lloyds Bank GmbH. Additionally, he is a director of the Parel
van Baarn Foundation and a member of the Management Committee of the Aston Martin Owners Club.
Education: LL.M. in Trade Law (1985), Leiden University, MBA, INSEAD (The Business School for the World), Fontainebleau
(1991), IN-BOARD Non-Executive Directors Program,INSEAD
CORPORATE GOVERNANCE STATEMENT
100 | ANNUAL FINANCIAL REPORT
Richard R. Gildea
Independent Non-Executive Member
Member of the Board of Directors from July 2016 to July 2023
Nationality: British
Born in Winthrop, Massachusetts, U.S.A., in 1952.
Experience: He served in JP Morgan Chase, in New York and London, from 1986 to 2015, wherein he held various senior
management positions throughout his career. He was Emerging Markets Regional Manager for the Central and Eastern Europe
Corporate Finance Group, London (1993-1997) and Head of Europe, Middle East and Africa (EMEA) Restructuring, London (1997-
2003). He also served as Senior Credit Officer in EMEA Emerging Markets, London (2003-2007) and Senior Credit Officer for JP
Morgan’s Investment Bank Corporate Credit in EMEA Developed Markets, London (2007-2015), wherein, among others, he was
Senior Risk Representative to senior committees.
Other positions of note: He is currently a member of the Board of Advisors at the Johns Hopkins University School of Advanced
International Studies, Washington D.C., where he chairs the Finance Committee, as well as a member of Chatham House (the
Royal Institute of International Affairs), London.
Education: BA in History, University of Massachusetts (1974), MA in International Economics, European Affairs, Johns Hopkins
University School of Advanced International Studies
Shahzad A. Shahbaz
Independent Non-Executive Member
Member of the Board of Directors from May 2014 to July 2023
Nationality: British
Born in Lahore, Pakistan, in 1960.
Experience: He has worked at various banks and investments firms, since 1981, including the Bank of America (1981-2006), from
which he left as Regional Head (Corporate and Investment Banking, Continental Europe, Emerging Europe, Middle East and
Africa). He served as Chief Executive Officer (CEO) of NBD Investment Bank/Emirates NBD Investment Bank (2006-2008) and of
QInvest (2008-2012).
Other positions of note: He is currently the Group CIO of Al Mirqab Holding Co. He is also a member of the Board of Directors of
El Corte Inglés and of Seafox.
Education: BA in Economics, Oberlin College, Ohio, USA
CORPORATE GOVERNANCE STATEMENT
101 | ANNUAL FINANCIAL REPORT
Eirini E. Tzanakaki
Secretary of the Board of Directors since December 2021
Corporate Secretariat and Governance Policies Director
Nationality: Greek
Born in Chania, Greece, in 1971.
Experience: From 1997 to 1999, she worked as a Senior Credit Officer at the Corporate Banking Division of Geniki Bank. Since
1999 she has been working for the Alpha Bank Group, initially as an Investment Banker in Alpha Finance and from 2006 until 2020
as an Associate Director of the Corporate Finance Division of Alpha Bank. She joined the Secretariat of the Board of Directors (now
Corporate Secretariat and Governance Policies Business Area) in May 2020 as an Assistant Manager of the Division.
She has more than 20 years of professional experience in the investment banking industry in Greece, having participated in a large
number of international and domestic capital market transactions as well as privatizations, Mergers and Acquisitions, tender offers
and corporate restructurings.
Education: BSc in Mathematics, University of Crete, MBA, Cyprus International Institute of Management, MSc in Finance and
Banking, Athens University of Economics and Business
CORPORATE GOVERNANCE STATEMENT
102 | ANNUAL FINANCIAL REPORT
3. PROFESSIONAL COMMITMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS
Professional commitments of the Members of the Board of Directors
(Based on the composition of the BoD on 31.12.2023)
Position
Principal outside activities
Chair (Non-Executive Member)
Vasileios T. Rapanos
Member of the BoD of the Foundation for Economic and Industrial Research (ΙΟΒΕ)
Member of the BoD of the Biomedical Research Foundation Academy of Athens
(BRFAA)
Chair of the BoD of the Alpha Bank Cultural Foundation
Executive Members
Vassilios E. Psaltis
CEO
Member of the Institut International d' Études Bancaires (IIEB)
Member of the BoD and of the Executive Committee of the Hellenic Federation of
Enterprises (SEV)
Member of the BoD of the Hellenic Bank Association
Spyros N. Filaretos
Chief of Growth and Innovation
Member of the BoD of Alpha Bank London Ltd
Chair of the BoD of the Efstathia J. Costopoulos Foundation
Member of the BoD of the Alpha Bank Cultural Foundation
Non-Executive Member
Efthimios O. Vidalis
Member of the BoD of Titan Cement Company S.A.
Member of the BoD of Eurolife FFH Insurance Group Holdings S.A.
President of the Executive Committee of the Hellenic Federation of Enterprises
(SEV) and
Member of the Board of Directors of SEV - Stegi Ellinikis Viomihanias
Independent Non-Executive Members
Elli M. Andriopoulou
Chair and Managing Director of the Stavros Niarchos Foundation Cultural Center
(SNFCC)
Aspasia F. Palimeri
Member of the BoD of the Foundation for Economic and Industrial Research (IOBE)
Panagiotis I.-K. Papazoglou
Member of the Executive Committee of the Foundation for Economic and Industrial
Research (IOBE)
Vice-Chair of the Citizens’ Movement for an Open Society
Dimitris C. Tsitsiragos
Member of the BoD of Titan Cement International
Jean L. Cheval
Member of the BoD and member of the Audit and Risk Committee of EFG-Hermès
Member of the BoD of Natixis Algérie
Chairman of the Natixis Foundation for Research and Innovation
Carolyn G. Dittmeier
Member of the BoD and/or Audit Committee of non-financial companies, such as
Moncler SpA and Illycaffè SpA
Member of the BoD, Chair of the Nomination Committee and Member of the
Control and Risk Committee of ENI SpA
Elanor R. Hardwick
Member of the BoD of specialty (re)insurer Axis Capital, Member of the Human
Capital and Compensation Committee and of the Corporate Governance,
Nominating and Social Responsibility Committee
External member of the Audit Committee of the University of Cambridge
Diony C. Lebot
Senior advisor to the CEO of Société Générale
Member of the BoD of Ayvens (former ALD Automotive)
Member of the BoD and Chair of the Audit Committee of EQT AB
Non-Executive Member
Johannes Herman Frederik G.
Umbgrove
Member of the Supervisory Board and Chair of the Risk Committee and the Audit
Committee of Lloyds Bank GmbH
Chair of the Supervisory Board and of the Nomination and Remuneration
Committee, Member of the Risk and Audit Committee and of the Related Party
Transactions Committee of DHB Bank N.V. [former Demir-Halk Bank (Nederland)
N.V.]
Risk Advisor at Sparrenwoude B.V.
Director of the Parel van Baarn Foundation
Member of the Management Committee of the Aston Martin Owners Club
CORPORATE GOVERNANCE STATEMENT
103 | ANNUAL FINANCIAL REPORT
4. PROFILE OF THE BOARD OF DIRECTORS AND COMMITTEE MEMBERSHIP FOR THE YEAR 2023 AND
SHARES OWNED ON 31.12.2023
Board of Directors
Gender
Age
Tenure
(in
years)
Term
ends
Shares owned
31.12.2023
Committees
Number
of shares
% of
the
share
capital
Audit
Risk
Management
Remuneration
Corporate
Governance,
Sustainability
and
Nominations
Chair
(Non-Executive Member)
Vasileios T. Rapanos
M
76
9
2026
0
0
-
-
-
-
Executive Members
Vassilios
E. Psaltis
CEO
M
55
5
2026
264,585
0.011
-
-
-
-
Spyros N.
Filaretos
Chief of
Growth
and
Innovation
M
65
18
2026
186,836
0.008
-
-
-
-
Non-Executive Member
Efthimios O. Vidalis
M
69
9
2026
0
0
M
(until
26.7.2023)
-
M
(as of 27.7.2023)
M
Independent Non-Executive Members
Elli M. Andriopoulou
F
48
1
2026
0
0
M
-
-
M
Aspasia F. Palimeri
F
50
1
2026
0
0
-
M
M
-
Panagiotis I.-K.
Papazoglou
(as of 27.7.2023)
M
64
5
months
2026
24,050
0.001
M
-
M
-
Dimitris C. Tsitsiragos
M
60
3
2026
0
0
-
M
C
(as of 27.7.2023)
M
(until 26.7.2023)
-
Jean L. Cheval
M
74
5
2026
0
0
M
C
-
-
Carolyn G. Dittmeier
F
67
6
2026
0
0
C
-
-
M
In charge of
overseeing
ESG issues
Richard R. Gildea
(until 26.7.2023)
M
71
6
26.7.2023
0
0
-
M
NPL Expert
(until
26.7.2023)
C
(until 26.7.2023)
-
Elanor R. Hardwick
F
50
3
2026
0
0
-
M
-
C
Diony C. Lebot
(as of 27.7.2023)
F
61
5
months
2026
0
0
-
M
NPL Expert
-
M
Shahzad A. Shahbaz
(until 26.7.2023)
M
63
7
26.7.2023
0
0
-
-
-
M
(until
26.7.2023)
Non-Executive Member
Johannes Herman
Frederik G. Umbgrove
M
62
5
2026
0
0
M
M
M
M
C: Chair
M: Member
-: The Member does not participate in this Committee
CORPORATE GOVERNANCE STATEMENT
104 | ANNUAL FINANCIAL REPORT
5.
BOARD AND COMMITTEES ATTENDANCE
During 2023, the Board of Directors convened 21 times. The average participation rate of the Members of the Board of Directors in
the meetings stood at 98%.
Two strategy offsite meetings took place during 2023 with the participation of all the Members of the Board of Directors (100%
attendance).
The Corporate Governance, Sustainability and Nominations Committee (CGSNC) deemed that there were no Member absences
from Board meetings without a valid reason. The Members of the Board of Directors who were absent had informed the Company
in time of the relevant reasons.
The table of the attendance rates of the Members of the Board of Directors is posted on the Company’s website
(https://www.alphaholdings.gr/en/corporate-governance/administrative-structure/board-of-directors).
CORPORATE GOVERNANCE STATEMENT
105 | ANNUAL FINANCIAL REPORT
6.
2023 BOARD MEMBERS’ INDIVIDUAL ATTENDANCE RATES AT MEETINGS
CORPORATE GOVERNANCE STATEMENT
106 | ANNUAL FINANCIAL REPORT
7.
SUITABILITY AND NOMINATION POLICY FOR THE MEMBERS OF THE BOARD OF DIRECTORS
The Suitability and Nomination Policy for the Members of the Board of Directors is a document of Alpha Services and Holdings S.A.
that sets out the principles and the framework for the selection, appointment, re-appointment and replacement of Members of the
Board of Directors as well as the criteria to be used in the assessment.
The Policy is supplemented by the “Suitability and Nomination Process for the Members of the Board of Directors”, which provides
for the specific process to be followed mainly by the CGSNC, to which accountability is attributed in this Policy.
The Policy complies with the legislative and regulatory framework in force, including the relevant Joint ESMA/EBA “Guidelines on
the assessment of the suitability of members of the management body and key function holders” (hereinafter the “ESMA/EBA
Guidelines”) and the ECB Guide to fit and proper assessments as well as with European best practices in corporate governance.
The objectives of the Policy are to:
• Set general principles that provide guidance to the CGSNC and its Chair on selecting, vetting and proposing candidates to
the Board of Directors as well as on the replacement and renewal of the Members of the Board of Directors.
• Set criteria, including diversity criteria, for the selection and suitability assessment of the Board of Directors candidates.
• Set criteria for the assessment of the ongoing individual suitability of the Members of the Board of Directors as well as of
the collective suitability of the Board of Directors.
• Establish a transparent, effective and time-efficient suitability and nomination process.
The Policy and its implementation are monitored and reviewed annually by the CGSNC, approved by the Board of Directors and
submitted for approval to the General Meeting of Shareholders. Any amendments thereto are approved by the Board of Directors
and in case they are material they are submitted for approval to the General Meeting of Shareholders. The Policy and every
material amendment thereto enters into force from the approval thereof by the General Meeting of Shareholders. Material are the
amendments that provide for derogations or significantly change the content of the Suitability and Nomination Policy, in particular
as to the applied general principles and criteria. In preparing, amending or reviewing the Policy, the CGSNC and the Board of
Directors shall take into account recommendations or findings of other Board Committees and competent areas, especially the
internal control functions. The internal control functions should provide effective input for the review of the Suitability and
Nomination Policy in accordance with their roles. Notably, the Compliance Division should analyze how the Suitability and
Nomination Policy affects the Company’s compliance with legislation, regulations, internal policies and procedures and should
report all identified compliance risks and issues of non-compliance to the CGSNC.
The CGSNC will nominate candidates whom it deems suitable to become Members of the Board of Directors according to the
criteria set out in the applicable regulatory framework and in this Policy. Suitability is determined in relation to the Policy’s criteria for
candidates (fit and proper and general suitability) and the current composition needs. For the purposes of this Policy, it is defined
as the degree to which an individual is deemed to have good repute and to have, individually and collectively with the other
Directors/Members, adequate knowledge, skills and experience to perform his/her duties and a clear understanding of the
Company’s culture, values and overall strategy. Suitability also covers the honesty, integrity and independence of mind of each
individual and his/her ability to commit sufficient time to perform his/her duties.
Further to the above, where any Members of the Board of Directors do not fulfill the requirements set out, the European Central
Bank, in the framework of the Single Supervisory Mechanism, shall have the power to remove such Members from the Board of
Directors. The CGSNC, within the aforementioned context, shall consider the suitability of the Members of the Board of Directors on
a periodic basis, utilizing Board Review assessments and any other pertinent information available.
In order to be considered as a suitable candidate by the Board of Directors and its CGSNC, the prospective nominee must: meet
the fit and proper requirements, meet individual and collective suitability requirements, have no systematic conflict of interests with
the Company, have no impediments according to the relevant legislation and be able to devote sufficient time to the Board of
Directors. All nominees must submit a declaration that they meet the relevant requirements.
CORPORATE GOVERNANCE STATEMENT
107 | ANNUAL FINANCIAL REPORT
The Suitability and Nomination Policy for the Members of the Board of Directors is posted on the Company’s website
(https://www.alphaholdings.gr/-/media/alphaholdings/files/genikes-syneleysis/h-suitability-and-nomination-policy-
en.pdf?la=en&hash=4DFF6607CAACF80624DC2D0647DF4F762F4A8C1F).
8.
POLICY AND PROCESS FOR THE SUCCESSION PLANNING OF NON-EXECUTIVE AND INDEPENDENT
NON-EXECUTIVE MEMBERS OF THE BOARD OF DIRECTORS
The Company considers the high quality of its Non-Executive and Independent Non-Executive Members of the Board of Directors
as a fundamental element of its culture and long-term performance, since good succession planning:
• ensures a continuous process to identify suitable candidates who are ready to take over when Members leave the Board
on various occasions;
• achieves continuity to deliver strategic plans by aligning the Company’s human resources with business planning;
• demonstrates a commitment to recruiting and promoting high-performing Members.
The Policy and Process for the Succession Planning of Non-Executive and Independent Non-Executive Members of the Board of
Directors is a document that sets out the framework for the succession planning of the aforementioned Members. It is in line with
the Greek and the European regulatory requirements and best practice standards, including, among others, the Basel Committee
Corporate Governance Principles for Banks, the Joint ESMA/EBA “Guidelines on the assessment of the suitability of members of
the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU”, as in force, as well as the
Hellenic Corporate Governance Code.
The succession planning for the Non-Executive and Independent Non-Executive Members of the Board, is also governed by the
“Suitability and Nomination Policy for the Members of the Board of Directors”.
The Policy is validated during a succession planning meeting that concludes with the identification of successors, after a thorough
discussion and analysis which, apart from the “Suitability and Nomination Policy for the Members of the Board of Directors” and the
findings of the annual evaluation, also takes into account the candidates’ level of readiness and their level of potential.
The Policy aims at ensuring each time the smooth and efficient operation of the Board of Directors of the Company.
In particular, the objectives of the Policy are to:
• Ensure the implementation of the Company’s strategy regarding leadership;
• Ensure organizational sustainability through leadership continuity;
• Strengthen the confidence of Investors, Regulators, Employees and other Stakeholders in the Company’s ability to
safeguard and promote organizational continuity;
• Establish principles, processes and role clarity to support smooth leadership transitions;
• Mitigate the risks that may arise from disorderly changes in the smooth operation of the Board;
• Ensure diversity and appropriate gender representation within the Board;
• Ensure that the principle of equal opportunities is respected when implementing the succession planning process;
• Provide guidance to the Board and to the CGSNC on the succession planning process of the Company’s Non-Executive
and Independent Non-Executive Members in order to ensure their smooth and proper succession based on the
Company’s Succession and Suitability Policies and the respective legal and regulatory framework;
• Identify the competency requirements of key positions and assess potential candidates;
• Identify and nominate suitable candidates to fill vacancies which occur.
Succession planning does not constitute a process of automatic nomination procedure of identified successors when actual
vacancies occur. It is, however, a key input to the selection process.
Succession plans may be activated under (a) Medium-term planning for the orderly replacement of current Non-Executive Members
and/or Independent Non-Executive Members and (b) Contingency planning for sudden and unforeseen events.
The Chair of the Board of Directors is actively involved in the succession planning, in collaboration with the Corporate Governance,
Sustainability and Nominations Committee and the Human Resources Unit of the Company. The CGSNC may request the
assistance of an external specialist consultant, if deemed necessary.
CORPORATE GOVERNANCE STATEMENT
108 | ANNUAL FINANCIAL REPORT
9.
EVALUATION OF THE BOARD OF DIRECTORS
With the support of the CGSNC, the Board of Directors annually assesses its effectiveness and that of its Committees.
From time to time and at least once every three years, the Board of Directors may appoint external consultants to facilitate a more
in-depth review of its effectiveness.
The collective evaluation of the Members of the Board of Directors and its Committees, for the year 2022, was conducted by
Morrow Sodali, with the assistance of the CGSNC. The Board Self-Evaluation, carried out through an on-line questionnaire
completed by all Board Members, focused on a variety of topics concerning Strategy, Risk Governance and Internal Control,
Strategic HR Issues and Remuneration, Corporate Governance and Sustainability – ESG Issues, Board Profile and Composition,
Board Functioning and Dynamics, Board Secretarial Support, Performance of the Chair, Information Flows and Interaction with
Management, Effectiveness of Board Committees, with the aim of identifying areas for further Board improvement.
The Individual Evaluation of the Members of the Board of Directors for the year 2022 was conducted by the Chair of the Board of
Directors through an on-line questionnaire provided by Morrow Sodali, which was completed by all Board Members.
The summary of the results showed that, overall, the Members of the Board of Directors are perceived to be engaged and
committed, work well together and provide constructive challenge.
The key recommendation was that the time devoted to strategic discussions at Board level should be further enhanced and the
agendas could be more streamlined.
As regards the Individual Evaluation of the Members of the Board of Directors for the year 2022, the main highlights were the
following:
− The Board performed its functions effectively.
− The Board worked with the Management in a productive and constructive manner.
10.
ASSESSMENT OF THE BOARD MEMBERS’ COLLECTIVE SUITABILITY BASED ON THE ESMA/EBA
GUIDELINES
Further to the aforementioned evaluation of the Board of Directors, an assessment of the Board Members’ collective suitability in
terms of knowledge, skills and experience, based on the ESMA/EBA “Guidelines on the assessment of the suitability of members of
the management body and key function holders” (the “ESMA/EBA Guidelines”), was conducted with the support of the CGSNC.
In this context and for the purposes of preparing the assessment of the collective suitability, each Member of the Board of Directors
conducted an Individual Self-Assessment, by using an individual self-assessment questionnaire, based on the criteria listed in the
ESMA/EBA Guidelines. The Chair of the Board of Directors completed the Collective Suitability Matrix of the ESMA/EBA Guidelines
based on the Individual Self-Assessments and examining, among others, the areas of governance, risk management, compliance,
audit, management, strategy, decision-making, basic knowledge and past experience, as suggested in the said Guidelines.
Furthermore, taking into consideration that the EBA Guidelines Matrix is a dynamic tool, new sections have been included therein,
taking into account changes in the banking landscape and the needs arising from the Company’s Business Plan.
Based on the approved Collective Suitability Matrix, the Board of Directors resolved that it would benefit from new Members who
have a good knowledge and experience of Greek market, ESG, IT and Digital and also are strategic thinkers.
1
1. ANNUAL CONFIRMATION OF THE MEMBERS’ INDEPENDENCE
The Independent Non-Executive Members of the Board of Directors should fulfill all the criteria for being Independent Non-
Executive Members, in accordance with the CGSNC Charter, with Law 4706/2020 on Corporate Governance as well as with the
Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council.
In particular:
i) The Independent Non-Executive Members are requested to fill in and sign, on an annual basis, a Declaration
pertaining to the fulfillment of all the criteria for being an Independent Non-Executive Member.
ii) The Corporate Secretariat and Governance Policies Business Area has established a process in order to confirm
that the Independent Non-Executive Members fulfill all the criteria set for being Independent Non-Executive
Members.
CORPORATE GOVERNANCE STATEMENT
109 | ANNUAL FINANCIAL REPORT
Moreover, the Corporate Secretariat and Governance Policies Business Area obtains a copy of the Members’ criminal record on a
quarterly basis.
The Board of Directors, with the support of the CGSNC, after reviewing the independence criteria, confirmed that the Independent
Non-Executive Members, Elli M. Andriopoulou, Aspasia F. Palimeri, Dimitris C. Tsitsiragos, Panagiotis I.-K. Papazoglou, Jean L.
Cheval, Carolyn G. Dittmeier, Elanor R. Hardwick and Diony C. Lebot, fulfill all the criteria for being Independent Non-Executive
Members of the Board of Directors, in accordance with Law 4706/2020 on corporate governance, the Articles of Incorporation and
the Hellenic Corporate Governance Code, as in force.
During 2023 the Corporate Secretariat and Governance Policies Business Area confirmed the independence of the
abovementioned Members based on the respective process (June 2023). Further to the above, the Independent Non-Executive
Members signed the Declaration Form (June 2023) and confirmed their independence through the Individual Self-Assessment
Questionnaire of the EBA Matrix (January 2024).
12.
COOPERATION OF THE NON-EXECUTIVE MEMBERS WITH THE EXECUTIVE MEMBERS
The Non-Executive Members of the Board of Directors reviewed issues of potential conflict of interests between the Company and
the Executive Members.
Additionally, the good cooperation between all the Executive Members of the Board of Directors and their Non-Executive peers was
highlighted.
The Executive Members stand out for their professional expertise, their quality of character, their integrity and their team spirit.
They devote sufficient time and demonstrate the required commitment in order to fully comply with the constantly increasing
regulatory reporting requirements.
The Non-Executive Members of the Board of Directors expressed their satisfaction to the Executive Members about their positive
contribution to the management of the Company.
13.
INDUCTION AND TRAINING
13.1 Induction and Training Policy for the Members of the Board of Directors
The Induction and Training Policy for the Members of the Board of Directors is a document of Alpha Services and Holdings S.A.
that sets out the principles and the approach for the induction and training programs addressed to the Members of the Board of
Directors in accordance with the legislative and regulatory framework in force, including the relevant Joint ESMA/EBA “Guidelines
on the assessment of the suitability of members of the management body and key function holders” (the “ESMA/EBA Guidelines”),
as well as with European best practices in corporate governance.
The Policy applies to the Members of the Board of Directors individually and/or collectively.
The objectives of the induction and training programs provided to the Board of Directors are to:
• facilitate the Board of Directors’ clear understanding of the relevant laws and regulations, the Company’s structure,
business model, risk profile and governance arrangements as well as of the role of the Member(s) within them;
• facilitate the Board of Directors’ clear understanding of the international, European and national economic and regulatory
developments in the financial sector and their impact on the Company;
• promote the Board of Directors’ awareness regarding the benefits of diversity in the Board of Directors and the Company;
• improve the skills, knowledge or competence of the Members of the Board of Directors to fulfill their responsibilities on an
ongoing or on an ad hoc basis;
• provide for relevant general and individually‐tailored training programs, as appropriate.
The Policy is approved by the Board of Directors and is reviewed every two years by the CGSNC, which may propose relevant
amendments to the Board of Directors.
CORPORATE GOVERNANCE STATEMENT
110 | ANNUAL FINANCIAL REPORT
13.2 Induction and Training Programs for the Members of the Board of Directors
All the newly-appointed Members of the Board of Directors receive key information one month after taking up their position at the
latest, and the induction should be completed within six months. For this purpose, the Company offers to all the new Members of
the Board of Directors an induction program on:
• The Company’s structure, business model, risk profile and governance arrangements;
• Legal and regulatory requirements in relation to the Company and the services it provides;
• Corporate Governance principles;
• Risk Management, Internal Audit, Compliance;
• Wholesale and Retail Banking;
• Wealth Management and Treasury;
• External Statutory Audit; Capital Adequacy, Financial and Accounting Services;
• Credit Risk and NPEs;
• ESG, Sustainability and Non-Financial Information;
• Information Technology and Security;
• Human Resources;
• International Network;
• Digitalization;
• Transformation;
• Strategic Planning.
During 2023 and in accordance with the Induction and Training Policy for the Members of the Board of Directors, an Induction
Program for the new Members of the Board of Directors, Ms. D.C. Lebot and Mr. P.I.-K. Papazoglou, took place. In the context of
this Induction Program, the new Members also met with the Chair of the Board of Directors, the CEO, Chiefs – Members of the
Executive Committee, Chief of Internal Audit, Chief of Compliance, the Secretary of the Board of Directors, the Statutory Certified
Auditor, as well as other Executives.
Additionally, the Company, in the framework of the continuous training of the Members of the Board of Directors, provides
informative and/or training sessions to all of them as well as the possibility for relevant informative and/or training seminars and
meetings on the abovementioned or on other topics concerning the financial sector and the Company. The training should place
emphasis on conceptual and strategic issues and focus on new developments and on the influence these developments may have
on the Company.
The CGSNC sets an annual training – informative schedule. The annual training plan is kept up to date, taking into account the
Board suitability assessment, governance changes, strategic changes and other relevant changes as well as changes in applicable
legislation and market developments. Furthermore, the annual training plan and/or the informative schedule for the Board of
Directors shall include separate sessions for the Executive and the Non-Executive Members, if appropriate, as well as, where
appropriate, sessions for specific positions according to their specific responsibilities and involvement in the Board Committees.
The Board of Directors, following relevant recommendation by the CGSNC, approved the 2023 annual training – informative
schedule for the Members of the Board of Directors at its meeting held on January 2023.
The following training programs (induction and informative sessions) took place during 2023:
CORPORATE GOVERNANCE STATEMENT
111 | ANNUAL FINANCIAL REPORT
The Company also provides its Board Members with the opportunity to participate in training and education sessions offered by
external institutions. Upon request by any Member, the Company may offer tailor-made programs to further enhance the Members’
knowledge and competences.
During 2023, certain Board Members attended the following training programs:
14.
RELATED PARTIES TRANSACTIONS
The Company has established and implements policies and processes on Related Parties Transactions in order to identify,
evaluate, approve and properly disclose the transactions it performs with the Related Parties.
All set processes and procedures aim at ensuring that the transactions are in the interest of the Company and at arm’s-length
terms. The Compliance Division of each Subsidiary is the responsible Unit to monitor the Related Parties transactions for
conformity with the principles and process applied.
15. COMMITTEES OF THE BOARD OF DIRECTORS
The Board of Directors may establish permanent or ad hoc Committees to assist it in the discharge of its responsibilities, facilitate
its operations and effectively support its decision-making. The Committees have an advisory role but may also assume delegated
authorities, as determined by the Board. Each Committee has its dedicated Charter prescribing its composition, tenure, functioning
and responsibilities.
Induction
Regulatory Framework
Materiality Analysis
Corporate Governance in the Banking Sector
Digital Euro
ESG – How banks can respond to climate change risks
The Retail Banking Perspective
ESG in Alpha Bank: Stepping up Stewards of Sustainability
BoD Member
Training Program
Company
Elli M.
Andriopoulou
Fundamentals of Bank Risk Analysis
Moody’s Analytics UK Limited
Aspasia F.
Palimeri
Fundamentals of Bank Risk Analysis
Moody’s Analytics UK Limited
Bank Risk Management
Euromoney Learning
Carolyn G.
Dittmeier
Joint ECB/EUI Seminar Diverse and
effective boards in a changing and
competitive landscape
Florence School of Banking and Finance
CSRD Fundamentals e-learning
Impact Institute/21 Markets B.V.
CORPORATE GOVERNANCE STATEMENT
112 | ANNUAL FINANCIAL REPORT
Four Committees operate at Board level, namely:
• the Audit Committee,
• the Risk Management Committee,
• the Remuneration Committee,
• the Corporate Governance, Sustainability and Nominations Committee.
Each Committee consists of not less than three Members. The composition of each Committee is proposed to the Board of
Directors by the CGSNC taking into account the “Suitability and Nomination Policy for the Members of the Board of Directors” as
well as the respective legal and regulatory framework.
The major focus of the Committees is placed on the oversight of policies, practices and procedures within their specific area of
mandate as detailed in the Charter of each Committee, on the preparation of draft resolutions to be approved by the Board of
Directors and on the submission of relevant briefings, reports, key information and recommendations to the Board. The Committees
report regularly to the Board of Directors about their work.
Audit Committee
The Committee has been established and operates in accordance with all applicable laws and regulations. The determination of the
type of the Audit Committee, its term of office, the number and the qualifications of its Members as per article 44 par. 1 case b) of
Law 4449/2017 were resolved upon by the Ordinary General Meeting of 27.7.2023. The Audit Committee currently constitutes a
Committee of the Board of Directors. Its Members were appointed by a resolution of the Board of Directors of 27.7.2023 and its
Chair was appointed by its Members at the meeting of the Committee held on 27.7.2023, in accordance with the provisions of
article 44 par. 1 case e) of Law 4449/2017, as in force.
Audit Committee Composition (as at 31.12.2023 and on the date of publication of the 2023 Annual Report)
CORPORATE GOVERNANCE STATEMENT
113 | ANNUAL FINANCIAL REPORT
The Committee convenes generally on a monthly basis, adding meetings on an as-needed basis. It may invite any Member of the
Management or Executive as well as external auditors to attend its meetings. The Head of the Internal Audit and the Head of
Compliance are regular attendees of the Committee meetings and have unhindered access to the Chair and to the Members.
The main responsibilities of the Audit Committee include but are not limited to those presented below.
The Committee:
▪ Performs the oversight of the financial reporting processes and procedures for drawing up the Annual and the Interim
Financial Statements of the Company and the Group, in accordance with the applicable accounting standards.
▪ Reviews the quarterly Financial Statements of the Group as well as the semi-annual and annual Financial Statements of the
Company and the Group, together with the Statutory Auditors’ Report, where applicable, and the Board of Directors’ semi-
annual and Annual Management Report, prior to their submission to the Board of Directors for approval.
▪ Is informed of the evolution of significant accounting standards and oversees the impact on accounting policies.
▪ Performs the oversight of the Non-Financial Report, the Sustainability Report, the reporting processes and the ESG
disclosures.
▪ Reviews annual or multi-year audit plans and recommends their approval by the Board of Directors.
▪ Reviews the periodic reports on the activity of the Internal Audit in the Company and the Group as well as on the corrective
actions for the adequate handling of comments and recommendations identified in these reports.
▪ Reviews and approves policies regarding the Internal Audit of the Company as well as any amendments thereto.
▪ Informs the Board of Directors of the outcome of the statutory audit and explains how the statutory audit contributed to the
integrity of the financial reporting and what the role of the Audit Committee was in that process.
▪ Assists the Board of Directors in ensuring the independent, objective and effective conduct of internal and external audits.
▪ Assists the Board of Directors in overseeing the effectiveness and performance of the Internal Audit and of the Compliance of
the Company and of the respective Units across the Group.
▪ Is responsible for the procedure followed for the selection and the annual evaluation of the Statutory Certified Auditors of the
Company and the Group and makes recommendations to the Board of Directors on the appointment or dismissal, rotation,
tenure and remuneration of the Statutory Certified Auditors, according to the relevant regulatory and legal provisions.
▪ Monitors the independence and performance of the Statutory Certified Auditors in accordance with the applicable laws, a
responsibility which includes reviewing, inter alia, the provision by them of Non-Audit Services to the Company and the
Group. In relation to this, the Committee examines and approves all proposals regarding the provision by the Statutory
Certified Auditor of Non-Audit Services to the Company and the Group, based on the relevant policy that the Audit Committee
oversees and recommends to the Board of Directors for approval.
▪ Monitors and assesses the adequacy, effectiveness and efficiency of the Internal Control System, based on reports by
Internal Audit and by Compliance, on findings of the external auditors, the supervisors and the tax authorities as well as on
management information, as appropriate.
▪ Evaluates the adequacy and effectiveness of the processes and procedures of the Compliance, based on the Annual
Compliance Report, as per the regulatory framework in force.
▪ Assesses the adequacy and effectiveness of the “Anti-Money Laundering and Combating the Financing of Terrorism Policy”,
reporting annually to the Board of Directors and to the Supervisory Authorities; reviews the framework of the Markets in
Financial Instruments Directive (MiFID) and the Market Abuse Regulation (MAR).
2023
Number of Audit Committee meetings
15
Average ratio of Members’ attendance
98%
CORPORATE GOVERNANCE STATEMENT
114 | ANNUAL FINANCIAL REPORT
▪ Promotes a culture of ethical behavior and integrity within the Group.
The Members of the Committee collectively possess adequate knowledge of the financial sector and, in general, the required
knowledge, skills and experience to adequately discharge the Committee’s responsibilities. At least one Member, who is
Independent from the audited entity, has accounting/auditing knowledge and experience and is present at the meetings regarding
the approval of the Financial Statements.
The specific duties and responsibilities of the Audit Committee are set out in its Charter, which is posted on the Company’s
website (https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-
practices/management/committees/audit-committee).
During 2023 the main activities of the Committee were, among others, the following:
The Committee:
▪ Was informed of the quarterly Activity Reports of the Internal Audit Unit and the Compliance Unit, based on the annual
plans previously endorsed by the Committee.
▪ Reviewed the organization, independence and capacity of the Internal Audit Unit and of the Compliance Unit.
▪ Evaluated the following reports for the year 2022 which were submitted to the Bank of Greece:
− the Annual Report of the Internal Audit Division on the Internal Control System of the Bank for the previous year,
as per the Bank of Greece Governor’s Act 2577/9.3.2006.
− the Annual Report of the Compliance Division as per the Bank of Greece Governor’s Act 2577/9.3.2006.
▪ Approved and submitted to the Bank of Greece its assessment report on the adequacy and effectiveness of the Internal
Control System of the Group.
▪ Reviewed the Internal Audit Charter and proposed its approval by the Board of Directors.
▪ Reviewed the selection process and endorsed the appointment of the new Head of the Internal Audit of Alpha Services
and Holdings S.A.
▪ Confirmed the independence of the Head of Internal Audit at a meeting without the presence of the Company’s
Management.
▪ Reviewed the reports regarding the assessment of the adequacy of the Internal Control System for the years 2020-2022
by Mazars, as per the Bank of Greece Governor’s Act 2577/9.3.2006 and Law 4706/2020 and endorsed their submission
to the Bank of Greece.
▪ Reviewed and proposed to the Board of Directors for approval the 2024 Annual Audit Plan of the Internal Audit Business
Area, considering the evolution of the “Audit Universe”, the risk assessment methodology and the incorporation of newly-
emerged risks and of the resource adequacy therein, taking into account the Internal Audit Business Area’s
Transformation Plan.
▪ Reviewed and proposed to the Board of Directors for approval the Compliance Annual Plan for 2024 along with the
Organizational Structure of the Compliance Business Area and the progress of the centralization of certain Anti-Money
Laundering (AML) monitoring units.
▪ Reviewed and discussed the annual performance evaluation of the Head of Internal Audit for the year 2022. It also
discussed and endorsed the Succession Planning - Emergency Fills for the Head of Internal Audit of the Company and
proposed its approval by the Board of Directors, through the Corporate Governance, Sustainability and Nominations
Committee.
▪ Submitted to the Board of Directors for approval the appointment of the Statutory Certified Auditor and the relevant
Statutory and Tax Audit fees for the year 2023 as well as of a follow-up on the 2022 Statutory and Tax Audit fees of the
Alpha Services and Holdings Group Companies.
▪ Reviewed the annual Financial Statements for Alpha Services and Holdings S.A. and the Group for the year 2022 as well
as the consolidated First Quarter Financial Statements of the Alpha Services and Holdings S.A. for the year 2023, the
standalone and consolidated semi-annual Financial Statements for Alpha Services and Holdings S.A. for the year 2023
and the consolidated Third Quarter Financial Statements of the Alpha Services and Holdings S.A. for the year 2023, as
well as the relevant Press Releases prior to their submission to the Board of Directors for approval.
▪ Informed the Board of Directors of the outcome of the statutory audit and explained how the statutory audit contributed to
the integrity of financial reporting and what the role of the Committee was in that process.
▪ Focused, among other things, on the significant accounting issues and accounting areas requiring professional judgment,
including the impact of any extraordinary transactions and provisioning.
▪ Recommended to the Board of Directors that the annual Financial Statements should be prepared in accordance with the
applicable accounting standards and give a true and fair view of the assets, liabilities, equity and financial performance of
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the Company and its Subsidiaries included in the Consolidated Financial Statements taken as a whole, as provided for in
article 4 pars 3 and 4 of Law 3556/2007.
▪ Performed the oversight of the Group Statutory Certified Auditors’ (Deloitte) activity and performance and reviewed the
Statutory Certified Auditors’ Audit Plan for the year 2023 with reference to the planned audit approach, key audit matters
and risks, materiality, risk assessment and scope of the audit as well as audit standards and regulation and evaluated the
internal control issues regarding financial reporting processes identified by the Statutory Certified Auditor and the
adequacy of the responses provided by the Management. The Committee assessed the Audit Plan for 2023 and ensured
that it covered the most significant areas of control, taking into account the main areas of business and financial risk of the
Company.
▪ Reviewed the Statutory Certified Auditors’ Audit Report according to article 10 of Regulation (EU) No 537/2014 as well as
the Additional Report according to article 11 of Regulation (EU) No 537/2014 and reviewed the action plan regarding the
Significant Deficiencies reported by the Statutory Auditor in its Additional Report as at 31.12.2022.
▪ Monitored the independence of the Statutory Certified Auditor, in accordance with the laws in force at a meeting without the
presence of the Company’s Management and, in particular, as regards the provision of Non-Audit Services to the Company
and the Group In this context the Committee reviewed and approved all Non-Audit Services provided to the Alpha Services
and Holdings Group by the Statutory Certified Auditor, on the basis of the Policy and Procedures for the Assignment of
Non-Audit Services to the Statutory Auditor. The fees recognized to the external auditor, i.e. Deloitte Certified Public
Accountants S.A. and its network, are analytically described in Note 50 of the Consolidated Annual Financial Statements
for the year 2023.
▪ Reviewed and approved the process pertaining to the annual evaluation and the Reappointment of the Group Statutory
Certified Auditor and in this context reviewed the annual evaluation of the Statutory Certified Auditor for the year 2022
after taken into account the overall considerations and evaluation of the Management.
▪ Monitored the procedure followed for the drafting of the Non-Financial Report and the Sustainability Report for the year
2022, was updated on the materiality analysis process and reviewed the relevant Limited Assurance Reports by an
External Auditor.
▪ Was informed of the Limited Assurance Reports, both for the Non-Financial Report and the Sustainability Report for the
year 2022, by Deloitte Certified Public Accountants S.A., prepared in accordance with the International Standard on
Assurance Engagements (ISAE) 3000.
▪ Was informed of the proposal of the Company for the Sustainability Report Redesign, based on a holistic approach,
aiming to address multiple disclosure requirements and associated data needs across key ESG dimensions.
▪ Was informed on the Task Force on Climate-related Financial Disclosures (TCFD) report.
▪ Conducted the annual review of its Charter.
▪ Was updated on the Supervisory Dialogue meeting in view of the draft Supervisory Review and Evaluation Process
(SREP) Decision of 2023.
▪ Was informed of the progress of the On-Site Inspection (OSI) on Liquidity and on Operational Risk.
▪ Acquired a full understanding of the work of the Risk Management Unit through the participation of some of its Members in
the Risk Management Committee and reviewed the monthly update on the Regulatory Agenda on the most significant
capital adequacy, regulatory liquidity, supervisory and environmental issues.
▪ Conducted the first reading of the Group’s Code of Conduct and Ethics.
▪ Met with the Company’s Management was informed about the progress of significant projects affecting the Group’s
internal control systems and had several meetings with Executives from various Business Areas of the Company and the
Bank. in order to review operational risk, cyber, IT, human resources, legal and other issues. The Committee also took
cognizance, on a quarterly basis, of the minutes of the Whistleblowing Committee as well as of the outcome of the
investigations with regard to the reported cases, in accordance with the Whistleblowing Policy and Procedures.
▪ In the context of the periodic review of the Group’s Policies, reviewed and endorsed the following policies (or revised
policies) and proposed their approval by the Board of Directors:
- Policy and Procedure for the Periodical Assessment of the Internal Control System;
- Policy and Procedures for the Selection and Reappointment of the Statutory Auditor;
- Whistleblowing Policy and Procedures;
- Market Abuse Prevention Policy;
- Policy and Procedures for the Assignment of Non-Audit Services to the Statutory Auditor.
Regarding the Subsidiaries, the Audit Committee:
▪ Reviewed the Annual Activity Reports for 2022 and the Semi-Annual Activity Reports for 2023 prepared by the Audit
Committees of the Subsidiaries of Alpha Services and Holdings S.A.
▪ Aiming at further enhancing corporate governance and the collaboration among the Subsidiaries, launched a series of
videoconference meetings with the Audit Committees of the Subsidiaries. In this context, meetings with the Members of
the Audit Committee of Alpha Bank Cyprus Ltd and ABC Factors S.A. took place.
During 2023, the Audit Committee met jointly with the Risk Management Committee in order to review and discuss issues of
common interest.
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Risk Management Committee
The Committee has been established and operates in accordance with all applicable laws and regulations. The Members of the
current Risk Management Committee were appointed by a resolution of the Board of Directors of 27.7.2023.
Risk Management Committee Composition (as at 31.12.2023 and on the date of publication of the 2023 Annual Report)
The Committee convenes at least once a month and may invite any Member of the Group’s Management or Executive to attend its
meetings. The Chief Risk Officer (CRO) is a regular attendee of the Committee meetings and has unhindered access to the Chair
and the Members. The CRO, while administratively reporting to the Chief Executive Officer (CEO), shall report functionally to the
Board of Directors through the Committee.
The main responsibilities of the Risk Management Committee include but are not limited to those presented below.
The Committee:
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▪ Assists the Board of Directors in promoting a sound risk culture at all levels throughout the Company and its Subsidiaries
(the “Group”), fostering risk awareness and encouraging open communication and challenge across the Organization.
▪ Reviews regularly and recommends to the Board of Directors for approval the risk and capital management strategy,
ensuring alignment with the business objectives of the Company and the Group.
▪ Reviews and recommends annually to the Board of Directors for approval the Group’s Risk Appetite Framework and
statement, considering also ESG risks, i.e. the risks of any negative financial impact to the Company stemming from the
current or prospective impacts of ESG factors on its counterparties, such as climate-related risks, and ensuring alignment
with the Group’s strategic objectives and capital allocation.
▪ Determines the principles which govern risk management across the Company and the Group in terms of the
identification, measurement, monitoring, control and mitigation of risks.
▪ Recommends to the Board of Directors for approval high-level policies on the management of risks.
▪ Monitors that the Company adequately embeds Environmental, Social and Governance (ESG) risks in the overall risk
appetite statement and framework, business strategy and risk management framework.
▪ Evaluates on an annual basis or more frequently, if necessary, the appropriateness of risk identification and measurement
systems, methodologies and models, including the capacity of the Company’s IT infrastructure to record, report,
aggregate and process risk-related information.
▪ Reviews the Annual Group’s Internal Capital Adequacy Assessment Process (ICAAP) and the Internal Liquidity Adequacy
Assessment Process (ILAAP) as well as related target ratios and recommends their approval to the Board of Directors.
▪ Assesses the overall effectiveness of capital planning, allocation processes and systems and the allocation of capital
requirements to risk types.
▪ Keeps itself informed of recent regulatory developments, emerging supervisory expectations, the results of supervisory
requests and the Supervisory Review and Evaluation Process (SREP) conclusions.
▪ Collaborates with the Audit Committee as necessary on the effective oversight of the mitigation of certain key areas of risk,
including climate-related or other ESG risks, and capital management and their repercussions on the Internal Control
System. The Committee also convenes jointly with the Audit Committee to discuss and review issues relevant to the
remediation plans from regulatory/supervisory assessments and certain operational risk or other issues of importance and
common interest.
▪ Collaborates with other Board Committees in relation to ESG issues.
The Members of the Committee have prior experience in the financial services sector and, individually and collectively, appropriate
knowledge, skills and expertise concerning risk management and control practices. One Member is in charge of overseeing ESG
risk issues.
The specific duties and responsibilities of the Risk Management Committee are set out in its Charter, which is posted on the
Company’s website (https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-
practices/management/committees/risk-management-committee).
During 2023 the main activities of the Committee were, among others, the following:
The Committee:
▪ Discussed, challenged and endorsed:
− The updated Risk and Capital Strategy (RCS)/Risk Appetite Framework (RAF) for 2023 and resolved to propose their approval
to the Board of Directors.
− The annual Risk Management Report as well as the relevant Assessment Report for the year 2022, which were submitted to
the Bank of Greece.
− The updated NPEs Reduction Plan of 2023 and resolved to submit it to the Board of Directors for approval.
− The Group Internal Capital Adequacy Assessment Process (ICAAP) Report for 2023 and the concluding Group Capital
Adequacy Statement (CAS) for 2023, along with the Group Internal Liquidity Adequacy Assessment Process (ILAAP) Report
for 2023 and the concluding Group Liquidity Adequacy Statement (LAS) for 2023 and proposed to the Board of Directors the
approval and submission thereof to the Single Supervisory Mechanism (SSM).
− The Issuance of the Additional Tier 1 Bond Loan and resolved to submit it to the Board of Directors for approval.
− The Dividend Policy and resolved to propose its approval by the Board of Directors
− The updated ICAAP and ILAAP Frameworks and the Stress Test Governance Framework and resolved to submit them to the
Board of Directors for approval.
− The Pillar III Disclosures Report for the Full Year 2022 and the First Half of 2023 and resolved to submit it to the Board of
Directors for approval.
− The first full data and the final full data collection submission of the EBA templates regarding the European Union-wide Stress
Test for 2023 to the SSM and resolved to submit them to the Board of Directors for ratification.
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− The updated Contingency Funding Plan (CFP) and resolved to propose its approval by the Board of Directors.
− The introduction of a new Interest Rate Risk in the Banking Book (IRRBB) Risk Appetite Framework Limit and resolved to
propose its approval by the Board of Directors.
− The Capital Management Policy and resolved to propose its approval by the Board of Directors.
− The updated Group Recovery Plan (2023) Report and the updated Recovery Plan Framework and Manual (2023) and resolved
to submit them to the Board of Directors for approval.
− The revised Wholesale Banking Concentration Policy and resolved to propose its approval to the Board of Directors.
− The Group Acquisition Policy and resolved to propose its approval by the Board of Directors.
− The action plan of the Bank with regard to the follow-up letter by the SSM on the OSI Credit and Counterparty Credit Risk and
recommended its approval by the Board of Directors.
▪ Discussed and endorsed the Succession Planning - Emergency Fills of the Chief Risk Officer of Alpha Services and Holdings
S.A. and proposed its approval by the Board of Directors, through the CGSNC.
▪ Took cognizance of the final version of the SREP Letter for 2022 and the draft version of the SREP Letter for 2023 and the
respective action plan.
▪ Was informed of and discussed:
− the NPEs Plan evolution and the quarterly performance on NPEs targets;
− the ECB feedback letter on Climate-Related and Environmental Risk Disclosures;
− the latest developments regarding the Non-Commercial Book;
− the preliminary outcome of the Supervisory Dialogue for 2023;
− the SSM and the Single Resolution Board (SRB) Agendas for 2023, on a monthly basis;
− the monthly evolution of the Capital Ratios, the Net Stable Funding Ratio (NSFR) and the Liquidity Coverage Ratio (LCR);
− the monthly Credit Committee I approvals for Wholesale Loans;
− the SSM’s feedback on the Group Recovery Plan 2022 submission;
− the ECB Cyber Resilience Stress Test;
− the Management Report on Data Governance, Data Quality and Significant Resubmissions
− the progress of the On-Site Inspection (OSI) on the Business Model and Profitability;
− the final report of the OSI on Liquidity and the relevant action plan for addressing SSM’s findings;
− the progress of the OSI on Credit and Counterparty Risk;
− the process and methodology of the Financed Emissions Assessment and the Forward-Looking Assessment;
− the annual review of its Charter.
▪ Reviewed and discussed the Climate and ESG Risk Management and the update of the Climate risk supervisory action plan.
Regarding the Subsidiaries, the Risk Management Committee:
▪ Reviewed the Annual Activity Reports for 2022 and the Semi-Annual Activity Reports for 2023 prepared by the Risk
Management Committees of the Subsidiaries as well as the Third Quarter 2023 Activity Reports prepared by the Risk
Management Committees of Alpha Bank Cyprus Ltd and Alpha Bank Romania S.A.
▪ Aiming at further enhancing corporate governance and the collaboration among the Subsidiaries, launched a series of
videoconference meetings with the Risk Management Committees of the Subsidiaries abroad. In this context, meetings with the
Members of the Risk Management Committee of Alpha Bank Cyprus Ltd took place.
In 2023, the Risk Management Committee had joint meetings with the Audit Committee in order to review areas of common interest
of risk and capital management and their repercussions on the Internal Control System.
Moreover, the Members of the Risk Management Committee participated in the meetings of the Audit Committee for the review of
the Financial Statements.
Remuneration Committee
The Committee has been established and operates in accordance with all applicable laws and regulations. The Members of the
current Remuneration Committee were appointed by a resolution of the Board of Directors of 27.7.2023.
Remuneration Committee Composition (as at 31.12.2023 and on the date of publication of the 2023 Annual Report)
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119 | ANNUAL FINANCIAL REPORT
The Committee convenes at least quarterly per year and may invite any Member of the Management or Executive to attend its
meetings. The Chief Human Resources Officer is a regular attendee of the Committee meetings.
The main responsibilities of the Remuneration Committee include but are not limited to those presented below.
The Committee:
▪ Assists the Board of Directors in ensuring that the Group Remuneration Policy as well as the “Remuneration Policy of the
Members of the Board of Directors as per the provisions of Law 4548/2018” are consistent with the values, culture,
business strategy, risk appetite and strategic objectives of the Company and its Subsidiaries (the “Group”), taking into
account Environmental, Social and Governance (ESG) risks that affect the business environment in the short, medium or
long term.
▪ Is responsible for the preparation of decisions on remuneration to be taken by the Non-Executive Members, in particular
regarding the remuneration of the Executive Members of the Board of Directors as well as of other identified Staff (i.e.
Staff whose professional activities have a material impact on the Institutions’ risk profile).
▪ Provides its support and advice to the Non-Executive Members of the Board of Directors on the design of the
Remuneration Policies for the Company and the Group, including that such remuneration policies are gender-neutral
according to the relevant legislative and regulatory provisions, support the equal treatment of Staff, promote inclusiveness
and respect diversity in general.
▪ Recommends to the Non-Executive Members the remuneration of the Members of the Board of Directors.
▪ Reviews and advises on fixed salaries, benefits and total remuneration within the Company.
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▪ Reviews the variable remuneration framework. Recommends to the Board of Directors for approval variable remuneration
schemes for Employees across the Company and the Group and proposes the total envelope for variable remuneration
across the Company and the Group.
▪ Reviews the performance of the Executive Members of the Board of Directors (the “Executive Members”), the Chiefs –
Members of the Executive Committee and the Key Function Holders (the “KFHs”) of the Company based on the input that
it receives from the evaluators, in accordance with the provisions of the “Policy for the Evaluation of Senior Executives and
Key Function Holders”.
▪ Validates the Evaluation Scorecards and the goals of the Executive Members, the Chiefs – Members of Executive
Committee and the KFHs.
▪ Ensures that adequate policies and processes for the regular performance evaluation of Senior Executives and Key
Function Holders of the Company and of the Group Staff are in place, adequately implemented and in alignment with the
Remuneration Policy and the Human Resources policies and processes (including staff succession planning and talent
management systems).
The Members of the Committee have collectively appropriate knowledge, skills and professional experience concerning
remuneration policies and practices, risk management and control activities as well as concerning the incentives and risks that can
arise therefrom. At least one Member has sufficient professional experience in risk management.
The specific duties and responsibilities of the Remuneration Committee are set out in its Charter, which is posted on the
Company’s website (https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-
practices/management/committees/remuneration-committee).
During 2023 the main activities of the Committee were, among others, the following:
The Committee:
▪ Reviewed the Remuneration Policy for Alpha Services and Holdings and its Group as well as its Annexes and
recommended the approval of the Group Benefits and Corporate Expenses Policy (Annex II of the Remuneration Policy
for Alpha Services and Holdings and its Group) and the Senior Executives Severance Payment Policy by the Non-
Executive Members of the Board of Directors.
▪ Reviewed the Total Rewards Strategy, i.e. Fixed Remuneration, the Variable Remuneration framework as well as the
revised Benefits following the new Career Framework.
▪ Reviewed the list of Material Risk Takers for 2022 and recommended the approval thereof by the Non-Executive Members
of the Board of Directors.
▪ Recommended to the Board of Directors that the requirements set by the HFSF Law in relation to the lifting of the Salary
Cap on fixed remuneration and the payment of variable remuneration to Board Members and Senior Management in the
form of shares or stock options or other instruments are met. Furthermore, it recommended that the above applies also in
relation to variable remuneration previously awarded by the Board in the form of Stock Options (the vesting of which was
subject to the amendment of the HFSF Law).
▪ Reviewed the amendments of the Executive Committee Members contracts and recommended the approval by the Non-
Executive Members and subsequently by the Board of Directors of the proposed fixed salary increases and of the
introduction of the variable remuneration clause in the Executive Committee Members contracts.
▪ Reviewed and endorsed the Regulation of the Stock Award Plan and the Regulation of the 2023 Retention Plan of Alpha
Services and Holdings S.A. and recommended the approval thereof by the Board of Directors.
▪ Endorsed the award under the Stock Award Plan for 2023.
▪ Was updated on the governance of the use of Shares vested under the Stock Award Plan and recommended the approval
of the respective documentation by the Board of Directors.
▪ Reviewed and endorsed a Senior Executives Savings Plan as a supplement to the current Institution for Occupational
Retirement Provision - Occupational Insurance Fund Alpha Services and Holdings Group Personnel.
▪ Reviewed and endorsed, as part of the material to be submitted to the Ordinary General Meeting of Shareholders, the
Remuneration Policy as per Law 4548/2018, the 2022 Remuneration Report as per Law 4548/2018 and a Stock Award
Plan.
▪ Reviewed and proposed to the Board of Directors the approval of the annual remuneration amounts of the Chairs and the
Members of the Audit Committee, the Risk Management Committee, the Remuneration Committee and the Corporate
Governance, Sustainability and Nominations Committee as well as of the Chair and Members of the Board of Directors.
▪ Finalized the remuneration amounts of the Members of the Board of Directors for the financial year 2023.
▪ Reviewed and proposed to the Board of Directors the approval of the Expenses Policy for the Non-Executive Members of
the Board of Directors.
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▪ Reviewed the Policy for the Evaluation of Senior Executives and Key Function Holders and provided input to the CGSNC.
▪ Reviewed the Remuneration Committee Charter.
▪ Reviewed and provided input on the Career Framework.
▪ Was updated on the Audit Report on the Remuneration Policy.
▪ Was updated on the Institution for Occupational Retirement Provision (IORP) Investment strategy.
▪ Reviewed its Annual Activity Report and submitted it to the Board of Directors for information.
Regarding the Subsidiaries, the Remuneration Committee:
▪ reviewed the Annual Activity Reports of the Remuneration Committees of the Subsidiaries, i.e. Alpha Bank London Ltd,
Alpha Bank Romania S.A., Alpha Bank Cyprus Ltd and Alpha Astika Akinita S.A., for the year 2022.
▪ reviewed the annual remuneration amounts of the Non-Executive Members of the Boards of Directors of Alpha Bank
Cyprus Ltd and Alpha Bank Romania S.A. and recommended the approval thereof to the Board of Directors.
▪ aiming at further enhancing corporate governance and the collaboration among the Subsidiaries, launched a series of
videoconference meetings with the Remuneration Committees of the Subsidiaries abroad. In this context, the
Remuneration Committee held joint meetings with the Chairs of the Remuneration Committees of the international
Subsidiaries, i.e. Alpha Bank Romania S.A., Alpha Bank London Ltd and Alpha Bank Cyprus Ltd.
Corporate Governance, Sustainability and Nominations Committee
The Committee has been established and operates in accordance with all applicable laws and regulations. The Members of the
current Corporate Governance, Sustainability and Nominations Committee were appointed by a resolution of the Board of Directors
of 27.7.2023.
Corporate Governance, Sustainability and Nominations Committee Composition (as at 31.12.2023 and on the date of
publication of the 2023 Annual Report)
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122 | ANNUAL FINANCIAL REPORT
The Committee convenes at least quarterly per year and may invite any Member of the Management or Executive to attend its
meetings.
The main responsibilities of the Corporate Governance, Sustainability and Nominations Committee include but are not
limited to those presented below.
The Committee:
▪ Is regularly informed of current trends and developments in the area of corporate governance, including best practice and
relevant regulations.
▪ Monitors the compliance of the Company and the Group with the pertinent Hellenic Corporate Governance Code, to which
the Company adheres, ensuring appropriate application of the “comply or explain” principle required; provides oversight
that the implementation of this principle aligns with the legislation in force, the regulatory expectations and the international
corporate governance best practice.
▪ Reviews the Company’s Internal Governance Regulation and recommends its approval by the Board of Directors.
▪ Facilitates the regular review of the Charters of the Board Committees, in consultation with the relevant Committees, by
providing input to each Committee in order to ensure that the Charters remain fit-for-purpose and align with the Hellenic
Corporate Governance Code as well as with corporate governance best practices.
▪ Reviews, at least semi-annually, current and emerging trends and regulatory developments in ESG issues that may
significantly affect the Company’s activities, highlighting to the Board of Directors areas that may require actions.
▪ Oversees the implementation of the Company’s policies on ESG issues.
▪ Reviews the respective communication, sustainability reporting to Stakeholders and ratings, in coordination with the Audit
Committee.
▪ Acts as the ultimate liaison/responsible Board Committee with respect to all sustainability/ESG issues and promotes
respective communications and feedback from all the Board of Directors Committees.
▪ Assists the Board of Directors in establishing the conditions required for effective succession and continuity in the Board of
Directors.
▪ Develops and regularly reviews the selection criteria and the appointment process for the Members of the Board of
Directors.
▪ Identifies and recommends for approval by the Board of Directors candidates to fill vacancies, according to the Suitability
and Nomination Policy for the Members of the Board of Directors, evaluates the balance of knowledge, skills, diversity and
experience of the Board of Directors, prepares a description of the roles and capabilities for a particular appointment and
assesses the time commitment expected.
▪ Assesses periodically, and at least annually, the structure, size, composition and performance of the Board of Directors
and makes recommendations to the Board of Directors with regard to any changes.
▪ Assesses periodically, and at least annually, the knowledge, skills and experience of each Member of the Board of
Directors and of the Board of Directors collectively and reports to the Board of Directors accordingly.
▪ Oversees the design and implementation of the induction program for the new Members of the Board of Directors as well
as the ongoing knowledge and skills development for the Members, which support the effective discharge of their
responsibilities.
The Committee ensures and regularly evaluates that its Members collectively possess the required knowledge, skills and
experience relating to sustainability and ESG issues as well as to the business of the Company to assess the appropriate
composition of the Board of Directors and, among others, the selection process and the suitability requirements, in order to
adequately discharge the Committee’s responsibilities.
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The specific duties and responsibilities of the Corporate Governance, Sustainability and Nominations Committee are set out in its
Charter, which is posted on the Company’s website (https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-
governance-practices/management/committees/corporate-governance-sustainability-nominations-committee).
During 2023 the main activities of the Committee were, among others, the following:
The Committee:
▪ Identified and recommended for approval by the Board of Directors candidates to fill vacancies in the Board of Directors; in
particular, it recommended to the Board of Directors the election of Ms. Diony C. Lebot and Mr. Panagiotis I.-K. Papazoglou as
Independent Non-Executive Members of the Board of Directors at the Ordinary General Meeting of Shareholders.
▪ Reviewed and proposed to the Board of Directors the approval of:
− the Corporate Governance Statement for the year 2022,
− the Policy for the Succession Planning of Senior Executives and Key Function Holders,
− the Policy and Process for the Succession Planning of Non-Executive and Independent Non-Executive Members of the
Board of Directors,
− the Induction and Training Policy and Procedure for the Members of the Board of Directors,
− the Training Program for the year 2023,
− the European Banking Authority (EBA) Guidelines Matrix concerning the assessment of the collective suitability of the
Board of Directors,
− the Internal Governance Regulation of Alpha Services and Holdings S.A.,
− the Executive Committee Charter.
▪ Reviewed:
− the Code of Conduct and Ethics,
− the BoD Committees’ Charters and the Board of Directors’ Charter,
− the Policy for the Evaluation of Senior Executives and Key Function Holders.
▪ Confirmed that the Independent Non-Executive Members fulfill all the criteria for being Independent Non-Executive Members of
the Board of Directors, in accordance with Law 4706/2020 on corporate governance, the Articles of Incorporation and the
Hellenic Corporate Governance Code, as in force.
▪ Reviewed and endorsed the new Career Framework and recommended the approval thereof by the Board of Directors.
▪ Recommended to the Board of Directors the content of the Draft Invitation and the Draft Resolutions of the Ordinary General
Meeting of Shareholders of 27.7.2023.
▪ Proposed to the Board of Directors the composition of the Board of Directors’ Committees, subject to the election of the new
Board of Directors at the Ordinary General Meeting of Shareholders of 27.7.2023.
▪ Received an update on the Succession Planning for the Non-Executive Members of the Board of Directors.
▪ Discussed the Succession Planning of Senior Executives and Key Function Holders as well as the respective Emergency Fills.
▪ Was updated regularly on Environmental, Social and Governance (ESG) issues.
▪ Reviewed the Sustainability Report and the Task Force on Climate-related Financial Disclosures (TCFD) Report and
recommended the approval thereof by the Board of Directors.
▪ Was updated on the draft ECB letter on the assessment of Alpha Bank’s Climate & Environmental Risk disclosures.
▪ Took cognizance of the Board Evaluation Report for the year 2022, drafted by Morrow Sodali, in the context of the evaluation
of the Board of Directors by the said firm.
▪ Was informed of the Individual Evaluation of the Members of the Board of Directors for the year 2022, performed by the Chair
of the Board of Directors.
▪ Was informed of the attendance of the Members at the Board of Directors’ and at the Committees’ meetings for the year 2022
and for the First Half of 2023.
▪ Reviewed and submitted its Annual Activity Report to the Board of Directors for information.
Regarding the Subsidiaries, the Corporate Governance, Sustainability and Nominations Committee:
▪ Reviewed the 2022 Annual and the 2023 Semi-Annual Activity Reports of the Subsidiaries’ Nomination Committees and
Boards of Directors.
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G. EXECUTIVE COMMITTEE
1. EXECUTIVE COMMITTEE
In accordance with Law 4548/2018 and the Company’s Articles of Incorporation, the Board of Directors has established an
Executive Committee.
The Executive Committee acts as a collective corporate body of the Company. The Committee’s powers and authorities are
determined by way of a CEO act, delegating powers and authorities to the Committee. The Committee is vested, at least, with the
following powers and authorities to manage the affairs of the Company and take decisions. The Committee has the right to
delegate further all or parts of its vested authority.
The indicative main responsibilities of the Committee include but are not limited to the following:
The Committee:
▪ Prepares the strategy, the business plan and the annual budget of the Company and the Group, including the strategy on
Environmental, Social and Governance (ESG) issues, for submission to and approval by the Board of Directors as well as
the annual and interim Financial Statements.
▪ Decides on and manages the capital allocation to the Business Units.
▪ Prepares the Internal Capital Adequacy Assessment Process (ICAAP) Report and the Internal Liquidity Adequacy
Assessment Process (ILAAP) Report for submission to and approval by the Board of Directors, manages their
implementation and reports accordingly to the Board of Directors.
▪ Monitors the performance of each Business Unit and Subsidiary of the Company versus the Budget and ensures that
corrective measures are taken.
▪ Reviews and approves, in the framework of its authorities, the Policies of the Company and informs the Board of Directors
accordingly or submits them, as the case may be, to the latter for approval.
▪ Discusses issues related to the Group’s Purpose and Values, culture and human resources as well as approves and
manages any collective program proposed by the Human Resources Unit for the Staff (including any bonus schemes,
voluntary separation schemes etc.).
▪ Is responsible for the implementation of (i) the overall risk strategy, including the Company’s risk appetite and its risk
management framework, (ii) an adequate and effective internal governance and internal control framework that includes a
clear organizational structure and well-functioning independent internal risk management, compliance and audit functions
of high stature and significant know-how as well as sufficient resources to perform their operations, (iii) an adequate and
effective framework for the implementation of the Company’s strategy on ESG issues, (iv) the amounts, types and
distribution of both internal capital and regulatory capital to adequately cover the risks of the Company, (v) the means for
achieving targets for the liquidity management of the Company, (vi) the selection and suitability assessment process for
Key Function Holders and (vii) any arrangements aimed at ensuring the integrity of the accounting and financial reporting
systems, including financial and operational controls, risk management and compliance with the law and the relevant
standards.
CORPORATE GOVERNANCE STATEMENT
125 | ANNUAL FINANCIAL REPORT
2. MEMBERS OF THE EXECUTIVE COMMITTEE
The composition of the Executive Committee of the Company is as follows:
The CVs of the Members of the Executive Committee are presented below and are also available on the Company’s website
(https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-practices/management/executive-
committee).
Chair
Vassilios E. Psaltis
CEO
He was born in Athens in 1968. He holds a PhD in Banking and a MA in Business and Banking from the University of St. Gallen in
Switzerland. He held various senior management positions at ABN AMRO Bank’s Financial Institutions Group in London (1999-
2001) and at Emporiki Bank where he has worked as Deputy (acting) Chief Financial Officer (2002-2006). He joined Alpha Bank in
2007. In 2010 he was appointed Group Chief Financial Officer (CFO) and in 2012 he was appointed General Manager. Through
these posts, he spearheaded capital raisings of several billions from foreign institutional shareholders, diversifying the Bank’s
shareholder base, as well as significant mergers and acquisitions that contributed to the consolidation of the Greek banking market,
reinforcing the position of the Bank. He has been a Member of the Board of Directors since November 2018 and Chief Executive
Officer since January 2019. In 2019 he was elected member of the Institut International d' Études Bancaires (IIEB). He has been a
Member of the Board of Directors and of the Executive Committee of the Hellenic Federation of Enterprises (SEV) since July 2021
as well as Member of the Board of Directors of the Hellenic Bank Association (HBA) since October 2021.
Chair
V.E. Psaltis
Chief Executive Officer (CEO)
Members
S.N. Filaretos
Chief of Growth and Innovation
S.A. Andronikakis
Chief Risk Officer (CRO)
L.A. Papagaryfallou
Chief Financial Officer (CFO)
I.M. Emiris
Chief of Wholesale Banking
I.S. Passas
Chief of Retail Banking
N.R. Chryssanthopoulos
(resignation effective as of 16.2.2024)
Chief of Corporate Center (CCC)
S.B.-A. Oprescu
Chief of International Network
A.C. Sakellariou
(resignation effective as of 1.2.2024)
Chief Transformation Officer (CTO)
S.N. Mytilinaios
Chief Operating Officer (COO)
F.G. Melissa
Chief Human Resources Officer (CHRO)
G.V. Michalopoulos
Chief of Wealth Management
CORPORATE GOVERNANCE STATEMENT
126 | ANNUAL FINANCIAL REPORT
Member
Spyros N. Filaretos
Chief of Growth and Innovation
He was born in Athens in 1958. He studied Economics at the University of Manchester and at the University of Sussex, UK. Ιn
1985, he joined Alpha Bank, where he held key positions at different branches and Divisions (Organization, Human Resources and
Treasury Management). He was appointed Executive General Manager in 1997 and General Manager in 2005. From October 2009
to November 2020, he served as Chief Operating Officer (COO). In December 2020, he was appointed General Manager - Growth
and Innovation (new title as of 15.12.2023 Chief of Growth and Innovation). He is a Member of the Boards of Directors of Alpha
Bank London Ltd and the Alpha Bank Cultural Foundation as well as Chair of the Board of Directors of Efstathia J. Costopoulos
Foundation. Moreover, he is a Member of the Executive Committee. He has been a Member of the Board of Directors since 2005.
Member
Spiros A. Andronikakis
Chief Risk Officer (CRO)
He was born in Athens in 1960. He holds a BA in Economics and Statistics from the Athens University of Economics and Business
(former Athens School of Economics and Business) and an MBA in Financial Management and Banking from the University of
Minnesota, USA. He has worked in the Corporate Banking Units of Greek and multinational banks since 1985. He served as a
Member of the Board of Directors of Alpha Leasing S.A., Alpha Finance Investment Services S.A., Tiresias Bank Information
Systems S.A. and Alpha Bank Romania S.A. He joined Alpha Bank in 1998. He was Corporate Banking Manager from 2004 to
2007. In 2007 he was appointed Chief Credit Officer and in 2012 General Manager – Chief Risk Officer (CRO) [new title as of
15.12.2023 Chief Risk Officer (CRO)]
Member
Lazaros A. Papagaryfallou
Chief Financial Officer (CFO)
He was born in Athens in 1971. He studied Business Administration at the Athens University of Economics and Business and holds
an MBA in Finance from the University of Wales, Cardiff Business School. He started his career in Citibank and ABN AMRO and he
joined Alpha Bank in 1998, having served as Manager of the Corporate Development, International Network and Strategic Planning
Divisions. On 1.7.2013 he was appointed Executive General Manager of the Bank and has contributed to the implementation of the
Group’s Restructuring Plan, the capital strengthening of the Bank, the design and closing of mergers, acquisitions and portfolio
transactions. During his career he served as Chairman and Member in the Boards of Directors of various Group Companies, both
in Greece and abroad, in the banking, insurance, financial services, industry and real estate sectors. On 2.1.2019 he was
appointed General Manager – Chief Financial Officer (CFO) for the Group [new title as of 15.12.2023 Chief Financial Officer
(CFO)].
CORPORATE GOVERNANCE STATEMENT
127 | ANNUAL FINANCIAL REPORT
Member
Ioannis M. Emiris
Chief of Wholesale Banking
He was born in Athens in 1963. He studied Economics and Business Administration at the Athens University of Economics and
Business (former Athens School of Economics and Business) and holds an MBA from Columbia Business School as well as a US
Certified Public Accounting (CPA) degree. He started his career as a certified public accountant in PricewaterhouseCoopers in New
York. From 1991 to 2012, he worked for the Alpha Bank Group, initially as an Investment Banker in Alpha Finance Investment
Services S.A. and from 2004 as Manager of the Project Finance and the Investment Banking Divisions of Alpha Bank. From 2012
to 2014, he was the Chief Executive Officer of the Hellenic Republic Asset Development Fund (HRADF). On 5.11.2014, he was
appointed Executive General Manager and on 19.11.2019 he was appointed General Manager of Wholesale Banking (new title as
of 15.12.2023 Chief of Wholesale Banking).
Member
Isidoros S. Passas
Chief of Retail Banking
He was born in Thessaloniki in 1967. He holds an MSc in Mechanical Engineering from the National Technical University of Athens
and an MBA from City, University of London (Bayes Business School) and has attended the Advanced Management Program
(AMP) at INSEAD. He started his career at Procter & Gamble and held managerial positions in Marketing and Sales Management
functions at multinational Fast-Moving Consumer Goods (FMCG) companies. He worked at Eurobank for 13 years, where he held
positions of responsibility in Retail Banking and served as a Deputy General Manager of the Retail Banking Network and as a
member of the boards of directors of the bank’s subsidiaries. In 2013 he took up duties as a Senior Advisor to the Management on
retail marketing distribution in Hellenic Petroleum. He joined Alpha Bank in 2014. He held the positions of Manager of the Deposit
and Investment Products and Manager of the Greek Branch Network Division. He is the Chairman of the Board of Directors of
AlphaLife Insurance Company S.A. and Member of the Board of Directors of Alpha Real Estate Management and Investments
(AREMI) S.A. On 1.4.2016 he was appointed Executive General Manager and on 19.11.2019 General Manager of Retail Banking
(new title as of 15.12.2023 Chief of Retail Banking).
Member
Nicholas R. Chryssanthopoulos
Chief of Corporate Center (CCC)
(resignation effective as of 16.2.2024)
He was born in Athens in 1975. He holds a BA and an MA in Philosophy, Politics and Economics from Oxford University. He has
worked in the Alpha Bank Group since 2000 in the areas of Investment Banking, Corporate Development and Strategic Planning
and has also served as Advisor to the Secretary General of the Ministry of Finance on banking matters. From 2016 to 2019, he
served as a Senior Manager in Alpha Bank’s Strategic Planning Unit, in charge of Group M&A and business planning. On
14.1.2019 he was appointed Executive General Manager and from 20.5.2022 to 16.2.2024 he was General Manager – Chief of
Corporate Center (CCC) [new title as of 15.12.2023 Chief of Corporate Center (CCC)].
CORPORATE GOVERNANCE STATEMENT
128 | ANNUAL FINANCIAL REPORT
Member
Sergiu-Bogdan A. Oprescu
Chief of International Network
He was born in 1963. He holds an MEng degree from the Faculty of Aerospace Engineering at Bucharest Polytechnic Institute, with
specialization in Avionics. He acquired a postgraduate degree in Reliability with specialization in “Complex technical systems’
reliability” from the Bucharest Polytechnic Institute and attended various executive programs at Harvard Business School, Stanford
Graduate School of Business and London Business School. In 1994 he joined Alpha Bank Romania S.A., where he held several
senior positions before he was appointed Executive President in 2007. He was Managing Director (1995-1996) and then Executive
President (1996-2002) at Alpha Finance Romania S.A. (former Bucharest Investment Group – Brokerage S.A.). He served as
President of the Board of Governors of the Bucharest Stock Exchange (2001-2006), as Board Member of the Romanian
Association of Banks and coordinator of the banking commissions on Mortgage Lending, Non-Performing Loans, European Union
Funds Absorption, Treasury and Capital Markets (2008-2014) and as Chairman of the Board of Directors of the Romanian
Association of Banks (2015-2021). On 11.2.2019 he was appointed General Manager of International Network (new title as of
15.12.2023 Chief of International Network).
Member
Anastasia C. Sakellariou
Chief Transformation Officer (CTO)
(resignation effective as of 1.2.2024)
She was born in Athens in 1973. She graduated from Arsakeio – Tositseio School in 1991 and completed her studies in Great
Britain. She holds postgraduate degrees in International Banking from the University of Reading and in International Studies from
the University of Warwick. She is a banker of international repute, with professional experience both in the private and in the public
sector. She began her career in London in the mid-90s, working for bulge bracket investment banking firms (Deutsche Bank,
Salomon Brothers and Credit Suisse), specializing in credit and credit restructuring, leverage finance as well as asset-liability
management, underwriting and risk management. Before repatriating in 2009, she was Managing Director of Investment Banking at
Credit Suisse. In Greece, she received her first executive appointment as Senior Advisor to the Chairman of Piraeus Bank and later
as Chief Risk Officer of Hellenic Postbank. In February 2013, she was appointed CEO of the Hellenic Financial Stability Fund
(HFSF). During her tenure in that position of critical importance, she played an instrumental role in the transformation, restructuring
and stabilization of the Greek banking sector. From 2017 to 2020, she was the CEO of the first digital banking platform in Greece,
Praxia bank. From April 2020 to January 2024, she was General Manager – Chief Transformation Officer (CTO) [new title as of
15.12.2023 Chief Transformation Officer (CTO)], being responsible for the overall design of the Transformation Plan as well as for
ensuring the prompt implementation and monitoring of the respective projects.
Member
Stefanos N. Mytilinaios
Chief Operating Officer (COO)
He was born in Athens in 1973. He holds a First-Class degree in Aerospace Engineering from the University of Bristol, Great
Britain, and an MBA with Distinction from INSEAD in Fontainebleau, France. He brings onboard extensive experience in
technology, operations and business, having assumed managerial positions in Greece and abroad. He served as the Deputy Group
CIO at Eurobank and as a business consultant at McKinsey & Company, based in Athens and London. Moreover, he has been the
Chief Technology Officer at Commercial Bank of Qatar and later on he was appointed General Manager, Digital Business at
Piraeus Bank. On 1.12.2020 he was appointed General Manager – Chief Operating Officer (COO) [new title as of 15.12.2023 Chief
Operating Officer (COO)].
CORPORATE GOVERNANCE STATEMENT
129 | ANNUAL FINANCIAL REPORT
Member
Fragiski G. Melissa
Chief Human Resources Officer (CHRO)
She was born in 1968. She studied Psychology at the National and Kapodistrian University of Athens and holds postgraduate
degrees in Industrial/Organizational Studies from Columbia University and in Social Studies from the New School for Social
Research. She brings 28 years of experience in human resources. She served as a Regional Human Resource Director for
Southeastern Europe at Colgate Palmolive, while in her career she also held positions of responsibility at Makro Cash & Carry and
at KPMG. For the last 8 years before joining Alpha Bank, she was Head of Human Resources at Vodafone in Greece and
Romania. On 3.3.2020 she was appointed Executive General Manager – Chief Human Resources Officer and on 20.5.2022 she
was appointed General Manager – Chief Human Resources Officer (CHRO) [new title as of 15.12.2023 Chief Human Resources
Officer (CHRO)].
Member
Georgios V. Michalopoulos
Chief of Wealth Management
He was born in Athens in 1973. He studied Mathematics at the National and Kapodistrian University of Athens and holds an MBA in
Finance from City, University of London (Bayes Business School). He started his career at Alpha Bank in 1994 and worked in the
Treasury functions in Athens and London. He has served as Group Treasurer and Manager of the Planning and Trading and the
Financial Markets Divisions. He has been a Member of the Board of Directors of various Group Companies in the banking, finance
and insurance sectors in Greece and abroad for a number of years. On 4.5.2016 he was appointed Executive General Manager of
Treasury Management and on 20.5.2022 he was appointed General Manager ‒ Wealth Management and Treasury (new title as of
15.12.2023 Chief of Wealth Management).
3. NUMBER OF ALPHA SERVICES AND HOLDINGS S.A. SHARES OWNED ON 31.12.2023
Chair
Number of
shares
% of the share
capital
V.E. Psaltis
Chief Executive Officer (CEO)
264,585
0.011
Members
S.N. Filaretos
Chief of Growth and Innovation
186,836
0.008
S.A. Andronikakis
Chief Risk Officer (CRO)
186,836
0.008
L.A. Papagaryfallou
Chief Financial Officer (CFO)
51,546
0.002
I.M. Emiris
Chief of Wholesale Banking
167,545
0.007
I.S. Passas
Chief of Retail Banking
97,290
0.004
N.R. Chryssanthopoulos
(resignation effective as of 16.2.2024)
Chief of Corporate Center (CCC)
39,722
0.002
S.B.-A. Oprescu
Chief of International Network
140,126
0.006
A.C. Sakellariou
(resignation effective as of 1.2.2024)
Chief Transformation Officer
(CTO)
27,176
0.001
S.N. Mytilinaios
Chief Operating Officer (COO)
0
0.000
F.G. Melissa
Chief Human Resources Officer
(CHRO)
30,573
0.001
G.V. Michalopoulos
Chief of Wealth Management
142,126
0.006
CORPORATE GOVERNANCE STATEMENT
130 | ANNUAL FINANCIAL REPORT
H. DESCRIPTION OF THE DIVERSITY POLICY APPLIED TO THE MEMBERS OF
THE BOARD OF DIRECTORS AND EMPLOYEES
The Diversity Policy is a document of Alpha Services and Holdings S.A. which sets out the principles and the approach for the
achievement of diversity in both the Board of Directors and the Employees, in accordance with the legislative and regulatory
framework in force, including the relevant Joint ESMA/EBA “Guidelines on the assessment of the suitability of members of the
management body and key function holders”, as well as with European best practices in corporate governance.
Diversity is defined as the situation in which the characteristics of the Members of the Board of Directors and of the Employees,
including age, gender, geographical provenance and educational and professional background, are sufficiently different to an
extent that allows a variety of views within the Board of Directors and among the Employees.
While the diversity of the Board of Directors is not a criterion for the assessment of the Members’ individual suitability, diversity
should be taken into account when selecting and assessing Members of the Board of Directors. Diversity within the Board of
Directors leads to a broader range of experience, knowledge, skills and values and is one of the factors that enhance its functioning
and address the phenomenon of “groupthink”. Thus, a more diverse Board of Directors, in its supervisory and management
functions, can reduce the phenomenon of “groupthink” and facilitate independent opinions and constructive challenging in the
process of decision-making.
The Policy applies to the selection procedure followed for the Members of the Board of Directors and is also taken into
consideration for the appointment of the Company’s Senior Management and Employees.
The objectives of the Policy are to:
• Support and promote diversity in the Board of Directors and the Employees.
• Engage a broad set of qualities and competences when recruiting Members of the Board of Directors and Employees, to
achieve a variety of views and experiences and to facilitate independent opinions and sound decision-making within the
Board of Directors.
• Ensure that there is an appropriate representation of all genders within the Board of Directors.
• Ensure that the principle of equal opportunities is respected when selecting Members of the Board of Directors.
• Ensure equal treatment and opportunities for Employees of different genders.
• Ensure that, when setting diversity objectives, the Company considers diversity benchmarking results published by the
competent authorities, the European Banking Authority (EBA) or other relevant international bodies or organizations.
The Policy is approved by the Board of Directors and is reviewed every two years by the CGSNC, which may propose relevant
amendments to the Board of Directors.
1. BOARD OF DIRECTORS
The Company, taking into account the existing framework, embraces the benefits of having a diverse Board of Directors. It
recognizes that diversity can help achieve maximum team performance and effectiveness, enhance innovation and creativity and
promote critical thinking and team cooperation within the Board. In this context, a diversified Board of Directors fosters constructive
challenge and discussion on the basis of different points of view, while also contributing to the improvement of decision-making
regarding strategies and risk-taking by encompassing a broader range of views, opinions, experience, perception, values and
backgrounds and reducing the phenomena of “groupthink” and “herd behavior”.
A truly diversified Board of Directors allows and makes good use of differences in skills, regional and industry experience,
background, abilities, qualifications, professional training, gender and other distinctions between the Members. Pursuant to the
Suitability and Nomination Policy for the Members of the Board of Directors of the Company, all Board appointments, including the
succession planning, are made in accordance with legal and regulatory requirements, ensuring an optimal balance, among others,
of skills, experience, knowledge independence and high ethical standards, without any discriminations based on sex, race, color,
ethnic or social origin, religion or belief, property, birth, disability, sexual orientation, gender, age, geographical provenance and/or
educational and professional background.
The above suitability and differentiation parameters should be taken into consideration in determining the best possible composition
of the Board of Directors and, when possible, should be balanced appropriately.
CORPORATE GOVERNANCE STATEMENT
131 | ANNUAL FINANCIAL REPORT
At least the following diversity aspects shall be taken into consideration for all Board appointments, without prejudice to the
legislative and regulatory framework and to the Suitability and Nomination Policy for the Members of the Board of Directors of the
Company:
• Educational and professional background, skills and knowledge as well as experience in order to facilitate
productive challenge and independent thinking, in accordance with the Suitability and Nomination Policy for the
Members of the Board of Directors.
• Gender: taking into consideration that different typical attitudes and behaviors can be observed in persons of different
genders.
• Age: considering that the time period in which a person has grown up influences his/her values, behavior and risk
culture.
• Geographical provenance: the region where a person has gained a cultural, educational or prior professional
background. Diversity regarding geographical provenance ensures that the Board has a direct understanding of the
culture values, market specificities and legal framework present in main business hubs that the Company is active in and
facilitates well-informed decision-making regarding the business strategy in those business and geographical areas.
In reviewing the composition of the Board of Directors and in identifying suitable candidates for appointment, reappointment or
during the succession planning, the CGSNC will:
a. Consider the benefits of all aspects of diversity, including, but not limited to, those described above, in order to enable
the Board of Directors to discharge its duties and responsibilities effectively.
b. Consider candidates on the basis of merit and objective criteria pursuant to the strategic objectives of the Company, the
legislative and regulatory requirements and with due consideration of diversity in the Board of Directors.
According to the legal and regulatory framework, as described in the “Suitability and Nomination Policy for the Members of the
Board of Directors”, the CGSNC assesses or re-assesses on an ongoing basis, and at least annually, on the basis of the “Suitability
and Nomination Process for the Members of the Board of Directors”, the collective and individual suitability of the Members of the
Board of Directors. As part of this annual evaluation of the effectiveness of the Board of Directors and its Committees, the CGSNC
will consider the adequate balance of all aspects of suitability and diversity, including, but not limited to, those described above.
The CGSNC will discuss and agree annually upon all measurable objectives for achieving diversity in the Board of Directors. In the
event that any diversity objectives or targets have not been met, the CGSNC shall explain the relevant reasons and the measures
to be taken, in order to ensure that the diversity objectives and targets will be met.
The CGSNC reviews and monitors regularly the effectiveness of the Policy and makes relevant recommendations to the Board of
Directors. Furthermore, it reviews regularly the proportion of women who are employed by the Company as a whole, in senior
management positions and in the Board of Directors.
According to the Diversity Policy, the Board of Directors’ actual target is that the percentage of the less represented gender in the
Board would reach at least 30% in the next three years, while always considering industry trends and best practices. In light of the
above, the Board of Directors’ target has been achieved, i.e. at a percentage of 38.5%.
All the candidates for the Board of Directors shall be assessed on the basis of the same criteria, irrespective of gender, since the
eligible Members for the Board of Directors must fulfill all the conditions set in relation to their qualifications. In this context, all
genders shall have equal opportunities to be nominated under the condition that they fulfill all the other prerequisites in accordance
with the Suitability and Nomination Policy for the Members of the Board of Directors of the Company. The Company shall not
nominate Members of the Board of Directors with the sole purpose of increasing diversity to the detriment of the functioning and
suitability of the Board of Directors collectively or at the expense of the suitability of individual Members of the Board of Directors.
(Based on the composition of the Board of Directors on 31.12.2023)
CORPORATE GOVERNANCE STATEMENT
132 | ANNUAL FINANCIAL REPORT
(Based on the composition of the Board of Directors on 31.12.2023)
(Based on the composition of the Board of Directors on 31.12.2023)
(Based on the composition of the Board of Directors on 31.12.2023)
2. EMPLOYEES
The provision of equal opportunities for employment and advancement to all its Employees is not merely a legal obligation of the
Company but rather a cornerstone of its Human Resources Strategy. It is thus incorporated in the Human Resources management
procedures and practices and the Company ensures the implementation thereof in every country where it is present.
When setting diversity objectives, the Company considers diversity benchmarking results, published by competent authorities, the
EBA or other relevant international bodies or organizations.
Seeking to implement gender equality in action and to address the issue of the low percentage of women in positions of
responsibility, issues which are typical of the Greek labor market, the Company takes a number of measures which help its
Employees balance their professional and family life, while also promoting equitable treatment and merit-based Employees’
advancement, with equal advancement opportunities for female Employees. In addition, a multitude of training, coaching and
mentoring initiatives are in place to support gender equality. The Company also aims to reflect the gender diversification evidenced
in the Employees in the Senior Management.
The Company applies uniform, gender-neutral Remuneration and Benefits and Corporate Expenses Policies to all categories of
Employees. It respects and defends the diversity of all Employees in general, promoting inclusiveness and equal treatment.
The Company provides a work environment free of discrimination and harassment and values the work and worth of each and
every Employee. It ensures top-quality work conditions and opportunities for advancement that are based on merit and equitable
treatment. It offers fair remuneration, based on contracts which are in agreement with the conditions of the corresponding national
labor market and ensures compliance with the respective national regulations, inter alia, on minimum pay, working hours and the
granting of leave.
CORPORATE GOVERNANCE STATEMENT
133 | ANNUAL FINANCIAL REPORT
The Company defends human rights and opposes all forms of child, forced or compulsory labor. The Company respects employee
rights and is committed to safeguarding them fully, in accordance with the national and the European Union Law and the
Conventions of the International Labour Organization.
The Company, in order to monitor and minimize diversity gaps, reviews relevant data on an annual basis and implements corrective
measures to narrow gaps, where these exist.
Employees in Management positions* as of 31.12.2023 (data for Alpha Services and Holdings S.A. and Alpha Bank S.A.)
*Management positions are defined as the positions from the level of Branch Manager and above.
The percentage and number of Employees in managerial positions per educational level indicate that Employees in managerial
positions holding postgraduate degrees represent in 2023 the highest percentage, i.e. 54%.
Recognizing, though, the need to enhance the soft skills of people managers and foster a culture of continuous training, the
Company has invested in multiple training channels. Dedicated learning leadership journeys are available on the online learning
platform of the Company, while during 2023 the course “Managing Hybrid Teams” was launched as part of the Leadership
Academy. Additionally, in each of the existing Academies currently provided, dedicated sections for people managers are available.
CORPORATE GOVERNANCE STATEMENT
134 | ANNUAL FINANCIAL REPORT
I. REMUNERATION
The updated and amended Remuneration Policy of the Members of the Board of Directors, in accordance with articles 110 and 111
of Law 4548/2018, was approved by the Ordinary General Meeting of 27.7.2023, as proposed by the Board of Directors, following a
relevant recommendation by the Remuneration Committee.
The Remuneration Policy of the Members of the Board of Directors, in accordance with articles 110 and 111 of Law 4548/2018, is
available on the Company’s website, as stipulated by Law, through the link https://www.alphaholdings.gr/-
/media/alphaholdings/files/genikes-syneleysis/taktiki-geniki-sineleusi-27072023/eggrafa-gs/remuneration-
policy_2023_en.pdf?la=en&hash=28FE55138633CBD7632EDB92C17CEE32C5C35D8A.
The Remuneration Report is and will remain available on the Company’s website for a time period of ten years, as stipulated by
Law, through the link https://www.alphaholdings.gr/en/esg-and-sustainability/advocating-sound-governance-
practices/management/codes-and-policies
Athens, March 6, 2024
THE CHAIRMAN
OF THE BOARD OF DIRECTORS
THE CHIEF
EXECUTIVE OFFICER
VASILEIOS T. RAPANOS
ID. No ΑΙ 666242
VASSILIOS E. PSALTIS
ID. No ΑΙ 666591
TRUE TRANSLATION FROM THE ORIGINAL IN GREEK
INDEPENDENT AUDITOR’S REPORT
To the Shareholders of Alpha Services and Holdings S.A.
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We have audited the separate and consolidated financial statements of Alpha Services and Holdings S.A. (the
Company), which comprise the separate and consolidated balance sheet as at 31 December 2023, and the separate
and consolidated statements of income and comprehensive income, changes in equity and cash flows for the year
then ended and the 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 financial position of Alpha Services and Holdings S.A. and its subsidiaries (the Group) as at 31
December 2023, their financial performance and their cash flows for the year then ended in accordance with
International Financial Reporting Standards (IFRSs), as endorsed by the European Union.
Basis for Opinion
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 Company 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 Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the
separate and consolidated financial statements of the current 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 at amortized cost
Loans at amortized cost of the Group amounted to 35,915 million
for the Group as at 31 December 2023 (31.12.2022: € 39,121
million) and allowance for expected credit losses amounted to
842 million, as at 31 December 2023 (31.12.2022: 1,095 million).
Measurement of ECL on loans at amortized cost is considered a
key audit matter as the determination of assumptions used,
involves critical Management judgments and accounting
estimates with high level of subjectivity, and complexity.
The most significant Management judgements and accounting
estimates, relate to:
• The criteria used for the staging assessment of loans at
amortized cost (Significant Increase in Credit Risk –SICR and
Unlikeness to Pay –UTP).
• The determination of credit risk parameters, such as Loss
Given Default (LGD), Probability of Default (PD) and the
Exposure at Default (EAD) as well as the modelling
assumptions and data used to build and run the credit risk
models (“models”).
• Assumptions of expected future cash flows of individually
assessed credit impaired exposures, including assessment
approach, valuation of collaterals, and the time to liquidate
the collaterals.
• The forecast of each significant forward-looking information
(growth rates, unemployment, inflation and real estate
indices) used by Management in the ECL models, and the
probability weightings used to estimate the impact of
multiple economic scenarios.
• The Identification and valuation of post model adjustments
made by Management to include any impact not captured by
the credit risk models.
Management has provided further information about principles
and accounting policies for determining the ECL on loans at
amortized cost and management of credit risk in Notes 1.2.13,
10, 22 and 47.1 to the 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 or operating effectiveness of
relevant internal controls over the ECL estimate including
the controls around:
- the incorporation of the model’s outcome within the
relevant systems and the calculation of the ECL
estimate
- the significant assumptions used in the models
- model monitoring and model validation
- governance and review of post model adjustments
- the determination of staging criteria and staging
allocation
- the selection of the significant forward-looking
information used in the credit risk models
- the selection of macro-economic scenarios and
probability weightings.
- accuracy and completeness of data used in the credit
risk models.
• We assessed the design and the operating effectiveness
of relevant controls over the ECL measurement of credit
impaired loans assessed on an individual basis, including
controls around the determination of the appropriate
approach, the valuation and time to liquidation of
collaterals as well as the estimation of the expected
future cash flows.
• With the support of our financial risk modelling
specialists we:
- assessed the appropriateness of the Group’s IFRS9
impairment methodologies,
- assessed the appropriateness of the criteria used to
allocate loans to stages in accordance with IFRS9.
This included an evaluation of the criteria set by
Management for determining whether there had
been a Significant Increase in Credit Risk (SICR) or an
Unlikeness to Pay (UTP). On a sample basis assessed
the timely identification of SICR, UTP and other
criteria used for staging allocation,
- inspected credit risk model codes (development) and
assessed the appropriateness of the significant credit
risk parameters (i.e. Loss Given Default-LGD,
Probability of Default –PD, Exposure at Default –
EAD), used in the models
Key audit matters
How our audit addressed the Key audit matters
Allowance for expected credit losses (ECL) for loans at amortized cost (continued)
- assessed the validation reports prepared by
Management through reperformance of certain
validation metrics
- on a sample basis tested the mathematical accuracy of
the ECL estimate through recalculation
- assessed the reasonableness and appropriateness of
the significant forward-looking information, used in the
models by comparing them to those included in
external market sources.
• We further performed substantive procedures to test the
accuracy and completeness of critical data used in the ECL
models by agreeing a sample of ECL calculation data points
to source systems or documentation.
• On a sample basis we assessed whether, the approach
used in the measurement of impairment for the
individually assessed credit impaired exposures is
appropriate, and we tested the reasonableness of
significant assumptions used, including valuation of
collaterals (where we also made use of our real estate
specialists), time to liquidate collaterals, and the estimation
of the discounted future cash flows.
• We assessed the post model adjustments, made by
Management in order to incorporate the uncertainty in the
economic environment, not captured by the models.
Given the complexity and granularity of the related
disclosures, we 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
Strategic Partnership with UniCredit SpA – Classification and Measurement of Assets Held for Sale
The Group in October 2023 entered into a partnership
agreement with UniCredit SpA. Τhe agreement, among
others, provides for the sale of 51% of the Group’s
investments in Alpha Life and the merger of the banking
subsidiaries of Alpha Services and Holdings S.A. and UniCredit
SpA in Romania, where the Group will maintain a 9.9% stake
in the new company (Project “Unicorn”). As of 31.12.2023
Held for Sale Assets in consolidated financial statements
relating to Unicorn project amount to € 5,521 million.
The classification and measurement of the underlying assets
and liabilities, as well as the disclosures related to this
transaction is considered a key audit matter as the
accounting treatment based on the terms of this transaction
involves complexity and high degree of Management
judgement and accounting estimates.
The most significant Management judgements and
accounting estimates, relate to:
• Management’s assessment for the determination of
whether the assets involved in this transaction meet the
criteria of IFRS 5 “Non -Current Assets Held for Sale and
Discontinued Operations” i.e. the assets are available for
immediate sale in its present condition and their sale is
highly probable,
• Methods, assumptions, terms and market data used for
the determination of the fair value of the underlying
assets.
Management has provided further information in Notes
1.2.17, 1.2.34, 52 and 55 to the consolidated financial
statements.
Based on our risk assessment and following a risk-based
approach, we have evaluated the assumptions made by
Management in relation to this key audit matter, and we
performed, inter alia, the following audit procedures:
• We assessed the design and implementation of the
relevant internal controls over the Project “Unicorn”,
including internal controls over the review and approval
process of the underlying transactions, classification and
measurement of the related assets and liabilities in
accordance with applicable reporting framework and the
relevant accounting entries performed as part of the
financial statements closing process.
• We assessed whether the classification criteria of IFRS 5
“Non-Current Assets Held for Sale and Discontinued
Operations” are being met, based on the available
information, including the terms of the Memorandum of
Agreement with UniCredit SpA and the relevant decisions
of the Board of Directors' Committees.
• We obtained the fair value exercise for the transaction
related to the subsidiaries in Romania and with the
assistance of our fair value specialists, we assessed the
reasonableness of the assumptions used, the accuracy of
the data included in the calculations and appropriateness
of the fair value method applied.
• We further assessed whether Management has properly
measured the held for sale assets i.e. at the lower of fair
value less cost to sell and carrying amount.
Given the complexity and granularity of the related
disclosures we assessed their accuracy and completeness in
accordance with the provisions of the relevant accounting
standards.
Key audit matters
How our audit addressed the Key audit matters
Recoverability of Deferred Tax Asset (DTA)
The Group has recognized deferred tax assets of €4,978
million as at 31 December 2023, (€ 5,233 million as at 31
December 2022).
The recognition and measurement of the deferred tax asset
is considered a key audit matter as it involves a high degree
of Management judgment and significant accounting
estimates.
The most significant judgements and estimates made by
Management for assessing the recoverability of deferred tax
assets include:
• Revenue and Cost forecasts for the preparation of the
annual budget and the 3 year business plan taking into
account the impact of the Group’s strategic plan.
• Forward looking information and Management
projections used to extend the period covered under the
business plan to the time when the deferred tax asset
can be utilized for tax purposes.
• Adjustments required for the conversion of accounting
profits to taxable profits.
Management has provided further information about the
deferred tax asset in Notes 1.2.16, 16 and 28 to the
consolidated financial statements.
Based on our risk assessment, we evaluated the method used
to determine the amount of deferred tax asset recognized
and examined the budgets prepared and significant
assumptions made by Management relating to the future
taxable profits.
Our examination included, inter alia, the following audit
procedures where we also made use of our tax specialists:
• We assessed the design and implementation of the
relevant internal controls over the preparation and
approval of the annual budget and the 3year business plan
as well as over the forward looking information, including
the internal controls over the significant assumptions,
inputs, calculation and methodologies used for this
purpose.
• We compared prior years’ budgets to actual results, to
evaluate the forecasting ability of Management.
• We compared the significant assumptions used by
Management in the DTA exercise with the approved
budget and the 3 year business plan for consistency and
assessed their reasonability by evaluating the underlying
business strategies.
• We assessed whether significant assumptions used beyond
the business plan period were reasonable in the context of
the long - term economic outlook.
• We assessed the appropriateness of the adjustments made
by Management to convert the forecasted accounting
profits into tax profits, considering the tax legislation
currently in force.
We evaluated the accuracy and completeness of the related
disclosures in accordance with the provisions of the relevant
accounting standards.
Information Technology General Controls and controls over financial reporting
The Company’s and the Group’s financial reporting processes
are highly dependent on Information Technology (“IT”)
systems 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 access security, cyber risks, system change control and
datacenter and network operations, are designed and
operate effectively to ensure complete and accurate financial
records and information.
Management has provided further information about
General Information Technology Controls under the header
“Internal Control System” in Section C of the Corporate
Governance Statement for the year 2023
Based on our risk assessment, we have tested the design and
operating effectiveness of General Information Technology
Controls (GITCs) relevant for financial reporting. Our
assessment included the evaluation of user access and the
change management process over applications, operating
systems and databases, as well as the evaluation of
datacenter and network IT 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 in Information
Systems .
- Change management process over applications,
operating systems and databases (i.e. user request,
user acceptance testing and final approval for
promotion to production).
- Datacenter and network operations.
Other Information
Management is responsible for the other information. The other information, included in the Annual Report
prepared in accordance with Law 3556/2007, comprises the Board of Directors’ Annual Management Report,
referred to in the section “Report on Other Legal and Regulatory Requirements”, the Statement by the Members
of the Board of Directors, the Explanatory Report of the Board of Directors, and the Corporate Governance
Statement 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
Company’s and the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to
going concern and using the going concern basis of accounting unless Management either intends to liquidate the
Company and the Group or to cease operations, or has no realistic alternative but to do so.
The Audit Committee (article 44 of Law 4449/2017) of the Company is responsible for overseeing the Company’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 Company’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 Company’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 Company 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.
• Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business
activities within the Group to express an opinion on the separate and consolidated financial statements.
We are responsible for the direction, supervision and performance of the audit of the Company and the
Group. 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’ Annual Management Report
Taking into consideration that Management is responsible for the preparation of the Board of Directors’
Annual Management report which also includes the Corporate Governance Statement, according to the
provisions of paragraph 5 of article 2 of Law 4336/2015 (part B) 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 - 151 and 153 - 154 and paragraph 1 (cases c and d)
of article 152 of Law 4548/2018 and its content is consistent with the accompanying separate
and consolidated financial statements for the year ended 31 December 2023.
c) Based on the knowledge we obtained during our audit of the Company and the Group and its
environment, we have not identified any material inconsistencies in the Board of Directors’
Annual Management Report.
2. Additional Report to the Audit Committee
Our audit opinion on the accompanying separate and consolidated financial statements is consistent with
the additional report to the Audit Committee of the Company referred to in Article 11 of the European
Union (EU) Regulation 537/2014.
3. Non-audit Services
We have not provided to the Company 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 Company and the Group by Deloitte Certified Public
Accountants S.A., which is a member firm of Deloitte Touche Tohmatsu Limited (“DTTL”), during the year
ended 31 December 2023 are disclosed in Note 35 and 50 to the accompanying separate and
consolidated financial statements respectively.
4. Appointment
We were first appointed as statutory auditors by the general assembly of the shareholders of the
Company on 30 June 2017. Our appointment has been, since then, uninterruptedly renewed by the
annual general assembly of the shareholders for seven consecutive years.
5. Internal Regulation
The Company retains an Internal Regulation according to the provisions of article 14 of Law 4706/2020.
6. Assurance Report on European Single Electronic Format reporting
We have examined the digital files of Alpha Services and Holdings S.A. (hereinafter the Company or/and
the Group), prepared in accordance with the European Single Electronic Format (ESEF), defined by the
Commission Delegated EU Regulation 2019/815 as amended by EU Regulation 2020/1989 (“ESEF
Regulation”), which include the separate and consolidated financial statements of the Company and the
Group for the year ended 31 December 2023 in XHTML format as well as the XBRL file
(5299009N55YRQC69CN08-2023-12-31-el.zip) with the appropriate tagging on these consolidated
financial statements, including the notes to the financial statements.
Regulatory Framework
The ESEF digital files are prepared in accordance with the ESEF Regulation, and the Interpretation Announcement
2020/C 379/01 of the European Commission dated 10 November 2020, as provided by L.3556/2007 and the
relevant announcements of the Hellenic Capital Market Commission and the Athens Stock Exchange (the “ESEF
Regulatory Framework”). In summary this Regulatory Framework includes, inter alia, the following requirements:
- Annual financial statements shall 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 Balance Sheet, Income statement
and 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.
Regulatory requirements included in ESEF Regulatory Framework consist an appropriate basis for the purpose of
expressing a conclusion that provides reasonable assurance.
Responsibilities of Management and Those Charged with Governance
Management is responsible for the preparation and submission of these separate and consolidated financial
statements of the Company and the Group for the year ended 31 December 2023, in accordance with the
requirements set by the ESEF Regulatory Framework and for such internal controls that Management determine
are necessary to enable the preparation of the digital files that are free from material misstatement, whether due
to fraud or error.
Auditor’s responsibilities
Our responsibility is to design and perform this assurance procedure in accordance with the decision 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 listed shares in the Hellenic capital market” dated 14/02/2022 as issued by the Institute of Certified Public
Accountants (the “ESEF Guidelines”) in order to obtain reasonable assurance about whether the separate and
consolidated financial statements of the Company and the Group, prepared by Management in accordance with
ESEF, comply in all material respects with the ESEF Regulatory Framework, as currently in force.
In conducting this work, we have complied with the International Ethics Standards Board for Accountants’ Code of
Ethics for Professional Accountants (IESBA Code), as incorporated into the Greek legislation and additionally we
have we have complied with ethical requirements regarding independence, in accordance with Law 4449/2017
and EU Regulation No 537/2014.
The assurance work performed, is limited to the items included in the ESΕF Guidelines and has been performed in
accordance with the International Standard on Assurance Engagements 3000 “Assurance engagements other than
audits or review of historical financial information”. Reasonable assurance is a high level of assurance but is not a
guarantee that this work will always detect a material misstatement when it exists relating to the compliance with
the requirements of ESEF Regulatory Framework.
Conclusion
Based on the procedures performed and the evidence obtained, we conclude that the separate and the consolidated financial
statements of the Company and the Group for the year ended 31 December 2023 prepared in XHTML format as well as the XBRL
file (5299009N55YRQC69CN08-2023-12-31-el.zip) with the appropriate tagging on these consolidated financial statements,
including the notes, are prepared in all material respects in accordance with the requirements of ESEF Regulatory Framework.
Athens, 6 March 2024
The Certified Public Accountant
Foteini D. Giannopoulou
Reg. No. SOEL: 24031
Deloitte Certified Public Accountants S.A.
3a Fragoklissias & Granikou Str.
151 25 Maroussi
Reg. No. SOEL: Ε120
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.
Group Financial Statements as at 31.12.2023
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
147 | ANNUAL FINANCIAL REPORT
The attached notes (pages 153-416) form an integral part of these consolidated financial statements
Consolidated Income Statement
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022 as
restated
Interest and similar income
Interest expense and similar charges
(1,922,514 )
(517,758 )
Net interest income
2
- of which: net interest income based on the effective interest rate
Fee and commission income
Commission expense
(59,367 )
(77,044 )
Net fee and commission income
3
Dividend income
4
Gains less losses on derecognition of financial assets measured at amortised cost
5
(17,220 )
(4,268 )
Gains less losses on financial transactions
6
Other income
7
Total income from banking operations
Staff costs
8
(332,951 )
(327,271 )
General administrative expenses
9
(326,702 )
(386,753 )
Depreciation and amortization
25,26,27
(157,420 )
(142,678 )
Total expenses
(817,073 )
(856,702 )
Impairment losses and provisions to cover credit risk
10
(381,027 )
(476,718 )
Expenses relating to credit risk management
11
(86,407 )
(84,246 )
Impairment losses on fixed assets and equity investments
12
(18,895 )
(67,583 )
Gains/(Losses) on disposal of fixed assets and equity investments
13
Provisions
14
(45,913 )
(32,664 )
Transformation costs
15
(4,007 )
(8,699 )
Share of profit/(loss) of associates and joint ventures
Profit/(loss) before income tax
Income tax
16
(233,008 )
(238,931 )
Net profit/(loss) from continuing operations for the year after income tax
Net profit/(loss) for the period after income tax from discontinued operations
55
Net profit/(loss) for the year
Net profit/(loss) attributable to:
Equity Holders of the Company
- from continuing operations
- from discontinued operations
Non-controlling interests
Earnings/(losses) per share:
Basic (€ per share)
17
Basic (€ per share) from continuing operations
17
Basic (€ per share) from discontinued operations
17
Diluted (€ per share)
17
Diluted (€ per share) from continuing operations
17
Diluted (€ per share) from discontinued operations
17
Certain figures of the previous year have been restated as described in note 54.
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
148 | ANNUAL FINANCIAL REPORT
The attached notes (pages 153-416) form an integral part of these consolidated financial statements
Consolidated Statement of Comprehensive Income
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022 as
restated
Net profit/(loss), after income tax, recognized in the Income Statement
Other comprehensive income
Items that may be reclassified subsequently to the Income Statement
Net change in investment securities' reserve measured at fair value through other
comprehensive income
(52,925 )
Net change in cash flow hedge reserve
(14,188 )
Foreign currency translation net of investment hedges of foreign operations
Income tax
16
(16,107 )
Items that may be reclassified subsequently to the Income Statement from
continuing operations
(45,408 )
Items that may be reclassified subsequently to the Income Statement from
discontinued operations
(100,323 )
Items that will not be reclassified to the Income Statement
Remeasurement of defined benefit liability/ (asset)
35
(2,127 )
Gains/(losses) from investments in equity securities measured at fair value through
other comprehensive income
(16,132 )
Income tax
16
(2,703 )
Items that will not be reclassified to the Income Statement from continuing
operations
(7,614 )
Other comprehensive income, after income tax, for the year
(153,345 )
Total comprehensive income for the year
Total comprehensive income for the period attributable to:
Equity holders of the Company
-from continuing operations
-from discontinued operations
(36,862 )
Non controlling interests
Certain figures of the previous year have been restated as described in note 54.
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
149 | ANNUAL FINANCIAL REPORT
The attached notes (pages 153-416) form an integral part of these consolidated financial statements
Consolidated Balance Sheet
(Amounts in thousands of Euro)
Note
31.12.2023
31.12.2022 as
restated
ASSETS
Cash and balances with central banks
18
Due from banks
19
Trading securities
20
Derivative financial assets
21
Loans and advances to customers
22
Reinsurance contract assets
Investment securities
23
- Measured at fair value through other comprehensive income
23a
- Measured at amortized cost
23b
- Measured at fair value through profit or loss
23c
Investments in associates and joint ventures
24
Investment property
25
Property, plant and equipment
26
Goodwill and other intangible assets
27
Deferred tax assets
28
Other assets
29
Assets classified as held for sale
52
Total Assets
LIABILITIES
Due to banks
30
Derivative financial liabilities
21
Due to customers
31
Insurance contract liabilities
32
Debt securities in issue and other borrowed funds
33
Liabilities for current income tax and other taxes
34
Deferred tax liabilities
28
Employee defined benefit obligations
35
Other liabilities
36
Provisions
37
Liabilities related to assets classified as held for sale
52
Total Liabilities
EQUITY
Equity attributable to holders of the Company
Share capital
38
Share premium
39
Other Εquity Ιnstruments
40
Special Reserve from Share Capital Decrease
39
Reserves
41
(111,301 )
(273,048 )
Amounts directly recognized in equity and are associated with assets classified as held
for sale
41
(63,656 )
Retained earnings
42
Less: Treasury shares
38
(10,631 )
(1,296 )
Non-controlling interests
Total Equity
Total Liabilities and Equity
Certain figures of the previous year have been restated as described in note 54.
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
150 | ANNUAL FINANCIAL REPORT
The attached notes (pages 153-416) form an integral part of these consolidated financial statements
Consolidated Statement of Changes in Equity
(Amounts in thousands of Euro)
Note
Share
Capital
Treasury
shares
Share
premium
Special Reserve
from Share Capital
Decrease
Reserves
Amounts directly
recognized in equity and
associated with assets
classified as held for sale
Retained earnings as
restated
Total as
restated
Non-controlling
interests
Hybrid
Securities
Total
Balance 31.12.2021
(6,366,258 )
Impact from initial application of IFRS 17
54
Restated Balance 1.1.2022
(6,350,782 )
Changes for the period 1.1 – 31.12.2022
Profit/(loss) for the year, after income tax as
restated
Other comprehensive income for the year, after
income tax
(130,604 )
(15,127 )
(7,614 )
(153,345 )
(153,345 )
Total comprehensive income for the year
(130,604 )
(15,127 )
Share Capital Increase through options
exercise
(1,597 )
Off setting of Net Profit with Reserves
(5,808,466 )
(420,425 )
Share capital decrease through distribution in
kind
(23,474 )
(23,474 )
(23,474 )
Transfer
(51,444 )
(Acquisitions), Disposals / Share capital
increase and other changes of ownership
interests in subsidiaries
(8,338 )
(8,338 )
Sales and purchases of treasury shares
(1,296 )
(1,296 )
(1,296 )
Valuation reserve of employee stock option
program
Dividend distribution
(3,031 )
(3,031 )
Appropriation of reserves
(8,101 )
(Purchases), (redemption)/ sales of hybrid
securities, after income tax
(14,229 )
(14,229 )
Expenses for share capital increase
(179 )
(179 )
(179 )
Other
Balance 31.12.2022
(1,296 )
(273,048 )
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
151 | ANNUAL FINANCIAL REPORT
The attached notes (pages 153-416) form an integral part of these consolidated financial statements
(Amounts in thousands of Euro)
Note
Share
Capital
Treasury
shares
Share
premium
Other Equity
Instruments
Special Reserve
from Share
Capital Decrease
Reserves
Amounts directly
recognized in equity
and associated with
assets classified as
held for sale
Retained
earnings
Total as
restated
Non-
controlling
interests
Total as
restated
Balance 1.1.2023
(1,296 )
(273,048 )
Restated Balance 1.1.2023
Profit/(loss) for the year, after income tax
Other comprehensive income for the year,
after income tax
Total comprehensive income for the
year, after income tax
Share Capital Increase through options
exercise
(2,700 )
Offsetting of Retained Earnings
(478,810 )
(296,424 )
(747 )
Transfer of cumulative income and
expenses recognised directly in equity that
relate to assets classified as held for sale
(63,656 )
(3,006 )
Valuation reserve of employee stock option
program
Reserve valuation for stock awards
Payment of AT1 dividend, after income tax
(16,747 )
(16,747 )
(16,747 )
Sales and purchases of treasury shares
(9,335 )
(8,060 )
(8,060 )
AT1 Capital instrument Issuance
Expenses of AT1 Capital instruments
Issuance
(5,550 )
(5,550 )
(5,550 )
Appropriation of reserves
(23,543 )
Dividend distribution
(617 )
(617 )
Expenses for share capital increase, after
income tax
(36 )
(36 )
(36 )
Other
(2,504 )
(1,844 )
(1,597 )
Balance 31.12.2023
(10,631 )
(111,301 )
(63,656 )
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
152 | ANNUAL FINANCIAL REPORT
Consolidated Statement of Cash Flows
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022 as
restated
Cash flows from continuing operating activities
Profit/(loss) before income tax from continued operations
Adjustments of profit/(loss) before income tax for:
Depreciation, impairment, write-offs and net result from disposal of property, plant and equipment
Amortization, impairment, write-offs of intangible assets
Impairment losses on financial assets, related expenses and other provisions
Gains less losses on derecognition of financial assets measured at amortised cost
Fair value (gains)/losses on financial assets measured at fair value through profit or loss
(194,045 )
(Gains)/losses from investing activities
(512,162 )
(248,426 )
(Gains)/losses from financing activities
(56,403 )
Share of (profit)/loss of associates and joint ventures
(875 )
(3,048 )
Net (increase)/decrease in assets relating to continuing operating activities:
Due from banks
(213,672 )
Trading securities and derivative financial instruments
Loans and advances to customers
(613,995 )
(1,996,542 )
Other assets
(238,668 )
Net increase/(decrease) in liabilities relating to continuing operating activities:
Due to banks
(7,016,119 )
Due to customers
Other liabilities
(96,517 )
Net cash flows from continuing operating activities before income tax
(5,228,912 )
Income tax paid
(482 )
(51,397 )
Net cash flows from continuing operating activities
(5,229,394 )
Net cash flows from discontinued operating activities
(127,790 )
Cash flows from continuing investing activities
Proceeds from disposals of subsidiaries
Dividend Received
Investments in associates and joint ventures
(245 )
Acquisitions of investment property, property, plant and equipment and intangible assets
25,26,27
(150,249 )
(135,795 )
Disposals of investment property, property, plant and equipment and intangible assets
Interest received from investment securities
Purchases of Greek Government Treasury Bills
(2,056,126 )
(1,233,713 )
Proceeds from disposal and redemption of Greek Government Treasury Bills
Purchases of investment securities (excluding Greek Government Treasury Bills)
(4,543,675 )
(4,023,755 )
Disposals/maturities of investment securities (excluding Greek Government Treasury Bills)
Net cash flows from continuing investing activities
(2,784,158 )
(2,910,971 )
Net cash flows from discontinued investing activities
(116,579 )
(65,931 )
Cash flows from continuing financing activities
Share Capital Increase and Amounts intended for Share Capital Increase
Share Capital Increase expense
(28 )
(179 )
AT 1 issuance
Payments to the holders of AT 1, before tax
(23,750 )
Proceeds from issue of debt securities and other borrowed funds
Repayments of debt securities in issue and other borrowed funds
(533,058 )
(371,118 )
Interest paid on debt securities in issue and other borrowed funds
(126,210 )
(87,690 )
(Purchases), (Redemption)/ sales of hybrid securities
(14,299 )
Payments of lease liabilities
(27,744 )
(30,605 )
Dividend payments
(617 )
(3,031 )
Treasury Shares
(8,060 )
Net cash flows from continuing financing activities
Net cash flows from discontinued financing activities
Effect of foreign exchange changes on cash and cash equivalents
(915 )
Net increase/(decrease) from continuing cash flows
(7,721,688 )
(228,023 )
Changes in cash equivalent from discontinued operations
(127,970 )
Cash and cash equivalents at the beginning of the year from continuing operations
Cash and cash equivalents at the end of the year from continuing operations
Certain figures of the previous year have been restated as described in note 54.
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
153 | ANNUAL FINANCIAL REPORT
Notes to the Consolidated Financial Statements
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
154 | ANNUAL FINANCIAL REPORT
****
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
155 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
156 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
157 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
158 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
159 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
160 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
161 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
162 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
163 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
164 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
165 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
166 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
167 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
168 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
169 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
170 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
171 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
172 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
173 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
174 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
175 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
176 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
177 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
178 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
179 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
180 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
181 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
182 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
183 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
184 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
185 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
186 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
187 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
188 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
189 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
190 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
191 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
192 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
193 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
194 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
195 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
196 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
197 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
198 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
199 | ANNUAL FINANCIAL REPORT
INCOME STATEMENT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
200 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
201 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
202 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
203 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
204 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
205 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
206 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
207 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
208 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
209 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
210 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
211 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
212 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
213 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
214 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
215 | ANNUAL FINANCIAL REPORT
ASSETS
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
216 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
217 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
218 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
219 | ANNUAL FINANCIAL REPORT
(48,703)
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
220 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
221 | ANNUAL FINANCIAL REPORT
Assets
Liabilities
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
222 | ANNUAL FINANCIAL REPORT
Assets
Liabilities
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
223 | ANNUAL FINANCIAL REPORT
Assets
Liabilities
Assets
Liabilities
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
224 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
225 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
226 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
227 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
228 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
229 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
230 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
231 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
232 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
233 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
234 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
235 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
236 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
237 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
238 | ANNUAL FINANCIAL REPORT
for Sale
31.12.2023
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
239 | ANNUAL FINANCIAL REPORT
17 adoption
31.12.2022
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
240 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
241 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
242 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
243 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
244 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
245 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
246 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
247 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
248 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
249 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
250 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
251 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
252 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
253 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
254 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
255 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
256 | ANNUAL FINANCIAL REPORT
EQUITY
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
257 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
258 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
259 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
260 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
261 | ANNUAL FINANCIAL REPORT
ADDITIONAL INFORMATION
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
262 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
263 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
264 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
265 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
266 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
267 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
268 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
269 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
270 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
271 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
272 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
273 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
274 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
275 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
276 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
277 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
278 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
279 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
280 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
281 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
282 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
283 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
284 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
285 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
286 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
287 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
288 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
289 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
290 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
291 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
292 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
293 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
294 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
295 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
296 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
297 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
298 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
299 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
300 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
301 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
302 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
303 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
304 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
305 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
306 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
307 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
308 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
309 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
310 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
311 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
312 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
313 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
314 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
315 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
316 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
317 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
318 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
319 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
320 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
321 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
322 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
323 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
324 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
325 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
326 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
327 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
328 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
329 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
330 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
331 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
332 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
333 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
334 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
335 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
336 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
337 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
338 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
339 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
340 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
341 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
342 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
343 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
344 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
345 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
346 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
347 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
348 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
349 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
350 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
351 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
352 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
353 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
354 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
355 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
356 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
357 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
358 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
359 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
360 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
361 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
362 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
363 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
364 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
365 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
366 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
367 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
368 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
369 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
370 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
371 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
372 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
373 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
374 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
375 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
376 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
377 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
378 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
379 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
380 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
381 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
382 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
383 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
384 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
385 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
386 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
387 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
388 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
389 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
390 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
391 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
392 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
393 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
394 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
395 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
396 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
397 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
398 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
399 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
400 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
401 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
402 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
403 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
404 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
405 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
406 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
407 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
408 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
409 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
410 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
411 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
412 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
413 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
414 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
415 | ANNUAL FINANCIAL REPORT
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
416 | ANNUAL FINANCIAL REPORT
Athens, 6 March 2024
THE CHAIRMAN
OF THE BOARD OF
DIRECTORS
THE CHIEF EXECUTIVE
OFFICER
THE CHIEF FINANCIAL
OFFICER
THE CHIEF OF STATUTORY
REPORTING AND TAX
VASILEIOS T. RAPANOS
ID No ΑΙ 666242
VASSILIOS E. PSALTIS
ID No ΑΙ 666591
LAZAROS A.
PAPAGARYFALLOU
ID No ΑΚ 093634
MARIANA D. ANTONIOU
ID No Χ 694507
CONSOLIDATED FINANCIAL STATEMENTS AS AT 31.12.2023
The amounts are presented in thousands of Euro unless otherwise indicated
417 | ANNUAL FINANCIAL REPORT
Financial Statements of Alpha Services and
Holdings S.A. as at 31.12.2023
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
418 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
Income Statement
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022 as
restated
Interest and similar income
53,881
54,930
Interest expense and similar charges
(49,784)
(50,125)
Net interest income based on the effective interest rate
2
4,097
4,805
Fee and commission income
26,219
26,341
Commission expense
(19,474)
(20,124)
Net fee and commission income
3
6,745
6,217
Dividend income
4
24,150
1,290
Gains less losses on derecognition of financial assets measured at amortised cost
(10)
Gains less losses on financial transactions
5
7,103
Other income
6
1,649
502
Total income
36,641
19,907
Staff costs
7
(1,019)
(887)
General administrative expenses
8
(9,065)
(5,646)
Depreciation and amortization
17, 18
(43)
(43)
Total expenses
(10,127)
(6,576)
Impairment losses, provisions to cover credit risk
9
2,371
7,255
Expenses relating to credit risk management
10
(664)
Impairment losses on fixed assets and equity investments
(290)
Gains/(Losses) on disposal of fixed assets and equity investments
92
Profit/(loss) before income tax
28,885
19,724
Income tax
11
(302)
(4,778)
Profit/(loss) for the year
28,583
14,946
Earnings/(losses) per share
Basic (€ per share)
12
0.0021
0.0064
Diluted (€ per share)
12
0.0021
0.0064
Certain figures of the previous year have been reclassified as described in note 40.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
419 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
Statement of Comprehensive Income
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022
Profit/(loss) for the year, recognized in the Income Statement
28,583
14,946
Other comprehensive income
Items that will not be reclassified to the Income Statement
Net change in actuarial gains/(losses) of defined benefit obligations
19
Gains/(losses) from investments in equity securities measured at fair value through other
comprehensive income
(74)
(59)
Income tax
Items that will not be reclassified to the Income Statement
11
(74)
(40)
Other comprehensive income, after income tax
(74)
(40)
Total comprehensive income for the year
28,509
14,906
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
420 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
Balance Sheet
(Amounts in thousands of Euro)
Note
31.12.2023
31.12.2022
ASSETS
Due from banks
13
17,907
7,648
Due from customers
14
182
339
Investment securities:
- Measured at fair value through other comprehensive income
15
74
- Measured at amortized cost
15
1,012,530
1,007,242
Investments in subsidiaries
16
6,639,021
6,251,797
Property, plant and equipment
17
4
5
Goodwill and other intangible assets
18
287
329
Other assets
19
29,600
30,667
7,699,531
7,298,101
Assets classified as held for sale
36
16,322
Total Assets
7,715,853
7,298,101
LIABILITIES
Due to banks
20
20,246
Debt securities in issue and other borrowed funds
21
1,029,396
1,028,924
Liabilities for current income tax and other taxes
22
372
15
Employee defined benefit obligations
23
39
16
Deferred tax liabilities
24
916
614
Other liabilities
25
15,219
13,945
Total Liabilities
1,066,188
1,043,514
EQUITY
Share capital
26
681,992
680,980
Share premium
27
4,782,948
5,259,114
Special Reserve from Share Capital Decrease
28
296,424
Other Equity instruments
29
400,000
Reserves
30
794,443
792,013
Retained earnings
31
(744)
(773,944)
Less: Treasury shares
26
(8,974)
Total Equity
6,649,665
6,254,587
Total Liabilities and Equity
7,715,853
7,298,101
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
421 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
Statement of Changes in Equity
(Amounts in thousands of Euro)
Note
Share capital
Share Premium
as restated
Special Reserve
from Share
Capital Decrease
Reserves
Retained
earnings
Total
Balance 1.1.2022
703,794
5,257,622
6,104,890
423,244
(6,228,891)
6,260,659
Changes for the year
1.1 - 31.12.2022
Profit/(loss) for the year, after
income tax
14,946
14,946
Other comprehensive income
for the year, after income tax
(40)
(40)
Total comprehensive income
for the year after income tax
-
-
-
-
14,906
14,906
Discrete monitoring of
intragroup dividends in reserves
788,777
(788,777)
-
Valuation reserve of employee
stock option program
37
2,014
2,014
Expenses for share capital
increase
(178)
(178)
Offsetting of Retained Earnings
with Reserves
(5,808,466)
(420,425)
6,228,891
-
Share Capital Increase through
options exercise
660
1,492
(1,597)
105
660
Share Capital decrease through
distribution in kind
(23,474)
(23,474)
Balance 31.12.2022
680,980
5,259,114
296,424
792,013
(773,944)
6,254,587
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
422 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
(Amounts in thousands of Euro)
Note
Share
capital
Share
Premium
Special
Reserve from
Share Capital
Decrease
Other
Equity
Instruments
Reserves
Retained
earnings
Treasury
shares
Total
Balance 1.1.2023
680,980
5,259,114
296,424
-
792,013
(773,944)
-
6,254,587
Changes for the year
1.1 - 31.12.2023
Profit/(loss) for the year, after
income tax
28,583
28,583
Other comprehensive income
for the year, after income tax
(74)
(74)
Total comprehensive income
for the year after income tax
-
-
-
-
-
28,509
-
28,509
Discrete monitoring of
intragroup dividends in
reserves
30
1,290
(1,290)
-
Appropriation of reserves
30
747
(747)
-
Valuation reserve of employee
stock option program
37
670
670
Valuation reserve of employee
stock award program
38
3,170
3,170
Expenses for share capital
increase
(37)
(37)
Offsetting of Retained Earnings
with Reserves
31
(478,810)
(296,424)
(747)
775,981
-
AT1 Capital Instrument
issuance
29
400,000
400,000
Expenses for AT1 Capital
Instrument issuance
29
(5,550)
(5,550)
Payment of AT1 dividend
29
(23,750)
(23,750)
Share Capital Increase through
options exercise
26, 27,
30
1,012
2,644
(2,700)
83
1,039
Purchase of treasury shares
26
(8,974)
(8,974)
Balance 31.12.2023
681,992
4,782,948
-
400,000
794,443
(744)
(8,974)
6,649,665
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
The attached notes (pages 424-492) form an integral part of the Company’s financial statements.
423 | ANNUAL FINANCIAL REPORT The amounts are presented in thousands of Euro unless otherwise indicated
Statement of Cash Flows
(Amounts in thousands of Euro)
From 1 January to
Note
31.12.2023
31.12.2022
Cash flows from operating activities
Profit/(loss) before income tax
28,885
19,724
Adjustments of profit/(loss) before income tax for:
Depreciation, impairment, write-offs and net result from disposal of property, plant and equipment
2
2
Amortization, impairment, write-offs of intangible assets
42
42
Impairment losses on financial assets, related expenses and other provisions
(2,371)
(7,235)
Gains less losses on derecognition of financial assets measured at amortised cost
10
Fair value (gains)/losses on financial assets measured at fair value through profit or loss
(7,103)
Impairment of investments
290
(Gains) /losses from sale of investments
(91)
(Gains)/losses from investing activities
(78,031)
(54,710)
(Gains)/losses from financing activities
49,784
50,021
Other adjustments
(2,490)
(2,672)
(4,180)
(1,722)
Net (increase)/decrease in assets relating to operating activities:
Due from customers
156
(610)
Other assets
(1,426)
58,434
Net increase/(decrease) in liabilities relating to operating activities:
Other liabilities
513
(533)
Net cash flows from operating activities before income tax
(4,936)
55,570
Income tax paid / Received
8,509
(35,818)
Net cash flows from operating activities
3,573
19,751
Cash flows from investing activities
Investments in subsidiaries
(400,000)
(90,979)
Absorption of subsidiary
1,365
Dividends received
24,150
1,290
Interest received from investment securities
47,413
47,132
Disposals/maturities of investment securities
69,803
Net cash flows from investing activities
(327,073)
27,246
Cash flows from financing activities
Share Capital Increase
1,039
660
Share Capital Increase expenses
(36)
(178)
Proceeds from borrowings
30,000
Repayments of borrowings
(10,000)
Interest paid on borrowings
(220)
(86)
AT 1 issuance
394,450
Interest paid on debt securities in issue and other borrowed funds
(48,750)
(48,753)
Repayments of debt securities in issue and other borrowed funds
(16,697)
Payments of AT1 Dividends
(23,750)
Purchase of treasury shares
(8,974)
Net cash flows from financing activities
333,759
(65,055)
Net increase/(decrease) in cash flows
10,259
(18,057)
Cash and cash equivalents at the beginning of the year
7,648
25,705
Cash and cash equivalents at the end of the year
13
17,907
7,648
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
424 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Notes to the Financial Statements
GENERAL INFORMATION
On April 16, 2021, the Hive – down was completed with the spin-off of the banking activity of Alpha Bank ("Demerged") and its
contribution to a new banking company, which was registered in the General Commercial Register (G.E.M.I.) on the same day with
the distinctive title of "Alpha Bank Societe Anonyme" ("Beneficiary"). In particular, Alpha Bank Societe Anonyme substituted as
universal successor in the entire, in all the transferred Banking Business Sector (assets and liabilities), as set out in the
transformation balance sheet of the transferred banking business sector dated June 30, 2020 and formed until 16.4.2021, the day
where the spin off was completed.
The “Demerged” taking all the shares issued by Alpha Bank Societe Anonyme, became the Parent of the Bank and its subsidiaries
(Bank’s Group).
On 19.4.2021 the amendment of the Articles of Incorporation of the “Demerged” was approved, by virtue of the decision of the
Ministry of Development and Investments number 45898/19.4.2021, and the banking license of the Demerged was revoked, while
its corporate name changed to “Alpha Services and Holdings S.A.”.
The main activities of the Company include the following:
a. direct and indirect participation in domestic and / or foreign companies and enterprises that have been or will be established, of
any kind and for any purpose;
b. design, promotion and distribution of insurance products in the name and on behalf of one or more insurance companies in the
capacity of insurance agent in accordance with applicable law,
c. provision of accounting and tax support services to companies affiliated with the Company and to third parties, as well as
elaboration of studies on strategic and financial management issues; and
d. issuance of securities for raising regulatory funds, which are expected to take the form of debit / credit securities.
The Company’s name and its distinctive title is "Alpha Services and Holdings Societe Anonyme". The Company’s registered office
is 40 Stadiou Street, Athens and is listed in the General Commercial Register with registration number 223701000 (ex societe
anonyme registration number 6066/06/B/86/05). The company’s duration is until 2100 but may be extended by the General Meeting
of Shareholders.
On 18.1.2022 the Company received the license from the European Central Bank, to operate as a Financial Holding Company.
In these "Alpha Services and Holdings Societe Anonyme" will be referred as "the Company", while "Alpha Bank" after the hive
down will be referred as "the Bank" and the “Alpha Services and Holdings Group” will be referred as “the Group”
The Company is managed by the Board of Directors, which represents the Company and is qualified to resolve on every action
concerning its management, the administration of its property and the promotion of its scope of business in general.
The tenure of the Board of Directors which was elected by the Ordinary General Meeting of Shareholders on 22.7.2022 is
quadrennial and may be extended until the termination of the deadline for the convocation of the next Ordinary General Meeting
and until the respective resolution has been adopted.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
425 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The composition of the Board of Directors as at 31.12.2023, consisted of:
CHAIR (Non-Executive Member)
Vasileios T. Rapanos
EXECUTIVE MEMBERS
Vassilios E. Psaltis, Chief Executive Officer (CEO)
Spyros N. Filaretos, Chief of Growth and
Innovation
NON-EXECUTIVE MEMBER
Efthimios O. Vidalis ***/****
INDEPENDENT NON-EXECUTIVE MEMBERS
Elli M. Andriopoulou */****
Aspasia F. Palimeri **/***
Panagiotis I. – K. Papazoglou */***
Dimitris C. Tsitsiragos **/***
Jean L. Cheval */**
Carolyn Adele G. Dittmeier */****
Elanor R. Hardwick **/****
Diony C. Lebot **/****
NON-EXECUTIVE MEMBER
Johannes Herman Frederik G. Umbgrove */**/***/****
(representative of the Hellenic Financial Stability Fund from
April 2018 until November 2023)
SECRETARY
Eirini E. Tzanakaki
The Board of Directors can set up the Executive Committee to which it delegates certain powers and responsibilities. The Executive
Committee acts as a collective corporate body of the Company. The powers and authorities of the Committee are determined by
way of a Chief Executive Officer Act, delegating powers and authorities to the Committee.
Indicatively, main responsibilities of the Committee include, but are not limited to, the preparation of the strategy, business plan
and annual Budget, including the strategy on Environmental, Social and Governance (ESG) issues, of the Company for
submission to and approval by the Board of Directors, as well as the annual and interim Financial Statements; the preparation of
the Internal Capital Adequacy Assessment Process (ICAAP) Report and the Internal Liquidity Adequacy Assessment Process
(ILAAP) Report; the review and approval, in the framework of its authorities, of the Company’s policies; ensuring the adequacy of
Resolution Planning governance, process and systems. Furthermore, the Committee is responsible for the implementation of the
overall risk strategy, including the Company’s risk appetite and its risk management framework-, the adequate and effective
internal governance and internal control framework, the adequate and effective framework for the implementation of the
Company’s strategy on ESG issues; the selection and suitability assessment process for Key Function Holders, the amounts,
types and distribution of both internal capital and regulatory capital to adequately cover the risks of the Company, the means for
achieving targets for the liquidity management of the Company and any arrangements aimed at ensuring the integrity of the
accounting and financial reporting systems.
-----------------------------------
* Member of the Audit Committee
** Member of the Risk Management Committee
*** Member of the Remuneration Committee
**** Member of the Corporate Governance, Sustainability and Nominations Committee
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
426 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The composition of the Executive Committee is as follows:
CHAIR
Vassilios E. Psaltis, Chief Executive Officer (CEO)
EXECUTIVE MEMBERS
Spyros N. Filaretos, Chief of Growth and Innovation
Spiros Α. Andronikakis, Chief Risk Officer (CRO)
Lazaros A. Papagaryfallou, Chief Financial Officer (CFO)
Ioannis Μ. Emiris, Chief of Wholesale Banking
Isidoros S. Passas, Chief of Retail Banking
Nicholas R. Chryssanthopoulos, Chief of Corporate Center (CCC) (resignation effective as of 16.2.2024)
Sergiu-Bogdan A. Oprescu, Chief of International Network
Anastasia C. Sakellariou, Chief Transformation Officer (CTO) (resignation effective as of 1.2.2024)
Stefanos Ν. Mytilinaios, Chief Operating Officer (COO)
Fragiski G. Melissa, Chief Human Resources Officer (CHRO)
Georgios V. Michalopoulos, Chief of Wealth Management
The company “Alpha Services and Holdings Societe Anonyme” is listed in the Athens Stock Exchange since 1925 and is constantly
included among the companies with the higher market capitalization. Additionally, the Company’s share is included in a series of
international indices, such as the MSCI Emerging Markets, MSCI Greece, FTSE All World and FTSE4Good Emerging Index.
Apart from the Greek listing, the share of the Company is traded over the counter in New York (ADRs).
Total ordinary shares in issue as at 31 December 2023 were 2,351,697,671 ordinary, registered, voting, dematerialized shares with
a face value of each equal to € 0.29.
During the year 2023, the average daily volume of the share per session was € 11,632.
The present annual financial statements have been approved by the board of directors on 6th March 2024.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
427 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1. ACCOUNTING POLICIES APPLIED
1.1 Basis of presentation
The financial statements for the year ended 31.12.2023 have been prepared in accordance with International Financial Reporting
Standards (IFRS), as adopted by the European Union, in accordance with Regulation 1606/2002 of the European Parliament and
the Council of the European Union on 19 July 2002.
The accounting policies applied by the Company in preparing the financial statements are the same as those stated in the
published financial statements for the year ended on 31.12.2022, after taking into account the amendments to standards which
were issued by the International Accounting Standards Board (IASB), adopted by the European Union and applied on 1.1.2023,
regarding which further analysis is provided in note 1.1.2.
It is also noted that the Company changed the presentation of the Income Statement in which the following lines were added:
•
Impairment losses on fixed assets and equity investments
•
Gains/(losses) from the disposal of fixed assets and equity investments and
•
Expenses relating to credit risk management
The above change constitutes, under IAS 8, an accounting policy change and leads to the restatement of the comparative period.
In note 40, the restatement in question is presented, while the previous way of presenting the above results is also visible.
The financial statements have been prepared on the historical cost basis with the exception of the investment securities measured
at fair value through other comprehensive income.
The financial statements are presented in Euro, rounded to the nearest thousand, unless otherwise indicated.
1.1.1 Going concern
The financial statements as at 31.12.2023 have been prepared based on the going concern principle. It is noted that since the
activity of the Company is directly related to the activity of the new credit institution that is its subsidiary, the assessment of the
going concern principle of the Company is directly related to the going concern of the Bank and the Group. For the application of
this principle, the Board of Directors considered current economic developments and made estimates for the formation, in the near
future, of the economic environment in which it operates. In this context, the Board of Directors assessed the following areas which
are considered important during its assessment:
Developments in the macroeconomic environment
The growth momentum during the first nine months of 2023 reflects the resilience of the Greek economy in the face of the
challenges it faced, such as the unstable international environment, inflationary pressures, the increased interest rates of the
European Central Bank, the slowdown of the European economy as well as the natural disasters in Greek territory during the third
quarter, and especially the disastrous floods in Thessaly. According to the latest available data from ELSTAT (December 2023), the
real GDP in the first nine months of 2023 increased by 2.2% on an annual basis, at a rate more than triple compared to the
Eurozone (0.6%) and one of the highest among the countries of the European Union (EU-27). Economic growth was driven
primarily by investment, which increased by 7.4% in the first nine months of the year compared to the same period last year,
contributing 1 percentage point (p.p.) to the annual GDP growth rate. Regarding the analysis of investments by category,
investments in housing and transportation equipment increased at a strong rate, by 40.2% and 21.8% respectively, while
investments in non-residential constructions by 5.5% and other investments by 4.1%.
Private consumption registered an annual increase of 1.3% in the first nine months of 2023, maintaining its momentum and
contributing to the change in GDP by 0.9 percentage points (p.p.). Also, the contribution of net exports was marginally positive (0.1
p.p), with the annual increase in exports (2.3%) exceeding the corresponding increase in imports (1.8%). Specifically, exports of
goods increased more strongly (2.9%) than the corresponding imports (0.5%), while exports of services increased milder (2.6%)
than imports of services (5.6%). Public consumption had a positive contribution of 0.2 percentage points (p.p.) which increased by
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
428 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1.1% on an annual basis in the first nine months of the year, while on the contrary, reserves had a marginally negative contribution
(-0.02 p.p. including statistical differences).
The Harmonized Index of Consumer Prices (HICP) increased by an average of 9.3% in 2022, primarily due to rising global energy
prices - given that Greece is a net energy importer - disruptions in supply chains and shortages in raw materials. However,
according to the latest available ELSTAT data, HICP inflation slowed significantly in 2023 to 4.2%. It is noted that the main
categories of goods, the prices of which continue to increase and keep inflation in positive territory, are those of food and services,
while energy prices decreased in 2023 on average, by 13%.
GDP growth is expected to strengthen in 2024, boosted by the gradual normalization of inflationary pressures. In addition, the
implementation of investments within the framework of the Recovery and Resilience Fund (Euro 3.6 billion) and the Public
Investment Program (Euro 8.6 billion) and the expected increase in Foreign Direct Investments (FDI) are estimated to contribute to
strengthening economic activity in 2024. The International Monetary Fund (World Economic Outlook, October 2023), the European
Commission (European Economic Forecast, Autumn, November 2023) and the Organization for Economic Co-operation and
Development (OECD Economic Outlook, November 2023) predict an increase of GDP by 2.5%, 2.4% and 2.4% for 2023, while the
Ministry of Finance (Recommended Budget Report 2024, November 2023) by 2.4% respectively. As for 2024, the same
organizations predict positive economic growth rates between 2% and 2.9%.
The main factors of uncertainty regarding Greece's macroeconomic prospects are as follows:
•
Geopolitical developments and inflationary pressures: The continuation and outcome of the war in Ukraine can undoubtedly
affect the European economies, since the conflict in the territories of the European continent, as well as the energy
dependence on Russia led to a sharp increase in energy prices in 2022. It is noted, however, that concerns about Europe's
energy sufficiency have eased. Both the high filling rate of natural gas storage tanks in Europe and the initiatives taken at
European level to reduce natural gas consumption have contributed to this. The recent conflict in the Middle East further
increases uncertainty, while a possible escalation of the conflict involving countries with a significant role in the oil market (e.g.
Iran) could trigger a new energy crisis and consequently inflationary pressures, burdening both the Greek, as well as the
European economy. Adding to the adverse geopolitical developments is the recent tension in the Red Sea, as approximately
10% of global trade passes through this region. This could lead to a renewed increase in oil prices and disruption to the supply
chain.
•
The slowdown or even recession of the European economy could adversely affect domestic economic activity, as 54% of
Greek exports are directed to the European Union, while 60%-70% of tourist arrivals come from it. It is noted that according to
the recent forecasts of the European Commission (European Economic Forecast, Autumn, November 2023) the GDP in the
European Union (EU-27) is expected to increase by 0.6% in 2023 and by 1.3% in 2024, against previous forecasts for an
increase of 0.8% and 1.4%, respectively (European Economic Forecast, Summer, September 2023).
•
In addition, risks for the Greek economy arise due to the extreme weather phenomena that hit various regions of the country in
the summer of 2023, and especially the catastrophic floods in the region of Thessaly. In the short term, upward pressures on
food prices are likely to intensify, while, in the medium term, the trade balance may deteriorate both due to a reduction in
exports of goods and due to replenishment, through imports of goods, of the lost agricultural and livestock production that was
intended for domestic consumption. In addition, the reduction of capital used in the production process (buildings, machinery,
land) is, in the long run, the most important challenge, as it adversely affects the productive capacity of the economy and,
consequently, the potential output. The negative effects are expected to be mitigated, to some extent, by the measures taken
at the domestic and European level. Specifically, a supplementary budget of Euro 600 million was submitted to cover the first
compensations. In addition, according to statements by the president of the European Commission, Greece can mobilize up to
Euro 2.25 billion of unused European funds to carry out infrastructure projects, while a request to draw up to Euro 400 million
in 2024 from the Solidarity Fund will be evaluated.
•
A sharp increase in interest rates in the last year and consequently the cost of borrowing for households and businesses,
which might have delayed the implementation of investment plans. In addition, the increased cost of borrowing, combined with
the effects of the energy crisis, following the gradual abolition of fiscal support measures for businesses and households, could
make it difficult to further reduce the NPL ratio, as it states the Monetary Policy Report of the Bank of Greece (December
2023).
•
Finally, there are risks arising from the speed of absorption of the funds of the Recovery and Resilience fund and the
implementation of the program, as well as possible delays in the implementation of structural reforms.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
429 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
In conclusion, despite the volatile economic environment, as defined among others by geopolitical uncertainty, the maintenance of
inflationary pressures and the sharp increase in interest rates by the main central banks, the Greek economy is expected to remain
resilient, achieving higher rates in 2023-24 of GDP growth above European averages, supported by private consumption and rising
investments.
Liquidity
Regarding Group's liquidity levels, it is noted that the Bank's unrestricted ability to draw liquidity from the mechanisms of the
Eurosystem and from the money (with or without collateral) and capital markets continues. During 2023, the increases in the
European Central Bank's intervention interest rates continued in order to ensure the timely return of inflation to the medium-term
target of 2%, while on 31.12.2023 the interbank deposit facility rate of commercial banks at the Central Bank of the Eurozone
(deposit facility rate) amounted to 4%. In February, March and June 2023, in the context of optimizing the Group's liquidity
management, and having sufficient reserves, the Bank decided to prepay €8 billion in total of the European Central Bank's TLTRO-
III program. The total funding from the European Central Bank on 31.12.2023 amounts to € 5 billion.
In 2023 the credit rating agencies Fitch, Standard & Poor's and DBRS upgraded the Greek government's bonds to investment
grade, a development that is of decisive importance for how international markets view the country and its assets. The Bank,
continuing to implement the strategy of achieving the MREL objectives in a sustainable manner, while improving its financial profile
and diversifying its sources of financing, issued in June 2023 and in February 2024 senior preferred bonds in the amount of €500
million and €400 million respectively. Liquidity of €400 million was also raised from the issue of AT1 in February 2023, as mentioned
below in the capital adequacy section. In addition, within 2023 total deposits, including those of the subsidiaries classified in
consolidated financial statements in assets held for sale, showed an increase of €1.7 billion.
As a result of the above, the liquidity ratios (liquidity coverage ratio and net stable liquidity ratio) significantly exceed the supervisory
limits that have been set. In addition, taking into account the conditions shaping the current economic environment, stress tests are
carried out regularly (at least monthly) for liquidity purposes, in order to assess potential outflows (contractual or contingent), which
aim to confirm whether the liquidity reserve is sufficient to cover the Bank's needs. These exercises are carried out in accordance
with the approved policy of "Liquidity Risk Management" (Liquidity Risk Policy) of the Group. It is noted that during 2023 the said
exercises demonstrated that the Bank and its subsidiaries in Cyprus and Romania remain viable in all scenarios.
Capital Adequacy
On 31.12.2023 the Group's Common Equity Tier I was at 14.4% while the Total Capital Adequacy Ratio at 18.8%, significantly
increased and much higher than the capital requirements, mainly due to the strong profitability of the year and the successful
completion of the planned transactions in accordance with the Business Plan. With the aim of strengthening its funds, Alpha
Services and Holdings issued, on 8.2.2023, a perpetual Additional Tier I bond of €400 million. Taking into account the results of the
internal capital adequacy assessment exercise (ICAAP), the fact that Alpha Services and Holdings has successfully completed the
EU-wide Stress Test 2023, as well as the actions aimed at creating internal capital through profitability the Total Capital Adequacy
Ratio and the MREL ratio are estimated to remain at levels higher than the supervisory limits for the next 12 months.
Updated Strategic Plan up to 2025
According to the updated Strategic Plan for the period 2023-2025, the Group's Strategy is based on the following 6 pillars that will
lead to an increase in the profitability of the Group as a whole:
•
Enhancing digital services and focusing on high value activities in retail banking.
•
Reshaping the service model to increase market share in the Wealth Management sector
•
Maintaining of the leadership position in Wholesale Banking
•
Improving the profitability performance of the Group's international activities
•
Maintaining balance sheet resilience
•
Full adoption and utilization of ESG criteria as a catalyst for value creation
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
430 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
In the years 2023-2025, the Bank will focus on the following three financial priorities:
d. Increase in profitability:
• Significant improvement in profitability in all Business Units, and reallocation of funds due to further reduction of Non-
Performing Exposures
• Revenue boost supported by a strong performance in Net Interest Income
• Disciplined cost management, thereby limiting the impact of inflationary pressures and reducing operating expenses
through specific actions
• Improvement of the Group's Cost-to-Income Ratio, as a result of increasing revenues and reducing costs.
e. Balance sheet resilience:
• Maintaining the quality structure of the Balance Sheet through investments in high-grade loans and securities and the
consequent strengthening of liquid assets.
• Reduction of non-performing exposures, mainly through organic deleveraging, further reduction of the NPE ratio and
improvement of the NPE coverage ratio as well as further de-escalation of the Credit Risk Cost
• Broad, well-diversified and resilient deposit base growing over the strategic plan period
f. Creation and distribution of capital:
• Capital creation due to significant returns within 3 years
• Achieve a higher Common Equity Tier 1 Capital Ratio with full implementation of Basel III (FL CET1)
• Resumption of dividend payment from 2023 earnings, subject to regulatory approval
Also, at the end of 2023, a landmark strategic partnership (project Unicorn) with a global systemic financial institution (UniCredit)
was announced, introducing cooperation in geographical areas and products.
The agreement included 3 main pillars:
4. UniUniCredit's strategic investment in the Bank
5. Merger of subsidiaries of the Bank and UniCredit Romania with the Bank retaining a 9.9% stake in the new company
6. Commercial Agreement in Bancassurance and Asset Management
This development will enable the Group to realize its strategic priorities and accelerate the execution of its business plan through:
•
Establishing a strong partnership with an internationally recognized financial institution
•
Acquisition of a stake in the third, following the merger, largest bank in Romania
•
Potential to enhance domestic profitability through synergies from strategic collaboration and know-how sharing
•
Focusing attention on domestic and on other foreign activities of the Group (Cyprus, United Kingdom)
Based on the above and taking into account:
•
the Group’s capital adequacy ratio that is significantly higher than the required minimum levels, the MREL ratio that is
higher than the intermediate target of 2024 by around 3 percentage points, as well as the specific actions the Bank has
planned to further strengthen the ratios,
•
the satisfactory liquidity of the Group,
•
the actions included in the update strategic plan up to 2025,
•
the fact that any impact on the Group’s financial result from inflation and increase in base rates is expected to be positive
as it is estimated that the higher performance of operating income, as a result of the balance sheet structure, will exceed
the expected increases in operating expenses,
•
the expected positive growth rates of the Greek Economy, despite the uncertainty caused by geopolitical developments,
the maintenance of inflationary pressures and the environment of high interest rates, and additionally the implementation of
the National Recovery and Resiliency Plan, within the framework of the "Next Generation EU" program of EU, through
which Greece is expected to receive a total of €36 billion by 2026
•
that despite the fact that the duration of the war between Russia and Ukraine and recent developments in Middle East may
adversely affect the macroeconomic environment, the Group has significant buffers of capital adequacy and liquidity,
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
431 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
•
that the Group confirms its stability and resistance to external negative market factors based on:
• the Bank's broad and well-diversified deposit base with private deposits accounting for 66% of its total deposits
• the absence of concentrations in deposits as well as the existence of low average balances,
• the supervisory liquidity ratios that stand on a consistent basis above the supervisory requirements. In particular, the
liquidity coverage ratio (LCR) and the net stable funding ratio (NSFR) significantly increased and reached 191.0% and
130.1% respectively, mainly due to the increase of deposits, the repayment of TLTRO and the senior preferred
issuance,
• the maintenance of an investment portfolio, 86% of which consists of high-quality liquid assets and which, after the
relevant interest rate risk hedges, presents a low repricing cycle - low modified duration,
• the balanced interest rate risk profile on its banking book, responding successfully to interest rate shock scenarios (i.e.
Economic Value of Equity/TIER I capital), with a balance sheet composition of predominantly floating rate loans,
• as mentioned above, its strong capital adequacy and satisfactory liquidity,
the Board of Directors estimates that, at least for the next 12 months from the date of approval of the financial statements, the conditions
for the application of the going concern principle for the preparation of its financial statements are met.
1.1.2 Adoption of new standards and of amendments to standards
The following are the new standards and the amendments to standards applied from 1.1.2023:
International Financial Reporting Standard 17 “Insurance Contracts” and Amendment to International Financial Reporting
Standard 17 “Insurance Contracts” (Regulation 2021/2036/19.11.2021).
On 18.5.2017 the International Accounting Standards Board issued IFRS 17 which replaces IFRS 4 “Insurance Contracts”. In
contrast to IFRS 4, the new standard introduces a consistent methodology for the measurement of insurance contracts. The key
principles in IFRS 17 are the following:
An entity:
•
identifies as insurance contracts those contracts under which the entity accepts significant insurance risk from another party
(the policyholder) by agreeing to compensate the policyholder if a specified uncertain future event adversely affects the
policyholder;
•
separates specified embedded derivatives, distinct investment components and distinct performance obligations from the
insurance contracts;
•
divides the contracts into groups that it will recognise and measure;
•
recognises and measures groups of insurance contracts at:
•
a risk-adjusted present value of the future cash flows (the fulfilment cash flows) that incorporates all of the available
information about the fulfilment cash flows in a way that is consistent with observable market information; and
•
an amount representing the unearned profit in the group of contracts (the contractual service margin);
•
recognises the profit from a group of insurance contracts over the period the entity provides insurance cover, and as the entity
is released from risk. If a group of contracts is or becomes loss-making, an entity recognises the loss immediately;
•
presents separately insurance revenue, insurance service expenses and insurance finance income or expenses; and
•
discloses information to enable users of financial statements to assess the effect that contracts within the scope of IFRS 17
have on the financial position, financial performance and cash flows of an entity.
On 25.6.2020 the International Accounting Standards Board issued an amendment to IFRS 17 which aimed to ease implementation
of the standard and make it easier for entities to explain their financial performance. Additionally, with the amendment the effective
date of the standard was postponed to 1.1.2023.
Finally, it is noted that under the Regulation of the European Union that adopted above standard, an entity may choose not to apply
paragraph 22 of the standard, in accordance with which an entity shall not include contracts issued more than one year apart in the
same group, to:
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
432 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
(a) groups of insurance contracts with direct participation features and groups of investment contracts with discretionary
participation features and with cash flows that affect or are affected by cash flows to policyholders of other contracts; (b) groups of
insurance contracts that are managed across generations of contracts and that meet the conditions laid down in Article 77b of
Directive 2009/138/EC and have been approved by supervisory authorities for the application of the matching adjustment.
IFRS 17 does not apply to the financial statements of the Company.
Amendment to International Financial reporting Standard 17: “Insurance Contracts”: Initial Application of IFRS 17 and IFRS 9 –
Comparative information (Regulation 2022/1491/8.9.2022).
On 9.12.2021 the International Accounting Standards Board issued an amendment to IFRS 17 according to which entities are
permitted on initial application of IFRS 17 to classify financial assets in the comparative period in a way that aligns with how the
entity would classify them on IFRS 9 transition. The amendment specifies how this option is applied depending on whether the
entity applies IFRS 9 for the first time at the same time as IFRS 17 or whether it has already applied it in a previous period.
The above amendment does not apply to the financial statements of the Company.
Amendment to the International Accounting Standard 1 “Presentation of Financial Statements”: Disclosure of accounting
policies (Regulation 2022/357/2.3.2022).
On 12.2.2021 the International Accounting Standards Board issued an amendment to IAS 1 with which it clarified that:
•
An entity shall disclose material accounting policy information. Accounting policy information is material if, when considered
together with other information included in an entity’s financial statements, it can reasonably be expected to influence decisions
that the primary users of financial statements make.
•
Accounting policy information that relates to immaterial transactions is immaterial and need not be disclosed. Accounting policy
information may nevertheless be material because of the nature of the related transactions even if the amounts are immaterial.
However, not all accounting policy information relating to material transactions and other events is itself material.
•
Accounting policy information is material if users of an entity’s financial statements would need it to understand other material
information in the financial statements.
•
Accounting policy information that focuses on how an entity has applied an accounting policy is more useful to users of
financial statements than standardized information or information that only summarizes the requirements of IFRSs.
•
If an entity discloses immaterial accounting policy information, such information shall not obscure material accounting policy
information
The above amendment has been considered in the financial statements of the Company.
Amendment to the International Accounting Standard 8 “Accounting Policies, Changes in Accounting Estimates and Errors”:
Definition of accounting estimates (Regulation 2022/357/2.3.2022).
On 12.2.2021 the International Accounting Standards Board issued an amendment to IAS 8 with which:
•
Defined accounting estimates as monetary amounts in financial statements that are subject to measurement uncertainty.
•
Clarified that an accounting policy may require items in financial statements to be measured in a way that involves
measurement uncertainty. In such a case, an entity develops an accounting estimate. Developing accounting estimates
involves the use of judgements and assumptions.
•
An entity uses measurement techniques and inputs to develop an accounting estimate
•
An entity may need to change an accounting estimate. By its nature, a change in an accounting estimate does not relate to
prior periods and is not the correction of an error. A change in an input or a change in a measurement technique are changes
in accounting estimates unless they result from the correction of prior period errors.
The adoption of the above amendment had no impact on the financial statements of the Company.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
433 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Amendment to International Accounting Standard 12 “Income Taxes”: Deferred tax related to assets and liabilities arising from a
single transaction (Regulation 2022/1392/11.8.2022).
On 7.5.2021 the International Accounting Standards Board issued an amendment to IAS 12 with which it narrowed the scope of the
recognition exception according to which, in specific circumstances, entities are exempt from recognising deferred tax when they
recognise assets or liabilities for the first time. The amendment clarifies that the exception no longer applies to transactions that, on
initial recognition, give rise to equal taxable and deductible temporary differences.
The adoption of the above amendment had no impact on the financial statements of the Company.
Amendment to the International Accounting Standard 12 “Income Taxes”: International Tax Reform – Pillar Two Model Rules
(Regulation 2023/2468/8.11.2023).
On 23.5.2023, the International Accounting Standards Board issued an amendment to the IAS. 12 in order to provide guidance
regarding the treatment of the provisions imposed through the Pillar Two Model Rules of the International Tax Reform. In particular,
according to the amendment, an entity:
•
Shall neither recognize nor disclose information regarding deferred tax assets and liabilities arising from Pillar Two income tax.
•
It shall disclose that it has applied above exception.
•
It shall disclose separately its current tax expense (income) related to Pillar Two income taxes.
•
In periods in which Pillar Two legislation has been enacted (or substantially enacted) but not yet in effect, it shall disclose
known or reasonably estimable information that help users of financial statements understand its exposure to Pillar Two
income taxes.
The adoption of the above amendment had no impact on the financial statements of the Company. The estimated impact in 2024
from Pillar Two income taxes is presented in note 32.
In addition, the European Union has adopted the following amendments to standards which are effective for annual periods
beginning after 1.1.2023 and have not been early adopted by the Company.
Amendment to International Financial Reporting Standard 16 “Leases”: Lease liability in a sale and leaseback (Regulation
2023/2579/20.11.2023).
Effective for annual periods beginning on or after 1.1.2024.
On 22 September 2022, the International Accounting Standards Board amended IFRS 16 in order to clarify that, in a sale and
leaseback transaction, the seller-lessee shall determine “lease payments” or “revised lease payments” in a way that he would not
recognize any amount of the gain or loss that relates to the right of use retained by the seller-lessee. In addition, in case of partial
or full termination of a lease, the seller-lessee is not prevented from recognizing in profit or loss any gain or loss resulting from this
termination.
The Company is examining the impact from the adoption of the above amendment on its financial statements.
Amendment to the International Accounting Standard 1 “Presentation of Financial Statements”: Classification of liabilities as
current or non-current (Regulation 2023/2822/19.12.2023).
Effective for annual periods beginning on or after 1.1.2024.
On 23.1.2020, the International Accounting Standards Board issued amendments to IAS 1 relating to the classification of liabilities
as current or non-current. More specifically:
•
The amendments specify that the conditions which exist at the end of the reporting period are those which will be used to
determine if the liability must be classified as current or non-current.
•
Management expectations about events after the balance sheet date must not be taken into account.
•
The amendments clarify the situations that are considered settlement of a liability.
On 15.7.2020 the International Accounting Standards Board extended effective date by one year taking into account the impact of
Covid-19.
The above amendment will have no impact on the financial statements of the Company since in it’s balance sheet liabilities are not
classified as current and non-current.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
434 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Amendment to the International Accounting Standard 1 “Presentation of Financial Statements”: Non-current liabilities with
covenants (Regulation 2023/2822/19.12.2023).
Effective for annual periods beginning on or after 1.1.2024.
On 31.10.2022, the International Accounting Standards Board (IASB) issued an amendment to IAS 1 with which it provided
clarifications regarding the classification as current or non-current of a liability that an entity has the right to defer for at least 12
months and which is subject to compliance with covenants. More specifically, it was clarified that only covenants with which an
entity is required to comply on or before the reporting date affect the classification of a liability as current or non-current. In addition,
the amendment extended the effective date of the amendment to IAS 1 “Classification of liabilities as current or non-current” issued
in 2020 by one year.
The above amendment will have no impact on the financial statements of the Company since in it’s balance sheet liabilities are not
classified as current and non-current.
In addition, 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 which have not been early applied by the Company.
Amendment to International Financial Reporting Standard 10 “Consolidated Financial Statements” and to International
Accounting Standard 28 “Investments in Associates and Joint Ventures”: Sale or contribution of assets between an investor and
its associate or joint venture.
Effective date: To be determined.
On 11.9.2014 the International Accounting Standards Board issued an amendment to IFRS 10 and IAS 28 in order to clarify the
accounting treatment of a transaction of sale or contribution of assets between an investor and its associate or joint venture. In
particular, IFRS 10 was amended in order to be clarified that in case that as a result of a transaction with an associate or joint
venture, a parent (investor) loses control of a subsidiary, which does not constitute a business, as defined in IFRS 3, it shall
recognise to profit or loss only the part of the gain or loss which is related to the unrelated investor’s interests in that associate or
joint venture. The remaining part of the gain from the transaction shall be eliminated against the carrying amount of the investment
in that associate or joint venture. In addition, in case the investor retains an investment in the former subsidiary and the former
subsidiary is now an associate or joint venture, it recognises the part of the gain or loss resulting from the remeasurement at fair
value of the investment retained in that former subsidiary in its profit or loss only to the extent of the unrelated investor’s interests in
the new associate or joint venture. The remaining part of the gain is eliminated against the carrying amount of the investment
retained in the former subsidiary.
In IAS 28, respectively, it was clarified that the partial recognition of the gains or losses shall be applied only when the involved
assets do not constitute a business. Otherwise, the total of the gain or loss shall be recognised.
On 17.12.2015, the International Accounting Standards Board deferred the effective date for the application of the amendment that
had been initially determined. The new effective date will be determined by the International Accounting Standards Board at a
future date after taking into account the results of its project relating to the equity method.
The Company is examining the impact from the adoption of the above amendments on its financial statements.
International Financial Reporting Standard 14 “Regulatory deferral accounts”.
Effective for annual periods beginning on or after 1.1.2016.
On 30.1.2014 the International Accounting Standards Board issued IFRS 14. The new standard, which is limited-scope, addresses
the accounting treatment and the disclosures required for regulatory deferral accounts that are maintained in accordance with local
legislation when an entity provides rate-regulated goods or services. The scope of this standard is limited to first-time adopters that
recognized regulatory deferral accounts in their financial statements in accordance with their previous GAAP. IFRS 14 permits
these entities to capitalize expenditure that non-rate-regulated entities would recognize as expense.
The above standard does not apply to the financial statements of the Company.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
435 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
It is noted that European Union has decided not to launch the endorsement of this standard and to wait for the final standard.
Amendment to the International Accounting Standard 7 “Statement of Cash Flows” and Amendment to the International
Financial Reporting Standards 7 “Financial Instruments: Disclosures”: Supplier Finance Arrangements.
Effective for annual periods beginning on or after 1.1.2024
On 25.5.2023, the International Accounting Standards Board amended IAS 7 and IFRS 7 for the purpose of providing disclosures
regarding supplier finance arrangements. These are agreements that companies enter into with third party finance providers, who
undertake to repay amounts the entities owe their suppliers. Then the entity will have to repay the third-party finance provider
based on the terms of the agreement between them. The amendment of the IAS 7 required the provision of information regarding
the terms of the agreements in question, the carrying amount of the relevant liability on the balance sheet, the non-cash changes in
the liability balances, the amounts with which third party finance providers have already repaid the suppliers and the range of
payment due dates Also, IFRS 7 was amended to include access to such agreements with third finance providers in the liquidity
risk disclosures.
The Company is examining the impact from the adoption of the above amendments on its financial statements.
Amendment to the International Accounting Standard 21 “The Effects of Changes in Foreign Exchange Rates”: Lack of
exchangeability.
Effective for annual periods beginning on or after 1.1.2025
On 15.8.2023, the International Accounting Standards Board issued an amendment to IAS 21 regarding currencies that lack
exchangeability. The amendment clarifies how an entity should assess whether a currency is exchangeable and how it should
determine a spot exchange rate when exchangeability is lacking. With the amendment disclosures are also added that enable
users of financial statements to understand the impact of a currency that is not exchangeable.
The Company is examining the impact from the adoption of the above amendment on its financial statements.
1.2 Material accounting policies
1.2.1 Transactions in foreign currency and translation of foreign operations
a. Transactions in foreign currency
The financial statements are presented in Euro, which is the functional currency and the currency of the Company’s country of
incorporation.
Items included in the financial statements for foreign branches are measured at the functional currency which is the currency of the
country of incorporation in which the branch operates or the currency used in the majority of the transactions held.
Transactions in foreign currencies are translated into the functional currency at the closing exchange rate at the date of the
transaction.
Monetary assets and liabilities denominated in foreign currencies are translated into the functional currency at the closing exchange
rate at the balance sheet date. Foreign exchange differences arising from the translation are recognized in the income statement.
Non-monetary assets and liabilities are translated using the rate of exchange at the transaction date, except for non-monetary
items denominated in foreign currencies that are measured at fair value which are translated at the exchange rate of the date that
the fair value is determined.
The exchange differences relating to these items are part of the change in fair value and they are recognized in the income
statement or recorded directly in equity depending on the classification of the non-monetary item.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
436 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
b. Translation of foreign operations
The results and financial position of all foreign branches that have a functional currency that is different from the presentation
currency of the Company’s financial statements are translated as follows:
•
Assets and liabilities are translated to Euro at the closing rate applicable on the balance sheet date. The comparative figures
presented are translated to Euro at the closing rates at the respective date of the comparative balance sheet.
•
Income and expense items are translated to Euro at average exchange rates applicable for each period presented.
The resulting exchange differences from the above translation and those arising from other monetary items designated as a part of
the net investment in a foreign entity are recorded in equity. These translation differences are reclassified to the income statement
when a foreign branch is sold.
1.2.2 Cash and cash equivalents
For the purposes of the cash flow statement, cash and cash equivalents consists of:
•
Cash on hand
•
Short-term balances due from banks
Short-term balances due from banks are those that upon initial recognition mature within three months.
Short-term balances due from banks are measured at amortised cost.
1.2.3 Classification and measurement of financial instruments
Initial recognition
The Company recognises financial assets or financial liabilities in its statement of financial position when it becomes a party to the
terms of the contract.
At initial recognition the Company measures financial assets and liabilities at fair values. Financial instruments not measured at fair
value through profit or loss are initially recognised at fair value plus or minus transaction costs and income or fees that are directly
attributable to the acquisition or issue of the financial instrument.
Regular way purchases and sales of financial instruments are recognized at the settlement date with the exception of equity shares
and derivatives that are recognized at the trade date. For bonds that are measured at fair value, the change in fair value during the
period between the trade date and the settlement date is recognized in profit or loss or in other comprehensive income based on
the bond’s classification category.
Subsequent measurement of financial assets
The Company classifies its financial assets as:
•
Financial assets measured at amortised cost,
•
Financial assets measured at fair value through other comprehensive income, with gains or losses reclassified in profit or loss
on derecognition,
•
Equity instruments measured at fair value through other comprehensive income, with no reclassification in gains or losses to
profit or loss on derecognition,
•
Financial assets measured at fair value through profit or loss.
For each of the above categories the following apply:
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
437 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
a. Financial assets measured at amortised cost
In this category are classified the financial assets that satisfy both of the following criteria:
•
are held within a business model whose objective is to hold financial assets in order to collect contractual cash flows,
•
the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and
interest (SPPI) on the principal amount outstanding.
The above category is measured at amortised cost using the effective interest method and is periodically assessed for expected
credit losses, as it is further described in notes 1.2.9 and 1.2.10.
b. Financial assets measured at fair value through other comprehensive income, with gains or losses reclassified in
profit or loss on derecognition
In this category are classified the financial assets that satisfy both of the following criteria:
•
are held within a business model whose objective is both to collect contractual cash flows and selling financial assets,
•
the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and
interest (SPPI) on the principal amount outstanding.
The above category is periodically assessed for expected credit losses, as it is further described in notes 1.2.9 and 1.2.10.
c. Equity instruments measured at fair value through other comprehensive income, with no reclassification in gains or
losses to profit or loss on derecognition
In this category are classified equity instruments that are neither held for trading nor contingent consideration arising from a
business combination and for which it is opted, at initial recognition, to be measured at fair value through other comprehensive
income. This decision is irrevocable. With the exception of dividends, which are directly recognized in profit or loss, all other gains
and losses arising from those instruments are directly recognized in other comprehensive income and are not reclassified to profit
or loss. For those equity instruments there is no impairment assessment.
d. Financial assets measured at fair value through profit or loss
Financial assets included in this category are:
•
those acquired principally for the purpose of selling in the near term to obtain short term profit (held for trading).
The Company has included in this category bonds, treasury bills and a limited number of shares.
•
those that do not meet the criteria to be classified into one of the above categories a-c.
•
those the Company designated, at initial recognition, as at fair value through profit or loss.
This classification option, which is irrevocable, is used when the designation eliminates an accounting mismatch which would
otherwise arise from measuring financial assets and liabilities on a different basis (i.e. amortised cost) in relation to another
financial asset or liability (i.e. derivatives which are measured at fair value through profit or loss).
As at the reporting date, the Company had not designated, at initial recognition, any financial assets as at fair value through profit
or loss.
Business Model assessment
The business model reflects how the Company manages its financial assets in order to generate cash flows. That is, the
Company’s business model determines whether cash flows will result from collecting contractual cash flows, selling financial assets
or both. The Company’s business model is determined at a level that reflects how groups of financial assets are managed together
to achieve a particular business objective. Accordingly, business model does not depend on management’s intentions for an
individual instrument but it is determined on a higher level of aggregation.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
438 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The business models of the Company are determined by the Executive Committee (ExCo). In this context for bonds and in general
for fixed income investments, the Company has identified the following business models:
•
Business model whose objective is to hold financial instruments in order to collect their contractual cash flows (hold to collect)
•
Business model that aims both at collecting contractual cash flows and selling (hold to collect and sell)
•
Trading portfolio.
•
Business model whose objective is achieved by the sale/distribution of the financial assets.
The determination of the above business models has been based on:
•
The way the performance of the business model and the financial assets held within that business model are evaluated and
reported to the Company key management personnel.
•
The risks that affect the performance of the business model (and the financial assets held within that business model) and,
specifically, the way those risks are managed.
•
The way the managers are evaluated (e.g., whether the evaluation is based on the fair value of the assets managed or the
contractual cash flows collected).
•
Past and expected frequency and value of sales from the portfolio.
The Company, at each reporting date, reassesses its business models in order to confirm that there has been no change compared
to the prior period or application of a new business model. In the context of the reassessment of the hold to collect business model
past sales as well as expected future sales are taken into account. In this assessment, the following cases of sales are considered
consistent with a hold to collect business model:
a. Sales made close to the maturity of the financial assets so that the proceeds from the sales approximate the collection of the
remaining contractual cash flows. In these cases, for bonds portfolio, the Company defines as ‘close’, the minimum between
10% of the original life of the instrument and a time period equal to 6 months up to maturity while no limitation on the size exists
on the sales that take place close to maturity where expected cash flows amount to at least 97% of principal plus accrued
interest.
b. Sales (excluding a) which are infrequent (even if significant in value) or insignificant in value both individually and in aggregate
(even if frequent). For bonds portfolio, sales deemed insignificant are those that sum up to 5% of the current total portfolio size
or the portfolio of the last quarterly reporting period, whichever is higher. In addition, up to 5 sales per month within the above
size limit are considered infrequent.
In addition the following sales are considered consistent with a hold to collect business model:
•
Sales of bonds that do not longer meet the requirements stated in the investment policy due to a significant increase in issuer’s
credit risk.
•
Infrequent sales under liquidity stress conditions.
Solely Payments of Principal and Interest (SPPI) assessment of the contractual cash flows
For the purposes of applying the SPPI assessment:
•
Principal is the fair value of the asset at initial recognition, which may change over the life of the financial asset, (for example if
there are repayments of principal).
•
Interest is the consideration for the time value of money, for the credit risk associated with the principal amount outstanding
during a particular period of time and for other basic lending risks (i.e. liquidity risk) and costs, as well as a profit margin.
Contractual terms that introduce exposure to risks and volatility in the contractual cash flows that are not related to a basic lending
arrangement, such as exposure to changes in equity prices or commodity prices, do not give rise to contractual cash flows that are
solely payments of principal and interest on the principal amount outstanding.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
439 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
In this context, in assessing whether contractual cash flows are SPPI, the Company assesses whether the instrument contain
contractual terms that change the timing or amount of contractual cash flows. More specifically, the following are taken into
account:
•
Leveraged payments
•
Payments linked with the variability in exchange rates
•
Conversion to equity terms
•
Interest rates indexed to non-interest variables
•
Prepayment or extension options
•
Terms that limit the Company’s claim to the cash flows from specified assets or based on which the Company has no
contractual right to unpaid amounts
•
Interest-free deferred payments
•
Terms based on which the performance of the instruments is affected by equity or commodity prices
Reclassification of financial assets
Reclassifications of financial assets between measurement categories occur when, and only when, the Company changes its
business model for managing the assets and IFRS 9 requirements are met. In this case the reclassification is applied prospectively
from the first reporting period following the change in the business model. Changes in the business model of the Company that lead
to the reclassification of financial assets are expected to be rare. They arise from decisions of the Executive Committee (ExCo) as
a result of external or internal changes which must be significant to the entity’s operations and demonstrable to external parties.
If the Company reclassifies a financial asset out of the amortised cost measurement category and into the fair value through profit
or loss measurement category, its fair value is measured at the reclassification date. Any gain or loss arising from a difference
between the previous amortised cost of the financial asset and fair value is recognized in profit or loss. The same happens if the
Company reclassifies a financial asset out of the amortised cost measurement category and into the fair value through other
comprehensive income measurement category, however in this case the difference between the previous amortised cost of the
financial asset and fair value is recognized in other comprehensive income. The effective interest rate and the measurement of
expected credit losses are not adjusted as a result of the reclassification. However, the loss allowance would be derecognized (and
thus would no longer be recognized as an adjustment to the gross carrying amount) but instead would be recognized as an
accumulated impairment amount in other comprehensive income.
If the Company reclassifies a financial asset out of the fair value through profit or loss measurement category and into the
amortised cost measurement category, its fair value at the reclassification date becomes its new gross carrying amount. At this
date, the effective interest rate of the asset is calculated while the date of the reclassification is treated as the date of initial
recognition for impairment calculation purposes.
If the Company reclassifies a financial asset out of the fair value through profit or loss measurement category and into the fair value
through other comprehensive income measurement category, the financial asset continues to be measured at fair value. As in the
above case, at this date, the effective interest rate of the asset is calculated while the date of the reclassification is treated as the
date of initial recognition for impairment calculation purposes.
Ιf a financial asset is reclassified out of the fair value through other comprehensive income measurement category and into the
amortised cost measurement category, the asset is reclassified at its fair value at the measurement date. However, the cumulative
gain or loss previously recognized in other comprehensive income is reversed and adjusted against the fair value of the financial
asset at the reclassification date. As a result, the financial asset is measured at the reclassification date as if it had always been
measured at amortised cost. This reversal affects other comprehensive income but does not affect profit or loss and therefore is not
a reclassification adjustment under IAS 1. The effective interest rate and the calculation of expected credit losses are not affected.
However, the loss allowance is recognized as an adjustment to the gross carrying amount of the financial asset from the
reclassification date.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
440 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
If the Company reclassifies a financial asset out of the fair value through other comprehensive income measurement category and
into the fair value through profit or loss measurement category, the financial asset continues to be measured at fair value. The
cumulative gain or loss previously recognised in other comprehensive income is reclassified from equity to profit or loss as a
reclassification adjustment (in accordance with IAS 1) at the reclassification date.
Derecognition of financial assets
The Company derecognizes financial assets when:
•
the contractual rights to the assets cash flows expire,
•
the contractual rights to receive the cash flows of the financial assets are transferred and at the same time all the risks and
rewards of ownership are substantially transferred,
•
loans or investments in securities are no longer recoverable and consequently are written off,
•
the contractual cash flows of the assets are significantly modified.
Subsequent measurement of financial liabilities
The Company classifies financial liabilities in the following categories for measurement purposes:
a. Financial liabilities measured at fair value through profit or loss
•
This category includes financial liabilities held for trading, that is:
•
financial liabilities acquired or incurred principally with the intention of selling or repurchasing in the near term for short term
profit, or
•
derivatives not used for hedging purposes. Liabilities arising from either derivatives held for trading or derivatives used for
hedging purposes are presented as “derivative financial liabilities” and are measured according to the principles set out in
note 1.2.4.
•
this category also includes financial liabilities which are designated by the Company as at fair value through profit or loss upon
initial recognition, when:
•
doing so results in more relevant information, because either:
• it eliminates or significantly reduces a measurement or recognition inconsistency that would otherwise arise from
measuring assets or liabilities or recognising the gains and losses on them on different bases; or
• a group of financial liabilities or financial assets and financial liabilities is managed and its performance is evaluated on
a fair value basis, in accordance with a documented risk management or investment strategy, and information about
the Company is provided internally on that basis to the Company’s key management personnel; or
•
the contract contains one or more embedded derivatives and the Company measures the compound financial instrument
as a financial liability measured at fair value through profit or loss unless:
• the embedded derivative does not significantly modify the cash flows that otherwise would be required by the contract
or
• it is clear with little or no analysis when a similar hybrid instrument is first considered that the separation of the
embedded derivative(s) is prohibited.
It is noted that in the above case, the amount of the change in fair value attributable to the Company’s credit risk is recognized in
other comprehensive income, unless this treatment would create or enlarge an accounting mismatch in profit or loss. Amounts
recognized in other comprehensive income are never transferred to profit or loss.
As at the reporting date, the Company had not designated, at initial recognition, any financial liabilities as at fair value through profit
or loss.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
441 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
b. Financial liabilities carried at amortised cost
The liabilities classified in this category are measured at amortised cost using the effective interest method.
Liabilities to credit institutions, debt securities issued by the Company and other loan liabilities are classified in this category.
c. Liabilities arising from financial guarantees and commitments to provide loans at a below market interest rate
A financial guarantee contract is a contract that requires the issuer to make specified payments to reimburse the holder for a loss it
incurs because a specified debtor fails to make payments when due in accordance with the agreed terms.
The financial guarantee contracts and the commitments to provide loans at a below market interest rate are initially recognized at
fair value, and measured subsequently at the higher of:
•
the amount of the provision determined during expected credit loss calculation ,
•
the amount initially recognised less cumulative amortization which is calculated based on the term of the instrument.
d. Financial liabilities that arise when a transfer of a financial asset does not qualify for derecognition or when the
continuing involvement approach applies
In the first case the liability should be equal to the amount received during the transfer while in the second case it should measured
in such a way that the net carrying amount of the transferred asset and the associated liability is:
•
The amortised cost of the rights and obligations retained by the Company, if the transferred asset is measured at amortised
cost or
•
Equal to the fair value of the rights and obligations retained by the Company when measured on a stand-alone basis, if the
transferred asset is measured at fair value.
e. Contingent consideration recognized by an acquirer in a business combination
Such contingent consideration is subsequently measured at fair value with changes recognized in profit or loss.
Derecognition of financial liabilities
Financial liabilities (or part thereof) are derecognized when the contractual obligation is been discharged, cancelled or expires.
When a financial liability is exchanged for another liability with substantially different terms, the exchange is accounted for as an
extinguishment of the original financial liability and the recognition of a new one. The same applies in cases of a substantial
modification of the terms of an existing financial liability or a part of it (whether or not attributable to the financial difficulty of the
debtor). The terms are considered substantially different if the discounted present value of the cash flows under the new terms
(including any fees paid net of any fees received), discounted using the original effective interest rate, is at least 10% different from
the present value of the remaining cash flows of the original financial liability.
In cases of derecognition, the difference between the carrying amount of the financial liability (or part of the financial liability)
extinguished or transferred to another party and the consideration paid, including any non-cash assets transferred or liabilities
assumed, is recognised in profit or loss.
Offsetting financial assets and financial liabilities
Financial assets and liabilities are offset and the amounts are reported net on the balance sheet, only when the Company has the
legally enforceable right to offset recognized amounts and there is the intention to settle on a net basis, or to realize the asset and
settle the liability simultaneously.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
442 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1.2.4 Derivative financial instruments
Derivative financial instruments
Derivatives are financial instruments that upon inception have a minimal or zero fair value that subsequently changes in
accordance with a particular underlying instrument or indices defined in the contract (foreign exchange, interest rate, index or other
variable).
All derivatives are recognized as assets when their fair value is positive and as liabilities when their fair value is negative.
Derivatives are entered into for either hedging or trading purposes and they are measured at fair value irrespective of the purpose
for which they have been transacted.
The change in the fair value of the interest and currency derivatives, excluding options, is separated into interest, foreign exchange
differences and other gains or losses from financial transactions.
In case a derivative is embedded in a financial asset, the embedded derivative is not separated and the hybrid contract is
accounted for based on the classification requirements mentioned in note 1.2.3.
In case a derivative is embedded in a host contract, other than a financial asset, the embedded derivative is separated and
measured at fair value through profit or loss when the following conditions are met:
•
the economic characteristics and risks of the embedded derivative are not closely related to the economic characteristics and
risks of the host,
•
a separate instrument with the same terms as the embedded derivative would meet the definition of a derivative; and
•
the hybrid contract is not measured at fair value with changes in fair value recognised in profit or loss.
Valuation differences arising from derivatives are recognized in Gains less losses on financial transactions.
1.2.5 Fair Value Measurement
Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market
participants at the measurement date, in the principal market for the asset or liability or, in the absence of a principal market, in the
most advantageous market for the asset or liability.
The Company measures the fair value of assets and liabilities traded in active markets based on available quoted market prices. A
market is regarded as active if quoted prices are readily and regularly available from an exchange, dealer, broker, pricing service or
regulatory agency, and those prices represent actual and regularly occurring market transactions on an arm’s length basis.
Especially, for the measurement of securities, the Company uses a particular range of prices, within the bid-ask spread, in order to
characterize the prices as prices of an active market (the difference between bid and ask prices quoted should not exceed 1.5/100
nominal value). Furthermore, if quoted market prices are not available on the measurement date, but they are available during the
three last working days of the reporting period and there are quoted prices for 15 working days during the last month of the
reporting period and the criteria of the bid-ask spread is met, then the market is considered to be active.
The fair value of financial instruments that are not traded in an active market is determined by the use of valuation techniques,
appropriate in the circumstances, and for which sufficient data to measure fair value are available, maximizing the use of relevant
observable inputs and minimizing the use of unobservable inputs. If observable inputs are not available, other model inputs are
used which are based on estimations and assumptions such as the determination of expected future cash flows, discount rates,
probability of counterparty default and prepayments. In all cases, the Company uses the assumptions that “market participants”
would use when pricing the asset or liability, assuming that market participants act in their economic best interest.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
443 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Assets and liabilities which are measured at fair value or for which - fair value is disclosed-, are categorized according to the inputs
used to measure their fair value as follows:
•
Level 1 inputs: quoted market prices (unadjusted) in active markets,
•
Level 2 inputs: directly or indirectly observable inputs,
•
Level 3 inputs: unobservable inputs used by the Company, to the extent that relevant observable inputs are not available.
More specifically for financial instruments, the best evidence of fair value at initial recognition is the transaction price, unless the fair
value can be derived by other observable market transactions relating to the same instrument, or by a valuation technique using
mainly observable inputs. In these cases, if the fair value differs from the transaction price, the difference is recognized in the
statement of comprehensive income. In all other cases, fair value is adjusted to defer the difference with the transaction price. After
initial recognition, the deferred difference is recognized as a gain or loss only to the extent that it arises from a change in a factor
that market participants would take into account when pricing the instrument.
When measuring fair value, the Company takes into consideration the effect of credit risk. Specifically, for derivative contracts, the
Company estimates the credit risk of both counterparties (bilateral credit valuation adjustments).
The Company measures fair value for all assets and liabilities separately. Regarding derivative exposures, however, that the
Company manages as a group on a counterparty basis and for which it provides information to the key management personnel, the
fair value measurement for credit risk is performed based on the net risk exposure per counterparty. Credit valuation adjustments
arising from the aforementioned process are allocated to either assets or liabilities, depending on whether the net exposure to the
counterparty is long or short respectively.
Furthermore, the fair value of deposit accounts with a demand feature (such as saving deposits) is no less than the amount payable
on demand, discounted from the first date that the amount could be required to be paid.
The principal inputs to the valuation techniques used by the Company are:
•
Bond prices - quoted prices available for government bonds and certain corporate securities.
•
Credit spreads - these are derived from active market prices, prices of credit default swaps or other credit based instruments,
such as debt. Values between and beyond available data points are obtained by interpolation and extrapolation.
•
Interest rates -these are principally benchmark interest rates such as the EURIBOR and other quoted interest rates in the
swap, bond and futures markets. Values between and beyond available data points are obtained by interpolation and
extrapolation.
•
Foreign currency exchange rates - observable markets both for spot and forward contracts and futures.
•
Equity and equity index prices - quoted prices are generally readily available for equity shares listed on stock exchanges and
for major indices on such shares.
•
Price volatilities and correlations - Volatility and correlation values are obtained from pricing services or derived from option
prices.
•
Unlisted equities - financial information specific to the company or industry sector comparables.
•
Mutual Funds- for open-ended investments funds listed on a stock exchange the published daily quotations of their net asset
values (NAVs).
•
Loans and Deposits – market data and Company/customer specific parameters.
1.2.6 Investments in subsidiaries
This caption includes Company’s investments in subsidiaries.
Investments in subsidiaries are carried at cost, plus any expenses directly attributable to their acquisition less impairment losses.
The acquisition cost also includes the issues of the subsidiary companies which are recognized as equity instruments and which
are held by the Company.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
444 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Dividends received by the Company from the above investments are recognised in the income statement when the dividend
distribution is approved by the appropriate body of the company that the Company has invested in.
In case of absorption of a subsidiary or of a sector that satisfies the definition of a business, the Company applies the provisions of
IFRS 3 for business combinations, as described in more detail in note 1.2.1 of the consolidated financial statements as at
31.12.2023.
Corporate reorganizations under the same Group, which are made through the establishment of a new company that absorbs
assets and liabilities of another company which satisfy the definition of business under IFRS 3, are not business combinations since
the new company does not satisfy the definition of an acquirer. Under the policy applied by the Company, those transactions are
accounted for by transferring assets and liabilities at the book values in the books of the company that makes the transfer. Additionally,
both in the separate and group financial statements of the new company, information is included from the date of the corporate
reorganization. However, in case corporate reorganization is inextricably linked to the transfer of the new company or of the above
assets and liabilities to a third party investor, the transfer of the assets and liabilities is accounted for at their fair value at the date of
the corporate reorganization.
1.2.7 Property, plant and equipment
This caption includes the equipment used by the Company.
Equipment is initially recognised at cost which includes any expenditure directly attributable to the acquisition of the asset.
Subsequently, equipment is measured at cost less accumulated depreciation and impairment losses.
Subsequent expenditure is recognized on the carrying amount of the item when it increases future economic benefit for the
Company and it can be measured reliably.
Expenditure on repairs and maintenance is recognized in profit or loss as an expense as incurred.
Depreciation is charged on a straight line basis over the estimated useful lives of the equipment and it is calculated on the asset’s
cost minus residual value.
The estimated useful life of the equipment has been defined from 5 to 14 years.
The residual value of the equipment and its useful life is periodically reviewed and adjusted if necessary at each reporting date.
Equipment is reviewed on an annual basis to determine whether there is an indication of impairment and if they are impaired the
carrying amount is adjusted to its recoverable amount with the difference recorded in profit or loss.
In case of sale of equipment as well as when no economic benefits are expected for the Company, the fixed asset is derecognised.
When selling the asset, the difference between the sale price and its carrying amount is recognized in profit or loss.
1.2.8 Goodwill and other intangible assets
The Company has included in this caption:
a. Goodwill which represents the difference between the cost of an acquisition as well as the value of non-controlling interests and
the fair value of the assets and liabilities of the entity acquired, as at the acquisition date.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
445 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Positive goodwill arising from acquisitions after 1/1/2004 is recorded to “Goodwill and other intangible assets”, if it relates to the
acquisition of a subsidiary, and it is tested for impairment at each balance sheet date.
Negative goodwill is recognized in profit or loss.
b. Software, which is measured at cost less accumulated amortization and impairment losses. Expenditure incurred to maintain
software programs is recognized in the income statement as incurred. Software that is considered to be an integral part of
hardware (hardware cannot operate without the use of the specific software) is classified in property, plant and equipment.
More specifically, separately acquired software is initially measured at cost which comprises its purchase price and any directly
attributable cost of preparing the software for its intended use, including employee benefits or professional fees. Software acquired
as part of a business combination is initially measured at fair value. Both software separately acquired and acquired as part of a
business combination is depreciated, using the straight line method, during its useful life which has been set from 2 to 15 years.
Regarding internally generated software, the Company recognizes an intangible asset when it can demonstrate all of the following
at the development phase:
•
the technical feasibility of completing the intangible asset so that it will be available for use or sale;
•
its intention to complete the intangible asset and use or sell it;
•
its ability to use or sell the intangible asset;
•
how the intangible asset will generate probable future economic benefits;
•
the availability of adequate technical, financial and other resources to complete the development and to use or sell the
intangible asset;
•
its ability to measure reliably the expenditure attributable to the intangible asset during is development.
Expenditure incurred during the research phase is directly recognized in profit or loss.
Consequently, the cost of an internally generated intangible asset is the sum of expenditure incurred from the date when the
intangible asset first meets the above criteria, including employee benefits arising from the generation of the software.
Internally generated software is depreciated during its useful life which has been set from 2 to 15 years.
All intangible assets are assessed for impairment when there are triggers for impairment (note 1.2.12).
No residual value is estimated for intangible assets.
In case of sale of an intangible asset the intangible asset is derecognized, while when no economic benefits are expected for the
Company, its value is fully impaired. When selling the asset, the difference between the sale price and its carrying amount is
recognized in profit or loss.
1.2.9 Credit impairment losses on advances to customers
The Company, at each reporting date, recognizes a loss allowance for expected credit losses on advances to customers.
The loss allowance for advances to customers is measured at an amount equal to the lifetime expected credit losses (there is no
stage allocation) based on the simplified approach provided by IFRS 9.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
446 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1.2.10 Credit impairment losses on due from banks and bonds
The Company, at each reporting date, recognizes a loss allowance for expected credit losses on due from banks and bonds not
measured at fair value through profit or loss.
The loss allowance is based on expected credit losses related to the probability of default within the next twelve months, unless
there has been a significant increase in credit risk from the date of initial recognition in which case expected credit losses are
recognized over the life of the instrument. In addition, if the financial asset falls under the definition of purchased or originated credit
impaired (POCI) financial assets, a loss allowance equal to the lifetime expected credit losses is recognized.
a. Default definition
Due from banks and bonds are considered impaired when the external rating of the issuer/counterparty is equivalent to default (D).
In case there is no external rating, then the instrument is characterized as impaired based on internal rating. If there is also an
exposure to the corporate issuer/counterparty to the loan portfolio which has been classified as impaired, the instrument is also
characterized as impaired.
b. Classification of exposures into stages based on credit risk (Staging)
For the purposes of calculating expected credit losses, the exposures are classified into stages as follows:
•
Stage 1: Stage 1 includes non impaired instruments that do not have significant increase in credit risk since initial recognition.
Stage 1 also includes instruments for which credit risk has been improved and the instrument has been reclassified from
stages 2 or 3. In this stage, expected credit losses are recognized based on the probability of default within the next twelve
months.
•
Stage 2: Stage 2 includes non impaired instruments for which there has been a significant increase in credit risk since initial
recognition. Stage 2 also includes instruments for which credit risk has been improved and the instrument has been
reclassified from stage 3. In this stage, lifetime expected credit losses are recognized.
•
Stage 3: Stage 3 includes impaired instruments. In this stage, lifetime expected credit losses are recognized.
As an exception to the above, for purchased or originated credit impaired (POCI) instruments, lifetime expected credit losses are
always recognized. An instrument is characterized as purchased or originated credit impaired when:
•
The instrument (or the issuer) has an external rating that corresponds to default at the time of acquisition
•
Corporate bonds resulting from debt restructuring are classified as purchased or originated credit impaired, based on the
guidelines applicable to the loan portfolio.
When a debt security has been purchased at a large discount and does not fall into any of the categories mentioned above, the
Company examines the transaction in detail (transaction price, recovery rate, issuer’s financial condition at the time of purchase,
etc.) in order to determine whether it should be recognised as purchased or originated credit-impaired (POCI). Classification in this
category requires documentation and approval by the relevant committees of the Company.
c. Significant increase in credit risk
The classification into stages for the purpose of expected credit loss measurement is based on the credit rating of rating agencies
or, for corporate securities issued by Greek issuers for which there is also an exposure in loan portfolio, on the issuer’s internal
rating.
The Company defines as low credit risk all investment grade securities, which are classified in Stage 1.
The determination of significant increase in credit risk for non-investment grade securities is based on the following two conditions:
•
Downgrade in the issuer / counterparty’s credit rating on the reporting dates compared to the credit rating on the date of the
initial recognition.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
447 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
•
Increase in the probability of default of the issuer / counterparty for the 12-month period compared to the corresponding
probability of default at initial recognition.
Additionally, the Company monitors the change in the credit spread since initial recognition. A change in credit spread at the
reporting date that exceeds a specific threshold compared to the credit margin prevailing at the date of initial recognition is a trigger
for reviewing the securities classification stage.
d. Calculation of expected credit loss
The expected credit loss is the present value of the difference between:
•
the contractual cash flows and
•
the cash flows that the Company expects to receive
For present value calculation, original effective interest rate is used as a discount rate. Especially for POCI assets credit-adjusted
effective interest rate is used.
For the calculation of the expected credit loss, the following parameters are used:
•
Probability of default (PD): the probability of default over the next 12 months is used to calculate the expected credit loss for 12
months, and the probability of default over the life of the instrument is used to calculate the lifetime expected credit losses.
•
Exposure at default (EAD): In the case of securities, the Company estimates the future unamortised cost in order to calculate
the EAD. In particular, for each period, EAD is the maximum loss that would result from issuer / counterparty potential default.
•
Loss given default (LGD) is the percentage of the total exposure that the Company estimates as unlikely to recover at the time
of the default. The Company distinguishes sovereigns from non-sovereign issuers / counterparties as regards to the LGD
estimation. In case the Company has also granted a loan to the issuer / counterparty of the security, the estimated LGD is
aligned to corresponding estimate for the loan portfolio (taking into account any potential collaterals the loan portfolio is likely to
have against the unsecured debt securities).
e. Presentation of expected credit losses in financial statements
Loss allowances for expected credit losses are presented in the Balance Sheet as follows:
•
Financial assets measured at amortised cost: loss allowance is presented as a deduction from the gross carrying amount of
the assets.
•
Financial assets measured at fair value through other comprehensive income: for those assets no loss allowance is recognized
in the Balance Sheet, however, its amount is disclosed in the notes to the financial statements.
The amount of expected credit losses for the period is presented in the caption “Impairment losses, provisions to cover credit risk and
related expenses”. The caption includes also the favourable changes in expected credit losses of POCI assets in case expected credit
losses are less than the amount of expected credit losses included in the estimated cash flows on initial recognition.
1.2.11 Impairment losses on investments and non-financial assets
The Company assess as at each balance sheet date its investments in subsidiaries as well as non-financial assets for impairment,
particularly, goodwill and other intangible assets and at least annually property, plant and equipment.
In assessing whether there is an indication that an asset may be impaired both external and internal sources of information are
considered, of which the following are indicatively mentioned:
•
The asset’s market value has declined significantly, more than would be expected as a result of the passage of time or normal
use.
•
Significant changes with an adverse effect have taken place during the period or will take place in the near future, in the
technological, economic or legal environment in which the entity operates or in the market to which the asset is dedicated.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
448 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
•
Significant unfavorable changes in foreign exchange rates.
•
Market interest rates or other rates of return of investments have increased during the period, and those increases are likely to
affect the discount rate used in calculating an asset’s value in use.
•
The carrying amount of the net assets of the entity is greater than its market capitalization.
•
The carrying amount of the net assets of the entity on a consolidated basis is less than entity’s acquisition cost in the books of
the Company
•
Evidence is available of obsolescence or physical damage of an asset.
In addition, collection of dividends from subsidiaries is considered as a possible impairment indicator when investments are tested
for impairment at each reporting date.
Specifically for right of use assets, triggers for impairment include:
•
The existence of leased properties that are neither used nor leased by the Company.
•
The fact that the present value of the leases received in the event of a sublease is lower than the value of the rents paid under
the lease.
An impairment loss is recognized in profit or loss when the recoverable amount of an asset is less than its carrying amount. The
recoverable amount of an asset is the higher of its fair value less costs to sell and its value in use.
Fair value less costs to sell is the amount received from the sale of an asset (less the cost of disposal) in an orderly transaction
between market participants.
Value in use is the present value of the future cash flows expected to be derived from an asset or cash –generating unit through
their use and not from their disposal.
For the valuation of property, plant and equipment, the calculation of the recoverable amount includes all improvements which
render the asset perfectly suitable for its use by the Company. In this way, the market participant’s ability to generate economic
benefits by using the asset in it’s highest and best use or by selling it to another market participant that would use the asset in its
highest and best use is taken into account.
An impairment loss recognised in prior periods shall be reversed in case of a change in the estimates for the determination of the
recoverable amount. The increased carrying amount of the asset attributable to the reversal of an impairment loss shall not exceed
the carrying amount that would have been determined had no impairment loss been recognised. An impairment loss recognised for
goodwill shall not be reversed.
1.2.12 Income tax
Income tax consists of current and deferred tax.
Current tax for a period includes the expected amount of income tax payable in respect of the taxable profit for the current reporting
period, based on the tax rates enacted at the balance sheet date.
Deferred tax is the tax that will be paid or for which relief will be obtained in future periods and it is calculated based on the
temporary differences between the tax base of assets and liabilities and their respective carrying amounts in the financial
statements.
Deferred tax assets and liabilities are calculated using the tax rates that are expected to apply when the temporary difference
reverses, based on the tax rates (and laws) enacted at the balance sheet date.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
449 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
A deferred tax asset is recognized to the extent that it is probable that future taxable profits will be available against which the asset
can be utilized.
In addition, deferred tax assets are not recognized from the initial recognition of an asset or liability in a transaction that is not a
business combination and at the time it takes place affects neither accounting profit nor taxable profit.
Furthermore, regarding investments in subsidiaries, deferred tax assets are recognized only when it is probable that the temporary
difference will reverse in the foreseeable future and taxable profit will be available against which the temporary difference can be
utilized.
Income tax, both current and deferred, is recognized in profit or loss except when it relates to items recognized directly in equity. In
such cases, the respective income tax is also recognized in equity.
1.2.13 Non-current assets held for sale
Non-current assets or disposal groups that are expected to be recovered principally through a sale transaction, along with the
related liabilities, are classified as held-for-sale.
The above classification is used if the asset is available for immediate sale in its present condition and its sale is highly probable.
The sale is considered highly probable when it has been decided by the competent bodies of the Management, an active
programme to locate a buyer has been initiated, the asset is actively marketed for sale at a price which is reasonable in relation to
its current fair value, and the sale is expected to be completed within one year. Non-current assets that are acquired exclusively
with a view to their subsequent disposal are classified as held for sale at the acquisition date when the one-year requirement is met
and it is highly probable that the remaining criteria will be met within a short period following the acquisition (usually within three
months).
Before their classification as held for sale, the assets are remeasured in accordance with the respective accounting standard.
Assets held for sale are initially recognised and subsequently remeasured at each balance sheet date at the lower of their carrying
amount and fair value less cost to sell.
Any loss arising from the above measurement is recorded in profit or loss and can be reversed in the future. In this case, the gain
from any subsequent increase in fair value less costs to sell cannot exceed the cumulative impairment losses that have been
recognized. When the loss relates to a disposal group it is allocated to assets within the disposal group with the exception of
specific assets that are not within the scope of IFRS 5. The impairment loss on a disposal group is first allocated to goodwill and
then to the remaining assets and liabilities on a pro-rata basis.
Assets in this category are not depreciated.
Gains or losses from the sale of these assets are recognized in the income statement.
Non-current assets held for sale, that the Company subsequently decides either to use or to lease, are reclassified to the
categories of property, plant and equipment or investment property respectively. During their reclassification, they are measured at
the lower of their recoverable amount and their carrying amount before they were classified as held for sale, adjusted for any
depreciation, amortization or revaluation that would have been recognized had the assets not been classified as held for sale.
Non-current assets that the Company intends to sell but are not available for immediate sale or are not expected to be sold within a
year are included in Other Assets and are measured at the lower of cost (or carrying amount) and net realizable value in
accordance with IAS 2. Net realizable value is considered equal to fair value less cost to sell.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
450 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1.2.14 Employee benefits related to the shares of the Company
a. Share options granted to employees
The granting of share options to the employees, their exact number, the price and the exercise date are decided by the Board of
Directors in accordance with Shareholders’ Meeting approvals and after taking into account the current legal framework.
The fair value calculated at grant date is recognized during the servicing period and recorded in staff costs when employees offer
their services to the Company or increase the acquisition cost of the subsidiary (as a capital contribution) to which the employees
offer their services (or the intermediate subsidiary in case the employees offer their services to a subsidiary in which the Company
has an indirect interest) with a corresponding increase of a reserve in equity. When there are no vesting conditions, it is considered
that services have been received. On the contrary, when there are service vesting conditions the expense or the increase in
subsidiary’s acquisition cost are recognized as the relative services are received. In case there are conditions that are not vesting
conditions, they are taken into account in share options valuation. The amount paid by the beneficiaries of share options on the
exercise date increases the share capital of the Company and the reserve in equity from the previously recognized fair value of the
exercised options is transferred to share premium. The reserve in equity from the previously recognized fair value of the
unexercised options is transferred to retained earnings.
b. Share awards granted to employees
The granting of stock awards to the employees is decided by the Board of Directors within the framework approved by the
Shareholders’ Meeting.
The fair value of the award, determined at the grant date, is recognized in staff costs when employees offer their services to the
Company or increase the acquisition cost of the subsidiary (as a capital contribution) to which the employees offer their services (or
the intermediate subsidiary in case the employees offer their services to a subsidiary in which the Company has an indirect interest)
with a corresponding increase of a reserve in equity. When there are no vesting conditions, it is considered that services have been
received. On the contrary, when there are service vesting conditions the expense or the increase in subsidiary’s acquisition cost is
recognized as the relative services are received. In case there are conditions that are not vesting conditions, they are taken into
account in the award’s valuation. At the time of registration of the shares in the portion of the beneficiaries, any difference between
the acquisition cost of the treasury shares offered and the formed reserve that is used is recognized in retained earnings.
1.2.15 Provisions and contingent liabilities
A provision is recognized if, as a result of a past event, the Company has a present legal or constructive obligation that can be
estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation.
Provisions are, also, recognized in cases of restructuring plans with which management attempts either to change the subject of a
corporate activity or the manner in which it is conducted (e.g. close down business locations). The recognition of provision is
accompanied with the relevant, authorized by the Management, program and with the suitable actions of disclosure. A restructuring
provision includes only the direct expenditures arising from the restructuring, which are those that are both necessarily entailed by
the restructurings and not associated with the ongoing activity of the Company.
The amount recognized as a provision shall be the best estimate of the expenditure required to settle the present obligation at the
end of the reporting period. Where the effect of the time value of money is material, the amount of the provision is equal to the
present value of the expenditures expected to settle the obligation.
Amounts paid for the settlement of an obligation are set against the original provisions for these obligations. Provisions are
reviewed at the end of each reporting period. If it is no longer probable that an outflow of resources embodying economic benefits
will be required to settle the obligation, the provision is reversed. Additionally, provisions are not recognized for future operating
losses.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
451 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Future events that may affect the amount required to settle the obligation, for which a provision has been recognized, are taken into
account when sufficient objective evidence exists that they will occur.
Reimbursements from third parties relating to a portion of or all of the estimated cash outflow are recognized as assets, only when
it is virtually certain that they will be received. The amount recognized for the reimbursement does exceed the amount of the
provision. The expense recognized in profit or loss relating to the provision is presented net of the amount of the reimbursement.
The Company does not recognize in the statement of financial position contingent liabilities which relate to:
•
possible obligations resulting from past events whose existence will be confirmed only by the occurrence or non-occurrence of
one or more uncertain future events not wholly within the control of the Company, or
•
present obligations resulting from past events for which:
•
it is not probable that an outflow of resources will be required, or
•
the amount of liability cannot be measured reliably.
The Company provides disclosures for contingent liabilities taking into consideration their materiality.
1.2.16 Equity
Distinction between debt and equity
Financial instruments issued by the Company to obtain funding are classified as equity when, based on the substance of the
transaction, the Company does not undertake a contractual obligation to deliver cash or another financial asset or to exchange
financial instruments under conditions that are potentially unfavorable to the issuer.
AT1 has been classified in this category since it is perpetual and there is no oblligation to pay either principal or interest.
In cases when the Company is required to issue equity instruments in exchange for the funding obtained, the number of equity
instruments must be fixed and determined on the initial contract, in order for the obligation to be classified as equity.
Distributions to the holders of equity instruments are directly recognized by debiting the equity of the Company.
Incremental costs of share capital increase
Incremental costs directly attributable to the issue of new shares are shown in equity as a deduction, net of tax, from retained
earnings.
Share premium
Share premium includes the difference between the nominal value of the shares and the cost consideration received in the case of
a share capital increase.
It also includes the difference between the nominal value of the shares issued and their market value, in cases of exchanges of
shares as consideration for the acquisition of a business by the Company.
Treasury shares
The cost of acquiring treasury shares is recognized as a reduction of equity. Subsequent gains or losses from the sale of treasury
shares, after deducting all direct costs and taxes, are recognized directly in retained earnings.
Dividends
Dividends are deducted from retained earnings and recorded as a liability in the period that the dividend is approved by the
Shareholders’ General Meeting.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
452 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Distributions of non-cash assets
Distributions of non-cash assets take place at the fair value of the asset distributed. Any difference between the carrying amount
and the fair value of the asset distributed is directly recognised in profit or loss.
1.2.17 Interest income and expense
Interest income and expense is recognized in the income statement for all interest bearing financial assets and liabilities.
Interest income and expense is recognised on an accrual basis and measured using the effective interest method with the
exception of derivatives as described in detail in note 1.2.4. Especially for POCI assets, interest income is calculated using credit-
adjusted effective interest rate.
Effective interest rate is the rate that exactly discounts estimated future cash payments or receipts through the expected life of the
financial asset or financial liability to the gross carrying amount of a financial asset or to the amortised cost of a financial liability.
When calculating the effective interest rate, the Company estimates the expected cash flows by considering all the contractual
terms of the financial instrument but does not consider the expected credit losses. The calculation includes all fees and points paid
or received between parties to the contract that are an integral part of the effective interest rate.
For financial assets, in particular, the following apply:
•
For those financial assets classified within Stage 1 or Stage 2 for the purpose of expected credit losses measurement, interest
income is calculated by applying effective interest rate to the gross carrying amount of the asset.
•
For those financial assets classified within Stage 3 for the purpose of expected credit losses measurement, interest income is
calculated by applying the effective interest rate to the amortised cost of the asset.
•
For purchased or originated credit impaired financial assets interest income is calculated by applying the credit-adjusted
effective interest rate to the amortised cost of the asset.
In case of negative interest rates, interest is presented within interest income for interest bearing financial liabilities and within
interest expense for interest bearing financial assets.
Borrowing costs that are directly attributable to assets that require a substantial period of time to get ready for their intended use or
sale are capitalized as part of the cost of the asset. Capitalisation ceases when substantially all the activities necessary to prepare
the asset for its intended use are complete.
1.2.18 Fee and commission income
Fees and commission income from contracts with customers are recognized based on the consideration specified in the contract
when the Company satisfies the performance obligation by transferring the service to the customer. With the exception of specific
portfolio management fees which are calculated on the basis of the size and performance of the portfolio, the services provided
have a fixed price. Variable portfolio management fees are recognized when all related uncertainties are resolved.
For commissions on services provided over time, revenue is recognized as the service is being provided to the customer, such as
commissions to provide account management services, fees for administration of loans, fees for portfolio management and
investment services advice.
For transaction-based fees, the execution and completion of the transaction executed signals the point in time, at which the service
is transferred to the customer and the revenue is recognized, such as currency transactions, purchases / sales of securities as well
as issue and disposal of syndicated loans and bonds.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
453 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Transaction revenues relating to the recognition of a financial instrument not measured at fair value through profit or loss are
capitalized and amortised in the income statement using the effective interest method over the life of the financial instrument and
included in interest income.
In particular, with regards to fee income for promotion and distribution of Insurance Products (bankassurance) the entity is entitled
to a commission as a percentage of sales that is recognized in profit or loss as sales occur. The entity is also entitled to a
performance bonus that is accounted as a variable consideration recognized in profit or loss based on the progress towards
complete satisfaction of the performance obligation (actual sales), provided that it is highly probable that a significant reversal in the
amount of cumulative revenue will not occur when the uncertainty associated with the variable consideration is subsequently
resolved.
1.2.19 Discontinued operations
A discontinued operation is a component of the Company that either has been disposed of, or has been classified as held for sale
and represents:
•
a separate major line of business or geographical area of operations or
•
part of a single co-ordinated plan to dispose of a separate major line of business or geographical area of operations.
The post tax profit or loss from discontinued operations and any losses recognized on the measurement to fair value less costs to
sell of the disposal group are presented in a separate line in the face of the income statement after net profit from continuing
operations. The comparative financial statements are restated only for the income statement and the cash flow statement.
1.2.20 Related parties definition
According to IAS 24, a related party is a person or entity that is related to the entity that is preparing its financial statements. For the
Company, in particular, related parties are considered:
•
An entity that constitutes for the Company:
•
a subsidiary,
•
a joint venture
•
an associate and
•
the Post-employment Benefit Plan, in this case the TEA Group Alpha Services and Holdings
•
A person or an entity that have control, or joint control, or significant influence over the Company.
This category included Hellenic Financial Stability Fund and its subsidiaries, because, in the context of the L.3864/2010, the
HFSF participated in the Board of Directors and as a result is considered to have significant influence over it. During the fourth
quarter of the current year, the Financial Stability Fund transferred the shares it owned to Alpha Services and Holdings and
therefore ceased to participate in its Board of Directors and to be a related party.
•
A person and his close family members, if that person is a member of the key management personnel.
The Company considers as key management personnel all the members of the Company’s Board of Directors and of the
Company’s Executive Committee while as their close family members it considers their children and spouses or domestic
partners and their dependents and the dependents of their spouses or domestic partners.
Related parties are also considered the entities controlled or jointly controlled by the above mentioned persons and more
specifically the entities in which the above persons participate with more than 20%.
1.2.21 Earnings per share
Basic earnings per share are calculated by dividing profit or loss attributable to ordinary equity holders of the Company by the
weighted average number of ordinary shares outstanding during the period.
Diluted earnings per share are calculated using the same method as the calculation of basic earnings per share, however, both the
nominator and the denominator are adjusted for the effects of all dilutive potential ordinary shares.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
454 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
1.2.22 Comparatives
To the extent considered necessary the comparatives have been adjusted to facilitate changes in presentation of the current year
amounts.
1.3 Significant accounting judgments and key sources of estimation uncertainty
Significant accounting judgments
The Company, in the context of applying accounting policies, makes judgments and assessments which have a significant impact
on the amounts recognized in the financial statements. Those judgements relate to the following:
Income Tax (notes 11, 32)
The recognition of assets and liabilities for current and deferred tax is affected, interalia, by the interpretation of the applicable tax
legislation, the practical implementation of the relevant legislation and the settlement of disputes that might exist with tax
authorities. When assessing the tax treatment of all significant transactions, the Company takes into account and evaluates all
available data (Circulars of the Ministry of Finance, case law, administrative practices, etc.) and / or opinions received from internal
and external legal advisers. Future tax audits and changes in tax legislation may result in the adjustment of the amount of assets
and liabilities for current and deferred tax and in tax payments other than those recognized in the financial statements of the
Company.
Key sources of estimation uncertainty
Key sources of estimation uncertainty used by the Company in the context of applying its accounting principles and relating to the
carrying amount of assets and liabilities at the end of the reporting period are presented below. Final amounts in the next periods
may be significantly different from those recognised in these financial statements.
Impairment losses on investments in subsidiaries and on non - financial assets
The Company, at each reporting date, assesses for impairment its intangible assets and its investments in subsidiaries, and at least
on an annual basis property, plant and equipment. Management estimates the recoverable amount of the assets, i.e. the higher
between the fair value less costs to sell and value in use by performing an impairment exercise, which includes inputs and
assumptions that are inherently uncertain. In cases where the sale of such items is imminent, the fair value derives from the
estimated price of the transaction considering any other element that could impact the recoverable amount upon the completion of
the transaction.
Revenue recognized from variable consideration in contracts with customers (note 19)
The Company under the contract of distribution of insurance products is entitled to a performance bonus on the achievement of a
specified sales target in the future. As a result, this amount represents a variable consideration which, however, according to the
Company’s assessment, is not considered constrained since the successful achievement of the target is highly dependent on
factors that are within its influence. Revenue is recognized as sales occur since it has been assessed that the best method for
measuring progress towards satisfaction of the performance obligation is the appraisal of sales achieved. At the end of each
reporting period, the Company updates its method for measuring progress of performance obligation, as well as its assessment of
whether the estimate of variable consideration is not constrained.
The estimates and judgments applied by the Company in making decisions and in preparing the financial statements are based on
historical information and assumptions which at present are considered appropriate. The estimates and judgments are reviewed at
each reporting period in order to take into account current conditions, and the effect of any changes is recognized in the period in
which the estimates are revised.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
455 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
INCOME STATEMENT
2. Net interest income
From 1 January to
31.12.2023
31.12.2022
Interest and similar income
Due from banks
4
Loans and advances to customers measured at amortized cost
644
Investment securities measured at amortized cost
53,667
53,711
Investment securities measured at fair value through profit or loss
473
Other
214
98
Total
53,881
54,930
Interest expense and similar charges
Due to banks
(466)
(284)
Debt securities in issue and other borrowed funds
(49,222)
(49,737)
Other
(96)
(104)
Total
(49,784)
(50,125)
Net interest income
4,097
4,805
Interest income from investment securities measured at amortized cost, includes interest from subordinated notes, issued by the
Bank and covered by the Company in April 2021, after the hive-down (note 15).
Interest expense and similar charges mainly include mainly amounts regarding Tier II notes issued by the Company (note 21).
In 2022, interest income from loans and advances to customers relates to the securitized loan portfolio of the special purpose entity
Galaxy III Funding DAC until their derecognition on 8.3.2022.
The following table presents the amounts of interest income and interest expense calculated using the effective interest rate
method, by financial instrument measurement category:
From 1 January to
31.12.2023
31.12.2022
Financial assets measured at amortised cost
53,881
54,457
Financial assets measured at fair value through profit or loss
473
Financial liabilities measured at amortised cost
(49,784)
(50,125)
Total
4,097
4,805
3. Net fee and commission income
From 1 January to
31.12.2023
31.12.2022
Loans
325
Credit cards
1
Advisory fees and securities transaction fees
110
Insurance brokerage
6,745
5,781
Total
6,745
6,217
In 2023, net fee and commission income includes the net fee and commission income from insurance brokerage of € 6,745
(31.12.2022: € 5,781), which consists of insurance contracts recognized upon sale (point in time) of € 5,496 (31.12.2022: € 3,166)
and fees related to performance bonus of € 1,249 (31.12.2022: € 2,615) that are recognized over time based on the level of
achievement of the sales target.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
456 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
4. Dividend income
From 1 January to
31.12.2023
31.12.2022
Subsidiaries
1,290
Other equity instruments
24,150
Total
24,150
1,290
Dividend income for 2023 of € 24,150 relates to the coupon payment receipt from the AT1 notes of € 400 mil. issued by the
subsidiary Alpha Bank S.A. and covered in full by the Company. Dividend income for 2022 relates to dividends from the former
subsidiary Alpha Insurance Agents S.A.
5. Gains less losses on financial transactions
From 1 January to
31.12.2023
31.12.2022 as
restated
Financial assets measured at fair value through profit or loss:
- Bonds
7,338
Other financial instruments
(235)
Total
7,103
Certain figures of the previous year have been reclassified as described in note 40.
Gains less losses on financial transactions for 2022 have been affected by gains of € 7,338 of bonds measured at fair value through
profit or loss, deriving mainly from the change in the valuation of mezzanine notes of the Galaxy securitization transaction until their
sale on 8.3.2022.
6. Other Income
From 1 January to
31.12.2023
31.12.2022
Income from accounting and tax services
497
502
Other
1,152
Total
1,649
502
On 28.7.2023, the merger by way of absorption of "Alpha Insurance Agents S.A." from the Company was completed. The
absorption was carried out based on the fair values of the assets and liabilities of the absorbed company in accordance with IFRS
3. From the absorption, the Company recognized a negative goodwill amounting to € 1,152 which is included under caption"Other"
(note 39).
7. Staff costs and expenses
From 1 January to
31.12.2023
31.12.2022
Wages and salaries
704
559
Social security contributions
147
108
Employee indemnity provision due to retirement based on Law 2112/1920
23
8
Other charges
145
212
Total
1,019
887
The total number of the Company’s employees as at 31.12.2023 was 18 (31.12.2022: 11).
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
457 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
8. General administrative expenses
From 1 January to
31.12.2023
31.12.2022
Lease expenses
28
29
Maintenance of EDP equipment
21
23
EDP expenses
297
32
Marketing and advertising expenses
802
505
Third party fees
3,813
2,006
Consultants fees related to financial information
688
451
Insurance
105
164
Stationary
1
Taxes and Duties (VAT, real estate tax etc)
2,105
1,078
Other
1,206
1,357
Total
9,065
5,646
Total General Administrative Expenses for 2023 are increased mainly due to the expenses incurred for the planning and hosting of
corporate presentations towards investors.
9. Impairment losses, provisions to cover credit risk
During 2023, the Company did not hold any loans and related receivables from customers.
Impairment losses and provisions to cover credit risk on loans and advances to customers and related expenses during 2022,
relate to the securitized loan portfolio of the special purpose vehicle Galaxy III Funding DAC, until its disposal on 8.3.2022.
From 1 January to
31.12.2023
31.12.2022 as
restated
Impairment losses on loans
2
(Gains) / Losses from modifications of contractual terms of loans and advances to customers
24
Recoveries
(22)
Impairment losses, provisions to cover credit risk on loans and advances to customers (a)
-
4
Impairments losses on debt securities and other securities measured at amortized cost
(2,371)
(7,259)
Impairment losses, provisions to cover credit risk on other financial instruments (b)
(2,371)
(7,259)
Total (a) + (b)
(2,371)
(7,255)
Certain figures of the previous year have been reclassified as described in note 40.
The credit amount from impairment of debt securities and other securities measured at amortized cost in 2023 is mainly attributed
to the reversal of expected credit loss of subordinated loans issued by the Bank and owned by the Company, resulting from the
credit rating upgrade of the Bank (as an issuer).
The following table presents the carrying amount of the loans and advances to customers for which there was gain or loss from the
modification of the contractual terms and the loss allowance was measured at an amount equal to lifetime expected credit loss i.e
loans categorised Stages 2, or stage 3 or loans Purchased or originated credit-impaired (POCI).
From 1 January to
31.12.2023
31.12.2022
Net carrying amount after impairment and before the modification
2,094
Net (gain) / loss due to the modification
(25)
10. Expenses relating to credit risk management
Costs relating to credit risk coverage for the year 2022 include an amount of € 664 of servicing fees of non-performing loans that
derive from the service agreement with Cepal for the management of non-performing loans.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
458 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
11. Income Tax
Statutory income tax rate applicable for societe anonymes for both years 2022 and 2023 is 22%.
Income tax is analyzed as follows:
From 1 January to
31.12.2023
31.12.2022
Current tax
4,188
Deferred tax
302
590
Total
302
4,778
The amount of “Current tax” of € 4,188 for the year 2022, refers to prior year income tax difference.
Deferred tax recognized in the income statement is attributable to temporary differences, the effect of which is analyzed in the table
below:
From 1 January to
31.12.2023
31.12.2022
Write-offs, depreciation, impairment of plant, property and equipment and leases
1
2
Other temporary differences
301
588
Total
302
590
A reconciliation between the effective and nominal tax rate is provided below:
From 1 January to
31.12.2023
31.12.2022
%
%
Profit / (Loss) before income tax
28,885
19,725
Income tax (nominal tax rate)
22
6,355
22
4,340
Increase / (Decrease) due to:
Non-taxable income
(0.24)
(69)
(1.44)
(284)
Non-deductible expenses
0.23
65
0.47
92
Non-recognition of deferred tax on tax losses
2.92
844
Non-recognition of deferred tax for temporary differences in the current period
(5.15)
(1,488)
Other tax adjustments
(18.71)
(5,405)
3.19
630
Income tax
1.04
302
24.23
4,778
The caption “other tax adjustments”, includes an amount of € 5,225 which relates to the tax effect from the dividend paid by the
company for Additional Tier 1. The abovemention dividend reduces the taxable results of the year with its payment, while for
accounting purposes has been recognized directly in equity.
Income tax of other comprehensive income recognized directly in equity is presented in the following table.
Income tax of other comprehensive income recognized directly in equity
From 1 January to
31.12.2023
31.12.2022
Before Income
tax
Income tax
After Income
tax
Before Income
tax
Income tax
After Income
tax
Amounts that will not be reclassified to the Income
Statement
Net change in actuarial gains/(losses) of defined benefit
obligations
19
19
Gains/(Losses) from equity securities measured at fair
value through other comprehensive income
(74)
(74)
(59)
(59)
Total
(74)
-
(74)
(40)
-
(40)
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
459 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
12. Earnings/(losses) per share
a. Basic
Basic earnings/(losses) per share are calculated by dividing the net profit/(losses) for the year, adjusted for the AT1 coupon
payment made in 2023 of € 23,750, attributable to ordinary equity shareholders of the Company, by the weighted average number
of ordinary shares outstanding during the period, excluding the weighted average of treasury shares held by the Company, during
the same period.
From 1 January to
31.12.2023
31.12.2022
Adjusted Profit/(Loss) attributable to equity holders of the Company
4,833
14,946
Weighted average number of outstanding ordinary shares
2,349,274,838
2,347,406,796
Basic earnings /(losses) per share (in €)
0.0021
0.0064
In January 2023 700,783 options were exercised which resulted in the issuance of 700,783 ordinary, registered, voting shares with
nominal value of € 0.29 each.
Additionally, in September 2023 2,789,104 were exercised which resulted in the issuance of 2,789,104 ordinary, registered, voting
shares with nominal value of € 0.29 each.
In December 2023 the Company purchased 5,855,794 own shares (note 26).
b. Diluted
Diluted earnings/(losses) per share are calculated by adjusting the weighted average number of ordinary shares outstanding during
the period with the dilutive potential ordinary shares. The Company holds shares of this category, which arise from a plan of
awarding stock options rights and stock awards to employees of the Company and Group companies.
For the calculation of the diluted earnings per share, stock awards are treated as stock option rights while stock option rights are
assumed to be exercised and that the related inflows derive from the issuance of common shares at the average market price of
the year during which the options and awards were outstanding. The difference between the number of options and awards to be
awarded and the ordinary shares issued at the average market price for ordinary shares, is recognized as issuance of ordinary
shares without exchange.
From 1 January to
31.12.2023
31.12.2022
Adjusted Profit/(Loss) attributable to equity holders of the Company
4,833
14,946
Weighted average number of outstanding ordinary shares
2,349,274,838
2,347,406,796
Adjustment for stock options
3,321,633
3,314,955
Adjustment for stock awards
25,544
Weighted average number of outstanding ordinary shares for diluted earnings per share
2,352,622,015
2,350,721,751
Diluted earnings /(losses) per share (in €)
0.0021
0.0064
In January 2024 the Company awarded to the benefiaries of the stock award plan 1,890,504 from the treasury shares από while in
February 2024 issued 1,142,026 new common shares with a nominal value of € 0.29 due to the exercise of stock options from the
beneficiaries (note 42).
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
460 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
ASSETS
13. Due from banks
31.12.2023
31.12.2022
Placements with banks
17,907
7,648
Total
17,907
7,648
Placement with banks refers to deposits of the Company in its subsidiary Alpha Bank S.A.
14. Due from customers
31.12.2023
31.12.2022
Advances to customers measured at amortised cost
182
339
Total
182
339
Due from customers relate to trade receivables from the provision of accounting and tax supporting services to the Group
companies.
The movement for 2023 and 2022 is presented below:
Balance 1.1.2022
18,446
Derecognition of Galaxy III Funding Designated Activity Company
(18,605)
Repayments and other movements
498
Balance 31.12.2022
339
Balance 1.1.2023
339
Repayments and other movements
(157)
Balance 31.12.2023
182
15. Investment securities
31.12.2023
31.12.2022
Securities measured at fair value through other comprehensive income
74
Securities measured at amortized cost
1,012,530
1,007,242
Total
1,012,530
1,007,316
Αn analysis of investment securities is provided in the following tables per classification category and per type of security.
a. Securities measured at fair value through other comprehensive income
31.12.2023
31.12.2022
Equity securities
- Non listed
74
Total
-
74
Securities in this category consist of securities of Reoco Cosmos Single Member S.A, Reoco Galaxy II Single Member S.A., Reoco
Galaxy IV Single Member S.A. and Reoco Orion X Single Member S.A.
During 2023, the Company did not dispose any shares included in this category. Change within the year is due to fair value
adjustments.
b. Securities measured at amortized cost
31.12.2032
31.12.2022
Other issuers
- Non listed
1,012,530
1,007,242
Total
1,012,530
1,007,242
The above amount includes subordinated notes issued by Alpha Bank on the 19.4.2021 covered in full by the Company.
The expected credit losses allowance for the investment securities measured at amortized cost amounted to € 2,034 (31.12.2022:
€ 4,406). The carrying amount before impairment of the investment securities amounts to € 1,014,564 (31.12.2022: € 1,011,648).
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
461 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
16. Investments in subsidiaries
31.12.2023
31.12.2022
SUBSIDIARIES
Balance 1.1
6,251,797
6,160,102
Additions
403,841
115,489
Decreases
(294)
(23,794)
Transfer to Assets held for sale
(16,323)
-
Balance 31.12
6,639,021
6,251,797
Additions represent amounts paid for the establishment of new entities, share purchases, participation in share capital increases, purchase
of equity instruments by subsidiaries which are recognised their equity and other capital contributions related to stock option rights and
stock awards.
Decreases represent sales of shares, return of capital, proceeds arising from the liquidation of companies, mergers/absorptions, and
impairments.
Additions in subsidiaries amounting to € 403,841 relate to:
a. Other equity instruments issuance by Alpha Bank of € 400,000:
On February 1st, 2023, the subsidiary Alpha Bank S.A. issued Additional Tier 1 instruments ("AT1 Notes") amounting to € 400,000 to
strengthen its regulatory capital position. In accordance with IAS 32, this instrument was recognized as an equity item in the subsidiary
while interest repayments will be recognized as a dividend subtracted from equity. Regarding the Company, which is also the holder of the
said bond, it recognized the bond as part of the acquisition cost of its investment in the Bank in accordance with the provisions of IFRS 9
and IAS 27
b. Granting of stock option rights of € 670:
In the context of implementation of the stock option plan of the Bank for the employees of the Bank and Group, as detailed in note 37 , the
Company’s acquisition cost of its subsidiaries, Alpha Bank S.A. and Alphalife ΑΕΑΖ increased by a total amount of € 670 which
corresponds to the fair value of the rights granted to employees of the above companies or their subsidiaries considering that the reward
provided by the Company through option rights represents an indirect capital contribution.
c. Stock award plan of € 3,170
In the context of the implementation of the Company's share awards program to the staff of the Bank and its affiliated companies, as
described in detail in note 38, the Company’s acquisition cost of its subsidiary Alpha Bank S.A. increased by the total amount of € 3,170
which corresponds to the fair value of the granted shares on the grant date taking into account the distribution date.
Decreases in subsidiaries amounting to € 294 relate to:
a. Merger
On 28 July 2023 the merger process by way of absorption of the subsidiary company Alpha Insurance Agents Single Member Societe
Anonyme was completed which had a value of € 294. The acquiring company was a 100% subsidiary of the Company, resulting in a
negative goodwill of € 1,152 as the book value of the subsidiary was less than the net assets of the company (note 39).
The table below presents the calculation of the negative goodwill:
28.7.2023
ASSETS
Due from banks
1,365
Due from customers
46
Other assets
108
Total Assets
1,519
LIABILITIES
Liabilities for current income tax and other taxes
54
Other liabilities
19
Total Liabilities
73
Net Assets (a)
1,446
Carrying amount of the investment (b)
294
Negative goodwill (b)-(a)
(1,152)
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
462 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Transfer to Assets held for sale
The transfer due to reclassification to Assets held sale of € 16,323 concerns the transfer of 51% of Alphalife AAEZ's participation in
Assets Held for Sale (note 36).
Key financial information of investments
Subsidiaries
Balance 31.12.2023
1.1 - 31.12.2023
Name
Country
Assets
Equity
Liabilities
Turnover
Profit/(Loss)
before taxes
Company’s
ownership
interest %
31.12.2023
Banks
1. Alpha Bank S.A
Greece
66,779,242
7,374,971
59,404,271
4,012,170
930,557
100.00
Insurance
1. Alphalife A.A.E.Z.
Greece
1,018,503
66,848
951,655
16,845
11,818
99.92
17. Property plant and equipment
Equipment
Total
Balance 1.1.2022
Acquisition Cost
23
23
Accumulated depreciation and impairment losses
(16)
(16)
Net book value 1.1.2022
7
7
Depreciation charge for the year
(2)
(2)
Net book value 31.12.2022
5
5
Balance 31.12.2022
Acquisition Cost
23
23
Accumulated depreciation and impairment losses
(18)
(18)
Net book value 1.1.2023
5
5
Depreciation charge for the year
(1)
(1)
Net book value 31.12.2023
4
4
Balance 31.12.2023
Acquisition Cost
23
23
Accumulated depreciation and impairment losses
(19)
(19)
18. Goodwill and other intangible assets
Software
Goodwill
Total
Balance 1.1.2022
Acquisition cost
440
237
677
Accumulated depreciation and impairment losses
(307)
(307)
Net book value 1.1.2022
133
237
370
Amortization charge for the year
(41)
(41)
Net book value 31.12.2022
92
237
329
Balance 31.12.2022
Acquisition cost
440
237
677
Accumulated depreciation and impairment losses
(348)
(348)
Net book value 1.1.2023
92
237
329
Amortization charge for the year
(41)
(41)
Net book value 31.12.2023
50
237
287
Balance 31.12.2023
Acquisition cost
440
237
677
Accumulated depreciation and impairment losses
(390)
(390)
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
463 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
19. Other assets
31.12.2023
31.12.2022
Tax advances and withholding taxes
16,661
21,540
Prepaid expenses
294
220
Employee advances
9
Accrued income
11,686
8,801
Other
959
97
Total
29,600
30,667
Change Decrease in “Τax advances and withholding taxes” is mainly attributed to the refund from Greek State of the year 2022
income tax return amounting to € 8,317.
“Accrued income” includes a contact asset of an amount of € 7,343 (31.12.2022: € 4,857) which relates to the performance bonus
from the distribution of insurance products based on relevant agreement. More specifically, this amount represents income
recognised from performance obligations satisfied up to 31.12.2023. The Company’s right to the total consideration will become
unconditional 10 years following the date of the signing of the agreement, therefore the consideration amount is variable and
subject to the constraining estimate in accordance with the provisions of IFRS 15. However, considering that in essence there is no
uncertainty with regards to the achievement of the target, it is assessed that the estimate of variable consideration is not
constrained. The most significant change in the balance of contract asset during 2023 is the recognition of commission income from
insurance brokerage fees amounting to € 2,3 mn related to the performance bonus. Moreover, taking into account the credit rating
of the counterparty and the payment history, no impairment loss has been recognised related to the contract asset.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
464 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
LIABILITIES
20. Due to Banks
31.12.2023
31.12.2022
Borrowings
20,246
Total
20,246
-
During 2023, the Company made use of the revolving account agreement with its subsidiary Bank with a credit limit of up to € 50
million for working capital purposes. As at 31.12.2023 the Company had an open balance of € 20 million (note 32).
21. Debt securities in issue and other borrowed funds
i. Subordinated Notes (Lower Tier II, Upper Tier II)
In the context of the Euro Medium Term Note Program amounting to € 15 billion, the Company issued on the 13.2.2020
subordinated notes with a nominal value of € 500 million and maturity date 13.2.2030, with redeemed option from the Company on
13.2.2025, subject to regulatory approval, and with an initially fixed annual interest rate of 4.25% until 13.2.2025 which is adjusted
to a new rate valid from the date of withdrawal until the expiration and is determined based on the five-year swap rate plus margin
4.504%.
On 11.3.2021 the Company before the Hive-down, proceeded to a new issuance of a subordinated debt of nominal value of € 500
million, with maturity date on 11.6.2031, and the possibility of redemption between 11.3.2026 and 11.6.2026 subject to regulatory
approval, and with initially fixed annual interest rate of 5.5% until 11.6.2026, which is adjusted to a new interest rate effective from
the date of cancellation until maturity, which is determined based on the five-year swap rate plus a margin of 5.823%. On 27.4.2022
the full repayment of the subordinated note with indefinite maturity with nominal value of € 0.65 million and a floating rate of 3m
Euribor +1.5% was made.
Balance 1.1.2023
1,028,924
Changes for the period 1.1 - 31.12.2023
Maturities / Repayments
(48,750)
Accrued interests
49,222
Balance 31.12.2023
1,029,396
Detailed information for the abovementioned issuances are provided in the following table:
Currency
Interest Rate
Maturity
Nominal value
31.12.2023
31.12.2022
Alpha Services and Holdings S.A
Euro
4.25%
13.2.2030
500,000
500,000
Alpha Services and Holdings S.A
Euro
5.50%
11.6.2031
500,000
500,000
Total
1,000,000
1,000,000
Total of debt securities in issue and other borrowed funds, not held by the Bank, as at 31.12.2023
1,029,396
The following table presents the changes in debt securities and other borrowing funds by separately disclosing the cash and non-
cash flows.
Cash flows from financing
activities
1.1.2023
Cash Flows
Non cash flows
31.12.2023
New issues,
maturities,
repayments
Accrued interest
Foreign exchange
differences
Fair value
change
Other
Subordinated loans (i)
1,028,924
(48,750)
49,222
1,029,396
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
465 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Cash flows from financing
activities
1.1.2022
Cash Flows
Non cash flows
31.12.2022
New issues,
maturities,
repayments
Accrued interest
Foreign exchange
differences
Fair value
change
Hive down of
banking
sector
Subordinated loans (i)
1,029,096
(49,403)
49,231
1,028,924
Other borrowed funds (i)
15,307
(16,047)
506
234
-
The above cash flows are included in the net cash flows from financing activities in the cash flow statement of the year.
22. Liabilities for current income tax and other taxes
31.12.2023
31.12.2022
Income tax
Other taxes
372
15
Total
372
15
23. Employee defined benefit obligations
Total amounts recognized in the financial statements for defined benefit obligations are presented in the table below:
Balance Sheet-Liabilities
31.12.2023
31.12.2022
Employee's indemnity provision due to retirement in accordance with Law 2112/1920
39
16
Total Liabilities
39
16
Income Statement
Expenses/(Income)
From 1 January to
31.12.2023
31.12.2022
Employee's indemnity provision due to retirement in accordance with Law 2112/1920
23
96
Total
23
96
Balance Sheet and Income Statement amounts are analyzed per fund and type of benefit as follows:
Employee indemnity due to retirement in accordance with Law 2112/1920
The contracts of the regular employees of the Company are indefinite term employee contracts and when terminated, the
provisions of Law 2112/1920 and Law 3198/1955 apply, as amended by Law 4093/2012, which provide a lump sum benefit
payment.
The amounts recognized in the balance sheet are as follows:
31.12.2023
31.12.2022
Present value of defined obligations
39
16
Liability
39
16
The amounts recognized in the income statement are as follows:
From 1 January to
31.12.2023
31.12.2022
Current service cost
5
8
Interest Cost
1
Past service cost
17
Settlement/Curtailment/Termination (gain)/loss
88
Total (included in staff costs)
23
96
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
466 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The movement in the present value of defined obligation is as follows:
2023
2022
Opening Balance
16
30
Current service cost
5
8
Interest Cost
1
Benefits paid
(91)
Past service cost
17
(Gain)/Loss from Settlement/Curtailment/Termination
88
Actuarial (gain)/loss – financial assumptions
1
(4)
Actuarial (gain)/loss – demographic assumptions
1
Actuarial (gain)/loss – experience assumptions
(2)
(15)
Closing Balance
39
16
The amounts recognized in equity during the year are analyzed as follows:
31.12.2023
31.12.2022
Change in liability gain/(loss) due to changes in financial and demographic assumptions
(2)
4
Change in liability gain/(loss) due to experience adjustments
2
15
Total actuarial gain/(loss) recognized directly in Equity
-
19
The movement in the defined obligation liability is as follows:
31.12.2023
31.12.2022
Opening Balance
16
30
Benefits paid
(91)
Loss/(Gain) recognized in income statement
23
96
Loss/(Gain) recognized in equity
(19)
Closing Balance
39
16
Valuation results depend on the actuarial assumptions used in the actuarial studies. The principal actuarial assumptions used for
the abovementioned defined benefit plans are as follows:
31.12.2023
31.12.2022
Discount rate
3.15%
3.79%
Inflation rate
2.15%
2.50%
Future salary growth
2.40%
2.60%
The discount rate was based on the iBoxx Euro Corporate AA+ adjusted to the characteristics of the programs.
The average duration per program is depicted in the table below:
31.12.2023
31.12.2022
Employee's indemnity provision due to retirement in accordance with Law 2112/1920
7.2
8.4
The table below presents the sensitivity analysis of the financial assumptions with regards to the obligation of the above programs:
Percentage variation
in liability (%)
Increase in discount rate by 0.5%
-3.40%
Decrease in discount rate by 0.5%
+3.60%
Increase in future salary growth rate by 0.5%
+3.60%
Decrease in future salary growth rate by 0.5%
-3.40%
Retirement compensation to employees under Law 2112/1920 is an unfunded defined benefit pan.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
467 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
24. Deferred tax liabilities
31.12.2023
31.12.2022
Liabilities
916
614
Total
916
614
Deferred tax liabilities are analyzed as follows:
Balance
1.1.2023
Recognised in
Balance
31.12.2023
Income Statement
Equity
Write-offs and depreciation of fixed assets and leases
(26)
(1)
(27)
Other temporary differences
(588)
(301)
(889)
Total
(614)
(302)
-
(916)
Balance
1.1.2022
Recognised in
Balance
31.12.2022
Income Statement
Equity
Write-offs and depreciation of fixed assets and leases
(24)
(2)
(26)
Other temporary differences
(588)
(588)
Total
(24)
(590)
-
(614)
The Company does not recognise deferred tax assets on the basis that no sufficient future taxable profits are expected in order to
offset the tax losses.
As at 31.12.2023 the deferred tax asset on tax losses that has not been recognized by the Company amounts to € 488,748
(31.12.2022: € 486,805) and is presented in the following table in the following table by maturity year.
Offsetting period
Deferred tax assets
2026
231,627
2027
256,277
2028
844
Total
488,748
In addition, as at 31.12.2023 the Company has not recognized Deferred Tax Assets amounting to € 7,674 (31.12.2022: 7,896)
which stems from the valuation of bonds. This amount mainly concerns valuations of bonds with a maturity of less than one year.
25. Other liabilities
31.12.2023
31.12.2022
Suppliers
1,741
259
Accrued Expenses
8,383
7,569
Liabilities to third parties
55
24
Other
5,040
6,093
Total
15,219
13,945
The balance in “Suppliers” includes liabilities to the subsidiary Alpha Bank S.A. mainly for promotion and distribution of insurance
products.
The balance in “Accrued expenses” includes as at 31.12.2023 an amount of € 3,304 (31.12.2022: € 2,186) relating to the
bancassurance agreement between the Company and the Bank for the distribution of bancassurance products through the Bank’s
network and the achievement of certain perofrmance obligations (performance bonus).
“Other” includes accrued expenses and contigent liabilities relating to the Galaxy transaction.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
468 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
EQUITY
26. Share Capital
Movement from 1.1. to 31.12.2023 (number of shares)
Open Balance as at
1.1.2023
Shares from Share Capital
Increase through the stock
options exercise
Shares from Share
Capital Increase
through cash
Balance as at
31.12.2023
Share Capital paid
on 31.12.2023
Number of ordinary shares
2,348,207,784
3,489,887
2,351,697,671
681,992
The Company’s share capital as of 31.12.2023 amounts to € 681,992 (31.12.2022: € 680,980) divided into 2,351,697,671
(31.12.2022: 2,348,207,784) ordinary, registered shares with voting rights with a nominal value of € 0.29 each.
In the context of Stock Options Plan through which stock options could be granted to key management and employees of the
Company and the Group were exercised:
•
in January 2023 700,783 option rights from the beneficiaries, in accordance with Performance Incentive Program for the years
of 2018, 2019 and 2020. As a result of the above, 700,783 ordinary, registered, voting shares with nominal value of Euro 0.29
were issued and the Share Capital of the Company increased by € 203.
•
in September 2023 2,789,104 option rights from the beneficiaries, in accordance with Performance Incentive Program for the
years of 2020 and 2021. From the above mentioned options 2,648,860 had an exercise price of € 0.30 and 140,244 options
had an exercise price of € 0.29. As a result of the above, 2,789,104 ordinary, registered, voting shares with nominal value of €
0.29 were issued and the Share Capital of the Company increased by € 809.
Treasury Shares
The Ordinary General Meeting of the Shares of 27.7.2023 decided the establishment of a Share Buyback Program for acquisition
by the Company of own existing shares for the purpose of their free distribution to Members of the Management and employees of
the Company and its Affiliated Companies, in the sense of article 32 of Law 4308/2014. In this context, in December 2023 the
company purchased 5,855,794 shares at a cost of € 8,974.
Number of
shares
Carrying amount
Balance as at 1.1.2023
-
Purchase
5,855,794
8,974
Balance as at 31.12.2023
5,855,794
8,974
27. Share premium
Balance as at 1.1.2023
5,259,114
Offsetting of Retained Earnings
(478,810)
Increase in Share Capital - share premium through exercise of stock options
2,644
Balance as at 31.12.2023
4,782,948
Share premium as at 31.12.2023 amounted to € 4,782,948 (31.12.2022: € 5,259,115).
Considering the share capital increase described above from the exercise of the option rights of the Company’s shares, the share
premium increased by € 507 and € 2,110 which is the fair value, determined on the grant date, of the stock options exercised during
the period. In addition, from the exercise of the stock options carried out in September, the share premium increased by € 27 which
resulted from the difference between the exercise price of 2,648,860 rights and the nominal value of the shares.
Finally, the Annual General Meeting of Shareholders held at 27.7.2023 decided on the partial net-off of the share premium reserve
with the Retained Earnings account as at 31.12.2022.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
469 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
28. Special Reserve from Share Capital Decrease
2023
2022
Balance as at 1.1
296,424
6,104,890
Changes for the year 1.1 - 31.12
Offsetting of Reserves with Special Reserve from Share Capital Decrease in accordance with Law 4548/2018
(296,424)
(5,808,466)
Balance as at 31.12
-
296,424
According to art 31 par.2 of Greek Law 4548/2018, share capital decrease is permitted for the formation of special reserve. This
special reserve can be used only for the purpose of its capitalization or for absorbing accumulated losses of the Company. the
Annual General Meeting of Shareholders held at 27.7.2023 decided on the net-off of the special reserve from share capital
decrease with the Retained Earnings account as at 31.12.2022
29. Other equity instruments
Balance 1.1.2023
-
Issuance of AT1 Notes
400,000
Balance 31.12.2023
400,000
On 1 February 2023, the Company issued additional Tier 1 instruments ("AT1 Notes") amounting to € 400,000 in order to
strengthen its regulatory capital position. The bonds are indefinite, with an adjustment clause, a maturity of 5.5 years and a yield of
11.875%.
“AT1 securities” are structured to qualify as Additional Tier 1 instruments in accordance with the applicable capital rules at the
relevant issue date. "AT 1 securities" are redeemable in their entirety, at the choice of the issuer, in case of specific changes in the
tax or regulatory treatment of the securities. Interest on the securities is due and payable only at the sole discretion of the
Company, which may at any time and for any reason cancel (in whole or in part) any interest payment that would otherwise be
payable on any interest payment date.
Based on the above characteristics, the instrument is recognized as an equity item while interest repayments will be recognized as
a dividend deducting equity.
For the aforementioned Notes the Company paid in August 2023 interest amounting to € 23,750 before tax. It should be noted that
in February 2024 the Company paid interest of the same amount before tax.
30. Reserves
Reserves are analyzed as follows:
a. Statutory reserve
2023
2022
Balance as at 1.1
-
420,425
Changes for the year 1.1 - 31.12
Appropriation of reserve
747
Offsetting of Reserves with Statutory reserve
(747)
(420,425)
Balance as at 31.12
-
-
According to art.158 of L.4548/2028, at least one twentieth (1/20) is deducted from the annual net profit for the formation of
regulatory reserve. This requirement seizes once regulatory reserve reaches the one third (1/3) of the share capital. The article
provides that this reserve can be utilized exclusively prior to any dividend distribution in order to offset prior year accumulated
losses.
The Annual General Meeting of Shareholders held at 27.7.2023 approved the formation of statutory reserve of € 747 from the net
profit of the year 2022. In addition, the same General Meeting approved the offsetting of € 747 with Retained Earnings as of
31.12.2022.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
470 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
b. Other reserves
2023
2022
Opening Balance 1.1
788,513
(264)
Changes for the year 1.1 - 31.12
Reclassification
788,777
Appropriation of reserve
1,290
Balance 31.12
789,803
788,513
The Shareholders Ordinary General Meeting of 22.7.2022 decided for the discrete monitoring and transfer of an amount of
€ 788,777 of dividend of subsidiaries of previous years from Retained Earnings to other reserve accounts. The Annual General
Meeting of Shareholders held at 27.7.2023 approved the increase of the intragroup dividends reserve be € 1,290.
c. Reserve valuation for stock options rights to employees
2023
2022
Opening Balance 1.1
3,500
3,083
Changes for the year 1.1 - 31.12
Exercise of rights
(2,700)
(1,597)
Reserve valuation for stock options right to employees
670
2,014
Balance 31.12
1,470
3,500
For further analysis please see note 37.
d. Reserve valuation of share award program to employees
2023
2022
Opening Balance 1.1
-
Changes for the year 1.1 - 31.12
Reserve valuation for share award program to employees
3,170
Balance την 31.12
3,170
-
For further analysis please see note 38.
Total reserves (a+b+c+d)
794,443
792,013
31. Retained earnings
The Annual General Meeting of Shareholders held on 27.7.2023 decided, among other things, not to distribute dividends to the
Shareholders of the Company for the financial year 2022 in accordance with the applicable legal and regulatory framework.
Τhe above Annual General Meeting approved the offsetting of the Retained Loss account as at 31.12.2022 by the amount of €
775,981 in order of the priority, with the Statutory Reserve of € 747, with the Special Reserve of article 31 of Law 4548/2018
amounting to € 296,424 and with the Share premium account of € 478,810.
Taking into account that there are distributable profits for the fiscal year 2023 according to article 159 N.4548/2018, the Board of
Directors intends to propose to the Annual General Meeting of the Shareholders the distribution of dividend, subject to the approval
by the competent regulatory authority.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
471 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
ADDITIONAL INFORMATION
32. Contingent liabilities and commitments
a. Legal issues
According to the demerger deed, the new bank under the name “ Alpha Bank Societe Anonyme “ is replaced as the universal
successor in the Hive-Down of the Banking Division and therefore all pending litigation and related contingent liabilities to the
banking activity were transferred to the new bank.
As of 31.12.2023 there are no claims or pending litigation against the Company that are expected to have a significant effect on the
Company’s Equity or operation.
b. Tax issues
According to art.65A of Law 4174/2013 from the year 2011, the statutory auditors and auditing firms that conduct mandatory audits
of societe anonymes are required to issue an annual tax compliance report regarding the application of the tax provisions in certain
tax areas. Based on art.56 of Law 4410/3.8.2016 tax compliance reports are optional for the years from 1.1.2016 and thereon.
Nevertheless, the intention of Alpha Services and Holdings S.A. is to continue receiving such tax compliance report.
Alpha Services and Holdings S.A. has been audited by the tax authorities for the years up to and including 2010 as well as for the
year 2014. Years 2011 to 2017 are considered as closed, in accordance with the Ministerial Decision 1208/20.12.2017 of the
Independent Public Revenue Authority. For the years from 2011 up to an including 2022 the Company has received tax compliance
report, according to the article 82 of Law 2238/1994 and the article 65A of Law 4174/2013, with no qualification. Tax audit in
connection with the tax compliance report of 2023 is in progress.
Based on Ministerial Decision 1006/5.1.2016 there is no exemption from tax audit by the tax authorities to those entities that have
been tax audited by the independent statutory auditor and they have received an unqualified tax compliance report. Therefore, the
tax authorities may reaudit the tax books.
Additional taxes, interest on late submission and penalties may be imposed by tax authorities, as a result of tax audits for unaudited
tax years, the amount of which cannot be accurately determined.
In December 2022, the European Council adopted the EU Directive 2022/2523 for a global minimum tax that is expected to be
used by individual jurisdictions. The goal of the framework is to reduce the shifting of profit from one jurisdiction to another, in order
to reduce global tax obligations in corporate structures. In March 2022, the OECD released detailed technical guidance on Pillar
Two of the rules.
As at the date of approval of the annual financial statements, the United Kingdom and Luxembourg have already incorporated
these changes into their domestic legislation. The remaining jurisdictions where the Group operates have not enacted legislation to
incorporate these rules of Pillar II into their national law. Therefore, the Group is unable to determine the potential effect of any
future changes to legislation.
Alpha Services and Holdings, as the ultimate parent entity, has already taken every necessary action to assess the potential impact
of those rules on the Group. In particular, it has processed the exercise based on the transitional safe harbor rules and estimates
that there is no significant effect on the Group.
The Company has not calculated Deferred Tax Asset or Deferred Tax Liability as a result of Tax calculation of Pillar II.
c. Off Balance Sheet Commitments
The Company has an open revolving facility with the Bank for an amount up to € 50 mil, with interests rate of EUR3M + 2.50 and 6
months duration for each withdrawal. As at 31.12.2023, the Company has used €20 million from the above mentioned loan facility.
d. Pledged assets
The entity did not have any pledged assets as at 31.12.2023.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
472 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
33. Risk Management
The main financial risks to which the Company is exposed are as follows:
33.1 Credit Risk
The credit risk to which the Company is exposed comes from the following:
DUE FROM BANKS
Exposure to credit institutions relates to bank sight deposits. Since these deposits are readily available, i.e. with short maturities
which exhibit negligible probabilities of default, they were excluded from ECL calculation.
INVESTMENTS IN DEBT SECURITIES
Investments in debt securities relate to securities that are classified into investment security portfolio. If there is a loan relationship
with the counterparty issuer at the time of classification of the security position as investment, the Corporate Credit Policy
procedures apply. These positions are subject to Bank investment limits and issuer’s limits and are monitored on a daily basis. At
each reporting date, a loss allowance for expected credit losses on bonds, which are not measured at fair value through profit or
loss, is recognized. In addition, if the debt securities fall under the definition of purchased or originated credit impaired (POCI)
financial assets, a loss allowance equal to the lifetime expected credit losses is recognized. The loss allowance is based on
expected credit losses related to the probability of default within the next twelve months, unless there has been a significant
increase in credit risk from the date of initial recognition in which case expected credit losses are recognized over the life of the
instrument. Credit risk of investment in debt securities is assessed based on credit ratings of rating agencies or internal credit rating
in case of Greek corporate issuers for which loan exposure exists.
The Company defines as low credit risk all investment grade securities, for which it calculates a credit allowance equal to a 12-
month expected credit loss (Stage 1).
For debt securities, which do not meet the criteria of investment grade, the assessment of the significant increase in credit risk for
which calculation of lifetime expected credit losses is required (Stage 2), is based on the two following conditions (whichever occurs
first):
− Downgrade by at least two notches of the counterparty credit rating between the reporting date and the initial recognition date
− The 12-month PD at reporting date is above 5% in absolute terms and has increased more than 50% compared to the
respective PD existing at initial recognition date
In addition, the Company is monitoring, the change in credit spreads since the initial recognition date. A change in the credit spread
of the issue of more than 500bps since the initial recognition date is a trigger for the review of the debt instrument staging.
Depending on the outcome of the above review the debt instrument will remain at Stage 1 or be allocated at Stage 2, regardless of
whether the primary staging criteria for allocation to Stage 2 have been triggered or not.
DUE FROM CUSTOMERS AND ACCRUED INCOME
The Company recognizes provision for the expected credit losses regarding due from customers. The said provision is estimated
for the lifetime of receivables (no staging) based on the simplified approach as described in IFRS 9. Accrued income includes a
contract asset for which no expected credit loss was calculated taking into account the credit rating of the counterparty and the
payment history.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
473 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
FINANCIAL ASSETS EXPOSURE TO CREDIT RISK
The maximum credit risk exposure per category of financial asset in which the Company is exposed is depicted in the “Net
exposure to credit risk” column.
31.12.2023
Exposure before
impairment
Provision for
impairment losses
Net exposure to
credit risk
A. Credit risk exposure relating to balance sheet items
Due from banks
17,907
17,907
Advances to customers measured at amortised cost
182
182
Securities measured at amortised cost:
- Securities measured at amortised cost (other)
1,014,564
2,034
1,012,530
Accrued income
11,686
11,686
Total amount of balance sheet items exposed to credit risk
1,044,339
2,034
1,042,305
Other balance sheet items not exposed to credit risk
6,673,548
6,673,548
Total assets
7,717,887
2,034
7,715,853
Total credit risk exposure
1,044,339
2,034
1,042,305
31.12.2022
Exposure before
impairment
Provision for
impairment losses
Net exposure to
credit risk
A. Credit risk exposure relating to balance sheet items
Balances with central banks
7,648
7,648
Loans and advances to customers measured at amortised cost
339
339
Securities measured at amortised cost:
Securities measured at amortised cost (Government bonds)
Securities measured at amortised cost (other)
1,011,648
4,406
1,007,242
Accrued income
8,801
8,801
Total amount of balance sheet items exposed to credit risk
1,028,436
4,406
1,024,030
Other balance sheet items not exposed to credit risk
6,274,072
6,274,072
Total Assets
7,302,507
4,406
7,298,101
Total credit risk exposure
1,028,436
4,406
1,024,030
ANALYSIS PER RATING
Other financial instruments subject to credit risk
The following table presents the other financial instruments measured at amortised cost and at fair value through other
comprehensive income as at 31.12.2023 and 31.12.2022 by IFRS 9 Stage and credit rating
31.12.2023
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Due from banks
Lower than BBB-
17,907
17,907
Carrying amount (before allowance for expected credit losses)
17,907
-
-
-
17,907
Allowance for expected credit losses
-
Net carrying amount
17,907
-
-
-
17,907
Securities measured at amortized cost
Lower than BBB-
1,014,564
1,014,564
Carrying amount (before allowance for expected credit losses)
1,014,564
-
-
-
1,014,564
Allowance for expected credit losses
(2,034)
(2,034)
Net carrying amount
1,012,530
-
-
-
1,012,530
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
474 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
31.12.2022
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Due from banks
Lower than BBB-
7,648
7,648
Carrying amount (before allowance for expected credit losses)
7,648
-
-
-
7,648
Allowance for expected credit losses
-
Net carrying amount
7,648
-
-
-
7,648
Securities measured at amortized cost
Lower than BBB-
1,011,648
1,011,648
Carrying amount (before allowance for expected credit losses)
1,011,648
-
-
-
1,011,648
Allowance for expected credit losses
(4,406)
(4,406)
Net carrying amount
1,007,242
-
-
-
1,007,242
Financial instruments measured at fair value through profit or loss
No financial instruments measured at fair value through profit were held by the Company as at 31.12.2023 and 31.12.2022.
ANALYSIS OF FINANCIAL ASSETS PER IFRS 9 STAGE
Due from Banks
The following table presents the classification of Due from Banks per IFRS 9 Stage as of 31.12.2023 and 31.12.2022.
31.12.2023
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Balance 31.12.2023
Carrying amount (before allowance for expected credit losses)
17,907
17,907
Allowance for expected credit losses
-
Net carrying amount 31.12.2023
17,907
-
-
-
17,907
31.12.2022
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Balance 31.12.2022
Carrying amount (before allowance for expected credit losses)
7,648
7,648
Allowance for expected credit losses
Net carrying amount 31.12.2022
7,648
-
-
-
7,648
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
475 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Investment Securities
Investment securities measured at amortized cost
The following table presents the classification of securities per IFRS 9 Stage and issuer’s category as of 31.12.2023 and
31.12.2022:
31.12.2023
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Other securities
Carrying amount (before allowance for expected credit losses)
1,014,564
1,014,564
Allowance for expected credit losses
(2,034)
(2,034)
Net value
1,012,530
-
-
-
1,012,530
Total securities measured at amortized cost
Carrying amount (before allowance for expected credit losses)
1,014,564
-
-
-
1,014,564
Allowance for expected credit losses
(2,034)
-
-
-
(2,034)
Net value
1,012,530
-
-
-
1,012,530
31.12.2022
Stage 1
Stage 2
Stage 3
Purchased or
originated credit
impaired (POCI)
Total
Other securities
Carrying amount (before allowance for expected credit losses)
1,011,648
1,011,648
Allowance for expected credit losses
(4,406)
(4,406)
Net value
1,007,242
-
-
-
1,007,242
Total securities measured at amortized cost
Carrying amount (before allowance for expected credit losses
1,011,648
-
-
-
1,011,648
Allowance for expected credit losses
(4,406)
-
-
-
(4,406)
Net value
1,007,242
-
-
-
1,007,242
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
476 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Reconciliation of financial assets before allowance for expected credit losses per IFRS 9 Stage
The tables below present the movement of the carrying amount before allowance for expected credit losses for Due from banks,
the movement of the fair value of investment securities measured at fair value through other comprehensive income and
investment securities measured at amortized cost including expected credit losses per IFRS 9 Stage.
31.12.2023
Due from banks
Investment securities measured at fair
value through other comprehensive income
Securities measured at amortized cost
Stage1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Stage1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Stage1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Balance
1.1.2023
7,648
-
-
-
7,648
-
-
-
-
-
1,011,6
48
-
-
-
1,011,64
8
Changes
for the year
1.1 -
31.12.2023
Interest on
carrying
amount
before
impairment
-
53,667
53,667
Repayments
and other
movements
10,259
10,259
(50,750)
(50,750)
Balance
31.12.2023
17,907
-
-
-
17,907
1,014,5
65
-
-
-
1,014,56
5
31.12.2022
Due from banks
Investment securities measured at fair value
through other comprehensive income
Securities measured at amortized cost
Stage 1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchas
ed or
originate
d credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Balance
1.1.2022
25,705
-
-
-
25,705
-
-
-
-
-
1,004,7
25
-
-
-
1,004,725
Changes
for the year
1.1 -
31.12.2022
Interest on
carrying
amount
before
impairment
-
-
53,711
53,711
Repayments
and other
movements
(18,057)
(18,057)
-
(46,788)
(46,788)
Balance
31.12.2022
7,648
-
-
-
7,648
-
-
-
-
-
1,011,6
48
-
-
-
1,011,648
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
477 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Reconciliation of allowance for expected credit losses
The tables below present the movement of the allowance for expected credit losses of due from banks, investment, securities
measured at fair value through other comprehensive income and securities measured at amortized cost per IFRS 9 stage.
31.12.2023
Due from banks
Investment securities measured at fair
value through other comprehensive income
Securities measured at amortized cost
Stage 1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchase
d or
originate
d credit
impaired
(POCI)
Total
Balance
1.1.2023
-
-
-
-
-
-
-
-
-
-
4,406
4,406
Changes
for the year
1.1 -
31.12.2023
-
Change in
credit risk
parameters
(2,371)
(2,371)
Allowance
for expected
credit
losses
receivables/
securities
(2,371)
(2,371)
Closing
Balance
31.12.2023
(2,034)
(2,034)
Gain from impairment of debt securities and other securities at amortized cost in 2023, is mainly attributed to the reversal of
expected credit losses of subordinated debt issued by the Bank and owned by the Company, as a result of the credit rate upgrade
of the Bank in 2023.
31.12.2022
Due from banks
Investment securities measured at fair
value through other comprehensive income
Securities measured at amortized cost
Stage 1
Stage 2
Stage 3
Purchased
or
originated
credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchase
d or
originated
credit
impaired
(POCI)
Total
Stage 1
Stage 2
Stage 3
Purchase
d or
originated
credit
impaired
(POCI)
Total
Balance
1.1.2022
-
-
-
-
-
-
-
-
-
-
11,665
11,665
Changes
for the year
1.1 -
31.12.2022
-
-
-
Change in
credit risk
parameters
-
-
(7,259)
(7,259)
Allowance
for expected
credit
losses
receivables/
securities
-
-
(7,259)
(7,259)
Balance
31.12.2022
-
-
-
-
-
-
-
-
-
-
4,406
4,406
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
478 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
33.2 Market risk
Market risk is the risk of losses arising from unfavorable changes in the value or volatility of interest rates, foreign exchange rates,
stock exchange indices, equity prices and commodities.
The company is exposed to market risk, which is the risk of potential loss due to adverse changes in market variables, such as
changes in interest rates and exchange rates.
a. Foreign currency risk
The financial assets and liabilities of the Company are in Euro, therefore the foreign exchange risk is eliminated.
b. Interest Rate Risk
The interest rate risk management framework is determined in accordance with the Asset Liability Risk Management Policy. Based
on this framework, the risk analysis is performed through the Interest Rate Gap Analysis. Particularly, assets and liabilities are
classified in Gaps depending on their reprising date for floating rate items, or maturity date for fixed rate items.
For those assets and liabilities with no maturity date, the distribution of flows is based on models of their behavior analysis. These
models have been validated by the competent Division. Stress interest rate scenarios are carried out on a monthly basis and their
impact on the interest income change through EAR (Earnings at Risk) and Equity Value through EVE (Economic Value of Equity) is
calculated. Corresponding limits have been set for both measures (EaR & EVE) which are monitored on a regular basis.
The following table presents the Interest Rate Repricing Analysis of both Assets and Liabilities, financial and non financial.
31.12.2023
Less than 1
month
1 to 3 months
3 to 6 months
6 to 12
months
1 to 5 years
> 5 years
Noninterest
bearing
Total
ASSETS
Due from Banks
17,907
17,907
Loans and advances to customers
182
182
Investment securities:
- Measured at fair value through
other comprehensive income
-
- Measured at amortized cost
1,012,530
1,012,530
Investments in subsidiaries
6,639,021
6,639,021
Property, plant and equipment
4
4
Goodwill and other intangible
assets
287
287
Other Assets
29,600
29,600
Assets held for sale
16,322
16,322
Total Assets
17,907
182
-
-
1,012,530
-
6,685,234
7,715,853
LIABILITIES
Due to Banks
20,246
20,246
Debt securities in issue and other
borrowed funds
1,029,396
1,029,396
Liabilities for current income tax
and other taxes
372
372
Employee defined benefit
obligations
39
39
Deferred tax liabilities
916
916
Other Liabilities
15,219
15,219
Total Liabilities
-
20,246
-
-
1,029,396
-
16,546
1,066,188
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
479 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
EQUITY
Share capital
681,992
681,992
Share premium
4,782,948
4,782,948
Special Reserve from Share
Capital Decrease
-
Other equity Instruments
400,000
400,000
Reserves
794,443
794,443
Retained earnings
(744)
(744)
Less: Treasury shares
(8,974)
(8,974)
Total Equity
-
-
-
-
-
-
6,649,665
6,649,665
Total Liabilities and Equity
-
20,246
-
-
1,029,396
-
6,666,212
7,715,853
Open Exposure
17,907
(20,064)
(16,866)
19,023
Cumulative Exposure
17,907
(2,157)
(2,157)
(2,157)
(19,023)
(19,023)
-
31.12.2022
Less than 1
month
1 to 3 months
3 to 6 months
6 to 12
months
1 to 5 years
> 5 years
Noninterest
bearing
Total
ASSETS
Due from Banks
7,648
7,648
Loans and advances to customers
339
339
Investment securities:
- Measured at fair value through
other comprehensive income
74
74
- Measured at amortized cost
490,474
516,768
1,007,242
Investments in subsidiaries
6,251,797
6,251,797
Property, plant and equipment
5
5
Goodwill and other intangible
assets
329
329
Other Assets
30,667
30,667
Assets held for sale
Total Assets
7,722
490,813
516,768
-
-
-
6,282,798
7,298,101
LIABILITIES
Debt securities in issue and other
borrowed funds
517,276
511,648
1,028,924
Liabilities for current income tax
and other taxes
15
15
Employee defined benefit
obligations
16
16
Deferred tax liabilities
614
614
Other Liabilities
13,945
13,945
Total Liabilities
-
517,276
511,648
-
-
-
14,590
1,043,514
EQUITY
Share capital
680,980
680,980
Share premium
5,259,114
5,259,114
Special Reserve from Share
Capital Decrease
296,424
296,424
Reserves
792,013
792,013
Retained earnings
(773,944)
(773,944)
Total Equity
-
-
-
-
-
-
6,254,587
6,254,587
Total Liabilities and Equity
-
517,276
511,648
-
-
-
6,269,177
7,298,101
Open Exposure
7,722
(26,463)
5,120
-
-
-
(13,621)
Cumulative Exposure
7,722
(18,741)
(13,621)
(13,621)
(13,621)
(13,621)
From the Interest Rate Gap Analysis and from the application of alternative scenarios regarding the changes in the market interest
rates or the changes in the base interest rates of the Company, the immediate change in the net interest income and equity relating
to securities measured at fair value through other comprehensive income is directly calculated and the respective hedging
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
480 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
instruments. In the Interest Rate Gap Analysis, the variance, up to the point it’s feasible (interest rate equals to zero), is studied,
according to the interest rate curves by currency in force.
It is noted that the sensitivity of the net interest income for the Company is zero as the investment portfolio, Assets and Liabilities
include fixed rate securities.
33.3 Liquidity Risk
Liquidity risk relates to Company’s ability to maintain sufficient funds to cover its planned or extraordinary obligations. Liquidity Risk
comprises both funding liquidity risk and the risk arising from the Company’s failure to recognize or address changes in market
conditions that affect the ability to liquidate assets quickly and with minimal loss in value (market liquidity risk).
For those assets and liabilities with no maturity date, the distribution of flows is based on models of their behavior analysis. These
models have been validated by the competent Division.
Company’s executive and senior management is informed on current liquidity risk exposures on a daily basis, ensuring that the
Company’s liquidity risk profile stays within approved limits. Moreover, management receives on a daily basis a liquidity report,
which presents a detailed analysis of Company’s funding sources and counterbalancing capacity. Among others, for the purpose of
proper management of liquidity risk and in line with supervisory requirements, the Company monitors and manages on a monthly
basis, the amount, quality and concentration of counterbalancing capacity, the cash flows arising from assets and liabilities (inflows,
outflows – maturity ladder) over time, the concentration and cost of funding, the rollover of funding.
According to the Liquidity Gap Analysis, the cash flows arising from balance sheet items are calculated and classified into time
periods in accordance with the contractual maturity date or the estimated maturity date based on a statistical analysis (convention).
Investment portfolios, which may be used to raise liquidity, and they are allocated in the first period under the condition they have
not been used to raise liquidity either through the Central Bank or through interbank repos agreement, are an exception to the
above.
Wholesale funding
Medium term borrowing from international capital markets
The Company’s constant aspiration is to cooperate with international investors who may offer medium term financing through
purchase of securities issued by the Company. For this purpose, the Company retains special financing programs appealing to
international investors and provides adequate coverage of credit needs through international capital markets by planning asset
level needs on an annual basis. However, the Company acknowledges that the demand of these bonds may not be enough to fully
meet the needs in specific time intervals as a result of factors which concern the credit assessment in the domestic and
international economic environment.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
481 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The table below presents the Liquidity Gap Analysis for all Assets and Liabilities.
31.12.2023
< 1 month
1 to 3 months
3 to 6 months
6 to 12 months
> 1 year
Total
ASSETS
Due from Banks
17,907
17,907
Due to customers
182
182
Investment securities:
- Measured at fair value through other comprehensive
income
-
- Measured at amortized cost
1,012,530
1,012,530
Investments in subsidiaries
6,639,021
6,639,021
Property, plant and equipment
4
4
Goodwill and other intangible assets
287
287
Other Assets
29,600
29,600
Assets held for sale
16,322
16,322
Total Assets
17,907
182
-
16,322
7,681,443
7,715,853
LIABILITIES
Due to Banks
20,246
20,246
Debt securities in issue and other borrowed funds
1,029,396
1,029,396
Liabilities for current income tax and other taxes
372
372
Employee defined benefit obligations
39
39
Deferred tax liabilities
27
889
916
Other Liabilities
56
6,820
5,039
3,304
15,219
Total Liabilities
56
6,820
25,657
27
1,033,627
1,066,188
EQUITY
Share capital
681,992
681,992
Share premium
4,782,948
4,782,948
Special Reserve from Share Capital Decrease
-
Other equity Instruments
400,000
400,000
Reserves
794,443
794,443
Retained earnings
(744)
(744)
Less: Treasury shares
(8,974)
(8,974)
Total Equity
-
-
-
-
6,649,666
6,649,665
Total Liabilities and Equity
56
6,820
25,657
27
7,683,293
7,715,853
OPEN LIQUIDITY GAP
17,851
(6,638)
(25,657)
16,295
(1,851)
CUMULATIVE LIQUIDITY GAP
17,851
11,213
(14,444)
1,851
-
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
482 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
31.12.2022
< 1 month
1 to 3 months
3 to 6 months
6 to 12 months
> 1 year
Total
ASSETS
Due from Banks
7,648
7,648
Due to customers
339
339
Investment securities:
-
- Measured at fair value through other comprehensive
income
74
74
- Measured at amortized cost
1,007,242
1,007,242
Investments in subsidiaries
6,251,797
6,251,797
Property, plant and equipment
5
5
Goodwill and other intangible assets
329
329
Other Assets
30,667
30,667
Assets held for sale
-
Total Assets
7,722
339
-
-
7,290,040
7,298,101
LIABILITIES
Debt securities in issue and other borrowed funds
1,028,924
1,028,924
Liabilities for current income tax and other taxes
15
15
Employee defined benefit obligations
16
16
Deferred tax liabilities
26
588
614
Other Liabilities
13,945
13,945
Total Liabilities
-
-
-
41
1,043,473
1,043,514
EQUITY
Share capital
680,980
680,980
Share premium
5,259,114
5,259,114
Special Reserve from Share Capital Decrease
296,424
296,424
Reserves
792,013
792,013
Retained earnings
(773,944)
(773,944)
Total Equity
-
-
-
-
6,254,587
6,254,587
Total Liabilities and Equity
-
-
-
41
7,298,060
7,298,101
OPEN LIQUIDITY GAP
7,722
339
(41)
8,020
CUMULATIVE LIQUIDITY GAP
7,722
8,061
8,061
8,020
31.12.2023
Total Balance
Sheet
Nominal inflows / (outflows)
Total
Less than one
month
1 to 3 months
3 to 6 months
6 to 12 months
More than a
year
Non derivative liabilities
Debt securities in issue and other
borrowed funds
1,029,396
(2,149)
(8,320)
(12,688)
(25,444)
(1,068,611)
(1,117,212)
Other liabilities
15,219
(56)
(6,820)
(5,039)
-
(3,304)
(15,219)
Total
1,044,615
(2,205)
(15,140)
(17,727)
(25,444)
(1,071,915)
(1,132,431)
31.12.2022
Total Balance
Sheet
Nominal inflows / (outflows)
Total
Less than one
month
1 to 3 months
3 to 6 months
6 to 12
months
More than a
year
Nonderivative liabilities
Debt securities in issue and other
borrowed funds
1,028,924
(4,140)
(7,880)
(12,154)
(24,575)
(1,142,231)
(1,190,981)
Other liabilities
13,945
(13,945)
(13,945)
Total
1,042,869
(4,140)
(7,880)
(12,154)
(24,575)
(1,156,176)
(1,204,925)
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
483 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
33.4 Fair value of financial assets and liabilities
Hierarchy of financial instruments that are not measured at fair value
31.12.2023
Level 1
Level 2
Level 3
Total fair value
Total Carrying
amount
Financial Assets
Due from customers
182
182
182
Investment securities:
- Measured at amortized cost
996,214
996,214
1,012,530
Financial liabilities
Debt securities in issue and other borrowed
funds
1,006,399
1,006,399
1,029,396
31.12.2022
Level 1
Level 2
Level 3
Total fair value
Total Carrying
amount
Financial Assets
Due from customers
339
339
339
Investment securities:
- Measured at amortized cost
807,758
807,748
1,007,242
Financial liabilities
Debt securities in issue and other borrowed
funds
423,702
420,030
843,732
1,028,924
The tables above depict the fair value and the carrying amount of those financial instruments that are measured at amortised cost,
per fair value hierarchy.
Level 1 includes securities and debt securities in issue that are traded in active markets.
Level 2 includes securities and debt securities in issue, the fair value of which, is determined based on nonbinding market prices
provided by dealers brokers or through the use of discounted cash flow methodologies such (income approach) using interest rates
and credit spreads which are observable in the market.
The fair value of the remaining financial assets and liabilities which are measured at amortised cost does not differ materially from
their respective book value
Fair value hierarchy financial instruments measured at fair value
As of 31.12.2023 the value of the Company’s financial instruments measured at fair value was nil.
The table below presents, for the comparative period 31.12.2022, the fair value of financial instruments measured at fair value by
fair value hierarchy based on the data used for its determination.
31.12.2022
Level 1
Level 2
Level 3
Total Fair Value
Securities measured at fair value through other comprehensive income:
- Shares
74
74
The Company’s portfolio in securities are classified as Level 3, since their fair value has been determined based on the Company’s
percentage to the issuer’s equity.
The table below sets out the valuation methods used for the determination of Level 3 fair values for the comparative period
31.12.2022
31.12.2022
Total Fair
Value
Fair Value
Valuation Method
Significant Non observable Inputs
Shares measured at fair
value through other
comprehensive income
74
74
Based on the Group's share in equity
Issuer's equity
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
484 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
The Company recognizes the transfer between fair value hierarchy Levels at the end of each reporting period.
A reconciliation for the movement of financial assets measured at fair value and classified at Level 3 is depicted below:
31.12.2023
Assets
Securities measured
at fair value through
other comprehensive
income
Securities measured
at fair value through
profit or loss
Loans measured at
fair value through
profit or loss
Derivative financial
assets
Other receivables
measured at fair value
through profit or loss
Opening Balance 1.1.2023
74
-
-
-
-
Total gain/(loss) recognized in
Equity Retained earnings
(74)
Balance 31.12.2023
-
-
-
-
-
31.12.2022
Assets
Securities measured
at fair value through
other comprehensive
income
Securities measured
at fair value through
profit or loss
Loans measured at
fair value through
profit or loss
Derivative financial
assets
Other receivables
measured at fair value
through profit or loss
Opening Balance 1.1.2022
133
22,537
-
-
-
Total gain/(loss) recognized in
Income Statement
7,810
- Net interest income
473
- Gains less losses on financial
transactions
7,338
Total gain/(loss) recognized in
Equity Retained earnings
(59)
Purchases / Disbursements/
Issues
70,613
Sales
(92,299)
Repayments
(8,662)
Balance 31.12.2022
74
-
-
-
-
Sensitivity analysis for Level 3 financial instruments as of 31.12.2023 and 31.12.2022 does not provide significant measurable
results as the valuation is perfomed on the issuer’s equity. It is also noted that there are no correlation between the non observable
data that could significantly impact the fair value measurement.
34. Related party transactions
The Company enters into a number of transactions with related parties in the normal course of business. These transactions are
performed at arm’s length terms and are approved by the Company’s competent bodies.
a. The outstanding balances and transactions between the Company and the active key Management personnel, consisting of
members of the Board of Directors and the Executive Committee, their close family members and the entities controlled by them
as at 31.12.2023 and 31.12.2022 are as follows:
31.12.2023
31.12.2022
Liabilities
Debt securities in issue and other borred funds
3,970
3,298
Total
3,970
3,298
The following table presents the results of the transactions with the related parties:
From 1 January to
31.12.2023
31.12.2022
Expenses
Interest expense and similar charges
179
151
Total
179
151
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
485 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
It is noted that in accordance with the Remuneration Policy, the members of the Company’s Board of Directors, as approved by the
General Meeting of Shareholders on 22.7.2021, given that the composition of the Company’s Board of Directors is the same as the
one of the Board of Directors of the 100% subsidiary Alpha Bank S.A. the remuneration of the members of the Board of Directors
will be paid, in accordance with the above, by one company and in specific by Alpha Bank S.A.
b. The outstanding balances with the Company’s associates, and joint ventures as well as the results related to these transactions
are as follows:
i. Subsidiaries
31.12.2023
31.12.2022
Assets
Due from banks
17,907
7,648
Due from customers
110
238
Investment securities measured at amortized cost
1,012,530
1,007,242
Other Assets
2,424
2,390
Total
1,032,971
1,017,518
Liabilities
Due to banks
20,246
Other liabilities
8,067
2,236
Total
28,313
2,236
From 1 January to
31.12.2023
31.12.2022
Income
Interest and similar income
53,667
50,746
Fee and commission income
9,173
7,478
Dividend income
24,150
1,290
Other income
338
332
Total
87,328
59,846
Expenses
Interest expense and similar charges
563
329
Commission expense
19,443
20,123
General administrative expenses
1,056
1,103
Impairment losses and provisions to cover credit risk
(2,371)
(7,259)
Total
18,690
14,296
In February 2023, the Company’s subsidiary, Alpha Bank S.A. issued AT1 Notes amounting to € 400,000 that were covered in full
by the Company. The Company recognised the purchase of the AT1 Notes as part of the acquisition cost of its investment in the
Bank. As a result from the above mentioned instruments the Company received interest during the year of € 24,150.
ii. Associates
31.12.2023
31.12.2022
Assets
Due from customers
28
19
Total
28
19
From 1 January to
31.12.2023
31.12.2022
Income
Other income
45
51
Total
45
51
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
486 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
iii. Joint Ventures
31.12.2023
31.12.2022
Assets
Due from customers
40
68
Total
40
68
From 1 January to
31.12.2023
31.12.2022
Income
Other income
96
99
Total
96
99
c. The Hellenic Financial Stability Fund (HFSF) exerted significant influence on the Company in the context of Law 3864/2010 and
based to Relationship Framework Agreement (“RFA”) signed on 23.11.2015, which replaced the previous one signed in 2013,
HFSF had participation in the Board of Directors and other significant Committees of the Bank. Therefore, according to IAS 24,
HFSF and its related entities were considered related parties for the Company. On 13.11.2023 HFSF fully disinvested from the
Company and is not longer considered a related party.
No outstanding balances existed as at 31.12.2023 and 31.12.2022 and no related transactions occurred during 2023 and 2022.
d. TEA Group Alpha Services and Holdings, founded in March 2023, is a post-employment benefit plan for the benefit of the
employees of the Group of Alpha Services and Holdings, with a salaried mandate relationship or with a dependent work relationship
of indefinite duration.
From 1 January to
31.12.2023
31.12.2022
Expenses
Staff costs and expenses
39
Total
39
-
35. Auditors’ fees
Total fees of “Deloitte Certified Public Accountants S.A.”, statutory auditor of the Company and member of Deloitte Touche
Tohmatsu Limited («DTTL»), as well as of the remaining firms of DTTL and their respective partners are analyzed below, in
accordance with the provisions of paragraph 2 and 32, article 29, of Law 4308/2014.
From 1 January to
31.12.2023
31.12.2022
Statutory audit of the annual accounts*
263
188
Issuance of tax certificate
58
57
Other fees for non audit service
343
374
Total
664
619
*In the fee concerning the statutory audit of the annual financial statements, are included also other related expenses
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
487 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
36. Assets held for sale
31.12.2023
31.12.2022
Investment in subsidiaries
16,322
Total
16,322
-
The agreement signed with Unicredit S.p.A (note 39) includes, among others, the sale of 51% of the Company’s subsidiary
AlphaLife Insurance Company, thus the Company classified the 51% of its investment in the subsidiary in assets held for sale. The
completion of the said transaction, which is expected within 2024, is subject to the prior completion of the due diligence process,
the receipt of the relevant corporate approvals and the required regulatory approvals and consents.
The carrying amount of 51% of the Company's participation in AlphaLife Insurance Company amounts to € 16,322 as of
31.12.2023, while there was no result from the valuation at the lower value between carrying amount and fair value less sales
costs. The fair value determination was based on the investor's price.
The above transaction was approved by the Board of Directors of the Company on 22.10.2023.
37. Awarding of stock options to employees
The Annual General Meeting of Shareholders of 31.7.2020 approved the establishment and implementation of a five year plan
which provides the right to acquire newly – issued shares (Stock Options Plan) by awarding of stock options to management and
employees of the Bank and its Group companies. The plan refers to period 2020 – 2024, and according to that the beneficiaries
may exercise their option to acquire each new share with an exercise price equal to the nominal value of the share. The General
Meeting also approved the assignment to the Board of Directors of the responsibility to determine the beneficiaries, the terms of
options’ awarding, as well as any other term and condition related to the plan, in accordance with the applicable legal and
regulatory framework and Company’s policies. Following the exercise of the stock options, the New Shares are subject to a twelve
(12) months retention period.
The Board of Directors of the Company, at its meeting on 30.12.2020 approved the Plan’s Regulation. The Board of Directors at the
meetings held on 16.12.2021 and 21.7.2021 awarded stock options to employees in the context of this Performance Incentive
Program for the years 2020 and 2021.
According to the terms of the Program, within the first year from the grant date, the beneficiaries may exercise 60% of their total
options while, for the options granted until 31.12.2021, for each year that follows they can exercise 13.3% of total options for the
next three years, while for the options granted in July 2022, for each year that follows they can exercise 10% of the totals options
for the next four years. The options are exercised in January or September.
Non exercised options expire. Also, in the event that one of the beneficiaries ceases to be an employee or executive of the Group
(with some exceptions such as due to retirement or working inability) they cease to have the option to purchase shares. It is also
noted that in the context of the Performance Incentive Program for the year 2020, 3,612,094 stock options were awarded to Senior
Executives, the exercise of which was subject to the deferral condition of the amendment or repeal of the provisions for the
prohibition of additional remuneration, introduced pursuant to article 10 par. 3 of the Law on the Hellenic Financial Stability Fund
(HFSF) and which should have entered into force, within a period of two (2) years, beginning on January 15, 2022 and ending on
January 15, 2024.
Τhe Board of Directors in its 31.8.2023 meeting found the satisfaction of the deferral condition and the Senior Executives exercised
2,648,860 options at the exercise price of € 0.30 in September 2023.
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
488 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
Changes in the number of existing stock options for the years 2022 and 2023 are presented in the tables below:
Number of
options
Weighted
average exercise
price
Balance 1.1.2022
6,802,236
0.30
Changes for the year 1.1 – 31.12.2022
Stock Options awarded during the year
1,402,545
0.30
Stock Options exercised during the year
(2,226,687)
0.296
Stock Options expired during the year
(151,316)
0.297
Balance 31.12.2022
5,826,778
0.296
Company’s share price at the time options were exercised in January 2022 and in September 2022 was € 0.68 and € 0.86
respectively.
Number of
options
Weighted
average exercise
price
Balance 1.1.2023
5,826,778
0.296
Changes for the year 1.1 – 31.12.2023
Stock Options exercised during the year
(3,489,887)
0.298
Stock Options expired during the year
(26,870)
0.290
Balance 31.12.2023
2,310,021
0.294
Company’s share price at the time options were exercised in January 2023 and in September 2023 was € 1.14 and € 1.38
respectively.
The average duration of the active stock optionsis 8.3 months (31.12.2022: 14.3 months).
As a result of the stock options award, in 2023 an amount of € 670 (2022: € 2,014), was recognized in an equity reserve against a
debit in the cost of investments in subsidiaries of the Company, since the beneficiaries provide their services to these subsidiaries.
Fair value of stock options
For options awarded on 29.7.2022 with exercise date September 2022, the fair value was determined as the difference between
the share price as of 29.7.2022, which is the grant date, and the exercise price.
For the remaining options the fair value was determined by using the Black & Scholes valuation model. The most significant inputs
of the model, as presented in the below table, are the share price, the exercise price, the volatility of the share price and the
remaining period until expiration. Historical volatility has been used as volatility, i.e. the standard deviation of the logarithmic
changes of the daily share price, for a period equal to the remaining duration of each option.
Options under the Performance Incentive
Program for the year 2021 which were granted
in 2022
Average weighted value
0.60
Expected volatility %
58.40%
Expected duration (in years)
2.5
Weighted average share price
0.865
Exercise price
0.30
Expected dividends
No risk interest rate
1.15%
Due to the reduction of the nominal value of the share by € 0.01 following the decision of the Ordinary General Meeting of
Shareholders of 22.7.2022, from 9.8.2022 the exercise price of active options (excluding the options awarded to the Senior
Executives) was reduced from € 0.30 to € 0.29. The incremental fair value recognised in the previous year in the equity reserve due
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
489 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
to the decrease in the excerise price was equal to € 61. The incremental fair value of the options was calculated as the difference
between the fair values between the old and new exercise price on modification date, using the same methodology and
parameters, as described above.
38. Stock awards to employees
The Ordinary General Meeting of Shareholders dated July 27, 2023 decided on the implementation, pursuant to article 114of Law
4548/2018, of a four year Stock Awards Plan for the free distribution of own common, dematerialized shares, with voting rights to
Members of the Management Team and other Employees of the Company, including those providing services on a permanent
basis pursuant to article 114 par. 1 of Law 4548/2018, and its Affiliated Companies, within the meaning of article 32 of Law
4308/2014.
The Ordinary General Meeting authorized the Board of Directors to determine the specific terms and conditions of the Stock Award
Plan and the Beneficiaries of each cycle of the Plan, following a recommendation by the Remuneration Committee, to amend,
subject to the above, any provisions of the Stock Award Plan and to proceed with all necessary actions for the Stock Award Plan’s
implementation, in accordance with the applicable remuneration policies and all Applicable Laws and Regulations.
The maximum amount of Company treasury shares that can be distributed in the duration of the Plan is 35,000,000 shares.
According to the terms, the Plan has a four year duration (2023-2027). For the Senior Leadership Team, at the end of the initial
vesting period, 40% of the total Shares awarded to them will be registered in their portion and the remaining 60% will be registered
in annual equal installments for the following five (5) years. For the beneficiaries, other than the Senior Leadership Team, at the end
of the initial vesting period, 60% of the total hares awarded to them will be registered in their portion and the remaining 40% will be
registered in annual equal installments for the following four (4) years. Beneficiaries must be Employees as at the registration date.
Finally, following the registration of the shares, there is a lock-up period for one (1) year, with the exception of the first instalment of
shares which vested and registered to the beneficiaries accounts in January 2024, for which lock-up period lapses in September
2024.
The Board of Directors of the Company held on 1.9.2023 approved the granting of a total of 4,611,595 stock awards. The grant
date was 21.11.2023, while the first vesting period expires in January 2024 and the last in September 2028.
The weighted average fair value of the 4,611,595 shares at the grant date is € 1.5852.
The fair value of the stock awards for each of the registration dates was based on the closing share price at the grant date and the
respective risk free rate. No dividend distribution has been assumed in the fair value of the stock awards.
From the implementation of the above Plan, for the year 2023 an amount of € 3,170, was recognized in an equity reserve against a
debit in the cost of investments in subsidiaries of the Company, since the beneficiaries provide their services to these subsidiaries.
39. Corporate events
•
At the meeting of the Board of Directors of the Company held on 30.3.2023, it was decided to initiate the merger process of the
Company ("Absorber") and its 100% Subsidiary "ALPHA INSURANCE AGENCIES SINGLE MEMBER SOCIETE ANONYME"
(hereinafter the "Absorbed Company") by absorption of the latter by the former. Also, according to the same decision, 31
December 2022 was set as the date of the transformation balance sheet of the Absorbed Company. The Merger resulted in the
transfer of all assets and liabilities of the Absorbed Company to the Acquiring Company. The transaction was completed in
28.7.2023.
•
In 28.7.2023 the Company announced the establishment of a Share Buyback Program (for the acquisition by the Company (or
any of its Subsidiaries) of own existing common, registered, dematerialized shares, with voting rights, in a price range
between the current nominal value of the share i.e. currently € 0.29 (minimum price) and € 3.00 (maximum price) per share,
for a period of 24 months starting from the day immediately after the day of its approval by the Ordinary General Meeting. The
maximum number of shares that may be acquired under the Share Buyback Program amounts to 35,000,000 shares, a
number corresponding to up to 1.5% of the Company’s paid-in share capital at the time of the announcement. It is noted that
the cost for the acquisition of own shares under the Share Buyback Program during the first twelve (12) months was not
expected not to exceed € 10,000. The Company commenced the buy back on 13.12.2023 and completed it on 22.12.2023. In
total, the Company purchased 5,855,794 own shares, at a total cost € 8,974.
•
On 23.10.2023 the Group, parent of which is the Company, and Unicredit S.p.A announced their agreement to achieve a
strategic partnership through the completion of the following individual transactions:
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
490 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
• The merger of their subsidiary banks in Romania. Upon completion of the above transaction, which is expected within
2024 and is subject to the prior completion of the due diligence process, the receipt of the relevant corporate approvals
and the required regulatory approvals and consents, the Group will retain a 9.9% stake in new shape.
• The acquisition by Unicredit of 51% of the subsidiary Alpha Life and the distribution of Unicredit onemarkets mutual funds
through the Bank's network. The completion of the said transaction, which is expected within 2024, is subject to the prior
completion of the due diligence process, the receipt of the relevant corporate approvals and the required regulatory
approvals and consents.
• The acquisition by Unicredit of all of the shares held by the Financial Stability Fund in Alpha Services and Holdings,
amounting to 9%.
As of 13.11.2023 Unicredit had acquired by a) virtue of a Shares Sale and Purchase Agreement with the Hellenic Financial
Stability Fund signed on 12.11.2023 211,138,299 shares and b) an additional on-market acquisition of 15,000,000 shares. As a
result Unicredit holds directly 226,138,299 voting rights, which correspond to 9.6159% of the total voting rights of the Company.
Following the above, the Hellenic Financial Stability Fund does not longer hold any voting rights on the Company.
40. Restatement of financial statements
In the context of improving the presentation of Income Statement, the Company decided in 2023, the distinct presentation of the
following cptions:
• Impairment losses on fixed assets and equity investments
•
Gains/ (losses) on disposal of fixed assets and equity investments
•
Expenses related to credit risk management
It has been evaluated that by using the amended presentation, the structure of the Income Statement is improved, and additional
information is provided regarding the results derived from specific activities that were previously being included in different captions
of the Income Statement.
As a result of the above changes, certain figures of the Income Statement were reclassified, as presented in the following table:
From 1 January to 31.12.2022
Published
amounts
Reclassification
Reclassified
amounts
Interest and similar income
54,930
54,930
Interest expense and similar charges
(50,125)
(50,125)
Net interest income based on the effective interest rate
4,805
-
4,805
Fee and commission income
26,341
26,341
Commission expense
(20,124)
(20,124)
Net fee and commission income
6,217
-
6,217
Dividend income
1,290
1,290
Gains less losses on derecognition of financial assets measured at amortised cost
(10)
(10)
Gains less losses on financial transactions
6,905
198
7,103
Other income
502
502
Total income
19,709
198
19,907
Staff costs
(887)
(887)
General administrative expenses
(5,645)
(5,646)
Depreciation and amortization
(43)
(43)
Total expenses
(6,576)
-
6,576
Impairment losses, provisions to cover credit risk
6,591
664
7,255
Expenses relating to credit risk management
(664)
(664)
Impairment losses on fixed assets and equity investments
(290)
(290)
Gains/(Losses) on disposal of fixed assets and equity investments
92
92
Profit/(loss) before income tax
19,724
-
19,724
Income tax
(4,778)
(4,778)
Profit/(loss) for the year
14,946
-
14,946
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
491 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
41. Strategic Plan
Alpha Services and Holding Group, in which the Company is the Parent, unveiled on June 2023 its 2023-2025 strategy.
Τhe new strategic priorities of the Group focus on growing earnings at an average annualized pace of approximately 20% for the
period up to 2025, through favorable dynamics around net interest income, further supported by macro tailwinds which will continue
to drive revenues, while meticulous cost management will provide a buffer against inflationary pressures.
Furthermore, the Group is aiming at maintaining balance sheet resilience and capital generation and distribution. The above are
based upon the successful implementation of transformation plan and the capitalization of the unique strengths of the Group.
Clearly defined strategic pillars will drive profitability across the Group’s business units:
a) Increase core revenues in retail banking, enhance productivity through automation and migrate core offering to digital
channels, reducing Cost to Income ratio
b) adapt offering to attract a wider customer base across private banking and other selected clients while investing in technology
to modernize service model,
c) Reinforce position in wholesale lending and ensure adequate returns for capital while growing fees and continuing to refine
operating model.
d) Improve profitability in International by accelerating lending momentum through digital channels, capitalizing on strengths in
payments and wealth to grow fees, transform operations and increase productivity,
e) Continue to selectively grow lending book while maintaining strong levels of liquidity. The Bank intends to further reduce its
Group NPE ratio while improving the coverage ratio (within a condensed Cost of Risk ratio) and to maintain a Loan-to-Deposit
ratio below 80% across the duration of the plan,
f) Scale-up sustainable finance strategy to meet full market potential and deliver on firm ESG commitments. Incorporate ESG
criteria in remuneration and risk-management framework and fully integrate sustainable finance strategy across business and
operating model.
During the period of strategic plan, the Bank will focus on the following three financial priorities:
Increase of profitability
− Significant business profitability improvement across Business units, and re-allocation of capital from NPA unit
− Revenues increase on the back of strong NII performance, largely attributed to NII growth driven by volume expansion and
favorable rates.
− Cost management limiting inflation impact, and OpEx reduction through specific levers
− Revenue’s boost and costs reduction to improve the Group’s cost-income ratio
Maitain Balance sheet resilience
− Diversified and resilient balance sheet, with liquid assets
− Structural NPE reduction through organic and inorganic levers, lowering NPE ratio and improving coverage while further de-
escalating cost of risk
− Diversified, granular and sticky deposit base
Capital generation and distribution
− Healthy capital generation on the back of strong returns
− Resulting fully loaded capital ratios significantly higher than management target of 13%
− Restarting dividend distribution from 2023 profits, subject to regulatory approval
42. Events after the balance sheet date
•
On 11.1.2024, the Company distributed to 56 beneficiaries of (i) the Performance Incentive Program and (ii) the Retention Plan
for 2023, 1,890,504 own, common registered with voting rights shares of the Company. The shares were distributed to the
beneficiaries free of charge and through over-the-counter transactions. Following the above distribution, the Company holds
directly, 3,965,290 own shares.
•
In the context of the stock option plan for the years 2019 and 2020, during the exercising period of the stock options and in
specific during the period 2.1.2024 until 15.1.2024, 1,142,026 stock options were exercised by the holders for the acquisition of
common, nominal shares of the Company of the same number with a nominal value of € 0.29 each and an exercise price of
FINANCIAL STATEMENTS OF ALPHA SERVICES AND HOLDINGS S.A. AS AT 31.12.2023
492 | ANNUAL FINANCIAL REPORT
The amounts are presented in thousands of Euro unless otherwise indicated
€ 0.29 corresponding to 660,418 stοck options and an exercise price of € 0.30 corresponding to 481,608 stock options . The
purchase amount of the above shares was paid in cash and amounted to a total of € 336. On 7.2.2024 the share capital
increase was registered in General Electronic Commercial Registry’s (GEMI) while on 13.2.2023 the above 1,142,026 new
common, registered shares of the Company) started trading on the Stock Exchange (ASE). It is noted that, following the above
increase, the share capital of the Company amounts to € 682,324, divided into 2,352,839,697 common, nominal, voting shares
with a nominal value of € 0.29 each.
Athens, 6 March 2024
THE CHAIRMAN
OF THE BOARD OF
DIRECTORS
THE CHIEF EXECUTIVE
OFFICER
THE CHIEF FINANCIAL
OFFICER
THE CHIEF OF
STATUTORY REPORTING
AND TAX
VASILEIOS T. RAPANOS
ID No AΙ 666242
VASSILIOS E. PSALTIS
ID No AΙ 666591
LAZAROS A.
PAPAGARYFALLOU
ID No AK 093634
MARIANA D. ANTONIOU
ID No Χ 694507
493 | ANNUAL FINANCIAL REPORT
Appendix of the Board of Directors’ Annual
Management Report
According to European Securities and Markets Authority (ESMA) guidelines in relation to Alternative Performance Measures (APMs),
not defined under IFRS, which were published in October 2015 and were applicable from 3 July 2016, in the following sections are
disclosed the definitions and the calculations of the related (APMs), as included in the Board of Directors’ Annual Management
Report for year 2023.
As described in the accounting policies section, the financial statements for the year 1.1 - 31.12.2023 have been prepared in
accordance with International Financial Reporting Standards (IFRS), as adopted by the European Union, in accordance with
Regulation 1606/2002 of the European Parliament and the Council of the European Union on 19 July 2002.
Alternative Performance Measures, include or exclude amounts which are not defined under IFRS, aiming at consistency and
comparability among financial periods or years and provision of information regarding non-recurring events. However, the presented
measures not defined under IFRS are not considered as substitute for IFRS measures.
A. Loans to deposits ratio
(Amounts in millions of Euro)
Alternative
Performance
Measure
Definition
Calculation
31.12.2023
31.12.2022
Loans to
deposits ratio
The indicator reflects the relationship of
loans and advances to customers with
the amounts due to customers
Numerator
+
Loans and
advances to
customers
36,161
38,748
Denominator
+
Due to
Customers
48,449
50,761
Ratio
=
74.6%
76.3%
494 | ANNUAL FINANCIAL REPORT
B.
Non Performing Exposures
(Amounts in millions of Euro)
Alternative
Performance
Measure
Definition
Calculation
31.12.2023
31.12.2022
NPEs
Νon-performing exposures are
defined according to EBA on
forbearance and Non-Performing
Exposures
Εxposures that satisfy either or both of the
following criteria: a) material exposures which
are more than 90 days past-due b)The debtor is
assessed as unlikely to pay its credit obligations
in full without realisation of collateral, regardless
of the existence of any past-due amount or of
the number of days past due.
2,240
3,116
C.
Non Performing Exposures Ratio
(Amounts in millions of Euro)
Alternative
Performance
Measure
Definition
Calculation
31.12.2023
31.12.2022
NPE Ratio
NPEs divided by Gross Loans at
the end of the reference period.
Numerator
+
Νon-performing
exposures are
defined
according to
EBA ITS on
forbearance and
Non-Performing
Exposures
2,240
3,116
Denominator
+
Gross Loans at
the end of the
reference period.
37,072
39,922
Ratio
=
6.0%
7.8%
495 | ANNUAL FINANCIAL REPORT
D. HQLA to total Deposits ratio
(Amounts in millions of Euro)
Alternative
Performance
Measure
Definition
Calculation
31.12.2023
31.12.2022
HQLA
High Quality Liquid Assets to total
Deposits ratio
Numerator
+
As defined in
calculation of LCR
ratio (Liquidity
Coverage Ratio)
according to Capital
Requirements
Regulation|2019|876
15,061
12,413
Denominator
+
Deposits for
regulatory purposes
48,465
50,263
Ratio
=
31.1%
24.7%
E.
Underlying Cost of Risk
Alternative
Performance
Measure
Definition
Calculation
31.12.2023
31.12.2022
Underlying Cost of
Risk
Impairment losses and provisions to
cover credit risk excluding the impact of
NPE transactions
Impairment losses and provisions to cover
credit risk excluding impairment losses of
Euro 162 million for 2023 and Euro 272
million for 2022 for the NPEs transactions
218
204
496 | ANNUAL FINANCIAL REPORT
F.
Normalized results after income tax
Normalization includes a set of non-recurring adjustments to the reported results for items which may be related to the
transformation performed by the Group or may not be related to the normal course of business operations or are non-recurring in
nature and distort the reported earnings of the business.
The purpose of normalization is to eliminate such one-off results and provide historical information that enables reliable
comparisons and forecasting.
The main areas of adjustments to the accounting results in order to derive the normalized results are mentioned below:
1. Transformation related events
a. Transformation Costs and related Expenses
b. Expenses and Gains/Losses due to Non-Core Assets’ Divestiture
c. Expenses/Gains/Losses as a result of NPE/NPA exposures transactions’
2. Other non-recurring related events
a. Expenses/Losses due to non-anticipated operational risk
b. Expenses/Losses due to non-anticipated legal disputes
c. Expenses/Gains/Losses due to short term effect of non-anticipated and extraordinary events with significant
economic impact
d. Nonrecurring human resources/social security related benefits/expenses
e. Impairment expenses related to owned used assets and property obtained from auctions and other property
held for sale
g. Initial (one off) impact from the adoption of new or amended IFRS
h. Tax related one-off expenses and gains/losses
3. Income Taxes Applied on the aforementioned transactions.
The normalized results after income tax for year 2023 are presented after the exclusion of the following:
•
Gains less losses on financial transactions that mainly relate to the valuation earn-out of Cepal of the amount of Euro 18
million;
•
Gains/(losses) on derecognition of financial assets measured at amortized cost that relate to loss from the sale of the
project Cell (Euro 1 million) and Hermes (Euro 1 million);
•
Impairment losses and provisions to cover credit risk and related expenses of loan portfolios of projects Solar, Leasing,
Sky, Gaia, Avramar, Hermes;
•
Impairment losses on fixed assets and equity investments mainly relating to Euro 8 million impairments for real estate
assets that were included in the transactions of projects Sky and Skyline
•
Gains/ (Losses) on disposal of fixed assets and equity instruments relating to the sale of the project Sky (loss of Euro 4
million), of properties under the perimeter of project Skyline (loss of Euro 2 million) and of the properties to third parties
that relate to the project skyline as also gain from sale of fixed assets (Euro 7 million);
•
Provisions and transformation costs mainly include expenses of Euro 39 million in relation to a new Voluntary Separation
Scheme (VSS) and a Targeted Separation Scheme, as well as Euro 12 million contribution for financial support of areas
affected by the flooding in Thessaly in 2023
•
Income Tax related to the above excluded results;
•
Net profit/(loss) from discontinued operations after income tax include impairment losses of intangible relating to the sale
of Alpha Bank Romania.
497 | ANNUAL FINANCIAL REPORT
Normalized results for 1.1.2023-31.12.2023 after income tax (amounts in million)
Amounts as presented in the
Consolidated Income Statement
Excluded
results
Normalized
Results
Gains less losses on financial transactions
71
16
55
Gains/(losses) on derecognition of financial assets measured at amortized cost
(17)
(2)
(15)
Total Income (after excluding Gains less losses on derecognition of financial
assets measured at amortised cost and Gains less losses on financial
transactions)
2,070
-
2,070
Total expenses before impairment losses and provisions to cover credit risk,
impairment losses on fixed assets and equity investments, provisions and
transformation costs
(817)
(817)
Impairment losses and provisions to cover credit risk and related expenses
(467)
(162)
(306)
Impairment losses on fixed assets and equity investments
(19)
(8)
(11)
Gains/(Losses) on disposal of fixed assets and equity investments
3
1
2
Provisions and transformation costs
(50)
(48)
(2)
Net profit/(loss) from continuing operations before income tax
773
(203)
979
Income Tax
(233)
46
(279)
Net profit/(loss) from discontinued operations after income tax
71
(12)
83
Net profit/(loss) for the period
611
(169)
780
The normalized results after income tax for year 2022 are presented after the exclusion of the following:
•
Gains less losses on financial transactions from trading profit of derivatives of Euro 142 million and from losses from project
Neptune of the amount of Euro 6 million;
•
Gains/(losses) on derecognition of financial assets measured at amortized cost of Euro 4 million related to loss from the
finalization of the Orbit transaction;
•
Impairment losses and provisions to cover credit risk of € 300 million mainly due to a) impairments of loan portfolios (Leasing,
Solar, Hermes, Light, Sky) that were transferred to the held for sale category amounting to Euro 273 million and b)
impairments of loan portfolios due to an update of the macroeconomic outlook as consequence of the invasion in Ukraine and
the energy crisis amounting to € 28 million;
•
Impairment losses on fixed assets and equity investments resulting mainly from impairments of real estate that are part of
the perimeter of the Skyline, Sky and Startrek transactions of Euro 65 million;
•
Gain /(losses) on fixed assets and equity investments mainly due to profits from the sale of the Bank's merchant acquiring
business unit amounting to Euro 298 million;
•
Provisions and transformation costs include mainly provision of costs for court cases amounting to € 13 million,
transformation costs of the amount of € 9 million, income relating to non-anticipated Operational Risk events of the amount
of € 6 million as well as income from sickness/maternity subsidy of previous years amounting to € 4 million and provisions
relating to project Sky of Euro 25 million;
•
Income tax of € 74 million related to the above excluded results;
•
Results from discontinued activities amounting to Euro 17 million relating to the subsidiary company Alpha Bank Albania
SHA.
498 | ANNUAL FINANCIAL REPORT
Normalized results for 1.1.2022-31.12.2022 after income tax (amounts in million)
Amounts as presented in
the Consolidated Income
Statement
Excluded
results
Normalized
Results
Gains less losses on financial transactions
181
132
48
Gains/(losses) on derecognition of financial assets measured at amortized cost
(4)
(4)
0
Total Income (after excluding Gains less losses on derecognition of financial
assets measured at amortised cost and Gains less losses on financial
transactions)
1,577
-
1,577
Total expenses before impairment losses and provisions to cover credit risk,
impairment losses on fixed assets and equity investments, provisions and
transformation costs
(857)
1
(857)
Impairment losses and provisions to cover credit risk and related expenses
(561)
(300)
(261)
Impairment losses on fixed assets and equity investments
(68)
(67)
(1)
Gain /(losses) on fixed assets and equity investments
317
306
11
Provisions and transformation costs
(41)
(41)
0
Net profit/(loss) from continuing operations before income tax
544
26
518
Income Tax
(239)
(74)
(165)
Net profit/(loss) from discontinued operations after income tax
63
17
46
Net profit/(loss) for the period
368
(30)
399
499 | ANNUAL FINANCIAL REPORT
Appendix for Non-Financial Report
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
GAR - Covered
assets in both
numerator and
denominator
1
Loans and
advances, debt
securities and
equity
instruments not
HfT eligible for
GAR calculation
16,275
8,965
1,234
1,005
22
129
375
5
0
0
9,650
1,239
1,005
22
191
2
Financial
undertakings
1,665
30
17
0
4
1
30
1
0
0
371
18
0
4
62
3
Credit institutions
1,519
0
0
0
0
0
0
0
0
0
309
0
0
0
0
4
Loans and
advances
263
0
0
0
0
0
0
0
0
0
52
0
0
0
0
5
Debt securities,
including UoP
1,248
0
0
0
0
0
0
0
0
0
256
0
0
0
0
500 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
6
Equity
instruments
8
0
0
0
0
0
0
0
1
0
0
0
7
Other financial
corporations
145
30
17
0
4
1
30
1
0
0
62
18
0
4
62
8
of which
investment firms
6
0
0
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
0
0
0
10
Debt securities,
including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity
instruments
6
0
0
0
0
0
0
0
0
0
0
0
12
of which
management
companies
12
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
Loans and
advances
12
0
0
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
0
0
0
15
Equity
instruments
0
0
0
0
0
0
0
0
0
0
0
0
501 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
16
of which
insurance
undertakings
4
0
0
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
0
0
0
18
Debt securities,
including UoP
4
0
0
0
0
0
0
0
0
0
1
0
0
0
0
19
Equity
instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Non-financial
undertakings
5,027
1,525
1,217
1,005
18
128
345
4
0
0
1,871
1,221
1,005
18
128
21
Loans and
advances
4,010
1,373
1,148
1,005
10
92
230
1
0
0
1,603
1,148
1,005
10
92
22
Debt securities,
including UoP
1,000
148
69
0
8
36
111
3
0
0
259
72
0
8
36
23
Equity
instruments
16
4
0
0
0
4
0
0
8
0
0
0
24
Households
9,547
7,409
0
0
0
0
0
0
0
0
7,409
0
0
0
0
25
of which loans
collateralised by
residential
6,684
6,684
0
0
0
0
0
0
0
0
6,684
0
0
0
0
502 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
immovable
property
26
of which building
renovation loans
650
650
0
0
0
0
0
0
0
0
650
0
0
0
0
27
of which motor
vehicle loans
74
74
0
0
0
0
0
0
0
0
74
0
0
0
0
28
Local
governments
financing
37
0
0
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
0
0
0
30
Other local
government
financing
37
0
0
0
0
0
0
0
0
0
0
0
0
0
0
31
Collateral
obtained by
taking
possession:
residential and
commercial
immovable
properties
819
819
0
0
0
0
0
0
0
0
819
0
0
0
0
503 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
32
Assets excluded
from the
numerator for
GAR calculation
(covered in the
denominator)
40,560
33
Financial and
Non-financial
undertakings
24,646
34
SMEs and NFCs
(other than
SMEs) not
subject to NFRD
disclosure
obligations
20,607
35
Loans and
advances
20,368
36
of which loans
collateralised by
commercial
immovable
property
1,726
37
of which building
renovation loans
0
504 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
38
Debt securities
131
39
Equity
instruments
109
40
Non-EU country
counterparties
not subject to
NFRD disclosure
obligations
4,039
41
Loans and
advances
3,169
42
Debt securities
812
43
Equity
instruments
57
44
Derivatives
1,819
45
On demand
interbank loans
1,460
46
Cash and cash-
related assets
492
47
Other
categories of
assets (e.g.
12,142
505 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
Goodwill,
commodities
etc.)
48
Total GAR
assets
57,655
49
Assets not
covered for
GAR calculation
16,401
50
Central
governments
and
Supranational
issuers
12,641
51
Central banks
exposure
3,727
52
Trading book
33
53
Total assets
74,055
Off-balance sheet exposures - Corporates subject to NFRD disclosure obligations
54
Financial
guarantees
4,999
0
0
0
0
0
0
0
0
0
0
0
0
0
0
55
Assets under
management
1,696
0
0
0
0
0
0
0
0
0
0
0
0
0
0
506 | ANNUAL FINANCIAL REPORT
1. Assets for the calculation of GAR - Turnover
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation
(CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy
relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
environmentally
sustainable (Taxonomy-
aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of
which
use of
procee
ds
Of which
transitio
nal
Of
which
enablin
g
Of
which
speciali
sed
lending
Of
which
enablin
g
Of which
specialise
d lending
Of which
transitional/adapt
ation
Of
which
enablin
g
56
Of which debt
securities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
57
Of which equity
instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.Assets for the calculation of GAR - Capex
Million EUR
31 December 2023
Total gross
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
507 | ANNUAL FINANCIAL REPORT
Of which
use of
proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional/adaptation
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
16,275
10,216
1,998
1,005
35
185
535
2
0
0
11,062
2,001
1,005
35
267
2
Financial undertakings
1,665
61
57
0
0
3
19
0
0
0
391
57
0
0
85
3
Credit institutions
1,519
0
0
0
0
0
0
0
0
0
309
0
0
0
0
4
Loans and advances
263
0
0
0
0
0
0
0
0
0
52
0
0
0
0
5
Debt securities,
including UoP
1,248
0
0
0
0
0
0
0
0
0
256
0
0
0
0
6
Equity instruments
8
0
0
0
0
0
0
0
1
0
0
0
7
Other financial
corporations
145
61
57
0
0
3
19
0
0
0
82
57
0
0
85
8
of which investment
firms
6
0
0
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
0
0
0
10
Debt securities,
including UoP
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11
Equity instruments
6
0
0
0
0
0
0
0
0
0
0
0
12
of which management
companies
12
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
Loans and advances
12
0
0
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
0
0
0
15
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
16
of which insurance
undertakings
4
0
0
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
0
0
0
18
Debt securities,
including UoP
4
0
0
0
0
0
0
0
0
0
1
0
0
0
0
19
Equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
Non-financial
undertakings
5,027
2,746
1,941
1,005
35
182
516
2
0
0
3,261
1,944
1,005
35
182
508 | ANNUAL FINANCIAL REPORT
21
Loans and advances
4,010
2,356
1,677
1,005
13
116
394
1
0
0
2,750
1,678
1,005
13
116
22
Debt securities,
including UoP
1,000
386
264
0
21
66
118
2
0
0
504
266
0
21
66
23
Equity instruments
16
3
1
1
0
3
0
0
7
1
1
0
24
Households
9,547
7,409
0
0
0
0
0
0
0
0
7,409
0
0
0
0
25
of which loans
collateralised by residential
immovable property
6,684
6,684
0
0
0
0
0
0
0
0
6,684
0
0
0
0
26
of which building
renovation loans
650
650
0
0
0
0
0
0
0
0
650
0
0
0
0
27
of which motor vehicle
loans
74
74
0
0
0
0
0
0
0
0
74
0
0
0
0
28
Local governments
financing
37
0
0
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
0
0
0
30
Other local government
financing
37
0
0
0
0
0
0
0
0
0
0
0
0
0
0
31
Collateral obtained by
taking possession: residential
and commercial immovable
properties
819
819
0
0
0
0
0
0
0
0
819
0
0
0
0
32
Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
40,560
33
Financial and Non-
financial undertakings
24,646
34
SMEs and NFCs (other
than SMEs) not subject to NFRD
disclosure obligations
20,607
35
Loans and advances
20,368
36
of which loans
collateralised by commercial
immovable property
1,726
37
of which building
renovation loans
0
38
Debt securities
131
39
Equity instruments
109
509 | ANNUAL FINANCIAL REPORT
40
Non-EU country
counterparties not subject to NFRD
disclosure obligations
4,039
41
Loans and advances
3,169
42
Debt securities
812
43
Equity instruments
57
44
Derivatives
1,819
45
On demand interbank
loans
1,460
46
Cash and cash-related
assets
492
47
Other categories of assets
(e.g. Goodwill, commodities etc.)
12,142
48
Total GAR assets
57,655
49
Assets not covered for GAR
calculation
16,401
50
Central governments and
Supranational issuers
12,641
51
Central banks exposure
3,727
52
Trading book
33
53
Total assets
74,055
Off-balance sheet exposures - Corporates subject to NFRD disclosure obligations
54
Financial guarantees
4,999
0
0
0
0
0
0
0
0
0
0
0
0
0
0
55
Assets under management
1,696
0
0
0
0
0
0
0
0
0
0
0
0
0
0
56
Of which debt securities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
57
Of which equity instruments
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
510 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Turnover
31 December 2023
Breakdown by sector - NACE 4 digits level (code
and label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC
not subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
1
A1.1.3 - Growing of vegetables and
melons, roots and tubers
0
0
0
0
0
0
2
B07.2.9 - Mining of other non-ferrous metal
ores
9
0
9
0
9
0
3
C10.5.1 - Operation of dairies and cheese
making
14
0
14
0
14
0
4
C11.0.5 - Manufacture of beer
31
0
31
0
31
0
5
C13.9.3 - Manufacture of carpets and rugs
10
2
10
0
10
2
6
C13.9.5 - Manufacture of non-wovens and
articles made from non-wovens, except
apparel
5
2
5
0
5
2
7
C16.2.4 - Manufacture of wooden
containers
1
0
1
1
1
1
8
C19.2.0 - Manufacture of refined petroleum
products
458
3
458
0
458
3
9
C20.1.1 - Manufacture of industrial gases
50
5
50
0
50
5
10
C20.5.9 - Manufacture of other chemical
products n.e.c.
5
0
5
0
5
0
11
C21.1.0 - Manufacture of basic
pharmaceutical products
8
0
8
0
8
0
12
C22.1.1 - Manufacture of rubber tyres and
tubes; retreading and rebuilding of rubber
tyres
8
0
8
0
8
0
13
C22.2.1 - Manufacture of plastic plates,
sheets, tubes and profiles
11
4
11
0
11
4
14
C23.4.2 - Manufacture of ceramic sanitary
fixtures
0
0
0
0
0
0
511 | ANNUAL FINANCIAL REPORT
15
C23.5.1 - Manufacture of cement
66
3
66
3
66
6
16
C24.1.0 - Manufacture of basic iron and
steel and of ferro-alloys
100
10
100
0
100
10
17
C24.2.0 - Manufacture of tubes, pipes,
hollow profiles and related fittings, of steel
4
0
4
0
4
0
18
C24.4.2 - Aluminium production
39
0
39
0
39
0
19
C24.4.4 - Copper production
89
0
89
0
89
0
20
C24.5.1 - Casting of iron
85
9
85
0
85
9
21
C24.5.4 - Casting of other non-ferrous
metals
13
1
13
0
13
1
22
C25.9.2 - Manufacture of light metal
packaging
0
0
0
0
0
0
23
C25.9.3 - Manufacture of wire products,
chain and springs
7
1
7
0
7
1
24
C26.5.1 - Manufacture of instruments and
appliances for measuring, testing and
navigation
14
0
14
0
14
0
25
C27.1.1 - Manufacture of electric motors,
generators and transformers
25
5
25
0
25
5
26
C27.3.2 - Manufacture of other electronic
and electric wires and cables
125
60
125
0
125
60
27
C28.9.9 - Manufacture of other special-
purpose machinery n.e.c.
19
0
19
0
19
0
28
C29.1.0 - Manufacture of motor vehicles
87
8
87
1
87
9
29
D35.1.1 - Production of electricity
1,694
908
1,694
0
1,694
908
30
D35.1.2 - Transmission of electricity
52
4
52
0
52
4
31
D35.1.3 - Distribution of electricity
86
41
86
0
86
41
32
D35.1.4 - Trade of electricity
15
15
15
0
15
15
33
D35.3.0 - Steam and air conditioning
supply
0
0
0
0
0
0
34
E36.0.0 - Water collection, treatment and
supply
24
8
24
0
24
8
35
E38.1.1 - Collection of non-hazardous
waste
2
2
2
0
2
2
36
E38.3.2 - Recovery of sorted materials
2
0
2
0
2
0
37
F41.1.0 - Development of building projects
13
0
13
0
13
0
38
F41.2.0 - Construction of residential and
non-residential buildings
5
0
5
0
5
0
512 | ANNUAL FINANCIAL REPORT
39
F42.1.1 - Construction of roads and
motorways
178
12
178
0
178
12
40
F42.9.9 - Construction of other civil
engineering projects n.e.c.
2
0
2
0
2
0
41
F43.9.9 - Other specialised construction
activities n.e.c.
0
0
0
0
0
0
42
G46.1.5 - Agents involved in the sale of
furniture, household goods, hardware and
ironmongery
2
0
2
0
2
0
43
G46.3.7 - Wholesale of coffee, tea, cocoa
and spices
10
0
10
0
10
0
44
G46.4.2 - Wholesale of clothing and
footwear
0
0
0
0
0
0
45
G46.4.3 - Wholesale of electrical
household appliances
0
0
0
0
0
0
46
G46.4.5 - Wholesale of perfume and
cosmetics
2
0
2
0
2
0
47
G46.5.1 - Wholesale of computers,
computer peripheral equipment and
software
27
0
27
0
27
0
48
G46.5.2 - Wholesale of electronic and
telecommunications equipment and parts
6
0
6
0
6
0
49
G46.6.9 - Wholesale of other machinery
and equipment
0
0
0
0
0
0
50
G46.7.1 - Wholesale of solid, liquid and
gaseous fuels and related products
179
2
179
0
179
2
51
G46.7.7 - Wholesale of waste and scrap
12
1
12
0
12
1
52
G47.1.1 - Retail sale in non-specialised
stores with food, beverages or tobacco
predominating
4
4
4
0
4
4
53
G47.4.2 - Retail sale of
telecommunications equipment in
specialised stores
0
0
0
0
0
0
54
G47.6.4 - Retail sale of sporting equipment
in specialised stores
28
0
28
0
28
0
55
G47.7.1 - Retail sale of clothing in
specialised stores
3
0
3
0
3
0
56
H50.1.0 - Sea and coastal passenger
water transport
33
0
33
0
33
0
57
H50.2.0 - Sea and coastal freight water
transport
10
1
10
0
10
1
58
H50.3.0 - Inland passenger water transport
23
0
23
0
23
0
59
H51.1.0 - Passenger air transport
10
0
10
0
10
0
513 | ANNUAL FINANCIAL REPORT
60
H52.1.0 - Warehousing and storage
10
0
10
0
10
0
61
H52.2.2 - Service activities incidental to
water transportation
16
4
16
0
16
4
62
H52.2.3 - Service activities incidental to air
transportation
429
3
429
0
429
3
63
H52.2.9 - Other transportation support
activities
7
0
7
0
7
0
64
I55.1.0 - Hotels and similar
accommodation
30
0
30
0
30
0
65
J58.2.9 - Other software publishing
7
0
7
0
7
0
66
J61.1.0 - Wired telecommunications
activities
156
0
156
0
156
0
67
J61.2.0 - Wireless telecommunications
activities
23
0
23
0
23
0
68
J62.0.9 - Other information technology and
computer service activities
31
0
31
0
31
0
69
J63.1.1 - Data processing, hosting and
related activities
4
0
4
0
4
0
70
K64.2.0 - Activities of holding companies
71
71
71
0
71
71
71
L68.1.0 - Buying and selling of own real
estate
47
4
47
0
47
4
72
L68.2.0 - Renting and operating of own or
leased real estate
90
1
90
0
90
1
73
L68.3.2 - Management of real estate on a
fee or contract basis
20
0
20
0
20
0
74
M70.2.2 - Business and other management
consultancy activities
15
0
15
0
15
0
75
M71.1.1 - Architectural activities
1
1
1
0
1
1
76
M74.9.0 - Other professional, scientific and
technical activities n.e.c.
1
1
1
0
1
1
77
N77.1.1 - Renting and leasing of cars and
light motor vehicles
110
4
110
0
110
4
78
N77.3.2 - Renting and leasing of
construction and civil engineering
machinery and equipment
1
0
1
0
1
0
79
N81.2.1 - General cleaning of buildings
1
0
1
0
1
0
80
Q86.1.0 - Hospital activities
49
0
49
0
49
0
81
R92.0.0 - Gambling and betting activities
58
0
58
0
58
0
82
S96.0.9 - Other personal service activities
n.e.c.
0
0
0
0
0
0
514 | ANNUAL FINANCIAL REPORT
83
Other unallocated
142
13
142
0
142
13
515 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
1
A1.1.3 - Growing of vegetables and melons, roots
and tubers
0
0
0
0
0
0
2
B07.2.9 - Mining of other non-ferrous metal ores
9
0
9
0
9
0
3
C10.5.1 - Operation of dairies and cheese making
14
0
14
0
14
0
4
C11.0.5 - Manufacture of beer
31
5
31
0
31
5
5
C13.9.3 - Manufacture of carpets and rugs
10
2
10
0
10
2
6
C13.9.5 - Manufacture of non-wovens and articles
made from non-wovens, except apparel
5
3
5
0
5
3
7
C16.2.4 - Manufacture of wooden containers
1
0
1
1
1
1
8
C19.2.0 - Manufacture of refined petroleum products
458
234
458
0
458
234
9
C20.1.1 - Manufacture of industrial gases
50
31
50
0
50
31
10
C20.5.9 - Manufacture of other chemical products
n.e.c.
5
4
5
0
5
4
11
C21.1.0 - Manufacture of basic pharmaceutical
products
8
0
8
0
8
0
516 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
12
C22.1.1 - Manufacture of rubber tyres and tubes;
retreading and rebuilding of rubber tyres
8
0
8
0
8
0
13
C22.2.1 - Manufacture of plastic plates, sheets, tubes
and profiles
11
6
11
0
11
6
14
C23.4.2 - Manufacture of ceramic sanitary fixtures
0
0
0
0
0
0
15
C23.5.1 - Manufacture of cement
66
11
66
0
66
11
16
C24.1.0 - Manufacture of basic iron and steel and of
ferro-alloys
100
10
100
0
100
10
17
C24.2.0 - Manufacture of tubes, pipes, hollow profiles
and related fittings, of steel
4
0
4
0
4
0
18
C24.4.2 - Aluminium production
39
2
39
0
39
2
19
C24.4.4 - Copper production
89
0
89
0
89
0
20
C24.5.1 - Casting of iron
85
9
85
0
85
9
21
C24.5.4 - Casting of other non-ferrous metals
13
1
13
0
13
1
22
C25.9.2 - Manufacture of light metal packaging
0
0
0
0
0
0
517 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
23
C25.9.3 - Manufacture of wire products, chain and
springs
7
1
7
0
7
1
24
C26.5.1 - Manufacture of instruments and appliances
for measuring, testing and navigation
14
0
14
0
14
0
25
C27.1.1 - Manufacture of electric motors, generators
and transformers
25
7
25
0
25
7
26
C27.3.2 - Manufacture of other electronic and electric
wires and cables
125
56
125
0
125
56
27
C28.9.9 - Manufacture of other special-purpose
machinery n.e.c.
19
0
19
0
19
0
28
C29.1.0 - Manufacture of motor vehicles
87
19
87
2
87
21
29
D35.1.1 - Production of electricity
1,694
1,059
1,694
0
1,694
1,059
30
D35.1.2 - Transmission of electricity
52
5
52
0
52
5
31
D35.1.3 - Distribution of electricity
86
41
86
0
86
41
32
D35.1.4 - Trade of electricity
15
15
15
0
15
15
33
D35.3.0 - Steam and air conditioning supply
0
0
0
0
0
0
518 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
34
E36.0.0 - Water collection, treatment and supply
24
2
24
0
24
2
35
E38.1.1 - Collection of non-hazardous waste
2
2
2
0
2
2
36
E38.3.2 - Recovery of sorted materials
2
1
2
0
2
1
37
F41.1.0 - Development of building projects
13
0
13
0
13
0
38
F41.2.0 - Construction of residential and non-
residential buildings
5
0
5
0
5
0
39
F42.1.1 - Construction of roads and motorways
178
80
178
0
178
80
40
F42.9.9 - Construction of other civil engineering
projects n.e.c.
2
1
2
0
2
1
41
F43.9.9 - Other specialised construction activities
n.e.c.
0
0
0
0
0
0
42
G46.1.5 - Agents involved in the sale of furniture,
household goods, hardware and ironmongery
2
0
2
0
2
0
43
G46.3.7 - Wholesale of coffee, tea, cocoa and spices
10
0
10
0
10
0
44
G46.4.2 - Wholesale of clothing and footwear
0
0
0
0
0
0
519 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
45
G46.4.3 - Wholesale of electrical household
appliances
0
0
0
0
0
0
46
G46.4.5 - Wholesale of perfume and cosmetics
2
0
2
0
2
0
47
G46.5.1 - Wholesale of computers, computer
peripheral equipment and software
27
5
27
0
27
5
48
G46.5.2 - Wholesale of electronic and
telecommunications equipment and parts
6
1
6
0
6
1
49
G46.6.9 - Wholesale of other machinery and
equipment
0
0
0
0
0
0
50
G46.7.1 - Wholesale of solid, liquid and gaseous
fuels and related products
179
116
179
0
179
116
51
G46.7.7 - Wholesale of waste and scrap
12
1
12
0
12
1
52
G47.1.1 - Retail sale in non-specialised stores with
food, beverages or tobacco predominating
4
4
4
0
4
4
53
G47.4.2 - Retail sale of telecommunications
equipment in specialised stores
0
0
0
0
0
0
520 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
54
G47.6.4 - Retail sale of sporting equipment in
specialised stores
28
0
28
0
28
0
55
G47.7.1 - Retail sale of clothing in specialised stores
3
0
3
0
3
0
56
H50.1.0 - Sea and coastal passenger water transport
33
3
33
0
33
3
57
H50.2.0 - Sea and coastal freight water transport
10
1
10
0
10
1
58
H50.3.0 - Inland passenger water transport
23
2
23
0
23
2
59
H51.1.0 - Passenger air transport
10
0
10
0
10
0
60
H52.1.0 - Warehousing and storage
10
0
10
0
10
0
61
H52.2.2 - Service activities incidental to water
transportation
16
12
16
0
16
12
62
H52.2.3 - Service activities incidental to air
transportation
429
53
429
0
429
53
63
H52.2.9 - Other transportation support activities
7
0
7
0
7
0
64
I55.1.0 - Hotels and similar accommodation
30
0
30
0
30
0
65
J58.2.9 - Other software publishing
7
0
7
0
7
0
66
J61.1.0 - Wired telecommunications activities
156
0
156
0
156
0
521 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
67
J61.2.0 - Wireless telecommunications activities
23
0
23
0
23
0
68
J62.0.9 - Other information technology and computer
service activities
31
0
31
0
31
0
69
J63.1.1 - Data processing, hosting and related
activities
4
2
4
0
4
2
70
K64.2.0 - Activities of holding companies
71
71
71
0
71
71
71
L68.1.0 - Buying and selling of own real estate
47
6
47
0
47
6
72
L68.2.0 - Renting and operating of own or leased real
estate
90
5
90
0
90
5
73
L68.3.2 - Management of real estate on a fee or
contract basis
20
0
20
0
20
0
74
M70.2.2 - Business and other management
consultancy activities
15
0
15
0
15
0
75
M71.1.1 - Architectural activities
1
1
1
0
1
1
76
M74.9.0 - Other professional, scientific and technical
activities n.e.c.
1
1
1
0
1
1
522 | ANNUAL FINANCIAL REPORT
2. GAR sector information - Capex
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Million EUR
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Gross carrying amount
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCM)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which
environmentally
sustainable (CCA)
Mn
EUR
Of which environmentally
sustainable (CCM + CCA)
Mn
EUR
Of which
environmentally
sustainable
(CCM + CCA)
77
N77.1.1 - Renting and leasing of cars and light motor
vehicles
110
11
110
0
110
11
78
N77.3.2 - Renting and leasing of construction and
civil engineering machinery and equipment
1
0
1
0
1
0
79
N81.2.1 - General cleaning of buildings
1
1
1
0
1
1
80
Q86.1.0 - Hospital activities
49
0
49
0
49
0
81
R92.0.0 - Gambling and betting activities
58
0
58
0
58
0
82
S96.0.9 - Other personal service activities n.e.c.
0
0
0
0
0
0
83
Other unallocated
142
36
142
0
142
36
523 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Turnover
% (compared to total covered assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity instruments not
HfT eligible for GAR calculation
15.5
2.1
1.7
0.0
0.2
0.7
0.0
0.0
0.0
16.7
2.1
1.7
0.0
0.3
22.0
2
Financial corporations
0.1
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.6
0.0
0.0
0.0
0.1
2.2
3
Credit institutions
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.0
0.0
0.0
0.0
2.1
4
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.4
5
Debt securities, including
UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.0
0.0
0.0
1.7
6
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7
Other financial corporations
0.1
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.1
0.2
8
of which investment firms
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
524 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Turnover
% (compared to total covered assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
9
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
15
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
525 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Turnover
% (compared to total covered assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
18
Debt securities, including
UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
19
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
20
Non-financial corporations
2.6
2.1
1.7
0.0
0.2
0.6
0.0
0.0
0.0
3.2
2.1
1.7
0.0
0.2
6.8
21
Loans and advances
2.4
2.0
1.7
0.0
0.2
0.4
0.0
0.0
0.0
2.8
2.0
1.7
0.0
0.2
5.4
22
Debt securities, including
UoP
0.3
0.1
0.0
0.0
0.1
0.2
0.0
0.0
0.0
0.4
0.1
0.0
0.0
0.1
1.4
23
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
24
Households
12.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
12.9
0.0
0.0
0.0
0.0
12.9
25
of which loans collateralised
by residential immovable property
11.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11.6
0.0
0.0
0.0
0.0
9.0
526 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Turnover
% (compared to total covered assets in the
denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
26
of which building renovation
loans
1.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
0.0
0.0
0.0
0.9
27
of which motor vehicle loans
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.1
28
Local governments financing
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
29
Housing financing
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
1.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.4
0.0
0.0
0.0
0.0
1.1
32
Total GAR assets
17.4
2.1
1.7
0.0
0.2
0.7
0.0
0.0
0.0
18.1
2.1
1.7
0.0
0.2
23.1
527 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Capex
% (compared to total covered assets in
the denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
17.7
3.5
1.7
0.1
0.3
0.9
0.0
0.0
0.0
19.2
3.5
1.7
0.1
0.5
22.0
2
Financial corporations
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.1
0.0
0.0
0.1
2.2
3
Credit institutions
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
0.0
0.0
0.0
0.0
2.1
4
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.4
5
Debt securities, including UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.0
0.0
0.0
1.7
6
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7
Other financial corporations
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.1
0.2
8
of which investment firms
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
528 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Capex
% (compared to total covered assets in
the denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
13
Loans and advance
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
15
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
19
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
20
Non-financial corporations
4.8
3.4
1.7
0.1
0.3
0.9
0.0
0.0
0.0
5.7
3.4
1.7
0.1
0.3
6.8
21
Loans and advances
4.1
2.9
1.7
0.0
0.2
0.7
0.0
0.0
0.0
4.8
2.9
1.7
0.0
0.2
5.4
22
Debt securities, including UoP
0.7
0.5
0.0
0.0
0.1
0.2
0.0
0.0
0.0
0.9
0.5
0.0
0.0
0.1
1.4
23
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
24
Households
12.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
12.9
0.0
0.0
0.0
0.0
12.9
25
of which loans collateralised by
residential immovable property
11.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11.6
0.0
0.0
0.0
0.0
9.0
26
of which building renovation
loans
1.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
0.0
0.0
0.0
0.9
27
of which motor vehicle loans
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.1
529 | ANNUAL FINANCIAL REPORT
3. GAR KPI Stock - Capex
% (compared to total covered assets in
the denominator)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion of
total assets
covered
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which use
of proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
28
Local governments financing
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
29
Housing financing
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
1.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.4
0.0
0.0
0.0
0.0
1.1
32
Total GAR assets
19.1
3.5
1.7
0.1
0.3
0.9
0.0
0.0
0.0
20.6
3.5
1.7
0.1
0.5
23.1
530 | ANNUAL FINANCIAL REPORT
4. GAR KPI flow - Turnover
% (compared to flow of total eligible assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion
of total
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
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
GAR - Covered assets
in both numerator and
denominator
1
Loans and
advances, debt
securities and equity
instruments not HfT
eligible for GAR
calculation
6.8
6.4
5.6
0.0
0.4
0.5
0.0
0.0
0.0
8.0
6.4
5.6
0.0
0.4
27.6
2
Financial
undertakings
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.9
3
Credit institutions
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.6
4
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.5
6
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
7
Other financial
corporations
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
8
of which investment
firms
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
9
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
531 | ANNUAL FINANCIAL REPORT
4. GAR KPI flow - Turnover
% (compared to flow of total eligible assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion
of total
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
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
10
Debt securities,
including UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
12
of which management
companies
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
13
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
14
Debt securities,
including UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
15
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
19
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
20
Non-financial
undertakings
6.8
6.4
5.6
0.0
0.4
0.5
0.0
0.0
0.0
7.3
6.4
5.6
0.0
0.4
22.8
21
Loans and advance
6.6
6.2
5.6
0.0
0.4
0.2
0.0
0.0
0.0
6.8
6.2
5.6
0.0
0.4
20.9
532 | ANNUAL FINANCIAL REPORT
4. GAR KPI flow - Turnover
% (compared to flow of total eligible assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion
of total
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
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
22
Debt securities,
including UoP
0.3
0.2
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.5
0.2
0.0
0.0
0.0
1.9
23
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
24
Households
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
25
of which loans
collateralised by
residential immovable
property
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
26
of which building
renovation loans
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
27
of which motor vehicle
loans
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
28
Local governments
financing
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
31
Collateral obtained by
taking possession:
residential and
commercial
immovable properties
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
533 | ANNUAL FINANCIAL REPORT
4. GAR KPI flow - Turnover
% (compared to flow of total eligible assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-eligible)
Proportion
of total
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
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
specialised
lending
Of which
transitional
Of which
enabling
32
Total GAR assets
6.8
6.4
5.6
0.0
0.4
0.5
0.0
0.0
0.0
8.0
6.4
5.6
0.0
0.4
27.6
534 | ANNUAL FINANCIAL REPORT
4. GAR KPI flow
% (compared to flow of total eligible assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
TOTAL (CCM + CCA)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion
of total
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
transitional
Of
which
enabling
Of which
specialised
lending
Of
which
enabling
Of which
specialised
lending
Of which
transitional
Of
which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
15.3
9.1
5.6
0.0
0.4
0.7
0.0
0.0
0.0
16.1
9.1
5.6
0.0
0.4
27.6
2
Financial undertakings
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.9
3
Credit institutions
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.6
4
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.7
0.0
0.0
0.0
0.0
4.5
6
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
7
Other financial
corporations
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
8
of which investment
firms
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
9
Loans and
advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
11
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
535 | ANNUAL FINANCIAL REPORT
12
of which management
companies
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
13
Loans and advances
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
14
Debt securities, including UoP
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
15
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
19
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
20
Non-financial undertakings
15.3
9.1
5.6
0.0
0.4
0.7
0.0
0.0
0.0
15.4
9.1
5.6
0.0
0.4
22.8
21
Loans and advances
14.8
9.1
5.6
0.0
0.4
0.6
0.0
0.0
0.0
15.4
9.1
5.6
0.0
0.4
20.9
22
Debt securities, including oP
0.5
0.1
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.9
23
Equity instruments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
24
Households
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
25
of which loans collateralised by
residential immovable property
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
26
of which building
renovationloans
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
27
of which motor vehicle loans
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
28
Local governments financng
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
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
0.0
0.0
0.0
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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
32
Total GAR assets
15.3
9.1
5.6
0.0
0.4
0.7
0.0
0.0
0.0
16.1
9.1
5.6
0.0
0.4
27.6
536 | ANNUAL FINANCIAL REPORT
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.
YES
3.
The undertaking carries out, funds or has exposures to safe operation of existing
nuclear installations that produce electricity or process heat, including for the
purposes of district heating or industrial processes such as hydrogen production
from nuclear energy, as well as their safety upgrades.
YES
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation
of electricity generation facilities that produce electricity using fossil gaseous
fuels
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment,
and operation of combined heat/cool and power generation facilities using fossil
gaseous fuels.
YES
6.
The undertaking carries out, funds or has exposures to construction, refurbishment
and operation of heat generation facilities that produce heat/cool using fossil gaseous
fuels.
YES
537 | ANNUAL FINANCIAL REPORT
Turnover KPI Templates
Template 2 - Taxonomy-aligned economic activities (denominator)
Template 3 -Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to
be presented in monetary amounts and as percentages)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to be
presented in monetary amounts and as percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.26 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
1.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.26 of
Annexes I and II to
Delegated Regulation
2021/2139 in the numerator
of the applicable KPI
0
0.0
0
0.0
0
0.0
2.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.27 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
2.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.27 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
3.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.28 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
4
0.0
4
0.0
0
0.0
3.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.28 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
4
0.3
4
0.3
0
0.0
4.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.29 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
4.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.29 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
538 | ANNUAL FINANCIAL REPORT
Turnover KPI Templates
Template 2 - Taxonomy-aligned economic activities (denominator)
Template 3 -Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to
be presented in monetary amounts and as percentages)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to be
presented in monetary amounts and as percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
5.
Amount and proportion of
taxonomy-aligned
economic activity EN 3 EN
referred to in Section 4.30
of Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
5.
Amount and proportion of
taxonomy-aligned
economic activity EN 3 EN
referred to in Section 4.30
of Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
6.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.31 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
6.
Amount and proportion of
taxonomy-aligned
economic activity referred
to in Section 4.31 of
Annexes I and II to
Delegated Regulation
2021/2139 in the
denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
7.
Amount and proportion
of other taxonomy-
aligned economic
activities not referred to
in rows 1 to 6 above in
the denominator of the
applicable KPI
1,235
2.1
1,230
2.1
5
0.0
7.
Amount and proportion
of other taxonomy-
aligned economic
activities not referred to
in rows 1 to 6 above in
the denominator of the
applicable KPI
1,235
99.7
1,230
99.7
5
100.0
8.
Total applicable KPI
1,239
2.1
1,234
2.1
5
0.0
8.
Total amount and
proportion of taxonomy-
aligned economic
activities in the
numerator of the
applicable KPI
1,239
100.0
1,234
100.0
5
100.0
539 | ANNUAL FINANCIAL REPORT
Template 4 - Taxonomy-eligible but not taxonomy-aligned economic activities
Row
Economic activities
Amount (in Million EUR) and Pproportion (the information is to be
presented in monetary amounts and as percentages)
Template 5 - Taxonomy non-eligible economic activities
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Row
Economic activities
Amount
(in
Million
EUR)
%
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
0.0
0
0.0
0
0.0
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
0.0
2.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
3.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
4.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
179
0.3
179
0.3
0
0.0
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
0.0
5.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
11
0.0
11
0.0
0
0.0
5.
Amount and proportion of economic activity referred to in
row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
EN 7 EN the applicable KPI
0
0.0
6.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated EN 6
EN Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
7.
Amount and proportion of other taxonomy-
eligible but not taxonomy-aligned economic
activities not referred to in rows 1 to 6 above in
the denominator of the applicable KPI
8,168
14.2
7,798
13.5
370
0.6
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
48,058
83.4
8.
Total amount and proportion of taxonomy eligible
but not taxonomy-aligned economic activities in
the denominator of the applicable KPI
8,358
14.5
7,987
13.9
370
0.6
8.
Total amount and proportion of taxonomy-non-
eligible economic activities in the denominator of the
applicable KPI
48,058
83.4
540 | ANNUAL FINANCIAL REPORT
CapexKPI Templates
Template 2 - Taxonomy-aligned economic activities (denominator)
Template 3 -Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to
be presented in monetary amounts and as percentages)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to be
presented in monetary amounts and as percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.26 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
1.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.26 of Annexes I and II to
Delegated Regulation 2021/2139
in the numerator of the
applicable KPI
0
0.0
0
0.0
0
0.0
2.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.27 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
1
0.0
1
0.0
0
0.0
2.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.27 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
1
0.0
1
0.0
0
0.0
3.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.28 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
7
0.0
7
0.0
0
0.0
3.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.28 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
7
0.3
7
0.3
0
0.0
4.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.29 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
4.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.29 of Annexes I and II to
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
5.
Amount and proportion of
taxonomy-aligned economic
activity EN 3 EN referred to in
Section 4.30 of Annexes I and II
to Delegated Regulation
2021/2139 in the denominator of
the applicable KPI
0
0.0
0
0.0
0
0.0
5.
Amount and proportion of
taxonomy-aligned economic
activity EN 3 EN referred to in
Section 4.30 of Annexes I and II
to Delegated Regulation
2021/2139 in the denominator of
the applicable KPI
0
0.0
0
0.0
0
0.0
6.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.31 of Annexes I and II to
0
0.0
0
0.0
0
0.0
6.
Amount and proportion of
taxonomy-aligned economic
activity referred to in Section
4.31 of Annexes I and II to
0
0.0
0
0.0
0
0.0
541 | ANNUAL FINANCIAL REPORT
CapexKPI Templates
Template 2 - Taxonomy-aligned economic activities (denominator)
Template 3 -Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to
be presented in monetary amounts and as percentages)
Row
Economic activities
Amount (in Million EUR) and proportion (the information is to be
presented in monetary amounts and as percentages)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
Amount
%
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
Delegated Regulation 2021/2139
in the denominator of the
applicable KPI
7.
Amount and proportion of
other taxonomy-aligned
economic activities not
referred to in rows 1 to 6
above in the denominator of
the applicable KPI
1,993
3.5
1,991
3.5
2
0.0
7.
Amount and proportion of
other taxonomy-aligned
economic activities not
referred to in rows 1 to 6
above in the denominator of
the applicable KPI
1,993
99.6
1,991
99.6
2
100.0
8.
Total applicable KPI
2,001
3.5
1,998
3.5
2
0.0
8.
Total amount and proportion
of taxonomy-aligned
economic activities in the
numerator of the applicable
KPI
2,001
100.0
1,998
100.0
2
100.0
Template 4 - Taxonomy-eligible but not taxonomy-aligned economic activities
Row
Economic activities
Amount (in Million EUR) and Pproportion (the information is to
be presented in monetary amounts and as percentages)
Template 5 - Taxonomy non-eligible economic activities
(CCM + CCA)
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Row
Economic activities
Amount
(in Million
EUR)
Percentage
Amount
%
Amount
%
Amount
%
542 | ANNUAL FINANCIAL REPORT
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
0.0
0
0.0
0
0.0
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
0.0
2.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
3.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
4.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
223
0.4
223
0.4
0
0.0
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
0.0
5.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the denominator of the
applicable KPI
7
0.0
7
0.0
0
0.0
5.
Amount and proportion of economic activity referred to
in row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
EN 7 EN the applicable KPI
0
0.0
6.
Amount and proportion of taxonomy-eligible but not
taxonomy-aligned economic activity referred to in
Section 4.31 of Annexes I and II to Delegated EN 6 EN
Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0
0
0.0
0
0.0
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
0.0
7.
Amount and proportion of other taxonomy-eligible
but not taxonomy-aligned economic activities not
referred to in rows 1 to 6 above in the denominator
of the applicable KPI
8,777
15.2
8,244
14.3
533
0.9
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
46,647
80.9
8.
Total amount and proportion of taxonomy eligible
but not taxonomy-aligned economic activities in
the denominator of the applicable KPI
9,007
15.6
8,475
14.7
533
0.9
8.
Total amount and proportion of taxonomy-non-
eligible economic activities in the denominator of
the applicable KPI
46,647
80.9
543 | ANNUAL FINANCIAL REPORT
Disclosures of Law 4374/2016
According to article 6 of Law 4374/1.4.2016 “Transparency among credit institutions, media companies and subsidized
persons” introduced to all credit institutions established in Greece the obligation to publish annually and on consolidated
basis:
a) All payments made within the year directly or indirectly to media company and its related parties, according to IAS 24, or
communication and advertising company.
b) All payments made within the year due to donation, subsidy, grant or other grantis to individuals and legal entities.
The information required is presented below, in Euro:
PAYMENTS TO MEDIA COMPANIES (Article 6 Par.1 of L.4374/2016)
Name (Names have not been translated into English)
Amounts before taxes
1984 ΑΝΕΞΑΡΤΗΤΗ ΔΗΜΟΣΙΟΓΡΑΦΙΑ Α.Μ.Κ.Ε.
11,655.00
24 MEDIA ΨΗΦΙΑΚΩΝ ΕΦΑΡΜΟΓΩΝ ΑΕ
64,746.00
ADWEB LTD ΕΤΑΙΡΕΙΑ ΠΕΡΙΟΡΙΣΜΕΝΗΣ ΕΥΘΥΝΗΣ
7,600.00
AIRLINK-ΕΛΛ/ΚΕΣ ΕΠΙΧ/ΣΕΙΣ ΕΚΔ.& ΟΠΤΙΚ/ΚΩΝ ΜΕΣΩΝ ΑΕ
17,985.06
ALPHA EDITIONS Α.Ε.
5,400.00
ALPHA ΔΟΡΥΦΟΡΙΚΗ ΤΗΛΕΟΡΑΣΗ Α.Ε
250,423.23
ALPHA ΡΑΔΙΟΦΩΝΙΚΗ Α.Ε.
18,199.57
ATCOM AE
2,500.00
BANKINGNEWS AE
65,000.00
BARKINGWELL MEDIA AE
3,000.00
BETTERMEDIA IKE
3,500.00
BRAINBUZZ MEDIA CONSULTING IKE
2,700.00
BRAINFOOD ΕΚΔΟΤΙΚΗ Μ.Ε.Π.Ε.
3,300.00
CLOCKWORK ORANGE MINDTRAP LIMITED
7,998.00
CPAN CONNECT - ED PUPLIC AFFAIRS NETWORK LTD "BANKWARS.GR"
6,532.00
D.G NEWSAGENCY ΑΝΩΝ.ΕΤΑΙΡ.ΗΛΕΚΤΡ.ΕΚΔΟΣΕΩΝ
27,425.00
DEBOP ΚΟΙΝ.ΣΥΝ.ΕΠΙΧ.ΣΥΛΛΟΓ.& ΚΟΙΝ. ΩΦΕΛΕΙΑΣ
550.00
DPG DIGITAL MEDIA ΜΟΝΟΠΡΟΣΩΠΗ Α.Ε.
17,040.00
DPG GROUP OF COMPANIES Μ.Α.Ε ΣΥΜΜΕΤΟΧΩΝ
28,419.00
ECONOMICO ΟΙΚΟΝΟΜΙΚΗ ΕΙΔΗΣΕΟΓΡΑΦΙΚΗ Α.Ε.
1,080.00
ELC PRODUCTIONS Ε.Ε.
2,800.00
ENERGY MAG ΜΟΝ.Ι.Κ.Ε.
4,000.00
ENIGMA M.G. ΜΟΝΟΠΡΟΣΩΠΗ Ι.Κ.Ε.
4,025.00
EXIT BEE GREECE ΥΠΟΚΑΤΑΣΤΗΜΑ ΑΛΛΟΔΑΠΗΣ
10,720.00
FAROSNET A.E
17,914.00
FAST RIVER ΔΗΜ.KEIMENO CONCEPTI ΕΚΔ.ΕΠΕ
22,435.12
FINAΝCIAL MARKETS VOICE AE ΕΦΗΜΕΡ. FM VOICE
37,700.00
FORWARD MEDIA IKE
21,602.25
FREED ΑΕ
24,013.99
FRONTSTAGE ΨΥΧΑΓΩΓΙΚΗ ΑΕ
31,121.28
GLOMAN AE
9,050.00
GREEN BOX ΕΚΔΟΤΙΚΗ ΑΕ
1,200.00
HAZLIS AND RIVAS COMMUNICATIONS LTD
6,500.00
HELLAS JOURNAL INC
10,750.00
HTTPOOL HELLAS M.IKE
152,733.24
ICAP CRIF A.E.
15,700.00
INFONEWS I.K.E.
15,100.00
INTERNATIONAL RADIO NETWORKS ΑΕ DEE JAY
8,400.85
J.O INFOCENT ΕΠΙΚΟΙΝΩΝΙΕΣ MON.ΕΠΕ
1,900.00
K.E. HEALTH TRAVEL O.E.
27,100.00
KISS AE ΜΕΣΑ ΜΑΖΙΚΗΣ ΕΝΗΜΕΡΩΣΗΣ
7,628.13
KONTRA MEDIA ΜΕΣΑ ΜΑΖΙΚΗΣ ΕΝΗΜΕΡΩΣΗΣ Α.Ε.
8,024.46
KOOLWORKS Μ. A.E.
11,224.25
KYRIAKOPOULOS ALEXANDROS TOU IOANNI -ΕΚΔΟΣΕΙΣ ΤΡΙΛΙΖΑ
4,000.00
LIQUID PUBLISHING A.E.
72,725.00
LOVE RADIO BROADCASTING AE
1,999.20
M.N.MARKETNEWS LIMITED
5,200.00
544 | ANNUAL FINANCIAL REPORT
PAYMENTS TO MEDIA COMPANIES (Article 6 Par.1 of L.4374/2016)
Name (Names have not been translated into English)
Amounts before taxes
MAMA365 ΔΙΑΔΙΚΤΥΑΚΕΣ ΕΠΙΧΕΙΡΗΣΕΙΣ ΕΠΕ
1,725.00
MEDIA PUBLISHING G.K. IKE
12,199.00
MEDIA2DAY ΕΚΔΟΤΙΚΗ ΑΝΩΝΥΜΗ ΕΤΑΙΡΕΙΑ
138,650.50
MINDSUPPORT IKE
3,685.75
MONOCLE MEDIA LAB MONONEWS Μ.Ι.Κ.Ε.
117,908.50
MY RADIO ΜΟΝΟΠΡΟΣΩΠΗ Ε.Π.Ε.
5,702.09
NAG Α.Ε.
6,500.00
NEW MEDIA NETWORK SYNAPSIS S.A.
108,516.00
NEWPOST PRIVATE COMPANY
21,165.00
NEWSFRONT ΝΑΥΤΙΛΙΑΚΕΣ ΕΚΔΟΣΕΙΣ ΙΚΕ
370.00
NEWSIT ΕΠΕ
74,974.00
NEWSROOM A.E
20,793.00
NOVA BROADCASTING ΜΟΝ. AE
3,111.22
NOVA TELECOMMUNICATIONS & MEDIA MON/ΠΗ Α.Ε
17,839.34
OCM DIGITAL MEDIA CYPRUS LTD
4,500.00
OLIVEMAGAZINE E.E.
7,770.00
ONE BRAND STUDIO I.K.E.
7,490.10
ONE DIGITAL SERVICES A.E.
35,760.00
PERFECT MEDIA ADVERTISING ΜΟΝ. ΑΕ
57,300.00
POLITICAL PUBLISHING I.K.E.
5,000.00
POLITIS GROUP RADIOS ΡΑΔ/ΚΗ & ΨΥΧΑΓ/ΚΗ ΜΟΝ. Α.Ε.
10,268.41
POWERGAME MEDIA I.K.E.
21,040.00
PREMIUM A.E.
26,315.00
PRIME APPLICATIONS A.E.
45,565.00
PRIME ONE ΥΠΟΚΑΤΑΣΤΗΜΑ ΑΛΛΟΔΑΠΗΣ ΕΠΕ
1,835.20
PROJECT AGORA LTD
2,515.00
REAL MEDIA A.E.
48,007.61
RELEVANCE
22,916.30
REPORT PRIVATE COMPANY
800.00
SABD ΕΚΔΟΤΙΚΗ Α.Ε.
73,028.00
SOLAR MEDIA Α.Ε.
5,676.00
SPORT TV ΡΑΔΙΟΤΗΛΕΟΠΤΙΚΗ ΠΡΟΒΟΛΗ Α.Ε.
9,464.61
SPORTNEWS ΥΠΗΡΕΣΙΕΣ ΔΙΑΔΙΚΤΙΟΥ Α.Ε.
9,500.00
SPREAD MEDIA Ι.Κ.Ε.
2,300.00
STRATEGIC BUSINESS DEVELOPMENT ΙΚΕ
13,698.00
TELIA COMMUNICATIONS AE
860.00
TELIA INTERNET I.K.E.
4,816.00
THE TOC DIGITAL MEDIA ΥΠΗΡΕΣΙΕΣ ΕΝΗΜΕΡΩΣΗΣ ΜΟΝ. Α.Ε.
6,960.00
THE WALT DISNEY COMPANY GREECE ΜΕΠΕ
9,543.60
THESSALONIKI 89 RAINBOW ΜΟΝ.ΕΠΕ
6,357.74
TLIFE ΕΦΑΡΜΟΓΕΣ ΔΙΑΔΙΚΤΥΟΥ ΕΕ
10,500.00
TOMORROW NEWS IKE
7,450.00
U MEDIA ΕΞΕΙΔΙΚΕΥΜΕΝΕΣ ΔΙΑΦ. ΥΠΗΡΕΣΙΕΣ Ι.Κ.Ε.
18,500.00
USAY Μ. Ε.Π.Ε - Σ.ΠΑΥΛΟΠΟΥΛΟΣ
2,262.50
VICE GREECE ΜΟΝ/ΠΗ ΑΕ
800.00
W.S.F. WALL STREET FINANCE Ι.Κ.Ε.
6,000.00
Α.Π.Ε.-Μ.Π.Ε. ΑΕ
14,000.00
ΑΒΡ ΕΚΔΟΤΙΚΗ ΙΔΙΩΤΙΚΗ ΚΕΦΑΛΑΙΟΥΧΙΚΗ ΕΤΑΙΡΕΙΑ
8,617.00
ΑΔΕΣΜΕΥΤΗ ΕΝΗΜΕΡΩΣΗ Ι.Κ.Ε.
2,308.00
ΑΘΑΝΑΣΙΟΥ ΔΑΜΙΑΝΟΣ ΕΦΗΜΕΡΙΔΑ Η ΔΗΜΟΚΡΑΤΙΚΗ ΤΗΣ ΡΟΔΟΥ
115.00
ΑΘΕΝΣ ΒΟΙΣ ΑΝΩΝΥΜΗ ΕΚΔΟΤΙΚΗ ΕΤΑΙΡΕΙΑ
35,360.00
ΑΙΟΛΟΣ ΕΚΔΟΤΙΚΗ ΑΕ
100.00
ΑΛΗΘΙΝΟ ΡΑΔΙΟΦΩΝΟ ΑΕ REAL FM
65,017.35
ΑΛΤΕΡ ΕΓΚΟ ΜΜΕ ΑΕ ΕΠΙΧΕΙΡΗΣΗ ΜΕΣΩΝ ΜΑΖΙΚΗΣ ΕΝΗΜΕΡΩΣΗΣ
892,436.74
ΑΝΕΞΑΡΤΗΤΑ ΜΕΣΑ ΜΑΖΙΚΗΣ ΕΝΗΜΕΡΩΣΗΣ ΑΕ
39,450.01
ΑΝΤΕΝΝΑ TV ΜΟΝΟΠΡΟΣΩΠΗ A.E.
318,101.00
ΑΝΩΝΥΜΟΣ ΕΤΑΙΡΕΙΑ ΕΡΕΥΝΑΣ-ΑΝΑΠΤΥΞΗΣ PHAISTOS
10,696.24
ΑΠΟΓΕΥΜΑΤΙΝΕΣ ΕΚΔΟΣΕΙΣ ΜΟΝ. Α.Ε.
14,000.00
ΑΤΤΙΚΑ ΠΟΛΥΚΑΤΑΣΗΜΑΤΑ ΜΟΝ/ΠΗ ΑΕ
5,609.92
ΑΤΤΙΚΕΣ ΕΚΔΟΣΕΙΣ ΑΕ
28,399.14
ΒΑΣΙΛΟΠΟΥΛΟΣ Χ - ΠΕΤΡΟΠΟΥΛΟΣ Δ. ΟΕ (NEMA PROBLEMA)
8,450.00
ΒΟΡΕΙΑ ΕΝΗΜΕΡΩΤΙΚΗ Α.Ε.
2,000.00
ΓΕΝΙΚΕΣ ΡΑΔΙΟΤΗΛΕΟΠΤΙΚΕΣ ΕΠΙΧ.ΑΕ
4,707.30
ΓΕΩΡΓΙΟΣ ΠΑΠΑΤΡΙΑΝΤΑΦΥΛΛΟΥ & ΣΙΑ Ε.Ε.
1,950.00
ΓΕΩΡΓΙΟΣ Σ.ΚΑΤΣΑΙΤΗΣ
200.00
ΓΙΑΣΕΜΙΔΗΣ ΓΙΩΡΓΟΣ
605.00
545 | ANNUAL FINANCIAL REPORT
PAYMENTS TO MEDIA COMPANIES (Article 6 Par.1 of L.4374/2016)
Name (Names have not been translated into English)
Amounts before taxes
Δ.ΜΠΟΥΡΑΣ & ΣΙΑ ΕΕ
52,500.00
ΔΑΦΝΗ ΕΠΙΚΟΙΝΩΝΙΕΣ ΑΕ
1,500.00
ΔΕΣΜΗ ΕΚΔΟΤΙΚΗ Α.Ε.
9,265.00
ΔΗΜΟΣΙΟΓΡΑΦΙΚΟΣ ΟΡΓΑΝΙΣΜΟΣ Ο ΧΡΟΝΟΣ ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ
100.00
ΔΗΜΟΤΙΚΗ ΕΠΙΧ/ΣΗ ΤΗΛΕΟΡΑΣΗΣ Δ.ΑΣΠΡ/ΡΓΟΥ ATTICA TV
1,032.00
ΔΙΟΓΕΝΗΣ ΜΚΟ ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΕΙΑ
1,500.00
ΔΟΥΣΗΣ ΑΝΑΣΤΑΣΙΟΣ & ΣΙΑ ΕΕ - DOUSIES COM EE
11,537.00
ΔΥΑΔΙΚΗ ΕΝΗΜΕΡΩΣΗ ΕΕ
19,141.00
ΔΥΟ ΔΕΚΑ ΑΝΩΝ.ΕΚΔΟ.ΕΤΑΙΡΕΙΑ
43,598.40
ΕΙΔΗΣΕΙΣ ΝΤΟΤ ΚΟΜ ΑΝΩΝ. ΤΗΛΕΟΠ/ΚΗ & ΕΜΠ.ΕΤ. ΠΑΡ.ΠΛ
393,851.26
ΕΚΔΟΣΕΙΣ MOTORI Ε.Π.Ε.
1,500.00
ΕΚΔΟΣΕΙΣ ΕΝΤΥΠΟΥ ΥΛΙΚΟΥ ΚΑΡΑΜΑΝΟΓΛΟΥ Ε.Π.Ε.
3,460.91
ΕΚΔΟΣΕΙΣ Ν.ΠΑΠΑΝΙΚΟΛΑΟΥ ΑΕ
923.39
ΕΚΔΟΣΕΙΣ ΝΈΟ ΧΡΗΜΑ ΑΕ NEWMONEY.GR
96,760.00
ΕΚΔΟΣΕΙΣ ΠΡΩΤΟ ΘΕΜΑ ΕΚΔΟΤΙΚΗ Α.Ε.
522,519.84
ΕΚΔΟΣΕΙΣ ΣΟΦΙΑ ΜΟΣΧΑΝΔΡΕΟΥ & ΣΙΑ ΕΕ
1,560.52
ΕΛΕΥΘΕΡΙΑ ΤΟΥ ΤΥΠΟΥ ΜΟΝ. Α.Ε.
18,600.00
ΕΛΛΗΝΟΓΕΡΜΑΝΙΚΟ ΕΜΠΟΡΙΚΟ & ΒΙΟΜΗΧΑΝΙΚΟ ΕΠΙΜΕΛΗ
1,680.00
ΕΛΝΑΒΙ Ι.Κ.Ε.
1,000.00
ΕΝΙΚΟΣ ΑΝΩΝΥΜΗ ΕΤΑΙΡΕΙΑ
32,651.00
ΕΝΤΥΠΟΕΚΔΟΤΙΚΗ Α.Ε.Β.Ε.Τ.
8,000.00
ΕΞΕΡΕΥΝΗΤΗΣ ΕΞΠΛΟΡΕΡ ΑΕ
12,750.00
ΕΡΙΝΥΑ ΕΙΔΗΣΕΙΣ Μ. ΙΚΕ
9,310.00
ΕΡΩΤΙΚΟΣ ΡΑΔΙΟ ΑΕ
944.40
ΕΣΤΙΑ ΕΠΕΝΔΥΤΙΚΗ ΜΜΕ Α.Ε.
45,000.00
ΕΦΗΜΕΡΙΣ "ΕΣΤΙΑ" ΑΝΩΝΥΜΗ ΕΚΔΟΤΙΚΗ ΕΤΑΙΡΕΙΑ
35,451.62
ΖΟΥΓΚΛΑ ΤΖΙ ΑΡ Α.Ε ΜΜΕ
88,367.00
ΖΩΗ ΛΕΥΚΟΦΡΥΔΟΥ ΙΚΕ
254.03
Η ΕΠΙΚΑΙΡΟΤΗΤΑ ΛΕΜΑΣ ΣΩΤ. ΕΥΑΓΓΕΛΟΣ
234.00
Η ΝΑΥΤΕΜΠΟΡΙΚΗ
82,233.10
ΗΛΙΑΣ ΚΑΝΕΛΛΗΣ & ΣΙΑ ΕΕ
3,300.00
ΗΤ PRESS ONLINE ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ
9,900.00
ΗΧΟΣ ΚΑΙ ΡΥΘΜΟΣ ΜΟΝΟΠΡΟΣΩΠΗ A.E.
18,512.53
ΘΕΜΑ ΡΑΔΙΟ AE
1,605.80
ΘΕΟΧΑΡΗΣ ΣΠΥΡ. ΓΕΩΡΓΙΟΣ
6,100.00
Ι. Κ. ΔΡΑΓΟΥΝΗΣ ΕΚΔΟΣΕΙΣ Ι.Κ.Ε.
5,000.00
Ι.ΔΙΟΝΑΤΟΣ & ΣΙΑ ΕΕ
14,150.00
ΙΚΑΡΟΣ ΡΑΔΙΟΤΗΛΕΟΠΤΙΚΕΣ ΕΠΙΧ/ΣΕΙΣ Α.Ε.
17,976.00
ΙΝΣΤΙΤΟΥΤΟ ΕΡΕΥΝΩΝ & ΜΕΛ. ΤΗΣ ΚΕΝΤ.ΕΝ.ΕΠΙΜ.ΕΛΛ/ΔΟΣ
2,500.00
ΙΟΝΙΚΕΣ ΕΚΔΟΣΕΙΣ Α.Ε.
3,000.00
ΚΑΘΗΜΕΡΙΝΕΣ ΕΚΔΟΣΕΙΣ ΜΟΝΟΠΡΟΣΩΠΗ Α.Ε.
69,998.60
ΚΑΛΟΠΟΥΛΟΥ ΓΕΩ.ΜΑΡΙΑ (WOMANIDOL)
500.00
ΚΑΠΙΤΑΛ.GR A.E.
116,797.50
ΚΛΑΔΙΚΑ ΜΕΣΑ ΜΟΝ Ι.Κ.Ε.
3,900.00
ΚΟΣΜΟΡΑΔΙΟ E.E.
4,411.50
ΚΥΡΙΑΚΟΠΟΥΛΟΣ ΙΩΑΝΝΗΣ ΦΙΛΙΠΠΟΣ
3,000.00
ΚΩΝΣΤΑΝΤΑΚΟΣ ΑΝΤΩΝΙΟΣ ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ
4,000.00
ΛΑΚΩΝΙΚΟΣ ΤΥΠΟΣ ΧΡΙΣΤΙΝΑ ΑΝΝΑ ΧΙΩΤΗ
407.00
ΛΑΜΨΗ ΕΚΔΟΤΙΚΕΣ & ΡΑΔΙΟΦΩΝΙΚΕΣ ΕΠΙΧ/ΣΕΙΣ ΑΕ
5,974.06
ΛΟΓΟΣ ΑΝΩΝΥΜΗ ΕΚΔΟΤΙΚΗ ΕΤΑΙΡΙΑ
100.00
ΜΑΚΕΔΟΝΙΑ ΕΝΗΜΕΡΩΣΗ Α.Ε.
141.51
ΜΑΚΕΔΟΝΙΑ ΤV ΜΟΝΟΠΡΟΣΩΠΗ A.E.
12,774.34
ΜΑΛΤΕΖΟΣ ΔΗΜΗΤΡΙΟΣ ΑΝΔΡΕΑΣ
365.00
ΜΑΡΙΑ ΒΑΣΙΛΑΚΗ ΜΟΝΟΠΡΟΣΩΠΗ ΕΠΕ
9,900.00
ΜΑΡΙΝΑ Γ.ΤΟΥΛΑ & ΣΙΑ ΟΕ
1,400.00
ΜΕΤΡΟΝΤΗΛ ΜΟΝ Ι.Κ.Ε
5,936.10
ΜΠΑΜ ΕΝΗΜΕΡΩΣΗ ΜΟΝ. Ι.Κ.Ε.
7,000.00
ΜΠΟΥΣΙΑΣ ΕΠΙΚΟΙΝΩΝΙΕΣ Ε.Π.Ε.
2,500.00
ΝΕΑ ΤΗΛΕΟΡΑΣΗ ΑΕ
268,114.65
ΝΕΕΣ ΚΑΘΗΜΕΡΙΝΕΣ ΕΚΔΟΣΕΙΣ ΜΟΝ ΑΕ
329,456.00
ΝΕΟΤΥΠΟΓΡΑΦΙΚΗ ΜΟΝΟΠΡΟΣΩΠΗ ΕΠΕ Ο ΛΟΓΟΣ
1,838.92
ΞΑΝΘΗΣ ΧΡΥΣΑΝΘΟΣ
1,000.00
ΟΚΤΑΣ MEDIA ΙΚΕ
38,200.00
ΟΜΙΛΟΣ ΤΟΤΣΗ
169.82
ΟΠΙΝΙΟΝ ΠΟΣΤ ΗΛΕΚΤΡΟΝΙΚΕΣ ΕΚΔΟΣΕΙΣ ΑΕ
5,200.00
ΟΡΓΑΝ.ΜΕΣΩΝ ΜΑΖΙΚΗΣ ΕΠΙΚ/ΝΙΑΣ ΑΕ
2,752.80
546 | ANNUAL FINANCIAL REPORT
PAYMENTS TO MEDIA COMPANIES (Article 6 Par.1 of L.4374/2016)
Name (Names have not been translated into English)
Amounts before taxes
ΟΤΕ Α.Ε
23,296.62
Π.Δ. ΕΚΔΟΣΕΙΣ Ε.Π.Ε.
17,500.00
Π.ΤΣΙΤΑΣ Ε.Ε.
1,500.00
ΠΑΠΑΔΟΠΟΥΛΟΥ ΑΘΑΝΑΣΙΑ & ΣΙΑ ΕΕ
1,400.00
ΠΑΠΑΛΙΟΣ ΚΩΝΣΤΑΝΤΙΝΟΣ & ΣΙΑ Ε.Ε
193.80
ΠΑΠΑΡΟΥΝΗΣ ΦΑΝ.ΜΙΧΑΛΗΣ
297.17
ΠΑΡΑΕΝΑ Ε.Π.Ε.
14,576.60
ΠΑΡΑΠΟΛΙΤΙΚΑ ΕΚΔΟΣΕΙΣ ΑΕ
65,945.00
ΠΕΛΟΠΟΝΝΗΣΟΣ ΠΑΤΡΩΝ ΕΚΔΟΣΕΙΣ ΑΕ
674.53
ΠΟΝΤΟΣ ΜΕΣΑ ΜΑΖΙΚΗΣ ΕΝΗΜΕΡΩΣΗΣ ΜΟΝ. Α.Ε.
5,430.80
ΠΡΟΤΑΓΚΟΝ ΑΝΩΝΥΜΗ ΕΤΑΙΡΕΙΑ
18,501.00
ΠΡΟΤΑΣΙΣ ΚΟΙΝΩΝΙΚΗ ΣΥΝΕΤΑΙΡΙΣΤΙΚΗ ΕΠΙΧΕΙΡΗΣΗ
550.00
ΡΑΔΙΟ ΘΕΣΣΑΛΟΝΙΚΗ AE
9,339.80
ΡΑΔΙΟΤΗΛ/ΚΕΣ ΕΠΙΧΕΙΡΗΣΕΙΣ Α.Ε.
8,927.16
ΡΑΔΙΟΤΗΛΕΟΠΤΙΚΗ ΑΕ
113,123.41
ΡΑΔΙΟΦΩΝΙΚΕΣ ΕΠΙΧ/ΣΕΙΣ RADIO NORTH 98ΦΜ ΕΠΕ
2,552.00
ΡΑΔΙΟΦΩΝΙΚΕΣ ΠΑΡΑΓΩΓΕΣ ΜΟΝ. Α.Ε.
10,488.40
ΡΑΔΙΟΦΩΝΙΚΗ ΕΠΙΚΟΙΝΩΝΙΑ ΑΕ
10,698.54
ΣΕΛΑΝΑ Α.Ε.
6,000.00
ΣΙΜΟΥΣΙ Ε.Ε.
8,215.00
ΣΥΝΕΡΓΑΣΙΑ - ΔΗΜΙΟΥΡΓΙΑ ΚΟΙΝ.Σ.ΕΠ
1,000.00
ΤΥΠΟΣ ΘΕΣΣΑΛΟΝΙΚΗΣ TYPOS MEDIA ΕΠΕ
210.00
ΦΕΛΝΙΚΟΣ ΗΛΕΚΤΡ.ΜΕΣΩΝ ΕΝΗΜΕΡΩΣΗΣ Μ. ΕΠΕ
3,862.00
ΦΙΛΑΘΛΟΣ ΙΚΕ
8,770.00
ΦΙΛΕΛΕΥΘΕΡΟΣ ΤΥΠΟΣ ΜΟΝΟΠΡΟΣΩΠΗ ΑΕ
70,701.00
ΦΩΤΑΓΩΓΟΣ ΕΠΕ
4,470.00
ΦΩΤΗΣ ΤΣΙΜΕΛΑΣ & ΣΙΑ ΕΕ
10,000.00
ΧΑΤΖΗΗΛΙΑΔΗΣ Κ.Μ. & ΣΙΑ Ε.Ε.
1,531.80
Total
6,445,542.03
PAYMENTS TO MEDIA COMPANIES OF AMOUNTS LESS THAN €100 PER MEDIA COMPANY
Name (Names have not been translated into English)
ΕΛΕΥΘΕΡΙΑ ΑΕ ΑΝΩΝΥΜΟΣ ΕΚΔΟΤΙΚΗ ΕΤΑΙΡΕΙΑ
Ι.Δ ΚΟΛΛΑΡΟΥ & ΣΙΑ ΑΕ ΒΙΒΛΙΟΠΩΛΕΙΟ ΤΗΣ ΕΣΤΙΑΣ
ΜΑΚΕΔΟΝΙΚΕΣ ΑΓΓΕΛΙΕΣ
ΜΕΣΣΗΝΙΑΚΟΣ ΛΟΓΟΣ
ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - GRATIA ΕΚΔΟΤΙΚΗ ΙΚΕ
ΠΡΩΙΝΟΣ ΤΥΠΟΣ ΔΡΑΜΑΣ
ΤΥΠΟΚΥΚΛΑΔΙΚΗ Α.Ε.
The above table refers to Media Companies of amounts less than € 100, with total amount equal to € 391.92.
TOTAL FOR MEDIA PAYMENTS
6,445,933.95
Ποσά
TELEVISION TAX PAYMENTS
49,453.21
DIGITAL TAX PAYMENTS 2%
36,155.40
MUNICIPAL FEE PAYMENTS 2%
2,303.33
SPECIAL FEE PAYMENTS 0,02%
1,247.40
SPECIAL FEE PAYMENTS 0,04%
1,248.44
PAYMENTS DUE TO DONATIONS, SPONSORSHIP, SUBSIDIES OR OTHER CHARITABLE REASONS (Article 6 Par. 2 of L.4374/2016)
Α) TO LEGAL ENTITIES
Name (Names have not been translated into English)
Amounts Before Taxes
1ο ΕΙΔΙΚΟ ΝΗΠΙΑΓΩΓΕΙΟ ΚΑΙ ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΓΙΟΥ ΔΗΜΗΤΡΙΟΥ
445.56
1ος ΠΥΡΟΣΒΕΣΤΙΚΟΣ ΣΤΑΘΜΟΣ ΑΘΗΝΩΝ
7,450.00
11TH BANKING FORUM & FINTECH EXPO - IMH C.S.C. LTD
4,000.00
AFFEKT ΑΜΚΕ
5,000.00
ASOCIATIA C.F.A. ROMANIA (CERTIFIED FINANCIAL ANALYSTS)
2,000.00
ASOCIATIA PENTRU EXCELENTA IN ECONOMIE - EXEC
2,000.00
ASOCIATIA PENTRU PROMOVAREA PERFORMANTEI IN EDUCATIE
10,000.00
ASOCIATIA ROMANA A BANCILOR
18,734.00
ASOCIATIA SOCIETATEA PENTRU MUZICA CLASICA
4,000.00
ASOCIATIA UNCHAIN
5,000.00
547 | ANNUAL FINANCIAL REPORT
PAYMENTS DUE TO DONATIONS, SPONSORSHIP, SUBSIDIES OR OTHER CHARITABLE REASONS (Article 6 Par. 2 of L.4374/2016)
Α) TO LEGAL ENTITIES
Name (Names have not been translated into English)
Amounts Before Taxes
BUTTERFLY AVM
230.25
CAMERA DE COMERT SI INDUSTRIE ELENO-ROMANA
5,000.00
CAPITAL LINK
15,000.00
CG&B
4,000.00
EBEN
1,000.00
ETHOS MEDIA AE ΕΚΔΟΤΙΚΗ ΣΥΝΕΔΡΙΑΚΗ
12,000.00
EUROPA DONNA ΚΥΠΡΟΥ
3,000.00
EY / ΕΡΝΣΤ ΚΑΙ ΓΙΑΝΓΚ ΜΟΝΟΠΡΟΣΩΠΗ ΑΝΩΝΥΜΗ ΕΤΑΙΡΙΑ ΠΑΡΟΧΗΣ ΣΥΜΒΟΥΛΕΥΤΙΚΩΝ ΥΠΗΡΕΣΙΩΝ
10,000.00
FUNDATIA DEMOCRATIE PRIN CULTURA
10,000.00
GIVMED SHARE MEDICINE SHARE LIFE ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΟΡΓΑΝΩΣΗ
3,510.00
HAZLIS AND RIVAS COMMUNICATONS LTD
20,000.00
J & P VERITAS IKE
8,000.00
KIDS SAVE LIVES
15,072.00
KYBERNITIS TRΑVEL & SHIPPING S.A.
35,000.00
MORGAN STANLEY
13,723.70
NEVRONAS ΝΕΥΡΩΝΑΣ ΕΡΓΟΘΕΡΑΠΕΥΤΗΣ
5,300.00
PALLADIAN COMMUNICATION SPECIALISTS
5,000.00
RADISSON BLU LARNACA INTERNATIONAL MARATHON
428.57
ROUND TABLE (MOVEMBER CYPRUS)
2,050.00
ROYAL NATIONAL INSTITUTE OF BLIND PEOPLE
460.50
SAFE WATERSPORTS ΝΠΙΔ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΟ ΣΩΜΑΤΕΙΟ
10,000.00
SAFER INTERNET HELLAS
2,000.00
SANIKOS GROUP
60,000.00
SCICO ΕΠΙΣΤΗΜΗ ΕΠΙΚΟΙΝΩΝΙΑ ΑΜΚΕ
52,800.00
SOLIDARITY NOW ΦΙΛΑΝΘΡΩΠΙΚΟ ΣΩΜΑΤΕΙΟ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΟ
13,500.00
SPECIAL OLYMPICS CYPRUS
1,000.00
SSA SOLD OUT LTD - BΡΑΒΕΙΑ MADAME FIGARO ΓΥΝΑΙΚΕΣ ΤΗΣ ΧΡΟΝΙΑΣ 2023
660.00
THE ART OF MUSIC
100.00
WORLD HUMAN FORUM ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΕΙΑ
30,000.00
ΑΓΑΝΤΑ ΑΜΚΕ
3,000.00
ΑΓΙΟΣ ΣΑΒΒΑΣ ΓΕΝΙΚΟ ΑΝΤΙΚΑΡΚΙΝΙΚΟ - ΟΓΚΟΛΟΓΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΑΘΗΝΩΝ
18,240.00
ΑΓΟΝΗ ΓΡΑΜΜΗ ΓΟΝΙΜΗ ΑΜΚΕ
22,100.00
ΑΘΛΗΤΙΚΟΣ ΟΜΙΛΟΣ ΑΘΗΝΩΝ ΥΑΔΕΣ
1,000.00
ΑΘΛΗΤΙΚΟΣ ΣΥΛΛΟΓΟΣ ΑΤΛΑΣ
5,000.00
ΑΛΕΚΟΣ ΦΑΣΙΑΝΟΣ ΑΜΚΕ
43,464.00
ΑΝΤΙΚΑΡΚΙΝΙΚΟΣ ΣΥΝΔΕΣΜΟΣ ΚΥΠΡΟΥ
800
ΑΝΩΝΥΜΗ ΚΤΗΜΑΤΙΚΗ ΚΑΙ ΤΟΥΡΙΣΤΙΚΗ ΕΤΑΙΡΙΑ Η ΞΕΝΙΑ Α.Ε.
5,000.00
ΑΝΩΤΑΤΗ ΣΧΟΛΗ ΚΑΛΩΝ ΤΕΧΝΩΝ
1,571.60
ΑΡΧΑΙΟΛΟΓΙΚΟ ΜΟΥΣΕΙΟ ΚΑΒΑΛΑΣ
654.20
ΒΕΡΤΙΚΑΛ ΣΟΛΟΥΣΙΟΝΣ ΑΕ
10,000.00
Γ.Ν.Α. ΚΑΤ
3,200.00
Γ.Ν.Α. ΛΑΪΚΟ
4,830.00
ΓΕΝΙΚΗ ΑΣΤΥΝΟΜΙΚΗ ΔΙΕΥΘΥΝΣΗ ΘΕΣΣΑΛΟΝΙΚΗΣ / ΥΠΟΔΙΕΥΘΥΝΣΗ ΚΡΑΤΙΚΗΣ ΑΣΦΑΛΕΙΑΣ
4,576.52
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΑΘΗΝΩΝ Ο ΕΥΑΓΓΕΛΙΣΜΟΣ
63,900.00
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΑΙΤΩΛΟΑΚΑΡΝΑΝΙΑΣ
1,208.00
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΘΕΣΣΑΛΟΝΙΚΗΣ "Γ. ΓΕΝΝΗΜΑΤΑΣ - ΑΓΙΟΣ ΔΗΜΗΤΡΙΟΣ"
4,000.00
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΘΕΣΣΑΛΟΝΙΚΗΣ "Ο ΑΓΙΟΣ ΔΗΜΗΤΡΙΟΣ"
3,985.00
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΚΟΡΓΙΑΛΕΝΕΙΟ ΜΠΕΝΑΚΕΙΟ
6,129.02
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΠΑΙΔΩΝ ΠΑΤΡΩΝ ΚΑΡΑΜΑΝΔΑΝΕΙΟ
1,175.00
ΓΕΝΚΑ ΑΕ
4,000.00
ΓΙΑΤΡΟΙ ΧΩΡΙΣ ΣΥΝΟΡΑ
3,000.00
ΓΡΑΜΜΗ ΖΩΗΣ ΕΛΛΑΣ ΑΝΘΡΩΠΙΣΤΙΚΟΣ ΟΡΓΑΝΙΣΜΟΣ LIFELINE HELLAS
1,000.00
ΔΗΜΙΟΥΡΓΙΚΟ ΕΡΓΑΣΤΗΡΙ ΑΓΙΑΣ ΤΡΙΑΔΑΣ ΣΤΑΥΡΟΔΡΟΜΙΟΥ
363.39
ΔΗΜΟΣ ΡΟΔΟΥ
3,271.65
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΣΤΥΠΑΛΑΙΑΣ
36,787.50
ΔΙΑΒΑΖΩ ΓΙΑ ΤΟΥΣ ΑΛΛΟΥΣ
16,300.00
ΔΙΑΖΩΜΑ
5,000.00
ΔΙΕΥΘΥΝΣΗ ΑΣΦΑΛΕΙΑΣ ΑΤΤΙΚΗΣ - ΥΠΟΔΙΕΥΘΥΝΣΗ ΚΡΑΤΙΚΗΣ ΑΣΦΑΛΕΙΑΣ
1,213.97
ΔΙΚΤΥΟ ΓΙΑ ΤΗ ΜΕΤΑΡΡΥΘΜΙΣΗ ΣΤΗΝ ΕΛΛΑΔΑ ΚΑΙ ΤΗΝ ΕΥΡΩΠΗ - ΣΩΜΑΤΕΙΟ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΟΥ ΧΑΡΑΚΤΗΡΑ
3,000.00
ΕΘΕΛΟΝΤΕΣ ΠΥΡΟΣΒΕΣΤΕΣ - ΡΟΔΟΣ
3,625.00
ΕΘΕΛΟΝΤΙΚΗ ΟΜΑΔΑ ΠΥΡΟΣΒΕΣΗΣ ΔΙΑΣΩΣΗΣ ΔΗΜΟΥ ΚΗΦΙΣΙΑΣ
20,450.00
ΕΘΝΙΚΗ ΛΥΡΙΚΗ ΣΚΗΝΗ
110,000.00
ΕΘΝΙΚΟ ΘΕΑΤΡΟ Ν.Π.Ι.Δ.
40,000.00
ΕΘΝΙΚΟ ΙΔΡΥΜΑ ΕΡΕΥΝΩΝ
4,000.00
ΕΘΝΙΚΟ ΚΕΝΤΡΟ ΕΡΕΥΝΑΣ ΚΑΙ ΤΕΧΝΟΛΟΓΙΚΗΣ ΑΝΑΠΤΥΞΗΣ (Ε.Κ.Ε.Τ.Α.)
5,000.00
548 | ANNUAL FINANCIAL REPORT
PAYMENTS DUE TO DONATIONS, SPONSORSHIP, SUBSIDIES OR OTHER CHARITABLE REASONS (Article 6 Par. 2 of L.4374/2016)
Α) TO LEGAL ENTITIES
Name (Names have not been translated into English)
Amounts Before Taxes
ΕΘΟΜΑΚ ΣΑΛΑΚΟΥ
5,600.00
ΕΙΔΙΚΟ ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΓΙΑ ΠΑΙΔΙΑ ΜΕ ΕΓΚΕΦΑΛΙΚΗ ΠΑΡΑΛΥΣΗ
504.26
ΕΙΔΙΚΟ ΚΕΝΤΡΟ ΕΦΟΔΙΑΣΜΟΥ ΜΟΝΑΔΩΝ ΣΤΡΑΤΟΥ (ΕΚΕΜΣ)
6,008.40
ΕΙΔΙΚΟ ΝΗΠΙΑΓΩΓΕΙΟ ΚΩΦΩΝ ΚΑΙ ΒΑΡΗΚΟΩΝ ΑΡΓΥΡΟΥΠΟΛΗΣ
127.58
ΕΛΚΕ ΑΡΙΣΤΟΤΕΛΕΙΟ ΠΑΝΕΠΙΣΤΗΜΙΟ ΘΕΣΣΑΛΟΝΙΚΗΣ
134.52
ΕΛΚΕ ΕΘΝΙΚΟΥ ΚΑΙ ΚΑΠΟΔΙΣΤΡΙΑΚΟΥ ΠΑΝΕΠΙΣΤΗΜΙΟΥ ΑΘΗΝΩΝ
29,000.00
ΕΛΚΕ ΠΑΝΕΠΙΣΤΗΜΙΟΥ ΔΥΤΙΚΗΣ ΑΤΤΙΚΗΣ
30,000.00
ΕΛΚΕ ΠΑΝΕΠΙΣΤΗΜΙΟΥ ΘΕΣΣΑΛΙΑΣ
51,000.00
ΕΛΚΕ ΠΑΝΤΕΙΟΥ ΠΑΝΕΠΙΣΤΗΜΙΟΥ
5,000.00
ΕΛΚΕ ΠΟΛΥΤΕΧΝΕΙΟΥ ΚΡΗΤΗΣ
10,000.00
ΕΛΛΗΝΙKΗ ΜΑΘΗΜΑΤΙΚΗ ΕΤΑΙΡΕΙΑ
400.00
ΕΛΛΗΝΙΚΗ ΔΗΜΟΚΡΑΤΙΑ ΥΠΟΥΡΓΕΙΟ ΕΣΩΤΕΡΙΚΩΝ ΚΑΙ ΔΙΟΙΚΗΤΙΚΗΣ ΑΝΑΣΥΓΚΡΟΤΗΣΗΣ ΑΡΧΗΓΕΙΟ ΕΛΛΗΝΙΚΗΣ
ΑΣΤΥΝΟΜΙΑΣ
242.35
ΕΛΛΗΝΙΚΟ ΙΔΡΥΜΑ ΚΑΡΔΙΟΛΟΓΙΑΣ
500.00
ΕΛΛΗΝΙΚΟ ΙΝΣΤΙΤΟΥΤΟ ΠΑΣΤΕΡ
10,000.00
ΕΛΛΗΝΙΚΟ ΚΕΝΤΡΟ ΘΑΛΑΣΣΙΩΝ ΕΡΕΥΝΩΝ
5,000.00
ΕΛΛΗΝΙΚΟΣ ΕΡΥΘΡΟΣ ΣΤΑΥΡΟΣ
5,000.00
ΕΜΠΟΡΙΚΟΣ KAI EΠΙΧΕΙΡΗΜΑΤΙΚΟΣ ΣΥΛΛΟΓΟΣ ΝΑΥΠΛΙΟΥ
500.00
ΕΜΠΟΡΟΕΠΑΓΓΕΛΜΑΤΙΚΟΣ ΚΑΙ ΒΙΟΤΕΧΝΙΚΟΣ ΣΥΛΛΟΓΟΣ ΤΗΝΟΥ
300.00
ΕΝΕΡΓΕΙΑΚΗ ΚΑΜΠΟΥ ΔΗΜΟΥ ΚΑΡΔΙΤΣΑΣ
1,500.00
ΕΝΩΣΗ ΑΣΦΑΛΙΣΤΙΚΩΝ ΕΤΑΙΡΕΙΩΝ ΕΛΛΑΔΟΣ (ΕΑΕΕ)
17,964.79
ΕΝΩΣΗ ΕΛΛΗΝΙΚΩΝ ΤΡΑΠΕΖΩΝ (ΕΙΣΦΟΡΑ για ΘΕΣΣΑΛΙΑ)
235,000.00
ΕΝΩΣΗ ΘΕΣΜΙΚΩΝ ΕΠΕΝΔΥΤΩΝ
7,500.00
ΕΝΩΣΗ ΞΕΝΟΔΟΧΩΝ ΡΟΔΟΥ
30,000.00
ΕΠΙΣΕΥ ΕΡΕΥΝΗΤΙΚΟ ΠΑΝΕΠΙΣΤΗΜΙΑΚΟ ΙΝΣΤΙΤΟΥΤΟ ΣΥΣΤΗΜΑΤΩΝ, ΕΠΙΚΟΙΝΩΝΙΩΝ ΚΑΙ ΥΠΟΛΟΓΙΣΤΩΝ
15,000.00
ΕΡΑΣΙΤΕΧΝΙΚΗ ΟΜΑΔΑ ΚΑΛΑΘΟΣΦΑΙΡΑΣ PN99
300.00
ΕΤΑΙΡΕΙΑ ΑΞΙΟΠΟΙΗΣΕΩΣ ΚΑΙ ΔΙΑΧΕΙΡΙΣΕΩΣ ΤΟΥ ΟΙΚΟΝΟΜΙΚΟΥ ΠΑΝΕΠΙΣΤΗΜΙΟΥ ΑΘΗΝΩΝ Α.Ε.
1,000.00
ΕΤΑΙΡΕΙΑ ΑΡΧΙΠΕΛΑΓΟΣ ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ
7,000.00
ΕΤΑΙΡΕΙΑ ΠΡΟΣΤΑΣΙΑΣ ΣΠΑΣΤΙΚΩΝ
5,375.00
Ι.Μ.ΣΕΡΡΩΝ ΚΑΙ ΝΙΓΡΙΤΗΣ
1,000.00
ΙΔΡΥΜΑ ΒΑΣΙΛΗ ΚΑΙ ΕΛΙΖΑΣ ΓΟΥΛΑΝΔΡΗ
60,000.00
ΙΔΡΥΜΑ ΕΥΣΤΑΘΙΑΣ Ι. ΚΩΣΤΟΠΟΥΛΟΥ
200,100.00
ΙΔΡΥΜΑ ΚΩΝΣΤΑΝΤΙΝΟΣ ΣΗΜΙΤΗΣ
3,000.00
ΙΔΡΥΜΑ ΜΟΥΣΕΙΟΥ ΜΑΚΕΔΟΝΙΚΟΥ ΑΓΩΝΑ
4,000.00
ΙΔΡΥΜΑ 'ΣΟΦΙΑ ΓΙΑ ΤΑ ΠΑΙΔΙΑ' - ΣΥΜΜΕΤΟΧΗ ΠΡΟΣΩΠΙΚΟΥ ΣΤΟΝ ΕΤΑΙΡΙΚΟ ΑΓΩΝΑ 'RUNNING UNDER THE MOON'
200.00
ΙΣΡΑΗΛΙΤΙΚΗ ΚΟΙΝΟΤΗΤΑ ΙΩΑΝΝΙΝΩN
5,000.00
ΙΤΑΛΙΚΗ ΠΡΕΣΒΕΙΑ
2,800.00
ΙΩΝΑΣ ΤΜΗΜΑ ΘΕΡΑΠΕΥΤΙΚΗΣ ΑΓΩΓΗΣ ΑΜΕΑ
200.00
ΚΑΝΕ ΜΙΑ ΕΥΧΗ ΕΛΛΑΔΟΣ (ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΕΙA)/KANE MIA EYXH
3,000.00
ΚΑΤΑΣΚΗΝΩΝΣΕΙΣ ΧΑΡΟΥΜΕΝΑ ΠΑΙΔΙΑ ΧΑΡΟΥΜΕΝΑ ΝΙΑΤΑ
2,000.00
ΚΕΝΤΡΟ ΕΙΔΙΚΩΝ ΑΤΟΜΩΝ Η ΧΑΡΑ
750.00
ΚΕΝΤΡΟ ΕΝΗΜΕΡΩΣΗΣ ΚΑΙ ΘΕΡΑΠΕΙΑΣ ΕΞΑΡΤΗΜΕΝΩΝ ΑΤΟΜΩΝ (ΚΕΝΘΕΑ)
100.00
ΚΕΝΤΡΟ ΠΑΡΟΧΗΣ ΚΟΙΝΩΝΙΚΩΝ ΥΠΗΡΕΣΙΩΝ ΑΝΔΡΕΑΣ ΣΟΦΟΚΛΕΟΥΣ (ΚΕΠΑΚΥ)
500.00
ΚΠΙΣΝ
10,000.00
ΚΥΠΡΙΑΚΗ ΑΘΛΗΤΙΚΗ ΟΜΟΣΠΟΝΔΙΑ ΑΤΟΜΩΝ ΜΕ ΑΝΑΠΗΡΙΑ
100.00
ΚΥΠΡΙΑΚΟΣ ΕΡΥΘΡΟΣ ΣΤΑΥΡΟΣ
200.00
ΛΥΚΕΙΟ ΑΓΙΟΥ ΝΕΟΦΥΤΟΥ ΠΑΦΟΥ
200.00
ΛΥΡΕΙΟ ΕΚΚΛΗΣΙΑΣΤΙΚΟ ΠΑΙΔΙΚΟ ΙΔΡΥΜΑ ΟΙ ΑΓΙΟΙ ΑΝΑΡΓΥΡΟΙ
350.00
ΜΟΥΣΕΙΟ ΜΠΕΝΑΚΗ
500.00
ΜΠΟΡΟΥΜΕ SAVING FOOD – SAVING LIVES
10,000.00
ΝΑΥΤΕΜΠΟΡΙΚΗ
10,000.00
ΝΟΜΙΚΗ ΒΙΒΛΙΟΘΗΚΗ
1,000.00
ΟΜΑΔΑ ΕΘΕΛΟΝΤΩΝ ΔΑΣΟΠΥΡΟΣΒΕΣΤΩΝ ΔΙΑΣΩΣΤΩΝ
5,000.00
ΟΡΓΑΝΙΣΜΟΣ ΜΕΓΑΡΟΥ ΜΟΥΣΙΚΗΣ ΑΘΗΝΩΝ
49,660.38
ΟΡΓΑΝΙΣΜΟΣ ΜΕΓΑΡΟΥ ΜΟΥΣΙΚΗΣ ΘΕΣΣΑΛΟΝΙΚΗΣ
25,000.00
ΟΡΦΑΝΟΤΡΟΦΕΙΟ ΘΗΛΕΩΝ ΙΩΑΝΝΟΥ ΚΑΙ ΜΑΡΙΓΟΥΣ ΧΑΤΖΗΚΥΡΙΑΚΟΥ
1,500.00
ΟΦΘΑΛΜΙΑΤΡΕΙΟ ΑΘΗΝΩΝ
2,035.40
ΠΑΓΚΥΠΡΙΑ ΟΡΓΑΝΩΣΗ ΤΥΦΛΩΝ (Π.Ο.Τ)
100.00
ΠΑΓΚΥΠΡΙΟ ΣΥΝΤΟΝΙΣΤΙΚΟ ΣΥΜΒΟΥΛΙΟ ΕΘΕΛΟΝΤΙΣΜΟΥ
2,000.00
ΠΑΓΚΥΠΡΙΟ ΣΥΝΤΟΝΙΣΤΙΚΟ ΣΥΜΒΟΥΛΙΟ ΕΘΕΛΟΝΤΙΣΜΟΥ - ΣΤΗΡΙΞΗ ΕΚΣΤΡΑΤΕΙΑΣ 'ΥΙΟΘΕΤΗΣΤΕ ΜΙΑ ΟΙΚΟΓΕΝΕΙΑ
ΤΑ ΧΡΙΣΤΟΥΓΕΝΝΑ'
1,000.00
ΠΑΓΚΥΠΡΙΟΣ ΑΝΤΙΝΑΡΚΩΤΙΚΟΣ ΣΥΝΔΕΣΜΟΣ
50.00
ΠΑΓΚΥΠΡΙΟΣ ΣΥΝΔΕΣΜΟΣ ΚΑΡΚΙΝΟΠΑΘΩΝ ΚΑΙ ΦΙΛΩΝ - ΠΑΣΥΚΑΦ ΠΑΦΟΥ
100.00
ΠΑΓΚΥΠΡΙΟΣ ΣΥΝΔΕΣΜΟΣ ΚΑΡΚΙΝΟΠΑΘΩΝ ΚΑΙ ΦΙΛΩΝ (ΠΑΣΥΚΑΦ)
160.00
ΠΑΓΚΥΠΡΙΟΣ ΣΥΝΔΕΣΜΟΣ ΦΙΛΩΝ ΝΕΦΡΟΠΑΘΩΝ
5,000.00
549 | ANNUAL FINANCIAL REPORT
PAYMENTS DUE TO DONATIONS, SPONSORSHIP, SUBSIDIES OR OTHER CHARITABLE REASONS (Article 6 Par. 2 of L.4374/2016)
Α) TO LEGAL ENTITIES
Name (Names have not been translated into English)
Amounts Before Taxes
ΠΑΝΕΠΙΣΤΗΜΙΑΚΟ Γ. Ν. ΑΛΕΞΑΝΔΡΟΥΠΟΛΗΣ
144.00
ΠΑΝΕΠΙΣΤΗΜΙΟ ΑΙΓΑΙΟΥ
40,070.35
ΠΑΝΕΠΙΣΤΗΜΙΟ ΚΥΠΡΟΥ
1,000.00
ΠΑΝΕΠΙΣΤΗΜΙΟ ΠΕΙΡΑΙΩΣ ΕΙΔΙΚΟΣ ΛΟΓ/ΣΜΟΣ (Ε.Λ.Κ.Ε.)
12,000.00
ΠΑΡΑΟΛΥΜΠΙΟΝΙΚΗΣ ΑΘΛΗΤΗΣ BOCCIA ΓΡΗΓΟΡΙΟΣ ΠΟΛΥΧΡΟΝΙΔΗΣ
3,000.00
ΠΕΡΙΦΕΡΕΙΑ ΝΟΤΙΟΥ ΑΙΓΑΙΟΥ
300,300.00
ΠΟΛΙΤΙΣΤΙΚΟ ΙΔΡΥΜΑ ALPHA BANK
15,000.00
ΠΡΟΓΡΑΜΜΑ ΜΑΖΙ ΜΕ ΣΤΟΧΟ ΤΗΝ ΠΑΙΔΕΙΑ
52,050.00
ΠΡΟΓΡΑΜΜΑ ΜΑΖΙ ΜΕ ΣΤΟΧΟ ΤΗΝ ΥΓΕΙΑ
78,000.00
ΠΡΟΓΡΑΜΜΑ ΠΑΡΑΟΛΥΜΠΙΟΝΙΚΩΝ - ΓΡΗΓΟΡΗΣ ΠΟΛΥΧΡΟΝΙΔΗΣ
15,864.27
ΠΡΟΓΡΑΜΜΑ ΠΑΡΑΟΛΥΜΠΙΟΝΙΚΩΝ - ΝΑΣΟΣ ΓΚΑΒΕΛΑΣ
15,000.00
ΠΥΡΟΣΒΕΣΤΙΚΟ ΣΩΜΑ
2,750.00
ΡΑΔΙΟΜΑΡΑΘΩΝΙΟΣ 2023
3,000.00
Σ.ΑΥΓΟΥΛΕΑ - ΛΙΝΑΡΔΑΤΟΥ ΑΝΩΝΥΜΗ ΕΚΠΑΙΔΕΥΤΙΚΗ ΕΤΑΙΡΕΙΑ
1,000.00
ΣΠΙΤΙΑ ΤΗΣ ΕΛΠΙΔΑΣ - HOPE FOR CHILDREN
1,500.00
ΣΥΛΛΟΓΟΣ ΕΘΕΛΟΝΤΩΝ ΠΥΡΟΣΒΕΣΤΩΝ ΡΟΔΟΥ
3,350.00
ΣΥΛΛΟΓΟΣ ΕΠΑΓΓΕΛΜΑΤΙΩΝ ΚΑΙ ΕΜΠΟΡΩΝ ΕΥΟΣΜΟΥ-ΕΛΕΥΘΕΡΙΟΥ-ΚΟΡΔΕΛΙΟΥ
500.00
ΣΥΛΛΟΓΟΣ ΗΛΙΟΣ
1,500.00
ΣΥΛΛΟΓΟΣ ΦΙΛΩΝ ΑΜΕΡΙΚΑΝΙΚΗΣ ΓΕΩΡΓΙΚΗΣ ΣΧ. ΘΕΣΣ.
52,000.00
ΣΥΛΛΟΓΟΣ ΦΙΛΩΝ ΓΡΑΜΜΑΤΩΝ ΚΑΙ ΤΕΧΝΩΝ ΣΕΡΡΩΝ
700.00
ΣΥΜΠΛΕΥΣΗ ΑΜΚΕ
7,300.00
ΣΥΝΔΕΣΜΟΣ ΈΝΑ ΟΝΕΙΡΟ ΜΙΑ ΕΥΧΗ
1,500.00
ΣΥΝΔΕΣΜΟΣ ΒΑΓΟΝΙ ΑΓΑΠΗΣ
1,550.00
ΣΥΝΔΕΣΜΟΣ ΓΟΝΕΩΝ Α' ΔΗΜΟΤΙΚΟΥ ΣΧΟΛΕΙΟΥ ΑΓΙΟΥ ΔΟΜΕΤΙΟΥ
100.00
ΣΥΝΔΕΣΜΟΣ ΓΟΝΕΩΝ ΚΑΙ ΚΗΔΕΜΟΝΩΝ ΓΥΜΝΑΣΙΟΥ ΑΚΡΟΠΟΛΗΣ
100.00
ΣΥΝΔΕΣΜΟΣ ΓΟΝΕΩΝ ΚΑΙ ΚΗΔΕΜΟΝΩΝ ΔΗΜΟΣΙΟΥ ΝΗΠΙΑΓΩΓΕΙΟΥ ΕΡΓΑΤΩΝ
100.00
ΣΥΝΔΕΣΜΟΣ ΓΟΝΕΩΝ ΚΑΙ ΚΗΔΕΜΟΝΩΝ ΔΗΜΟΤΙΚΟΥ ΣΧΟΛΕΙΟΥ ΠΥΡΓΟΥ ΛΕΜΕΣΟΥ
100.00
ΣΥΝΔΕΣΜΟΣ ΓΟΝΕΩΝ ΛΥΚΕΙΟΥ ΑΠ. ΒΑΡΝΑΒΑ
100.00
ΣΥΝΔΕΣΜΟΣ ΕΠΙΧΕΙΡΗΣΕΩΝ ΚΑΙ ΒΙΟΜΗΧΑΝΙΩΝ
5,000.00
ΣΥΝΔΕΣΜΟΣ ΘΕΣΣΑΛΙΚΩΝ ΕΠΙΧΕΙΡΗΣΕΩΝ ΚΑΙ ΒΙΟΜΗΧΑΝΙΩΝ
1,000.00
ΣΥΝΔΕΣΜΟΣ ΦΙΛΩΝ ΙΔΡΥΜΑΤΟΣ ΧΡΙΣΤΟΥ ΣΤΕΛΙΟΥ ΙΩΑΝΝΟΥ
250.00
ΣΥΝΔΙΚΑΛΙΣΤΙΚΗ ΕΝΩΣΗ ΑΣΤΥΝΟΜΙΚΩΝ ΥΠΑΛΛΗΛΩΝ ΑΛΕΞΑΝΔΡΟΥΠΟΛΗΣ
4,032.26
ΣΥΝΕΔΡΙΟ PRODEXPO 2023
10,540.00
ΣΧΟΛΗ ΚΩΦΩΝ - ΓΕΩΡΓΙΟΣ ΜΑΡΚΟΥ
151.80
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ ΠΡΩΤΟΒΑΘΜΙΑΣ ΕΚΠΑΙΔΕΥΣΗΣ ΔΗΜΟΥ ΚΥΘΝΟΥ
1,000.00
ΣΩΜΑΤΕΙΟ ΑΡΕΜΕΝΙΩΝ ΝΕΩΝ Α.Υ.Μ.Α
200.00
ΣΩΜΑΤΕΙΟ ΦΙΛΟΙ ΚΟΙΝΩΝΙΚΗΣ ΠΑΙΔΙΑΤΡΙΚΗΣ ΚΑΙ ΙΑΤΡΙΚΗΣ ΑΝΟΙΧΤΗ ΑΓΚΑΛΙΑ
3,000.00
ΤΑΜΕΙΟ ΕΥΗΜΕΡΙΑΣ ΣΧΟΛΗΣ ΚΩΦΩΝ ΠΑΙΔΩΝ
400.00
ΤΡΑΠΕΖΑ ΧΡΩΜΑΤΟΣ / VITEX
806.45
ΥΠΟΔΙΕΥΘΥΝΣΗ ΑΣΦΑΛΕΙΑΣ ΑΘΗΝΩΝ
790.00
ΦΑΡΙΣ ΚΟΙΝΩΦΕΛΗΣ ΕΠΙΧΕΙΡΗΣΗ ΔΗΜΟΥ ΚΑΛΑΜΑΤΑΣ
10,000.00
ΦΕΣΤΙΒΑΛ ΚΙΝΗΜΑΤΟΓΡΑΦΟΥ ΘΕΣΣΑΛΟΝΙΚΗΣ
50,000.00
ΦΙΛΑΝΘΡΩΠΙΚΟΣ ΣΥΝΔΕΣΜΟΣ "ΙΘΑΚΗ"
20.00
ΦΙΛΑΝΘΡΩΠΙΚΟΣ ΣΥΝΔΕΣΜΟΣ ΣΤΗΡΙΞΗΣ ΑΤΟΜΩΝ ΜΕ ΑΝΟΙΑ 'ΙΘΑΚΗ'
100.00
ΦΛΟΓΑ ΣΥΛΛΟΓΟΣ ΓΟΝΙΩΝ ΠΑΙΔΙΩΝ ΜΕ ΝΕΟΠΛΑΣΜΑΤΙΚΕΣ ΑΣΘΕΝΕΙΕΣ
500.00
ΧΡΙΣΤΙΑΝΙΚΟΣ ΣΥΝΔΕΣΜΟΣ ΑΓΙΟΥ ΓΕΩΡΓΙΟΥ ΑΓΛΑΝΤΖΙΑΣ
500.00
TOTAL TO LEGAL ENTITIES
2,442,741.25
DONATIONS OF FIXED ASSETS
Name (Names have not been translated into English)
11ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΓΡΙΝΙΟΥ
145ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΘΗΝΩΝ
152 ΝΗΠΙΑΓΩΓΕΙΟ ΑΘΗΝΩΝ
19ο ΝΗΠΙΑΓΩΓΕΙΟ ΘΕΣΣΑΛΟΝΙΚΗΣ
1ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΙΕΡΑΠΕΤΡΑΣ
1ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΚΑΛΛΙΘΕΑΣ
1ο ΚΔΑΠ ΔΗΜΟΥ ΜΕΣΟΛΟΓΓΙΟΥ
2/ΘΕΣΙΟ ΝΗΠΙΑΓΩΓΕΙΟ ΑΓΙΩΝ ΣΑΡΑΝΤΑ
24 ΕΠΙΛΑΡΧΙΑ ΜΕΣΩΝ ΑΡΜΑΤΩΝ
2o ΝΗΠΙΑΓΩΓΕΙΟ ΦΕΡΩΝ ΒΕΛΕΣΤΙΝΟΥ
2ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΚΟΜΟΤΗΝΗΣ
2ο ΗΜΕΡΗΣΙΟ ΕΠΑ.Λ. ΙΛΙΟΥ
41ο ΔΗΜΟΤΙΚΟ ΚΑΙ 31ο ΝΗΠΙΑΓΩΓΕΙΟ ΠΑΤΡΑΣ
550 | ANNUAL FINANCIAL REPORT
DONATIONS OF FIXED ASSETS
Name (Names have not been translated into English)
4ο ΓΥΜΝΑΣΙΟ ΙΛΙΟΥ
4ο ΝΗΠΙΑΓΩΓΕΙΟ ΜΕΣΣΗΝΗΣ
5/Θ ΔΗΜ.ΣΧΟΛΕΙΟ ΧΡΥΣΑΣ-ΤΣΑΚΩ-ΡΟΔΩΝΙ
6ο ΓΕΛ ΚΑΛΑΜΑΤΑΣ
6ο ΠΕΙΡΑΜΑΤΙΚΟ ΓΥΜΝΑΣΙΟ
77ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΘΗΝΩΝ
7ο ΓΥΜΝΑΣΙΟ ΝΙΚΑΙΑΣ
8ο ΓΥΜΝΑΣΙΟ ΚΟΡΥΔΑΛΛΟΥ
9ο ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΑΙΓΙΟΥ
HUMANS UNITED GLOBAL PONTS FOR KID
Α. Τ. ΑΕΡΟΛΙΜΕΝΟΣ ΑΘΗΝΩΝ (ΣΠΑΤΑ)
Α.Ο. ΙΩΝΙΚΟΣ ΝΙΚΑΙΑΣ
Α.Τ. ΔΙΟΝΥΣΟΥ
Α.Τ. ΙΛΙΟΥ
ΑΔΕΛΦΟΤΗΤΑ ΛΕΥΚΑΔΙΤΙΩΤΩΝ ΔΩΡΙΔΟΣ
ΑΗΕΡΑ - ATHENS CHAPTER HJ001
ΑΘΛΗΤΙΚΟΣ ΚΑΙ ΕΞΩΡΑΪΣΤΙΚΟΣ ΣΥΛΛΟΓΟΣ
ΑΘΛΗΤΙΚΟΣ ΟΜΙΛΟΣ ΣΕΡΙΦΟΥ
ΑΡΧΗΓΕΙΟ ΕΛΛΗΝΙΚΗΣ ΑΣΤΥΝΟΜΙΑΣ
ΑΣΤ. ΤΜΗΜΑ ΚΟΡΥΔΑΛΛΟΥ
ΑΣΤΥΝ.ΣΤΑΘΜΟΣ ΟΛΥΜΠΟΥ ΚΑΡΠΑΘΟΥ
ΑΣΤΥΝΟΜΙΑ ΤΡΙΚΑΛΩΝ
ΑΣΤΥΝΟΜΙΚΟ ΤΜΗΜΑ ΚΑΡΠΑΘΟΥ
ΓΑΔΑ 3ο ΤΜΗΜΑ ΕΣΩΤΕΡΙΚΩΝ ΛΕΙΤΟΥΡΓΙΩΝ
ΓΕΛ ΣΑΜΟΘΡΑΚΗΣ
ΓΕΝΙΚΟ ΛΥΚΕΙΟ ΔΟΜΕΝΙΚΟΥ
ΓΕΝΙΚΟ ΝΟΣΟΚΟΜΕΙΟ ΑΛΕΞΑΝΔΡΟΥΠΟΛΗΣ
Δ ΕΑΝ ΣΤΡΑΤΟΥ
Δ/ΝΣΗ Β/ΒΑΘΜΙΑΣ ΕΚΠ Γ ΑΘΗΝΑΣ
Δ/ΝΣΗ Β/ΘΜΙΑΣ ΕΚΠ/ΣΗΣ ΚΥΚΛΑΔΩΝ
ΔΗΜΟΣ ΑΓ. ΑΝΑΡΓΥΡΩΝ ΚΑΜΑΤΕΡΟΥ
ΔΗΜΟΣ ΑΝΔΡΑΒΙΔΑΣ - ΚΥΛΛΗΝΗΣ
ΔΗΜΟΣ ΒΑΡΗΣ ΒΟΥΛΑΣ ΒΟΥΛΙΑΓΜΕΝΗΣ
ΔΗΜΟΣ ΔΙΟΝΥΣΟΥ
ΔΗΜΟΣ Ι.Π. ΜΕΣΟΛΟΓΓΙΟΥ
ΔΗΜΟΣ ΝΑΥΠΑΚΤΙΑΣ
ΔΗΜΟΣ ΠΕΡΙΣΤΕΡΙΟΥ ΝΠΔΔ ΕΝΝΙΑΙΑ ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ
ΔΗΜΟΣ ΠΕΤΡΟΥΠΟΛΗΣ
ΔΗΜΟΣ ΡΑΦΗΝΑΣ - ΠΙΚΕΡΜΙΟΥ
ΔΗΜΟΣ ΡΑΦΗΝΑΣ - ΠΙΚΕΡΜΙΟΥ
ΔΗΜΟΣ ΣΠΑΤΩΝ-ΑΡΤΕΜΙΔΟΣ
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΓΙΑΝΝΙΤΣΟΧΩΡΙΟΥ
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΛΕΧΑΙΝΩΝ
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΜΑΚΡΙΣΙΩΝ
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΝΕΑΣ ΡΑΙΔΕΣΤΟΥ ΘΕΣ.
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΣΙΦΝΟΥ
ΔΗΜΟΤΙΚΟ ΣΧΟΛΕΙΟ ΣΠΕΡΧΟΓΕΙΑΣ
ΔΝΣΗ ΑΛΛΟΔΑΠΩΝ ΑΤΤΙΚΗΣ
ΔΡΑΣΙΣ ΑΓΑΠΗΣ
Ε.Ε.Ε.Κ. ΝΑΟΥΣΑΣ
ΕΘΕΛΟΝΤΙΚΗ ΟΜΑΔΑ ΚΑΠΑΝΔΡΙΤΙΟΥ
ΕΘΝΙΚΟΝ ΚΑΙ ΚΑΠΟΔΙΣΤΡΙΑΚΟΝ ΠΑΝΕΠΙΣΤΗΜΙΟ
ΕΙΔ. ΕΠΑΓΓ. ΓΥΜΝΑΣΙΟ ΛΥΚΕΙΟ ΚΑΛΑΜΑΤΑΣ
ΕΙΔΙΚΟ ΣΧΟΛΕΙΟ ΓΙΑΝΝΙΤΣΩΝ
ΕΛΑΣ ΤΜΗΜΑ ΟΙΚΟΝΟΜΙΚΟΥ ΕΓΚΛΗΜΑΤΟΣ
ΕΛΛΗΝΙΚΟ ΠΑΙΔΙΚΟ ΜΟΥΣΕΙΟ
ΕΛΛΗΝΙΚΟΣ ΕΡΥΘΡΟΣ ΣΤΑΥΡΟΣ
ΕΠΙΤΡΟΠΗ ΠΡΩΤΟΒΑΘΜΙΑΣ ΕΚΠΑΙΔΕΥΣΗΣ Ν. ΗΜΑΘ
Η ΘΕΟΤΟΚΟΣ ΙΔΡΥΜΑ ΠΡΟΣΤΑΣΙΑΣ
ΗΜΕΡΗΣΙΟ ΓΥΜΝΑΣΙΟ Λ.Τ. ΑΡΝΙΣΣΑΣ
ΙΔΡΥΜΑ ΝΕΟΛΑΙΑΣ ΚΑΙ ΔΙΑ ΒΙΟΥ ΜΑΘΗΣΗ
ΙΕΡΑ ΜΗΤΡΟΠΟΛΙΣ ΠΟΛΥΑΝΗΣ & ΚΙΛΚΙΣ
ΚΕΝΤΡΟ ΥΓΕΙΑΣ ΜΕΣΟΛΟΓΓΙΟΥ
ΚΕΝΤΡΟ ΥΓΕΙΑΣ ΠΑΛΑΜΑ
ΛΙΜΕΝΑΡΧΕΙΟ ΜΥΚΟΝΟΥ
ΛΙΜΕΝΑΡΧΕΙΟ ΣΑΜΟΥ
551 | ANNUAL FINANCIAL REPORT
DONATIONS OF FIXED ASSETS
Name (Names have not been translated into English)
ΛΥΚΕΙΟ ΜΥΓΔΟΝΙΑΣ ΘΕΣΣΑΛΟΝΙΚΗΣ
ΝΗΠΙΑΓΩΓΕΙΟ ΠΑΤΣΙΑΝΟΥ
ΝΗΠΙΑΓΩΓΕΙΟ-ΔΗΜΟΤΙΚΟ ΑΡΜΕΝΙΚΗΣ
ΟΙΚΟΥΜΕΝΙΚΗ ΟΜΟΣΠΟΝΔΙΑ
ΟΦΘΑΛΜΙΑΤΡΕΙΟ ΑΘΗΝΩΝ
Π.Π.Ι. ΚΑΛΛΙΑΝΩΝ - ΠΕΡΙΦ. ΙΑΤΡΕΙΟ
ΠΔ ΠΕΛΟΠ-Δ/ΝΣΗ ΠΡΩΤ/ΘΜΙΑΣ ΕΚΠ.ΜΕΣΣΗ
ΠΕΡΙΦΕΡΕΙΑΚΗ Δ/ΝΣΗ Π.Ε. & Δ.Ε ΑΝ.ΑΤ
ΠΟΛΕΜΙΚΟ ΝΑΥΤΙΚΟ
ΠΟΛΙΤΙΣΤΙΚΟΣ ΣΥΛΛΟΓΟΣ ΚΥΡΙΑΚΟΧΩΡΙΤΩ
ΠΟΛΙΤΙΣΤΙΚΟΣ ΣΥΛΛΟΓΟΣ ΠΥΛΑ
ΠΥΡΟΣΒΕΣΤΙΚΗ ΥΠΗΡΕΣΙΑ ΛΕΧΑΙΝΩΝ
ΣΥΛΛ.ΑΠΟΧΩΡΗΣΑΝΤΩΝ-ΑΠΟΛΥΘΕΝΤΩΝ
ΣΥΛΛΟΓΟΣ ΙΕΡΟΨΑΛΤΩΝ ΑΙΓΙΑΛΕΙΑΣ
ΣΥΛΛΟΓΟΣ ΥΔΑΚΑΛΛΙΕΡΓΗΤΩΝ ΘΕΣΠΡΩΤΙΑΣ
ΣΥΛΛΟΓΟΣ ΦΙΛΩΝ ΒΥΖΑΝΤΙΝΗΣ ΜΟΥΣΙΚΗΣ
ΣΧ ΕΠ Π.Ε. ΔΗΜΟΥ ΑΓ.ΑΝΑΡΓΥΡΩΝ-ΚΑΜΑΤ
ΣΧΟΛ ΕΠ Π.Ε. ΔΗΜΟΥ ΝΙΚΑΙΑΣ-ΑΓ Ι. Ρ
ΣΧΟΛ ΕΠ Π.Ε. ΔΗΜΟΥ ΝΙΚΑΙΑΣ
ΣΧΟΛ ΕΠΙΤΡ Π.Ε. ΔΗΜΟΥ ΖΑΚΥΝΘΟΥ Π.ΧΙ
ΣΧΟΛ ΕΠΙΤΡ Π.Ε. ΔΗΜΟΥ ΚΕΡΑΤΣΙΝΙΟΥ-Δ
ΣΧΟΛ ΕΠΙΤΡ Π.Ε. ΔΗΜΟΥ ΜΟΣΧΑΤΟΥ- ΤΑΥΡΟΥ
ΣΧΟΛ ΕΠΙΤΡ Π.Ε. ΔΗΜΟΥ ΝΑΞΟΥ & ΜΙΚΡΩΝ ΚΥΚΛΑΔΩΝ
ΣΧΟΛ ΕΠΙΤΡ Π.Ε. ΔΗΜΟΥ ΠΕΤΡΟΥΠΟΛΗΣ Ν
ΣΧΟΛ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΑΛΕΞΑΝΔΡΟΥ
ΣΧΟΛ. ΕΠΙΤΡ. ΠΡΩΤΟΒΑΘΜΙΑΣ ΕΚΠ. ΔΗΜ. ΚΑΛΥΜΝΟΥ
ΣΧΟΛ. ΕΠΙΤΡΟΠΗ Δ.Ε. ΔΗΜΟΥ ΕΔΕΣΣΗΣ
ΣΧΟΛ.ΕΠ. Π.Ε. 3ης Δ.ΚΟΙΝ.ΔΗΜ ΑΘΗΝΩΝ
ΣΧΟΛ.ΕΠΙΤΡ.Π.Ε.ΔΗΜΟΥ ΠΑΛΛΗΝΗΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Δ.Ε. ΔΗΜΟΥ ΑΓ.ΒΑΡΒ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Δ.Ε. ΔΗΜΟΥ ΘΕΣΣΑΛΟΝΙΚΗΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Δ.Ε. ΔΗΜΟΥ ΙΛΙΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Δ.Ε. ΔΗΜΟΥ ΚΑΛΑΜΑΤΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ ΔΗΜΟΥ ΞΑΝΘΗΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.E. ΔΗΜΟΥ ΑΘΗΝΑΙΩΝ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε ΔΗΜΟΥ ΗΛΙΔΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. Δ.ΚΑΛΑΜΑΤΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΑΙΓΑΛΕΩ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΑΙΓΙΑΛΕΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΑΛΜΩΠΙΑ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΒΟΛΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΓΛΥΦΑΔΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΕΛΕΥΣΙΝΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΙΛΙΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΚΑΛΑΜΑΡΙΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΚΙΛΚΙΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΚΟΡΥΔΑΛΛΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΛΑΜΙΕΩΝ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΜΕΣΣΗΝΗΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΟΡΧΟΜΕΝΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΠΕΛΛΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΣΑΛΑΜΙΝΑΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΣΑΜΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΣΕΡΡΩΝ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΧΑΙΔΑΡΙΟΥ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ Π.Ε. ΔΗΜΟΥ ΧΑΛΚΙΔΟΣ
ΣΧΟΛΙΚΗ ΕΠΙΤΡΟΠΗ ΠΕ ΔΗΜΟΥ ΒΥΡΩΝΑ
ΤΜΗΜΑ ΑΣΦΑΛΕΙΑΣ ΠΑΓΚΡΑΤΙΟΥ
ΤΟΠΙΚΗ ΚΟΙΝΟΤΗΤΑ ΠΑΥΛΟΥ ΒΟΙΩΤΙΑΣ
ΤΡΙΘΕΣΙΟ ΝΗΠΙΑΓΩΓΕΙΟ ΞΑΝΘΗΣ
ΥΠ.ΕΘΝΙΚΗΣ ΑΜΥΝΗΣ-ΔΙΟΙΚ.ΔΙΟΙΚΗΤΙΚΗΣ
ΥΠ.ΠΡΟΣΤ.ΠΟΛΙΤΗ - ΑΡΧ.ΕΛΛ.ΑΣΤΥΝΟΜΙΑΣ
ΥΠΗΡ.ΠΡΟΣΤΑΣΙΑΣ ΠΡΟΕΔΡΟΥ ΔΗΜΟΚΡΑΤΙΑΣ
ΥΠΟΥΡΓ.ΚΛΙΜ/ΚΗΣ ΚΡΙΣΗΣ & ΠΟΛ.ΠΡΟΣΤ.
ΥΠΟΥΡΓΕΙΟ ΔΗΜΟΣΙΑΣ ΤΑΞΗΣ ΚΑΙ ΠΡΟΣΤΑΣΙΑΣ ΤΟΥ ΠΟΛΙΤΗ
ΥΠΟΥΡΓΕΙΟ ΔΙΚΑΙΟΣΥΝΗΣ
552 | ANNUAL FINANCIAL REPORT
DONATIONS OF FIXED ASSETS
Name (Names have not been translated into English)
ΥΠΟΥΡΓΕΙΟ ΕΘΝΙΚΗΣ ΑΜΥΝΑΣ
ΥΠΟΥΡΓΕΙΟ ΕΘΝΙΚΗΣ ΑΜΥΝΑΣ ΔΙΟΙΚ.Δ.Μ.
ΥΠΟΥΡΓΕΙΟ ΝΑΥΤΙΛΙΑΣ & ΝΗΣΙΩΤΙΚΗΣ ΠΟΛΙΚΗΣ
ΥΠΟΥΡΓΕΙΟ ΠΡΟΣΤΑΣΙΑΣ ΤΟΥ ΠΟΛΙΤΗ
The above table refers to donations of fully amortised fixed assets of the Bank with total residual value € 58.24.
TOTAL FOR MEDIA PAYMENTS
6,445,933.95
TOTAL PAYMENTS DUE TO DONATIONS, SPONSORSHIP, SUBSIDIES OR OTHER CHARITABLE REASONS TO
LEGAL ENTITIES
2,442,741.25
553 | ANNUAL FINANCIAL REPORT
Availability of Annual Financial Report
The Annual Financial Report as at 31.12.2023, which includes:
• The Statement by the Members of Board of Directors
• The Board of Directors’ Annual Management Report
• The Explanatory Report of the Board of Directors
• The Corporate Governance Statement
• The Independent Auditors’ Report
• The Annual Financial Statements of the Company and the Group
are available on the website address: https://www.alphaholdings.gr/en/investor-relations/group-results-and-reporting/financial-
statements-bank-and-group.
The Annual Financial Statements, the Independent Auditors’ report and the Board of Directors’ Report of consolidated companies
are available on the website: https://www.alphaholdings.gr/el/enimerosi-ependuton/oikonomika-stoixeia-omilou/oikonomikes-
katastaseis-thigatrikon-alpha-services-and-holdings?listfilter=C8B2FEC7E58944619BDD360219104002
The Annual Financial Statements of the Company and Group of Alpha Services and Holdings SA, as at 31.12.2023, in XHTML
format, as well as the XBRL file with the appropriate tagging, on the Consolidated Financial Statements are available on the
website: https://www.alphaholdings.gr/en/investor-relations/group-results-and-reporting/financial-statements-bank-and-group.